HomeMy WebLinkAbout06.01 Trails at Santiago Creek Specific Plan EIR
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Environmental Impact Report
Trails at Santiago Creek Specific Plan
City of Orange, Orange County, California
State Clearinghouse No: 2017031020
Prepared for:
City of Orange
Community Development Department, Planning Division
300 East Chapman Avenue, Orange, CA 92866
714.744.7231
Contact: Robert Garcia, Senior Planner
Prepared by:
FirstCarbon Solutions
250 Commerce, Suite 250
Irvine, CA 92602
714.508.4110
Contact: Jason Brandman, Project Director
Charles Holcombe, Project Manager
Date: November 14, 2018
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PREFACE
On March 16, 2017, the City of Orange conducted a Scoping Meeting, in accordance with THE STATE
CEQA GUIDELINES, for the Trails at Santiago Creek Project, (“Project”). The Project described in the
Notice of Preparation (NOP) consisted of approximately 150 residential dwellings configured within
various development plan alternatives. The various land use scenarios were based on the City’s approval
of a Pre-Development Agreement, (“PDA”) on October 11, 2016. The PDA represented several months
of meetings and discussions with community, numerous representatives from Orange Park Acres
Homeowners Association (“OPA”), Mabury Ranch Homeowners Association and The Reserve
Homeowners Association. An essential component of the PDA and working agreement with the
community representatives was the temporary suspension of all backfill and stockpiling operations at
the Sully-Miller sand and gravel operation, effective September 15, 2015. Based on the PDA, the City
obtained input at the Scoping meeting. The most significant concerns expressed by the community at
the Scoping meeting pertained to traffic on East Santiago Canyon Road and Cannon Road; the
preservation of Santiago Creek as a greenway, open space, flooding and elimination of the current sand
and gravel operation.
An extensive 3-year community outreach collaboration effort to address concerns related to traffic on
East Santiago Canyon Road and Cannon Street, the preservation of Santiago Creek as a greenway open
space, flooding, and elimination of the current sand and gravel operation, as well as other matters
related to the Property Owner resulted in the following modifications, reductions, and changes to the
original proposal commitments.
1. The Specific Plan (Appendix Q of the RDEIR) and associated project accommodates a maximum
number of 128 single-family detached lots located in the southerly portion of the property and
will consist of housing types and lot sizes compatible with the surrounding neighborhoods as
depicted in the Trails at Santiago Creek Specific Plan, Exhibits 3.1-3.4 and consistent with the
development standards and guidelines set forth in the Specific Plan.
2. The implementation of the Specific Plan and associated project will fund up to $1,000,000.00 for
traffic improvements to widen East Santiago Canyon Road and restripe Cannon Road prior to the
issuance of the 1st certificate of occupancy of any housing units for the Project. Please refer to
the Trails at Santiago Creek Specific Plan, Exhibit 4.1, Areas of Traffic Congestion—Pre-Project,
Exhibit 4.2, Area of Project Related Traffic Improvements, and Exhibit 4.3, Additional Project
Related Traffic Improvements, and Section 4.2.3, Circulation Plan.
3. The implementation of the Specific Plan and associated project will fund approximately up to a
maximum of $4,100,000.00 in landscape and other improvements for the Santiago Creek
Greenway. Said Improvements are to be completed or funded prior to the issuance of the 60th
Certificate of Occupancy for the Project. Please refer to the Trails at Santiago Creek Specific Plan,
Section 4.2.4, Trails, Open Space and Recreation Plan, and Exhibit 4.14, Preliminary Greenway,
Open Space and Trails Plan.
4. The implementation of the Specific Plan and associated project will fund $1,000,000.00 to be
used for in local area-wide equestrian trail purposes prior to the issuance of the first Certificate of
Occupancy for the Project.
5. The implementation of the Specific Plan and associated project will finance and fund the City’s
acquisition of the Ridgeline Property consisting of which will provide the community an
additional approximately fifty (50) acres of public open space to the issuance of the first
Certificate of Occupancy for the Project. Please refer to the Trails at Santiago Creek Specific Plan,
Exhibit 4.4, Sully Miller, Arena and Ridgeline Properties.
6. The implementation of the Specific Plan and associated project will provide $2,000,000.00 for
equestrian and recreational purposes in the East Orange Area as determined by the City prior to
the issuance of the first Certificate of Occupancy for the Project.
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Table of Contents
Acronyms and Abbreviations ..................................................................................................... xxix
Executive Summary ................................................................................................................... ES-1
Purpose ................................................................................................................................. ES-1
Project Summary .................................................................................................................. ES-2
Significant Unavoidable Adverse Impacts ............................................................................ ES-7
Summary of Project Alternatives .......................................................................................... ES-8
Areas of Controversy ............................................................................................................ ES-9
Public Review of the RDEIR ................................................................................................ ES-11
Executive Summary Matrix ................................................................................................. ES-1 2
Section 1: Introduction ............................................................................................................... 1-1
1.2 - Scope of the EIR ............................................................................................................ 1-10
1.3 - Organization of the RDEIR ............................................................................................ 1-15
1.4 - Documents Incorporated by Reference ........................................................................ 1-17
1.5 - Documents Prepared for the Project ........................................................................... 1-17
1.6 - Review of the RDEIR ..................................................................................................... 1-18
Section 2: Project Description ..................................................................................................... 2-1
2.1 - Project Location and Setting........................................................................................... 2 -1
2.2 - Project History .............................................................................................................. 2-33
2.3 - Project Characteristics .................................................................................................. 2-36
2.4 - Project Objectives ......................................................................................................... 2-64
2.5 - Intended Uses of this Draft EIR..................................................................................... 2-65
Section 3: Environmental Impact Analysis ................................................................................... 3-1
Organization of Issue Areas .................................................................................................... 3-1
Issues Addressed in this EIR ................................................................................................... 3-1
Level of Significance ............................................................................................................... 3-1
Impact Analysis and Mitigation Measure Format .................................................................. 3-1
Comparative Analysis of Scenarios ......................................................................................... 3-3
3.1 - Aesthetics, Light, and Glare ......................................................................................... 3.1-1
3.2 - Agriculture Resources and Forest Resources .............................................................. 3.2-1
3.3 - Air Quality .................................................................................................................... 3.3-1
3.4 - Biological Resources .................................................................................................... 3.4-1
3.5 - Cultural Resources ....................................................................................................... 3.5-1
3.6 - Geology and Soils ........................................................................................................ 3.6-1
3.7 - Greenhouse Gas Emissions ......................................................................................... 3.7-1
3.8 - Hazards and Hazardous Materials ............................................................................... 3.8-1
3.9 - Hydrology and Water Quality ...................................................................................... 3.9-1
3.10 - Land Use and Planning ............................................................................................ 3.10-1
3.11 - Mineral Resources ................................................................................................... 3.11-1
3.12 - Noise ........................................................................................................................ 3.12-1
3.13 - Population and Housing .......................................................................................... 3.13-1
3.14 - Public Services ......................................................................................................... 3.14-1
3.15 - Recreation ............................................................................................................... 3.15-1
3.16 - Transportation and Traffic ....................................................................................... 3.16-1
3.17 - Tribal Cultural Resources ......................................................................................... 3.17 -1
3.18 - Utilities and Service Systems ................................................................................... 3.18-1
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Section 4: Cumulative Effects ...................................................................................................... 4-1
4.1 - Introduction ................................................................................................................... 4-1
4.2 - Cumulative Impact Analysis ........................................................................................... 4-2
Section 5: Alternatives to the Proposed Project ........................................................................... 5-1
5.1 - Introduction ................................................................................................................... 5-1
5.2 - Project Objectives .......................................................................................................... 5-4
5.3 - Alternative 1—Development within the Existing Land Use Designations ..................... 5-4
5.4 - Alternative 2—No Project Alternative/Existing Land Use Activities Alternative ......... 5-17
5.5 - Alternative 3—Collaborative Group ............................................................................. 5-22
5.6 - Alternative 4—122-Unit ............................................................................................... 5-28
5.7 - Environmentally Superior Alternative .......................................................................... 5-33
Section 6: Other CEQA Considerations ......................................................................................... 6-1
6.1 - Significant Unavoidable Impacts .................................................................................... 6-1
6.2 - Growth-Inducing Impacts .............................................................................................. 6-2
6.3 - Significant Irreversible Changes ..................................................................................... 6-3
6.4 - Energy Conservation ...................................................................................................... 6-4
Section 7: Effects Found Not To Be Significant ............................................................................. 7-1
7.1 - Introduction ................................................................................................................... 7-1
7.2 - Effects Found Not To Be Significant ............................................................................... 7-1
Section 8: Persons and Organizations Consulted/List of Preparers ............................................... 8-1
8.1 - Persons and Organizations Consulted ............................................................................ 8-1
8.2 - List of Preparers ............................................................................................................. 8-1
Section 9: References .................................................................................................................. 9-1
List of Appendices
Appendix A: Pre-development Agreement
Appendix B: Draft EIR Notice of Availability (NOA) and Comment Letters
B.1 - NOA
B.2 - Public Agency Comment Letters
B.3 - Private Party Comment Letters
Appendix C: Notice of Preparation (NOP) and Comment Letters
C.1 - Notice of Preparation (NOP)
C.2 - Notice of Preparation (NOP) Comment Letters
C.3 - Scoping Meeting Sign-In Sheets
C.4 - Scoping Meeting Comments
Appendix D: Orange Park Acres Association Fieldstone Letter
Appendix E: Santiago Creek Greenway Alliance Letter
Appendix F: Air Quality and Greenhouse Gas Supporting Information
Appendix G: Biological Resources Supporting Information
G.1 - Biological Resource Assessment
G.2 - Jurisdictional Delineation
G.3 - Tree Survey
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Appendix H: Cultural Resources Assessment
H.1 - Phase I Cultural Resources Assessment and Paleontological Records Review
H.2 - Addendum to a Phase I Cultural Resources Assessment and Paleontological Records
Review
H.3 - Updated Native American Consultation for the Rio Santiago Specific Plan
Appendix I: Geotechnical Investigation
Appendix J: Phase I and Phase II Environmental Site Assessments
J.1 - Phase I Environmental Site Assessments
J.2 - Phase II Environmental Site Assessments
Appendix K: Hydrology and Water Quality Reports
K.1 - Preliminary Hydrology and Hydraulic Report
K.2 - Preliminary Water Quality Management Plan (PWQMP)
Appendix L: Land Use Background
L.1 - Broadmoor Homes
L.2 - Leadership Housing Specific Plan (Pheasant Run)
L.3 - Pacesetter Homes (The Wilderness)
Appendix M: City of Orange SMARA Memo
Appendix N: Noise Analysis
Appendix O: Public Services Supporting Information
Appendix P: Traffic Impact Analysis
List of Tables
Table ES-1: Trails at Santiago Creek Specific Plan Residential Lots .................................................... ES-2
Table ES-2: Executive Summary Matrix ........................................................................................... ES-13
Table 1-1: DEIR Comment Letters ........................................................................................................ 1-1
Table 1-2: RDEIR Revision Summary Table, Public Agencies ............................................................... 1-7
Table 1-3: RDEIR Revision Summary Table, Private Parties ................................................................. 1-7
Table 1-4: NOP Comment Letters ...................................................................................................... 1-10
Table 1-5: Scoping Meeting Attendees .............................................................................................. 1-13
Table 2-1: Project Land Use Summary ............................................................................................... 2-39
Table 2-2: City of Orange Zoning Code Development Standards ...................................................... 2-40
Table 2-3: Trails at Santiago Creek Specific Plan Residential Lot Sizes and Applicable
Zoning ............................................................................................................................ 2-49
Table 2-4: Comparison to Prior Development Proposals .................................................................. 2-63
Table 3.3-1: Air Quality Monitoring Summary .................................................................................. 3.3-3
Table 3.3-2: SoCAB Attainment Status .............................................................................................. 3.3-4
Table 3.3-3: Description of Air Pollutants ......................................................................................... 3.3-8
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Table 3.3-4: SCAQMD Regional Significance Thresholds ................................................................ 3.3-21
Table 3.3-5: Exposure Assumptions for Cancer Risk—Updated OEHHA Guidance ........................ 3.3-24
Table 3.3-6: Conceptual Construction Schedule ............................................................................ 3.3-35
Table 3.3-7: Construction Equipment Assumptions ....................................................................... 3.3-35
Table 3.3-8: Construction Maximum Daily Regional Emissions—Unmitigated .............................. 3.3-36
Table 3.3-9: Construction Maximum Daily Regional Emissions—Mitigated .................................. 3.3-37
Table 3.3-10: Maximum Daily Regional Operational-related Emissions—Unmitigated................. 3.3-38
Table 3.3-11: Construction Equipment Summary .......................................................................... 3.3-41
Table 3.3-12: Maximum Daily Disturbed Acreage .......................................................................... 3.3-41
Table 3.3-13: Construction Localized Significance Analysis—Unmitigated .................................... 3.3-42
Table 3.3-14: Construction Localized Significance Analysis—Mitigated ........................................ 3.3-43
Table 3.3-15: Operational Localized Significance Analysis—Unmitigated ..................................... 3.3-44
Table 3.3-16: Project PM10 Construction Emissions—Unmitigated and Tier IV Final
Mitigation ................................................................................................................... 3.3-46
Table 3.3-17: Estimated Health Risks and Hazards: Project Construction—Unmitigated .............. 3.3-46
Table 3.3-18: Estimated Health Risks and Hazards: Project Construction-with Tier IV Final
Mitigation ................................................................................................................... 3.3-47
Table 3.4-1: Natural Community Summary ...................................................................................... 3 .4-1
Table 3.4-2: Jurisdictional Feature Summary ................................................................................. 3.4-19
Table 3.4-3: Impacts to Natural Communities ............................................................................... 3.4 -48
Table 3.5-1: Previously Recorded Cultural Resources .................................................................... 3.5-12
Table 3.6-1: Soil Summary ................................................................................................................ 3.6-4
Table 3.7-1: Description of Select GHGs .......................................................................................... 3.7-5
Table 3.7-2: Construction GHG Emissions—Unmitigated .............................................................. 3.7-20
Table 3.7-3: Operational GHG Emissions—Unmitigated ................................................................ 3.7-21
Table 3.7-4: Scoping Plan Reduction Measures Consistency Analysis ........................................... 3.7-22
Table 3.8-1: Previous Phase I/II Environmental Site Assessment Findings ...................................... 3.8-2
Table 3.8-2: GeoTracker Search Results Summary ........................................................................... 3.8-4
Table 3.8-3: Indoor Radon Testing Summary ................................................................................... 3 .8-6
Table 3.9-1: Orange Meteorological Summary ................................................................................ 3.9-1
Table 3.9-2: Expected Pollutants of Concern ................................................................................... 3.9-2
Table 3.9-3: Impaired Water Body Summary ................................................................................... 3.9-3
Table 3.9-4: Santiago Creek Field Screening Data ............................................................................ 3 .9-4
Table 3.9-5: Santiago Creek Channel Monitoring Data .................................................................... 3.9-4
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Table 3.9-6: Existing and Proposed Discharge Rates—Proposed Storm Drainage System ............. 3.9-24
Table 3.9-7: Existing and Proposed Discharge Rates—Handy Creek Storm Drainage .................... 3.9-24
Table 3.10-1: Surrounding Land Use Designations ......................................................................... 3.10-4
Table 3.10-2: General Plan Consistency Analysis .......................................................................... 3.10 -12
Table 3.10-3: East Orange General Plan Consistency Analysis ..................................................... 3.10-24
Table 3.10-4: OPA Plan Consistency Analysis ................................................................................ 3.10-26
Table 3.10-5: City of Orange Zoning Code R-1-8 and R-1-10 Development Standards ................ 3.10-29
Table 3.10-6: Residential Lot Sizes and Applicable Zoning ........................................................... 3.10-29
Table 3.12-1: Typical A-Weighted Noise Levels .............................................................................. 3.12-1
Table 3.12-2: Typical Construction Equipment Maximum Noise Levels, Lmax ................................. 3.12-4
Table 3.12-3: Vibration Levels of Construction Equipment ............................................................ 3.12-6
Table 3.12-4: Existing Traffic Noise Levels Along Modeled Roadways ............................................ 3.12-8
Table 3.12-5: Summary of EPA Recommended Noise Levels to Protect Public Welfare ................ 3.12-8
Table 3.12-6: Construction Vibration Impact Criteria ................................................................... 3.12-11
Table 3.12-7: Maximum Allowable Noise Exposure—Transportation Sources ............................ 3.12-13
Table 3.12-8: Maximum Allowable Noise Exposure—Stationary Noise Sources .......................... 3.12-14
Table 3.12-9: City of Orange Municipal Code Exterior Noise Standards ...................................... 3.12-15
Table 3.12-10: City of Orange Municipal Code Interior Noise Standards ..................................... 3.12-16
Table 3.12-11: SoundPlan Model Roadway Parameters ............................................................... 3.12-18
Table 3.12-12: Roadway Noise Impacts to Nearby Sensitive Receptors—Existing
Conditions ................................................................................................................. 3.12-33
Table 3.12-13: Roadway Noise Impacts to Nearby Sensitive Receptors—Year 2022
Conditions ................................................................................................................. 3.12-34
Table 3.12-14: Roadway Noise Impacts to Nearby Sensitive Receptors—Year 2040
Conditions ................................................................................................................. 3.12-35
Table 3.13-1: City of Orange Population and Housing Summary (2016) ........................................ 3.13-1
Table 3.13-2: Population Growth (1970–2015) .............................................................................. 3.13-1
Table 3.13-3: Population Growth .................................................................................................... 3.13-3
Table 3.14-1: Fire Station Summary ............................................................................................... 3.14-1
Table 3.14-2: Orange Unified School District Facilities ................................................................... 3.1 4-3
Table 3.16-1: Study Facilities Summary .......................................................................................... 3.16-2
Table 3.16-2: Level of Service Criteria for Signalized Intersections ................................................ 3.16-8
Table 3.16-3: Roadway Link Capacities ......................................................................................... 3.16-13
Table 3.16-4: Existing and With Trip Credit Existing Peak-Hour Intersection Capacity
Analysis ..................................................................................................................... 3.16-14
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Table 3.16-5: Existing and With Trip Credit Existing Roadway Segment Level of Service
Summary .................................................................................................................. 3.16 -16
Table 3.16-6: Project Traffic Generation Forecast (Without Sand and Gravel Credit) ................. 3.16-21
Table 3.16-7: Project Traffic Generation Forecast (With Sand and Gravel Credit) ....................... 3.16-22
Table 3.16-8: Location and Description of Cumulative Projects .................................................. 3.16-24
Table 3.16-9: Cumulative Projects Traffic Generation Forecast ................................................... 3.16-53
Table 3.16-10: With Trip Credit Existing Peak-Hour Intersection Capacity Analysis .................... 3.16-80
Table 3.16-11: Existing With Project Peak-Hour Intersection Capacity Analysis (Without
Sand and Gravel Credit) ............................................................................................ 3.16-84
Table 3.16-12: With Trip Credit Existing With Project Peak-Hour Intersection Capacity
Analysis (With Sand and Gravel Credit) .................................................................... 3.16-86
Table 3.16-13: With Trip Credit Existing Roadway Segment Level of Service Summary .............. 3.16-87
Table 3.16-14: Existing With Project Roadway Segment Level of Service Summary
(Without Sand and Gravel Credit) ............................................................................ 3.16-89
Table 3.16-15: With Trip Credit Existing With Project Roadway Segment Level of Service
Summary (With Sand and Gravel Credit).................................................................. 3.16-91
Table 3.16-16: Year 2022 Peak-Hour Intersection Capacity Analysis (Without Sand and
Gravel Credit) ............................................................................................................ 3.1 6-97
Table 3.16-17: Year 2022 Peak-Hour Intersection Capacity Analysis (With Sand and Gravel
Credit) ....................................................................................................................... 3.16-99
Table 3.16-18: Year 2022 Roadway Segment Level of Service Summary (Without Sand
and Gravel Credit) ................................................................................................... 3.16-100
Table 3.16-19: Year 2022 Roadway Segment Level of Service Summary (With Sand and
Gravel Credit) .......................................................................................................... 3.16-102
Table 3.16-20: Year 2022 Project Fair Share Contribution ......................................................... 3.16-104
Table 3.16-21: Year 2040 Buildout Peak-Hour Intersection Capacity Analysis (Without
Sand and Gravel) .................................................................................................... 3.16-113
Table 3.16-22: Year 2040 Buildout Peak-Hour Intersection Capacity Analysis (With Sand
and Gravel) ............................................................................................................. 3.16-115
Table 3.16-23: Year 2040 Buildout Roadway Segment Level of Service Summary (Without
Sand and Gravel Credit) .......................................................................................... 3.16-116
Table 3.16-24: Year 2040 Buildout Roadway Segment Level of Service Summary (With
Sand and Gravel Credit) .......................................................................................... 3.16-118
Table 3.16-25: Project Driveway Peak-Hour Levels of Service Summary ................................... 3.16-121
Table 3.18-1: Actual Water Supply (2015) ..................................................................................... 3.18-2
Table 3.18-2: Long-Term Water Supply Projections ....................................................................... 3.18-3
Table 3.18-3: Landfill Summary ...................................................................................................... 3.18-5
Table 3.18-4: Estimated Water Demand ........................................................................................ 3 .18-9
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Table 3.18-5: Estimated Wastewater Generation ......................................................................... 3.18-10
Table 3.18-6: Estimated Construction Waste Generation ............................................................ 3.18-12
Table 3.18-7: Estimated Operational Waste Generation .............................................................. 3.18-13
Table 3.18-8: Energy Consumption Estimate ................................................................................ 3.18 -14
Table 4-1: Cumulative Projects ............................................................................................................ 4-1
Table 5-1: Development within the Existing Land Use Designations Alternative Summary ............. 5-11
Table 5-2: Development within the Existing Land Use Designations Alternative Trip
Generation Comparison ................................................................................................. 5-16
Table 5-3: No Project Alternative/Existing Land Use Activities Alternative Trip Generation
Comparison .................................................................................................................... 5-21
Table 5-4: Collaborative Group Alternative Summary ....................................................................... 5-23
Table 5-5: Collaborative Group Alternative Trip Generation Comparison ......................................... 5-27
Table 5-6: 122-Unit Alternative Residential Lot Sizes ........................................................................ 5-28
Table 5-7: 122-Unit Alternative Summary ......................................................................................... 5-29
Table 5-8: 122-Unit Alternative Trip Generation Comparison ........................................................... 5-32
Table 5-9: Summary of Alternatives .................................................................................................. 5-34
Table 6-1: Population Growth .............................................................................................................. 6-2
Table 6-2: Transportation Fuel Consumption ...................................................................................... 6-6
List of Exhibits
Exhibit 2-1: Regional Location Map ..................................................................................................... 2-3
Exhibit 2-2: Local Vicinity Map, Aerial Base ......................................................................................... 2-5
Exhibit 2-3: Assessor Parcel Map ......................................................................................................... 2-7
Exhibit 2-4: Site Photographs .............................................................................................................. 2-9
Exhibit 2-5: Surrounding Properties with Lots Sizes under 10,000 sq. ft. ......................................... 2-13
Exhibit 2-5a: West of Cannon Community Lot Sizes .......................................................................... 2-1 5
Exhibit 2-5b: Creekside Ranch and The Colony North Lot Sizes ........................................................ 2-17
Exhibit 2-5c: Mabury Ranch 1 Lot Sizes ............................................................................................. 2-19
Exhibit 2-5d: Mabury Ranch 2 Lot Sizes ............................................................................................ 2-21
Exhibit 2-5e: Mabury Ranch 3 Lot Sizes ............................................................................................. 2-23
Exhibit 2-5f: The Reserve Lot Sizes .................................................................................................... 2-25
Exhibit 2-5g: Orange Park Acres Lot Sizes .......................................................................................... 2-27
Exhibit 2-6: City of Orange General Plan Land Use............................................................................ 2 -29
Exhibit 2-7: City of Orange Zoning ..................................................................................................... 2-31
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Exhibit 2-8a: Pre-Development Agreement Alternatives A-D ........................................................... 2-41
Exhibit 2-8b: Pre-Development Agreement Alternatives E–F ........................................................... 2-43
Exhibit 2-9: Proposed Land Use Plan ................................................................................................ 2-45
Exhibit 2-10: Proposed Site Plan ....................................................................................................... 2-47
Exhibit 2-11: Preliminary Greenway, Open Space and Trails Plan ..................................................... 2-53
Exhibit 2-12a: Existing Circulation ..................................................................................................... 2-57
Exhibit 2-12b: Proposed Circulation .................................................................................................. 2-59
Exhibit 3.1-1: Surrounding Land Uses .............................................................................................. 3.1-3
Exhibit 3.2-1: Land Use Classification Map ...................................................................................... 3.2-3
Exhibit 3.4-1: Natural Communities ................................................................................................. 3.4-3
Exhibit 3.4-2: Sensitive Natural Communities .................................................................................. 3.4-9
Exhibit 3.4-3: Special-Status Plant Species ..................................................................................... 3.4-13
Exhibit 3.4-4: Special-Status Wildlife Species ................................................................................ 3.4-17
Exhibit 3.4-5: Jurisdictional Features ............................................................................................. 3.4-21
Exhibit 3.4-6: Orange County Natural Community Conservation Plan/Habitat
Conservation Plan ....................................................................................................... 3.4-3 1
Exhibit 3.4-7: Impacts to Special-Status Plant Species ................................................................... 3.4-35
Exhibit 3.4-8: Impacts to Special-Status Wildlife Species............................................................... 3.4-41
Exhibit 3.4-9: Impacts to Sensitive Natural Communities .............................................................. 3.4-53
Exhibit 3.4-10: Impacts to Jurisdictional Features ......................................................................... 3.4-55
Exhibit 3.4-11: Impacts to Regulated Trees .................................................................................... 3.4-59
Exhibit 3.5-1: Archaeological and Paleontological Monitoring Areas ............................................ 3.5-17
Exhibit 3.9-1: Santiago Creek Watershed ......................................................................................... 3.9-5
Exhibit 3.9-2: Santa Ana River Watershed ....................................................................................... 3.9-7
Exhibit 3.9-3: Existing Drainage Patterns ....................................................................................... 3.9-11
Exhibit 3.9-4: 100-Year Flood Hazard Areas ................................................................................... 3.9-13
Exhibit 3.10-1: East Orange General Plan ...................................................................................... 3.10-5
Exhibit 3.10-2: Orange Park Acres Plan .......................................................................................... 3.10-7
Exhibit 3.12-1: Existing Noise Contour Map (dBA CNEL) ............................................................... 3.12-9
Exhibit 3.12-2: Existing with Project Noise Contour Map (dBA CNEL) ......................................... 3.12-23
Exhibit 3.12-3: Year 2022 Baseline Noise Contour Map (dBA CNEL) ........................................... 3.12-25
Exhibit 3.12-4: Year 2022 with Project Noise Contour Map (dBA CNEL) ..................................... 3.12-27
Exhibit 3.12-5: Year 2040 Baseline Contour Map (dBA CNEL) ..................................................... 3.12-29
Exhibit 3.12-6: Year 2040 with Project Contour Map (dBA CNEL) ............................................... 3.12-31
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Exhibit 3.12-7: Year 2040 with Project Sound Walls/Berms Noise Contour Map (dBA
CNEL) ......................................................................................................................... 3.12-41
Exhibit 3.16-1: Roadway Network .................................................................................................. 3.16-3
Exhibit 3.16-2: Existing Roadway Conditions and Intersection Controls ........................................ 3.16-5
Exhibit 3.16-3: Existing AM Peak Hour Traffic Volumes .................................................................. 3.16-9
Exhibit 3.16-4: Existing PM Peak Hour and Daily Traffic Volumes ................................................ 3.16-11
Exhibit 3.16-5: Project Trip Distribution Pattern .......................................................................... 3.16-25
Exhibit 3.16-6A: AM Peak Hour Project Traffic Volumes (Without Sand and Gravel Credit) ........ 3.16-27
Exhibit 3.16-6B AM Peak Hour Project Traffic Volumes (With Sand & Gravel Credit) .................. 3.16-29
Exhibit 3.16-7A: PM Peak Hour Project Traffic Volumes (Without Sand and Gravel Credit) ........ 3.16-31
Exhibit 3.16-7B: PM Peak Hour Project Traffic Volumes (With Sand & Gravel Credit) ................. 3.16-33
Exhibit 3.16-8: With Trip Credit Existing AM Peak Hour Traffic Volumes ..................................... 3.16-35
Exhibit 3.16-9: With Trip Credit Existing PM Peak Hour and Daily Traffic Volumes ..................... 3.16-37
Exhibit 3.16-10A: Existing With Project AM Peak Hour Traffic Volume (Without Sand and
Gravel Credit) ............................................................................................................ 3.1 6-39
Exhibit 3.16-10B: Existing With Project AM Peak Hour Traffic Volume (With Sand &
Gravel Credit) ............................................................................................................ 3.1 6-41
Exhibit 3.16-11A: Existing With Project PM Peak Hour and Daily Traffic Volume (Without
Sand and Gravel Credit) ............................................................................................ 3.16-43
Exhibit 3.16.11B: Existing With Project PM Peak Hour and Daily Traffic Volume (With
Sand & Gravel Credit) ................................................................................................ 3.16-45
Exhibit 3.16-12: Cumulative Project Location Map ...................................................................... 3.16-47
Exhibit 3.16-13: AM Peak Hour Cumulative Projects Traffic Volumes .......................................... 3.16-49
Exhibit 3.16-14: PM Peak Hour and Daily Cumulative Projects Traffic Volumes .......................... 3.16-51
Exhibit 3.16-15A:Year 2022 Without Project AM Peak Hour Traffic Volumes (Without
Sand and Gravel Credit) ............................................................................................ 3.16-55
Exhibit 3.16-15B: Year 2022 Without Project AM Peak Hour Traffic Volumes (With Sand &
Gravel Credit) ............................................................................................................ 3.1 6-57
Exhibit 3.16-16A: Year 2022 Without Project PM Peak Hour and Daily Traffic Volumes
(Without Sand and Gravel Credit) ............................................................................. 3.16-59
Exhibit 3.16-16B: Year 2022 Without Project PM Peak Hour and Daily Traffic Volumes
(With Sand & Gravel Credit) ...................................................................................... 3.16-61
Exhibit 3.16-17A: Year 2022 With Project AM Peak Hour Traffic Volumes (Without Sand
and Gravel Credit) ..................................................................................................... 3.16-63
Exhibit 3.16-17B: Year 2022 With Project AM Peak Hour Traffic Volumes (With Sand &
Gravel Credit) ............................................................................................................ 3.1 6-65
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Exhibit 3.16-18A: Year 2022 With Project PM Peak Hour and Daily Traffic Volumes
(Without Sand and Gravel Credit) ............................................................................ 3.16-67
Exhibit 3.16-18B: Year 2022 with Project PM Peak Hour and Daily Traffic Volumes (With
Sand & Gravel Credit) ............................................................................................... 3.16-69
Exhibit 3.16-19A: Year 2040 Buildout With Project AM Peak Hour Traffic Volumes
(Without Sand and Gravel Credit) ............................................................................ 3.16-71
Exhibit 3.16-19B: Year 2040 Buildout With Project AM Peak Hour Traffic Volumes (With
Sand & Gravel Credit) ............................................................................................... 3.16-73
Exhibit 3.16-20A: Year 2040 Buildout With Project PM Peak Hour and Daily Traffic
Volumes (Without Sand and Gravel Credit) ............................................................. 3.16-75
Exhibit 3.16-20B: Year 2040 Buildout With Project PM Peak Hour and Daily Traffic
Volumes (With Sand & Gravel Credit) ...................................................................... 3.16-77
Exhibit 3.16-21: Year 2022 Planned and Recommended Improvements .................................. 3.16-105
Exhibit 3.16-22: Year 2040 Planned Improvements ................................................................... 3.16-109
Exhibit 5-1: Development within the Existing Land Use Designations Alternative ............................. 5-5
Exhibit 5-2: Collaborative Group Alternative ...................................................................................... 5-7
Exhibit 5-3: 122-Unit Alternative ........................................................................................................ 5-9
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ACRONYMS AND ABBREVIATIONS
µg/m3 micrograms per cubic meter
AAQS Ambient Air Quality Standards
AB Assembly Bill
ACHP Advisory Council on Historic Preservation
ACM asbestos-containing material
ADA Americans with Disabilities Act
ADT average daily traffic
af acre-foot
AFY acre-feet per year
AIC Archaeological Information Center
APE Area of Potential Effect
APN Assessor’s Parcel Number
ARB California Air Resources Board
AST aboveground storage tank
ATCM Airborne Toxic Control Measures
BMP Best Management Practice
BVOC biogenic volatile organic compound
C Celsius
CAAQS California Ambient Air Quality Standards
Cal OSHA California Occupational Health and Safety Administration
Cal/EPA California Environmental Protection Agency
CalFIRE California Department of Forestry and Fire Protection
Caltrans California Department of Transportation
CAP Clean Air Plan
CCR California Code of Regulations
CDFW California Department of Fish and Wildlife
CEQA California Environmental Quality Act
CESA California Endangered Species Act
CFC chlorofluorocarbon
CFR Code of Federal Regulations
CH4 methane
CHL California Historical Landmarks
CMP Congestion Management Plan
CNDDB California Natural Diversity Database
CNEL Community Noise Equivalent Level
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CNPS California Native Plant Society
CO carbon monoxide
CO2e carbon dioxide equivalent
CPHI California Points of Historical Interest
CPUC California Public Utilities Code
dB decibel
DOT United States Department of Transportation
DPM diesel particulate matter
DTSC California Department of Toxic Substances Control
EIR Environmental Impact Report
EMS Emergency Medical Services
EPA United States Environmental Protection Agency
ESA Endangered Species Act
F Fahrenheit
FCS FirstCarbon Solutions
FEMA Federal Emergency Management Agency
FESA Federal Endangered Species Act
FHWA Federal Highway Administration
FIRM Flood Insurance Rate Map
GWh/y gigawatt-hours per year
GWP global warming potential
HCM Highway Capacity Manual
HFC hydrofluorocarbon
HRI California Historic Resources Inventory
I Interstate
ISA International Society of Arboriculture
Ldn day/night average sound level
Leq equivalent sound level
LOS Level of Service
LUST leaking underground storage tank
MBTA Migratory Bird Treaty Act
Metropolitan Metropolitan Water District of Southern California
mgd million gallons per day
MMI Modified Mercalli Intensity
mph miles per hour
MRZ Mineral Resource Zone
MTS Metropolitan Transportation System
MWDOC Municipal Water District of Orange County
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N2O nitrous oxide
NAAQS National Ambient Air Quality Standards
NCCP/HCP Natural Community Conservation Plan/Habitat Conservation Plan
NESHAP National Emissions Standards for Hazardous Air Pollutants
NHPA National Historic Preservation Act
NO2 nitrogen dioxide
NOC Notice of Completion
NOP Notice of Preparation
NOx nitrogen oxides
NPDES National Pollutant Discharge Elimination System
NRCS Natural Resources Conservation Service
NRHP National Register of Historic Places
O3 ozone
OC Orange County
OCSD Orange County Sanitation District
OCWD Orange County Water District
OEHHA California Office of Environmental Health Hazard Assessment
OUSD Orange Unified School District
PCB polychlorinated biphenyl
pCi/l picocuries per liter
PFC perfluorocarbon
Phase I ESA Phase I Environmental Site Assessment
Phase II ESA Phase II Environmental Site Assessment
PMx particulate matter
ppb parts per billion
ppm parts per million
PPV peak particle velocity
PVC polyvinyl chloride
RMP Risk Management Plan
ROG reactive organic gas
RWQCB Regional Water Quality Control Board
SCAQMD South Coast Air Quality Management District
SCE Southern California Edison
SF6 sulfur hexafluoride
SMARA Surface Mining and Reclamation Act
SO2 sulfur dioxide
SoCalGas Southern California Gas Company
SR State Route
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SWPPP Stormwater Pollution Prevention Plan
SWRCB State Water Resources Control Board
TAC toxic air contaminants
TCE trichloroethylene
TCM transportation control measures
TDS total dissolved solids
Tg teragram
therms/y therms per year
TMDL Total Maximum Daily Load
TPH Total Petroleum Hydrocarbons
USACE United States Army Corps of Engineers
USFWS United States Fish and Wildlife Service
USGS United States Geological Survey
UST underground storage tank
UWMP Urban Water Management Plan
V/C volume-to-capacity ratio
WDR Waste Discharge Requirements
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EXECUTIVE SUMMARY
Purpose
On February 23, 2018, the City of Orange circulated a Draft Environmental Impact Report (Draft EIR)
evaluating the Trails at Santiago Creek Specific Plan for public review. Various comments were
submitted during the public review period, February 23, 2018 to April 9, 2018. After review of the
comments, the City of Orange elected to revise and recirculate the Draft EIR in its entirety.
The California Environmental Quality Act (CEQA) Guidelines generally require a lead agency to
evaluate and prepare a written response to all comments on environmental issues received on the
Draft EIR. (Guidelines, § 15088(a), (d).) Such a response may take the form of a revision to the Draft
EIR. (Guidelines, § 15088(d).) When a Draft EIR is substantially revised and the entire document is
recirculated, however, the lead agency only needs to respond to comments on the Recirculated Draft
EIR (RDEIR), not those received during the earlier circulation period. (Guidelines, § 15088.5 (f)(1).)
Instead, the agency need only provide a summary of the revisions that were made to the previously
circulated Draft EIR. (Guidelines, § 15088.5 (g).)
Given that revisions will be made to multiple sections of the RDEIR, the City is recirculating the entire
document. Doing so will avoid the need to respond to comments received during the previous
circulation period. The RDEIR will include a summary, in table format, of the revisions made to the
previously circulated Draft EIR. The RDEIR will also advise reviewers that although prior comments
received are part of the administrative record, they do not require a written response in the final EIR,
and that new comments must be submitted for the revised DEIR. (Guidelines, § 15088.5 (f)(1).)
This RDEIR has been prepared in accordance with CEQA to evaluate the potential environmental
impacts associated with the implementation of the Trails at Santiago Creek Specific Plan (State
Clearinghouse No. 2017031020). This document is prepared in conformance with CEQA (California
Public Resources Code, Section 21000, et seq.) and the State CEQA Guidelines (California Code of
Regulations, Title 14, Section 15000, et seq.), and City of Orange rules and regulations.
This RDEIR is intended to serve as an informational document for the public agency decision-makers
and the public regarding the objectives and components of the project. This document will address
the potentially significant adverse impacts related to construction and long-term operation of the
project, as well as identify feasible mitigation measures and alternatives that may be adopted to
reduce or eliminate these impacts.
Section 1, Introduction, of this RDEIR, provides further information regarding comments received on
the previously circulated Draft EIR and the process by which this RDEIR is being prepared.
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Project Summary
Project Location
The project is located within the City of Orange, in north-central Orange County. The site is generally
located to the east of State Route 55; to the west of State Route 261; approximately 2 miles to the
north of Chapman Avenue; on the north side of East Santiago Canyon Road, between Orange Park
Boulevard on the east and Cannon Street on the west; and south of Mabury Avenue. The site
address is 6118 East Santiago Canyon Road (see Exhibit 2-1 and Exhibit 2-2). The project site is
located on the Orange, California 7.5-minute quadrangle, Township 4 South, Range 9 West, Section
23 (Latitude 33° 48’55” North; Longitude 117° 47’17” West).
Project Description
The Trails at Santiago Creek Specific Plan (Appendix Q) proposes the transformation of a rock and
concrete materials recycling and backfilling operation to an environmentally enhanced, ecologically
friendly open space environment embracing a well-planned and attractive single-family detached
residential neighborhood.
Previously, the project included 129 units on 8,000-square-foot lots. In contrast, and in response to
input provided to the applicant during a series of meetings with the Collaborative Group, the RDEIR
evaluates the development of 128 dwellings on approximately 40.7 acres of the approximately
109.2-acre site, with varying lots sizes including lots larger than 8,000 square feet. Table ES-1
summarizes the residential lots included in the proposed project.
Table ES-1: Trails at Santiago Creek Specific Plan Residential Lots
Lot Size (sq ft) Number of Lots
8,000 82
9,200 17
10,000 29
Source: Milan REI X, 2018
The majority of the project site (62.7 percent) is intended for the enhancement and preservation of
the natural greenway/open space and Santiago Creek environs, as well as re-establishing open
grasslands in areas that have been denuded by the project site’s history of commercial operations,
totaling approximately 68.5 acres. Recreational trails will provide public access to the enhanced
revegetated interior of the site. Refer to Section 2, Project Description, for a complete description of
the proposed project.
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Pre-Development Agreement
Public Outreach
Since 2015, over two years before the circulation of the Trails of Santiago Creek Notice of
Preparation (NOP), the Applicant has conducted extensive outreach with representatives of the
adjacent neighborhoods, including Orange Park Association, Mabury Ranch Homeowners
Association, and The Reserve Homeowners Association, in an attempt to determine community
priorities for the site.
In response to the outreach and as a good faith gesture to further constructive dialogue regarding
the long-term land uses for the property, the Applicant agreed to curtail and modify the current sand
and gravel operations on an interim basis, as follows:
a) Suspend backfill and stockpiling operations effective September 15, 2015;
b) After July 31, 2015, restrict rock crushing operations to a total of 15 consecutive business
days within a six-month period;
c) Continue dust abatement measures; and
d) Continue ongoing maintenance of the property and enhance East Santiago Canyon Road
frontage.
e) The property owner reserved all right to resume sand and gravel operations consistent with
the City’s Zoning Code.
As part of the community outreach, City staff, as well as representatives from OPA, Mabury Ranch, the
Reserve, and the Applicant’s representatives worked together to establish a framework for an
appropriate land use entitlement. To formalize and ensure transparency for the entitlement process,
the City and the Applicant have entered said Pre-Development Agreement. This agreement sets the
general parameters and provides development alternatives that are intended to guide the processing
of various requested land use approvals required for the project as a byproduct of public outreach.
Pre-Development Agreement (Appendix A)
To formalize and ensure transparency for the entitlement process, with input from Orange Park
Association, Mabury Ranch Homeowners Association, and The Reserve Homeowners Association, the
City and the Applicant entered into a Pre-Development Agreement (PDA) dated October 11, 2016 in
accordance with the June 2015 Memorandum. This agreement establishes general parameters and
sets forth various development alternatives that are intended to guide the processing of various
requested land use approvals required for the project.
The major provisions of the agreement are as follows:
• Evaluate proposed alternatives (for the project on approximately 109.2 acres with a range of
25 to 50 acres available for residential units as set forth in Exhibit B of the PDA.
• An obligation of the Applicant to submit an application for land use entitlement approvals that
include a General Plan Amendment, Zoning Change, Major Site Plan Review, Design Review,
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CEQA compliance, Development Agreement, Park Planning and Development Committee
consideration of project trails, and commitment by the City to expeditiously process these
entitlements while complying with all legal requirements.
• Continue the cessation of the currently permitted operation of the sand and gravel operation
during the processing of the Project consistent with the June 12, 2015 memorandum submitted
by the Applicant to the City, Mabury Ranch, OPA, and the Reserve (attached within the PDA).
The Applicant will also commence the interim remediation of the property, which will result in
the lowering of the existing sand and gravel material stockpiles on the project site; subject to the
Applicant’s right to resume sand and gravel operations.
• Cooperation between the Applicant and the City for the evaluation of easements and
the possible extension of the Santiago Creek Trail to the north side of the project site.
PDA Alternative Land Use Plans
As part of the community outreach effort, City staff and the Applicant’s representatives have also
worked together to establish a framework for an appropriate land use entitlement process. To
formalize and ensure transparency for the entitlement process, the City and the Applicant entered
into a PDA on October 11, 2016, which sets out some general parameters and development
alternatives, which were born of extensive community outreach, to guide the processing of various
requested land use approvals required for the project.
The PDA set forth six land use plans, described as follows:
• Alternative A consists of residential uses occupying up to 50 acres in the southern portion of
the site between Santiago Creek and East Santiago Canyon Road. This area coincides with the
former mining area and the oval-shaped raised pad.
• Alternative B consists of 42 acres of residential and 67.2 acres of open space uses; no
community or recreational uses would be developed. Residential would occupy the same
footprint as the proposed project, albeit with 1.8 fewer acres in the western portion of the
site scenario.
• Alternative C consists of 40 acres of residential and 69 acres of open space uses; no
community or recreational uses would be developed. Residential would occupy the central
portion of the site; the eastern portion of the site would be dedicated for open space use.
The 69 acres of passive open space would consist of privately owned, undeveloped land; no
community or recreational uses would be developed.
• Alternative D consists of 40 acres of residential and 69 acres of open space uses; no
community or recreational uses would be developed. Residential would occupy the central
portion of the site; the eastern portion of the site would be dedicated for open space use.
The 69 acres of passive open space would consist of privately owned, undeveloped land; no
community or recreational uses would be developed.
• Alternative E consists of 25 acres of residential, 58 acres of open space/greenway uses, and 30
acres of organic gardens and community activity center.
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• Alternative F consists of residential uses would be developed 15.4 acres north of Santiago
Creek, with resource land use activities (sand, gravel, and materials recycling) occurring on
77.3 acres on both sides of the waterway. Vehicular access would be taken from two points
Mabury Drive. Resource land use activities would be located on 77.3 acres on both sides of
the waterway. These activities would consist of the continuation of the existing materials
recycling and backfilling operation.
The PDA Alternative Land Use Plans relate to the Collaborative Group Alternative evaluated in the
RDEIR.
Pre-Development Agreement in Relation to the Proposed Project
On March 16, 2017, the City of Orange conducted a Scoping meeting, in accordance with the State
CEQA Guidelines, for the Trails at Santiago Creek Project, (“Project”). The Project described in the
Notice of Preparation (NOP) consisted of approximately 150 residential dwellings configured within
various development plan alternatives. The various land use scenarios were based on the City’s
approval of a Pre-Development Agreement, (“PDA”) on October 11, 2016. This PDA represented
several months of meetings and discussions with community, numerous representatives from
Orange Park Acres Homeowners Association (“OPA”), Mabury Ranch Homeowners Association and
The Reserve Homeowners Association. An essential component of the PDA and working agreement
with the community representatives was the temporary suspension of all backfill and stockpiling
operations at the Sully-Miller sand and gravel operation, effective September 15, 2015. Based on
the PDA, the City obtained input at the Scoping Meeting. The most significant concerns expressed
by the community at the Scoping Meeting pertained to traffic on East Santiago Canyon Road and
Cannon Road, the preservation of Santiago Creek as a greenway, open space, flooding, and
elimination of the current sand and gravel operation.
An extensive 3-year community outreach collaboration effort to address these concerns as well as
other matters related to the Property Owner resulted in the following modifications, reductions, and
changes to the original proposal commitments.
1. The Specific Plan (Appendix Q of the RDEIR) and associated project accommodates a
maximum number of 128 single-family detached lots located in the southerly portion of the
property and will consist of housing types and lot sizes compatible with the surrounding
neighborhoods as depicted in the Trails at Santiago Creek Specific Plan, Exhibits 3.1-3.4, and
is consistent with the development standards and guidelines set forth in the Specific Plan.
2. The implementation of the Specific Plan and associated project will fund up to $1,000,000.00
for traffic improvements to widen East Santiago Canyon Road and restripe Cannon Road prior
to the issuance of the First Certificate of Occupancy of any housing units for the Project. Please
refer to the Trails at Santiago Creek Specific Plan, Exhibit 4.1, Areas of Traffic Congestion—Pre-
Project, Exhibit 4.2, Area of Project Related Traffic Improvements, and Exhibit 4.3, Additional
Project Related Traffic Improvements, and Section 4.2.3, Circulation Plan.
3. The implementation of the Specific Plan and associated project will fund approximately up to
a maximum of $4,100,000.00 in landscape and other improvements for the Santiago Creek
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Greenway. Said Improvements are to be completed or funded prior to the issuance of the
60th Certificate of Occupancy for the Project. Please refer to the Trails at Santiago Creek
Specific Plan, Section 4.2.4, Trails, Open Space and Recreation Plan, and Exhibit 4.14,
Preliminary Greenway, Open Space and Trails Plan.
4. The implementation of the Specific Plan and associated project will fund $1,000,000.00 to be
used for in local area-wide equestrian trail purposes prior to the issuance of the first
Certificate of Occupancy for the Project.
5. The implementation of the Specific Plan and associated project will finance and fund the
City’s acquisition of the Ridgeline Property, which will provide the community an additional
50 acres of public open space to the issuance of the first Certificate of Occupancy for the
Project. Please refer to the Trails at Santiago Creek Specific Plan, Exhibit 4.4, Sully Miller,
Arena, and Ridgeline Properties.
6. The implementation of the Specific Plan and associated project will provide $2,000,000.00 for
equestrian and recreational purposes in the East Orange Area as determined by the City prior
to the issuance of the first Certificate of Occupancy for the Project.
Project Objectives
The objectives of the proposed project are to:
OBJ-1. Locate single-family detached residential units in the most suitable areas of the
project site and preserve other areas for open space and greenway.
OBJ-2. Preserve and protect Santiago Creek by abating the remnants of the resource
extraction activities and establishing a greenway along the creek corridor.
OBJ-3. Promote land use compatibility with neighboring residential uses through the use
of locating landscaped setbacks, and the development of a compatible housing
product and lot size to the adjoining uses.
OBJ-4. Develop a network of publicly accessible trails within the project site that provide
access to Santiago Creek and Santiago Oaks Regional Park.
OBJ-5. Lessen the noise, improve air quality, and reduce traffic impacts from the existing
materials recycling and backfilling operations within the project site.
OBJ-6. Provide a circulation system that will minimize adverse effects on local residential
neighborhoods and encourage pedestrian and bicycle circulation.
OBJ-7. Provide an infrastructure system, including sewer, water, and storm drain systems
that will adequately serve full build-out of the proposed project.
OBJ-8. Improve local circulation by widening of East Santiago Canyon Road and restriping
Cannon Road prior to the first Certificate of Occupancy.
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Significant Unavoidable Adverse Impacts
Significant and unavoidable impacts identified in this RDEIR, include the following:
• As discussed in Impact AIR-1, the maximum daily construction emissions after the
implementation of Mitigation Measures AIR-1a through AIR-1g would continue to exceed the
South Coast Air Quality Management District’s (SCAQMD) regional significance thresholds.
Because no additional feasible mitigation measures are available, the project’s regional
operational emissions of NOX would continue to exceed the applicable SCAQMD regional
construction significance threshold even after implementation of all feasible mitigation. This
represents a significant and unavoidable impact.
• As discussed in Impact AIR-2, the project’s construction activities are estimated to generate a
maximum of 199.47 pounds of NOX per day with implementation of mitigation measures AIR-1a
through AIR-1g. As such, the project’s construction would continue to exceed the SCAQMD’s
recommended regional threshold of significance for NOX even after implementation of
Mitigation Measures AIR-1a through AIR-1g. The project’s construction activities are only
anticipated to exceed any of SCAQMD’s regional thresholds of significance during the combined
site preparation and grading period. A review of the detailed emissions estimates, contained in
Appendix F, show that 196.17 of the 199.47 pounds of NOX are from off-site sources. As
previously discussed, the project is anticipated to require up to 275,400 total haul trips during
the grading period. Because the exceedance is largely a result of the anticipated haul trips,
feasible and enforceable mitigation measures to reduce the impact are limited. Based on the
total haul trucks required each day and the fact that specific make and model of haul trucks can
vary by contractor and within each contractor fleet, it would not be feasible to mandate the use
of specific vehicles to haul soil for the proposed project. Because no additional feasible
mitigation measures are available beyond those already quantified in Impact AIR-2, the project’s
regional operational emissions of NOX would continue to exceed the applicable SCAQMD
regional construction significance threshold even after implementation of all feasible mitigation.
This represents a significant and unavoidable impact.
• As discussed in Impact AIR-3, the region is non-attainment for the federal and State ozone
standards, the State PM10 standards, and the federal and State PM2.5 standards. Therefore, a
project that would not exceed the SCAQMD thresholds of significance on a project-level would
also not result in a cumulatively considerable contribution to these regional air quality
impacts. The impacts from the project would, therefore, be cumulatively less than significant
during project operations and significant and unavoidable during project construction.
• As discussed in Impact TRANS-2, while the fair share contribution provided through Mitigation
Measure TRANS-2 would mitigate the proposed project’s impacts at the intersection of
Orange Park Boulevard/East Santiago Canyon Road, impacts would be significant and
unavoidable as the Orange Park Boulevard/East Santiago Canyon Road intersection is not
listed in the City of Orange MPAH, or any similar plans.
All additional impacts analyzed within the Draft EIR were found to be less than significant after
mitigation or less than significant with no mitigation required.
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Summary of Project Alternatives
Below is a summary of the alternatives to the proposed project considered in Section 5, Alternatives
to the proposed project.
Development within the Existing Land Use Designations Alternative
This alternative consists of allowing residential development north of the Santiago Creek and the
continuation of existing sand and gravel operations in accordance with the current City of Orange
General Plan and Zoning designations.1 As such, 15.4 acres of Low-Density as Residential (confirmed
by the City of Orange Community Development Department) are allowed in the north-central
portion of the site, north of Santiago Creek and abutting Mabury Ranch Road. Consistent with the
General Plan’s density range of 2.1 to 6.0 units per acre, there is an allowable range of 32 to 92
residential homes, and a target of 77 residential homes on this 15.4-acre residential land use parcel.
The existing R-1-8 Zoning for the residential area would provide a maximum of 77 single-family
dwelling units based on acre density and would yield approximately 40 to 50 single-family dwelling
units (although a range of 32 to 92 dwelling units could be developed under the existing land use
designations). Access to this residential parcel would be from Mabury Avenue.
A section of approximately 16.5 acres of Open Space (OS) bisects the site in an east-west trend,
generally following the Santiago Creek corridor, and avails itself to creekside trails to allow for
connectivity to regional trails to the west, and eventually connecting to Santiago Oaks Regional Park
to the east.
The majority of the site, approximately 77.3 acres, is designated Resource Area (RA) and avails itself
of ongoing rock crushing and sand and gravel operations that are current and historic to the site. No
changes in land use designations would occur under this alternative. Exhibit 5-1, located within
Section 5, Alternatives to the Proposed Project, of this RDEIR depicts this alternative.
No Project Alternative/Existing Land Use Activities Alternative
The No Project Alternative/Existing Land Use Activities Alternative consists of the continuation of the
existing sand and gravel operations on approximately 77.3 acres of the project site. Approximately
40 acres between Santiago Creek and East Santiago Canyon Road are characterized by soil piles and
berms, and unpaved roads. An approximately 5-acre area near East Santiago Canyon Road supports
a materials recycling operation that includes apparatus for crushing boulders, bricks, rocks, and
similar materials for recycling. Since 2015, backfilling operations have been limited to 15
consecutive business days in any 6-month period; this alternative would allow backfilling operations
to resume year-round as allowed by the grading permit. The project site would remain inaccessible
to the public under this alternative.
1 The Development within the Existing Land Use Designations Alternative corresponds to Alternative F in the PDA.
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Collaborative Group Alternative
The Collaborative Group Alternative was developed in response to a series of meetings between the
applicant representatives and the Collaborative Group, consisting of representatives from Orange
Park Acres, Mabury Ranch, and The Reserve.
The Collaborative Group Alternative consists of 47 lots and 47 dwelling units of varying sizes, on
approximately 40 acres. The remaining 69.2 acres would be turned into the Santiago Greenway
Open Space area. Overall, the Collaborative Group Alternative would have 81 fewer dwellings and
would develop the residential on approximately 0.7 less acres than the proposed project.
This alternative would not permit all items listed in the preface to the Draft EIR, which are a part of
the proposed project.
The Collaborative Liaison Committee Alternative is depicted in Exhibit 5-2.
122-Unit Alternative
The 122-Unit Alternative was developed in response to a series of meetings between the applicant
representatives and the Collaborative Group, consisting of representatives from Orange Park Acres,
Mabury Ranch, and The Reserve.
The 122-Unit Alternative consists of 122 lots, with an average lot size of 11,200-square-feet, on 40.9
acres of the project site. The remaining 68.3 acres of the project site would be turned into open
space consisting of 40.2 acres of Greenway Open Space, and 28.1 acres of Grasslands Open Space.
This alternative differs from the proposed project in that it would develop ten 0.5-acre equestrian
lots on the eastern border of the residential envelope, and twenty-four 10,000-square-foot lots
adjacent to East Santiago Canyon Road. Moreover, in response to input the applicant received
during meetings with the Collaborative Group, this alternative proposes larger lot sizes adjacent to
the Preserve and portions of Orange Park Acres.
Overall, the 122-Unit Alternative would have six less dwellings than the proposed project, but would
develop approximately 0.2 additional acres of the project site for residential, thereby reducing open
space by approximately 0.2 acres in comparison to the proposed project.
Additionally, this alternative would have $1,000,000 less in local trail improvements from the
Development Agreement.
The 122-Unit Alternative is depicted in Exhibit 5-3.
Areas of Controversy
Pursuant to CEQA Guidelines Section 15123(b), a summary section must address areas of
controversy known to the lead agency, including issues raised by agencies and the public, and it must
also address issues to be resolved, including the choice among alternatives and whether or how to
mitigate the significant effects.
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An NOP for the proposed project was issued on March 3, 2017. The NOP describing the original
concept for the project and issues to be addressed in the EIR was distributed to the State
Clearinghouse, responsible agencies, and other interested parties for a 30-day public review period
extending from March 3, 2017, through April 3, 2017. The NOP identified the potential for
significant impacts on the environment related to the following topical areas:
• Aesthetics, Light, and Glare
• Agriculture Resources and Forestry
Resources
• Air Quality
• Biological Resources
• Cultural Resources
• Geology and Soils
• Greenhouse Gas Emissions
• Hazards and Hazardous Materials
• Hydrology and Water Quality
• Land Use and Planning
• Mineral Resources
• Noise
• Population and Housing
• Public Services
• Recreation
• Transportation and Traffic
• Tribal Cultural Resources
• Utilities and Service Systems
Disagreement among Experts
This RDEIR contains substantial evidence to support all the conclusions presented herein. It is
possible that there will be disagreement among various parties regarding these conclusions,
although the City of Orange is not aware of any disputed conclusions at the time of this writing.
Both the CEQA Guidelines and case law clearly provide the standards for treating disagreement
among experts. Where evidence and opinions conflict on an issue concerning the environment, and
the lead agency knows of these controversies in advance, the RDEIR must acknowledge the
controversies, summarize the conflicting opinions of the experts, and include sufficient information
to allow the public and decision-makers to make an informed judgment about the environmental
consequences of the proposed project.
Potentially Controversial Issues
Below is a list of potentially controversial issues that may be raised during the public review and
hearing process of this RDEIR:
• Aesthetics, Light, and Glare
• Air Quality
• Biological Resources
• Cultural Resources
• Greenhouse Gas Emissions
• Hazards and Hazardous Materials
• Hydrology and Water Quality
• Land Use and Planning
• Mineral Resources
• Noise
• Population and Housing
• Public Services
• Transportation and Traffic
• Tribal Cultural Resources
• Utilities and Service Systems
It is also possible that evidence will be presented during the 45-day, statutory RDEIR public review
period that may create disagreement. Decision makers would consider this evidence during the
public hearing process.
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In rendering a decision on a project where there is disagreement among experts, the decision-
makers are not obligated to select the most environmentally preferable viewpoint. Decision makers
are vested with the ability to choose whatever viewpoint is preferable and need not resolve a
dispute among experts. In their proceedings, decision-makers must consider comments received
concerning the adequacy of the RDEIR and address any objections raised in these comments.
However, decision-makers are not obligated to follow any directives, recommendations, or
suggestions presented in comments on the RDEIR, and can certify the Final EIR without needing to
resolve disagreements among experts.
Public Review of the RDEIR
Upon completion of the RDEIR, the City of Orange filed a Notice of Completion (NOC) with the State
Office of Planning and Research to begin the public review period (Public Resources Code, Section
21161). Concurrent with the NOC, this RDEIR has been distributed to responsible and trustee
agencies, other affected agencies, surrounding cities, and interested parties, as well as all parties
requesting a copy of the RDEIR in accordance with Public Resources Code 21092(b)(3). During the
public review period, the RDEIR, including the technical appendices, is available for review at the City
of Orange offices and the Orange Public Library. The address for each location is provided below:
City of Orange
Community Development Department
Planning Division
300 East Chapman Avenue
Orange, CA 92866
Hours:
Monday–Thursday: 7:30 a.m. to 5:30 p.m.
Orange Public Library
407 East Chapman Avenue
Orange, CA 92866
Hours:
Monday–Wednesday: 10:00 a.m. to 9:00 p.m.
Thursday–Saturday: 10:00 a.m. to 6:00 p.m.
El Modena Branch Library
300 South Hewes Street
Orange, CA 92869
Hours:
Monday–Wednesday: 2:00 p.m. to 7:00 p.m.
Thursday–Saturday: 1:00 p.m. to 6:00 p.m.
Taft Branch Library
740 East Taft Avenue
Orange, CA 92865
Hours:
Monday–Wednesday: 2:00 p.m. to 7:00 p.m.
Thursday–Saturday: 1:00 p.m. to 6:00 p.m.
Online at the City of Orange website at:
http://www.cityoforange.org/292/Project-NoticesRelated-Environmental-Doc
Agencies, organizations, and interested parties have the opportunity to comment on the RDEIR
during the 45-day public review period. Written comments on this RDEIR should be addressed to:
Mr. Robert Garcia, Senior Planner
City of Orange
Community Development Department, Planning Division
300 East Chapman Avenue
Orange, CA 92866
Phone: 714.744.7231
Fax: 714.744.7222
Email: rgarcia@cityoforange.org
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Submittal of electronic comments in Microsoft Word or Adobe PDF format is encouraged. Upon
completion of the public review period, written responses to all significant environmental issues
raised will be prepared and made available for review by the commenting agencies at least 10 days
prior to the Planning Commission public hearing. The Orange City Council will ultimately consider
the comments and responses during the public hearing for the Final EIR. All comments received and
the responses to comments will be included as part of the record for consideration by decision-
makers for the project.
Executive Summary Matrix
Table ES-2 below summarizes the impacts, mitigation measures, and resulting level of significance
after mitigation for the relevant environmental issue areas evaluated for the proposed project. The
table is intended to provide an overview; narrative discussions for the issue areas are included in the
corresponding section of this RDEIR. Table ES-2 is included in the RDEIR as required by CEQA
Guidelines Section 15123(b)(1).
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Executive Summary FirstCarbon Solutions ES-13 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec00-03 ExecSummary.docx Table ES-2: Executive Summary Matrix Impacts Mitigation Measures Level of Significance After Mitigation Section 3.1—Aesthetics, Light, and Glare Impact AES-1: The project would not have a substantial adverse effect on a scenic vista. No mitigation is necessary. Less than significant impact. Impact AES-2: The project would not substantially degrade the existing visual character or quality of the site and its surroundings. No mitigation is necessary. Less than significant impact. Impact AES-3: The project may create a new source of substantial light or glare which would adversely affect day or nighttime views in the area. MM AES-3: Prior to issuance of building permits, the project applicant shall prepare and submit lighting plans to the City of Orange for review and approval. The plans shall demonstrate that all exterior lighting fixtures comply with Orange Municipal Code Chapter 17.12.030, which requires that new light fixtures be directed, controlled, screened or shaded in such a manner as not to shine directly on surrounding premises. Additionally, lighting on any residential property must be controlled so as to prevent glare or direct illumination of any public sidewalk or thoroughfares. Less than significant impact. Section 3.2—Agriculture and Forestry Resources Impact AFR-1: The project would not convert Important Farmland to non-agricultural use. No mitigation is necessary. Less than significant impact. Impact AFR-2: The project would not conflict with existing agricultural zoning, agricultural use or with land subject to a Williamson Act contract. No mitigation is necessary. Less than significant impact. Impact AFR-3: Forest: The project would not conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Govt. Code section 51104(g)). No mitigation is necessary. Less than significant impact. Impact AFR-4: The project would not result in the loss of forest land or conversion of forest land to non-forest use. No mitigation is necessary. Less than significant impact.
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Executive Summary FirstCarbon Solutions ES-14 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec00-03 ExecSummary.docx Table ES-2 (cont.): Executive Summary Matrix Impacts Mitigation Measures Level of Significance After Mitigation Impact AFR-5: Forest: The project would not involve other changes in the existing environment which, due to their location or nature, could result in conversion of agricultural land to non-agricultural use or forest land to non-forest use. No mitigation is necessary. Less than significant impact. Section 3.3—Air Quality Impact AIR-1: The project may conflict with or obstruct implementation of the applicable air quality plan. MM AIR-1a: During construction, all equipment shall be maintained in good operating condition so as to reduce emissions. The construction contractor shall ensure that all construction equipment is properly serviced and maintained in accordance with the manufacturer’s specifications. Maintenance records shall be available at the construction site for City verification. MM AIR-1b: All paints and coatings shall meet or exceed performance standards noted in SCAQMD Rule 1113. To ensure compliance with SCAQMD Rule 1113, the following volatile organic compound (VOC) control measures shall be implemented during architectural coating activities: a) Use paints with a VOC content of no more than 50 grams per liter for both interior and exterior coatings. b) Keep lids closed on all paint containers when not in use to prevent VOC emissions and excessive odors. c) Use compliant low VOC cleaning solvents to clean paint application equipment. d) Keep all paint and solvent laden rags in sealed containers to prevent VOC emissions. MM AIR-1c: Prior to the issuance of grading permits for the project, the project applicant shall include a dust control plan as part of the construction contract standard specifications. The dust control plan shall include measures to meet the requirements of SCAQMD Rules 402 and 403. Such basic measures may include but are not limited to the following: a) All haul trucks shall be covered prior to leaving the site to prevent dust from impacting the surrounding areas. Significant and unavoidable.
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Executive Summary FirstCarbon Solutions ES-15 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec00-03 ExecSummary.docx Table ES-2 (cont.): Executive Summary Matrix Impacts Mitigation Measures Level of Significance After Mitigation b) Moisten soil each day prior to commencing grading to depth of soil cut. c) Water exposed surfaces at least three times a day under calm conditions, and as often as needed on windy days or during very dry weather in order to maintain a surface crust and minimize the release of visible emissions from the construction site. d) Treat any area that will be exposed for extended periods with a soil conditioner to stabilize soil or temporarily plant with vegetation. e) Use street sweepers that comply with SCAQMD Rules 1186 and 1186.1. f) All contractors shall turn off all construction equipment and delivery vehicles when not in use, or limit on-site idling to no more than 5 minutes in any one hour. g) On-site electrical hook ups to a power grid shall be provided for electric construction tools including saws, drills, and compressors, where feasible, to reduce the need for diesel powered electric generators. h) Traffic speeds on all unpaved roads to be reduced to 15 miles per hour or less. i) Sweep streets at the end of the day if visible soil is carried onto adjacent public paved roads. MM AIR-1d: Prior to and during grading activities, the project applicant shall comply with South Coast Air Quality Management District Rule 403 as follows: • The applicant shall submit a fully executed Large Operation Notification (Form 403 N) to the SCQAMD Executive Officer within 7 days of qualifying as a large operation. The form shall include the name(s), address(es), and phone number(s) of the person(s) responsible for the submittal, and a description of the operation(s), including a map depicting the location of the site. • Maintain daily records to document the specific dust control actions taken, maintain such records for a period of not less than three years; and make such records available to the Executive Officer upon request • Install and maintain project signage with project contact signage that meets the minimum standards of the Rule 403 Implementation Handbook, prior to initiating any earthmoving activities
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Executive Summary FirstCarbon Solutions ES-16 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec00-03 ExecSummary.docx Table ES-2 (cont.): Executive Summary Matrix Impacts Mitigation Measures Level of Significance After Mitigation • Identify a dust control supervisor that (1) is employed by or contracted with the property owner or developer; (2) is on the site or available on-site within 30 minutes during working hours; (3) has the authority to expeditiously employ sufficient dust mitigation measures to ensure compliance with all Rule requirements; (4) has completed the AQMD Fugitive Dust Control Class and has been issued a valid Certificate of Completion for the class; and (5) will notify the Executive Officer in writing within 30 days after the site no longer qualifies as a large operation. MM AIR-1e: Prior to and during grading activities, the project applicant shall implement the following dust control measures for large operations, as applicable, pursuant to South Coast Air Quality Management District Rule 403: Earth Moving (except construction cutting and filling areas, and mining operations) 1a. Maintain soil moisture content at a minimum of 12 percent, as determined by ASTM method D-2216, or other equivalent method approved by the Executive Officer, the California Air Resources Board, and the U.S. EPA. Two soil moisture evaluations must be conducted during the first three hours of active operations during a calendar day, and two such evaluations each subsequent four-hour period of active operations; or 1a-1. For any earth-moving which is more than 100 feet from all property lines, conduct watering as necessary to prevent visible dust emissions from exceeding 100 feet in length in any direction. Earth Moving—Construction Fill Areas 1b. Maintain soil moisture content at a minimum of 12 percent, as determined by ASTM method D-2216, or other equivalent method approved by the Executive Officer, the California Air Resources Board, and the U.S. EPA. For areas which have an optimum moisture content for compaction of less than 12 percent, as determined by ASTM Method 1557 or other equivalent method approved by the Executive Officer and the California Air Resources Board and the U.S. EPA, complete the
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Executive Summary FirstCarbon Solutions ES-17 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec00-03 ExecSummary.docx Table ES-2 (cont.): Executive Summary Matrix Impacts Mitigation Measures Level of Significance After Mitigation compaction process as expeditiously as possible after achieving at least 70 percent of the optimum soil moisture content. Two soil moisture evaluations must be conducted during the first three hours of active operations during a calendar day, and two such evaluations during each subsequent four-hour period of active operations. Earth Moving—Construction Cut Areas and Mining Operations 1c. Conduct watering as necessary to prevent visible emissions from extending more than 100 feet beyond the active cut or mining area unless the area is inaccessible to watering vehicles due to slope conditions or other safety factors. Disturbed Surface Areas—Completed Grading Areas 2a/b. Apply dust suppression in sufficient quantity and frequency to maintain a stabilized surface. Any areas which cannot be stabilized, as evidenced by wind driven fugitive dust must have an application of water at least twice per day to at least 80 percent of the unstabilized area. 2c. Apply chemical stabilizers within five working days of grading completion; OR 2d. Take actions (3a) or (3c) specified for inactive disturbed surface areas. Inactive Disturbed Surface Areas 3a. Apply water to at least 80 percent of all inactive disturbed surface areas on a daily basis when there is evidence of wind driven fugitive dust, excluding any areas which are inaccessible to watering vehicles due to excessive slope or other safety conditions; or 3b. Apply dust suppressants in sufficient quantity and frequency to maintain a stabilized surface; or 3c. Establish a vegetative ground cover within 21 days after active operations have ceased. Ground cover must be of sufficient density to expose less than 30 percent of unstabilized ground within 90 days of planting, and at all times thereafter; OR 3d. Utilize any combination of control actions (3a), (3b), and (3c) such that, in total, these actions apply to all inactive disturbed surface areas.
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Executive Summary FirstCarbon Solutions ES-18 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec00-03 ExecSummary.docx Table ES-2 (cont.): Executive Summary Matrix Impacts Mitigation Measures Level of Significance After Mitigation Unpaved Roads 4a. Water all roads used for any vehicular traffic at least once per every two hours of active operations [3 times per normal 8-hour work day]; or 4b. Water all roads used for any vehicular traffic once daily and restrict vehicle speeds to 15 miles per hour; or 4c. Apply a chemical stabilizer to all unpaved road surfaces in sufficient quantity and frequency to maintain a stabilized surface. Open Storage Piles 5a. Apply chemical stabilizers; or 5b. Apply water to at least 80 percent of the surface area of all open storage piles on a daily basis when there is evidence of wind driven fugitive dust; or 5c. Install temporary coverings; or 5d. Install a three-sided enclosure with walls with no more than 50 percent porosity which extend, at a minimum, to the top of the pile. This option may only be used at aggregate-related plants or at cement manufacturing facilities. All Categories 6a. Any other control measures approved by the Executive Officer and the U.S. EPA as equivalent to the methods specified in this mitigation measure may be used. MM AIR-1f: Prior to and during grading activities, the project applicant shall implement the following contingency control measures for large operations, as applicable, pursuant to South Coast Air Quality Management District Rule 403: Earth Moving 1A. Cease all active operations; or 2A. Apply water to soil not more than 15 minutes prior to moving such soil. 0B. On the last day of active operations prior to a weekend, holiday, or any other period when active operations will not occur for not more
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Executive Summary FirstCarbon Solutions ES-19 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec00-03 ExecSummary.docx Table ES-2 (cont.): Executive Summary Matrix Impacts Mitigation Measures Level of Significance After Mitigation than four consecutive days: apply water with a mixture of chemical stabilizer diluted to not less than 1/20 of the concentration required to maintain a stabilized surface for a period of six months; OR 1B. Apply chemical stabilizers prior to wind event; or 2B. Apply water to all unstabilized disturbed areas 3 times per day. If there is any evidence of wind driven fugitive dust, watering frequency is increased to a minimum of four times per day; or 3B. Establish a vegetative ground cover within 21 days after active operations have ceased. Ground cover must be of sufficient density to expose less than 30 percent of unstabilized ground within 90 days of planting, and at all times thereafter; or 4B. Utilize any combination of control actions (1B), (2B), and (3B) such that, in total, these actions apply to all disturbed surface areas. Unpaved Roads 1C. Apply chemical stabilizers prior to wind event; or 2C. Apply water twice per hour during active operation; or 3C. Stop all vehicular traffic. Open Storage Piles 1D. Apply water twice per hour; or 2D. Install temporary coverings. Paved Road Track Out 1E. Cover all haul vehicles; or 2E. Comply with the vehicle freeboard requirements of Section 23114 of the California Vehicle Code for both public and private roads. All Categories 1F. Any other control measures approved by the Executive Officer and the U.S. EPA as equivalent to the methods specified in this mitigation measure may be used. MM AIR-1g: During construction activities, all off-road equipment with engines greater than 50 horsepower shall meet either EPA or ARB Tier IV
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Executive Summary FirstCarbon Solutions ES-20 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec00-03 ExecSummary.docx Table ES-2 (cont.): Executive Summary Matrix Impacts Mitigation Measures Level of Significance After Mitigation Final off-road emission standards. The construction contractor shall maintain records concerning its efforts to comply with this requirement, including equipment lists. Off-road equipment descriptions and information may include but are not limited to equipment type, equipment manufacturer, equipment identification number, engine model year, engine certification (Tier rating), horsepower, and engine serial number. If engines that comply with Tier IV Final off-road emission standards are not commercially available, then the construction contractor shall use the next cleanest piece of off-road equipment (e.g., Tier IV Interim) available. For purposes of this mitigation measure, “commercially available” shall mean the availability of Tier IV Final engines taking into consideration factors such as (i) critical-path timing of construction; and (ii) geographic proximity to the project site of equipment. The contractor can maintain records for equipment that is not commercially available by providing letters from at least two rental companies for each piece of off-road equipment where the Tier IV Final engine is not available. Impact AIR-2: The project may violate any air quality standard or contribute substantially to an existing or projected air quality violation. Implement Mitigation Measures AIR-1a through AIR-1g. Significant and unavoidable impact. Impact AIR-3: The project may result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or State ambient air quality standard. Impact AIR-3: The project may result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or State ambient air quality standard. Significant and unavoidable impact. Impact AIR-4: The project may expose sensitive receptors substantial pollutant concentrations. Implement Mitigation Measures AIR-1a through AIR-1g. Less than significant impact. Impact AIR-5: The project would not create objectionable odors affecting a substantial number of people. No mitigation is necessary. Less than significant impact. Section 3.4—Biological Resources Impact BIO-1: The proposed project would not have a substantial adverse effect on special status plant species. No mitigation is necessary. Less than significant impact.
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Executive Summary FirstCarbon Solutions ES-21 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec00-03 ExecSummary.docx Table ES-2 (cont.): Executive Summary Matrix Impacts Mitigation Measures Level of Significance After Mitigation Impact BIO-2: The proposed project may have a substantial adverse effect on special status wildlife species. MM BIO-2a: Prior to the issuance of any grading permit for areas supporting least Bell’s vireo habitat (such as southern cottonwood-willow riparian forest), the project applicant shall obtain federal and State take authorizations via regulatory permits (such as a CWA Section 404 permit issued by the United States Army Corp of Engineers [USACE]), which will require that the U.S. Fish and Wildlife Service (USFWS) be consulted as provided for by Section 7 of the FESA (for the federally listed least Bell’s vireo). The federal regulatory permits (such as CWA Section 404 permit issued by the USACE) provide a “federal nexus” by which Section 7 consultation can occur. This statute imposes the obligation on federal agencies to ensure that their actions (such as issuing federal CWA permits for this project) are not likely to jeopardize the continued existence of a listed species or destroy or adversely modify its designated critical habitat. This obligation is enforced through the procedural requirement that agencies such as the USACE initiate consultation with the USFWS on any actions that may affect a threatened or endangered species. During the FESA Section 7 consultation anticipated for this project, the USFWS will gather all relevant information concerning the proposed project and the potential project-related impacts on the least Bell’s vireo (i.e., the project applicant will submit a species-specific Biological Assessment), prepare its opinion with respect to whether the project is likely to jeopardize the continued existence of the species (i.e., the USFWS will issue a Biological Opinion), and recommend mitigation/conservation measures where appropriate. Additionally, the need for State regulatory permits (i.e., Fish and Game Code Section 1602 Streambed Alteration Agreement issued by the California Department of Fish and Wildlife [CDFW]) will require a Consistency Determination from the CDFW for the State-listed least Bell’s vireo under CESA. In addition, the following best management practices (BMPs) will ensure that indirect impacts will not occur to the least Bell’s vireo within 300 feet of occupied habitat as monitored by a certified biologist: 1. Construction limits in and around least Bell’s vireo potential habitat shall be delineated with flags and fencing prior to the initiation of any grading or construction activities. Less than significant impact.
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Executive Summary FirstCarbon Solutions ES-22 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec00-03 ExecSummary.docx Table ES-2 (cont.): Executive Summary Matrix Impacts Mitigation Measures Level of Significance After Mitigation 2. Prior to grading and construction a training program shall be developed and implemented to inform all workers on the project about listed species, sensitive habitats, and the importance of complying with avoidance and minimization measures. 3. All construction work shall occur during the daylight hours. The construction contractor shall limit all construction-related activities that would result in high noise levels according to the construction hours determined by the City. 4. During all excavation and grading on-site, the construction contractors shall equip all construction equipment, fixed or mobile, with properly operating and maintained mufflers, consistent with manufacturers’ standards to reduce construction equipment noise to the maximum extent possible. The construction contractor shall place all stationary construction equipment so that emitted noise is directed away from sensitive receptors (i.e., least Bell’s vireo territory within Santiago Creek) nearest the project site. 5. The construction contractor shall stage equipment in areas that will create the greatest distance between construction-related noise sources and noise sensitive receptors nearest the project site during all project construction. 6. Noise from construction activities shall be limited to the extent possible through the maximum use of technology available to reduce construction equipment noise. Project-generated noise, both during construction and after the development has been completed, shall be in compliance with the requirements outlined in the City of Orange General Plan Noise Element to ensure that noise levels to which the riparian area is exposed do not exceed noise standards for residential areas. 7. The project shall be designed to minimize exterior night lighting while remaining compliant with City of Orange ordinances related to street lighting. Any necessary lighting (e.g., to light up equipment for security measures), both during construction and after the development has been completed, will be shielded or directed away from Santiago Creek and are not to exceed 0.5 foot-candles. Monitoring by a qualified lighting engineer (attained by the project applicant and subject to spot checking by City Staff) shall be conducted as needed to verify light levels
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Executive Summary FirstCarbon Solutions ES-23 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec00-03 ExecSummary.docx Table ES-2 (cont.): Executive Summary Matrix Impacts Mitigation Measures Level of Significance After Mitigation are below 0.5 foot-candles required within identified, occupied least Bell’s vireo territories, both during construction and at the onset of operations. If the 0.5 foot-candles requirement is exceeded, the lighting engineer shall make operational changes or install a barrier to alleviate light levels during the breeding season. 8. Two brown-headed cowbird traps shall be installed and maintained within the general vicinity of the habitat for five years. If equestrian trails are proposed within the project site, which may result in increased horse manure and the potential for increased foraging resources for brown-headed cowbirds, an ongoing manure management receptacle/maintenance plan shall be prepared and implemented. MM BIO-2b: The following shall be incorporated into the Biological Assessment as proposed mitigation for potential impacts to least Bell’s vireo, subject to USFWS and CDFW approval: 1. On- or off-site restoration or enhancement of least Bell’s vireo habitat at a ratio no less than 3:1 for permanent grading impacts. MM BIO-2c: All construction, grading, and fuel modification activities (i.e., thinning) shall take place outside of the least Bell’s vireo breeding season (March 15 to September 15) to the greatest extent feasible. If any construction, grading, and fuel modification activities are required during the breeding season within 300 feet of potential least Bell’s vireo habitat, and pre-construction surveys determine least Bell’s vireo are present, activities may continue in the presence of a biological monitor who will confirm that no work will occur within a 300-foot buffer of least Bell’s vireo, and that any least Bell’s vireo are not being disturbed by project activities. If any disturbance to the least Bell’s vireo is detected by the biological monitor, the buffer will be increased, other disturbance minimizing measures may be implemented (e.g., visual and/or noise barrier), and/or work will cease as recommended by the monitor. Additional measures to be taken for all construction activities within 300 feet of potential least Bell’s vireo habitat during the breeding season (March 15 to September 15):
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Executive Summary FirstCarbon Solutions ES-24 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec00-03 ExecSummary.docx Table ES-2 (cont.): Executive Summary Matrix Impacts Mitigation Measures Level of Significance After Mitigation 1. Pre-construction surveys shall be conducted within 1 week prior to initiation of construction activities and all results forwarded to the USFWS and CDFW. Focused surveys shall be conducted for least Bell’s vireo during construction activities. 2. If at any time least Bell’s vireo are found to occur within 300 feet of construction areas, the monitoring biologist shall inform the appropriate construction supervisor to cease such work and shall consult with the USFWS and CDFW to determine if work shall commence or proceed during the breeding season and, if work may proceed, what specific measures shall be taken to ensure least Bell’s vireos are not affected. 3. Installation of any noise barriers and any other corrective actions taken to mitigate noise during the construction period shall be communicated to the USFWS and CDFW. MM BIO-2d: Prior to the issuance of any grading permit that would remove habitat containing raptor and songbird nests, the project applicant shall demonstrate to the satisfaction of the City that either of the following have been or will be accomplished. 1. Vegetation removal activities shall be scheduled outside the nesting season (September 1 to February 14 for songbirds; September 1 to January 14 for raptors) to avoid potential impacts to nesting birds. 2. Any construction activities that occur during the nesting season (February 15 to August 31 for songbirds; January 15 to August 31 for raptors) will require that all suitable habitat be thoroughly surveyed for the presence of nesting birds by a qualified biologist before commencement of clearing. If any active nests are detected, a buffer of at least 300 feet (500 feet for raptors) will be delineated, flagged, and avoided until the nesting cycle is complete, or as determined appropriate by the biological monitor, to minimize impacts. Impact BIO-3: The project may impact sensitive natural communities. MM BIO-3: Prior to the issuance of any grading permit in the areas designated as sensitive riparian communities (e.g., southern cottonwood-willow riparian forest or black willow scrub/ruderal), the project applicant shall demonstrate to the satisfaction of the City that either of the following have been or will be accomplished: Less than significant impact.
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Executive Summary FirstCarbon Solutions ES-25 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec00-03 ExecSummary.docx Table ES-2 (cont.): Executive Summary Matrix Impacts Mitigation Measures Level of Significance After Mitigation On- or off-site restoration or enhancement of sensitive riparian communities (e.g., southern cottonwood-willow riparian forest) at a ratio no less than 1:1 for permanent impacts. Temporary impacts will be restored to pre-project conditions (i.e., pre-project contours and revegetate with native species, where appropriate). Off-site restoration or enhancement at a ratio no less than 1:1 may include the purchase of mitigation credits at an agency-approved off-site mitigation bank or in-lieu fee program (e.g., Santa Ana Watershed Association [SAWA]). If mitigation is to occur on-site and/or off-site (i.e., not an in-lieu fee program), a mitigation and monitoring plan shall be prepared. The plan shall focus on the creation of equivalent habitats within disturbed habitat areas of the project site and/or off-site. In addition, the plan shall provide details as to the implementation of the plan, maintenance, and future monitoring. Mitigation for impacts to sensitive riparian communities shall be accomplished by on- or off-site restoration and/or enhancement (e.g., transplantation, seeding, and/or planting/staking of sensitive riparian species; salvage/dispersal of duff and seed bank; removal of large stands of giant reed within riparian areas). Impact BIO-4: The proposed project may impact federally protected wetlands. MM BIO-4: Prior to the issuance of any grading permit for permanent impacts in the areas designated as jurisdictional features, the project applicant shall obtain a CWA Section 404 permit from the USACE, a CWA Section 401 permit from the Regional Water Quality Control Board (RWQCB), and Streambed Alteration Agreement permit under Section 1602 of the California Fish and Game Code from the CDFW. The following would be incorporated into the permitting, subject to approval by the regulatory agencies: 1. On- or off-site restoration or replacement of USACE/RWQCB jurisdictional waters of the United States/waters of the State at a ratio no less than 2:1 for permanent impacts, and for temporary impacts, restore impact area to pre-project conditions (i.e., pre-project contours and revegetate with native species, where appropriate). Off-site restoration or enhancement at a ratio no less than 2:1 may include the purchase of mitigation credits at an agency-approved off-site mitigation bank or in-lieu fee program (e.g., SAWA). 2. On- or off-site restoration or enhancement of CDFW jurisdictional Less than significant impact.
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Executive Summary FirstCarbon Solutions ES-26 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec00-03 ExecSummary.docx Table ES-2 (cont.): Executive Summary Matrix Impacts Mitigation Measures Level of Significance After Mitigation streambed and associated riparian habitat at a ratio no less than 2:1 for permanent impacts, and for temporary impacts, restore impact area to pre-project conditions (i.e., pre-project contours and revegetate with native species, where appropriate). Off-site restoration or enhancement at a ratio no less than 2:1 may include the purchase of mitigation credits at an agency-approved off-site mitigation bank or in-lieu fee program (e.g., SAWA). Impact BIO-5: The project would not interfere with fish or wildlife movement. No mitigation is necessary. Less than significant impact. Impact BIO-6: The project would not conflict with local biological ordinances or policies. No mitigation is necessary. Less than significant impact. Impact BIO-7: The project would not conflict with any applicable habitat conservation plan or natural communities conservation plan No mitigation is necessary. Less than significant impact. Section 3.5—Cultural Resources Impact CUL-1: Subsurface construction activities associated with the proposed project may damage or destroy previously undiscovered historic resources. MM CUL-1: In the event that buried cultural resources are discovered during construction, operations shall stop within a 50-foot radius of the find and a qualified archaeologist shall be consulted to determine whether the resource requires further study. The qualified archaeologist and shall make recommendations to the Lead Agency on the measures that shall be implemented to protect the discovered resources, including but not limited to excavation of the finds and evaluation of the finds in accordance with Section 15064.5 of the CEQA Guidelines. Potentially significant cultural resources consist of but are not limited to stone, bone, fossils, wood, or shell artifacts or features, including hearths, structural remains, or historic dumpsites. Any previously undiscovered resources found during construction within the project area should be recorded on appropriate Department of Parks and Recreation (DPR) forms and evaluated for significance in terms of CEQA criteria. If the resources are determined to be unique historic resources as defined Less than significant impact.
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Executive Summary FirstCarbon Solutions ES-27 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec00-03 ExecSummary.docx Table ES-2 (cont.): Executive Summary Matrix Impacts Mitigation Measures Level of Significance After Mitigation under Section 15064.5 of the CEQA Guidelines, mitigation measures shall be identified by the monitor in accordance with Public Resource Code Section 21083.1 and CEQA Guidelines Section 15126.4 and recommended to the Lead Agency. Appropriate mitigation measures for significant resources could include avoidance or capping, incorporation of the site in green space, parks, or open space, or data recovery excavations of the finds. No further grading shall occur in the area of the discovery until the Lead Agency approves the measures to protect these resources. Any archaeological artifacts recovered as a result of mitigation shall be donated to a qualified scientific institution approved by the Lead Agency where they would be afforded long-term preservation to allow future scientific study. Impact CUL-2: Subsurface construction activities associated with the proposed project may damage or destroy previously undiscovered archaeological resources. Implement Mitigation Measure CUL-1 and: MM CUL-2: During the ground disturbing activities in the areas depicted in Exhibit 3.5 1, a qualified archaeological and paleontological monitor shall be present on-site to observe earthwork activities. In the event of a discovery of an archaeological or paleontological resource, the monitor shall have the discretion to halt all ground disturbing activities within 50 feet of the find until it has been evaluated for significance. If the find is determined to have archaeological or paleontological, the procedures in Mitigation Measure CUL-1 or Mitigation Measure CUL-3 shall be implemented. Monitoring may cease once all of the areas depicted in Exhibit 3.5 1 have been thoroughly disturbed. Less than significant impact. Impact CUL-3: Subsurface construction activities associated with the proposed project may damage or destroy previously undiscovered paleontological resources. MM CUL-3: If the subsurface excavations for this project are proposed to exceed depths of 15 feet below surface, a qualified paleontological monitor should be retained to observe such excavations, which may breach the older Quaternary Alluvium deposits. In this situation, a detailed Mitigation Monitoring Plan (MMP) or Paleontological Resource Impact Management Plan (PRIMP) should be prepared in order to set forth the observation, collection, and reporting duties of the paleontological monitor. Additional mitigation measures and procedures will be outlined in the MMP or PRIMP as needed. In the event that fossils or fossil-bearing deposits are discovered during Less than significant impact.
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Executive Summary FirstCarbon Solutions ES-28 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec00-03 ExecSummary.docx Table ES-2 (cont.): Executive Summary Matrix Impacts Mitigation Measures Level of Significance After Mitigation construction activities that are shallower than 10 feet in depth, excavations within a 50-foot radius of the find shall be temporarily halted or diverted. The project contractor shall notify a qualified paleontologist to examine the discovery. The paleontologist shall document the discovery as needed (in accordance with Society of Vertebrate Paleontology standards), evaluate the potential resource, and assess the significance of the find under the criteria set forth in CEQA Guidelines Section 15064.5. The paleontologist shall notify the appropriate agencies to determine procedures that would be followed before construction activities are allowed to resume at the location of the find. If the Applicant determines that avoidance is not feasible, the paleontologist shall prepare an excavation plan for mitigating the effect of construction activities on the discovery. The plan shall be submitted to the Lead Agency for review and approval prior to implementation, and the Applicant shall adhere to the recommendations in the plan. Impact CUL-4: Subsurface construction activities associated with the proposed project may damage or destroy previously undiscovered human burial sites. MM CUL-4: In the event of an accidental discovery or recognition of any human remains, Public Resource Code (PRC) Section 5097.98 must be followed. In this instance, once project-related earthmoving begins and if there is accidental discovery or recognition of any human remains, the following steps shall be taken: 1. There shall be no further excavation or disturbance of the site or any nearby area reasonably suspected to overlie adjacent human remains until the County Coroner is contacted to determine if the remains are Native American and if an investigation of the cause of death is required. If the coroner determines the remains to be Native American, the coroner shall contact the NAHC within 24 hours, and the Native American Heritage Commission (NAHC) shall identify the person or persons it believes to be the “most likely descendant” of the deceased Native American. The most likely descendant may make recommendations to the landowner or the person responsible for the excavation work, for means of treating or disposing of, with appropriate dignity, the human remains and any associated grave goods as provided in PRC Section 5097.98, or Less than significant impact.
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Executive Summary FirstCarbon Solutions ES-29 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec00-03 ExecSummary.docx Table ES-2 (cont.): Executive Summary Matrix Impacts Mitigation Measures Level of Significance After Mitigation 2. Where the following conditions occur, the landowner or his/her authorized representative shall rebury the Native American human remains and associated grave goods with appropriate dignity either in accordance with the recommendations of the most likely descendent or on the project area in a location not subject to further subsurface disturbance: • The NAHC is unable to identify a most likely descendent or the most likely descendent failed to make a recommendation within 48 hours after being notified by the commission; • The descendent identified fails to make a recommendation; or • The landowner or his authorized representative rejects the recommendation of the descendent, and the mediation by the NAHC fails to provide measures acceptable to the landowner. Section 3.6—Geology and Soils Impact GEO-1: The project may expose people or structures to potential substantial adverse effects, including the risk of loss, injury or death involving seismic hazards. MM GEO-1: Prior to the issuance of building permits, the project applicant shall submit a design-level Geotechnical Investigation to City of Orange for review and approval. The investigation shall be prepared by a qualified engineer and identify grading and building practices necessary to achieve compliance with the latest adopted edition of the California Building Standards Code’s geologic, soils, and seismic requirements. The measures identified in the approved report shall be incorporated into the Project plans. Less than significant impact. Impact GEO-2: The project will result in substantial soil erosion or the loss of topsoil. Implement Mitigation Measure GEO-1 and HYD-1a. Less than significant impact. Impact GEO-3: The project would not be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse. No mitigation is necessary. Less than significant impact. Impact GEO-4: The project would not be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial risks to life or property. No mitigation is necessary. Less than significant impact.
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Executive Summary FirstCarbon Solutions ES-30 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec00-03 ExecSummary.docx Table ES-2 (cont.): Executive Summary Matrix Impacts Mitigation Measures Level of Significance After Mitigation Section 3.7—Greenhouse Gas Emissions Impact GHG-1: The project would not generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment. No mitigation is necessary. Less than significant impact. Impact GHG-2: The project would not conflict with any applicable plan, policy or regulation of an agency adopted for the purpose of reducing the emissions of greenhouse gases. No mitigation is necessary. Less than significant impact. Section 3.8—Hazards and Hazardous Materials Impact HAZ-1: The project would not create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials. No mitigation is necessary. Less than significant impact. Impact HAZ-2: The project may create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the likely release of hazardous materials into the environment. MM HAZ-2a: The proposed enclosed structures shall be situated strategically to allow for future remediation of any potential landfill gas migration. Prior to issuance of building permits for dwelling units in areas of the project site where vapor intrusion has the potential to occur, the applicant shall prepare and submit plans to the City of Orange identifying vapor intrusion abatement measures for trichloroethylene (TCE) and methane. Areas where vapor intrusion has the potential to occur are those identified in the Phase II Environmental Site Assessment. Such abatement measures may include but are not limited to vapor barriers or passive/active venting systems, as determined by the appropriate regulatory agency. The approved abatement measures shall be incorporated into project building plans. Design plans for: 1) any occupied structures within 1,000 feet of the landfill boundary; and/or 2) structural systems to prevent gas-related hazards are required to be reviewed and approved by the County of Orange Health Care Agency/Local Enforcement Agency. MM HAZ-2b: Prior to issuance of grading permits, the project applicant shall retain a qualified hazardous materials contractor to remove all soil containing Total Petroleum Hydrocarbons in excess of residential Less than significant impact.
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Executive Summary FirstCarbon Solutions ES-31 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec00-03 ExecSummary.docx Table ES-2 (cont.): Executive Summary Matrix Impacts Mitigation Measures Level of Significance After Mitigation development standards set forth by the California Department of Toxic Substances Control (DTSC) or other applicable regulatory agency. Soil removal and disposal shall occur in accordance with DTSC (or other applicable agency) guidelines. The applicant shall submit documentation to the City of Orange in the form of confirmatory soil sampling results verifying that this mitigation measure was successfully implemented as part of the grading permit application for this property. All environmental investigations, sampling and/or remediation for the project site shall be conducted under a workplan approved and overseen by a regulatory agency with jurisdiction to oversee hazardous substance cleanup, such as the RWQCB. As part of proper construction operations and maintenance, any construction areas that are found to contain contaminated soils shall be excluded using a security fence. All contaminated soils shall then be excavated and disposed of off-site in accordance with the rules and regulations of: United States Department of Transportation (USDOT), USEPA, CalEPA, CalOSHA, and any local regulatory agencies. All retention and detention features used during construction would be lined to prevent infiltration through contaminated soils. Post-construction retention features shall be lined to prevent infiltration of groundwater. MM HAZ-2c: Prior to commencement of any construction activities that would impact existing landfill or related gas monitoring equipment, the project applicant shall contact the City Engineer to consult with and obtain approval from the Orange County Integrated Waste Management Department for the relocation of any monitoring wells or probes that would be impacted by development on the project site. Impact HAZ-3: The project would not emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school. No mitigation is necessary. Less than significant impact.
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Executive Summary FirstCarbon Solutions ES-32 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec00-03 ExecSummary.docx Table ES-2 (cont.): Executive Summary Matrix Impacts Mitigation Measures Level of Significance After Mitigation Impact HAZ-4: The project may be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment. Implement Mitigation Measure HAZ-2a. Less than significant impact. Impact HAZ-5: The project may impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan. MM HAZ-5: Prior to issuance of the first building permit, the applicant shall prepare and submit plans to the City of Orange for review and approval demonstrating compliance with all applicable emergency access provisions of the Fire Code. The approved plan shall be incorporated into the proposed project. Less than significant impact. Impact HAZ-6: The project may expose persons or property to wildland fire hazards. MM HAZ-6: Prior to issuance of the first building permit, the applicant shall retain a qualified fire safety consultant to prepare a Fuel Modification Plan for the proposed project. The plan shall identify defensible space around dwelling units in accordance with City requirements. The plan shall be submitted to the City of Orange for review and approval. The approved plan shall be incorporated into the proposed project. Less than significant impact. Section 3.9—Hydrology and Water Quality Impact HYD-1: Construction and operational activities associated with the proposed project may potentially degrade water quality in downstream water bodies. MM HYD-1a: Prior to the issuance of grading permits, the project applicant shall file a Notice of Intent with and obtain a facility identification number from the State Water Resources Control Board. The project applicant shall also submit a Storm Water Pollution Prevention Plan (SWPPP) to the California State Water Resources Control Board/Santa Ana Regional Water Quality Control Board. The SWPPP that identifies specific actions and BMPs to prevent stormwater pollution during construction activities. The SWPPP shall identify a practical sequence for BMP implementation, site restoration, contingency measures, responsible parties, and agency contacts. The SWPPP shall include but not be limited to the following elements: • Comply with the requirements of the State of California’s most current Construction Stormwater Permit. • Temporary erosion control measures shall be implemented on all disturbed areas. Less than significant impact.
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Executive Summary FirstCarbon Solutions ES-33 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec00-03 ExecSummary.docx Table ES-2 (cont.): Executive Summary Matrix Impacts Mitigation Measures Level of Significance After Mitigation • Sediment shall be retained on-site by a system of sediment basins, traps, or other BMPs. • The construction contractor shall prepare Standard Operating Procedures for the handling of hazardous materials on the construction site to eliminate discharge of materials to storm drains. • BMP performance and effectiveness shall be determined either by visual means where applicable (e.g., observation of above-normal sediment release), or by actual water sampling in cases where verification of contaminant reduction or elimination (such as inadvertent petroleum release) is required by the Santa Ana Regional Water Quality Control Board to determine adequacy of the measure. • In the event of significant construction delays or delays in final landscape installation, native grasses or other appropriate vegetative cover shall be established on the construction site as soon as possible after disturbance, as an interim erosion control measure throughout the wet season. MM HYD-1b: Prior to the issuance of building permits, the project applicant shall submit a Water Quality Management Plan (WQMP) to the City of Orange for review and approval. The plan shall be developed using the Orange County Model Water Quality Management Plan and Technical Guidance Document. The WQMP shall identify pollution prevention measures, low impact development features, and BMPs necessary to control stormwater pollution from operational activities and facilities, identify hydromodification flow controls, and provide for appropriate maintenance over time. The WQMP shall include design concepts and BMPs that are intended to address the Design Capture Volume, more commonly referred to as the “first flush,” and remove pollutants from the design system event before entering the Municipal Separate Storm Sewer Systems (MS4). In accordance with the Regional MS4 Permit and City of Orange WQMP requirements, the use of low impact development features will be consistent with the prescribed hierarchy of treatment provided in the Permit: including techniques to infiltrate, filter, store, evaporate, or retain runoff close to the source of runoff. For those areas of the project where infiltration is not recommended or acceptable and harvest/reuse
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Executive Summary FirstCarbon Solutions ES-34 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec00-03 ExecSummary.docx Table ES-2 (cont.): Executive Summary Matrix Impacts Mitigation Measures Level of Significance After Mitigation demands are insufficient, biofiltration features will be designed to treat runoff and discharge controlled effluent flows to downstream receiving waters. The project WQMP shall also include an operations and maintenance plan for the prescribed Low Impact Development (LID) features, structural BMPs, and any hydromodification controls to ensure their long-term performance. A funding mechanism for operations and maintenance shall also be prescribed. Impact HYD-2: The proposed project would not contribute to groundwater overdraft or impair groundwater recharge. No mitigation is necessary. Less than significant impact. Impact HYD-3: The proposed project would not contribute runoff to downstream storm drainage facilities that would result in the potential for flooding. No mitigation is necessary. Less than significant impact. Impact HYD-4: The proposed project would not place housing or structures within a 100-year flood hazard area. No mitigation is necessary. Less than significant impact. Impact HYD-5: The project may be susceptible to inundation from dam failure. MM HYD-5: Prior to issuance of the first Certificate of Occupancy, the applicant shall retain a qualified consultant to prepare and implement an Emergency Evacuation Plan. The plan shall identify the various types of emergency that could affect the proposed project (e.g., dam failure, earthquake, flooding, etc.) and identify procedures for the safe and orderly evacuation of the project. The plan shall require that streets be identified with clear and visible signage and, if necessary, wayfinding signage be provided to identify exit points. Less than significant impact. Section 3.10—Land Use and Planning Impact LUP-1: The project would not conflict with any of the applicable provisions of the City of Orange General Plan. No mitigation is necessary. Less than significant impact. Impact LUP-2: The project would not conflict with the applicable provisions of the Orange Municipal Code. No mitigation is necessary. Less than significant impact.
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Executive Summary FirstCarbon Solutions ES-35 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec00-03 ExecSummary.docx Table ES-2 (cont.): Executive Summary Matrix Impacts Mitigation Measures Level of Significance After Mitigation Impact LUP-3: The project would not conflict with any applicable habitat conservation plan or natural communities conservation plan. No mitigation is necessary. Less than significant impact. Section 3.11—Mineral Resources Impact MIN-1: The proposed project would not result the in the loss of availability of a known mineral resource that would be of value to the region and the residents of the State. No mitigation is necessary. Less than significant impact. Impact MIN-2: The proposed project would not result in the loss of availability of a locally-important mineral resource recovery site delineated on a local general plan, specific plan, or other local land use plan. No mitigation is necessary. Less than significant impact. Section 3.12—Noise Impact NOI-1: The proposed project will result in exposure of persons to or generation of noise levels in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies. MM NOI-1a: To reduce potential construction noise impacts, the following multi-part mitigation measure shall be implemented for the proposed project: • The construction contractor shall ensure that all equipment driven by internal combustion engines shall be equipped with mufflers, which are in good condition and appropriate for the equipment. • The construction contractor shall locate stationary noise-generating equipment as far as possible from sensitive receptors when sensitive receptors adjoin or are near a construction project area. In addition, the project contractor shall place such stationary construction equipment so that emitted noise is directed away from sensitive receptors nearest the project site. • The construction contractor shall ensure that unnecessary idling of internal combustion engines (i.e., idling in excess of 5 minutes) is prohibited. • The construction contractor shall utilize “quiet” models of air compressors and other stationary noise sources where technology exists. • The construction contractor shall, to the maximum extent practical, locate on-site equipment staging areas to maximize the distance between construction-related noise sources and noise-sensitive receptors nearest Less than significant impact.
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Executive Summary FirstCarbon Solutions ES-36 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec00-03 ExecSummary.docx Table ES-2 (cont.): Executive Summary Matrix Impacts Mitigation Measures Level of Significance After Mitigation the project site during all project construction. • The construction contractor shall ensure that the construction staging areas shall be located to create the greatest feasible distance between the staging area and noise-sensitive receptors nearest the project site. • The construction contractor shall designate a noise disturbance coordinator who would be responsible for responding to any local complaints about construction noise. The disturbance coordinator would determine the cause of the noise complaints (starting too early, bad muffler, etc.) and establishment reasonable measures necessary to correct the problem. The construction contractor shall visibly post a telephone number for the disturbance coordinator at the construction site. • All on-site construction activities, including deliveries and engine warm-up, shall be restricted to the hours between 7:00 a.m. and 8:00 p.m. Monday through Saturday. Construction, except emergency work, shall not be permitted on Sunday or federal holidays. MM NOI-1b: To reduce potential future on-site exterior traffic noise impacts at on-site receptors adjacent to East Santiago Canyon Road, the following multi-part mitigation measure shall be implemented for the proposed project: • Based on SoundPlan model runs, a 6-foot high noise barrier, relative to the receptor elevation, is required to comply with the City’s exterior noise standard for proposed residential uses located adjacent to East Santiago Canyon Road. The calculated noise contours are shown in Exhibit 3.12 7. In order to meet the City’s exterior noise standard for community uses, a 4-foot high berm would be required along East Santiago Canyon Road; or • A minimum setback distance of 164 feet from the centerline of East Santiago Canyon Road shall be incorporated into the design feature. The first row of residential uses constructed 164 feet from the centerline will also have front yards facing East Santiago Canyon Road. MM NOI-1c: To reduce potential future on-site interior traffic noise impacts at on-site receptors adjacent to East Santiago Canyon Road, the following multi-part mitigation measure shall be implemented for the proposed project:
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Executive Summary FirstCarbon Solutions ES-37 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec00-03 ExecSummary.docx Table ES-2 (cont.): Executive Summary Matrix Impacts Mitigation Measures Level of Significance After Mitigation • All proposed residential units located within 560 feet of the centerline of East Santiago Canyon Road shall include an alternate form of ventilation, such as an air conditioning system, in order to ensure that windows can remain closed for a prolonged period of time. The building plans approved by the County shall reflect this requirement. • All second story habitable rooms of proposed residential units located within 164 feet of the centerline of East Santiago Canyon Road shall include STC 30 rated windows in facades that would be parallel and perpendicular to East Santiago Canyon Road; or, • Upon completion of the architectural plans, a detailed acoustical study shall be prepared by a qualified noise analyst that analyzes the interior noise levels of the proposed residential units and provides design features to reduce the interior noise levels to within the 45 dBA CNEL standard. Impact NOI-2: The project would not expose persons to or generation of excessive groundborne vibration or groundborne noise levels. No mitigation is necessary. Less than significant impact. Impact NOI-3: The proposed project would not result in a substantial permanent increase in ambient noise levels in the project vicinity. No mitigation is necessary. Less than significant impact. Impact NOI-4: The proposed project will result in a substantial temporary increase in ambient noise levels in the project vicinity. Implement Mitigation Measure NOI-1a. Less than significant impact. Section 3.13—Population and Housing Impact POP-1: The project would not induce substantial population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure). No mitigation is necessary. Less than significant impact.
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Executive Summary FirstCarbon Solutions ES-38 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec00-03 ExecSummary.docx Table ES-2 (cont.): Executive Summary Matrix Impacts Mitigation Measures Level of Significance After Mitigation Section 3.14—Public Services Impact PS-1: The proposed project may result in a need for new or expanded fire protection facilities. Implement Mitigation Measures HAZ-5 and HAZ-6. Less than significant impact. Impact PS-2: The proposed project would not result in a need for new or expanded police protection facilities. No mitigation is necessary. Less than significant impact. Impact PS-3: The proposed project would not result in a need for new or expanded school facilities. No mitigation is necessary. Less than significant impact. Impact PS-4: The project would not result in a need for new or expanded park facilities. No mitigation is necessary. Less than significant impact. Impact PS-5: The proposed project would not result in a need for new or expanded public facilities such as libraries. No mitigation is necessary. Less than significant impact. Section 3.15—Recreation Impact REC-1: The project would not increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated. No mitigation is necessary. Less than significant impact. Impact REC-2: The project would not include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment. No mitigation is necessary. Less than significant impact. Section 3.16—Transportation and Traffic Impact TRANS-1: The project may conflict with an applicable plan, ordinance or policy establishing measures of effectiveness for the performance of the circulation system under Existing With Project Traffic Conditions. No mitigation is necessary. Less than significant impact.
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Executive Summary FirstCarbon Solutions ES-39 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec00-03 ExecSummary.docx Table ES-2 (cont.): Executive Summary Matrix Impacts Mitigation Measures Level of Significance After Mitigation Impact TRANS-2: The project may conflict with an applicable plan, ordinance or policy establishing measures of effectiveness for the performance of the circulation system under Year 2022 Traffic Conditions. MM TRANS-2: Prior to issuance of building permits, the project applicant shall provide the City of Orange with fair share fees to restripe the northbound approach of Orange Park Boulevard at East Santiago Canyon Road to provide one exclusive left-turn lane and one shared left-turn/right-turn lane. The applicant’s fair share responsibility for these improvements is 18.2 percent. Significant and unavoidable impact. Impact TRANS-3: The project would not conflict with an applicable plan, ordinance or policy establishing measures of effectiveness for the performance of the circulation system under Year 2040 Traffic Conditions. No mitigation is necessary. Less than significant impact. Impact TRANS-4: The project would not conflict with an applicable congestion management program, including, but not limited to level of service standards and travel demand measures, or other standards established by the county congestion management agency for designated roads or highways. No mitigation is necessary. Less than significant impact. Impact TRANS-5: The project may substantially increase hazards due to a design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment). MM TRANS-5: Prior to issuance of the first certificate of occupancy, the City of Orange shall verify that the Applicant has made improvements to traffic circulation in the area and ensured that adequate ingress and egress to the project site is provided, as follows: • Project Driveway/Nicky Way at East Santiago Canyon Road: - Construct the north leg of the intersection and provide one inbound lane and two outbound lanes (i.e., one dedicated left turn lane and one shared through/right-turn lane). - Widen and/or restripe East Santiago Canyon Road to provide one eastbound left-turn lane, one westbound right-turn lane and a third westbound through-lane. - A five-phase signal has been installed with protected left-turn phasing in the east-west direction and permissive phasing in the north-south direction. • Cannon Street at Taft Avenue: - Widen and/or restripe Canon Street to provide a third northbound through lane. Less than significant impact.
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Executive Summary FirstCarbon Solutions ES-40 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec00-03 ExecSummary.docx Table ES-2 (cont.): Executive Summary Matrix Impacts Mitigation Measures Level of Significance After Mitigation Impact TRANS-6: The project would not result in inadequate emergency access. No mitigation is necessary. Less than significant impact. Impact TRANS-7: The project would not conflict with adopted policies, plans, or programs regarding public transit, bicycle, or pedestrian facilities, or otherwise decrease the performance or safety of such facilities. No mitigation is necessary. Less than significant impact. Section 3.17—Tribal Cultural Resources Impact TCR-1: The project would not cause a substantial adverse change in the significance of a tribal cultural resource listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k). No mitigation is necessary. Less than significant impact. Impact TCR-2: The project would not cause a substantial adverse change in the significance of a tribal cultural resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. No mitigation is necessary. Less than significant impact. Section 3.18—Utilities and Service Systems Impact USS-1: The proposed project would be served with adequate water supplies and would not require additional entitlements or the construction or expansion of water facilities. No mitigation is necessary. Less than significant impact.
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Executive Summary FirstCarbon Solutions ES-41 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec00-03 ExecSummary.docx Table ES-2 (cont.): Executive Summary Matrix Impacts Mitigation Measures Level of Significance After Mitigation Impact USS-2: The proposed project would be served by a wastewater treatment plant with adequate capacity and would not require the construction of new or expanded facilities. No mitigation is necessary. Less than significant impact. Impact USS-3: The proposed project would not create a need for new or expanded downstream storm drainage facilities. No mitigation is necessary. Less than significant impact. Impact USS-4: The project would be served with adequate landfill capacity and will comply with federal, state, and local statutes and regulations related to solid waste. No mitigation is necessary. Less than significant impact. Impact USS-5: The project would not result in the inefficient, unnecessary, or wasteful use of energy. No mitigation is necessary. Less than significant impact.
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SECTION 1: INTRODUCTION
On February 23, 2018, the City of Orange circulated a Draft EIR evaluating the Trails at Santiago
Creek Specific Plan for public review. Various comments were submitted during the public review
period relative to the Draft EIR, including comments related to air quality, biological resources,
greenhouse gas (GHG) emissions, hazardous materials, hydrology and water quality, land use, traffic,
and alternatives. After review of the comments, the City elected to revise and recirculate the Draft
EIR in its entirety.
The California Environmental Quality Act (CEQA) Guidelines require a lead agency to evaluate and
prepare a written response to all comments on environmental issues received on the Draft
EIR(Guidelines, § 15088(a), (d)). Such a response may take the form of a revision to the Draft EIR
(Guidelines, § 15088(d)). When a Draft EIR is substantially revised and the entire document is
recirculated, however, the lead agency only needs to respond to comments on the Recirculated Draft
EIR (RDEIR), not those received during the earlier circulation period (Guidelines, § 15088.5 (f)(1)).
Instead, the agency need only provide a summary of the revisions that were made to the previously
circulated Draft EIR (Guidelines, § 15088.5 (g)).
As such, the comments submitted during the comment period for the Trails at Santiago Creek
Specific Plan Draft EIR, dated February 23, 2018, were taken into consideration when preparing this
RDEIR, and information has been added where feasible to address pertinent comments received.
The comments submitted on the previous Draft EIR will be part of the overall administrative record
for the project; however, because this RDEIR replaces the previous Draft EIR in its entirety, written
responses will only be provided to new comments submitted on this RDEIR during the RDEIR public
comment period.
In total, the City received 130 letters during the public comment period for the previously circulated
Draft EIR. Twelve of these letters were from public agencies, and 118 from private parties. While
the preparation of this RDEIR reviewed and considered all these letters in its drafting, Table 1-1
below provides a full list of DEIR commenters. The previously circulated Notice of Availability (NOA)
and comment letters are provided in Appendix B.
Table 1-1: DEIR Comment Letters
Status Affiliation Signatory Date
Public Agencies City of Irvine Melissa Chao, Senior Planner March 9, 2018
Department of Toxic
Substances Control
Johnson P. Abraham, Program
Manager
March 20, 2018
City of Villa Park Karen Goebel, Assistant Field
Supervisors; Jonathan Snyder
March 24, 2018
Santa Ana Regional
Water Quality Control
Board
Keith Person, Regional Salt and
Nutrient Coordinator
March 28, 2018
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Table 1-1 (cont.): DEIR Comment Letters
Status Affiliation Signatory Date
Irvine Ranch Water
District
Fiona M. Sanchez, Director of Water
Resources
April 5, 2018
OC Public Works Richard Vuong, Manager April 5, 2018
OC Health Care Agency Ossama Abu Shaban, Senior Civil
Engineer
April 6, 2018
Orange County
Transportation Authority
Dan Phu, Environmental Programs
Manager
April 6, 2018
California Department of
Fish and Wildlife
Gail K. Sevrens, Environmental
Program Manager
April 9, 2018
OC Waste and Recycling Jeff Arbour, Environmental Services
Manager
April 9, 2018
Orange County Water
District
Michael R. Markus, General Manager April 9, 2018
Transportation Corridor
Agencies
Virginia Gomez, Environmental
Planner
April 9, 2018
Private Parties Private Citizen Ann-Mari Kliss March 4, 2018
April 8, 2018
Private Citizen Donna Elliot March 6, 2018
Private Citizen Jennifer Pirt March 7, 2018
Private Citizen Sun-Sun Murillo March 9, 2018
Private Citizen Ann and Rob Forbes March 14, 2018
Private Citizen Mark Maize March 14, 2018
Private Citizen Kelly Herbeck March 18, 2018
Private Citizen Toni Bradley March 22, 2018
Private Citizen Laurie Marine March 22, 2018
Private Citizen Ron Doyle March 23, 2018
Private Citizen Steve Ducolon March 23, 2018
April 2, 2018
April 9, 2018
Private Citizen Lucy Busby March 24, 2018
Private Citizen Bonnie Robinson March 25, 2018
March 26, 2018
Private Citizen Greg Cygan March 27, 2018
Private Citizen Robert Hoff March 27, 2018
Private Citizen Ken Kribel March 27, 2018
Private Citizen Brian Lochrie March 27, 2018
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Table 1-1 (cont.): DEIR Comment Letters
Status Affiliation Signatory Date
Private Citizen Sharon Mule March 27, 2018
Private Citizen Peter Piferi March 27, 2018
Private Citizen Joanne Pritts March 27, 2018
Private Citizen Antoinette Baker March 29, 2018
Private Citizen Jane Canseco March 29, 2018
Private Citizen Carol Cora March 29, 2018
Private Citizen David Swoish March 29, 2018
Private Citizen Howard Rothfender April 1, 2018
Private Citizen Jerry Bohr April 2, 2018
Santiago Creek
Greenway Alliance
John Moore, President
Pamela Galera, Vice President
April 2, 2018
Private Citizen Joel Robinson April 4, 2018
Private Citizen David Bogardus April 5, 2018
Private Citizen Jeremy J. Clark April 5, 2018
Private Citizen Michelle Gregory April 5, 2018
Private Citizen Diane Kelley April 5, 2018
Private Citizen Lance Mora April 5, 2018
Private Citizen Kim Plehn April 5, 2018
Private Citizen Heather Allen April 6, 2018
Private Citizen Michael A. Forkert April 6, 2018
Private Citizen David Hillman April 6, 2018
April 8, 2018
April 8, 2018
Private Citizen Vickie Homer April 6, 2018
Private Citizen Donna Hooker April 6, 2018
Respect Orange Adam L. Duberstein, Founder April 6, 2018
Private Citizen Dan Graupensperger April 7, 2018
Private Citizen Martha Wetzel April 7, 2018
Private Citizen Kathy Spain Bonnaud April 8, 2018
California Cultural
Resource Preservation
Alliance, Inc.
Patricia Martz, President April 8, 2018
Private Citizen Patricia Closson April 8, 2018
Private Citizen Doug Cohen April 8, 2018
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Table 1-1 (cont.): DEIR Comment Letters
Status Affiliation Signatory Date
Private Citizen Steve and Jane Elmers April 8, 2018
Private Citizen Carla French April 8, 2018
Friends of Harbors,
Parks, Beaches and Parks
Michael Wellborn, President April 8, 2018
Private Citizen Sarah Huff April 8, 2018
April 9, 2018
Private Citizen Vee Kay April 8, 2018
Private Citizen Katrina Kirkeby April 8, 2018
Private Citizen Bob Kirkeby April 8, 2018
Private Citizen Frank Lesinski April 8, 2018
Private Citizen Stephanie Lesinski April 8, 2018
Private Citizen Eric Noble April 8, 2018
Private Citizen Ellen Richards April 8, 2018
Private Citizen Emilia Sugiyama April 8, 2018
Private Citizen Synde Sutherland April 8, 2018
Private Citizen Maria von Sprecken April 8, 2018
Private Citizen William Wimberly April 8, 2018
Private Citizen Addison Addams April 9, 2018
Private Citizen Scott Armstrong April 9, 2018
Private Citizen Kathy Ashford April 9, 2018
Private Citizen Brad Banks April 9, 2018
Private Citizen Debra Banks April 9, 2018
Private Citizen Michael Bonnaud April 9, 2018
Private Citizen Thomas A. Broz April 9, 2018
Private Citizen Jean Buckley April 9, 2018
Private Citizen James Cathcart April 9, 2018
Private Citizen Eric Christiansen April 9, 2018
Private Citizen Cindy Cousine April 9, 2018
Private Citizen Tom Davidson April 9, 2018
Private Citizen Charlene Davis April 9, 2018
Private Citizen Larry Day April 9, 2018
Private Citizen Joy DeGroot April 9, 2018
Private Citizen Rich Dobson April 9, 2018
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Table 1-1 (cont.): DEIR Comment Letters
Status Affiliation Signatory Date
Private Citizen Sonya Evans April 9, 2018
Private Citizen Arlene Finke April 9, 2018
Private Citizen Hollis Fitz April 9, 2018
Private Citizen Chris Flathers April 9, 2018
Private Citizen Joy Fletcher April 9, 2018
Private Citizen Roberta Granek April 9, 2018
Private Citizen Carrie Hale April 9, 2018
Private Citizen Barbara Higgins-Dargahi April 9, 2018
Private Citizen Peter Jacklin April 9, 2018
Private Citizen Nick Lall April 9, 2018
Private Citizen Kimiya Leuteritz April 9, 2018
Private Citizen Julie Maurer April 9, 2018
April 9, 2018
Private Citizen Leigh McDonough April 9, 2018
Private Citizen Deborah M. Mongan April 9, 2018
Private Citizen Paul Noesser April 9, 2018
PEDal Brenda Miller, Founder April 9, 2018
Private Citizen Jason Phlaum April 9, 2018
April 9, 2018
Private Citizen Tom Rappot April 9, 2018
Private Citizen Sharon G. Seelert April 9, 2018
Private Citizen Gloria Sefton April 9, 2018
Private Citizen Julia Bailey-Serres April 9, 2018
Shute, Mihaly, and
Weinberger LLP
Laura L. Impett, Urban Planner April 9, 2018
Sully Millar Liaison
Committee
Sully Miller Liaison Committee April 9, 2018
Private Citizen Theresa Sears April 9, 2018
Private Citizen Laura Thomas April 9, 2018
Private Citizen Debra Tous April 9, 2018
Private Citizen Brian Trevino April 9, 2018
Private Citizen Ussalesgw April 9, 2018
Private Citizen Matt Wagner April 9, 2018
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Table 1-1 (cont.): DEIR Comment Letters
Status Affiliation Signatory Date
Private Citizen Avriel Webb April 9, 2018
Private Citizen Peter J. Wetzel April 9, 2018
Private Citizen Thomas Walsh April 10, 2018
Table 1-2 and Table 1-3 below provide a summary of key areas where the document was revised to
address pertinent and representative comments made during the prior public review period. Please
note that the tables provide a representative list of sections revised stemming from specific
comments received, compiled to not be repetitive in the types of comments, and do not include
minor text revisions throughout the document.
Edits to specific sections include, but are not limited to, the following:
• Section 2: Project Description, revised to reflect changes to the proposed project,
additionally, now includes a site plan exhibit, which shows the potential layout of the 128
parcels, Exhibit 2-10: Proposed Site Plan.
• Section 3-3: Air Quality, revised to reflect new modeling that was conducted for
grading/excavation activities, and identification of significant and unavoidable impacts, and
mitigation measures.
• Section 3-4: Biological Resources, revised to reflect changes to the proposed trails component
of the project.
• Section 3-7: Greenhouse Gas Emissions, revised language throughout the section to provide
background information and clarity, including a new consistency analysis with the State of
California Air Resources Board’s AB 32 2008 Scoping Plan.
• Section 3-8: Hazards, revised to provide more clarity in the mitigation measures, particularly
the addition of language in MM HAZ-2b regarding mitigation for potentially hazardous soils.
• Section 3-9: Hydrology and Water Quality, revised to provide more clarity in the mitigation
measures, particularly the addition of language in MM HYD-1b regarding the inclusion of low
impact development features.
• Section 3-10: Land Use, updated to include information on the established concept of
clustering within the Orange Park Acres Plan and revised to include City of Orange Zoning
Code Development Standards that the proposed project would adhere.
• Section 3-11: Mineral Resources, revised to include background information on the Surface
Mining and Reclamation Act of 1975’s non-applicability to the project site.
• Section 3-16: Transportation, revised to provide a comparison between baseline traffic
conditions. As the project site’s existing entitled land use is currently dormant, but operations
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can commence at any given moment, the section was revised to include baselines with and
without site operation conditions. Additionally, Impact TRANS-2 has been updated to reflect
significant and unavoidable impacts, despite the proposed project’s fair share contribution,
provided through Mitigation Measure TRANS-2.
• Section 5: Alternatives, revised to remove the Land Use Plan/OPA 2008 “WIN-WIN”
Alternative, per public comments. Additionally, two new alternatives were added, the
Collaborative Group Alternative, consisting of 47 lots on 40 acres, and the 122-Unit
Alternative.
• Section 6: Other CEQA Considerations, 6-1—Significant Unavoidable Impacts, has been
updated to reflect Significant and Unavoidable Impacts to Impact AIR-1, AIR-2, AIR-3, and
TRANS-2; as analyzed in the updated Section 3-3: Air Quality and Section 3-16: Transportation.
Table 1-2: RDEIR Revision Summary Table, Public Agencies
Commenter Name Document Location
California Department of Fish and Wildlife Section 3-4: Biological
Resources
City of Irvine Section 3-16: Transportation
Department of Toxic Substances Control Section 3-8: Hazards
Section 3-9: Hydrology and
Water Quality
OC Health Care Agency Section 3-8: Hazards
OC Waste and Recycling Section 3-8: Hazards
OC Public Works Section 3-9: Hydrology and
Water Quality
Orange County Transportation Authority Section 3-16: Transportation
Orange County Water District Section 3-9: Hydrology and
Water Quality
Santa Ana Regional Water Quality Control
Board
Section 3-9: Hydrology and
Water Quality
Table 1-3: RDEIR Revision Summary Table, Private Parties
Commenter Name Document Location
City of Orange Sully Miller Liaison Committee Section 2: Project Description
Section 3-10: Land Use
Section 3-16: Transportation
Section 5: Alternatives
PEDal Section 3-16: Transportation
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Table 1-3 (cont.): RDEIR Revision Summary Table, Private Parties
Commenter Name Document Location
Peter Jacklin, Chairman of Orange Park
Association Traffic Committee
Section 2: Project Description
Section 3-11: Mineral
Resources
Section 3-16: Transportation
Peter Wetzel Section 3-9: Hydrology and
Water Quality
Section 5: Alternatives
Respect Orange Section 2: Project Description
Section 3-16: Transportation
Santiago Creek Greenway Alliance Section 2: Project Description
Shute, Mihaly, and Weinberger LLP, on behalf
of Orange Park Association
Section 3-3: Air Quality
Section 3-7: Greenhouse Gas
Emissions
Section 3-11: Mineral
Resources
Section 3-10: Land Use
Section 5: Alternatives
Stephanie Lesinski Section 2: Project Description
Theresa Sears Section 2: Project Description
Section 3-10: Land Use
Section 3-11: Mineral
Resources
Section 5: Alternatives
Tom Davidson Section 2: Project Description
Section 3-10: Land Use
This RDEIR is prepared in accordance with CEQA to evaluate the potential environmental impacts
associated with the implementation of the Trails at Santiago Creek Specific Plan (State Clearinghouse
No. 2017031020). This document is prepared in conformance with CEQA (California Public
Resources Code, Section 21000, et seq.) and the State CEQA Guidelines (California Code of
Regulations, Title 14, Section 15000, et seq.), and City of Orange rules and regulations. This RDEIR is
intended to serve as an informational document for the public agency decision-makers and the
public regarding the project.
The purpose of the RDEIR is to disclose information to the public and to the decision-makers about
the potential environmental effects of the project. An EIR does not recommend either approval or
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denial of a project; rather, it is intended to provide a source of independent and impartial analysis of
the foreseeable environmental impacts of a proposed course of action. This RDEIR describes the
project, analyzes its environmental effects, and discusses reasonable alternatives that would avoid,
reduce, or minimize environmental impacts.
1.1.1 - Overview
The proposed project consists of 128 single-family residential dwelling units on approximately 40.7
acres of the approximately 109.2-acre site. The majority of the project site (approximately 62.7
percent) is intended for the enhancement and preservation of the natural greenway/open space and
Santiago Creek environs, as well as re-establishing open grasslands in areas that have been denuded
by the project site’s history of commercial operations, totaling approximately 69 acres. Recreational
trails will provide public access to the enhanced revegetated interior of the site.
Section 2, Project Description provides a complete description of the project, and an expanded
discussion of the entitlement process in the forward to this document.
1.1.2 - Purpose and Authority
This RDEIR provides a project-level analysis of the environmental effects of the Trails at Santiago Creek
Specific Plan. The environmental impacts of the proposed project are analyzed in the EIR to the degree
of specificity appropriate, in accordance with CEQA Guidelines Section 15146. Moreover, in accordance
with CEQA Guidelines Section 15151, this EIR has been prepared with a sufficient degree of analysis
to provide decision makers with information that enables them to make a decision which
intelligently takes account of environmental consequences.
In accordance with CEQA Guidelines Section 15161, this document focuses primarily on the changes in
the environment that would result from the development project. The EIR examines all phases of the
project including planning, construction, and operation, and identifies appropriate and feasible
mitigation measures and alternatives that may be adopted to significantly reduce or avoid these
impacts. CEQA requires that an EIR contain, at a minimum, certain specific elements. In accordance
with CEQA Guidelines Section 15120 through 15130, these elements are contained in this RDEIR and
include:
• Table of Contents
• Introduction
• Executive Summary
• Project Description
• Environmental Setting, Significant Environmental Impacts, and Mitigation Measures
• Cumulative Impacts
• Significant Unavoidable Adverse Impacts
• Alternatives to the Proposed Project
• Growth-Inducing Impacts
• Effects Found Not To Be Significant
• Areas of Known Controversy
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1.1.3 - Lead Agency Determination
The City of Orange is designated as the lead agency for the project. CEQA Guidelines Section 15367
defines the lead agency as “. . . the public agency, which has the principal responsibility for carrying
out or approving a project.” Other public agencies may use this RDEIR in the decision-making or
permit process and consider the information in this RDEIR along with other information that may be
presented during the CEQA process.
This RDEIR was prepared by FirstCarbon Solutions (FCS), an environmental consultant. This Draft EIR
reflects the independent judgment and analysis of the City of Orange as required by CEQA. Lists of
organizations and persons consulted and the report preparation personnel are provided in Section 8 of
this RDEIR.
1.2 - Scope of the EIR
In compliance with the CEQA Guidelines, the City of Orange has provided opportunities for the public
and other public agencies to participate in the review process, including the Notice of Preparation
(NOP), Scoping Meeting, and NOA.
This RDEIR addresses the potential environmental effects of the proposed project. The City of Orange
issued a NOP for the proposed project on March 3, 2017, which circulated between March 3, 2017 and
April 3, 2017 for the statutory 30-day public review period. The scope of this RDEIR includes the
potential environmental impacts identified in the NOP and issues raised by agencies and the public in
response to the NOP. The NOP is contained in Appendix C of this RDEIR.
Eighty-one comment letters were received in response to the NOP. They are listed in Table 1-4 and
provided in Appendix C of this RDEIR.
Table 1-4: NOP Comment Letters
Status Affiliation Signatory Date
Public
Agencies
South Coast Air Quality
Management District
Lijin Sun, CEQA IGR Program Supervisor March 17, 2017
California Department of
Fish and Wildlife
Jennifer Turner, Environmental Scientist March 23, 2017
United States Fish and
Wildlife Service
Karen Goebel, Assistant Field Supervisors;
Jonathan Snyder
March 24, 2017
OC Waste and Recycling Jeff Arbour, Environmental Services
Manager
March 29, 2017
Irvine Ranch Water District Fiona Sanchez, Director of Water Resources March 31, 2017
OC Public Works Laree Alonso, Planning Division Manager March 31, 2017
California Department of
Fish and Wildlife
Gail Sevrens, Environmental Program Manager April 3, 2017
City of Anaheim Christine Saunders, Associate Planner April 3, 2017
City of Irvine Bill Jacobs, Principal Planner April 3, 2017
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Table 1-4 (cont.): NOP Comment Letters
Status Affiliation Signatory Date
Orange County Water
District
Gary Woodside, Executive Director of
Planning and Natural Resources
April 3, 2017
Private
Parties
Private Citizens Donna Elliot and Brian Elliot March 12, 2017
Private Citizens Robert Brunner and Kathleen Brunner March 13, 2017
Private Citizen Joel Robinson March 14, 2017
Private Citizen Allyson Ascher March 16, 2017
Private Citizen Bonnie Robinson March 16, 2017
Private Citizens Robert Wagner and Nancy Wagner March 16, 2017
Santiago Creek Greenway
Alliance
John Moore, President; Pamela Galera, Vice
President March 17, 2017
Private Citizen Michael Granek March 17, 2017
Private Citizens Carol Graupensperger and Dan
Graupensperger March 17, 2017
Private Citizens Ron Rothschild and Jane Rothschild March 17, 2017
Private Citizen Gary Wright March 17, 2017
Private Citizen David Bailey March 18, 2017
Private Citizen Kelly Herbeck March 19, 2017
Private Citizen Leisha Fauth March 21, 2017
Private Citizens Ann Forbes and Bob Forbes March 21, 2017
Private Citizen Brandon Herbeck March 21, 2017
Orange Park Acres Traffic
Committee Peter Jacklin, Chair March 21, 2017
Private Citizen Peter Piferi March 21, 2017
Private Citizen Barbie Stevenson March 21, 2017
Private Citizens Kathy Corrigan and Mike Sole March 23, 2017
Private Citizen Robert Hoff March 23, 2017
Private Citizen Danielle King March 23, 2017
Private Citizen Mark Maize March 23, 2017
Private Citizen Jennifer Pirt March 23, 2017
Private Citizen Rosemarie Reynolds March 23, 2017
Private Citizen Angela Knarr March 24, 2017
Private Citizen Joy Feltcher (2) March 25, 2017
Private Citizen Frank Lesinski March 26, 2017
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Table 1-4 (cont.): NOP Comment Letters
Status Affiliation Signatory Date
Private Citizen Paul Andrews March 27, 2017
Private Citizen Carol Cora March 29, 2017
Private Citizen Barbara Hillman March 29, 2017
Private Citizen Charles Hillman March 29, 2017
Private Citizen David Hillman March 29, 2017
Private Citizen LeRoy Pendray March 30, 2017
Private Citizen Frances Bauer March 30, 2017
Private Citizen Cindy Davidson March 31, 2017
Private Citizen Ann-Mari Kliss March 31, 2017
Private Citizen Reggie Mundekis March 31, 2017
Private Citizen Jerry Bohr April 1, 2017
Private Citizen Nick Lall April 1, 2017
Private Citizen Julie Maurer April 1, 2017
Private Citizens Bill Quarton and Lori Quarton April 1, 2017
Private Citizen Tom Rapport April 1, 2017
Private Citizen Elise Roberts April 1, 2017
Private Citizen Michael Bonnaud April 2, 2017
Private Citizen Steve Ducolon April 2, 2017
Private Citizen Nancy Flathers April 2, 2017
Private Citizen Randall Hillman April 2, 2017
Mabury Ranch Homeowners
Association Dick Hollinger, President April 2, 2017
Private Citizens Bob Kirkeby and Katrina Kirkeby April 2, 2017
Private Citizen Ken Kribel April 2, 2017
Private Citizen Dawn Robinette April 2, 2017
Private Citizen Kate Spain April 2, 2017
Private Citizen Gary Wright April 2, 2017
City of Orange Sully Miller
Liaison Committee
Tom Davidson, Theresa Sears, Nick Lall,
Stephanie Lesinski, Addison Adams, Dan
Martin
April 3, 2017
Private Citizen Don Bradley April 3, 2017
Private Citizen Toni Bradley April 3, 2017
Private Citizen Victoria Coonradt April 3, 2017
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Table 1-4 (cont.): NOP Comment Letters
Status Affiliation Signatory Date
Private Citizen Tom Davidson April 3, 2017
Private Citizens Tom French and Carla French April 3, 2017
Private Citizen Michelle Gregory April 3, 2017
Shute, Mihaly and
Weinberger LLP Laurel Impett, Urban Planner April 3, 2017
Private Citizen Suzanne Kiel April 3, 2017
Private Citizen Peter Masuck April 3, 2017
Private Citizens Susan Philipp and James Philipp April 3, 2017
Private Citizen Theresa Sears April 3, 2017
Friends of Harbors, Beaches,
and Parks Gloria Sefton, Vice President April 3, 2017
Private Citizen Laura Thomas April 3, 2017
Private Citizen Martha Wetzel April 3, 2017
Private Citizen [No Name Provided] April 3, 2017
Source: City of Orange, 2017.
1.2.1 - Scoping Meeting
Pursuant to CEQA Guidelines Section 15082(c)(1), the City of Orange held a public scoping meeting
for the proposed project on Thursday, March 16, 2017, at Salem Lutheran Church and School, 6500
East Santiago Canyon Road, Orange, CA 92869. The meeting was duly noticed in the NOP that was
posted on the City’s website and directly mailed to public agencies and private parties. The scoping
meeting sign-in sheet is provided in Appendix C. Table 1-5 provides the names of attendees to the
scoping meeting.
Table 1-5: Scoping Meeting Attendees
Paul Andrews Joy Feltcher Bob Kirkeby Rosemarie Reynolds
Allyson Ascher Nancy Flathers Katrina Kirkeby Elise Roberts
David Bailey Ann Forbes Ann-Mari Kliss Dawn Robinette
Frances Bauer Bob Forbes Angela Knarr Bonnie Robinson
Jerry Bohr Carla French Ken Kribel Joel Robinson
Don Bradley Tom French Nick Lall Jane Rothschild
Toni Bradley Michael Granek Frank Lesinski Ron Rothschild
Michael Bonnaud Carol Graupensperger Mark Maize Theresa Sears
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Table 1-5 (cont.): Scoping Meeting Attendees
Kathleen Brunner Dan Graupensperger Peter Masuck Mike Sole
Robert Brunner Michelle Gregory Julie Maurer Kate Spain
Victoria Coonradt Brandon Herbeck Reggie Mundekis Barbie Stevenson
Carol Cora Kelly Herbeck LeRoy Pendray Laura Thomas
Kathy Corrigan Barbara Hillman Susan Philipp Nancy Wagner
Cindy Davidson Charles Hillman James Philipp Robert Wagner
Tom Davidson David Hillman Peter Piferi Martha Wetzel
Steve Ducolon Randall Hillman Jennifer Pirt Gary Wright
Brian Elliot Robert Hoff Bill Quarton
Donna Elliot Suzanne Kiel Lori Quarton
Leisha Fauth Danielle King Tom Rapport
Source: FCS, 2017.
1.2.2 - Environmental Issues Determined not to be Significant
Certain subjects with various topical areas were determined not to be significant. Other potentially
significant issues are analyzed in these topical areas; however, the following issues are not analyzed:
• State Scenic Highways (Section 3.1, Aesthetics, Light, and Glare)
• Septic and Alternative Wastewater Disposal Systems (Section 3.6, Geology and Soils)
• Airports (Section 3.8, Hazards and Hazardous Materials)
• Private Airstrips (Section 3.8, Hazards and Hazardous Materials)
• Seiches, Tsunamis, or Mudflows (Section 3.9, Hydrology and Water Quality)
• Division of an Established Community (Section 3.10, Land Use and Planning)
• Aviation Noise (Section 3.12, Noise)
• Displacement of Persons or Housing (Section 3.12, Population and Housing)
• Air Traffic Patterns (Section 3.16, Transportation and Traffic)
An explanation of why each issue is determined not to be significant is provided in Section 7, Effects
Found not to be Significant.
1.2.3 - Potentially Significant Environmental Issues
The NOP found that the following topical areas may contain potentially significant environmental
issues that will require further analysis in the RDEIR. These sections are as follows:
• Aesthetics, Light, and Glare
• Agriculture Resources and Forestry Resources
• Air Quality
• Land Use and Planning
• Mineral Resources
• Noise
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• Biological Resources
• Cultural Resources
• Geology and Soils
• Greenhouse Gas Emissions
• Hazards and Hazardous Materials
• Hydrology and Water Quality
• Population and Housing
• Public Services
• Recreation
• Transportation and Traffic
• Tribal Cultural Resources
• Utilities and Service Systems
1.3 - Organization of the RDEIR
This RDEIR is organized into the following main sections:
• Section ES: Executive Summary. This section includes a summary of the proposed project and
alternatives to be addressed in the RDEIR. A brief description of the areas of controversy and
issues to be resolved, and overview of the Mitigation Monitoring and Reporting Program, in
addition to a table that summarizes the impacts, mitigation measures, and level of significance
after mitigation, are also included in this section.
• Section 1: Introduction. This section provides an introduction and overview describing the
purpose of this RDEIR, its scope and components, and its review and certification process.
• Section 2: Project Description. This section includes a detailed description of the proposed
project, including its location, site, and project characteristics. A discussion of the project
objectives, intended uses of the RDEIR, responsible agencies, and approvals that are needed
for the proposed project are also provided.
• Section 3: Environmental Impact Analysis. This section analyzes the environmental impacts
of the proposed project. Impacts are organized into major topic areas. Each topic area
includes a description of the environmental setting, methodology, significance criteria,
impacts, mitigation measures, and significance after mitigation. The specific environmental
topics that are addressed within Section 3 are as follows:
- Section 3.1—Aesthetics, Light, and Glare: Addresses the potential visual impacts of
development intensification and the overall increase in illumination produced by the project.
- Section 3.2—Agriculture Resources and Forest Resources: Addresses the potential for
conversion of Important Farmland to non-agricultural use and forest land to non-forest use.
- Section 3.3—Air Quality Addresses the potential air quality impacts associated with project
implementation, as well as consistency with the South Coast Air Quality Management
District’s Air Quality Management Plan. In addition, the section also evaluates project
emissions of criteria pollutants and the potential for objectionable odors.
- Section 3.4—Biological Resources: Addresses the project’s potential impacts on habitat,
vegetation, and wildlife; the potential degradation or elimination of important habitat; and
impacts on listed, proposed, and candidate threatened and endangered species.
- Section 3.5—Cultural Resources: Addresses potential impacts on historical resources,
archaeological resources, paleontological resources, and burial sites.
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- Section 3.6—Geology and Soils: Addresses the potential impacts the project may have on
soils and assesses the effects of project development in relation to geologic and seismic
conditions.
- Section 3.7—Greenhouse Gas Emissions: Addresses the potential emissions of greenhouse
gases (GHG).
- Section 3.8—Hazards and Hazardous Materials: Addresses the potential for the presence of
hazardous materials or conditions on the project site and in the project area that may have
the potential to impact human health.
- Section 3.9—Hydrology and Water Quality: Addresses the potential impacts of the project
on local hydrological conditions, including drainage areas, and changes in the flow rates.
- Section 3.10—Land Use and Planning: Addresses the potential land use impacts associated
with division of an established community and consistency with the City of Orange General
Plan and Orange Municipal Code.
- Section 3.11—Mineral Resources: Addresses the potential loss of mineral resources of
statewide or regional importance.
- Section 3.12—Noise: Addresses the potential noise impacts during construction and at
project buildout from mobile and stationary sources. The section also addresses the impact
of noise generation on neighboring uses.
- Section 3.13—Population and Housing: Addresses the potential for growth inducement.
- Section 3.14—Public Services: Addresses the potential impacts upon public services,
including fire protection, law enforcement, schools, parks, and recreational facilities.
- Section 3.15—Recreation: Addresses the potential for physical deterioration of recreation
facilities.
- Section 3.16—Transportation and Traffic: Addresses the impacts on the local and regional
roadway system, public transportation, bicycle, and pedestrian access.
- Section 3.17—Tribal Cultural Resources: Addresses potential impacts on tribal cultural
resources.
- Section 3.18—Utilities and Services Systems: Addresses the potential impacts upon service
providers, including fire protection, law enforcement, water supply, wastewater, solid waste,
and energy providers.
• Section 4: Cumulative Effects. This section discusses the cumulative impacts associated with
the proposed project, including the impacts of past, present, and probable future projects.
• Section 5: Alternatives to the Proposed Project. This section compares the impacts of the
proposed project with four land-use project alternatives: Development within the Existing
Land Use Designations Alternative, No Project Alternative/Existing Land Use Activities
Alternative, Collaborative Group Alternative, and 122-Unit Alternative. An environmentally
superior alternative is identified. In addition, alternatives initially considered but rejected
from further consideration are discussed.
• Section 6: Other CEQA Considerations. This section provides a summary of significant
environmental impacts, including unavoidable and growth-inducing impacts. This section
discusses the cumulative impacts associated with the proposed project, including the impacts
of past, present, and probable future projects. In addition, the proposed project’s energy
demand is discussed.
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• Section 7: Effects Found Not To Be Significant. This section contains analysis of the topical
sections not addressed in Section 3.
• Section 8: Persons and Organizations Consulted/List of Preparers. This section also contains
a full list of persons and organizations that were consulted during the preparation of this
RDEIR. This section also contains a full list of the authors who assisted in the preparation of
the RDEIR, by name and affiliation.
• Section 9: References. This section contains a full list of references that were used in the
preparation of this RDEIR.
• Appendices. This section includes all notices and other procedural documents pertinent to
the RDEIR, as well as all technical material prepared to support the analysis.
1.4 - Documents Incorporated by Reference
As permitted by CEQA Guidelines Section 15150, this RDEIR has referenced several technical studies,
analyses, and previously certified environmental documentation. Information from the documents,
which have been incorporated by reference, has been briefly summarized in the appropriate
section(s). The relationship between the incorporated part of the referenced document and the
RDEIR has also been described. The documents and other sources that have been used in the
preparation of this RDEIR include but are not limited to:
• City of Orange General Plan
• City of Orange Municipal Code
• City of Orange 2015 Urban Water Management Plan
• City of Orange Recreational Trails Master Plan
• City of Orange Sewer Master Plan
These documents are specifically identified in Section 9, References, of this RDEIR. In accordance
with CEQA Guidelines Section 15150(b), the General Plan, the Municipal Code, the Urban Water
Management Plan, and the referenced documents and other sources used in the preparation of the
RDEIR are available for review at the City of Orange Community Development Department at the
address shown in Section 1.6.
1.5 - Documents Prepared for the Project
The following technical studies and analyses were prepared for the proposed project:
• Air Quality and GHG Emissions Analysis, prepared by FCS (modeling output is provided in
Appendix F).
• Biological Resources Assessment, prepared by PCR Services (Appendix G)
• Jurisdictional Delineation, prepared by PCR Services (Appendix G)
• Tree Survey, prepared by PCR Services (Appendix G)
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• Phase I Cultural Resources Assessment and Paleontological Records Review, prepared by
Michael Brandman Associates (Appendix H)
• Addendum to the Phase I Cultural Resources Assessment, prepared by BCR Consulting
(Appendix H)
• Updated Native American Consultation for the Rio Santiago Specific Plan Project prepared by
BCR Consulting (Appendix H)
• Geotechnical Investigation prepared by Ginter and Associates, Inc. (Appendix I)
• Phase I Environmental Site Assessment, prepared by Michael Brandman Associates (Appendix J)
• Phase II Environmental Site Assessment, prepared by Tait Environmental Services (Appendix J)
• Hydrologic Assessment Report, prepared by Fuscoe Engineering, Inc. (Appendix K)
• Water Quality Technical Report, prepared by Fuscoe Engineering, Inc. (Appendix K)
• Noise Analysis, prepared by FCS (modeling output is provided in Appendix N)
• Traffic Impact Analysis prepared by Linscott, Law, and Greenspan, Engineers (Appendix P)
• Trails at Santiago Creek Specific Plan (Appendix Q)
1.6 - Review of the RDEIR
Upon completion of the RDEIR, the City of Orange filed a Notice of Completion (NOC) with the State
Office of Planning and Research to begin the public review period (Public Resources Code, Section
21161). Concurrent with the NOC, this RDEIR has been distributed to responsible and trustee
agencies, other affected agencies, surrounding cities, and interested parties, as well as all parties
requesting a copy of the RDEIR in accordance with Public Resources Code 21092(b)(3). During the
public review period, the RDEIR, including the technical appendices, is available for review at the City
of Orange Community Development Department, the Orange Public Library, El Modena Branch
Library, and Taft Branch Library; as well as online. The address for each location is provided below.
City of Orange
Community Development Department
Planning Division
300 East Chapman Avenue
Orange, CA 92866
Hours:
Monday–Thursday: 7:30 a.m. to 5:30 p.m.
Orange Public Library
407 East Chapman Avenue
Orange, CA 92866
Hours:
Monday–Wednesday: 10:00 a.m. to 9:00 p.m.
Thursday–Saturday: 10:00 a.m. to 6:00 p.m.
El Modena Branch Library
300 South Hewes Street
Orange, CA 92869
Hours:
Monday–Wednesday: 2:00 p.m. to 7:00 p.m.
Thursday–Saturday: 1:00 p.m. to 6:00 p.m.
Taft Branch Library
740 East Taft Avenue
Orange, CA 92865
Hours:
Monday–Wednesday: 2:00 p.m. to 7:00 p.m.
Thursday–Saturday: 1:00 p.m. to 6:00 p.m.
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Online at the City of Orange website at:
http://www.cityoforange.org/292/Project-NoticesRelated-Environmental-Doc
Agencies, organizations, and interested parties have the opportunity to comment on the RDEIR
during the 45-day public review period. Written comments on this RDEIR should be addressed to:
Mr. Robert Garcia, Senior Planner
City of Orange
Community Development Department, Planning Division
300 East Chapman Avenue
Orange, CA 92866
Phone: 714.744.7231
Fax: 714.744.7222
Email: rgarcia@cityoforange.org
Submittal of electronic comments in Microsoft Word or Adobe PDF format is encouraged. Upon
completion of the public review period, written responses to all significant environmental issues
raised will be prepared and made available for review by the commenting agencies at least 10 days
prior to the Planning Commission public hearing. The Orange City Council will ultimately consider
the comments and responses during its publics hearing for the Final EIR. All comments received and
the responses to comments will be included as part of the record for consideration by decision
makers for the project.
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SECTION 2: PROJECT DESCRIPTION
As indicated in Section 1, Introduction, this Recirculated Draft Environmental Impact Report (RDEIR)
has been prepared in accordance with the California Environmental Quality Act (CEQA) (Pub. Res.
Code Section 21000, et seq.) to evaluate the potential environmental impacts associated with the
Trails at Santiago Creek Specific Plan.
2.1 - Project Location and Setting
2.1.1 - Location
The project is located within the City of Orange, in north-central Orange County. The site is generally
located to the east of State Route 55 (SR-55); to the west of SR-261; approximately 2 miles to the
north of Chapman Avenue; on the north side of East Santiago Canyon Road, between Orange Park
Boulevard on the east and Cannon Street on the west; and south of Mabury Avenue. The site
address is 6118 East Santiago Canyon Road (see Exhibit 2-1 and Exhibit 2-2). The project site is
located on the Orange, California 7.5-minute quadrangle, Township 4 South, Range 9 West, Section
23 (Latitude 33° 48’ 55” North; Longitude 117° 47’ 17” West).
2.1.2 - Existing Land Use Activities
The approximately 109.2-acre project site contains disturbed/undisturbed, privately owned
undeveloped land that supported mining activities and currently supports a historically
grandfathered land use sand and gravel operation in accordance with the existing Sand and Gravel
zoning (Orange Municipal Code Chapter 17.32). The project site consists of 12 parcels (Exhibit 2-3)
and is bisected by Santiago Creek in an east-west direction. The site contains gently sloping terrain,
with an overall change in elevation from 456 feet above mean sea level in the northeast corner to
344 feet above mean sea level in the southwest corner. An approximately 10-acre, semi-oval-
shaped raised pad is located in the eastern portion of the site. The pad sits roughly 15 feet higher
than the mining area to the west.
Aerial photographs of the project site and area show that approximately 40 acres between Santiago
Creek and East Santiago Canyon Road contains remnants of the mining operation and is the location
of the ongoing sand and gravel operation. This area is characterized by soil piles and berms,
unpaved roads. An approximately 5-acre area near East Santiago Canyon Road supports a materials
recycling operation that includes apparatus for crushing boulders, bricks, rocks, and similar materials
for recycling. Materials used for these operations originated primarily from off-site sources and the
materials generated by these operations have historically been used both on-site and transported
off-site. Ancillary uses included administration and maintenance buildings, caretaker residence,
material testing laboratory, driver’s shack, rock crushing facilities, several above ground and below
ground fuel storage tanks and two hot-mix asphalt plants.
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Additionally, the previously mined portions of the site were “backfilled,” in which unsuitable materials
were excavated and replaced with fill, pursuant to a grading permit1 issued by the City of Orange in
2011. It was anticipated that approximately 223,000 cubic yards of material would be imported to the
site during the process, including concrete, asphalt and rock that would be crushed on-site.
Approximately 2,000 cubic yards of material was anticipated to be excavated from the site for reuse
and would be blended with the crushed import material for a total of 225,000 cubic yards of backfill.
In 2015, in “good faith” gesture, the property owner voluntarily temporarily suspended operations on
the site, and limited rock crushing operations to a total of 15 consecutive business days in any 6-month
period. Should entitlement of the project not succeed, the property owner reserved the right to
resume all operations consistent with the Sand and Gravel zoning and grandfathered uses.
Santiago Creek enters part of the site at the eastern boundary, flows west, and exits the western
boundary at North Cannon Street. The creek originates at Irvine Lake and is tributary to the Santa Ana
River. The drainage feature splits near the central portion of the project site, with an upland area
separating Santiago Creek into two rivulets. The Santiago Creek waterway totals 5,355 feet in length
and has an average width of approximately 55 feet, which includes the area between the ordinary high
water mark and the adjacent defined wetland areas. Wetland areas are generally located on either
side of the active channel. The creek corridor is privately owned and is not accessible to the public.
Natural vegetation within the site is primarily located along Santiago Creek; most of the site (81.6
acres) is classified as disturbed or mined. Plant communities include southern cottonwood-willow
riparian forest, ornamental, coastal sage scrub, non-native grassland, eucalyptus woodland, coast live
woodland, and undifferentiated open woodland. There are 323 trees located within the project site, of
which the most common species are lemon bottlebrush, eucalyptus, coast live oak, and willow.
The Handy Creek storm drain operated by the Orange County Flood Control District (OCFCD) (Facility
No. E08S06) is located in the central portion of the project site. The storm drain enters the project
site from the south at the intersection of North Nicky Way/East Santiago Canyon Road. The storm
drain coveys stormwater collected in areas south of East Santiago Canyon Road into Santiago Creek.
An unnamed storm drain located in the northwestern portion of the project site conveys stormwater
collected in the Mabury Ranch neighborhood directly into Santiago Creek.
The Allen McCulloch Pipeline trunk water distribution line2 operated by the Metropolitan Water
District (MWD) traverses the easterly portion of the project site and is located entirely below grade.
The pipeline traverses the site within a 50-foot-wide easement. The easement crosses through the
site in a northwest-southeast direction, entering the site from the north at the intersection of
Mabury Avenue/Yellowstone Boulevard and exiting at the single-family residential subdivision to the
south. The pipe measures 109 inches in diameter and is part of the MWD transmission system that
supplies potable water to southern Orange County.
There are historic groundwater and methane monitoring wells associated with the closed adjoining
Villa Park Landfill that are located on the western portion of the project site.
Site photographs of the project site are provided in Exhibit 2-4.
1 Grading Permit No. 2047
2 Also referred to as the “Diemer Transmission”
OrangeCounty
SanBernardinoCounty
O r a n g e C o u n t yLosAngelesCou n t y
91
83
91
91
55
57
241
60
261
241
74
5 Orange
C
ounty
Riverside
C
ounty
60605
10
5
405
22
133
15
1
1
210
15Villa Park
Tustin
73
10
Prado FloodControlBasin
IrvineLake ClevelandNationalForest
RanchoCucamongaSan Dimas Fontana
Covina
El Monte Pomona Ontario
Walnut
Chino
Whittier
Norco
Norwalk Yorba LindaFullerton
Anaheim
Orange
Garden Grove
Seal Beach
Santa Ana
FountainValleyHuntingtonBeach
Costa Mesa Irvine Lake Forest
Newport Beach
Laguna Hills
Laguna Niguel
San JuanCapistrano
Corona
Chino Hills
UplandClaremont
Montclair
Laguna Woods
Exhibit 2-1Regio n al Lo catio n Map
5 0 52.5
Miles
Text
Project Site
So urce: Cen sus 2000 Data, The CaSIL.
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT27650002 • 07/2018 | 2-1_regio n al.mxd
Project Site
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27650002 • 07/2018 | 2-2_vicin ity.m xd
Exhibit 2-2Lo cal V icin ity Map Aerial Base
So urce: ESRI Im agery, 2015
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN RECIRCULATED DRAFT ENV IRONMENTAL IMPACT REPORT
E S a n t i a g o C a n y o n R d
NHewesStNCanonSt SerranoAveOrangeParkBlvdN
C
a
n
nonSt
ViaEs c o la
M a b u ry A v eETaftAve SantiagoCreekSantiago CreekRecharge Basin
Villa ParkLandfill (Closed)
Linda VistaElementarySchool
OakridgePrivateSchool
Salem LutheranChurch and School
MaraBrandmanArena
1,500 0 1,500750
Feet
Legend
Project Site
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27650002 • 08/2018 | 2-3_assessor_parcel_map.mxd
Exhibit 2-3Asse ssor Parce l Map
Source : bing Ae rial Image ry . Orange County Parce l Data.
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
420 0 420210
Fe e t
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View of project site looking south from Mabury Avenue View of project site looking southeast from Santiago Creek Trail
View of surface mining area from E. Santiago Canyon Road.View of eastern portion of site from E. Santiago Canyon Road.
Source: FirstCarbon Solutions, 2016.
27650002 • 08/2018 |2-4_sitephotos.cdr
Exhibit 2-4
Site Photographs
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
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City of Orange—Trails at Santiago Creek Specific Plan
Recirculated Draft EIR Project Description
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2.1.3 - Surrounding Land Uses
West
The closed Villa Park Landfill and North Cannon Street form the western boundary of the project site.
The 18-acre County Villa Park Landfill property occupies the northeast quadrant of the intersection of
East Santiago Canyon Road/North Cannon Street and is owned by the County of Orange. The landfill
operated from 1962 through 1966. The site is enclosed with a fence and contains groundwater
monitoring wells and a landfill gas disposal system. Areas to the west also include detached, single-
family dwelling units related to West of Cannon (typical lot size 7,800–10,000 square feet). See Exhibit
2-5 for location of surrounding residential uses with typical lot sizes less than 10,000 square feet.
Additionally, Exhibit 2-5a provides a detailed view of the lot sizes in the West of Cannon community.
North Cannon Street is a four-lane divided roadway and crosses Santiago Creek via a concrete
bridge. A paved Class I bicycle/pedestrian path (Santiago Creek Bike Trail) is located along the west
side of North Cannon Street south of Santiago Creek.
North
Single-family residential uses are located to the north of the project site, including Creekside Ranch
(typical lot size 9,200–12,000 square feet), The Colony-North (typical lot size 8,600–12,000 square
feet), Mabury Ranch (typical lot size 7,600–11,000 square feet), Hidden Creek (typical lot size 20,000–
24,500 square feet), Serrano Heights (typical lot size 4,500–9,000 square feet), and Parkridge (typical
lot size 8,000–12,000 square feet). Detached, single-family dwelling units are located along the north
bank of Santiago Creek. See Exhibit 2-5 for location of surrounding residential uses with typical lot
sizes less than 10,000 square feet. Additionally, Exhibits 2-5b, 2-5c, 2-5d, and 2-5e provide a detailed
view of the lot sizes in the Creekside Ranch, The Colony-North, and Mabury Ranch communities.
Mabury Avenue is a two-lane undivided roadway. An unpaved trail (Santiago Creek Trail) is located
along the north bank of the creek, parallel to Mabury Avenue.
East
Santiago Oaks Regional Park and detached, single-family residential uses associated with The Reserve
(typical lot size 20,000–44,000 square feet) form the eastern boundary of the project site. The
regional park contains the Santiago Creek corridor, which consists of the waterway and dense
vegetation. Detached, single-family dwelling units are located east of the project site. See Exhibit 2-5
for location of surrounding residential uses with typical lot sizes less than 10,000 square feet
Additionally, Exhibit 2-5f provides a detailed view of the lot sizes in The Reserve community.
South
East Santiago Canyon Road, a four-lane, divided roadway, forms the southern boundary of the project
site. Detached single-family dwelling units associated with the Jamestown neighborhood (typical lot
size 8,000–11,000 square feet), Orange Park Acres (typical lot size 50,000 to 1 acre plus square feet),
Eichler Homes (typical lot size 7,600–12,000 square feet), and The Colony-South (typical lot size 7,000–
10,000 square feet) are located south of the roadway. See Exhibit 2-5 for location of surrounding
residential uses with typical lot sizes less than 10,000 square feet. Additionally, Exhibit 2-5g provides a
detailed view of the lot sizes in the Orange Park Acres community.
City of Orange—Trails at Santiago Creek Specific Plan
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The Mara Brandman Arena is located at the intersection of East Santiago Canyon Road and N. Nicky
Way.
2.1.4 - Land Use Designations
The City of Orange General Plan designates a portion of the project site as Low Density Residential
(LDR) (15.4 acres), Resource Area (RA) (77.3 acres), and Open Space (OS) (16.5 acres) (Exhibit 2-6).
The City of Orange Zoning for the project site is S-G (Sand and Gravel Extraction) and R-1-8 (Single-
Family Residential 8,000 square-feet) (Exhibit 2-7).
Additionally, portions of the project site are within the boundaries of the East Orange General Plan
and Orange Park Acres Plan. The East Orange General Plan was adopted in 1975 and encompasses
approximately 1,900 acres. Approximately 37 acres of the project site are located within the
boundaries of the 1975 East Orange General Plan and are designated “Regional Park.” The Orange
Park Acres Plan was adopted on December 26, 1973 and encompasses approximately 1,794 total
acres. The Orange Park Acres Plan designates approximately 39 acres of the project site as “Open
Space.” The East Orange General Plan and Orange Acres Plan are specific plans.
The proposed project entitlements would include a General Plan Amendment that would amend
both the East Orange General Plan and Orange Park Acres Plan to incorporate the Trails at Santiago
Creek Specific Plan. By doing so, the Trails at Santiago Creek Specific Plan would be included as part
of these two existing relevant plans, which would create vertically consistent documents, that cover
and include the proposed project.
Refer to Section 3.10, Land Use for a detailed discussion of project consistency with the City of
Orange General Plan, City of Orange zoning, East Orange General Plan, and Orange Park Acres Plan.
Additionally, land use designations for surrounding properties are included below.
West
The closed Villa Park Landfill and North Cannon Street form the western boundary of the project
site.
The 18-acre Villa Park Landfill occupies the northeast quadrant of the intersection of East Santiago
Canyon Road/North Cannon Street and is owned by the County of Orange. The landfill operated
from 1962 through 1966. The site is enclosed with a fence and contains groundwater monitoring
wells and a landfill gas disposal system.
North Cannon Street is a four-lane divided roadway and crosses Santiago Creek via a concrete
bridge. A paved Class I bicycle/pedestrian path (Santiago Creek Bike Trail) is located along the west
side of North Cannon Street south of Santiago Creek.
North
Single-family residential uses (typical lot size 8,000–11,000 square feet) and Mabury Avenue form
the northern boundary of the project site. Detached, single-family dwelling units are located along
the north bank of Santiago Creek. Mabury Avenue is a two-lane undivided local street. An unpaved
trail (Santiago Creek Trail) is located along the north bank of the creek, parallel to Mabury Avenue.
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27650002 • 07/2018 |2-5_sur_props.cdr
Exhibit 2-5
Surrounding Properties with Lots Sizes Under 10,000 sq. ft.
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Fuscoe Engineering, September 2017.
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Exhibit 2-5a
West of Cannon Community Lot Sizes
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Fuscoe Engineering, June 2018.
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Exhibit 2-5b
Creekside Ranch and The Colony North Lot Sizes
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Fuscoe Engineering, April 2018.
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Exhibit 2-5c
Mabury Ranch 1 Lot Sizes
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Fuscoe Engineering, April 2018.
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Exhibit 2-5d
Mabury Ranch 2 Lot Sizes
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Fuscoe Engineering, April 2018.
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Exhibit 2-5e
Mabury Ranch 3 Lot Sizes
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Fuscoe Engineering, April 2018.
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27650002 • 07/2018 |2-5f_The_Reserve_Lot_Sizes.cdr
Exhibit 2-5f
The Reserve Lot Sizes
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Fuscoe Engineering, September 2017.
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Exhibit 2-5g
Orange Park Acres Lot Sizes
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Fuscoe Engineering, April 2018.
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27650002 • 11/2018 |2-6_orange_general_plan_land_use.cdr
Exhibit 2-6
City of Orange General Plan Land Use
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source:
LAND USE SUMMARY*
OS - Open Space 16.5 Ac.
RA - Resource Area 77.3 Ac.
LDR - Residential Low Density 15.4 Ac.
TOTAL 109.2 Ac.
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Exhibit 2-7
City of Orange Zoning
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source:
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City of Orange—Trails at Santiago Creek Specific Plan
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East
Santiago Oaks Regional Park and single-family residential uses (typical lot size 20,000–44,000 square
feet) form the eastern boundary of the project site. The Santiago Creek corridor contains dense
vegetation. Detached, single-family dwelling units are located east of the project site.
South
East Santiago Canyon Road, a four-lane, divided roadway, forms the southern boundary of the
project site. Detached single-family dwelling units associated with the Jamestown neighborhood
(typical lot size 8,000–11,000 square feet), Orange Park Acres (typical lot size 50,000 to 1 acre plus
square feet), the Fairhills Eichler Homes (typical lot size 7,600–12,000 square feet), and The Colony-
South (typical lot size 7,000–10,000 square feet) are located south of the roadway. The Mara
Brandman Arena is located at the intersection of East Santiago Canyon Road and North Nicky Way.
2.2 - Project History
2.2.1 - Proposed Project
The project site has had several owners over the years, including Sully Miller, Fieldstone, Rio
Santiago and Hanson Properties; proposed projects that have been reflective of land use activities or
development proposals. The following is a summary of past land use activities and development
proposals.
Sully Miller
The project site has been used for resource extraction activities for close to 100 years. Mining activities
occurred on-site starting from 1919 and ceased before January 1, 1976 and consisted of surface
mining of sand and aggregates.
Agricultural production intermittently occurred on the project site with the most recent production
occurring from approximately 1993 through 2004. Agricultural production included fruit orchards
and strawberry production. All agricultural uses on the site ceased in 2004.
The project site has also been used intermittently for storage of firewood and green waste recycling.
Existing permitted uses consistent with the City of Orange General Plan and Figure LU-5, General
Plan Land Use Policy Map pertaining to the Sully Miller property are outlined below.
City of Orange General Plan
The City of Orange General Plan Land Use Element, Figure LU-5, General Plan Land Use Policy Map,
indicates three land use designations on the Sully Miller property: OS, RA, and LDR.
According to the City of Orange General Plan, page LU-15, OS is described as, “Steep hillsides, creeks,
or environmentally sensitive areas that should not be developed. Although designated as
permanent open space, most areas will not be developed as public parks with the exception of river
and creek side areas that promote connectivity to the City of Orange trail system. Lands in this
category include both privately held open space and public lands.”
City of Orange—Trails at Santiago Creek Specific Plan
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The General Plan’s RA designation is described on page LU-23 as allowing for “Agricultural uses and
continued use of stream and river channels for aggregate mining. Passive and active recreational
uses are also permitted. May serve as a holding zone for future uses compatible with established
and planned land uses in surrounding areas.”
According to page LU-13 of the General Plan, LDR 2.1-6.0 du/ac. Designation is described as
“Conventional single-family residential development characterized by individual single-family homes
constructed in subdivisions, or by custom units built on individual lots.”
The approximate acres by land use designation for the Sully Miller property consistent with the City
of Orange General Plan Land Use Policy Map designation for the property results in the following:
Sully Miller Site (109.2 acres)
• OS—16.5 acres
• RA—77.3 acres
• LDR—15.4 acres
City of Orange Zoning
The City of Orange Zoning Map indicates two land use designations on the Sully Miller property:
Sand and Gravel (SG) and Residential—8,000-square-foot minimum lot (R-1-8).
According to the City of Orange Municipal Code, Title 17, Zoning, Chapter 17.14, Residential Districts,
and Section 17.14.020, Districts Established, the zoning designation R-1-8 is described as “A single-
family residential district with a minimum lot area of 8,000 square feet.”
Chapter 17.32, Sand and Gravel Extraction District Section 17.32.01, Purpose and Intent states that
“. . . It is also the intent of these regulations to provide assurance that as soon as it is feasible to do
so that excavated areas will be maintained or modified in order to guarantee that the property will
be suitable for a useful purpose.” Section 17.32.030, Prohibited Uses, states, “Any use not listed in
Table 17.32.020 as a permitted use, conditional use, or accessory use is prohibited. However, the
Community Development Director shall have the authority to determine whether an unlisted use
substantially conforms to the intent of this chapter.”
The approximate acres by zoning designation for the Sully Miller property consistent with the City of
Orange Zoning Map results in the following:
Sully Miller Site (109.2 acres)
• SG—97.4 acres
• R-1-8—11.8 acres
Previous Development Proposals
Fieldstone
The project site was the subject of a proposed residential development known as the Sully
Miller/Fieldstone Communities project (Fieldstone Project). In October 2003, the Orange City Council
approved the Fieldstone Project, certifying an Environmental Impact Report (Final EIR No. 1647-00)
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and approving a series of land use entitlement permits, including a General Plan Amendment, Orange
Park Acres Plan Amendment (processed as a General Plan Amendment), 1975 East Orange (EO)
General Plan Amendment (GPA), Zone Change, and Tentative Tract Map. The Orange City Council took
no specific action with respect to the Specific Plan Amendments, Zone Change, or the certified
Fieldstone Project EIR. City of Orange staff have determined that the Orange City Council’s action
related to the referendum invalidated the Specific Plan Amendments and Zone Change. The Final Map
was not recorded.
The Fieldstone Project proposed the development of a gated residential community with a maximum
of 189 single-family homes on lots ranging from 8,000 to 22,000 square feet. The residential
development was spread across most of the project site, including both the north and south sides of
Santiago Creek encompassing approximately 83 acres. The remaining portion of the site consisted of
approximately 26 acres of open space (approximately 31 percent of the site), which did not include a
greenway aspect, unlike the proposed Trails of Santiago project. The project proposed private
internal streets, open space and recreation areas, and riding and hiking trail linkages along Santiago
Creek and East Santiago Canyon Road. Access to the project was proposed off East Santiago Canyon
Road and Mabury Avenue.
The Orange Park Acres Association supported the Fieldstone Project for being compatible with the
Orange Park Acres Plan (Appendix D).
Rio Santiago
In 2013, the Rio Santiago project (JMI/Santiago Partners, LLC) proposed a variety of residential
housing totaling 395 dwelling units. The remainder of the project site consisted of approximately 10
acres of active recreation and playfields, and approximately 50 acres (approximately 45 percent of
the site) of natural greenway/open space. In the southeastern portion of the site, abutting the
closed Villa Park Landfill, the 10-acre recreation parcel was proposed that included a YMCA-type
facility with outdoor swimming pools, an Autism Center, sports courts and playfields, and passive
play areas. A multipurpose trail easement was provided along the north side of East Santiago
Canyon Road to connect to the City of Orange’s existing trail to the east, and another trail easement
extended into the site from East Santiago Canyon Road to the Greenway Reserve, paralleling the
community entry and then extending along the Handy Creek easement. The application required
approval of a General Plan Amendment, Zone Change, Tentative Tract Map, Tentative Parcel Map,
Major Site Plan Review, Design Review, and a Development Agreement. The City of Orange issued a
Draft EIR in May 2013. The Orange City Council rejected the proposed Rio Santiago land use plan in
June 2014.
Hanson Properties
In 1993, the City of Orange approved the Hanson Properties Development for residential on 12.6
acres of the Sully Miller aggregate mining property to the north bank of Santiago Creek, east of
Lassen Boulevard, and south of Mabury Avenue. The Hanson Properties Development required the
following discretionary approvals: General Plan Amendment from Resource Area to Low Density
Residential, Zone Change from S-G to R-1-8. While the property was not developed, the
discretionary approvals remained in place, and the area remains as LDR in the General Plan and is
zoned for R-1-8.
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2.3 - Project Characteristics
2.3.1 - Pre-Development Agreement
Public Outreach
Since 2015, over two years before the circulation of the Trails of Santiago Creek Notice of
Preparation (NOP), the Applicant has conducted extensive outreach with representatives of the
adjacent neighborhoods, including Orange Park Association, Mabury Ranch Homeowners
Association, and The Reserve Homeowners Association, in an attempt to determine community
priorities for the site.
In response to the outreach and as a good faith gesture to encourage further constructive dialogue
regarding the long-term land uses for the property, the Applicant agreed to curtail and modify the
current sand and gravel operations on an interim basis, as follows:
a) Suspend backfill and stockpiling operations effective September 15, 2015;
b) After July 31, 2015, restrict rock crushing operations to a total of 15 consecutive business
days within a six-month period;
c) Continue dust abatement measures; and
d) Continue ongoing maintenance of the property and enhance East Santiago Canyon Road
frontage.
e) The property owner reserved all right to resume sand and gravel operations consistent with
the City of Orange Zoning Code.
As part of the community outreach, City of Orange staff, as well as representatives from Orange Park
Acres Homeowners Association (OPA), Mabury Ranch, the Reserve, and the Applicant’s representatives
worked together to establish a framework for an appropriate land use entitlement. To formalize and
ensure transparency for the entitlement process, the City of Orange and the Applicant have entered
into a Pre-Development Agreement. This agreement sets the general parameters and provides
development alternatives that are intended to guide the processing of various requested land use
approvals required for the project as a byproduct of public outreach.
In addition to the Pre-Development Agreement, following review of the comments received on the
Draft EIR, an RDEIR is being prepared that will respond to the issues and concerns raised during the
public review of the Draft EIR. The intent of this approach is to ensure and further promote
transparency during the environmental review process for the project.
Pre-Development Agreement
To formalize and ensure transparency for the entitlement process, with input from Orange Park
Association, Mabury Ranch Homeowners Association, and The Reserve Homeowners Association,
the City of Orange, and the Applicant entered into a Pre-Development Agreement (PDA) dated
October 11, 2016 in accordance with the June 2015 Memorandum. This agreement establishes
general parameters and sets forth various development alternatives that are intended to guide the
processing of various requested land use approvals required for the project.
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The major provisions of the agreement are as follows:
• Evaluate proposed alternatives A through F for the project on approximately 109 acres with a
range of 25 to 50 acres available for residential units as set forth in Exhibit B of the PDA. See
Exhibits 2-8a and 2-8b on pages 2-33 and 2-35.
• An obligation of the Applicant to submit an application for land use entitlement approvals that
may include a General Plan Amendment, amendments to the Orange Park Acres and East
Orange Plan to remove the project area from the coverage of both documents, Zoning Change,
adoption of a stand-alone Specific Plan that will regulate development on-site, Major Site Plan
Review, Design Review, CEQA compliance, Development Agreement, Park Planning and
Development Committee consideration of project trails, and commitment by the City of Orange
to expeditiously process these entitlements while complying with all legal requirements.
• Continue the cessation of the currently permitted operation of the sand and gravel operation
during the processing of the project consistent with the June 12, 2015 memorandum submitted
by the Applicant to the City of Orange (attached within the PDA). The Applicant will also
commence the interim remediation of the property, which will result in the lowering of the
existing sand and gravel material stockpiles on the project site; subject to the Applicant’s right to
resume sand and gravel operations.
• Cooperation between the Applicant and the City of Orange for the evaluation of easements
and the possible extension of the Santiago Creek Trail to the north side of the project site.
Pre-Development Agreement in Relation to the Proposed Project
On March 16, 2017, the City of Orange conducted a Scoping Meeting, in accordance with State CEQA
Guidelines, for the Trails at Santiago Creek Project, (“Project”). The Project described in the Notice
of Preparation (NOP) consisted of approximately 150 residential dwellings configured within various
development plan alternatives. The various land use scenarios were based on the City’s approval of
a Pre-Development Agreement, (“PDA”) on October 11, 2016. This PDA represented several months
of meetings and discussions with community, numerous representatives from Orange Park Acres
Homeowners Association (“OPA”), Mabury Ranch Homeowners Association, and The Reserve
Homeowners Association. An essential component of the PDA and working agreement with the
community representatives was the temporary suspension of all backfill and stockpiling operations
at the Sully-Miller sand and gravel operation, effective September 15, 2015. Based on the PDA, the
City obtained input at the Scoping meeting. The most significant concerns expressed by the
community at the Scoping meeting pertained to traffic on East Santiago Canyon Road and Cannon
Road; the preservation of Santiago Creek as a greenway, open space, flooding, and elimination of the
current sand and gravel operation.
An extensive 3-year community outreach collaboration effort to address these concerns as well as
other matters related to the Property Owner resulted in the following modifications, reductions, and
changes to the original proposal commitments:
1. The Specific Plan (Appendix Q of the RDEIR) and associated project accommodates a
maximum number of 128 single-family detached lots located in the southerly portion of the
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property and will consist of housing types and lot sizes compatible with the surrounding
neighborhoods as depicted in the Trails at Santiago Creek Specific Plan, Exhibits 3.1-3.4 and
consistent with the development standards and guidelines set forth in the Specific Plan.
2. The implementation of the Specific Plan and associated project will fund up to $1,000,000.00
for traffic improvements to widen East Santiago Canyon Road and restripe Cannon Road prior
to the issuance of the first Certificate of Occupancy of any housing units for the Project. Please
refer to the Trails at Santiago Creek Specific Plan, Exhibit 4.1, Areas of Traffic Congestion—Pre-
Project, Exhibit 4.2, Area of Project Related Traffic Improvements, and Exhibit 4.3, Additional
Project Related Traffic Improvements, and Section 4.2.3, Circulation Plan.
3. The implementation of the Specific Plan and associated project will fund approximately up to
a maximum of $4,100,000.00 in landscape and other improvements for the Santiago Creek
Greenway. Said Improvements are to be completed or funded prior to the issuance of the
60th Certificate of Occupancy for the Project. Please refer to the Trails at Santiago Creek
Specific Plan, Section 4.2.4, Trails, Open Space and Recreation Plan, and Exhibit 4.14,
Preliminary Greenway, Open Space and Trails Plan.
4. The implementation of the Specific Plan and associated project will fund $1,000,000.00 to be
used for in local area-wide equestrian trail purposes prior to the issuance of the first
Certificate of Occupancy for the project.
5. The implementation of the Specific Plan and associated project will finance and fund the
City’s acquisition of the Ridgeline Property, which will provide the community an additional
50 acres of public open space to the issuance of the first Certificate of Occupancy for the
Project. Please refer to the Trails at Santiago Creek Specific Plan, Exhibit 4.4, Sully Miller,
Arena and Ridgeline Properties.
6. The implementation of the Specific Plan and associated project will provide $2,000,000.00 for
equestrian and recreational purposes in the East Orange Area as determined by the City prior
to the issuance of the first Certificate of Occupancy for the project.
2.3.2 - Project Summary
A Specific Plan (Appendix Q) has been prepared to provide a comprehensive evaluation of the land
uses proposed for the site and includes land use regulations, infrastructure plans, zoning and
development regulations, design guidelines and implementation criteria. The Specific Plan process
enables the development of the property and implementation of proposed improvements, both
short-term and long-term, while also addressing infrastructure improvements and community
services. The Applicant requests the City of Orange’s consideration of the following components:
• General Plan Amendment.
• Zone Change (Trails at Santiago Creek Specific Plan).
• Development Agreement offering additional community benefits and vesting rights associated
with project approvals for a period of time mutually agreed upon by the City of Orange and
Applicant.
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• An EIR for disclosure and assessment of potential project impacts and establishment of
mitigation measures and a Mitigation Monitoring and Reporting Program.
• Adoption of the Trails at Santiago Creek Specific Plan.
The Specific Plan proposes the Greenway/Open Space and Santiago Creek environs in the north
portion of the site and a Grasslands/Open Space element in the eastern portion of the site abutting the
adjacent Reserve residential neighborhood. A Single-Family Detached Residential parcel is proposed in
the south-central and southwestern portion of the site abutting the adjacent County-owned vacant
parcel west of the project site. The residential neighborhood will be accessed from East Santiago
Canyon Road across from Nicky Way. The proposed land use plan is shown in Exhibit 2-9, a summary
of the project is listed in Table 2-1, and a breakdown of each land use is provided below.
Table 2-1: Project Land Use Summary
Planning
Area Land Use Acres
Percent of
Site
Maximum
Dwelling Units Maximum Density
Open Space
A Greenway/Santiago Creek 40.2 — 0 0
B Grasslands Open Space 28.3 — 0 0
Total 68.5 62.7% — —
Low-Density Residential
C Single-Family Detached
Residential 40.7 37.3% 128 3.1 du/ac
Grand Total 109.2 100% 128 3.1 du/ac
Source: Milan REI X, 2017.
Residential Uses
The Trails at Santiago Creek proposes a well-planned Single-Family Detached Residential
neighborhood comprising 40.7 acres within Planning Area C, located in the south-central and
southwestern portions of the site abutting the adjacent vacant County-owned parcel. The project
proposes 128 units, equating to 3.1 du/ac. Reflective of residential lots in the existing surrounding
neighborhoods of Mabury Ranch, The Colony North and Creekside Ranch, Orange Park Acres at
Orange Park Boulevard and East Santiago Canyon Road, and Jamestown, the project includes three
different single-family detached lot programs ranging in size from 8,000-square-feet–9,000-square-
feet; 9,200-square-feet–10,000-square-feet; and 10,000 square-feet and greater. The overall
average lot size for PA-C is approximately 10,300-square-feet. Homes will be one-story and two-
story. The largest lots are located in the east side of PA-C Adjacent to The Reserve. Please refer to
Exhibit 2-10: Proposed Site Plan.
The project’s residential neighborhoods in PA-C will be a present-day interpretation of the existing
surrounding neighborhoods, complimentary to and in character with them. Similar materials will be
used, rooflines and roof styles will be comparable, and the architectural theme will be an updated
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version of the surrounding neighborhoods and compatible with the area. Homes will be designed to
reinforce the pedestrian scale of the neighborhood by incorporating second floor setbacks and
covered front porches and entryways that address the sidewalk and reduce the scale of the homes.
Building massing and setbacks will be in-keeping with existing neighborhoods. Residential
Development Standards will be the standards contained in the City of Orange Zoning Code, Chapter
7.14, Residential District, Section 17.14.070, General Requirements, Table 17.14.070, Residential
Development Standards R-1-8 and R-1-10.
The influence of the project’s natural open space that surrounds the residential neighborhood and
the network of multi-use trails and amenities within the open space having a rustic equestrian
character provides the opportunity to establish a quasi-rural personality to the neighborhoods.
Residential/local streets will have curb adjacent landscape parkways planted with street trees in
character with the surrounding natural environs. Entry monumentation, signage and lighting will
reinforce this character in design interpretation and materials (stone, timbers, and rustic metals).
Edge treatments and any public landscape within PA-C will utilize plant materials and be designed in
character with the natural surroundings, i.e. drifts and swaths of grasses and shrubs, vines, and
accent plantings in informal/natural patterns. Pedestrian and bicycle connectivity from the
residential neighborhoods to the surrounding open space and trail network will be via trail paseos
extending into the neighborhoods as well as via the Handy Creek Easement Linear Park.
As stated above, the residential planning area will abide by the City of Orange Zoning Code
Development Standards for R-1-8 and R-1-10 (Single-Family Residential) development, shown in
detail in Table 2-2.
Table 2-2: City of Orange Zoning Code Development Standards
Zoning
Units
Per Lot
Minimum
Lot Area
(Sq. Ft.)
Minimum
Lot
Frontage
(Feet)
Minimum
Lot Depth
(Feet)
Minimum Yard Setback
(Feet)
Maximum
Height
(Feet)
Maximum
Floor
Area
Ratio
Minimum
Usable
Open
Space
(Sq. Ft.) Front Side Rear
R-1-8 1 8,000 60 100 20 5 20 32—
2 stories
0.60 1,000
R-1-10 1 10,000 80 100 20 5 20 32—
2 stories
0.50 1,000
Source: City of Orange Zoning Code, version: June 30, 2018.
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Exhibit 2-8a
Pre-Development Agreement Alternatives A-D
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source:
Pre-Development Agreement Alternative D
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Exhibit 2-8b
Pre-Development Agreement Alternatives E-F
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
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Exhibit 2-9
Proposed Land Use Plan
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Milan REI X, October 29, 2018.
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Exhibit 2-10
Proposed Site Plan
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Milan REI X, October 29, 2018.
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Table 2-3 provides a breakdown of the Trails at Santiago Creek Specific Plan residential lots and lot
sizes, and which City of Orange Development Standards will apply.
Table 2-3: Trails at Santiago Creek Specific Plan Residential Lot Sizes and Applicable Zoning
Planning Area Location Lots Lot Size Applicable Zoning
C1 82 8,000 R-1-8
C1 and C2 17 9,200 R-1-8
C2 29 10,000 R-1-10
Source: City of Orange Zoning Code, version: June 30, 2018.
Santiago Creek Greenway and Open Space Areas
The open space at The Trails at Santiago Creek will be approximately 68.5 acres and will comprise
natural hillsides, re-established grasslands, a restored Santiago Creek riparian corridor and a
managed vegetation/fuel modification zone. The open space will occupy approximately 62.7% of the
site and will include:
• Planning Area A—Greenway Open Space and Santiago Creek Riparian Corridor: 40.2 acres
• Planning Area B—Grasslands Open Space (includes East Santiago Canyon Road trail easement
and a managed vegetation/fuel modification zone): 28.3 acres
Santiago Creek, which meanders across the site in an east-to-west trend, is an incised perennial
USGS blue-line drainage course that primarily supports southern cottonwood-willow riparian forests
as well as the development of fringe wetlands. The creek bifurcates into two stream beds in the
center of the site, ultimately rejoining in the western portion of the property.
Planning Area A, the Greenway Open Space and Santiago Creek, with its riparian and wetland habitats,
provides an environment that supports both on-site “live-in” wildlife as well as a movement corridor for
regionally oriented wildlife. Off-site to the east, the Santiago Creek open space corridor provides a link
to Santiago Oaks Regional Park and the natural open space beyond. Off-site to the west the Santiago
Creek open space corridor connects with the Santa Ana River environs with its ponds and tributaries.
Planning Area B, the Grassland area located south of Santiago Creek, has been disturbed over the years
due to commercial operations on the site and will be restored as a natural grasslands interspersed with
other plant communities and seasonal wildflowers. Planning Area B also includes the Managed
Vegetation/Fuel Modification zone located north of and east of Planning Area C and acts as a
vegetative buffer between the open space and residential neighborhood. This 130-foot-wide buffer
zone will be comprised of plantings that are compatible with on-site plant communities while being
responsive to fuel management policies. A 20-foot wet zone falls within the rear yard of the residential
lots along this edge. The Managed Vegetation/Fuel Modification Zone(s) complies with fuel
modification requirements specified by Section 320 of the Orange Fire Code (per Orange Municipal
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Code Section 15.32.020). Upon dedication of the Specific Plan’s open space in Planning Areas A and B
to the City of Orange, County of Orange, or other entity, the Applicant/developer will retain an
easement for fuel modification zone maintenance at the time of final mapping.
The Trails at Santiago Creek supports and restores the open space habitats on-site and cleans up and
restores Santiago Creek on-site, both of which during the property’s life span have fallen, in some
areas, to a degraded environmental state. Studies will be conducted and plans will be prepared and
submitted to the City and/or other jurisdictional agencies for review and approval for the
enhancement, restoration and re-establishment of the plant community habitats on the land on the
north side of Santiago Creek, within the Santiago Creek corridor and within the grassland areas in
the southeast portion of the Specific Plan area.
The uses within the open space planning areas will be compatible with and reflective of uses as
described in the Santiago Creek Vision Plan (2018), Santa Ana River, Santiago Creek Greenbelt Plan
(1971), and the Santa Ana River/Santiago Creek Greenbelt Implementation Plan (1976). Other
documents that guided proposed uses and/or trails included the City of Orange General Plan
Circulation and Mobility Section, the East Orange General Plan (1975), the Orange Park Acres Plan
(1973), and the Riding and Hiking Trails Map of Orange Park Acres and Vicinity.
According to the Santiago Creek Greenway Alliance, open space grasslands and trails should be cared
for and maintained by OC Parks as part of the regional park system, in order to ensure that the
habitat will be properly managed for public benefit (Appendix E). No such commitment has been
made by OC Parks for long-term stewardship of the open space grasslands and trails as part of this
proposed project. In the event that OC Parks will not provide management and maintenance for the
open space grasslands and trails, the responsibility would be the responsibility of the Homeowners
Association as part of the proposed project.
Responsibility for open space grasslands and trails management and maintenance will be discussed
as part of the ongoing process.
Trails, Open Space, and Recreation
Taking into consideration the previously referenced documentation and the quality, character and
intended restoration of the project’s open space planning areas, the open space within The Trails at
Santiago Creek avails itself to a variety of passive recreational uses including trailheads, multi-use
recreational trails and trail-side resting areas. Please refer to Exhibit 2-11: Preliminary Greenway,
Open Space and Trails Plan.
As outlined in the Preface of this document, approximately $4,100,000.00 in landscape and other
improvements for the Santiago Creek Greenway will be funded, as part of the proposed project.
Said Improvements are to be completed or funded prior to the 60th Certificate of Occupancy.
Trailhead
In the southerly portion of the site within Planning Area B a signature trailhead is provided
reinforcing the equestrian vernacular of the area. Intended to be an informative entryway into the
greenway and open space environs, there will be informational signage and trail maps, equestrian
hitching rails and watering station, bike racks and rustic benches, and a shade shelter and tables for
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resting and/or waiting for others. This area will be a gathering place for riders and hikers to meet
and join up with friends and community colleagues for mutual recreation and trail enjoyment.
Educational kiosks will inform the public about the ecology, biological resources, and special-status
species of the area, as well as emphasizing the importance of staying on the trails, respecting
seasonal trail closures, and the community’s responsibility in protecting the natural resources.
A variety of recreational trails for combined uses of hiking, bicycling, and horseback riding will
traverse the project site as described in the following. Trails are proposed to be unpaved
(decomposed granite or similar) in keeping with the natural setting.
Trails
Trail A
Along the north side of East Santiago Canyon Road, in addition to the existing Class II bike trail, an off-
street recreational trail will extend along the entire length of the project site. This trail will provide
continuity from the existing recreation trail that parallels the roadway east of the project site, with the
intention of eventually connecting to future planned trails off-site to the west (provided by others).
This 10’ wide trail will be separated from East Santiago Canyon Road by a 6-foot wide landscaped
parkway (minimum, as measured from the back of curb) within an 18-foot minimum wide easement.
Trail A will be constructed by the Applicant as part of the proposed project.
Trail B
This recreational trail will extend northward from the East Santiago Canyon Road trail, pass through
the project’s trailhead and meander through the grassland open space area in the southeast portion
of the site (Planning Area B). The trail will pass through open areas in the northeast portion of PA-B
that can be used by the community at large for informal passive gatherings and activities such as
casual picnics, kite-flying, and Frisbee play.
Continuing northward Trail B will cross the Santiago Creek riparian corridor via a bridge that will span
the creek environs. The bridge, with a span in excess of 100 feet, will be constructed of wood and/or
steel and be of a character in keeping with the locale and setting. The bridge will be located toward
the easterly end of the creek corridor in the most feasible location to be the least intrusive to the
creek environment. This 10-foot wide trail will be set within an 18-foot minimum wide easement.
Trail C
This trail is an existing unpaved recreational trail known as the Santiago Creek Trail. It is
predominantly off-site abutting the project’s boundary and Planning Area A, the Greenway Open
Space, with a short length running within the property along the northwest boundary. The trail
begins at Cannon Street and trends along the project’s northwesterly boundary to Mabury Avenue,
where it turns east and runs off-site along the entire northern boundary of the project site between
Mabury Avenue and the Greenway Open Space. At the project’s eastern boundary, the trail
continues off-site to the Santiago Oaks Regional Park via the Santiago Creek open space corridor.
Trail D
This recreational trail trends east/west through Planning Area A, the greenway open space on the
north side of the Specific Plan area, and above Santiago Creek. The trail traverses the sloping land on
the east and west sides and meanders through the gently sloping meadow area in the central portion
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of the site, providing for overviews of the Santiago Creek corridor and its woodland communities. The
trail connects at three points with Trail C, the Mabury Ranch Trail, allowing for an enjoyable loop
through varying terrain. It also connects with Trail B south through Planning Area B to Trail A and East
Santiago Canyon Road, and to Cannon Road that abuts the westerly most portion of Planning Area A.
The final design and alignment of Trail D will be done to avoid or minimize impacts to coastal sage
scrub and other native habitats, and to traverse through vegetation communities that already exhibit
disturbance. Portions of the trail may be closed or partially closed seasonally when adjacent to
habitat that may support special-status birds during breeding season.
This 10-foot wide trail will be set within an 18-foot minimum wide easement.
Trail E
Trail E is located in Planning Area B south of and above Santiago Creek and north of the residential
neighborhoods in Planning Area C. It is oriented in an east/west trend and serves multiple purposes:
as a multi-use recreation trail, as a seasonal access for servicing the managed vegetation/fuel
modification zone, and as a fire access road (complying with the Orange Fire Code Section 320 and
associated guidelines). This trail will have a 20-foot-wide all-weather surface suitable to carry
vehicle weight. Also, Trail E’s alignment is comparable to the trail depicted in the 2018 Santiago
Creek Vision Plan, page 33, Figure 44.
Trail F
Trail F is oriented in a north/south trend within the Handy Creek Linear Park in Planning Area B. It
provides a direct link into the Planning Area B open space environs from the community entry and
signalized intersection at East Santiago Canyon Road and Nicky Way. A trail crossing signal for hikers,
bicyclists and horseback riders will be provided for safe crossing of the residential street upon
entering the community and Planning Area C.
This 10-foot wide trail will be set within an 18-foot minimum wide easement.
Rest Areas
Within Planning Area A and Planning Area B, trailside rest areas are proposed at select locations.
These rest areas will have rustic benches, a horse hitching rail, and a bike rack. They are provided to
allow trail users the opportunity to rest and take a break, take in the view and setting, and enjoy the
company of other trail users.
Parks
Through extensive meetings and dialogues with representatives of adjacent residential neighborhoods
including Orange Park Association, Mabury Ranch Homeowners Association, and The Reserve
Homeowners Association, it was mutually agreed upon that no active parks or recreational facilities
would be proposed on the project site, but rather passive recreational uses and trails would be
incorporated into the plan as have been described above. Within Planning Area B, the existing Handy
Creek OCFCD Easement provides for an open space extension to East Santiago Canyon Road and the
project entry. A linear park (Handy Creek Linear Park) will be developed within the easement providing
trail connectivity and will be accented with shade structures, benches and accent plantings. All areas,
including Handy Creek Linear Park, will comply with fuel modification requirements specified by
Section 320 of the Orange Fire Code (per Orange Municipal Code Section 15.32.020).
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27650002 • 11/2018 |2-11_prelim_greenway_os_trails.cdr
Exhibit 2-11
Preliminary Greenway, Open Space and Trails Plan
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Milan REI X, October 29, 2018.
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Circulation Plan
The Circulation Plan for The Trails at Santiago Creek provides for the movement of vehicular traffic
while creating an environment for pedestrians, bicyclists, and equestrian riders through the inclusion
of both a regional and local on-site trail system. The trail system provides internal connectivity
within The Trails at Santiago Creek, as well as the potential for external connections to the greater
Orange community, Santiago Oaks Regional Park, the existing regional trail system, and other off-site
destinations and amenities. For existing circulation, please refer to Exhibit 2-12a. For proposed
circulation, please refer to Exhibit 2-12b: Proposed Circulation.
Vehicle Circulation
Existing
Regional access to the site is provided via the SR-55 Freeway, SR-91 Freeway, and the SR-241/SR-261
Freeways (Toll Roads). The principal local network of streets serving the proposed project includes
East Santiago Canyon Road and Cannon Street. The project site is located on the north side of East
Santiago Canyon Road between Cannon Street and Orange Park Boulevard.
There is no existing public access to the project site. Private controlled access to the project site
occurs from East Santiago Road via two gated and monitored entrances.
East Santiago Canyon Road is generally a four-lane divided roadway that borders the project site on
the south. On-street parking is generally not permitted along this roadway within the vicinity of the
project. The posted speed limit on East Santiago Canyon Road adjacent to the project site is 50 miles
per hour (mph). In the vicinity of the project site traffic signals control the intersections of East
Santiago Canyon Road at Hewes Street, Cannon Street, Orange Park Boulevard and Meads Avenue.
Approximately 5 acres in the southeastern portion of the project site are used for materials
recycling, including the crushing of boulders, bricks, rocks, etc. Access to the materials recycling area
is provided via a controlled entrance along East Santiago Canyon Road. Materials generated by this
operation have historically been used within and transported off the project site.
Cannon Street is a four-lane divided roadway oriented in a north-south direction. On-street parking
is generally not permitted along this roadway within the vicinity of the project. Adjacent to the
project site the posted speed limit on Cannon Street is 45 mph.
Current traffic volumes resulting from the existing on-site rock crushing operation generates
approximately 686 daily trips, of which over 500 of those trips are truck traffic. Traffic movement on
East Santiago Canyon Road and through intersections in the vicinity of the proposed project is less
than desirable at peak hours.
Proposed Access to the project will be provided via one proposed full access signalized entry road,
located directly opposite Nicky Way, along East Santiago Canyon Road. No parking will be allowed
along either side of the entry road. Sidewalks will be located on each side of the entry road
separated by a landscaped parkway.
While the proposed project has the potential for a gross increase of 1,228 daily trips and the
potential for a net increase of daily trips (542), but which also results in a significant reduction of the
current rock crushing operations traffic generated by heavy-trucks, the project proposes several
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improvements to the surrounding roadways and intersections, thus ensuring increased capacity and
adequate traffic flow in the area. These are improvements that would not be incorporated in the
absence of the project. These capacity improvements involve roadway widening and/or re-striping
to reconfigure (add lanes) to specific approaches of key intersections. The identified improvements
are expected to:
• Mitigate the impact of existing traffic, project traffic and future non-project (ambient traffic
growth and cumulative project) traffic; and
• Improve Levels of Service to an acceptable range and/or to pre-project conditions.
To ensure that adequate ingress and egress to the project site can occur from East Santiago Canyon
Road without impeding through traffic flow, the following Project Feature Improvements will be
provided at the project’s entry across from Nicky Way:
• Construct the project’s entry road on the north side of the intersection and provide one
inbound lane and two outbound lanes (one left turn lane and one shared through-right turn
lane). Widen and/or restripe East Santiago Canyon Road to provide one eastbound left-turn
lane and one westbound right-turn deceleration lane. Install a five-phase traffic signal with
protected left-turn phasing in the east-west direction and permissive phasing in the north-
south direction.
In addition to the above the following additional Voluntary Improvements will be provided:
• East Santiago Canyon Road—Widen and restripe the north side of East Santiago Canyon Road
approximately 4 to 6 feet from the easterly project boundary to the existing free-right turn
lane at Cannon Street to provide a third westbound through lane
• Cannon Street—Restripe Cannon Street from East Santiago Canyon Road to Serrano Avenue to
provide a third northbound through lane.
Within the proposed residential neighborhood (Planning Area C) local streets will be designed in
accordance with the City of Orange 100 Series—Street Improvement Standards, Standard Plan 106
Local Streets, Case I and Case II. Streets will have one travel lane in each direction and sidewalks
separated by a landscape parkway. Parallel parking will be allowed on one or both sides of the
street pending neighborhood design.
Non-Vehicular Circulation
Existing
Pedestrian circulation is provided via existing public sidewalks along the south side of East Santiago
Canyon Road east of the project site terminating at the Mara Brandman Equestrian Center and
resuming west of Nicky Way. There is no public sidewalk on the north side of Santiago Canyon Road
abutting the project site or west of the site. Lastly, there are existing public sidewalks of both the
east and west sides of Cannon Street.
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Exhibit 2-12a
Existing Circulation
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
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27650002 • 11/2018 |2-12b_proposed_circulation.cdr
Exhibit 2-12b
Proposed Circulation
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Milan REI X, October 29, 2018.
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Class II bike lanes (on-street bike lanes delineated by painted strips and other features) exist along
the north and south sides of East Santiago Canyon Road and the east and west sides of Cannon
Street. A public Recreation Trail currently exists along the north side of East Santiago Canyon Road
adjacent to the existing Reserve neighborhood to the east of the project site. Along the north
boundary of the site exists the Santiago Creek Bike Trail extending from Cannon Street east to the
easterly project boundary and further on to Santiago Oaks Regional Park.
Proposed
As described above, in Santiago Creek Greenway and Open Space Areas, numerous documents have
been reviewed and taken into consideration in preparing the pedestrian, bicycle and equestrian trail
network for the project. Below is a brief description of the various components of this network.
Please refer to Trails, Open Space and Recreation, above, for a more detailed discussion.
A variety of public multi-use recreation trails will traverse the project site, providing shared use of
hiking, biking and horseback riding on decomposed granite trail surfaces. Along the north side of
East Santiago Canyon Road, in addition to the existing Class II bike lane, an off-street recreational
trail will extend along the entire length of the project site. This trail will provide continuity from the
existing trail that parallels the roadway east of the project site, with the intention of connecting to
future planned trails off-site to the west (provided by others). This 10-foot-wide trail will be
separated from East Santiago Canyon Road by a minimum 6-foot-wide landscaped parkway
measured from the back of curb within a minimum 18-foot-wide easement, as per the City of
Orange Recreational Trail Master Plan (RTMP) Detail #2. Trail fencing between the trail and the
street shall also be consistent with the City of Orange RTMP Detail #14 and shall be placed outside of
the trail tread area. The fence will be in-keeping with the existing fencing along East Santiago
Canyon Road east of the project.
Throughout the open space in Planning Areas A and B, a network of 10-foot-wide multi-use
recreation trails will meander across the land providing public access to the restored open space and
the Santiago Creek environs on this once private land. A bridge located in the northeast portion of
PA-A will provide trail access across the Santiago Creek environs. The trail system will connect to the
existing Santiago Creek Trail along the northern boundary and on the west side at Cannon Street
Trail access to the residential neighborhoods in PA-C will be via a number of trail paseos allowing for
hiking and bicycling access, and via the handy Creek Linear Park in PA-B. Within the PA-C, all streets
will have sidewalks on one or both sides.
It is the intent of The Trails at Santiago Creek to provide a recreational trail system that avails the
open space areas and the Santiago Creek environs to the community of Orange and the general
public at large, as well as the project’s residential neighborhood, and becomes an integral part of the
City’s and County’s trail master plans via connectivity opportunities.
Emergency Access
Emergency vehicle access will be provided on the Specific Plan area per the City of Orange Fire
Department Fire Code and associated guidelines. The City Fire Department staff will review the
project’s Site Plan and TTM upon preparation to verify the adequacy of the emergency vehicle
access. As indicated on Exhibit 4.8, Proposed Circulation, emergency access is provided from East
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Santiago Canyon Road to the single-family detached residential neighborhood (Planning Area C) in
two locations. One access point is located in the southeast end of Planning Area C, and the other
access point is located in the southwest portion of Planning Area C. Access will be controlled via a
knockdown bollard or gate off of East Santiago Canyon Road. A 20-foot wide all-weather travel
surface will be provided within a 32-foot wide easement allowing emergency access from East
Santiago Canyon Road to the interior neighborhood street system.
No public roadways are proposed within open space Planning Areas A or B. Currently, Orange County
Flood Control accesses the site from the north via a gated access point at Mabury Avenue and
Yellowstone Boulevard. This access will still be provided once the project is complete and will be via
the proposed trail system.
In addition, Orange County Flood Control and the City of Orange Fire Department will have access
from Cannon Street via County owned property to the proposed 20-foot wide multi-use recreational
trail/fire access road along the south side of Santiago Creek in Planning Area B. This trail/access road
provides access for the managed vegetation and fuel modification zone maintenance and may also
be used by emergency vehicles. All fire access roads shall comply with the City of Orange Fire Code
and associated guidelines.
Grading and Earthwork
The proposed project includes extensive remediation of bad soils conditions left as a byproduct of
the former mining operation. This will necessitate the import of approximately 877,000 cubic yards
of new clean materials and the export of approximately 500,000 cubic yards of silty soils. The blend
of imported materials will be based on the recommendation of the project’s soils engineer and will
include asphalt, concrete, rock, and soil to be mixed in with the materials found on-site currently.
These activities are expected to take place over an 18-month period.
Utilities
Storm Drainage
The storm drain system for the Specific Plan area will extend from Santiago Creek into Planning Area
C via underground pipes of various sizes. Runoff would be conveyed by a curb and gutter system
into catch basins and the underground storm drain piping system to control runoff from the
residential and open space areas. The storm drain system will discharge to a water quality basin
within Planning Area B and then into Santiago Creek. Elevation of Planning Area C will be raised
above the 100-year flood elevation. Stormwater facilities will be provided on-site to adequately
serve the residential and open space development.
The storm drain system located in public streets and public easements shall be dedicated to the City
at the time of final map recordation.
Potable Water
The City of Orange Water Division would provide potable water service to the proposed project.
Two existing water mains are located within East Santiago Canyon Road and measure 18 inches and
24 inches in diameter, respectively.
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The proposed project would install a network of underground water lines within the project site that
would connect to one or both of the existing water mains within East Santiago Canyon Road.
Underground service laterals would be extended to each dwelling unit.
Wastewater
Orange County Sanitation District (OCSD) would provide wastewater collection and treatment to the
proposed project. An existing OCSD trunk sewer main is located within East Santiago Canyon Road
that measures 18 inches in diameter.
The proposed project would install a network of underground sewer piping within the project site
that would connect to the existing sewer main within East Santiago Canyon Road. Underground
service laterals would be extended to each dwelling unit.
Electricity
Southern California Edison (SCE) would provide electrical service to the proposed project. A network
of underground electrical lines would be installed within the project site and connect to existing SCE
facilities along East Santiago Canyon Road. Underground service laterals would be extended to each
dwelling unit.
Natural Gas
The Southern California Gas Company (SoCalGas) would provide natural gas service to the proposed
project. A network of underground natural gas lines would be installed within the project site and
connect to existing SoCalGas facilities along East Santiago Canyon Road. Underground service
laterals would be extended to each dwelling unit.
Comparison to Prior Development Proposals
Table 2-4 compares the current Trails at Santiago Creek Specific Plan proposal with the previous
Fieldstone, Rio Santiago, and Hanson Properties proposals.
Table 2-4: Comparison to Prior Development Proposals
Proposal Unit Count and Acres
Open Space/
Greenway Comparison of Previous Plan vs Current Plan1
Fieldstone (Previous) 189 single-family
dwelling units
located on
approximately 50
acres
36.5 acres of open
space and
recreation (33
percent)
The Fieldstone Previous Plan would add 60
additional units, and would provide 23.5
fewer acres of open space and recreation,
with no greenway proposed.
Rio Santiago (Previous) 395 single-family
dwelling units
located on 83
acres;
50 acres of/open
space greenway (45
percent) and 10
acres of recreation
The Rio Santiago Previous Project would
add 266 additional units, and would
provide 1 less acre of open space
greenway and recreation.
Hanson Properties
(Previous)
25 single-family
dwelling units
located on 16.3
acres
N/A The Hanson Properties Previous Project
would develop the north bank of Santiago
Creek, whereas the proposed project
would create open space in that area.
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Table 2-4 (cont.): Comparison to Prior Development Proposals
Proposal Unit Count and Acres
Open Space/
Greenway Comparison of Previous Plan vs Current Plan1
Trails at Santiago
Creek Specific Plan
(Current)
128 single-family
dwelling units
located on 40.7
acres
28.3 acres of open
space (26 percent)
and 40.2 acres of
greenway (36.8
percent)
—
Note:
1 For informational purposes only. See Section 3.10, Land Use for additional information.
Source: FCS, 2016.
Project Implementation
Implementation of the proposed project will be primarily dictated by economic conditions and may
occur on a phased basis over a period of years. However, for the purposes of providing a
conservative, worst-case analysis in this EIR, it will be assumed that the entire project would be
developed in a single phase that takes 24 months to complete. Construction would begin in January
2020 and the project would be completed by January 2022.
2.4 - Project Objectives
The objectives of the proposed project are to:
OBJ-1. Locate single-family detached residential units in the most suitable areas of the
project site and preserve other areas for open space and greenway.
OBJ-2. Preserve and protect Santiago Creek by abating the remnants of the resource
extraction activities and establishing a greenway along the creek corridor.
OBJ-3. Promote land use compatibility with neighboring residential uses through the use of
locating landscaped setbacks, and the development of a compatible housing product
and lot size to the adjoining uses.
OBJ-4. Develop a network of publicly accessible trails within the project site that provide
access to Santiago Creek and Santiago Oaks Regional Park.
OBJ-5. Lessen the noise, improve air quality, and reduce traffic impacts from the existing
materials recycling and backfilling operations within the project site.
OBJ-6. Provide a circulation system that will minimize adverse effects on local residential
neighborhoods and encourage pedestrian and bicycle circulation.
OBJ-7. Provide an infrastructure system, including sewer, water, and storm drain systems
that will adequately serve full build-out of the proposed project.
OBJ-8. Improve local circulation by widening of East Santiago Canyon Road and restriping
Cannon Road prior to the first certificate of occupancy.
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2.5 - Intended Uses of this Draft EIR
This Draft EIR is being prepared by the City of Orange to assess the potential environmental impacts
that may arise in connection with actions related to implementation of the proposed project.
Pursuant to CEQA Guidelines Section 15367, the City of Orange is the lead agency for the proposed
project and has discretionary authority over the proposed project and project approvals. The Draft
EIR is intended to address all public infrastructure improvements and all future development that
are within the parameters of the proposed project.
2.5.1 - Discretionary and Ministerial Actions
Discretionary approvals and permits are required by the City of Orange for implementation of the
proposed project. The project application would require the following discretionary approvals and
actions, including:
• A General Plan Amendment to Change the City of Orange General Plan Designation for the site
from Resource Area (RA) to Low Density Residential (LDR 2.1-6 Du/Ac) and Open Space (OS);
and from Low Density Residential (LDR2-6 Du/Ac) to Open Space (OS).
• A Zone Change to re-designate the site designation from Sand and Gravel (S-G) and Single
Family Residential 8,000 sf (R-1-8) to Specific Plan (SP), consistent with the Trails at Santiago
Creek Specific Plan.
• A Development Agreement offering additional community benefits and vesting rights
associated with project approvals for a period of time mutually agreed upon by the City of
Orange and Applicant.
• Certification of an Environmental Impact Report for disclosure and assessment of potential
project impacts and establishment of mitigation measures and a Mitigation Monitoring and
Reporting Program.
• Adoption of the Trails at Santiago Creek Specific Plan.
Subsequent ministerial actions would be required for the implementation of the proposed project,
including issuance of grading and building permits.
2.5.2 - Responsible and Trustee Agencies
A number of other agencies in addition to the City of Orange will serve as Responsible and Trustee
Agencies, pursuant to CEQA Guidelines Section 15381 and Section 15386, respectively. This Draft
EIR will provide environmental information to these agencies and other public agencies, which may
be required to grant approvals or coordinate with other agencies, as part of project implementation.
These agencies may include but are not limited to the following:
• United States Army Corps of Engineers (USACE)
• United States Fish and Wildlife Service
• California Department of Fish and Wildlife (CDFW)
• California Department of Toxic Substances Control (DTSC)
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• Santa Ana River Regional Water Quality Control Board (RWQCB)
• South Coast Air Quality Management District
• County of Orange
Actions that are necessary to implement the project that must be taken by other agencies are:
• Issuance of Section 404 Permits (USACE)
• Issuance of a Lake and Streambed Alteration Agreement (CDFW)
• Issuance of Section 401 Water Quality Certification (RWQCB)
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SECTION 3: ENVIRONMENTAL IMPACT ANALYSIS
Organization of Issue Areas
This Draft Environmental Impact Report (Draft EIR) provides analysis of impacts for those
environmental topics where it was determined in the Notice of Preparation, or through subsequent
analysis that the proposed project would result in “potentially significant impacts.” Sections 3.1
through 3.18 discuss the environmental impacts that may result with approval and implementation
of the proposed project.
Issues Addressed in this EIR
The following environmental issues are addressed in Section 3:
• Aesthetics, Light, and Glare
• Agriculture Resources and Forest Resources
• Air Quality
• Biological Resources
• Cultural Resources
• Geology and Soils
• Greenhouse Gas Emissions
• Hazards and Hazardous Materials
• Hydrology and Water Quality
• Land Use and Planning
• Mineral Resources
• Noise
• Population and Housing
• Public Services
• Recreation
• Transportation and Traffic
• Tribal Cultural Resources
• Utilities and Service Systems
Level of Significance
Determining the severity of project impacts is fundamental to achieving the objectives of CEQA.
CEQA Guidelines Section 15091 requires that decision makers mitigate, as completely as is feasible,
the significant impacts identified in the Final EIR. If the EIR identifies any significant unmitigated
impacts, CEQA Guidelines Section 15093 requires decision makers in approving a project to adopt a
statement of overriding considerations that explains why the benefits of the project outweigh the
adverse environmental consequences identified in the EIR.
The level of significance for each impact examined in this Draft EIR was determined by considering
the predicted magnitude of the impact against the applicable threshold. Thresholds were developed
using criteria from the CEQA Guidelines and checklist; state, federal, and local regulatory schemes;
local/regional plans and ordinances; accepted practice; consultation with recognized experts; and
other professional opinions.
Impact Analysis and Mitigation Measure Format
The format adopted in this EIR to present the evaluation of impacts is described and illustrated
below.
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Summary Heading of Impact
Impact AES-1: An impact summary heading appears immediately preceding the impact
description (Summary Heading of Impact in this example). The impact
number identifies the section of the report (AES for Aesthetics, Light, and
Glare in this example) and the sequential order of the impact (1 in this
example) within that section. To the right of the impact number is the
impact statement, which identifies the potential impact.
Impact Analysis
A narrative analysis follows the impact statement.
Level of Significance Before Mitigation
This section identifies the level of significance of the impact before any mitigation is
proposed.
Mitigation Measures
In some cases, following the impact discussion, reference is made to state and federal
regulations and agency policies that would fully or partially mitigate the impact. In addition,
policies and programs from applicable local land use plans that partially or fully mitigate the
impact may be cited.
Project-specific mitigation measures, beyond those contained in other documents, are set
off with a summary heading and described using the format presented below:
MM AES-1 Project-specific mitigation is identified that would reduce the impact to the
lowest degree feasible. The mitigation number links the particular
mitigation to the impact it is associated with (AES-1 in this example);
mitigation measures are numbered sequentially.
Level of Significance After Mitigation
This section identifies the resulting level of significance of the impact following mitigation.
Abbreviations used in the mitigation measure numbering are:
Code Environmental Issue
AES Aesthetics, Light, and Glare
AFR Agriculture Resources and Forest Resources
AIR Air Quality
BIO Biological Resources
CUL Cultural Resources
GEO Geology and Soils
GHG Greenhouse Gas Emissions
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Code Environmental Issue
HAZ Hazards and Hazardous Materials
HYD Hydrology and Water Quality
LUP Land Use and Planning
MIN Mineral Resources
NOI Noise
POP Population and Housing
PS Public Services
REC Recreation
TRANS Transportation and Traffic
TCR Tribal Cultural Resources
USS Utilities and Service Systems
Comparative Analysis of Scenarios
This EIR will evaluate the proposed project plus three additional scenarios that consist of
modifications to the project. Because each scenario contemplates less residential development than
the proposed project, they will be evaluated at a qualitative level in each topical section.
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3.1 - Aesthetics, Light, and Glare
3.1.1 - Introduction
This section describes the existing aesthetics, light and glare setting and potential effects from
project implementation on visual resources and the site and its surrounding area. Descriptions and
analysis in this section are based on site reconnaissance by FCS, as well as review of the City of
Orange General Plan.
3.1.2 - Environmental Setting
Visual Character
Regional Setting
The City of Orange, population 141,240, is located in central Orange County at the base of the Santa
Ana Mountains. Orange is characterized by a mix of contemporary low-rise suburban development
in the northern and eastern portions of the city limits; early 20th century development in the historic
Old Towne area in the western and central portion of the city limits; and denser mid-rise
development near the “Orange Crush” interchange1 in the southern portion of the city. Wholly
contained within the Orange city limits is the City of Villa Park, which exhibits similar visual
attributes. The eastern portion of Orange sits on the lower slopes of the Santa Ana Mountains and
thus features lower-density residential development and open space areas.
Local Setting
The approximately 109-acre project site contains disturbed, privately owned undeveloped land that
previously supported mining activities and currently supports a sand gravel operator in accordance
with the existing Sand and Gravel zoning (Orange Municipal Code Chapter 17.32). The project site is
comprised of 12 parcels and is bisected by Santiago Creek in an east-west direction. The site
contains gently sloping terrain, with an overall change in elevation from 456 feet above mean sea
level in the northeast corner to 344 feet above mean sea level in the southwest corner. An
approximately 10-acre, semi-oval-shaped raised pad is located in the eastern portion of the site. The
pad sits roughly 15 feet higher than the mining area to the west.
Approximately 40 acres between Santiago Creek and East Santiago Canyon Road contains remnants
of the mining operation and is the location of the ongoing sand and gravel operation. This area is
characterized by soil piles and berms, and unpaved roads. Near East Santiago Canyon Road is an
approximately 5-acre area that supports a materials recycling operation that included apparatus for
the crushing of boulders, bricks, rocks, and similar materials for recycling. Materials used for these
operations originated primarily from off-site sources and the materials generated by these
operations have historically been used both on-site and transported off-site. Ancillary uses included
administration and maintenance buildings, caretaker residence, material testing laboratory, driver’s
shack, rock crushing facilities, several above ground and below ground fuel storage tanks and two
hot-mix asphalt plants.
1 The interchange of Interstate 5, State Route 22, and State Route 57.
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Additionally, the previously mined portions of the site were “backfilled,” in which unsuitable
materials were excavated and replaced with fill, pursuant to a grading permit issued by the City of
Orange in 2011. It was anticipated that approximately 223,000 cubic yards of material would be
imported to the site during the process, including concrete, asphalt and rock that would be crushed
on-site. Approximately 2,000 cubic yards of material was anticipated to be excavated from the site
for reuse and would be blended with the crushed import material for a total of 225,000 cubic yards
of backfill. In 2015, the operator voluntarily temporarily suspended operations on the site, and
limited rock crushing operations to a total of 15 consecutive business days in any six-month period.
The operator reserved the right to resume all operations consistent with the Sand and Gravel zoning.
Santiago Creek enters the site at the eastern boundary, flows west, and exits the western boundary
at North Cannon Street. The creek originates at Irvine Lake and is tributary to the Santa Ana River.
The drainage feature splits near the central portion of the project site, with an upland area
separating Santiago Creek into two rivulets. The average width of the drainage feature is
approximately 55 feet, which includes the area between the ordinary high water mark and the
adjacent defined wetland areas. Wetland areas are generally located on either side of the active
channel. The creek corridor is not accessible to the public.
Natural vegetation within the site is primarily located along Santiago Creek. Plant communities
include coast live woodland, coastal sage scrub, eucalyptus woodland, non-native grassland,
ornamental, southern cottonwood-willow riparian forest, and undifferentiated open woodland.
There are 323 trees located with the project site, of which the most common species are blue gum
(eucalyptus), oak, willow, and palm; the proposed project would follow the City of Orange Tree
Preservation Ordinance by replacing any removed trees in a no-less-than 1:1 ratio. Further
discussion of on-site trees is found in Section 3.4, Biological Resources.
Surrounding Land Uses
The following is a summary of surrounding land uses. Exhibit 3.1-1 provides views of surrounding
land uses.
West
The closed Villa Park Landfill and North Cannon Street form the western boundary of the project
site.
The 18-acre Villa Park Landfill occupies the northeast quadrant of the intersection of East Santiago
Canyon Road/North Cannon Street and is owned by the County of Orange. The landfill operated
from 1962 through 1966. The site is enclosed with a fence and contains groundwater monitoring
wells and a landfill gas disposal system. The western and southern portions of the project site are
visible from the landfill.
North Cannon Street is a four-lane divided roadway and crosses Santiago Creek via a concrete
bridge. A paved Class I bicycle/pedestrian path (Santiago Creek Bike Trail) is located along the west
side of North Cannon Street south of Santiago Creek. The western portion of the project site is
visible from North Cannon Street.
Single-family residential uses north of Mabury Avenue Villa Park Landfill (Closed)
Mara Brandman Arena Single-family residential uses south of E. Santiago Canyon Road
Source: FirstCarbon Solutions, 2016.
27650002 • 07/2018 | 3.1-1_surroundLU.cdr
Exhibit 3.1-1
Surrounding Land Uses
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
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North
Single-family residential uses (8,000-square-foot lots) and Mabury Avenue form the northern
boundary of the project site. Detached, single-family dwelling units are located along the north bank
of Santiago Creek. Mabury Avenue is a two-lane undivided roadway. An unpaved trail (Santiago
Creek Trail) is located along the north bank of the creek, parallel to Mabury Avenue. The northern
portion of the project site is visible from Mabury Avenue.
East
Santiago Oaks Regional Park and single-family residential uses (40,000-square-foot lots) form the
eastern boundary of the project site. The Santiago Creek corridor contains dense vegetation.
Detached, single-family dwelling units are located east of the project site. The eastern portion of the
project site is visible from Santiago Regional Park and the single-family residential uses.
South
East Santiago Canyon Road, a four-lane, divided roadway, forms the southern boundary of the
project site. Detached single-family dwelling units (8,000- and 40,000-square-foot lots) are located
south of the roadway. The Mara Brandman Arena is located at the intersection of East Santiago
Canyon Road and North Nicky Way. The southern portion of the project site is visible from East
Santiago Canyon Road.
Scenic Vistas
A Scenic Vista, as defined by the City of Orange General Plan EIR, is a viewpoint that provides
expansive views of a highly valued landscape for the benefit of the general public. Portions of the
City are characterized by scenic vistas including undeveloped hillsides, ridgelines, and open space
areas that provide a unifying visual backdrop to the urban environment. An abundance of scenic
vistas occur in the largely undeveloped Santiago Hills II and East Orange portions of the planning
area including Irvine Lake, grassy valleys, rugged hillsides, and winding canyons.
Viewscape Corridor
Several city roadways display scenic qualities and are designed as viewscape corridors by the County of
Orange. Viewscape corridors are defined by the City ’s General Plan EIR as routes that traverse a
corridor within which unique or unusual scenic resources and aesthetic values are found. The County
of Orange designates viewscape corridors including portions of Jamboree Road, Santiago Canyon Road,
and Newport Boulevard. The City does not contain any County-designated landscape corridors.
According to the Visual and Aesthetic Resources of the City’s General Plan (page NR-8), Policy 7.2, (as
shown in figure NR-4, Viewscape Corridors) the section of Santiago Canyon Road designated a
viewscape corridor is located to the east of Jamboree Road and is not within the vicinity of the
project site.
Scenic Resources
Scenic resources are defined as those landscape patterns and features that are visually or
aesthetically pleasing and that, therefore, contribute affirmatively to the definition of a distinct
community or region including, but not limited to, trees, rock outcroppings, and historic buildings.
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Scenic areas, open spaces, rural landscapes, vistas, country roads, and other factors interact to
produce a net visual benefit upon individuals or communities.2 Santiago Creek is considered a scenic
resource by the City’s General Plan EIR.
Light and Glare
There are no existing sources of light and glare within the project boundaries. The proposed project
may include light poles, solar panels, window glazing, and lights/glare typically associated with
residential uses. To preserve the naturalness of the site, light and glare from the proposed project
will be managed in accordance with the City of Orange Zoning Ordinance. The City of Orange Zoning
Ordinance regulates lighting and stipulates that lighting and glare shall be controlled in order to
prevent glare or direct illumination on surrounding premises, public sidewalks, or thoroughfares.
3.1.3 - Regulatory Framework
Local
City of Orange
General Plan
The General Plan sets forth the following goals and policies that are relevant to aesthetics, light, and
glare:
Land Use Element
• Goal 6.0: Advance development activity that is mutually beneficial to both the environment
and the community.
• Policy 6.1: Ensure that new development is compatible with the style and design of
established structures and the surrounding environment.
• Policy 6.3: Establish and maintain greenways, and pedestrian and bicycle connections that
complement the residential, commercial and open space areas they connect.
• Policy 6.4: Create and maintain open space resources that provide recreational opportunities,
protect hillside vistas and ridgelines, and conserve natural resources.
• Policy 6.6: Enhance the walkability of both new and current development.
• Policy 6.7: Integrate natural amenities and connections, including waterways and wildlife
corridors, within the design of urban and suburban spaces.
• Goal 7.0: Promote coordinated planning among City departments and agencies, property
owners, residents, special districts, and other jurisdictions in the region.
• Policy 7.5: Work with and encourage other agencies and service providers to minimize
potential visual and environmental impacts of their facilities on Orange.
Natural Resources Element
• Goal 7.0: Protect significant view corridors, open space, and ridgelines within the urban
environment.
• Policy 7.1: Preserve the scenic nature of significant ridgelines visible throughout the community.
• Policy 7.2: Designate Santiago Canyon Road east of Jamboree Road as a City Scenic Highway to
preserve the scenic nature of the open space adjacent to the road.
2 City of Orange. “City of Orange General Plan Program EIR.” Planning. N.P., 2010. Web. 12 Dec. 2016.
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• Policy 7.3: Encourage the development of landscaped medians and parkway landscaping
along arterial streets in public and private projects, and encourage the state to provide
freeway landscaping.
• Policy 7.4: Coordinate with Southern California Edison and other utilities to place utility lines
underground wherever possible.
• Policy 7.5: Encourage the retention and enhancement of scenic corridors and visual focal
points within the community.
City of Orange Municipal Code
The City’s Zoning Ordinance regulates lighting. Section 17.12.030 states:
The following provisions shall apply:
A. Lighting on any premises shall be directed, controlled, screened or shaded in such a
manner as not to shine directly on surrounding premises. Furthermore, lighting on any
residential property shall be controlled so as to prevent glare or direct illumination of
any public sidewalk or thoroughfares.
The City’s Tree Preservation Ordinance (Municipal Code Chapter 12.32) protects all trees, regardless
of species, that measure a minimum 10.5 inches in circumference, measured at a point 24 inches
above the ground. The purpose of the Ordinance is provided below.
The primary concern of the City Council of the City is the regulation of large scale
tree removal from undeveloped property in that large parcels of undeveloped
acreage are more likely to have a vast number of trees, the removal of which is more
likely to have an adverse effect upon the surrounding environment. Past destruction
of trees on such property has not only interfered with the natural scenic beauty and
tourism of the City, but also greatly diminished the ecological value of such natural
vegetation.
Other areas of the Code related to aesthetics are not applicable to the proposed project because of
the Planning Community (PC) zoning allows for the Specific Plan (SP) to create its own design
standards. The Residential Infill Guideline does not apply to the proposed project because the
proposed project is a subdivision consisting of more than four lots.
Grading Guidelines
The Orange City Council adopted the Guidelines for Landform Grading and Planting on April 12,
1988, which establishes policies designed to preserve visually significant ridgelines. Many of these
ridgelines are identified on the General Plan Land Use Policy Map and no development or grading is
permitted in areas so designated.
3.1.4 - Methodology
FCS evaluated potential project impacts on aesthetics, light, and glare through site reconnaissance
and review of applicable plans and policies. FCS personnel visited the project site and surrounding
land uses in December of 2016; documented the site conditions through photographs and notation;
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and reviewed aerial photographs, topographical maps, street maps, project plans, and elevations to
identify surrounding land uses and evaluate potential impacts form project development. The City
of Orange General Plan was reviewed to determine applicable policies and design requirements for
the Project. Project plans and design guidelines were reviewed to determine compliance with the
requirements of the General Plan.
3.1.5 - Thresholds of Significance
According to Appendix G, Environmental Checklist of the CEQA Guidelines, aesthetics impacts resulting
from the implementation of the proposed project would be considered significant if the project would:
a) Have a substantial adverse effect on a scenic vista?
b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings,
and historic building within a state scenic highway? (Refer to Section 7, Effects Found Not To
Be Significant.)
c) Substantially degrade the existing visual character or quality of the site and its surroundings?
d) Create a new source of substantial light or glare which would adversely affect day or
nighttime views in the area?
3.1.6 - Project Impacts and Mitigation Measures
This section discusses potential impacts associated with the development of the project and
provides mitigation measures where appropriate.
Scenic Vistas
Impact AES-1: The project would not have a substantial adverse effect on a scenic vista.
Impact Analysis
The City of Orange’s General Plan EIR defines a scenic vista as a viewpoint that provides expansive
views of a highly valued landscape for the benefit of the general public.
The only portion of the project site that could be considered a scenic vista would be the Santiago
Creek Trail along the north bank of Santiago Creek. (The trail passes through several heavily
vegetated areas, which limits viewpoint opportunities.) The balance of the project site is closed to
public access and secured with a fence.
A greenway would be established along the creek corridor and the undeveloped land along the
north bank of the creek would be permanently protected as open space. Thus, scenic views from
the Santiago Creek Trail would not be affected by the project.
Additionally, a trail network is proposed to be developed within the project site that would connect
North Cannon Street and Santiago Oaks Regional Park. This would create new opportunities for
scenic vistas.
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In summary, the proposed project would not significantly impact designated scenic resources,
including views of the project and from the project vicinity. Impacts would be less than significant.
Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
Visual Character
Impact AES-2: The project would not substantially degrade the existing visual character or quality
of the site and its surroundings.
Impact Analysis
Implementation of the project would represent a change from disturbed undeveloped land to
residential uses on approximately 40.7 acres of the western and southern portion of the site. Other
areas of the project would be preserved for recreation and open space purposes. In addition, the
project would include a multipurpose trail network for biking, hiking, and horseback that would
connect North Cannon Street and Santiago Oaks Regional Park. The following discusses the potential
visual character impacts of these proposed changes.
The approximately 109-acre site contains disturbed, undeveloped land that previously supported
mining activities. The project proposes to develop approximately 40.7 acres of residential uses, and
preserve the remaining acreage for recreation and open space. Natural vegetation within the site is
primarily located along Santiago Creek. There are 323 trees located within the project site, with the
most common species being blue gem (eucalyptus), oak, willow, and palm.
The residential uses would occupy the 40.7 acres in the southern and western portion of the site
between Santiago Creek and East Santiago Canyon Road. This area coincides with the former mining
area and the oval-shaped raised pad. Open space and residential uses would occupy the balance of
the project site. Santiago Creek and the area north of the creek would be permanently preserved as
greenway.
The area located south of the creek and west of the residential uses would be occupied by open
space and recreation uses. This latter area would serve as a buffer between the adjoining Villa Park
Landfill and the proposed residential uses. Additionally, a trail would be developed along the south
bank of Santiago Creek that would connect North Cannon Street and Santiago Oaks Regional Park.
While development of the residences on site would change the character of approximately 40.7
acres of the project site to residential uses, and the remaining acreage to open space and recreation,
these changes would not result in a significant impact. In addition, the residential development area
would be compatible with surrounding uses and consistent with City policies related to aesthetics.
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Therefore, the project would not substantially degrade the visual quality of the project area or its
surroundings, and impacts related to changed character would be considered less than significant.
Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
Light and Glare
Impact AES-3: The project may create a new source of substantial light or glare which would
adversely affect day or nighttime views in the area.
Impact Analysis
The proposed project would install exterior lighting fixtures for safety and security purposes.
Lighting would consist of building-mounted and freestanding fixtures around buildings, along drive
aisles and along pedestrian routes.
Orange Municipal Code Chapter 17.12.030 regulates the installation of new exterior lighting fixtures
and requires that they be directed, controlled, screened or shaded in such a manner as not to shine
directly on surrounding premises. Furthermore, lighting on any residential property must be
controlled so as to prevent glare or direct illumination of any public sidewalk or thoroughfares. The
proposed project has the potential to use construction materials, solar panels and window glazing
that have the potential to increase light and glare. However, the proposed project’s lighting shall be
controlled to prevent glare and illumination within outside areas of the project site. Therefore,
Mitigation Measure AES-3 requires the applicant to prepare and submit a lighting plan to the City of
Orange for review and approval that complies the Municipal Code requirements. In summary, the
City of Orange establishes restrictions on outdoor lighting that require fixtures to be directed
downward, and of appropriate intensity. This would ensure that outdoor lighting associated with
the proposed project would not create adverse spillover impacts onto adjoining uses or interfere
with aviation activities. Impacts would be less than significant.
Level of Significance Before Mitigation
Potentially significant impact.
Mitigation Measures
MM AES-3 Prior to issuance of building permits, the project applicant shall prepare and submit
lighting plans to the City of Orange for review and approval. The plans shall
demonstrate that all exterior lighting fixtures comply with Orange Municipal Code
Chapter 17.12.030, which requires that new light fixtures be directed, controlled,
screened or shaded in such a manner as not to shine directly on surrounding
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premises. Additionally, lighting on any residential property must be controlled so as
to prevent glare or direct illumination of any public sidewalk or thoroughfares.
Level of Significance After Mitigation
Less than significant impact.
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3.2 - Agriculture Resources and Forest Resources
This section describes the existing agricultural resources and potential effects from project
implementation on the project site and its surrounding area. Descriptions and analysis in this section
are based in part on information provided by the California Department of Conservation Farmland
Mapping and Monitoring Program, the United States Department of Agriculture Natural Resources
Conservation Service Web Soil Survey, the California Department of Conservation’s Williamson Act and
Farmland Mapping and Monitoring Program, and the City of Orange General Plan.
3.2.1 - Existing Conditions
Land Use Activities
The project site has supported surface mining activities (aggregate) and currently supports sand and
gravel operations and materials recycling (such as asphalt and concrete crushing). The remaining
portions of the project site are undeveloped.
Agricultural production intermittently occurred on the project site with the most recent production
occurring from approximately 1993 through 2004. Agricultural production included fruit orchards
and strawberry production. All agricultural uses on the site ceased in 2004. Additionally, the project
site has also been used intermittently for storage of firewood and green waste recycling.
Farmland Mapping
The California Department of Conservation Farmland Mapping and Monitoring Program maps the
project site as “Other Land,” which is a non-agricultural land use designation. Exhibit 3.2-1 depicts
the Farmland Mapping and Monitoring Program mapping for the project vicinity.
Williamson Act Contracts
The project site does not support agricultural land use activities and therefore is not eligible for a
Williamson Act contract.
Agricultural Zoning
The City of Orange Zoning Ordinance zones the project site “S-G (Sand and Gravel Extraction)” and
“R-1-8 (Single-Family Residential 8,000 square-feet).” The S-G Zoning is a non-agricultural zoning
district. The R-1-8 zoning allows agriculture/horticulture by-right, as well as tree and shrub farms
through a conditional use permit.
3.2.2 - Regulatory Setting
State Regulations
California Land Conservation Act (Williamson Act)
The California Land Conservation Act of 1965 (Williamson Act) enables local governments to enter
into contracts with private landowners for the purpose of restricting specific parcels of land to
maintain agricultural or related open space use. As an incentive, landowners receive lower property
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tax assessments based on agricultural or open space land uses, as opposed to the real estate value
of the land. No land within the City of Orange is currently under a Williamson Act contract.
California Department of Conservation Classification
The California Department of Conservation (CDC), Division of Land Resource Protection developed
the Farmland Mapping and Monitoring Program (FMMP) in 1984 to analyze impacts to California’s
agricultural resources. In the FMMP, land ratings are based on a land capability classification
system, and land use. According to FMMP (2014), the project site has an agricultural land rating of
“Other Land.”
Public Resources Code
The California Public Resource Codes Section 4562 defines Forest Land and Timber Land as follows:
Forest Land
Land that can support 10-percent native tree cover of any species, including: hardwoods, under
natural conditions, and that allows for management of one or more forest resources, including
timber, aesthetics, fish and wildlife, biodiversity, water quality, recreation, and other public benefits.
Timber Land
Land, other than land owned by the federal government and land designated by the Board of
Forestry and Fire Protection (Board) as experimental forest land, which is available for, and capable
of, growing a crop of trees of any commercial species used to produce lumber and other forest
products, including Christmas trees. Commercial species shall be determined by the Board on a
District basis after consultation with the District committees and others.
Local
City of Orange
There are no City General Plan goals or policies that pertain to farmland and forest land.
3.2.3 - Thresholds of Significance
According to CEQA Guidelines Appendix G, to determine whether impacts to agriculture and forestry
resources are significant environmental effects, the following questions are analyzed and evaluated.
Would the project:
a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance
(Farmland) as shown on the maps prepared pursuant to the Farmland Mapping and
Monitoring Program of the California Resources Agency, to non-agricultural use?
b) Conflict with existing agricultural zoning, agricultural use or with land subject to a
Williamson Act contract?
c) Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public
Resources Code section 12220(g)), timberland (as defined by Public Resources Code section
4526), or timberland zoned Timberland Production (as defined by Govt. Code section
51104(g))?
27650002 • 07/2018 | 3.2-1_fm m p_lan duse.m xd
Exhibit 3.2-1Lan d U se Classification Map
Source: CA Dept of Con servatoin - Im portan t Farm lan d Data 2014.
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN RECIRCU LATED DRAFT ENVIRONMENTAL IMPACT REPORT
E S a n t i a g o C a n y o n R d
NHewesStNCanonSt SerranoAveOrangeParkBlvdN
C
a
n
nonSt
ViaEs c o la
M a b u ry A v eETaftAve SantiagoCreekSantiago CreekRecharge Basin
Villa ParkLandfill (Closed)
Linda VistaElementarySchool
OakridgePrivateSchool
Salem LutheranChurch and School
1,500 0 1,500750
Feet
Legend
Project Site
Urban and Built-Up Land
Other Land
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d) Result in the loss of forest land or conversion of forest land to non-forest use?
e) Involve other changes in the existing environment which, due to their location or nature,
could result in the conversion of Farmland to non-agricultural use or the conversion of
forest land to non-forest use?
3.2.4 - Project Impacts and Mitigation Measures
This section discusses potential impacts associated with the proposed project and provides
mitigation measures where necessary.
Convert Farmland to Non-Agricultural Use
Impact AFR-1: The project would not convert Important Farmland to non-agricultural use.
Impact Analysis
Agricultural land use activities occurred on the project site as recently as 2004; however, the project
site does not currently support agricultural activities. As shown in Exhibit 3.2-1, the project site is
mapped as containing “Other Land” by the California Department of Conservation Farmland
Mapping and Monitoring Program, which is a non-agricultural land use designation. Therefore, the
development of the proposed project would not result in the conversion of Important Farmland to
non-agricultural use. No impacts would occur.
Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
Conflict with Existing Zoning or Williamson Act Contract
Impact AFR-2: The project would not conflict with existing agricultural zoning, agricultural use or
with land subject to a Williamson Act contract.
Impact Analysis
The project site does not support agricultural land use activities and, therefore, is not eligible for a
Williamson Act contract. The City of Orange Zoning Ordinance zones the project site “S-G (Sand and
Gravel Extraction)” and “R-1-8 (Single-Family Residential 8,000 square-feet).” The S-G is a non-
agricultural zoning district. The R-1-8 zoning allows agriculture/horticulture by-right, as well as tree
and shrub farms through a conditional use permit. The proposed project would rezone the project
site to Specific Plan (SP), which represent non-agricultural zoning. Thus, no conflicts with agricultural
zoning would occur.
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Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
Forest Zoning
Impact AFR-3: Forest: The project would not conflict with existing zoning for, or cause rezoning
of, forest land (as defined in Public Resources Code section 12220(g)), timberland
(as defined by Public Resources Code section 4526), or timberland zoned
Timberland Production (as defined by Govt. Code section 51104(g)).
Impact Analysis
The project site is not currently zoned as forest land, timberland, or timberland zoned timberland
production as defined by Public Resources Code sections 1220(g), 4526, or 51104(g). The project
site is currently zoned for R-1-8 (Single-Family Residential) and S-G (Sand and Gravel Extraction).
Therefore, the proposed project would not conflict with existing zoning for, or cause the rezoning of
forest land, timberland, or timberland zoned timberland production. Thus, no impacts would occur
as a result of the proposed project.
Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
Loss or Conversion of Forest Land
Impact AFR-4: The project would not result in the loss of forest land or conversion of forest land
to non-forest use.
Impact Analysis
The project site contains disturbed, undeveloped land that previously supported mining activities.
There are 323 trees within the project site, of which the most common species are blue gum
(eucalyptus), oak, willow, and palm. The trees within the project site do not meet Public Resources
Code criteria for “timberland” because they are not commercial species used to produce lumber or
other forest products. Additionally, they do not meet the Public Resource Code definition of “forest
land” because they do not meet the minimum density requirements to be classified as forest land.
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Thus, tree removal activities would not result in the conversion of timberland to non-timber use or
forest land to non-forest use. No impacts would occur.
Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
Other Changes to Agricultural or Forest Land
Impact AFR-5: Forest: The project would not involve other changes in the existing environment
which, due to their location or nature, could result in conversion of agricultural
land to non-agricultural use or forest land to non-forest use.
Impact Analysis
Neither the project site nor surrounding land uses support agricultural land or timberland. This
condition precludes the possibility of the proposed project creating pressures to convert farmland or
timberland in the project vicinity to non-agricultural use. No impact would occur.
Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
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3.3 - Air Quality
This section describes the existing air quality setting and potential effects from project
implementation on the site and its surrounding area. Additionally, this section evaluates the
possible impacts related to air quality that could result from implementation of the proposed
project. Information included in this section is based on project-specific air quality modeling results
utilizing California Emissions Estimator Model (CalEEMod) Version 2016.3.2 and the United States
Environmental Protection Agency (EPA) AERMOD air dispersion model (Version 9.6.1); complete
modeling output is provided in Appendix F.
3.3.1 - Environmental Setting
South Coast Air Basin
The project is located in the City of Orange and is within the South Coast Air Basin (SoCAB). The San
Gabriel, San Bernardino, and San Jacinto Mountains bound the SoCAB on the north and east while
the Pacific Ocean lies to the west of the SoCAB. The southern limit of the SoCAB is the San Diego
County line. The SoCAB consists of Orange County, Los Angeles County (except for the Antelope
Valley), the non-desert portion of western San Bernardino County, and the western and Coachella
Valley portions of Riverside County.
Sensitive receptors represent the locations where potential project-related impacts are estimated and
can include uses such as long term health care facilities, rehabilitation centers, and retirement homes.
Residences, schools, playgrounds, child care centers, and athletic facilities can also be considered as
sensitive receptors where individuals can be located for time periods of 24 hours or longer.
There are a number of existing residences near the project site. The closest existing residences are
located to the east of the project site along River Birch Circle and Sycamore Glen Dr. The Salem
Lutheran School is located approximately 600 feet to the south of the project across the East
Santiago Canyon Rd. The shortest distances between existing sensitive receptors and the
construction site ranges from 25 meters to 35 meters (82 to 115 feet).
Regional Climate
The regional climate factors such as the temperature, wind, humidity, precipitation, and amount of
sunshine have a substantial influence on air quality in the SoCAB. The annual average temperatures
throughout the SoCAB vary from the low to middle 60s (degrees Fahrenheit [°F]). Because of a
decreased marine influence, the eastern portion of the SoCAB shows greater variability in average
annual minimum and maximum temperatures. January is the coldest month throughout the SoCAB,
with average minimum temperatures of 47°F in downtown Los Angeles and 36°F in San Bernardino.
All portions of the SoCAB have recorded maximum temperatures above 100°F.
Although the climate of the SoCAB can be characterized as semi-arid, the air near the land surface is
relatively humid on most days because of the presence of a marine layer from the Pacific Ocean.
This shallow layer of sea air is an important modifier of SoCAB climate. Humidity restricts visibility in
the SoCAB, and the conversion of sulfur dioxide to sulfates is heightened in air with high relative
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humidity. The marine layer provides an environment for that conversion process, especially during
the spring and summer months. The annual average relative humidity within the SoCAB is 71
percent along the coast and 59 percent inland. Since the ocean effect is dominant, periods of heavy
early morning fog are frequent and low stratus clouds are a characteristic feature of the coastal
areas. These effects decrease with distance from the coast.
More than 90 percent of the SoCAB’s rainfall occurs from November through April. The annual
average rainfall varies from approximately 9 inches in Riverside to 14 inches in downtown Los
Angeles. Monthly and yearly rainfall totals are extremely variable. Summer rainfall usually consists
of widely scattered thunderstorms near the coast and slightly heavier shower activity in the eastern
portion of the SoCAB with frequency being higher near the coast.
Because of its generally clear weather, about three-quarters of available sunshine is received in the
SoCAB. The remaining one-quarter is absorbed by clouds. The ultraviolet portion of this abundant
radiation is a key factor in photochemical reactions. On the shortest day of the year there are
approximately 10 hours of possible sunshine, and on the longest day of the year there are
approximately 14.5 hours of possible sunshine.
The importance of wind to air pollution is considerable. The direction and speed of the wind
determines the horizontal dispersion and transport of the air pollutants. During the late autumn to
early spring rainy season, the SoCAB is subjected to wind flows associated with the traveling storms
moving through the region from the northwest. This period also brings five to ten periods of strong,
dry offshore winds, locally termed “Santa Ana Winds” each year. During the dry season, which
coincides with the months of maximum photochemical smog concentrations, the wind flow is
bimodal, typified by a daytime onshore sea breeze, and a nighttime offshore drainage wind.
Summer wind flows are created by the pressure differences between the relatively cold ocean, and
the unevenly heated and cooled land surfaces that modify the general northwesterly wind
circulation over Southern California. Nighttime drainage begins with the radiational cooling of the
mountain slopes. Heavy, cool air descends the slopes and flows through the mountain passes and
canyons as it follows the lowering terrain toward the ocean. Another characteristic wind regime in
the SoCAB is the “Catalina Eddy,” a low level cyclonic (counterclockwise) flow centered over Santa
Catalina Island, which results in an offshore flow to the southwest. On most spring and summer
days, some indication of an eddy is apparent in coastal sections.
In the SoCAB, there are two distinct temperature inversion structures that control vertical mixing of
air pollution. During the summer, warm high-pressure descending (subsiding) air is undercut by a
shallow layer of cool marine air. The boundary between these two layers of air is a persistent
marine subsidence/inversion. This boundary prevents vertical mixing which effectively acts as an
impervious lid to pollutants over the entire SoCAB. The mixing height for the inversion structure is
normally situated 1,000 to 1,500 feet above mean sea level.
A second inversion-type forms in conjunction with the drainage of cool air off the surrounding
mountains at night followed by the seaward drift of this pool of cool air. The top of this layer forms a
sharp boundary with the warmer air aloft and creates nocturnal radiation inversions. These inversions
occur primarily in the winter, when nights are longer and onshore flow is weakest. They are typically
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only a few hundred feet above mean sea level. These inversions effectively trap pollutants, such as
oxides of nitrogen (NOX) and carbon monoxide (CO) from vehicles, as the pool of cool air drifts
seaward. Winter is therefore a period of high levels of primary pollutants along the coastline.
Existing Local Air Quality
Existing ambient air quality, historical trends, and future projections of air quality in the project area
are best documented from measurements made near the project site. The South Coast Air Quality
Management District (SCAQMD) maintains an extensive air-morning network that measures levels of
several air pollutants throughout the SoCAB. Air quality in the SoCAB continues to improve over the
long term, although the maximum concentration and number of days each year in which some
standards are exceeded fluctuates from year to year due to weather conditions.
The SCAQMD has subdivided the SoCAB into 36 Source-Receptor Areas (SRAs), many containing one or
more monitoring stations. These SRAs are designated to provide a general representation of the local
meteorology, terrain, and air quality conditions within the particular geographical area. The project is
located within the SRA 17 (Central Orange County). The nearest SCAQMD operated monitoring station
to the project site where pollutant data are collected is the Pampas Lane Anaheim station in Anaheim,
California, located about 7.5 miles east of the project site. Table 3.3-1 summarizes published
monitoring data for the time period of 2014 through 2016. The data show that during the past few
years, the project area has exceeded the state and/or federal ambient air quality standards for ozone,
particulate matter PM10 and PM2.5. The pollutant levels from SRA 17 were used to represent a
“background” air quality for the project location.
Table 3.3-1: Air Quality Monitoring Summary
Air Pollutant
Averaging
Time Air Standard 2014 2015 2016
Ozone 1 Hour Max 1 Hour (ppm) 0.111 0.100 0.103
Days > State Standard (0.09 ppm) 2 1 2
8 Hour Max 8 Hour (ppm) 0.081 0.080 0.074
Days > State Standard (0.07 ppm) 6 1 4
Days > National Standard (0.07 ppm) 6 1 4
Carbon
monoxide
8 Hour
Max 8 Hour (ppm) 2.1 2.2 2.1
Days > State Standard (9.0 ppm) ND ND ND
Days > National Standard (9 ppm) ND ND ND
Nitrogen
dioxide
Annual Annual Average (ppm) 0.0152 0.014 0.0148
1 Hour Max 1 Hour (ppm) 0.0758 0.0591 0.0643
Days > State Standard (0.18 ppm) 0 0 0
98th Percentile 0.0598 0.0546 0.0567
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Table 3.3-1 (cont.): Air Quality Monitoring Summary
Air Pollutant
Averaging
Time Air Standard 2014 2015 2016
Inhalable
coarse
particles
(PM10)
Annual Annual Average (µg/m3) 26.7 25.3 24.4
24 hour 24 Hour (µg/m3) 85.0 59.0 74.0
Days > State Standard (50 µg/m3) 2 2 ID
Days > National Standard (150 µg/m3) 0 0 0
Fine
particulate
matter
(PM2.5)
Annual Annual Average (µg/m3) 16.1 14.8 9.4
24 Hour 24 Hour (µg/m3) 45.0 45.8 44.4
Days > National Standard (35 µg/m3) 4 3 1
Notes:
> = exceed ppm = parts per million µg/m3 = micrograms per cubic meter
ID = insufficient data ND = no data max = maximum
State Standard = California Ambient Air Quality Standard
National Standard = National Ambient Air Quality Standard
Source: Air quality data from the Fontana Arrow monitoring station, and SCAQMD historical ambient air quality
summaries.
The current attainment designations for the SoCAB are shown in Table 3.3-2. The SoCAB is
designated as nonattainment for the state and/or federal ozone, PM10, and PM2.5 standards. The Los
Angeles County portion of the SoCAB is in nonattainment for lead; however, the project area is in
attainment for lead.
Table 3.3-2: SoCAB Attainment Status
Pollutant State Status National Status
Ozone Nonattainment Nonattainment—Extreme
Carbon monoxide Attainment Unclassified/Attainment
Nitrogen dioxide Attainment Unclassified/Attainment
Sulfur dioxide Attainment Attainment
PM10 Nonattainment Attainment
PM2.5 Nonattainment Nonattainment
Lead Attainment Nonattainment
(Los Angeles County Only)
Sulfates Attainment No national standard
Visibility Reducing Particles Unclassified No national standard
Hydrogen Sulfide Unclassified No national standard
Source of State status: ARB 2016b.
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Toxic Air Contaminants
A toxic air contaminant (TAC) is defined as an air pollutant which may cause or contribute to an
increase in mortality or serious illness, or which may pose a hazard to human health. TACs are
usually present in minute quantities in the ambient air. However, their high toxicity or health risk
may pose a threat to public health even at very low concentrations. For those TACs that may cause
cancer, there is no concentration that does not present some risk. In other words, there is no
threshold level below which adverse health impacts are not expected to occur. This contrasts with
the criteria pollutants for which acceptable levels of exposure can be determined, and for which the
State and federal governments have set ambient air quality standards. The majority of the
estimated health risk from TACs can be attributed to a relatively few compounds, the most important
being particulate matter (PM) from diesel-fueled engines, known as diesel particulate matter (DPM).
In addition to DPM, benzene and 1,3 butadiene are also significant contributors to overall ambient
public health risk in California.
The health risks can be defined in terms of the probability of developing cancer as a result of
exposure to carcinogens at a given concentration. The Office of Environmental Health Hazard
Assessment (OEHHA) Air Toxics Hot Spots Program Guidance Manual for Preparation of Health Risk
Assessments (OEHHA Guidance) recommends the incorporation of several factors to quantify the
carcinogenic compound dose via the inhalation pathway which is the most important pathway for
exposures to airborne TACs.
Some studies indicate that DPM poses the greatest health risk among the TACs listed above. A 10-
year research program (ARB 1998) demonstrated that DPM from diesel-fueled engines is a human
carcinogen and that chronic (long-term) inhalation exposure to DPM poses a chronic health risk. In
addition to increasing the risk of lung cancer, exposure to diesel exhaust can have other health
effects. Diesel exhaust can irritate the eyes, nose, throat, and lungs, and it can cause coughs,
headaches, lightheadedness, and nausea. Diesel exhaust is a major source of fine particulate
pollution as well, and studies have linked elevated particle levels in the air to increased hospital
admissions, emergency room visits, asthma attacks, and premature deaths among those suffering
from respiratory problems.
DPM differs from other TACs in that it is not a single substance but a complex mixture of hundreds of
substances. Although DPM is emitted by diesel-fueled, internal combustion engines, the
composition of the emissions varies, depending on engine type, operating conditions, fuel
composition, lubricating oil, and whether an emission control system is present. Unlike the other
TACs, however, no ambient monitoring data are available for DPM because no routine measurement
method currently exists. The ARB has made preliminary concentration estimates based on a DPM
exposure method. This method uses the ARB emissions inventory’s particulate matter less than 10
microns in diameter (PM10) database, ambient PM10 monitoring data, and the results from several
studies to estimate concentrations of DPM.
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Odors
Odors can cause a variety of responses. The impact of an odor results from interacting factors, such
as frequency (how often), intensity (strength), duration (in time), offensiveness (unpleasantness),
location, and sensory perception.
Odor is typically a warning system that prevents animals and humans from consuming spoiled food
or toxic materials. Odor-related symptoms reported in a number of studies include nervousness,
headache, sleeplessness, fatigue, dizziness, nausea, loss of appetite, stomach ache, sinus congestion,
eye irritation, nose irritation, runny nose, sore throat, cough, and asthma exacerbation (SCAQMD
2007b).
The SCAQMD’s role is to protect the public’s health from air pollution by overseeing and enforcing
regulations. The SCAQMD’s resolution activity for odor compliance is mandated under California
Health & Safety Code Section 41700, and falls under SCAQMD Rule 402. This rule on Public Nuisance
Regulation states: “A person shall not discharge from any source whatsoever such quantities of air
contaminants or other material which cause injury, detriment, nuisance, or annoyance to any
considerable number of persons or to the public, or which endanger the comfort, repose, health or
safety of any such persons or the public, or which cause, or have a natural tendency to cause, injury
or damage to business or property. The provisions of this rule shall not apply to odors emanating
from agricultural operations necessary for the growing of crops or the raising of fowl or animals.”
The SCAQMD indicates that the number of overall complaints has declined over the last five years.
Over the last four years, odor complaints make up 50 to 55 percent of the total nuisance complaints.
Over the past decade, odors from paint and coating operations have decreased from 27 to 7 percent,
and odors from refuse collection stations have increased from 9 to 34 percent.
Local Sources of Air Pollutants
The project site is largely vacant. Therefore, the only emissions from the current site would consist
of fugitive windblown dust. The project site is surrounded by numerous residences within a radius
of 0.5 mile. Emissions from the surrounding residences include the following: space and water
heating, landscape maintenance, and motor vehicles.
3.3.2 - Regulatory Framework
Air Quality Regulations
Air pollutants are regulated at the national, state, and air basin level; each agency has a different
level of regulatory responsibility. The EPA regulates at the national level. The ARB regulates at the
state level and SCAQMD regulates at the air basin level.
Federal and State
The EPA handles global, international, national, and interstate air pollution issues and policies. The
EPA sets national vehicle and stationary source emission standards, oversees approval of all State
Implementation Plans, provides research and guidance for air pollution programs, and sets National
Ambient Air Quality Standards, also known as federal standards or national standards. There are
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national standards for six common air pollutants, called criteria air pollutants, which were identified
from provisions of the Clean Air Act of 1970. The criteria pollutants are:
• Ozone
• Particulate matter (PM10 and PM2.5)
• Nitrogen dioxide
• Carbon monoxide
• Lead
• Sulfur dioxide
The national standards were set to protect public health, including that of sensitive individuals; thus,
the standards are periodically updated as more medical research is available regarding the health
effects of the criteria pollutants. Primary national standards are the levels of air quality necessary,
with an adequate margin of safety, to protect public health, as discussed in Table 3.3-3 below.
A State Implementation Plan (SIP) is a document prepared by each state describing existing air
quality conditions and measures that will be followed to attain and maintain national standards. The
State Implementation Plan for the State of California is administered by the ARB, which has overall
responsibility for statewide air quality maintenance and air pollution prevention. The ARB also
administers California Ambient Air Quality Standards for the 10 air pollutants designated in the
California Clean Air Act. The 10 state air pollutants are the six national standards listed above as well
as the following: visibility-reducing particulates, hydrogen sulfide, sulfates, and vinyl chloride.
The national and state ambient air quality standards, the most relevant effects, the properties, and
sources of the pollutants are summarized in Table 3.3-3.
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City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Air Quality FirstCarbon Solutions 3.3-9 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec03-03 Air Quality.docx Table 3.3-3 (cont.): Description of Air Pollutants Air Pollutant Averaging Time California Standard Federal Standarda Most Relevant Effects from Pollutant Exposure Properties Sources Sulfur dioxidec (SO2) 1 Hour 0.25 ppm 0.075 ppm Bronchoconstriction accompanied by symptoms which may include wheezing, shortness of breath and chest tightness, during exercise or physical activity in persons with asthma. Some population-based studies indicate that the mortality and morbidity effects associated with fine particles show a similar association with ambient sulfur dioxide levels. It is not clear whether the two pollutants act synergistically or one pollutant alone is the predominant factor. Sulfur dioxide is a colorless, pungent gas. At levels greater than 0.5 ppm, the gas has a strong odor, similar to rotten eggs. Sulfur oxides (SOX) include sulfur dioxide and sulfur trioxide. Sulfuric acid is formed from sulfur dioxide, which can lead to acid deposition and can harm natural resources and materials. Although sulfur dioxide concentrations have been reduced to levels well below state and federal standards, further reductions are desirable because sulfur dioxide is a precursor to sulfate and PM10. Human caused sources include fossil-fuel combustion, mineral ore processing, and chemical manufacturing. Volcanic emissions are a natural source of sulfur dioxide. The gas can also be produced in the air by dimethylsulfide and hydrogen sulfide. Sulfur dioxide is removed from the air by dissolution in water, chemical reactions, and transfer to soils and ice caps. The sulfur dioxide levels in the State are well below the maximum standards. 3 Hour — 0.5 ppm 24 Hour 0.04 ppm 0.14 (for certain areas) Annual — 0.030 ppm (for certain areas) Particulate matter (PM10) 24 hour 50 µg/m3 150 µg/m3 • Short-term exposure (hours/days): irritation of the eyes, nose, throat; coughing; phlegm; chest tightness; shortness of breath; aggravate existing lung disease, causing asthma attacks and acute bronchitis; those with heart disease can suffer heart attacks and arrhythmias. • Long-term exposure: reduced lung function; chronic bronchitis; changes in lung morphology; death. Suspended particulate matter is a mixture of small particles that consist of dry solid fragments, droplets of water, or solid cores with liquid coatings. The particles vary in shape, size, and composition. PM10 refers to particulate matter that is between 2.5 and 10 microns in diameter, (one micron is one-millionth of a meter). PM2.5 refers to particulate matter that is 2.5 microns or less in diameter, about one-thirtieth the size of the average human hair. Stationary sources include fuel or wood combustion for electrical utilities, residential space heating, and industrial processes; construction and demolition; metals, minerals, and petrochemicals; wood products processing; mills and elevators used in agriculture; erosion from tilled lands; waste disposal, and recycling. Mobile or transportation related sources are from vehicle exhaust and road dust. Secondary particles form from reactions in the atmosphere. Mean 20 µg/m3 — Particulate matter (PM2.5) 24 Hour — 35 µg/m3 Annual 12 µg/m3 12.0 µg/m3 Visibility reducing particles 8 Hour See note belowd
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Air Quality FirstCarbon Solutions 3.3-10 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec03-03 Air Quality.docx Table 3.3-3 (cont.): Description of Air Pollutants Air Pollutant Averaging Time California Standard Federal Standarda Most Relevant Effects from Pollutant Exposure Properties Sources Sulfates 24 Hour 25 µg/m3 — (a) Decrease in ventilatory function; (b) aggravation of asthmatic symptoms; (c) aggravation of cardio-pulmonary disease; (d) vegetation damage; (e) degradation of visibility; (f) property damage. The sulfate ion is a polyatomic anion with the empirical formula SO42−. Sulfates occur in combination with metal and/or hydrogen ions. Many sulfates are soluble in water. Sulfates are particulates formed through the photochemical oxidation of sulfur dioxide. In California, the main source of sulfur compounds is combustion of gasoline and diesel fuel. Leade 30-day 1.5 µg/m3 — Lead accumulates in bones, soft tissue, and blood and can affect the kidneys, liver, and nervous system. It can cause impairment of blood formation and nerve conduction, behavior disorders, mental retardation, neurological impairment, learning deficiencies, and low IQs. Lead is a solid heavy metal that can exist in air pollution as an aerosol particle component. Leaded gasoline was used in motor vehicles until around 1970. Lead concentrations have not exceeded state or federal standards at any monitoring station since 1982. Lead ore crushing, lead-ore smelting, and battery manufacturing are currently the largest sources of lead in the atmosphere in the United States. Other sources include dust from soils contaminated with lead-based paint, solid waste disposal, and crustal physical weathering. Quarter — 1.5 µg/m3 Rolling 3-month average — 0.15 µg/m3 Vinyl chloridee 24 Hour 0.01 ppm — Short-term exposure to high levels of vinyl chloride in the air causes central nervous system effects, such as dizziness, drowsiness, and headaches. Epidemiological studies of occupationally exposed workers have linked vinyl chloride exposure to development of a rare cancer, liver angiosarcoma, and have suggested a relationship between exposure and lung and brain cancers. Vinyl chloride, or chloroethene, is a chlorinated hydrocarbon and a colorless gas with a mild, sweet odor. In 1990, ARB identified vinyl chloride as a toxic air contaminant and estimated a cancer unit risk factor. Most vinyl chloride is used to make polyvinyl chloride plastic and vinyl products, including pipes, wire and cable coatings, and packaging materials. It can be formed when plastics containing these substances are left to decompose in solid waste landfills. Vinyl chloride has been detected near landfills, sewage plants, and hazardous waste sites.
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Air Quality FirstCarbon Solutions 3.3-11 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec03-03 Air Quality.docx Table 3.3-3 (cont.): Description of Air Pollutants Air Pollutant Averaging Time California Standard Federal Standarda Most Relevant Effects from Pollutant Exposure Properties Sources Hydrogen sulfide 1 Hour 0.03 ppm — High levels of hydrogen sulfide can cause immediate respiratory arrest. It can irritate the eyes and respiratory tract and cause headache, nausea, vomiting, and cough. Long exposure can cause pulmonary edema. Hydrogen sulfide (H2S) is a flammable, colorless, poisonous gas that smells like rotten eggs. Manure, storage tanks, ponds, anaerobic lagoons, and land application sites are the primary sources of hydrogen sulfide. Anthropogenic sources include the combustion of sulfur containing fuels (oil and coal). Volatile organic compounds (VOC) There are no State or federal standards for VOCs because they are not classified as criteria pollutants. Although health-based standards have not been established for VOCs, health effects can occur from exposures to high concentrations because of interference with oxygen uptake. In general, concentrations of VOCs are suspected to cause eye, nose, and throat irritation; headaches; loss of coordination; nausea; and damage to the liver, the kidneys, and the central nervous system. Many VOCs have been classified as toxic air contaminants. Reactive organic gases (ROGs), or VOCs, are defined as any compound of carbon—excluding carbon monoxide, carbon dioxide, carbonic acid, metallic carbides or carbonates, and ammonium carbonate—that participates in atmospheric photochemical reactions. Although there are slight differences in the definition of ROGs and VOCs, the two terms are often used interchangeably. Indoor sources of VOCs include paints, solvents, aerosol sprays, cleansers, tobacco smoke, etc. Outdoor sources of VOCs are from combustion and fuel evaporation. A reduction in VOC emissions reduces certain chemical reactions that contribute to the formulation of ozone. VOCs are transformed into organic aerosols in the atmosphere, which contribute to higher PM10 and lower visibility. Benzene There are no ambient air quality standards for benzene. Short-term (acute) exposure of high doses from inhalation of benzene may cause dizziness, drowsiness, headaches, eye irritation, skin irritation, and respiratory tract irritation, and at higher levels, loss of consciousness can occur. Long-term (chronic) occupational exposure of high doses has caused blood disorders, leukemia, and lymphatic cancer. Benzene is a VOC. It is a clear or colorless light-yellow, volatile, highly flammable liquid with a gasoline-like odor. The EPA has classified benzene as a “Group A” carcinogen. Benzene is emitted into the air from fuel evaporation, motor vehicle exhaust, tobacco smoke, and from burning oil and coal. Benzene is used as a solvent for paints, inks, oils, waxes, plastic, and rubber. Benzene occurs naturally in gasoline at one to two percent by volume. The primary route of human exposure is through inhalation.
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Air Quality FirstCarbon Solutions 3.3-12 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec03-03 Air Quality.docx Table 3.3-3 (cont.): Description of Air Pollutants Air Pollutant Averaging Time California Standard Federal Standarda Most Relevant Effects from Pollutant Exposure Properties Sources Diesel particulate matter (DPM) There are no ambient air quality standards for DPM. Some short-term (acute) effects of DPM exposure include eye, nose, throat, and lung irritation, coughs, headaches, light-headedness, and nausea. Studies have linked elevated particle levels in the air to increased hospital admissions, emergency room visits, asthma attacks, and premature deaths among those suffering from respiratory problems. Human studies on the carcinogenicity of DPM demonstrate an increased risk of lung cancer, although the increased risk cannot be clearly attributed to diesel exhaust exposure. Diesel PM is a source of PM2.5—diesel particles are typically 2.5 microns and smaller. Diesel exhaust is a complex mixture of thousands of particles and gases that is produced when an engine burns diesel fuel. Organic compounds account for 80 percent of the total particulate matter mass, which consists of compounds such as hydrocarbons and their derivatives, and polycyclic aromatic hydrocarbons and their derivatives. Fifteen polycyclic aromatic hydrocarbons are confirmed carcinogens, a number of which are found in diesel exhaust. Diesel exhaust is a major source of ambient particulate matter pollution in urban environments. Typically, the main source of DPM is from combustion of diesel fuel in diesel-powered engines. Such engines are in on-road vehicles such as diesel trucks, off-road construction vehicles, diesel electrical generators, and various pieces of stationary construction equipment. Notes: ppm = parts per million (concentration) µg/m3 = micrograms per cubic meter Annual = Annual Arithmetic Mean 30-day = 30-day average Quarter = Calendar quarter a Federal standard refers to the primary national ambient air quality standard, or the levels of air quality necessary, with an adequate margin of safety to protect the public health. All standards listed are primary standards except for 3-Hour SO2, which is a secondary standard. A secondary standard is the level of air quality necessary to protect the public welfare from any known or anticipated adverse effects of a pollutant. b To attain the 1-hour nitrogen dioxide national standard, the 3-year average of the annual 98th percentile of the 1-hour daily maximum concentrations at each site must not exceed 100 parts per billion (0.100 ppm). c On June 2, 2010, a new 1-hour SO2 standard was established and the existing 24-hour and annual primary standards were revoked. To attain the 1-hour national standard, the 3-year average of the annual 99th percentile of the 1-hour daily maximum concentrations at each site must not exceed 75 ppb. The 1971 SO2 national standards (24-hour and annual) remain in effect until one year after an area is designated for the 2010 standard, except that in areas designated nonattainment for the 1971 standards, the 1971 standards remain in effect until implementation plans to attain or maintain the 2010 standards are approved. d Visibility reducing particles: In 1989, ARB converted both the general statewide 10-mile visibility standard and the Lake Tahoe 30-mile visibility standard to instrumental equivalents, which are “extinction of 0.23 per kilometer” and “extinction of 0.07 per kilometer” for the statewide and Lake Tahoe Air Basin standards, respectively. e ARB has identified lead and vinyl chloride as “toxic air contaminants” with no threshold level of exposure for adverse health effects determined. These actions allow for the implementation of control measures at levels below the ambient concentrations specified for these pollutants. Source of effects, properties, and sources: South Coast Air Quality Management District 2007a; California Environmental Protection Agency 2002; California Air Resources Board 2009; United States Environmental Protection Agency 2003, 2009a, 2009b, 2010, 2011a, and 2012; National Toxicology Program 2011a and 2011b. Source of standards: California Air Resources Board 2013c.
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Federal Regulations
The EPA is responsible for setting and enforcing the National Ambient Air Quality Standards (NAAQS)
for ozone (O3), CO, nitrogen dioxide (NO2), sulfur dioxide (SO2), particulate matter (PM10), and lead.
The EPA has jurisdiction over emissions sources that are under the authority of the federal
government including aircraft, locomotives, and emissions sources outside state waters (Outer
Continental Shelf). The EPA also establishes emission standards for vehicles sold in states other than
California. Automobiles sold in California must meet the stricter emission requirements of the ARB.
The Federal Clean Air Act (CAA) was first enacted in 1955, and has been amended numerous times in
subsequent years (1963, 1965, 1967, 1970, 1977, and 1990). The CAA establishes the federal air
quality standards, the NAAQS, and specifies future dates for achieving compliance. The CAA also
mandates that states submit and implement SIPs for local areas not meeting these standards. These
plans must include pollution control measures that demonstrate how the standards will be met.
The 1990 amendments to the CAA that identify specific emission reduction goals for areas not
meeting the NAAQS require a demonstration of reasonable further progress toward attainment and
incorporate additional sanctions for failure to attain or to meet interim milestones. The sections of
the CAA most directly applicable to the development of the project site include Title I (Non-
Attainment Provisions) and Title II (Mobile Source Provisions). Title I provisions were established
with the goal of attaining the NAAQS for the following criteria pollutants: O3, NO2, SO2, PM10, CO,
PM2.5, and lead. The NAAQS were amended in July 1997 to include an additional standard for O3 and
to adopt a NAAQS for PM2.5.
Mobile source emissions are regulated in accordance with Title II provisions. These provisions
require the use of cleaner burning gasoline and other cleaner burning fuels such as methanol and
natural gas. Automobile manufacturers are also required to reduce tailpipe emissions of
hydrocarbons and NOX. NOX is a collective term that includes all forms of nitrogen oxides (NO, NO2,
NO3), which are emitted as byproducts of the combustion process.
State Regulations
California Air Resources Board (ARB)
The ARB, which became part of the California Environmental Protection Agency in 1991, is
responsible for ensuring implementation of the California Clean Air Act (CAA) (Assembly Bill [AB]
2595), responding to the federal CAA, and for regulating emissions from consumer products and
motor vehicles. The California CAA mandates achievement of the maximum degree of emissions
reductions possible from vehicular and other mobile sources in order to attain the state ambient air
quality standards by the earliest practical date. The ARB established the California Ambient Air
Quality Standards (CAAQS) for all pollutants for which the federal government has NAAQS and, in
addition, established standards for sulfates, visibility, hydrogen sulfide, and vinyl chloride. However,
at this time, hydrogen sulfide and vinyl chloride are not measured at any monitoring stations in the
SoCAB because they are not considered to be a regional air quality problem. Generally, the CAAQS
are more stringent than the NAAQS. Table 3.3-3 provides listing of the federal and state ambient air
quality standards, relevant effects, properties, and sources of the pollutants. Several pollutants
listed in Table 3.3-3 are not addressed in this analysis. Analysis of lead is not included in this report
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because the project is not anticipated to emit lead. Visibility-reducing particles are not explicitly
addressed in this analysis because particulate matter is addressed. The project is not expected to
generate or be exposed to vinyl chloride because project uses do not use the chemical processes
that create this pollutant, and there are no such uses in the project vicinity. The project is not
expected to cause exposure to hydrogen sulfide because it would not generate hydrogen sulfide in
any substantial quantity.
The ARB has adopted a number of regulatory programs aimed at specifically reducing toxics air
contaminant emissions. These programs include the following.
Diesel Risk Reduction Plan
In September 2000, the ARB adopted the Diesel Risk Reduction Plan (Diesel RRP or Plan), which
recommends many control measures to reduce the risks associated with DPM and achieve a goal of
75 percent PM reduction by 2010 and 85 percent by 2020 (ARB 2000). The Plan involves the
implementation of:
• New regulatory standards for on-road, off-road, and stationary diesel-fueled engines and
vehicles
• New retrofit requirements for existing on-road, off-road, and stationary diesel-fueled engines
and vehicles were determined to be technically feasible and cost-effective; and
• New Phase 2 diesel fuel regulations to reduce the sulfur content levels of diesel fuel to no
more than 15 ppm to provide the quality of diesel fuel needed by the advanced diesel PM
emission controls
The Plan set into motion a series of emission reduction regulations and control measures as
discussed below.
Emission Reduction Funding
Carl Moyer Memorial Air Quality Standards Attainment Program. Since 1998, the Carl Moyer
Memorial Air Quality Standards Attainment Program (Carl Moyer Program) has provided funding to
encourage the voluntary purchase of cleaner engines, equipment, and emission reduction
technologies. The Carl Moyer Program plays a complementary role to California’s regulatory
program by funding emission reductions that are surplus, i.e., early and/or in excess of what is
required by regulation. The Carl Moyer Program accelerates the turnover of old highly polluting
engines, speeds the commercialization of advanced emission controls, and reduces air pollution
impacts on environmental justice communities. Emission reductions achieved through the Carl
Moyer Program are an important component of the California SIP.
Regulation for Construction-Related Equipment
Airborne Toxic Control Measure for DPM from Portable Engines Rated at 50 horsepower and
Greater. The purpose of this measure is to reduce DPM emissions from portable diesel-fueled
engines with a horsepower of 50 or greater. Each fleet is required to comply with weighted reduced
particulate matter emission fleet averages by compliance dates listed in 17 California Code of
Regulations Section 93116. Portable equipment includes but is not limited to, air compressors,
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generators, concrete pumps, tub grinders, wood chippers, water pumps, drill rigs, pile drivers, rock
drills, abrasive blasters, aggregate screening and crushing plants, concrete batch plants, and welders.
ARB Regulation for In-Use Off-Road Diesel Vehicles (Off-Road Regulation), Title 13, Article 4.8,
Chapter 9, Section 2449 in the California Code of Regulations. On July 26, 2007, the ARB adopted a
regulation to reduce particulate matter and NOX emissions from in-use (existing) off-road heavy-duty
diesel vehicles in California. All self-propelled off-road diesel vehicles over 25 horsepower (hp) used
in California and most two-engine vehicles (except on-road two-engine sweepers) are subject to this
regulation. This includes vehicles that are rented or leased (rental or leased fleets). Such vehicles
are used in construction, mining, and industrial operations. The Off-Road regulation:
• Imposes limits on idling (no more than five consecutive minutes) and requires a written idling
policy;
• Requires a disclosure when selling vehicles;
• Requires all vehicles to be reported to ARB (using the Diesel Off-Road Online Reporting
System, DOORS) and labeled;
• Restricts adding older equipment into fleets; and
• Requires fleets to reduce their emissions by retiring, replacing, or repowering older engines,
or installing Verified Diesel Emission Control Strategies (i.e., exhaust retrofits).
Regulations for Heavy-Duty Vehicles/Trucks
ARB Airborne Toxic Control Measure to Limit Diesel-Fueled Commercial Motor Vehicle Idling
adopts new section 2485 within Chapter 10, Article 1, Division 3, title 13 in the California Code of
Regulations. The measure limits the idling of diesel vehicles (i.e., commercial trucks over 10,000
pounds) to reduce emissions of toxics and criteria pollutants. The driver of any vehicle subject to
this section: (1) shall not idle the vehicle’s primary diesel engine for greater than five minutes at any
location; and (2) shall not idle a diesel-fueled auxiliary power system for more than five minutes to
power a heater, air conditioner, or any ancillary equipment on the vehicle if it has a sleeper berth
and the truck is located within 100 feet of a restricted area (homes and schools).
ARB Requirements to Reduce Idling Emissions from New and In-Use Trucks. Amendments were
made to Title 13 in California Code of Regulations in Sections 1956.8, 2404, 2424, 2425, and 2485.
The amendment states: “all new 2008 and subsequent model-year heavy-duty diesel engines shall
be equipped with an engine shutdown system that automatically shuts down the engine after 300
seconds of continuous idling operation once the vehicle is stopped, the transmission is set to
‘neutral’ or ‘park,’ and the parking brake is engaged. If the parking brake is not engaged, then the
engine shutdown system shall shut down the engine after 900 seconds of continuous idling
operation once the vehicle is stopped and the transmission is set to ‘neutral’ or ‘park.’” There are a
few conditions where the engine shutdown system can be overridden to prevent engine damage.
Any project trucks manufactured after 2008 would be consistent with this rule, which would
ultimately reduce air emissions.
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Statewide Truck and Bus Regulation (Regulation to Reduce Emissions of DPM, Oxides of Nitrogen
and Other Criteria Pollutants, from In-Use Heavy-Duty Diesel-Fueled Vehicles, Title 13, California
Code of Regulations, Section 2025). On December 12, 2008, the ARB approved this regulation to
reduce emissions from existing on-road diesel trucks and buses operating in California. This
regulation applies to all on-road heavy-duty diesel-fueled vehicles with a gross vehicle weight rating
greater than 14,000 pounds, agricultural yard trucks with off-road certified engines, and certain
diesel fueled shuttle vehicles of any gross vehicle weight rating. Out-of-state trucks and buses that
operate in California are also subject. Under the regulation, older, heavier trucks (i.e. those with pre-
2000 year engines and a gross vehicle weight rating greater than 26,000 pounds), are required to
have installed a particulate matter filter and must be replaced with a 2010 engine between 2015 and
2020, depending on the model year. By 2015, all heavier pre-1994 trucks must be upgraded to 2010
engines and newer trucks are thereafter required to be replaced over the next eight years. Older,
more polluting trucks are required to be replaced first, while trucks that already have relatively clean
2007-2009 engines are not required to be replaced until 2023. Lighter trucks (14,001-26,000
pounds) must adhere to a similar schedule. Furthermore, nearly all trucks that are not required
under the Truck and Bus Regulation to be replaced by 2015 are required to be upgraded with a
particulate matter filter by that date.
California Health and Safety Code Section 42301.6 to 42301.9
This state code section addresses sources of hazardous air pollutants near schools. It requires new
or modified sources of hazardous air emissions located within 1,000 feet from the outer boundary of
a school to give public notice to the parents or guardians of children enrolled in any school located
within one-quarter mile of the source and to each address within a 1,000-foot radius.
Regional Regulations
South Coast Air Quality Management District
Local air quality management districts such as the SCAQMD regulate air emissions from stationary
and area-wide sources of emissions and to limited extent from mobile sources. All air pollution
control districts have been formally designated attainment or non-attainment for each CAAQS. The
project is located within the SCAQMD and, therefore, is subject to its rules and regulations.
Serious non-attainment areas are required to prepare air quality management plans that include
specified emission reduction strategies in an effort to meet clean air goals. These plans are required to
include:
• Application of Best Available Retrofit Control Technology to existing sources.
• Developing control programs for area sources (e.g., architectural coatings and solvents) and
indirect sources (e.g. motor vehicle use generated by residential and commercial development).
• An air district permitting system designed to allow no net increase in emissions from any new
or modified permitted sources of emissions.
• Implementing reasonably available transportation control measures and assuring a substantial
reduction in growth rate of vehicle trips and miles traveled.
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• Significant use of low emissions vehicles by fleet operators.
• Sufficient control strategies to achieve a five percent or more annual reduction in emissions or
15 percent or more in a period of three years for ROGs, NOX, CO and PM10. However, air
basins may use alternative emission reduction strategy that achieves a reduction of less than
five percent per year under certain circumstances.
2016 AQMP
On March 3, 2017, the SCAQMD adopted the 2016 AQMP. The 2016 AQMP address strategies and
measures to attain the 2008 federal 8-hour ozone standard by 2032, the 2012 federal annual PM2.5
standard by 2021 to 2025, and the 2006 federal 24-hour PM2.5 standard by 2019. The 2016 AQMP
also examined the regulatory requirements for attaining the 2015 federal 8-hour ozone standard.
The 2016 AQMP also updates previous attainment plans for ozone and PM2.5 that have not yet been
met (SCAQMD 2016). In general, the AQMP is updated every 3 to 4 years. However, the air quality
planning process for the AQMP is continuous and each iteration is an update of the previous plan.
To ensure air quality goals will be met while minimizing impacts to the regional economy, the
following policy objectives guided the development of the plan:
• Eliminate reliance on “black box” (future technologies) to the maximum extent possible by
providing specific pathways to attainment with specific control measures.
• Calculate and take credit for co-benefits from other planning efforts (e.g., Greenhouse Gas
(GHG) reduction targets, energy efficiency, transportation).
• Develop a strategy with fair-share emission reductions at the federal, state, & local levels such
as a new federal engine emission standards and/or additional authority provided to the state
or SCAQMD for mobile sources.
• Seek significant funding for incentives to implement early deployment and commercialization
of known zero and near-zero technologies.
• Invest in strategies and technologies meeting multiple objectives regarding air quality, climate
change, air toxic exposure, energy, and transportation.
• Enhance the socioeconomic analysis and select the most efficient and cost-effective path to
achieve multi-pollutant and multi-deadline targets.
• Prioritize non-regulatory, innovative and “win-win” approaches for emission reductions.
The 2016 AQMP also demonstrates attainment of the 2008 Ozone Standard in Coachella Valley by
2026. The Plan also demonstrates compliance with all applicable Federal Clean Air Act requirements
pertaining to nonattainment areas pursuant to the EPA approved Implementation Rules, such as the
annual average and summer planning emission inventory for criteria and precursor pollutants,
attainment demonstrations, reasonably available control measure and reasonably available control
technology analyses, reasonable further progress, particulate matter precursor requirements,
vehicle miles traveled (VMT) demonstrations, and transportation conformity budgets for SoCAB and
Coachella Valley.
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The control measures in the 2016 AQMP are based on implementing all feasible control measures
through the accelerated deployment of available cleaner technologies, best management practices,
co-benefits from existing programs, and incentive measures. The 2016 AQMP control measures
consist of three main components: (1) the SCAQMD’s Stationary and Mobile Source Control
Measures; (2) suggested state and federal Source Control Measures; and (3) Regional Transportation
Plan Transportation Control Measures provided by Southern California Association of Governments.
These measures rely on not only the traditional command-and-control approach, but also public
incentive programs, as well as advanced technologies expected to be developed and deployed in the
next several years
Air Quality Management Plans
An Air Quality Management Plan (AQMP) is a plan prepared and implemented by an air pollution
district for a county or region designated nonattainment for the federal and/or California ambient air
quality standards. The term nonattainment area is used to refer to an area where one or more
ambient air quality standards are exceeded. The AQMPs prepared by the various air districts within
the State are then assembled to form the SIP.
South Coast Air Quality Management District Rules
The AQMP for the air basin establishes a program of rules and regulations administered by SCAQMD
necessary to attain the state and national air quality standards. The rules and regulations that apply
to this project include, but are not limited to, the following:
SCAQMD Rule 402
Prohibits a person from discharging from any source whatsoever such quantities of air contaminants
or other material which cause injury, detriment, nuisance, or annoyance to any considerable number
of persons or to the public, or which endanger the comfort, repose, health or safety of any such
persons or the public, or which cause, or have a natural tendency to cause, injury or damage to
business or property.
SCAQMD Rule 403
Governs emissions of fugitive dust during construction and operation activities. Compliance with
this rule is achieved through application of standard Best Management Practices, such as application
of water or chemical stabilizers to disturbed soils, covering haul vehicles, restricting vehicle speeds
on unpaved roads to 15 miles per hour, sweeping loose dirt from paved site access roadways,
cessation of construction activity when winds exceed 25 miles per hour (mph), and establishing a
permanent ground cover on finished sites.
SCAQMD Rule 481
Applies to all spray painting and spray coating operations and equipment. This rule would apply to
the application of architectural coatings to the exterior and interior of the building walls. The rule
states that a person shall not use or operate any spray painting or spray coating equipment unless
one of the following conditions is met:
(1) The spray coating equipment is operated inside a control enclosure, which is approved by
the Executive Officer. Any control enclosure for which an application for permit for new
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construction, alteration, or change of ownership or location is submitted after the date of
adoption of this rule shall be exhausted only through filters at a design face velocity not less
than 100 feet per minute nor greater than 300 feet per minute, or through a water wash
system designed to be equally effective for the purpose of air pollution control.
(2) Coatings are applied with high-volume low-pressure, electrostatic and/or airless spray
equipment.
(3) An alternative method of coating application or control is used which has effectiveness
equal to or greater than the equipment specified in the rule.
SCAQMD Rule 1108
Governs the sale, use, and manufacturing of asphalt and limits the VOC content in asphalt used in
the SoCAB. This rule would regulate the VOC content of asphalt used during construction.
Therefore, all asphalt used during construction of the project must comply with SCAQMD Rule 1108.
SCAQMD Rule 1113
Governs the sale, use, and manufacturing of architectural coating and limits the VOC content in
paints and paint solvents. This rule regulates the VOC content of paints available during
construction. Therefore, all paints and solvents used during construction and operation of the
project must comply with SCAQMD Rule 1113.
SCAQMD Rule 1143
Governs the manufacture, sale, and use of paint thinners and solvents used in thinning of coating
materials, cleaning of coating application equipment, and other solvent cleaning operations by
limiting their VOC content. This rule regulates the VOC content of solvents used during construction.
Solvents used during the construction phase must comply with this rule.
SCAQMD Rule 1186
Limits the presence of fugitive dust on paved and unpaved roads and sets certification protocols and
requirements for street sweepers that are under contract to provide sweeping services to any federal,
state, county, agency or special district such as water, air, sanitation, transit, or school district.
SCAQMD Rule 1303
Governs the permitting of re-located or new major emission sources, requiring Best Available
Control Measures and setting significance limits for PM10 among other pollutants.
SCAQMD Rule 220
Sets forth “On-Road Motor Vehicle Mitigation Options” provides employers with a menu of options
to reduce mobile source emissions generated from employee commutes, to comply with federal and
state Clean Air Act requirements, Health & Safety Code Section 40458, and Section 182(d)(1)(B) of
the federal Clean Air Act. It applies to any employer who employs 250 or more employees on a full
or part-time basis at a worksite for a consecutive six-month period, calculated as a monthly average.
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Local
City of Orange
General Plan
The City of Orange General Plan contains the following goals and policies that address air quality and
are applicable to the proposed project:
Natural Resources Element
• Goal 2.0: Protect air, water and energy resources from pollution and overuse.
• Policy 2.1: Cooperate with the SCAQMD and other regional agencies to implement and
enforce regional air quality management plans.
• Policy 2.2: Support alternative transportation modes, alternative technologies and bicycle-
and pedestrian-friendly neighborhoods to reduce emissions related to vehicular travel.
• Policy 2.6: Encourage sustainable building and site designs for new construction and
renovation projects.
3.3.3 - Thresholds of Significance
According to the California Environmental Quality Act (CEQA) Guidelines’ Appendix G Environmental
Checklist, the following questions are analyzed and evaluated to determine whether impacts to air
quality are significant environmental effects:
Where available, the significance criteria established by the applicable air quality management
or air pollution control district may be relied upon to make the following determinations.
Would the project:
a) Conflict with or obstruct implementation of the applicable air quality plan?
b) Violate any air quality standard or contribute substantially to an existing or projected air
quality violation?
c) Result in a cumulatively considerable net increase of any criteria pollutant for which the project
region is non-attainment under an applicable federal or state ambient air quality standard
(including releasing emissions, which exceed quantitative thresholds for ozone precursors)?
d) Expose sensitive receptors to substantial pollutant concentrations?
e) Create objectionable odors affecting a substantial number of people?
This analysis will follow the guidance in the CEQA Guideline Amendments.
To assist in the establishment of a quantitative determination of what is considered “significant,” the
SCAQMD has published a number of significance thresholds that apply to new projects constructed
or operated within the SCAQMD. The SCAQMD recommends that lead agencies apply these
thresholds in determining whether a proposed project would result in a significant air quality impact.
If the lead agency finds that a proposed project has the potential to exceed these air pollution
thresholds, the project would be considered significant. These thresholds have been defined by
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SCAQMD for the SoCAB, based on scientific data the SCAQMD has obtained and factual data within
the federal and state Clean Air Acts. Since the project is located within the SoCAB, these thresholds
are applicable to this project. The SCAQMD has defined thresholds for oxides of nitrogen (NOX),
volatile organic carbon (VOC), oxides of sulfur (SOX), CO, PM10, and PM2.5, hereinafter referred to as
“criteria” pollutants, and for health risk in terms of cancer and non-cancer risk.
From the perspective of this analysis, four types of significance thresholds were evaluated in terms
of impacts on air quality from the construction and operation of the project. These thresholds are
the Regional Significance Thresholds, Local Significance Thresholds (LSTs), Health Risk Significance
Thresholds, and CO “Hot Spot” Thresholds, which are discussed below.
Regional Air Quality Significance Thresholds
The regional thresholds apply to all aspects of the project including construction and operations.
The mass emission-based regional thresholds were established because a project’s emissions could
potentially contribute to the basin’s regional emission burden and affect air quality many miles away
from a project location. The SCAQMD recommends regional significance thresholds for VOC, NOX,
SOX, CO, and particulate matter (PM10, and PM2.5). Any construction or operational-related
emissions from the project in excess of any of the thresholds presented in Table 3.3-4 would be
considered to result in a significant impact.
Table 3.3-4: SCAQMD Regional Significance Thresholds
Pollutant
Mass Daily Thresholds (lbs/day)
Construction Operation
NOX 100 55
VOC 75 55
PM10 150 150
PM2.5 55 55
SOX 150 150
CO 550 550
Notes:
From SCAQMD CEQA Handbook (SCAQMD, 1993)
NOX = nitrogen oxides
VOC = Volatile Organic Compounds
CO = carbon monoxide
PM10 = particulate matter with an aerodynamic resistance diameter of 10 micrometers or less;
PM2.5 = particulate matter with an aerodynamic resistance diameter of 2.5 micrometers
Local Air Quality Significance Thresholds (LSTs)
LSTs were developed in response to the SCAQMD Governing Board’s environmental justice (EJ)
initiatives (EJ initiative 1–4) in recognition of the fact that criteria pollutants such as CO, NOX, and
PM10 and PM2.5 in particular, can have local impacts as well as regional impacts. The goal of
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significance thresholds is to ensure that no source creates, or receptor endures, a significant adverse
impact from any project. The evaluation of localized air quality impacts determines the potential to
cause or contribute to an existing or new air quality violation, or expose sensitive receptors to
substantial pollutant concentrations. LSTs represent the maximum emissions or air concentrations
from a project that will not cause or contribute to an exceedance of the most stringent applicable
federal or State ambient air quality standard, at any nearby sensitive or worker receptor. LSTs are
defined separately for construction and operational activities and are dependent upon location,
project size, and distance to the sensitive receptor.
The SCAQMD created a series of lookup tables that present the maximum emission (e.g., the localized
significance thresholds) that a project can emit without contributing to an existing or new air quality
standard exceedance. The value of the LST depends on the project location, size of the project area,
and distance to the nearest sensitive receptor. The project is located within SRA 17 (Central Orange
County). Therefore, the LSTs for this SRA location were selected for the LST assessment.
In addition to the dependence on geographic location within the SCAQMD (e.g., the SRA), the
localized thresholds also depend on the distance to the impacted receptor from the source of
emissions. The distance to the nearest sensitive receptor is within 25 meters from the boundary of
the project. Specifically, the closest sensitive receptor is located at 25 meters (82 feet) to the east of
the project, at the corner along River Birch Circle.
Construction
During construction, the project size is generally represented as the maximum area disturbed during
a day from which emissions are calculated. Based on the level of various activities during
construction, the largest amount of area to be disturbed is expected to occur during grading of the
project site. The emission lookup tables are used to identify the relevant construction LSTs.
Operations
During operational-activities, the project would generate on-site emissions including area sources
and energy sources. Area sources would include activities such as landscape maintenance and
occasional architectural coatings. Energy sources would include electricity and natural gas
combustion for space and water heating. The emission lookup tables are used to identify the
relevant operation LSTs. Because a majority of the project’s mobile-source emissions would occur
on the local and regional roadway network away from the project, only the on-site area-, energy-,
and mobile-source emissions were included in this analysis. A trip length of 0.5 mile was used in the
modeling input assumptions to account for on-site emissions from mobile sources.
A significant impact would occur if a project’s construction or operational-related impacts exceed
any of the LSTs.
Health Risk Significance Thresholds
In addition to the LSTs established above for criteria pollutants, the SCAQMD has also defined health
risk significance thresholds. These thresholds are represented as a cancer risk to the public and a
non-cancer hazard from exposures to TACs. Cancer risk represents the probability (in terms of risk
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per million individuals) that an individual would contract cancer resulting from exposure to TACs
continuously over a lifetime period of several years. The principal TAC emission analyzed in this
assessment was the emission of DPM from the operation of off-road equipment and diesel-powered
delivery and worker vehicles during construction. The derivation of the emissions from these
sources and the assumptions used to estimate cancer risks are provided in Appendix F in this EIR.
As a point of reference, an individual located in an area with a cancer risk of 10 in one million would
experience ten chances out of a population of one million of contracting cancer over lifetime period,
assuming that individual lives in that area continuously for the entire time period. The SCAQMD
recommends assessing cancer risks over a lifetime of 30 years. For purposes of this health risk
assessment (HRA), the potential health risks resulting from project construction emissions were
estimated over the 4.5 years of construction.
TACs can also cause chronic (long-term) and acute (short-term) related non-cancer illnesses such as
reproductive effects, respiratory effects, eye sensitivity, immune effects, kidney effects, blood
effects, central nervous system effects, birth defects, or other adverse environmental effects. Risk
characterization for non-cancer health hazards from TACs is expressed as a hazard index (HI). The HI
is a ratio of the predicted concentration of the project’s emissions to a concentration considered
acceptable to public health professionals, termed the Reference Exposure Level (REL).
The SCAQMD has established the following health risks thresholds:
Project-Specific Health Risk Significance Thresholds
The SCAQMD has established the following project-specific health risk significance thresholds:
• Maximum Incremental Cancer Risk > = 10 in 1 million
• Hazard Index (project increment) > = 1.0
A significant impact would occur if a project’s impacts exceeded any of these thresholds.
Estimation of Cancer Risks
As discussed in Section 3.3.1—Environmental Setting, OEHHA has developed Risk Assessment
Guidelines for estimating cancer risks that provide adjustment factors that emphasize the increased
sensitivities and susceptibility of human to exposures to TACs.1 The recommend method for the
estimation of cancer risk is shown in the equations below for the duration of the construction time
period (4.5 years),
Cancer Risk = CDPM x Inhalation Exposure Factor (EQ-1)
Where:
Cancer Risk = Total individual excess cancer risk defined as the cancer risk a hypothetical
individual faces if exposed to carcinogenic emissions from a particular source for specified
exposure durations; this risk is defined as an excess risk because it is above and beyond the
1 Office of Environmental Health Hazard Assessment. Air Toxics Hot Spots Program—Risk Assessment Guidelines. Guidance Manual
for Preparation of Health Risk Assessments. February 2015.
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background cancer risk to the population; cancer risk is expressed in terms of risk per million
exposed individuals.
CDPM = Period average DPM air concentration calculated from the air dispersion model in
µg/m3
Inhalation is the most important exposure pathway to impact human health from DPM and the
inhalation exposure factor is defined as follows:
Inhalation Exposure Factor = CPF x EF x ED x DBR x AAF/AT (EQ-2)
Where:
CPF = Inhalation cancer potency factor for the TAC: 1.1 (mg/kg-day)-1 for DPM
EF = Exposure frequency: 350 (days/year)
ED = Exposure duration (4.5 years of construction)
AT = Averaging time period over which exposure is averaged (days)
AAF = set of age-specific adjustment factors that include age sensitivity factors (ASF), daily
breathing rates (DBR), and time at home factors (TAH)
The OEHHA recommended values for the various cancer risk parameters shown in the Equation 2 are
shown in Table 3.3-5. Note, however, the SCAQMD has not officially adopted the updated OEHHA
guidance for CEQA evaluations. However, the SCAQMD provides recommended values for the
various cancer risk parameters as part of its procedures for demonstrating compliance with SCAQMD
Rules 1401 and 212 that are also shown in Table 3.3-5.
Table 3.3-5: Exposure Assumptions for Cancer Risk—Updated OEHHA Guidance
Receptor Type
Exposure Frequency Construction
Exposure
Duration
(years)
Age Sensitivity
Factors
(ASF)
Time at Home
Factor
(TAH)(1)
(%)
Daily Breathing
Rate(2)
(DBR)
(L/kg-day) Hours/day Days/year
Sensitive/Residential
3rd Trimester 24 350 0.25 10 100 361
0–2 years 24 350 2 10 100 1,090
3–16 years 24 350 4.5 3 72 572
>16–30 years 24 350 4.5 1 73 261
Notes:
(1) Time at Home (TAH) factors recommended by the SCAQMD
(2) The daily breathing rates recommended by the SCAQMD are the 95th percentile rate for sensitive/residential
receptors 0 to 2 years
(L/kg-day) = liters per kilogram body weight per day
Source of Current OEHHA Guidance: OEHHA 2015 and SCAQMD 2015b
Source: Appendix F
The project site is surrounded by residences, and the closest sensitive receptor is located at 25
meters (82 feet) to the east of the project, at the corner along River Birch Circle. The Salem Lutheran
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School is located approximately 600 feet to the south of the project across the East Santiago Canyon
Road. The exposure frequency of the school students is 180 days, the age sensitive factor is 3, and
the daily breathing rate is 520 liters/kg-day. All these parameters are lower than the parameters
listed in Table 3.3-5. The inhalation exposure factor for students is lower than the factors for
children at year 1-2. Therefore, the cancer risk assumptions shown in Table 3.3-5 are the most
conservative assumptions. If the cancer risks are estimated based on the assumptions presented
above and do not exceed the SCAQMD’s maximum incremental cancer risk, the project would not
result in significant impact on human health cancer risks.
Estimation of Non-Cancer Hazards
An evaluation of the potential non-cancer effects of chronic chemical exposures was also conducted.
Adverse health effects are evaluated by comparing the annual receptor concentration of each
chemical compound with the appropriate REL. To calculate the HI, each chemical concentration or
dose is divided by the appropriate toxicity reference exposure level. For compounds affecting the
same toxicological endpoint, this ratio is summed. Where the total equals or exceeds 1, a health
hazard is presumed to exist.
To quantify non-carcinogenic impacts, the HI approach was used.
HI = Cann/REL (EQ-3)
Where:
HI = chronic hazard index
Cann = annual average concentration of TAC as derived from the air dispersion model (μg/m3)
REL = reference exposure level above which a significant impact is assumed to occur (μg/m3)
For purposes of this assessment, the TAC of concern is DPM for which the OEHHA has defined a
chronic non-cancer REL for DPM of 5 μg/m3. The principal toxicological endpoint assumed in this
assessment was through inhalation.
Cumulative Health Risk Significance Thresholds
The AQMD has published a report on how to address cumulative impacts from air pollution: White
Paper on Potential Control Strategies to Address Cumulative Impacts from Air Pollution.2 In this
report, the AQMD clearly states (page D-3):
The AQMD uses the same significance thresholds for project specific and cumulative
impacts for all environmental topics analyzed in an Environmental Assessment or
EIR. The only case where the significance thresholds for project specific and
cumulative impacts differ is the Hazard Index (HI) significance threshold for toxic air
contaminant (TAC) emissions. The project specific (project increment) significance
threshold is HI > 1.0 while the cumulative (facility-wide) is HI > 3.0. It should be
2 South Coast Air Quality Management District (SCAQMD). 2003. White Paper on Potential Control Strategies to Address Cumulative
Impacts from Air Pollution. Website: http://www.aqmd.gov/docs/default-source/Agendas/Environmental-Justice/cumulative-
impacts-working-group/cumulative-impacts-white-paper.pdf?sfvrsn=2.
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noted that the HI is only one of three TAC emission significance thresholds
considered (when applicable) in a CEQA analysis. The other two are the maximum
individual cancer risk (MICR) and the cancer burden, both of which use the same
significance thresholds (MICR of 10 in 1 million and cancer burden of 0.5) for project
specific and cumulative impacts.
Projects that exceed the project-specific significance thresholds are considered by
the SCAQMD to be cumulatively considerable. This is the reason project-specific and
cumulative significance thresholds are the same. Conversely, projects that do not
exceed the project-specific thresholds are generally not considered to be
cumulatively significant.
Air Dispersion Modeling
An air dispersion model is a mathematical formulation used to estimate the air quality impacts at
specific locations (receptors) surrounding a source of emissions given the rate of emissions and
prevailing meteorological conditions. The air dispersion model applied in this assessment was the
EPA AERMOD (Version 9.6.1) air dispersion model that is approved by the SCAQMD for preparing air
dispersion assessments. Specifically, the AERMOD model was used to estimate levels of air
emissions at sensitive receptor locations from the project’s construction PM10 exhaust emissions.
The use of the AERMOD model provides a refined methodology for estimating construction impacts
by utilizing long-term measured, representative meteorological data for the project site,
construction area, and a representative construction schedule.
Three emission sources were used to represent the project’s DPM construction emissions. One
source represented the generation of on-site construction DPM emissions (as PM10 exhaust) from
the off-road construction equipment, while the other two sources were used to represent the
project’s off-site construction DPM emissions generated by construction vehicles. The emissions
from the on-site source were represented in the AERMOD model as an area source, while the
emissions from the two off-site sources were represented in the AERMOD as line volume sources.
Construction vehicles were assumed to travel to the project site along East Santiago Canyon Rd to
the east toward CA State Route 241 (50 percent), and the other 50 percent vehicles travel along East
Santiago Canyon Rd to the west. The percentage of trips in each direction was estimated based on
traffic impact analysis for operational vehicle trip distribution. Construction was assumed to take
place on an 8-hour-per-day/5-day-per-week basis between the years 2020 and 2024.
Receptor locations within the AERMOD model were placed at locations of existing residences
surrounding the project. The air dispersion model assessment used meteorological data from the
SCAQMD John Wayne International Airport monitoring station for the years 2012–2016. All the
receptors were placed within the breathing zone at zero meters above ground level.3
Carbon Monoxide “Hot Spot” Thresholds
The largest contributor of CO emissions during project operations is typically from motor vehicles. A
CO hotspot represents a condition wherein high concentrations of CO may be produced by motor
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vehicles accessing a congested traffic intersection under heavy traffic volume conditions. The CO
hotspot thresholds are represented by the most restricted state or federal CO ambient air quality
standards:
• 1-hour CO standard: 20 ppm (state), 35 ppm (federal); and
• 8-hour CO standard: 9 ppm (state/federal).
If the CO contributed by the project in combination with CO produced by non-project traffic exceeds
the above standards, then the project would have a significant impact.
3.3.4 - Project Impacts and Mitigation Measures
This section discusses potential impacts associated with the development of the proposed project
and provides mitigation measures where appropriate.
Consistency with Air Quality Management Plan
Impact AIR-1: The project may conflict with or obstruct implementation of the applicable air
quality plan.
Impact Analysis
To evaluate whether or not a project conflicts with, or obstructs the implementation of the applicable
air quality plan (2017 AQMP for the SoCAB), the SCAQMD CEQA Air Quality Handbook states that there
are two key indicators. These indicators are identified and discussed below.
1. Indicator: Whether the project will not result in an increase in the frequency or severity of
existing air quality violations or cause or contribute to new violations, or delay timely
attainment of air quality standards or the interim emission reductions specified in the AQMP.
2. Indicator: According to Chapter 12 of the SCAQMD CEQA Air Quality Handbook, the purpose
of the General Plan consistency findings is to determine whether a project is inconsistent
with the growth assumptions incorporated into the air quality plan, and thus, whether it
would interfere with the region’s ability to comply with federal and California air quality
standards.
Considering the recommended criteria in the CEQA Handbook, this analysis uses the following
criteria to address this potential impact:
• Criterion 1: Project’s contribution to air quality violations (SCAQMD’s first indicator);
• Criterion 2: Assumptions in AQMP (SCAQMP’s second indicator); and
• Criterion 3: Compliance with applicable emission control measures in the AQMPs.
Criterion 1: Project’s Construction to Air Quality Violations
According to the SCAQMD, the project is consistent with the AQMP if the project would not result in
an increase in the frequency or severity of existing air quality violations or cause or contribute to
new violations, or delay timely attainment of air quality standards or the interim emission reductions
specified in the AQMP.
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As discussed in Impact AIR-2, construction-related activities would result in emissions of NOX that
exceed SCAQMD’s significance thresholds on a daily basis prior to the application of mitigation. The
operation of the project as discussed in Impact AIR-2 would not exceed the SCAQMD’s operational
significance thresholds. Therefore, the project would result in a potentially significant impact during
construction under Criteria 1.
Criterion 2: Assumptions in AQMP
According to Chapter 12 of the SCAQMD CEQA Air Quality Handbook, the purpose of the General
Plan consistency finding is to determine whether a project is inconsistent with the growth
assumptions incorporated into the air quality plan and thus, whether it would interfere with the
region’s ability to comply with federal and California air quality standards.
The City of Orange designates the project site “Low Density Residential,” “Resource Area” and “Open
Space.” The City of Orange Zoning Ordinance zones the project site “S-G (Sand and Gravel
Extraction)” and “R-1-8 (Single-Family Residential 8,000 square-feet).”
The proposed project involves the development of up to 128 dwelling units on approximately 40.7
acres within the area designated “Resource Area” and the preservation of the remaining 68.5 acres
(which overlap with the “Resource Area” and “Low Density Residential” designations) as open space
and recreation uses. Accordingly, the applicant is proposing to change the “Resource Area”
designation to a combination of “Low Density Residential,” and “Open Space,” and the “Low Density
Residential” designation to “Open Space.”
The development of the Air Quality Management Plan (AQMP) is based in part on the land use
general plan determinations of the various cities and counties that constitute the SoCAB. A project
that is consistent with the general plan is considered to be accounted for in the AQMP. Since the
proposed project entitlements would include a General Plan Amendment that would amend both
the East Orange General Plan and Orange Park Acres Plan to incorporate the Trails at Santiago Creek
Specific Plan, the proposed project would not be consistent with the growth assumptions within the
current AQMP. The project would be potentially significant under Criteria 2.
Criterion 3: Control Measures
The proposed project would comply with all applicable rules and regulations of the AQMP. Because
of the nature of the proposed project, which includes earthmoving activity, SCAQMD Rule 403
applies. Rule 403 governs emissions of fugitive dust during construction and operation activities.
The rule requires that fugitive dust be controlled with best available control measures so that the
presence of such dust does not remain visible in the atmosphere beyond the property line of the
emission source. In addition, SCAQMD Rule 403 requires implementation of dust suppression
techniques to prevent fugitive dust from creating a nuisance off-site. Compliance with this rule is
achieved through application of standard Best Management Practices (BMPs). These BMPs include
application of water or chemical stabilizers to disturbed soils; covering haul vehicles; restricting
vehicle speeds on unpaved roads to 15 miles per hour; sweeping loose dirt from paved site access
roadways; cessation of construction activity when winds exceed 25 miles per hour; and establishing
a permanent ground cover on finished sites. The project’s compliance with SCAQMD Rule 403 would
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result in consistency with the applicable AQMP control measures. As such, emissions from fugitive
dust during construction would be reduced to less than significant levels.
Therefore, the project would comply with the required control measures and therefore, the impact
would be less than significant under Criteria 3.
As discussed in Impact AIR-2, the maximum daily construction emissions after the implementation of
Mitigation Measures AIR-1a through AIR-1g would continue to exceed the SCAQMD’s regional
significance thresholds. Because no additional feasible mitigation measures are available, the
project’s regional operational emissions of NOX would continue to exceed the applicable SCAQMD
regional construction significance threshold even after implementation of all feasible mitigation.
This represents a significant and unavoidable impact.
Level of Significance Before Mitigation
Potentially significant impact.
Mitigation Measures
MM AIR-1a During construction, all equipment shall be maintained in good operating condition
so as to reduce emissions. The construction contractor shall ensure that all
construction equipment is properly serviced and maintained in accordance with the
manufacturer’s specifications. Maintenance records shall be available at the
construction site for City verification.
MM AIR-1b All paints and coatings shall meet or exceed performance standards noted in
SCAQMD Rule 1113. To ensure compliance with SCAQMD Rule 1113, the following
volatile organic compound (VOC) control measures shall be implemented during
architectural coating activities:
a) Use paints with a VOC content of no more than 50 grams per liter for both
interior and exterior coatings.
b) Keep lids closed on all paint containers when not in use to prevent VOC emissions
and excessive odors.
c) Use compliant low VOC cleaning solvents to clean paint application equipment.
d) Keep all paint and solvent laden rags in sealed containers to prevent VOC
emissions.
MM AIR-1c Prior to the issuance of grading permits for the project, the project applicant shall
include a dust control plan as part of the construction contract standard
specifications. The dust control plan shall include measures to meet the
requirements of SCAQMD Rules 402 and 403. Such basic measures may include but
are not limited to the following:
a) All haul trucks shall be covered prior to leaving the site to prevent dust from
impacting the surrounding areas.
b) Moisten soil each day prior to commencing grading to depth of soil cut.
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c) Water exposed surfaces at least three times a day under calm conditions, and as
often as needed on windy days or during very dry weather in order to maintain a
surface crust and minimize the release of visible emissions from the construction
site.
d) Treat any area that will be exposed for extended periods with a soil conditioner
to stabilize soil or temporarily plant with vegetation.
e) Use street sweepers that comply with SCAQMD Rules 1186 and 1186.1.
f) All contractors shall turn off all construction equipment and delivery vehicles when
not in use, or limit on-site idling to no more than 5 minutes in any one hour.
g) On-site electrical hook ups to a power grid shall be provided for electric
construction tools including saws, drills, and compressors, where feasible, to
reduce the need for diesel powered electric generators.
h) Traffic speeds on all unpaved roads to be reduced to 15 miles per hour or less.
i) Sweep streets at the end of the day if visible soil is carried onto adjacent public
paved roads.
MM AIR-1d Prior to and during grading activities, the project applicant shall comply with South
Coast Air Quality Management District Rule 403 as follows:
• The applicant shall submit a fully executed Large Operation Notification (Form 403
N) to the SCQAMD Executive Officer within 7 days of qualifying as a large
operation. The form shall include the name(s), address(es), and phone number(s)
of the person(s) responsible for the submittal, and a description of the
operation(s), including a map depicting the location of the site.
• Maintain daily records to document the specific dust control actions taken,
maintain such records for a period of not less than three years; and make such
records available to the Executive Officer upon request
• Install and maintain project signage with project contact signage that meets the
minimum standards of the Rule 403 Implementation Handbook, prior to initiating
any earthmoving activities
• Identify a dust control supervisor that (1) is employed by or contracted with the
property owner or developer; (2) is on the site or available on-site within 30
minutes during working hours; (3) has the authority to expeditiously employ
sufficient dust mitigation measures to ensure compliance with all Rule
requirements; (4) has completed the AQMD Fugitive Dust Control Class and has
been issued a valid Certificate of Completion for the class; and (5) will notify the
Executive Officer in writing within 30 days after the site no longer qualifies as a
large operation.
MM AIR-1e Prior to and during grading activities, the project applicant shall implement the
following dust control measures for large operations, as applicable, pursuant to
South Coast Air Quality Management District Rule 403:
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Earth Moving (except construction cutting and filling areas, and mining operations)
1a. Maintain soil moisture content at a minimum of 12 percent, as determined by
ASTM method D-2216, or other equivalent method approved by the Executive
Officer, the California Air Resources Board, and the U.S. EPA. Two soil moisture
evaluations must be conducted during the first three hours of active
operations during a calendar day, and two such evaluations each subsequent
four-hour period of active operations; or
1a-1. For any earth-moving which is more than 100 feet from all property lines,
conduct watering as necessary to prevent visible dust emissions from
exceeding 100 feet in length in any direction.
Earth Moving—Construction Fill Areas
1b. Maintain soil moisture content at a minimum of 12 percent, as determined by
ASTM method D-2216, or other equivalent method approved by the Executive
Officer, the California Air Resources Board, and the U.S. EPA. For areas which
have an optimum moisture content for compaction of less than 12 percent, as
determined by ASTM Method 1557 or other equivalent method approved by
the Executive Officer and the California Air Resources Board and the U.S. EPA,
complete the compaction process as expeditiously as possible after achieving
at least 70 percent of the optimum soil moisture content. Two soil moisture
evaluations must be conducted during the first three hours of active
operations during a calendar day, and two such evaluations during each
subsequent four-hour period of active operations.
Earth Moving—Construction Cut Areas and Mining Operations
1c. Conduct watering as necessary to prevent visible emissions from extending
more than 100 feet beyond the active cut or mining area unless the area is
inaccessible to watering vehicles due to slope conditions or other safety
factors.
Disturbed Surface Areas—Completed Grading Areas
2a/b. Apply dust suppression in sufficient quantity and frequency to maintain a
stabilized surface. Any areas which cannot be stabilized, as evidenced by wind
driven fugitive dust must have an application of water at least twice per day to
at least 80 percent of the unstabilized area.
2c. Apply chemical stabilizers within five working days of grading completion; OR
2d. Take actions (3a) or (3c) specified for inactive disturbed surface areas.
Inactive Disturbed Surface Areas
3a. Apply water to at least 80 percent of all inactive disturbed surface areas on a
daily basis when there is evidence of wind driven fugitive dust, excluding any
areas which are inaccessible to watering vehicles due to excessive slope or
other safety conditions; or
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3b. Apply dust suppressants in sufficient quantity and frequency to maintain a
stabilized surface; or
3c. Establish a vegetative ground cover within 21 days after active operations have
ceased. Ground cover must be of sufficient density to expose less than 30
percent of unstabilized ground within 90 days of planting, and at all times
thereafter; OR
3d. Utilize any combination of control actions (3a), (3b), and (3c) such that, in
total, these actions apply to all inactive disturbed surface areas.
Unpaved Roads
4a. Water all roads used for any vehicular traffic at least once per every two hours
of active operations [3 times per normal 8-hour work day]; or
4b. Water all roads used for any vehicular traffic once daily and restrict vehicle
speeds to 15 miles per hour; or
4c. Apply a chemical stabilizer to all unpaved road surfaces in sufficient quantity
and frequency to maintain a stabilized surface.
Open Storage Piles
5a. Apply chemical stabilizers; or
5b. Apply water to at least 80 percent of the surface area of all open storage piles
on a daily basis when there is evidence of wind driven fugitive dust; or
5c. Install temporary coverings; or
5d. Install a three-sided enclosure with walls with no more than 50 percent
porosity which extend, at a minimum, to the top of the pile. This option may
only be used at aggregate-related plants or at cement manufacturing facilities.
All Categories
6a. Any other control measures approved by the Executive Officer and the U.S.
EPA as equivalent to the methods specified in this mitigation measure may be
used.
MM AIR-1f Prior to and during grading activities, the project applicant shall implement the
following contingency control measures for large operations, as applicable, pursuant
to South Coast Air Quality Management District Rule 403:
Earth Moving
1A. Cease all active operations; or
2A. Apply water to soil not more than 15 minutes prior to moving such soil.
0B. On the last day of active operations prior to a weekend, holiday, or any other
period when active operations will not occur for not more than four
consecutive days: apply water with a mixture of chemical stabilizer diluted to
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not less than 1/20 of the concentration required to maintain a stabilized
surface for a period of six months; OR
1B. Apply chemical stabilizers prior to wind event; or
2B. Apply water to all unstabilized disturbed areas 3 times per day. If there is any
evidence of wind driven fugitive dust, watering frequency is increased to a
minimum of four times per day; or
3B. Establish a vegetative ground cover within 21 days after active operations have
ceased. Ground cover must be of sufficient density to expose less than 30
percent of unstabilized ground within 90 days of planting, and at all times
thereafter; or
4B. Utilize any combination of control actions (1B), (2B), and (3B) such that, in
total, these actions apply to all disturbed surface areas.
Unpaved Roads
1C. Apply chemical stabilizers prior to wind event; or
2C. Apply water twice per hour during active operation; or
3C. Stop all vehicular traffic.
Open Storage Piles
1D. Apply water twice per hour; or
2D. Install temporary coverings.
Paved Road Track Out
1E. Cover all haul vehicles; or
2E. Comply with the vehicle freeboard requirements of Section 23114 of the
California Vehicle Code for both public and private roads.
All Categories
1F. Any other control measures approved by the Executive Officer and the U.S.
EPA as equivalent to the methods specified in this mitigation measure may be
used.
MM AIR-1g During construction activities, all off-road equipment with engines greater than 50
horsepower shall meet either EPA or ARB Tier IV Final off-road emission standards.
The construction contractor shall maintain records concerning its efforts to comply
with this requirement, including equipment lists. Off-road equipment descriptions
and information may include but are not limited to equipment type, equipment
manufacturer, equipment identification number, engine model year, engine
certification (Tier rating), horsepower, and engine serial number.
If engines that comply with Tier IV Final off-road emission standards are not
commercially available, then the construction contractor shall use the next cleanest
piece of off-road equipment (e.g., Tier IV Interim) available. For purposes of this
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mitigation measure, “commercially available” shall mean the availability of Tier IV
Final engines taking into consideration factors such as (i) critical-path timing of
construction; and (ii) geographic proximity to the project site of equipment. The
contractor can maintain records for equipment that is not commercially available by
providing letters from at least two rental companies for each piece of off-road
equipment where the Tier IV Final engine is not available.
Level of Significance After Mitigation
Significant and unavoidable.
Potential for Air Quality Standard Violation
Impact AIR-2: The project may violate any air quality standard or contribute substantially to an
existing or projected air quality violation.
Impact Analysis
This section addresses regional criteria pollutant impacts. The non-attainment regional pollutants of
concern are ozone, PM10 and PM2.5. Ozone is a regional pollutant formed by a photochemical
reaction in the atmosphere and not directly emitted into the air. Ozone precursors, such as VOC and
nitrogen oxides (NOX), react in the atmosphere in the presence of sunlight to form ozone. Therefore,
the SCAQMD ozone threshold is based on the emissions of the ozone precursors VOC and NOX. This
impact section includes analysis of, and significance determinations for, those pollutants. The
concentration and operational emissions from the project were estimated using CalEEMod (Version
2016.3.2).
Construction Emissions
Construction emissions result from on-site and off-site activities. On-site emissions principally
consist of exhaust emissions from the heavy-duty off-road construction equipment, on-site motor
vehicle operation, and fugitive dust (mainly PM2.5 and PM10) from disturbed soil. Off-site emissions
are caused by motor vehicle exhaust from deliver and haul truck vehicles, work traffic, and road dust
(mainly PM2.5 and PM10). The majority of this fugitive dust will remain localized and will be limited to
the atmosphere around the project site. However, the potential for off-site impacts from fugitive
dust exists unless control measures are implemented to reduce the particulate emissions from this
source prior to leaving the project site.
Based on applicant-provided information, it was assumed that construction of the project would begin
in January of 2019 and would last approximately four and one half years. A conceptual construction
schedule is provided in Table 3.3-6. There are no existing buildings or hardscape on-site, therefore, the
demolition phase would not be necessary. During grading, the project is expected to require the
import of approximately 877,000 cubic yards of new material and the removal of approximately
500,000 cubic yards of silt. As a conservative estimate, it was assumed that each haul truck would
have a capacity of 10 cubic yards per load. Based on this information, it was estimated that the project
would require up to 275,400 haul trips during the 1.5-year grading period.
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The emissions generated by construction equipment are based on the horsepower and load factors
of the equipment. The inventory of construction equipment derived from the CalEEMod land use
emission model for the land uses consistent with this project is shown as Table 3.3-7.
Table 3.3-6: Conceptual Construction Schedule
Phase Name Start Date End Date Number of working days
Site Preparation/Grading 1/1/2020 6/30/2021 391
Paving 7/1/2021 9/1/2021 45
Building Construction 9/2/2021 6/30/2024 737
Architectural Coating 3/16/2024 6/30/2024 75
Source: CalEEMod and FCS 2018, see Appendix F
Table 3.3-7: Construction Equipment Assumptions
Activity Equipment Amount Hours per day
Default
Horse-power
Default Load
Factor
Site
Preparation/Grading
Excavators 2 8 158 0.38
Graders 1 8 187 0.41
Rubber Tired Dozers 1 8 247 0.40
Scrapers 2 8 367 0.48
Tractors/Loaders/Backhoes 2 8 97 0.37
Building Construction
Cranes 1 7 231 0.29
Forklifts 3 8 89 0.20
Generator Sets 1 8 84 0.74
Tractors/Loaders/Backhoes 3 7 97 0.37
Welders 1 8 46 0.45
Paving
Pavers 2 8 130 0.42
Paving Equipment 2 8 132 0.36
Rollers 2 8 80 0.38
Architectural Coating Air Compressors 1 6 78 0.48
Source: CalEEMod and FCS 2018, see Appendix F
Table 3.3-8 presents the project construction emissions prior to the application of mitigation
measures. The maximum daily emissions are compared with SCAQMD regional significance
thresholds.
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Table 3.3-8: Construction Maximum Daily Regional Emissions—Unmitigated
Activity
Mass Daily Emissions (pounds per day)
VOC NOX CO SOX PM10 PM2.5
2020
Site Preparation/Grading—2020 9.99 246.36 84.09 0.60 22.68 8.50
2021
Site Preparation/Grading—2021 9.47 227.62 83.08 0.60 36.75 11.78
Paving 1.32 12.96 15.07 0.02 0.85 0.67
Building Construction—2021 3.07 25.94 25.37 0.07 4.10 1.77
2022
Building Construction—2022 2.82 23.63 24.63 0.07 3.94 1.63
2023
Building Construction—2023 2.59 20.50 23.92 0.07 3.83 1.52
2024
Building Construction—2024 2.44 19.45 23.40 0.07 3.74 1.43
Architectural Coating 22.87 1.30 2.85 0.01 0.58 0.20
Building Construction and Architectural
Coating Overlap 25.31 20.75 26.25 0.08 4.32 1.63
Maximum Daily Emissions 25.31 246.36 84.09 0.60 36.75 11.78
SCAQMD Air Quality Significance
Thresholds 75 100 550 150 150 55
Exceed Threshold? No Yes No No No No
Notes:
VOC = Volatile Organic Compounds NOX = nitrogen oxides CO = carbon monoxide PM10 = particulate matter with an
aerodynamic resistance diameter of 10 micrometers or less; PM2.5 = particulate matter with an aerodynamic resistance
diameter of 2.5 micrometers
The PM10 and PM2.5 emissions reflect the exhaust and “mitigated” fugitive dust emissions in accordance with SCAQMD
Rule 403.
Source of emissions: CalEEMod and FCS 2018, see Appendix F.
As shown in Table 3.3-8, the maximum daily construction emissions are below the recommended
SCAQMD’s regional thresholds of significance, with the exception of NOX. The project is estimated to
generate up to 246.36 pounds of NOX per day, which exceed the 100 pounds per day threshold of
significance. Therefore, the project would result in a potentially significant impact prior to the
application of mitigation. Consequently, mitigation measures are required.
Table 3.3-9 presents the project’s maximum daily construction emissions with implementation of
mitigation measures AIR-1a through AIR-1g.
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Table 3.3-9: Construction Maximum Daily Regional Emissions—Mitigated
Activity
Mass Daily Emissions (pounds per day)
VOC NOX CO SOX PM10 PM2.5
2020
Site Preparation/Grading—2020 6.30 199.47 85.13 0.60 20.61 6.60
2021
Site Preparation/Grading—2021 6.04 184.52 85.20 0.60 34.87 10.06
Paving 0.34 1.25 17.72 0.02 0.21 0.08
Building Construction—2021 1.76 11.24 26.47 0.07 3.25 0.98
2022
Building Construction—2022 1.67 10.71 25.93 0.07 3.24 0.97
2023
Building Construction—2023 1.55 8.76 25.31 0.07 3.22 0.95
2024
Building Construction—2024 1.49 8.61 24.86 0.07 3.21 0.94
Architectural Coating 22.72 0.21 2.87 0.01 0.52 0.14
Building Construction and Architectural
Coating Overlap 24.20 8.83 27.74 0.08 3.73 1.08
Maximum Daily Emissions 24.20 199.47 85.20 0.60 34.87 10.06
SCAQMD Air Quality Significance
Thresholds 75 100 550 150 150 55
Exceed Threshold? No Yes No No No No
Notes:
NOX = nitrogen oxides VOC = Volatile Organic Compounds CO = carbon monoxide PM10 = particulate matter with an
aerodynamic resistance diameter of 10 micrometers or less; PM2.5 = particulate matter with an aerodynamic resistance
diameter of 2.5 micrometers
The PM10 and PM2.5 emissions reflect the exhaust and “mitigated” fugitive dust emissions in accordance with SCAQMD
Rule 403.
Source: CalEEMod and FCS 2018, see Appendix F
As shown in Table 3.3-9, the project’s construction activities are estimated to generate a maximum
199.47 pounds of NOX per day with implementation of mitigation measures AIR-1a through AIR-1g.
As such, the project’s construction would continue to exceed the SCAQMD’s recommended regional
threshold of significance for NOX even after implementation of Mitigation Measures AIR-1a through
AIR-1g. As shown summarized in Table 3.3-9, the project’s construction activities are only
anticipated to exceed any of SCAQMD’s regional thresholds of significance during the combined site
preparation and grading period. A review of the detailed emissions estimates, contained in
Appendix F, shows that 196.17 pounds of the 199.47 pounds of NOX are from off-site sources. As
previously discussed, the project is anticipated to require up to 275,400 total haul trips during the
grading period. Because the exceedance is largely a result of the anticipated haul trips, feasible and
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enforceable mitigation measures to reduce the impact are limited. Based on the total haul trucks
required each day and the fact that specific make and model of haul trucks can vary by contractor
and within each contractor fleet, it would not be feasible to mandate the use of specific vehicles to
haul soil for the proposed project. Because no additional feasible mitigation measures are available
beyond those already quantified in Table 3.3-9, the project’s regional operational emissions of NOX
would continue to exceed the applicable SCAQMD regional construction significance threshold even
after implementation of all feasible mitigation. This represents a significant and unavoidable impact.
Operational Emissions
As previously discussed, the pollutants of concern include VOC, NOX, PM10, and PM2.5. Operational
emissions are generated by area, energy, and mobile sources. Area sources would include activities
such as landscape maintenance and occasional architectural coatings. Energy sources would include
electricity and natural gas combustion for space and water heating. Mobile sources would include
vehicle trips associated with passenger cars. The SCAQMD regional emission significance thresholds
were used. The operational emissions were also modeled for summer and winter seasons. Table
3.3-10 shows the project’s maximum daily emissions prior to the application of mitigation.
Table 3.3-10: Maximum Daily Regional Operational-related Emissions—Unmitigated
Category
Mass Daily Emissions (pounds per day)
VOC NOX CO SOX PM10 PM2.5
Area 6.15 0.12 10.66 0.00 0.06 0.06
Energy 0.10 0.84 0.36 0.01 0.07 0.07
Mobile 0.80 3.31 10.98 0.04 3.96 1.08
Total Emissions 7.05 4.27 21.99 0.05 4.08 1.20
SCAQMD Significance
Thresholds (lbs/day) 55 55 550 150 150 55
Exceed Threshold? No No No No No No
Notes:
VOC = Volatile Organic Compounds NOX = nitrogen oxides CO = carbon monoxide PM10 = particulate matter with an
aerodynamic resistance diameter of 10 micrometers or less; PM2.5 = particulate matter with an aerodynamic resistance
diameter of 2.5 micrometers
Source: CalEEMod and FCS 2018, see Appendix F—For each source, the maximum emissions between summer and winter
are shown.
As shown in Table 3.3-10, the maximum daily operational emissions are below the thresholds of
significance. Therefore, the project’s operational-related impacts are less than significant.
The project’s operational-related emissions would be below SCAQMD’s thresholds; however, the
project’s construction-related emissions would continue to exceed SCAQMD’s applicable significance
threshold for NOX with implementation of mitigation measures. Therefore, the project would violate
an air quality standard or contribute substantially to an existing or projected air quality violation.
Impacts would be significant and unavoidable.
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Level of Significance Before Mitigation
Potentially significant impact.
Mitigation Measures
Implement Mitigation Measures AIR-1a through AIR-1g.
Level of Significance After Mitigation
Significant and unavoidable impact.
Cumulative Impacts
Impact AIR-3: The project may result in a cumulatively considerable net increase of any criteria
pollutant for which the project region is non-attainment under an applicable
federal or state ambient air quality standard.
Impact Analysis
The project’s regional operational emissions were determined to be below the SCAQMD’s project-
level regional thresholds of significance; however, the project’s construction-related emissions would
exceed the applicable SCAQMD significance threshold for NOX with implementation of all feasible
mitigation measures. The thresholds of significance represent the allowable amount of emissions
each project can generate without generating a cumulatively considerable contribution to regional
air quality impacts. If an area is in non-attainment for a criteria pollutant, then the background
concentration of that pollutant has historically exceeded the ambient air quality standard. It follows
that if a project exceeds the regional thresholds for that non-attainment pollutant, then it would
result in a cumulatively considerable net increase of that pollutant and result in a significant
cumulative impact.
As discussed above, the region is non-attainment for the federal and state ozone standards, the state
PM10 standards, and the federal and state PM2.5 standards. Therefore, a project that would not
exceed the SCAQMD thresholds of significance on a project-level would also not result in a
cumulatively considerable contribution to these regional air quality impacts. The impacts from the
project would, therefore, be cumulatively less than significant during project operations and
significant and unavoidable during project construction.
Level of Significance Before Mitigation
Potentially significant impact.
Mitigation Measures
Implement Mitigation Measures AIR-1a through AIR-1g.
Level of Significance After Mitigation
Significant and unavoidable impact.
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Impacts on Sensitive Receptors
Impact AIR-4: The project may expose sensitive receptors substantial pollutant concentrations.
Impact Analysis
To result in a less than significant impact, the following criteria must be true:
• Criterion 1: LST assessment: emissions and air quality impacts during project construction or
operation must be below the applicable LSTs.
• Criterion 2: A CO hot spot assessment must demonstrate that the project would not result in
the development of a CO hot spot that would result in an exceedance of the CO ambient air
quality standards.
• Criterion 3: The construction or operation of the project would not result in an exceedance of
the health risk significance thresholds.
Criterion 1: Localized Significance Threshold
As mentioned in Section 3.3.3, the SCAQMD has recommended LSTs for project construction and
operational emissions. The SCAQMD has prepared LST emission look-up tables that were developed
for each SRA that can be used to determine whether a project may generate significant adverse
localized air quality impacts4. The SCAQMD has established LSTs for project construction and operation
emissions for NO2, CO, PM10, and PM2.5. Project impacts for these pollutants are then compared
against the applicable SCAQMD’s LSTs to determine the significance of the project impacts.
As noted in Section 3.3.3, the project is located within SRA 17 in central Orange County and the
nearest sensitive receptors from the project site would be in the residential areas located within in
25 meters from the east edge of the project site.
Construction
The SCAQMD has published a “Fact Sheet for Applying CalEEMod to Localized Significance
Thresholds” (SCAQMD 2011a). The CalEEMod calculates construction emissions based on the number
of equipment hours and the maximum daily disturbance activity possible for each piece of equipment.
To compare CalEEMod reported emissions against the LST lookup tables, the CEQA document should
contain in its project design features or its mitigation measures the following parameters:
1. The off-road equipment list (including type of equipment, horsepower, and hours of
operation) assumed for the day of construction activity with maximum emissions;
2. The maximum number of acres disturbed on the peak day the equipment list summarized in
Table 3.3-11;
4 SCAQMD Localized Significance Thresholds website: http://www.aqmd.gov/home/regulations/ceqa/air-quality-analysis-
handbook/localized-significance-thresholds
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Table 3.3-11: Construction Equipment Summary
Activity Equipment
Acres disturbed/8 hour
day
Site Preparation and Grading Crawler Tractors 0.5
Graders 0.5
Rubber Tired Dozers 0.5
Scrapers 1
Source: CalEEMod User’s Guide.
3. Any emission control devices added onto off-road equipment; and
4. Specific dust suppression techniques used on the day of construction activity with maximum
emissions.
The LST emission look-up tables only apply to projects that their maximum daily disturbed area is
less than or equal to 5 acres. Table 3.3-12 shows the project’s maximum daily disturbed acreage
during construction.
Table 3.3-12: Maximum Daily Disturbed Acreage
Activity Equipment Number Acres/8-hour day Total Acres
Site
Preparation/Grading
Crawler Tractors 2 0.5 1
Graders 1 0.5 0.5
Rubber Tired Dozers 1 0.5 0.5
Scrapers 2 1 2
Maximum Number of Acres Disturbed per Day 4
Source: SCAQMD 2011.
As shown in Table 3.3-12, the maximum daily disturbed acreage is 4 acres, which is less than the
maximum 4 acres per day limitation in using the LST emission lookup tables. The LST emission
lookup tables contain LSTs for 1-, 2-, and 5-acre sites; therefore, the LSTs for a 2-acre site and a 5-
acre were obtained. The LSTs used to determine significance for the construction portion of this
criterion are for a 4-acre site, which was determined by linearly interpolating between the values for
the 2- and 5-acre thresholds. Therefore, if the maximum daily on-site emissions generated per day
during construction are below the 4-acre emission thresholds, the project’s localized air pollutant
impacts would be less than significant. If on-site emissions exceed the LSTs, then the project would
require a further air dispersion models for criteria pollutants.
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Therefore, on-site emissions from construction activities were compared with the LSTs for a 4-acre
site in SRA 17 at a distance of 25 meters to the nearest sensitive receptor. Table 3.3-13 shows the
maximum daily on-site construction emissions.
Table 3.3-13: Construction Localized Significance Analysis—Unmitigated
Activity
On-site Emissions (pounds per day)
NOX CO PM10 PM2.5
Site Preparation/Grading—2020 50.20 31.96 4.97 3.35
Site Preparation/Grading—2021 46.40 30.88 4.78 3.17
Paving 12.92 14.65 0.68 0.62
Building Construction—2021 17.43 16.58 0.96 0.90
Building Construction—2022 15.62 16.36 0.81 0.76
Building Construction—2023 14.38 16.24 0.70 0.66
Building Construction—2024 13.44 16.17 0.61 0.58
Architectural Coating 1.22 1.81 0.06 0.06
Building Construction and
Architectural Coating Overlap 14.66 17.98 0.67 0.64
Maximum Daily On-Site Emissions 50.20 31.96 4.97 3.35
LST (4-acre site) 160 1,074 11 6
Exceed Threshold? No No No No
Notes:
NOX = nitrogen oxides; VOC = volatile organic compounds; CO = carbon monoxide
PM10 = particulate matter with an aerodynamic resistance diameter of 10 micrometers or less
PM2.5 = particulate matter with an aerodynamic resistance diameter of 2.5 micrometers
The PM10 and PM2.5 emissions reflect the exhaust and “mitigated” fugitive dust emissions in accordance with SCAQMD
Rule 403.
Source of emissions: CalEEMod and FCS 2018, see Appendix F
Source of thresholds: SCAQMD 2009, for SRA 17, 25 meters for 5-acre and 2-acre sites.
As shown in Table, unmitigated on-site emissions during construction would not exceed the LSTs. If
the project results in emissions that do not exceed the LSTs, it follows that those emissions would
not cause or contribute to a local exceedance of appropriate ambient air quality standard.
Therefore, the project would not expose receptors to substantial criteria pollutant concentrations
from construction activities prior to the implementation of mitigation.
For informational purposes, construction emissions with the application of Mitigation Measures
AIR-1a through AIR-1g are shown below in Table 3.3-14.
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Table 3.3-14: Construction Localized Significance Analysis—Mitigated
Activity
On-site Emissions (pounds per day)
NOX CO PM10 PM2.5
Site Preparation/Grading—2020 3.30 33.00 2.90 1.45
Site Preparation/Grading—2021 3.30 33.00 2.90 1.45
Paving 1.22 17.30 0.04 0.04
Building Construction—2021 2.74 17.68 0.11 0.11
Building Construction—2022 2.69 17.66 0.10 0.10
Building Construction—2023 2.65 17.64 0.09 0.09
Building Construction—2024 2.61 17.63 0.09 0.09
Architectural Coating 0.13 1.83 0.00 0.00
Building Construction and
Architectural Coating Overlap 2.74 19.46 0.09 0.09
Maximum Daily On-Site
Emissions 3.30 33.00 2.90 1.45
LST (2-acre site) 115 715 6 4
LST (5-acre site) 183 1,253 13 7
LST (4-acre site) 160 1,074 11 6
Exceed Threshold? No No No No
Notes:
NOX = nitrogen oxides; VOC = volatile organic compounds; CO = carbon monoxide
PM10 = particulate matter with an aerodynamic resistance diameter of 10 micrometers or less
PM2.5 = particulate matter with an aerodynamic resistance diameter of 2.5 micrometers
The PM10 and PM2.5 emissions reflect the exhaust and “mitigated” fugitive dust emissions in accordance with SCAQMD
Rule 403.
Source of emissions: CalEEMod and FCS 2018, see Appendix F
Source of thresholds: SCAQMD 2009, for SRA 17, 25 meters for 5-acre and 2-acre sites.
As shown in Table 3.3-14, mitigated construction emissions would remain less than significant.
Operations
The project consists of the development of a maximum of 128 single family houses (25 to 50 acres)
and the preservation of the remaining acreage as open space. The operational-related on-site
emissions would include activities such as landscape maintenance, occasional architectural coatings,
and electricity and natural gas usage for space and water heating. Since the majority of project-
generated emissions would come from residential use, the project is not expected to generate
relatively large amounts of pollutant emissions. In addition, the on-site emissions during operation
are compared to the LSTs and summarized in Table 3.3-15. Because the project site is larger than the
largest size available on the emission lookup tables (5 acres), the project’s on-site operational
emissions are compared with the LSTs for a 5-acre site in SRA 17 at a distance of 25 meters.
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Table 3.3-15: Operational Localized Significance Analysis—Unmitigated
Emissions Source
Maximum On-site Emissions (Pounds per Day)
NOX CO PM10 PM2.5
Area 0.12 10.66 0.06 0.06
Energy 0.84 0.36 0.07 0.07
Mobile1 1.40 2.43 0.21 0.06
Total On-site Emissions 2.37 13.45 0.34 0.19
Localized Significance Threshold 183 1,253 3 2
Exceeds Significance Threshold? No No No No
Notes:
NOX = nitrogen oxides VOC = Volatile Organic Compounds CO = carbon monoxide PM10 = particulate matter with an
aerodynamic resistance diameter of 10 micrometers or less; PM2.5 = particulate matter with an aerodynamic resistance
diameter of 2.5 micrometers
1 All trips used a trip length of 0.5 mile and all trips were considered primary to estimate on-site mobile emissions.
Source of emissions: CalEEMod and FCS 2018, see Appendix F
Source of thresholds: SCAQMD 2009, for SRA 17, 25 meters, 5-acre site.
As shown in Table 3.3-15, on-site project operational-related emissions would not exceed the
operational LSTs. Therefore, the project would not expose receptors to substantial criteria pollutant
concertation from operational-related activities.
Criterion 2: Carbon Monoxide Hot Spot Analysis
An adverse CO concentration, known as a “hot spot,” would occur if an exceedance of the state one-
hour standard of 20 ppm or the eight-hour standard of 9 ppm were to occur. At the time of the
SCAQMD 1993 Handbook, the SoCAB was designated nonattainment under the California AAQS and
National AAQS for CO.
It has long been recognized that CO hotspots are caused by vehicular emissions, primarily when
idling at congested intersections. In response, vehicle emissions standards have become increasingly
stringent in the last twenty years. Currently, the allowable CO emissions standard in California is a
maximum of 3.4 grams/mile for passenger cars (there are requirements for certain vehicles that are
more stringent). With the turnover of older vehicles, introduction of cleaner fuels, and
implementation of increasingly sophisticated and efficient emissions control technologies, CO
concentration in the SoCAB is now designated as attainment.
To establish a more accurate record of baseline CO concentrations affecting the SoCAB, a CO “hot
spot” analysis was conducted in 2003 for four busy intersections in Los Angeles at the peak morning
and afternoon time periods.
The analysis prepared for CO attainment in the SoCAB by the SCAQMD can be used to assist in
evaluating the potential for CO exceedances in the SoCAB. CO attainment was thoroughly analyzed
as part of the SCAQMD’s 2003 Air Quality Management Plan (2003 AQMP) and the 1992 Federal
Attainment Plan for Carbon Monoxide (1992 CO Plan). As discussed in the 1992 CO Plan, peak
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carbon monoxide concentrations in the SoCAB are due to unusual meteorological and topographical
conditions, and not due to the impact of particular intersections. Considering the region’s unique
meteorological conditions and the increasingly stringent CO emissions standards, CO modeling was
performed as part of 1992 CO Plan and subsequent plan updates and air quality management plans.
In the 1992 CO Plan, a CO hot spot analysis was conducted for four busy intersections in Los Angeles
at the peak morning and afternoon time periods. The intersections evaluated included: Long Beach
Boulevard and Imperial Highway (Lynwood); Wilshire Boulevard and Veteran Avenue (Westwood);
Sunset Boulevard and Highland Avenue (Hollywood); and La Cienega Boulevard and Century
Boulevard (Inglewood). These analyses did not predict a violation of CO standards. The busiest
intersection evaluated was that at Wilshire Boulevard and Veteran Avenue, which has a daily traffic
volume of approximately 100,000 vehicles per day. The Los Angeles County Metropolitan
Transportation Authority evaluated the LOS in the vicinity of the Wilshire Boulevard/Veteran Avenue
intersection and found it to be Level E at peak morning traffic and Level F at peak afternoon traffic.
The Traffic Impact Analysis prepared by Linscott, Law & Greenspan, Engineers identified peak-hour
traffic volumes for nine intersections affected by the project. The report provided scenarios for
current year, year 2022 (operations start year) and year 2040.
As identified in the Traffic Impact Analysis, the maximum peak-hour intersection volume for year
2022 would occur at the East Chapman Avenue/Santiago Canyon Road/Jamboree Road intersection
in the Cumulative Plus Project Scenario during the PM peak hour. The estimated cumulative traffic
volume at this intersection is 5,663 PM peak-hour trips.
In addition, the maximum peak-hour intersection volume for year 2040 would occur at the E
Santiago Canyon Road/N Cannon Street in the cumulative plus project scenario during PM peak
hour. The estimated cumulative traffic volume at this intersection would be 7,496 PM peak-hour
trips. All of the estimated intersection traffic volumes are substantially lower than the intersection
volumes analyzed in the 1992 CO Plan. Consequently, at buildout of the project, according to the
project Traffic Impact Analysis, none of the intersections in the vicinity of the project would have
peak hourly traffic volumes exceeding those at the intersections modeled in the 2003 AQMP, nor
would there be any reason unique to SoCAB meteorology to conclude that this intersection would
yield higher CO concentrations if modeled in detail. As a result, the SoCAB has been designated as
attainment for CO since 2007 and even very busy intersections do not result in exceedances of the
CO standard. Therefore, the operation of the project would not be expected to generate a CO hot
spot that would exceed the CO ambient air quality standards.
Criterion 3: Construction Toxic Air Pollutants
Project-Specific Impacts during Construction and Operation
DPM has been identified by the ARB as a carcinogenic substance. Major sources of DPM include off-
road construction equipment and heavy-duty delivery truck activities. For purposes of this analysis,
DPM is represented as exhaust emissions of PM10.
The results of the HRA prepared for the project construction, for cancer risk, and long-term chronic
cancer risk are summarized below. Air dispersion modeling was utilized to assess the project’s
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potential health risks using the current version of AERMOD (Version 9.6.1) air dispersion model,
which is the air dispersion model accepted by the EPA and the SCAQMD for preparing HRAs. Exhaust
emissions of DPM were estimated using CalEEMod (Version 2016.3.2). Table 3.3-16 summarizes the
emission rates of unmitigated PM10 and PM10 with Tier IV Final mitigation.
Table 3.3-16: Project PM10 Construction Emissions—Unmitigated and Tier IV Final
Mitigation
Year
On-site DPM
(grams/m2/sec)
off-site DPM-WEST
(grams/sec)
Off-site DPM-EAST
(grams/sec)
Annual Construction Emissions (Unmitigated)
2020 1.52E-07 1.16E-04 1.91E-04
2021 9.86E-08 1.17E-04 1.84E-04
2022 5.60E-08 2.56E-05 4.21E-05
2023 4.85E-08 1.75E-05 2.91E-05
2024 4.49E-08 1.86E-05 3.07E-05
Annual Construction Emissions (Tier IV Final Mitigation)
2020 7.08E-09 1.16E-04 1.91E-04
2021 6.53E-09 1.17E-04 1.84E-04
2022 7.03E-09 2.56E-05 4.21E-05
2023 6.44E-09 1.75E-05 2.91E-05
2024 6.07E-09 1.86E-05 3.07E-05
Source: CalEEMod and FCS 2018, see Appendix F.
The estimated health and hazard impacts at the maximum impacted sensitive receptor from the
project’s construction emissions are provided in Table 3.3-17.
Table 3.3-17: Estimated Health Risks and Hazards: Project Construction—Unmitigated
Source
Cancer Risk
(risk per million)
Chronic
Non-Cancer Hazard Index(2)
Risks and Hazards at the Maximum Impacted
Sensitive Receptor (MIR): Infants(1) 18.6 0.01
Risks and Hazards at the Maximum Impacted
Sensitive Receptor (MIR): Child(1) 4.1 0.01
Risks and Hazards at the Maximum Impacted
Sensitive Receptor (MIR): Adult(1) 0.4 0.01
Significance Threshold 10 1
Exceeds Individual Source Threshold? Yes No
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Table 3.3-17 (cont.): Estimated Health Risks and Hazards: Project Construction—
Unmitigated
Source
Cancer Risk
(risk per million)
Chronic
Non-Cancer Hazard Index(2)
Notes:
(1) Maximum impacted sensitive receptor is a residence located approximately 25 meters east of the Project along the
River Birch Circle near Sycamore Glen Drive.
(2) Chronic non-cancer hazard index was estimated by dividing the maximum annual DPM concentration (as PM10
exhaust) by the REL of 5 μg/m3.
Source: AERMOD and FCS 2018, see Appendix F.
The sensitive receptor that has the highest cancer risks is located within in 25 meters (82 feet) from
the east edge of the project site, at the corner of River Birch Circle near Sycamore Glen Drive. As
noted in Table 3.3-17, the project’s construction DPM emissions would not exceed the non-cancer HI
significance threshold; however, the project’s construction DPM emissions would exceed the cancer
risk significance threshold prior to the application of mitigation. Therefore, the project is required to
implement Tier IV Final mitigation, as shown in Table 3.3-18.
Table 3.3-18: Estimated Health Risks and Hazards: Project Construction-with Tier IV Final
Mitigation
Source
Cancer Risk
(risk per million)
Chronic
Non-Cancer Hazard Index(2)
Risks and Hazards at the Maximum Impacted
Sensitive Receptor (MIR): Infants(1) 1.2 <0.01
Risks and Hazards at the Maximum Impacted
Sensitive Receptor (MIR): Child (1) 0.4 <0.01
Risks and Hazards at the Maximum Impacted
Sensitive Receptor (MIR): Adult (1) <0.1 <0.01
Significance Threshold 10 1
Exceeds Individual Source Threshold? No No
Notes:
(1) Maximum impacted sensitive receptor is a residence located approximately 25 meters east of the Project along the
River Birch Circle near Sycamore Glen Drive.
(2) Chronic non-cancer hazard index was estimated by dividing the maximum annual DPM concentration (as PM10
exhaust) by the REL of 5 μg/m3.
Source: AERMOD and FCS 2018, see Appendix F.
As noted in Table 3.3-17, the project’s construction DPM emissions would not exceed the cancer risk
and non-cancer HI significance thresholds with Tier IV Final mitigation. Therefore, the project would
not result in a significant impact on nearby sensitive receptors during construction, after the
implementation of Mitigation Measures AIR-1a through AIR-1g.
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As previously mentioned, the residential nature of the project would not result in the emissions of
TACs during project operation. Therefore, the operation of the project would not result in a
significant health risk during operations.
Cumulative HRA Impacts during Construction and Operation
As presented in Section 3.3.3 above, projects that exceed the project-specific significance thresholds
are considered by the SCAQMD to be cumulatively considerable. Conversely, projects that do not
exceed the project-specific thresholds are generally not considered to be cumulatively significant. As
discussed in criteria 1 through 3, the project would not expose sensitive receptors to substantial
pollutant concentrations after the implementation of Mitigation Measure AIR-1a through AIR1g.
Since this project does not exceed the project-specific thresholds after mitigation, it would not be
considered to result in cumulatively significant impacts.
Level of Significance Before Mitigation
Potentially significant impact.
Mitigation Measures
Implement Mitigation Measures AIR-1a through AIR-1g.
Level of Significance After Mitigation
Less than significant impact.
Objectionable Odors
Impact AIR-5: The project would not create objectionable odors affecting a substantial number
of people.
Impact Analysis
Odors can cause a variety of responses. The impact of an odor often results from interacting factors
such as frequency (how often), intensity (strength), duration (time), offensiveness (unpleasantness),
location, and sensory perception.
Odor is typically a warning system that prevents animals and humans from consuming spoiled food
or toxic materials. Odor-related symptoms reported in a number of studies include nervousness,
headache, sleeplessness, fatigue, dizziness, nausea, loss of appetite, stomachache, sinus congestion,
eye irritation, nose irritation, runny nose, sore throat, sough and asthma exacerbation (SCAQMD
2007).
The SCAQMD’s role is to protect the public’s health from air pollution by overseeing and enforcing
regulations (SCAQMD 2007). The SCAQMD’s resolution activity for odor compliance is mandated
under California Health & Safety Code Section 41700, and falls under SCAQMD Rule 402. The Public
Nuisance Regulation states: “A person shall not discharge from any source whatsoever such
quantities of air contaminants or other material which cause injury, detriment, nuisance, or
annoyance to any considerable number of persons or to the public, or which endanger the comfort,
repose, health or safety of any such persons or the public, or which cause, or have a natural
tendency to cause, injury or damage to business or property. The provisions of this rule shall not
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apply to odors emanating from agricultural operations necessary for the growing of crops or the
raising of fowl or animals.”
During construction, the various diesel-powered vehicles and equipment in use on-site would create
localized odors. These odors would be temporary and would not likely be noticeable beyond the
project’s site boundaries. The potential for diesel odor impacts associated with construction
activities at the project site is therefore less than significant. Land uses typically considered
associated with odors include wastewater treatment facilities, waste-disposal facilities, or
agricultural operations and these types of land uses are not located in the project’s vicinity. The
project does not contain land uses typically associated with emitting objectionable odors.
During operation of the project, odors would primarily consist of vehicles traveling to the urban
linear park and additionally from the use of equi pment during landscaping and facility maintenance.
These occurrences would not produce a significant amount of odors; therefore, operational impacts
would be less than significant.
Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
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3.4 - Biological Resources
3.4.1 - Introduction
This section describes the existing biological setting and potential effects from project
implementation on the site and its surrounding area. Descriptions and analysis in this section are
based on the Biological Resources Assessment prepared by ESA, the Jurisdictional Delineation
prepared by PCR, and the Tree Survey prepared by PCR. The reports are provided in Appendix G.
3.4.2 - Environmental Setting
Natural Communities and Habitats
The project site contains 28 natural communities and habitats, which are summarized in Table 3.4-1.
The locations of the natural communities and habitats are provided in Exhibit 3.4-1.
Table 3.4-1: Natural Community Summary
Natural Community
Acres
Total
Southern Cottonwood—Willow Riparian Forest 12.79
Coastal Sage Scrub 0.57
Coastal Sage Scrub/Non-Native Herbaceous Cover 0.19
Coast Live Oak Woodland 0.33
Blue Elderberry Scrub 0.13
California Brittlebush Scrub 0.26
Laurel Sumac Scrub 0.38
Yerba Santa Scrub 0.31
Mule Fat Scrub 0.17
Open Water 0.66
Giant Reed 0.44
Ornamental 0.49
Eucalyptus Woodland 0.43
Non-Native Grassland/Non-Native Herbaceous Cover 25.47
Non-Native Grassland/Disturbed 3.89
Non-Native Herbaceous Cover 5.11
Non-Native Herbaceous Cover/Black Willow Scrub 0.20
Non-Native Herbaceous Cover/Coastal Sage Scrub 0.43
Non-Native Herbaceous Cover/Mule Fat Scrub 0.26
Non-Native Herbaceous Cover/Ornamental 7.05
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Table 3.4-1 (cont.): Natural Community Summary
Natural Community
Acres
Total
Non-Native Herbaceous Cover/Disturbed 0.19
Disturbed 19.46
Disturbed/Arroyo Willow Scrub 0.11
Disturbed/Black Willow Scrub 0.31
Disturbed/Coastal Sage Scrub 0.30
Disturbed/Mule Fat Scrub 0.03
Disturbed/Non-Native Herbaceous Cover 26.22
Developed 3.57
Total 109.75
Source: ESA, 2017.
Southern Cottonwood-Willow Riparian Forest
Southern cottonwood-willow riparian forest is dominated by Fremont’s cottonwood (Populus
fremontii), black cottonwood (Populus trichocarpa), black willow (Salix gooddingii), red willow (Salix
laevigata), arroyo willow (Salix lasiolepis), and mule fat (Baccharis salicifolia). Other species found
within this community include coast live oak (Quercus agrifolia), poison oak (Toxicodendron
diversilobum), cattail (Typha sp.), Southern California grape (Vitis girdiana), cocklebur (Xanthium
strumarium), California sagebrush (Artemisia californica), western sycamore (Platanus racemosa),
blue elderberry (Sambucus nigra ssp. caerulea), phacelia (Phacelia sp.), watercress (Nasturtium
officinale), rush (Juncus sp.), spike rush (Eleocharis sp.), mugwort (Artemisia douglasiana), California
blackberry (Rubus ursinus), giant reed (Arundo donax), and giant wild rye (Leymus condensatus). In
addition, several non-native invasive species were observed, including Mexican fan palm
(Washingtonia robusta), date palm (Phoenix canariensis), Peruvian peppertree (Schinus molle),
castor bean (Ricinus communis), tree tobacco (Nicotiana glauca), white cudweed
(Pseudognaphalium luteo-album), and black mustard (Brassica nigra). Southern cottonwood-willow
riparian forest is found throughout the northern portion of the project site within Santiago Creek.
Coastal Sage Scrub
Coastal sage scrub, which is covered under the County of Orange (Central/Coastal) Natural
Community Conservation Plan/Habitat Conservation Plan (NCCP/HCP), is dominated by California
sagebrush and California bush sunflower (Encelia californica). Other species within this community
include coastal prickly pear (Opuntia littoralis), California buckwheat (Eriogonum fasciculatum), felt-
leaved yerba santa (Eriodictyon crassifolium), deerweed (Acmispon glaber), Wright’s cudweed
(Pseudognaphalium canescens ssp. microcephalum), poison oak, and black mustard. Coastal sage
scrub is found along the northwestern portion of the project site.
27650002 • 07/2018 |3.4-1_natural_com.cdr
Exhibit 3.4-1
Natural Communities
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: ESA, July 2018. ESRI Aerial Imagery, 2017.
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Coastal Sage Scrub/Non-Native Herbaceous Cover
This community consists of coastal sage scrub dominated by California sagebrush, but has a large
component of weedy non-native herbaceous species, such as black mustard. Coastal sage
scrub/non-native herbaceous cover is found along the northwestern portion of the project site.
Coast Live Oak Woodland
Coast live oak woodland is dominated by coast live oak with an understory of poison oak. Associated
species found within this community include gum tree, blue elderberry, toyon, vinca (Vinca major),
poison oak, wild grape, and English ivy. Coast live oak woodland occurs in patches throughout the
southeastern portion of the project site.
Blue Elderberry Scrub
Blue elderberry scrub is dominated by patches of blue elderberry intermixed with patches of laurel
sumac (Malosma laurina), some dead trees, and non-native herbaceous cover. This community
occurs within the northern portion of the project site.
California Brittlebush Scrub
California brittlebush scrub consists of a nearly monotypic community of California brittlebush that is
spaced out adjacent to the northern boundary of the project site along Mabury Avenue.
Laurel Sumac Scrub
Laurel sumac scrub is dominated by patches of laurel sumac intermixed non-native herbaceous cover
along the northern slopes of the project site.
Yerba Santa Scrub
Yerba santa scrub is dominated by felt-leaved yerba santa within a nearly monotypic community.
Associated species observed include California sagebrush, wild cucumber (Marah macrocarpa),
scalebroom (Lepidospartum squamatum), coastal prickly pear, and black mustard. Yerba santa scrub
occurs within the northwestern portion of the project site.
Mule Fat Scrub
Mule fat scrub is dominated by patches of mule fat. This community was found adjacent to Santiago
Creek in the northern portion of the project site, and patches of mule fat were found adjacent to a
ponded area in the southwestern portion of the project site. Associated species observed include
Southern California black walnut in the patch near Santiago Creek, and arroyo willow and non-native
gum tree and Mexican fan palm near the ponded area.
Open Water
Open water was mapped in two ponded areas in the southwestern corner of the project site.
Although ponded open water has not been observed here in previous years, due to the heavy rainfall
during the 2016–2017 rainy season, ponding was observed during the vegetation mapping update.
Giant Reed
Large dense stands of giant reed dominate this community within Santiago Creek.
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Ornamental
Ornamental landscaping consists of introduced trees and shrubs associated with development.
Ornamental areas within the project site are dominated by non-native trees, including gum tree,
pine (Pinus sp.), Mexican fan palm, and Peruvian peppertree, among other ornamental tree species.
Ornamental landscaping occurs in patches throughout the southeastern portion of the project site.
Eucalyptus Woodland
Areas mapped as eucalyptus woodland consisted of windrows of planted gum trees of various
species. Eucalyptus woodland was found within the southeastern portion of the project site.
Non-Native Grassland/Non-Native Herbaceous Cover
Non-native grassland/non-native herbaceous cover is dominated by non-native annual grasses, such
as barley (Hordeum sp.), ripgut brome (Bromus diandrus), red brome (Bromus madritensis),
peregrine saltbush (Atriplex suberecta), and intermixed with non-native herbaceous species such as
black mustard. This community is found within large fields in the northern and western portions of
the project site.
Non-Native Grassland/Disturbed
Non-native grassland/disturbed is dominated by non-native annual grasses and open, disturbed
areas that support little or no vegetation. Non-native grassland/disturbed is found within the
western portion of the project site.
Non-Native Herbaceous Cover
A non-native herbaceous cover area observed within the eastern portion of the project site is
dominated by non-native, weedy species such as short-podded mustard (Hirschfeldia incana) and
tocalote (Centaurea melitensis).
Non-Native Herbaceous Cover/Black Willow Scrub
Within the eastern portion of the project site, there is an open field exhibiting evidence of discing.
Although most of this area is dominated by non-native herbaceous cover, weedy species, an isolated
patch of a few black willow trees were planted along the southern edge of the field and comprise a
small community of non-native herbaceous cover/black willow scrub. This community comprises
less than ten individual black willow trees with an understory dominated by non-native herbaceous
cover species.
Non-Native Herbaceous Cover/Coastal Sage Scrub
Non-native herbaceous cover/coastal sage scrub is dominated by weedy, non-native herbaceous
species but exhibit sparse, remnant species of coastal sage scrub, including California sagebrush.
Non-native herbaceous cover/coastal sage scrub is found within the northwestern portion of the
project site.
Non-Native Herbaceous Cover/Mule Fat Scrub
Non-native herbaceous cover/mule fat scrub is dominated by weedy, non-native herbaceous species
but contains patches of sparse mule fat. Non-native herbaceous cover/mule fat scrub is found
within the western portion of the project site.
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Non-Native Herbaceous Cover/Ornamental
Non-native herbaceous cover/ornamental is dominated by weedy, non-native herbaceous species
such as black mustard, short-podded mustard, tree tobacco, Russian thistle (Salsola tragus), and
castor bean, intermixed with large ornamental tree species such as gum tree, Mexican fan palm,
date palm, Peruvian pepper tree, Brazilian pepper (Schinus terebinthifolius), and tree of heaven
(Ailanthus altissima). A number of native Southern California black walnuts are also found within
this community. Non-native herbaceous cover/ornamental is found north of Santiago Creek along
the northern boundary of the project site.
Non-Native Herbaceous Cover/Disturbed
Non-native herbaceous cover/disturbed is dominated by weedy, non-native herbaceous species
interspersed with disturbed areas that contain little or no vegetation. Non-native herbaceous
cover/disturbed is found in the central portion of the project site.
Disturbed
Disturbed or barren areas either completely lack vegetation or contain only very sparse nonnative
herbaceous cover. Disturbed areas within the project site consist of paved roads, dirt roads which
were compacted by vehicular use, areas which were previously disced or disturbed, or stockpiles of
recycling materials. Disturbed areas occur in the southeastern portions of the project site.
Disturbed/Arroyo Willow Scrub
This community comprises disturbed areas due to the existing activities on-site and these deep
trenches were excavated. Since water sometimes collects within these trenches, some sparse
vegetation has begun to grow and contain disturbed areas with arroyo willows. This community
occurs in the central-western portion of the project site.
Disturbed/Black Willow Scrub
This community comprises disturbed areas due to the existing activities on-site and these deep
trenches were excavated. Since water sometimes collects within these trenches, some sparse
vegetation has begun to grow and contain disturbed areas with black willows. This community
occurs in the central-western portion of the project site.
Disturbed/Coastal Sage Scrub
Disturbed/coastal sage scrub is dominated by non-native herbaceous cover, weedy species but
exhibit components of a coastal sage scrub community, including California sagebrush and
deerweed. Disturbed/coastal sage scrub is found within the northern central portion of the project
site.
Disturbed/Mule Fat Scrub
A small, isolated patch of disturbed/mule fat scrub is located within the southern portion of the
project site near the parking area. This community consists of sparse mule fat plants within an
otherwise disturbed area.
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Disturbed/Non-Native Herbaceous Cover
Disturbed/non-native herbaceous cover areas within the project site have various levels of previous
disturbance and range from sparsely vegetated or bare areas to disturbed areas vegetated with non-
native herbaceous cover species. Species observed within this community include horehound
(Marrubium vulgare), short-podded mustard, black mustard, tree tobacco, tocalote, red-stemmed
filaree (Erodium cicutarium), mule fat, broom baccharis (Baccharis sarothroides), slenderleaf iceplant
(Mesembryanthemum nodiflorum), scarlet pimpernel (Anagallis arvensis), Russian thistle, fennel
(Foeniculum vulgare), giant reed, laurel sumac, peregrine saltbush, and Mexican fan palm.
Disturbed/non-native herbaceous cover areas were found within the central and southwestern
portion of the project site.
Developed
The developed area consists of a paved parking area or roadways along the southern boundary of
the project site adjacent to East Santiago Canyon Road.
Sensitive Natural Communities
Because of its ability to support “Target Species” and “Identified Species,” coastal sage scrub is a
community that is covered under the NCCP/HCP. The project site includes 0.57 acre of coastal sage
scrub and 0.19 acre of coastal sage scrub/non-native herbaceous cover. In addition, the project site
supports four sensitive communities that are considered high priority for conservation by the
CDFW’s List of California Terrestrial Natural Communities, including southern cottonwood-willow
riparian forest (12.79 acres), blue elderberry scrub (0.13 acre), California brittlebush scrub (0.26
acre), and yerba santa scrub (0.31 acre) (refer to Exhibit 3.4-2).
Special-status Plant Species
Plant Species that Occur or with Potential to Occur
Sensitive plants include those listed, or candidates for listing, by the United States Fish and Wildlife
Service (USFWS) and California Department of Fish and Wildlife (CDFW), and species considered
sensitive by the California Native Plant Society (CNPS) (particularly Ranks 1A, 1B, 2A and 2B). Many
of the sensitive species addressed are also “Identified Species” under the NCCP/HCP and are
considered covered species. Several sensitive plant species were reported in the California Natural
Diversity Database (CNDDB) from the vicinity.
Focused sensitive plant surveys were conducted within suitable habitat on the project site in May
and August of 2010, 2012, 2013, 2014; June and August of 2015; and May of 2017 for the following
species: Coulter’s matilija poppy, foothill mariposa lily, chaparral sand verbena, Braunton’s milk-
vetch, Coulter’s saltbush, South Coast saltscale, thread-leaved brodiaea, Plummer’s mariposa lily,
southern tarplant, long-spined spineflower, many-stemmed dudleya, Los Angeles sunflower,
Coulter’s goldfields, mud nama, Southern California black walnut, Gambel’s water cress, Peninsular
nolina, Allen’s pentachaeta, white rabbit-tobacco, chaparral ragwort, and San Bernardino aster. Only
two of these sensitive plant species, Southern California black walnut and southern tarplant, were
observed within the project site during focused surveys, including the most recent surveys in May
2017, and are described below.
27650002 • 07/2018 |3.4-2_sens_com.cdr
Exhibit 3.4-2
Sensitive Natural Communities
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: ESA, July 2018. ESRI Aerial Imagery, 2017.
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Southern California Black Walnut
Southern California black walnut is a CNPS List 4.2 species [“Watch List” plants of limited
distribution; fairly endangered in California (20 to 80 percent occurrences threatened)]. Based on
the 2017 survey, a total of 71 Southern California black walnuts occur within the southern
cottonwood-willow riparian forest and non-native herbaceous cover communities within the
northwestern portion of the project site; refer to Exhibit 3.4-3.
Southern Tarplant
Southern tarplant is a CNPS List 1B.1 species [Plants Rare, Threatened, or Endangered in California
and elsewhere; seriously endangered in California (over 80 percent of occurrences threatened/high
degree and immediacy of threat)]. Approximately 48,417 southern tarplant individuals were
observed within disturbed habitat within the central portion of the project site and disturbed habitat
within the southern portion of the project site during the focused sensitive plant surveys conducted
in 2010; refer to Exhibit 3.4-3.
As part of the existing backfilling and material recycling operations, the project Applicant salvaged the
southern tarplant seed in 2010, 2013, and 2015. The southern tarplant seed was processed and stored
at RSABG. A portion of the southern tarplant seed was donated to RSABG’s permanent conservation
collection, and in 2015, a portion of the remaining seed was donated to Newport Banning Land Trust
for restoration. The remainder of the salvaged southern tarplant seed will be relocated and sown on-
and/or off-site within the open space areas to be avoided and preserved. A special-status plant survey
was conducted on May 19, 2017 and fewer than 100 southern tarplants were observed on-site.
Plant Species Not Expected to Occur
The following plant species have been documented to occur within the region but are not expected
to occur, due to lack of suitable habitat or because the project site is outside of the known range or
elevation for these species: Tecate cypress (Cupressus forbesii), Malibu baccharis (Baccharis
malibuensis), aphanisma (Aphanisma blitoides), big-leaved crownbeard (Verbesina dissita), Parish’s
brittlescale (Atriplex parishii), Davidson’s saltscale (Atriplex sernana var. davidsonii), estuary seablite
(Suaeda esteroa), Santa Monica Mountains dudleya (Dudleya cymosa ssp. ovatifola), Laguna Beach
dudleya (Dudleya stolonifera), Jokerst’s monardella (Monardella australis ssp. jokerstii), intermediate
monardella (Monardella hypoleuca ssp. intermedia), California Orcutt grass (Orcuttia californica),
California beardtongue (Penstemon californicus), Nuttall’s scrub oak (Quercus dumosa), heart-leaved
pitcher sage (Lepechinia cardiophylla), salt spring checkerbloom (Abronia villosa var. aurita), Santa
Ana River woollystar (Eriastrum densifolium ssp. sanctorum), prostrate vernal pool navarretia
(Navarretia prostrata), San Fernando Valley spineflower (Chorizanthe parryi var. fernandina), coast
woolly-heads (Nemacaulis denudata var. denudata), small-flowered mountain mahogany
(Cercocarpus minutiflorus), salt marsh bird’s-beak (Cordylanthus maritimus ssp. maritimus), and
Catalina mariposa lily (Calochortus catalinae).
Wildlife Species
Special-status wildlife include those species listed as Endangered or Threatened under the Federal
Endangered Species Act (FESA) or California Endangered Species Act (CESA), candidates for listing by
the USFWS or CDFW, and species of special concern to the CDFW. A number of sensitive wildlife
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species known to occur in the region were reported in the CNDDB. Many of the sensitive species
addressed are also included as “Identified Species” and are covered under the NCCP/HCP. In addition,
a few species were included in the table of sensitive wildlife presented below that have no Federal or
State status, but that were included in the NCCP/HCP. These “Target Species” are included and
analyzed in this document to provide a comprehensive list of species regardless of their Federal or
State status. Six sensitive wildlife species or NCCP/HCP species which were observed on-site include
white-tailed kite (Elanus leucurus), yellow-breasted chat (Icteria virens), coastal California gnatcatcher,
least Bell’s vireo, willow flycatcher (Empidonax traillii), and coyote (Canis latrans).
Focused sensitive wildlife surveys for arroyo toad, burrowing owl, coastal California gnatcatcher,
least Bell’s vireo, and southwestern willow flycatcher were conducted. An analysis of sensitive
wildlife species is presented as follows.
The following wildlife species have been documented to occur within the region, but are not
expected to occur because of lack of suitable habitat, the determination that they are not present
on-site, or because the project site is outside of the known range for these species: San Diego fairy
shrimp (Branchinecta sandiegonensis), Riverside fairy shrimp (Streptocephalus woottoni), Quino
checkerspot butterfly (Euphydryas editha quino), Santa Ana sucker (Catostomus santaanae), Santa
Ana speckled dace (Rhinichthys osculus ssp. 3), western spadefoot (Spea hammondii), black-bellied
slender salamander (Batrachoseps nigriventris), northern leopard frog (Rana pipiens), coastal rosy
boa (Charina trivirgata roseofusca), ring-necked snake (Diadophis punctatus), two-striped garter
snake (Thamnophis hammondii), western pond turtle (Actinemys marmorata), golden eagle (Aquila
chrysaetos), western yellow-billed cuckoo (Coccyzus americanus occidentalis), western snowy plover
(Charadrius alexandrinus nivosus), grasshopper sparrow (Amodramus savannarum), Belding’s
savannah sparrow (Passerculus sandwichensis beldingi), California least tern (Sternula antillarum
browni), tri-colored blackbird (Agelaius tricolor), cactus wren (Campylorhynchus brunneicapillus),
California black rail (Laterallus jamaicensis), light-footed clapper rail (Rallus longirostris levipes),
pocketed free-tailed bat (Nyctinomops femorosaccus), big free-tailed bat (Nyctinomops macrotis),
Mexican long-tongued bat (Choeronycteris mexicana), Southern California saltmarsh shrew (Sorex
ornatus salicornicus), Pacific pocket mouse (Perognathus longimembris pacificus), southern
grasshopper mouse (Onychomys torridus ramona), and American badger (Taxidea taxus ).
Sensitive wildlife species or NCCP/HCP species with potential to occur on-site include arboreal
salamander (Aneides lugubris), coast range newt (Taricha torosa torosa), coast patch-nosed snake
(Salvadora hexalepis virgultea), red-diamond rattlesnake (Crotalus ruber), coast horned lizard
(Phrynosoma coronatum), Coronado skink (Eumeces skiltonainus interparietalis), orange-throated
whiptail (Cnemidophorus hyperythrus), western mastiff bat (Eumops perotis californicus), San Diego
black-tailed jackrabbit (Lepus californicus bennettii), coastal (western) whiptail (Cnemidophorus tigris
stejnegeri), sharp-shinned hawk (Accipiter striatus), rough-legged hawk (Buteo lagopus), red-
shouldered hawk (Buteo lineatus), northern harrier (Circus cyaneus), burrowing owl (Athene
cunicularia), Southern California rufous-crowned sparrow (Aimophila ruficeps canescens), prairie
falcon (Falco mexicanus), American peregrine falcon (Falco peregrinus anatum), loggerhead shrike
(Lanius ludovicianus), long-eared owl (Asio otus), pallid bat (Antrozous pallidus), northwestern San
Diego pocket mouse (Chaetodipus fallax fallax), San Diego desert woodrat (Neotoma lepida
intermedia), and gray fox (Urocyon cinereoargenteus).
27650002 • 07/2018 |3.4-3_sens_plant.cdr
Exhibit 3.4-3
Special-Status Plant Species
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: ESA, July 2018. ESRI Aerial Imagery, 2017.
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Because of the presence of suitable habitat, focused surveys were conducted for arroyo toad,
burrowing owl, coastal California gnatcatcher, least Bell’s vireo, and southwestern willow flycatcher,
and are discussed in further detail as follows.
Arroyo Toad
The arroyo toad is a Federal Endangered Species and a Species of Special Concern. Focused surveys
for this species were conducted by Michael Brandman Associates (MBA) in 2008, and PCR in 2010.
No arroyo toads were found on-site. Because of the negative results of focused surveys, and lack of
suitable habitat for this species on-site, this species is not expected to occur within the project site.
Therefore, surveys were not repeated after 2010.
Burrowing Owl
The burrowing owl is a Species of Special Concern species. Focused surveys were conducted for this
species by PCR in 2012, 2013, 2014, and 2017. No burrowing owl were observed during focused
surveys and, because of the negative results of focused surveys, are not expected to occur within the
project site.
Coastal California Gnatcatcher
The coastal California gnatcatcher is a Federal Threatened and Species of Special Concern species.
This species is also a “Target Species” of the NCCP/HCP. Focused surveys were conducted for this
species by MBA in 2008 and PCR in 2010, 2012, 2013, 2014, 2015, and by ESA in 2017. An incidental
sighting of one dispersing coastal California gnatcatcher was observed on August 3, 2010 during a
focused special-status plant survey conducted by PCR. Because the coastal California gnatcatcher
was observed in disturbed/ruderal habitat (and not coastal sage scrub habitat), and since results of
the focused breeding season survey were negative in 2010, it is believed this individual observed was
likely a juvenile dispersing through the project site. No coastal California gnatcatchers were
observed on-site during focused breeding season surveys conducted in 2008, 2010, 2012, or 2013.
During focused surveys conducted in 2014, a coastal California gnatcatcher pair was observed within
the western portion of the project site on March 27, 2014. The pair did not appear to be engaged in
any definite breeding-related activity and was not observed within the project site on subsequent
surveys conducted during that season. However, what was believed to be the same pair was later
observed off-site on May 2, 2014, on the west side of Cannon Street in a more extensive area of
poor-quality coastal sage scrub habitat. No coastal California gnatcatchers were observed during the
2015 and 2017 focused breeding season surveys. In addition, incidental sightings of two separate
coastal California gnatcatcher individuals were observed on both June 9 and 27, 2017, by ESA
biologist Amy Lee and Michael Cady during jurisdictional delineation surveys. The locations of the
sightings are depicted on Exhibit 3.4-4. Because the habitat where the coastal California
gnatcatchers were seen were disturbed/non-native herbaceous cover or within disturbed areas
perched on mule fat (and not coastal sage scrub), and since results of the focused breeding season
surveys were negative (for 2017 focused surveys), it is believed these individuals observed were
likely juveniles dispersing through the project site. A number of coastal California gnatcatcher
occurrences are documented in the USFWS occurrences database within the vicinity of the project
site. Thus, it is likely that the coastal California gnatcatchers observed on-site are foraging or
dispersing through the project site from adjacent areas, particularly off-site areas downstream of the
project site to the west. However, no breeding pairs were found within the project site during the
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2008, 2010, 2012, 2013, 2014, 2015, or 2017 focused breeding season surveys. The coastal
California gnatcatcher is a covered species with implementation of the NCCP/HCP; however, no
impacts are proposed to coastal sage scrub habitat, which will be avoided by the project. The
project site is not within critical habitat for this species; the nearest final critical habitat for coastal
California gnatcatcher is 0.3-mile south of the project site.
Least Bell’s Vireo
The least Bell’s vireo is a Federal Endangered and State Endangered species. Least Bell’s vireo is
conditionally covered under the NCCP/HCP.17 Focused surveys were conducted for this species by
MBA in 2008 and PCR in 2010 and 2012. Least Bell’s vireo was observed within the project site
during focused surveys in 2008, 2010, and 2017; none were observed during the 2012, 2013, 2014,
or 2015 surveys. During the 2010 surveys conducted by PCR, a pair of least Bell’s vireo was observed
within the canopy of the southern cottonwood-willow riparian forest during the May 16, 2010
survey. Only the male least Bell’s vireo was seen or heard during subsequent surveys (on May 26,
June 5 and 16, July 17, and July 27, 2010). The location of least Bell’s vireo territory on-site which
was delineated by MBA is shown in Exhibit 3.4-4. Least Bell’s vireo was not detected during surveys
in 2012, 2013, 2014, or 2015. However, two separate individual males were detected by sight and
vocalization during the 2017 focused surveys, but because of the presence of least Bell’s vireo within
the southern cottonwood-willow-riparian forest located within the project site, the entire extent of
the southern cottonwood-willow riparian forest has been evaluated as potential habitat for this
species, as depicted in Exhibit 3.4-4.
Southwestern Willow Flycatcher
The southwestern willow flycatcher is a Federal Endangered and State Endangered species. The
project site is not within critical habitat for this species. The southwestern willow flycatcher is
conditionally covered under the NCCP/HCP. Focused surveys were conducted for this species by
MBA in 2008 and PCR in 2010, 2012, 2013, 2014, 2015, and ESA in 2017. No southwestern willow
flycatchers were observed on-site during focused surveys. However, willow flycatchers (i.e., not the
southwestern subspecies) were observed during the 2012 survey,1 as shown in Exhibit 3.4-4. Two
willow flycatchers were observed foraging and calling in the trees within the non-native herbaceous
cover/black willow scrub community that border the fallow field in the eastern portion of the project
site.
The habitat that these willow flycatchers were observed within is considered unsuitable as potential
nesting habitat; therefore, it is assumed that both birds were migrants passing through the area and
are not the southwestern willow flycatcher subspecies. In addition, one willow flycatcher was
observed calling in two locations within southern cottonwood-willow riparian forest within the
north-central portion of the project site. The habitat that this willow flycatcher was observed in is
considered suitable for nesting; however, no breeding willow flycatchers were observed during the
focused surveys.
1 Willow flycatcher (i.e., not the southwestern subspecies) were also surveyed for during the focused surveys for southwestern willow
flycatcher.
27650002 • 07/2018 |3.4-4_sens_wildlife.cdr
Exhibit 3.4-4
Special-Status Wildlife Species
Source: ESA, July 2018. ESRI Aerial Imagery, 2017.
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
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Jurisdictional Features
The project site contains one perennial United States Geological Survey (USGS) blueline stream
(Santiago Creek) and four associated tributaries, Tributaries A, B, C, and D. Total jurisdiction within the
project site consists of 5,686 linear feet of perennial streambed that supports approximately 4.24 acres
of United States Army Corps of Engineers (USACE)/Regional Water Quality Control Board (RWQCB)
jurisdictional “waters of the United States”/”waters of the State,” of which 1.19 acres are wetlands,
and 13.62 acres of CDFW jurisdictional streambed and associated riparian vegetation, as summarized
in Table 3.4-2 and shown on Exhibit 3.4-5.
Table 3.4-2: Jurisdictional Feature Summary
Feature Length
Acres
Type USACE/RWQCB CDFW
Santiago Creek 5,355 4.18 (1.19) 13.46 Perennial
Tributary A 68 <0.01 N/A* Ephemeral
Tributary B 48 0.01 N/A* Ephemeral
Tributary C 51 0.02 N/A* Perennial
Tributary D 184 0.03 0.16 Intermittent
Total 5,686 4.24 (1.19) 13.62 —
Notes:
Jurisdictional acreages overlap and are not additive
^ RWQCB acreages represent the portion of USACE jurisdiction that meets the three-parameter definition of a wetland
* Tributaries outlet within Santiago Creek and are therefore encompassed by the CDFW jurisdiction already quantified
for Santiago Creek
Source: PCR, 2013.
The Santiago Creek Watershed is approximately 99 square miles in size measured from the point
where the stream enters the Santa Ana River in the City of Santa Ana up to the southwest-facing
slopes of the Santa Ana Mountains in the Cleveland National Forest. Santiago Creek is a USGS
blueline drainage that supports regional flow from a significant upstream watershed that drains
several major canyons associated with the Santa Ana Mountains. The majority of canyon runoff
from the Santa Ana Mountains drains to the Santiago Reservoir which then conveys flow to the Villa
Park Dam facility located approximately 1.25 miles upstream of the project site. One major canyon
feature known as Walnut Canyon, and several minor canyon features associated with the adjacent
Santa Ana Mountain foothills to the north/northeast also convey flow to Santiago Creek between the
Villa Park Dam and the project site. Currently, five drainage outlets flow into Santiago Creek,
including a large concrete box culvert which transports flows from Handy Creek, and an underground
storm drain which conveys flows from the residential development to the north. Flows conveyed
through the project site ultimately discharge to the Pacific Ocean via the Santa Ana River located
approximately 7 miles southwest of the project site.
The on-site portion of Santiago Creek is an incised perennial USGS blueline drainage that primarily
supports southern cottonwood-willow riparian forest, as well as the development of fringe wetlands
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adjacent to the active channel. Santiago Creek bifurcates into two streambeds near the center of
the site, which ultimately rejoin in the western portion of the site as a single drainage feature. Soils
associated with Santiago Creek were dominated by sandy loam soils underlain by less permeable
silty clay soils or granitic bedrock.
Wildlife Movement
Wildlife corridors link together areas of suitable habitat that are otherwise separated by rugged terrain,
changes in vegetation, or human disturbance. The fragmentation of open space areas by urbanization
creates isolated “islands” of wildlife habitat. In the absence of habitat linkages that allow movement to
adjoining open space areas, various studies have concluded that some wildlife species, especially the
larger and more mobile mammals, will not likely persist over time in fragmented or isolated habitat
areas because they prohibit the infusion of new individuals and genetic material.
Corridors effectively act as links between different populations of a species. A group of smaller
populations (termed “demes”) linked together via a system of corridors is termed a
“metapopulation.” The long-term health of each deme within the metapopulation is dependent
upon its size and the frequency of interchange of individuals (immigration vs. emigration). The
smaller the deme, the more important immigration becomes, because prolonged inbreeding with
the same individuals can reduce genetic variability. Immigrant individuals that move into the deme
from adjoining demes mate with individuals and supply that deme with new genes and gene
combinations that increases overall genetic diversity. An increase in a population’s genetic variability
is generally associated with an increase in a population’s health and long-term viability.
Corridors mitigate the effects of habitat fragmentation by: (1) allowing animals to move between
remaining habitats, which allows depleted populations to be replenished and promotes genetic
diversity; (2) providing escape routes from fire, predators, and human disturbances, thus reducing
the risk that catastrophic events (such as fires or disease) will result in population or local species
extinction; and (3) serving as travel routes for individual animals as they move within their home
ranges in search of food, water, mates, and other needs.
Wildlife movement activities usually fall into one of three movement categories: (1) dispersal (e.g.,
juvenile animals from natal areas, individuals extending range distributions); (2) seasonal migration;
and, (3) movements related to home range activities (foraging for food or water, defending territories,
searching for mates, breeding areas, or cover). A number of terms have been used in various wildlife
movement studies, such as “wildlife corridor,” “travel route,” and “wildlife crossing” to refer to areas in
which wildlife move from one area to another. To clarify the meaning of these terms and facilitate the
discussion on wildlife movement in this study, these terms are defined as follows:
• Travel Route: A landscape feature (such as a ridgeline, drainage, canyon, or riparian strip)
within a larger natural habitat area that is used frequently by animals to facilitate movement
and provide access to necessary resources (e.g., water, food, cover, den sites). The travel
route is generally preferred because it provides the least amount of topographic resistance in
moving from one area to another; it contains adequate food, water, or cover while moving
between habitat areas; and provides a relatively direct link between target habitat areas.
27650002 • 07/2018 |3.4-5_jd.cdr
Exhibit 3.4-5
Jurisdictional Features
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: ESA, July 2018. ESRI Aerial Imagery, 2017.
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• Wildlife Corridor: A piece of habitat, usually linear in nature, that connects two or more habitat
patches that would otherwise be fragmented or isolated from one another. Wildlife corridors
are usually bounded by urban land areas or other areas unsuitable for wildlife. The corridor
generally contains suitable cover, food, or water to support species and facilitate movement
while in the corridor. Larger, landscape-level corridors (often referred to as “habitat or
landscape linkages”) can provide both transitory and resident habitat for a variety of species.
• Wildlife Crossing: A small, narrow area, relatively short in length and generally constricted in
nature, that allows wildlife to pass under or through an obstacle or barrier that otherwise
hinders or prevents movement. Crossings typically are manmade and include culverts,
underpasses, drainage pipes, and tunnels to provide access across or under roads, highways,
pipelines, or other physical obstacles. These are often “choke points” along a movement
corridor.
Wildlife Movement within the Project Site
From a regional perspective, the project site abuts Santiago Oaks Regional Park along the
northeastern most portion of the project site, and is approximately 0.5 mile northwest of Santiago
Creek Recharge Basin. The project site is situated approximately 0.6-mile northeast of El Modena
Open Space, 2.4 miles north-northwest of Peters Canyon Reservoir, 3.8 miles northwest of Irvine
Lake, and 2.0 miles west of the Santa Ana Mountains (Cleveland National Forest). The project site is
not within NCCP/HCP established reserve assembly or wildlife corridors. Santiago Creek runs
through the northern portion of the project site, and merges with the Santa Ana River approximately
7.0 miles southwest of the project site. Because of the past urbanization of the region, large open
space areas in the immediate vicinity of the project site are limited to Santiago Oaks Regional Park,
Santiago Creek Recharge Basin, and El Modena Open Space. The project site is immediately
surrounded by residential development to the north and south, which may deter the movement of
larger mammals that require larger home range areas and dispersal distances or dense vegetative
cover. However, species that are less restricted in movement pathway requirements or are adapted
to urban areas (e.g., raccoon, skunk, coyote, birds) will likely move through the project site.
From east to west, the project site is bordered by Santiago Oaks Regional Park (to the east) and vacant
land, which connects to the Santiago Creek Recharge Basin (to the west). Santiago Creek provides
habitat, which connects Santiago Oaks Regional Park to the Santiago Creek Recharge Basin. Although
there is somewhat limited riparian habitat downstream of the project site associated with the Santiago
Creek Recharge Basin, the portion of Santiago Creek that is found within the project site provides
dense riparian and wetland habitat and thus functions as a wildlife movement corridor which supports
wildlife movement within and through the site. In addition, by providing resources, such as a perennial
water source (for a variety of species, including several fishes), foraging habitat, nesting and den sites,
and cover (for both predator and prey species), the project site provides live-in and movement habitat
for many invertebrate, fish, herptile, avian, and mammal species, including NCCP/HCP identified
species (such as least Bell’s vireo and coyote, both of which were observed on-site).
Although Santiago Creek is channelized and surrounded by development along portions of its extent,
Santiago Creek serves as a corridor for wildlife movement by providing patches of habitat, as well as
a water source, which connect the Santa Ana Mountains to the Santa Ana River, and eventually flows
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out to the Pacific Ocean. Thus, the habitat associated with Santiago Creek within the northern
portion of the project site supports live-in and movement habitat for species on a local scale (i.e.,
some limited live-in habitat for fish, and live-in and at least marginal movement habitat for
amphibian, reptile, bird, and mammal species), and likely functions to facilitate wildlife movement
for a number of species on a regional scale.
Trees
PCR conducted a tree survey in 2012 that indicated that there were 204 trees within the project
development footprint. Common tree species include lemon bottlebrush, eucalyptus, coast live oak,
and willow. Most of the trees (77 percent) were found to be in fair condition, with 9 percent in good
condition, and 13 percent in poor condition. Two trees were found to be dead or nearly dead.
3.4.3 - Regulatory Framework
Federal
Federal Endangered Species Act
The Federal Endangered Species Act (FESA) of 1973 defines an endangered species as “any species
which is in danger of extinction throughout all or a significant portion of its range.” A threatened
species is defined as “any species which is likely to become an endangered species within the
foreseeable future throughout all or a significant portion of its range.” Under provisions of Section
9(a)(1)(B) of the FESA, unless properly permitted, it is unlawful to “take” any listed species. “Take” is
defined in Section 3(18) of FESA: “. . . harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or
collect, or to attempt to engage in any such conduct.” Further, the USFWS, through regulation, has
interpreted the terms “harm” and “harass” to include certain types of habitat modification as forms
of “take.” These interpretations, however, are generally considered and applied on a case-by-case
basis and often vary from species to species. In a case where a property owner seeks permission
from a federal agency for an action which could affect a federally listed plant or animal species, the
property owner and agency are required to consult with USFWS pursuant to Section 7 of the ESA if
there is a federal nexus, or pursuant to Section 10 of the ESA. Section 9(a)(2)(b) of the FESA
addresses the protections afforded to listed plants.
Some of the USFWS offices maintain a database of listed species within their jurisdiction, for example
the Sacramento11 and Carlsbad12 offices. The Carlsbad USFWS Office jurisdiction encompasses the
counties of Los Angeles, Orange, Riverside, San Bernardino, Imperial, and San Diego.
Migratory Bird Treaty Act
The Migratory Bird Treaty Act (MBTA) protects individuals as well as any part, nest, or eggs of any
bird listed as migratory. In practice, federal permits issued for activities that potentially impact
migratory birds typically have conditions that require surveys for nesting birds prior to project
activities which may result in disturbance. In the event nesting is observed, a buffer area with a
specified radius must be established, within which no disturbance or intrusion is allowed until the
young have fledged and left the nest, or it has been determined that the nest has failed. If not
otherwise specified in the permit, the size of the buffer area varies with species and local
circumstances (e.g., presence of busy roads, intervening topography, etc.), and is based on the
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professional judgment of a monitoring biologist. A list of migratory bird species protected under the
MBTA is published by USFWS.
Clean Water Act
Section 404
Section 404 of the Clean Water Act (CWA) regulates the discharge of dredged or fill material into
waters of the United States and authorizes the Secretary of the Army, through the Chief of
Engineers, to issue permits for such actions. Implementing regulations for the CWA define waters of
the United States as “rivers, creeks, streams, and lakes extending to their headwaters and any
associated wetlands.” Wetlands are defined as “areas that are inundated or saturated by surface or
groundwater at a frequency and duration sufficient to support a prevalence of vegetation typically
adapted for life in saturated soil conditions.” The permit review process entails an assessment of
potentially adverse impacts to USACE jurisdictional waters of the United States.
Over the years, the USACE has modified its regulations, typically due to evolving policy or judicial
decisions, through the issuance of Regulatory Guidance Letters, memorandums, or more expansive
instruction guidebooks. These guidance documents help to update and define how jurisdiction is
claimed, and how these waters of the United States will be regulated. The most recent, significant
modification occurred on June 5, 2007, subsequently updated in December 2008, when the USACE
and the U.S. Environmental Protection Agency (EPA) issued a series of guidance documents outlining
the requirements and procedures, effective immediately, to establish jurisdiction under Section 404
of the CWA and the Section 10 of the Rivers and Harbors Act of 1899. These documents are
intended to be used for all jurisdictional delineations and provide specific guidance for the
jurisdictional determination of potentially jurisdictional features affected by the U.S. Supreme Court
rulings in Rapanos v. the United States and Carabell v. the United States 547 U.S. 715 (2006) (jointly
referred to as Rapanos).
The Rapanos case outlines the conditions and criteria used by the USACE to assess and claim
jurisdiction over non-isolated, non-navigable, ephemeral tributaries. Under a plurality ruling, the
Court noted that certain “not relatively permanent” (i.e., ephemeral), non-navigable tributaries must
have a “significant nexus” to downstream traditional navigable waters to be jurisdictional. An
ephemeral tributary has a significant nexus to downstream navigable “waters” when it has “more
than a speculative or an insubstantial effect on the chemical, physical, and/or biological integrity of a
Traditional Navigable Water (TNW).” A significant nexus is established through the consideration of a
variety of hydrologic, geologic and ecological factors specific to the particular drainage feature in
question. For drainage features that do not meet the significant nexus criteria, a significant nexus
determination is provided by the USACE to the EPA for the final determination of federal jurisdiction.
Drainage features that do not meet the significant nexus criteria based on completion of an AJD,
and/or are determined to be isolated pursuant to the SWANCC ruling (see below), may still be
regulated by CDFW under Fish and Game Code Section 1600 or the RWQCB under the Porter-
Cologne Water Quality Act.
On January 15, 2003, the USACE and EPA issued a Joint Memorandum to provide clarifying guidance
regarding the United States Supreme Court ruling in the Solid Waste Agency of Northern Cook County
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v. United States Army Corps of Engineers, No. 99-1178 (January 9, 2001) (“the SWANCC ruling”),
(Federal Register: Vol. 68, No. 10.). This ruling held that the CWA does not give the federal government
regulatory authority over non-navigable, isolated, intrastate waters. As a result of this decision, some
previously regulated depressional areas such as mudflats, sandflats, wetlands, prairie potholes, wet
meadows, playa lakes, natural ponds, and vernal pools, which are not hydrologically connected to
other intra- or inter-state “waters of the United States,” are no longer regulated by the USACE.
Section 401
The mission of the RWQCB is to develop and enforce water quality objectives and implement plans
that will best protect the beneficial uses of the state’s waters, recognizing local differences in
climate, topography, geology, and hydrology. The California RWQCB is responsible for implementing
compliance not only with state codes such as the California Water Code but also some federal acts
such as Section 401 of the CWA. Section 401 of the CWA requires that any applicant for a federal
permit for activities that involve a discharge to waters of the State shall provide the federal
permitting agency with a certification from the state in which the discharge is proposed that states
that the discharge will comply with the applicable provisions of the federal CWA.13 As such, before
the USACE will issue a CWA Section 404 permit, applicants must apply for and receive a Section 401
water quality certification (WQC) from the RWQCB. The RWQCB regulates “discharging waste, or
proposing to discharge waste, within any region that could affect “waters of the State” (Water Code
§ 13260 (a)), pursuant to provisions of the Porter-Cologne Water Quality Control Act which defines
RWQCB jurisdictional “waters of the State” as “any surface water or groundwater, including saline
waters, within the boundaries of the state” (Water Code § 13050).
With the exception of isolated waters and wetlands, most discharges of fill to waters of the State are
also subject to a CWA Section 404 permit. If a CWA Section 404 permit is not required for the
project, the RWQCB may still require issuance of Waste Discharge Requirements (WDR) under the
Porter-Cologne Water Quality Control Act. The RWQCB may regulate isolated waters that are not
under jurisdiction of the USACE through issuance of WDR’s. However, projects that obtain a Section
401 WQC are simultaneously enrolled in a statewide general WDR. Processing of Section 401 WQC’s
generally requires submittal of 1) a construction Storm Water Pollution Prevention Plan (SWPPP), 2)
a final water quality technical report that demonstrates that post-construction stormwater Best
Management Practices (BMPs) comply with the local design standards for municipal storm drain
permits (MS4 permits) implemented by the State Water Resources Control Board effective January 1,
2011, and 3) a conceptual Habitat Mitigation and Monitoring Plan to compensate for permanent
impacts to RWQCB waters, if any. In addition to submittal of a draft California Environmental Quality
Act (CEQA) document, a WQC application typically requires a discussion of avoidance and
minimization of impacts to RWQCB jurisdictional resources, and efforts to protect beneficial uses as
defined by the local RWQCB basin plan for the project. The RWQCB cannot issue a Section 401 WQC
until the project CEQA document is certified by the lead agency.
State
California Endangered Species Act
The State of California enacted the California Endangered Species Act (CESA) in 1984. CESA is similar
to the FESA but pertains to State-listed endangered and threatened species. CESA requires state
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agencies to consult with CDFW when preparing CEQA documents. The purpose is to ensure that the
state lead agency actions do not jeopardize the continued existence of a listed species or result in
the destruction, or adverse modification of habitat essential to the continued existence of those
species, if there are reasonable and prudent alternatives available (Fish and Game Code §2080).
CESA directs agencies to consult with CDFW on projects or actions that could affect listed species,
directs CDFW to determine whether jeopardy would occur and allows CDFW to identify “reasonable
and prudent alternatives” to the project consistent with conserving the species. CESA allows CDFW
to authorize exceptions to the State’s prohibition against take of a listed species if the “take” of a
listed species is incidental to carrying out an otherwise lawful project that has been approved under
CEQA (Fish & Game Code § 2081).
California Department of Fish and Game Codes
Fully protected fish species are protected under Section 5515; fully protected amphibian and reptile
species are protected under Section 5050; fully protected bird species are protected under Section
3511; and fully protected mammal species are protected under Section 4700. The California Fish
and Game Code defines take as “hunt, pursue, catch, capture, or kill, or attempt to hunt, pursue,
catch, capture, or kill.” Except for take related to scientific research, all take of fully protected
species is prohibited. Section 3503 of the California Fish and Game Code prohibits the killing of birds
or the destruction of bird nests. Section 3503.5 prohibits the killing of raptor species and the
destruction of raptor nests. Sections 2062 and 2067 define endangered and threatened species.
California Department of Fish and Wildlife Species of Concern
In addition to formal listing under FESA and CESA, species receive additional consideration by CDFW
and local lead agencies during the CEQA process. Species that may be considered for review are
included on a list of “Species of Special Concern,” developed by the CDFW. It tracks species in
California whose numbers, reproductive success, or habitat may be threatened. In addition to Species
of Special Concern, the CDFW identifies animals that are tracked by the CNDDB, but warrant no federal
interest and no legal protection. These species are identified as California Special Animals.
Porter-Cologne Water Quality Control Act
CDFW is a trustee agency that has jurisdiction under Section 1600, et seq. of the California Fish and
Game Code. Under Sections 1602 and 1603, a private party must notify CDFW if a proposed project
will “substantially divert or obstruct the natural flow or substantially change the bed, channel, or
bank of any river, stream, or lake designated by the department, or use any material from the
streambeds…except when the department has been notified pursuant to Section 1601.”
Additionally, CDFW may assert jurisdiction over native riparian habitat adjacent to aquatic features,
including native trees over 4 inches in diameter at breast height (DBH). If an existing fish or wildlife
resource may be substantially adversely affected by the activity, CDFW may propose reasonable
measures that will allow protection of those resources. If these measures are agreeable to the
parties involved, they may enter into an agreement with CDFW identifying the approved activities
and associated mitigation measures.
Section 13260(a) of the Porter-Cologne Water Quality Control Act (contained in the California Water
Code) requires any person discharging waste or proposing to discharge waste, other than to a
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community sewer system, within any region that could affect the quality of the waters of the State
(all surface and subsurface waters) to file a report of waste discharge. The discharge of dredged or
fill material may constitute a discharge of waste that could affect the quality of waters of the State.
All of the wetlands and waterways in the project site are waters of the State, which are protected
under this act.
Historically, California relied on its authority under Section 401 of the CWA to regulate discharges of
dredged or fill material to California waters. That section requires an applicant to obtain “water
quality certification” from the State Water Resources Control Board (SWRCB) through its RWQCB to
ensure compliance with state water quality standards before certain federal licenses or permits may
be issued. The permits subject to Section 401 include permits for the discharge of dredged or fill
materials (CWA Section 404 permits) issued by the USACE. Waste discharge requirements under the
Porter-Cologne Water Quality Control Act were typically waived for projects that required
certification. With the recent changes that limited the jurisdiction of wetlands under the CWA, the
SWRCB has needed to rely on the report of waste discharge process.
California Native Plant Society
The CNPS maintains a rank of plant species native to California that has low population numbers,
limited distribution, or are otherwise threatened with extinction. This information is published in
the Inventory of Rare and Endangered Vascular Plants of California. Potential impacts to populations
of CNPS ranked plants receive consideration under CEQA review. The following identifies the
definitions of the CNPS ranks:
• Rank 1A: Plants presumed Extirpated in California and either rare or extinct elsewhere
• Rank 1B: Plants Rare, Threatened, or Endangered in California and elsewhere
• Rank 2A: Plants presumed Extirpated in California, but common elsewhere
• Rank 2B: Plants Rare, Threatened, or Endangered in California, but more numerous elsewhere
• Rank 3: Plants about which we need more information—A Review List
• Rank 4: Plants of limited distribution—A Watch List
All plants appearing on CNPS Rank 1 or 2 are considered to meet State CEQA Guidelines Section
15380 criteria. While only some of the plants ranked 3 and 4 meet the definitions of threatened or
endangered species, the CNPS recommends that all Rank 3 and Rank 4 plants be evaluated for
consideration under CEQA.
Regional
County of Orange (Central/Coastal) Natural Community Conservation Plan/Habitat
Conservation Plan
The project site is within the central subregion of the County of Orange (Central/Coastal) NCCP/HCP,
as shown in Exhibit 3.4-6. The NCCP/HCP was reviewed and approved by the USFWS and CDFW in
1996 to address protection and management of coastal sage scrub habitat and coastal sage scrub-
obligate species, as well as other covered habitats and species, and mitigate anticipated impacts on
those habitats and species on a programmatic, subregional level rather than on a project-by-project,
single-species basis. A habitat reserve in excess of 37,000 acres was established for the protection of
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coastal sage scrub, other upland habitats, the coastal California gnatcatcher, and the other primarily
coastal sage scrub-dependent species identified in the NCCP/HCP. Specifically, the NCCP/HCP, the
USFWS, and the CDFW authorized take of 39 identified species of plants and wildlife (including
covered and conditionally covered species). Further, the NCCP/HCP contains requirements for
adaptive management, interim management, and funding management for the reserve as well as
procedures and minimization measures related to the take of identified species and habitat. Thus,
the NCCP/HCP provides for the protection and management of a broad range of plant and wildlife
populations while providing certainty to the public and affected landowners with respect to the
location of future development and open space in the subregion.
The NCCP/HCP provides for the protection of a number of plant and animal species, referred to as
Target Species and Identified Species. There are also identified NCCP/HCP species that have
conditional regulatory coverage under the NCCP/HCP referred to as conditionally covered Identified
Species. The conservation and management of these species is provided for under the NCCP. A
development activity authorized under the NCCP/HCP necessarily includes protection of these species
and also means that no further action under CESA or FESA is required for the approved activity should
any of the Target or Identified Species be subsequently listed as endangered or threatened under
either of these Acts. As a consequence, Target and Identified Species are considered sensitive.
Local
City of Orange
General Plan
The City of Orange General Plan sets forth the following goals and policies relevant to biological
resources:
• Goal 4.0: Conserve and protect wildlife habitat, plant and animal species of concern, and
general biodiversity.
• Policy 4.1: Preserve and protect native and habitat-supporting plant resources throughout the
City.
• Policy 4.2: Work with agencies, including the Orange County Flood Control District, to identify
opportunities to enhance the natural qualities of Santiago Creek to protect habitat and
reintroduce native plants and animals.
• Policy 4.3: Reduce the impact of urban development on important ecological and biological
resources.
• Policy 4.4: Repair or improve ecological and biological conditions in the urban and natural
environments when reviewing proposals for site development and redevelopment, as well as
public improvements.
• Policy 4.5: Protect the Santiago Creek and Santa Ana River corridors from premature
urbanization to ensure the continued availability of important sand and gravel, flood control,
water recharge, biological, and open space resources.
Tree Preservation Ordinance
Orange Municipal Code Section 12.32.110 sets forth the Tree Preservation Ordinance, which requires
applicants for subdivision maps or grading permits to identify the location of trees proposed for
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removal. If the City of Orange approves the subdivision map, or grading permit, City staff have the
discretion to relieve the applicant of any necessity to apply for a separate permit for tree removal.
City staff have the discretion to impose conditions on tree removal activities.
3.4.4 - Methodology
Descriptions and analysis in this section are based on the Biological Resources Assessment,
Jurisdictional Delineation, and Tree Survey, which were all prepared by ESA and PCR. The reports are
provided in Appendix G. Each report is summarized as follows:
Biological Resources Assessment
ESA (formerly PCR) prepared a Biological Resources Assessment that evaluated the potential
presence of sensitive biological resources. The assessment was based on field reconnaissance and
appropriate reference materials.
PCR first reviewed relevant literature on the biological resources of the project site and surrounding
vicinity. CNDDB, a CDFW species account database, was reviewed for all pertinent information
regarding the localities of known observations of sensitive species and habitats in the vicinity of the
project site. The vicinity of the project site includes the La Habra, Yorba Linda, and Prado Dam,
Anaheim, Orange, Black Star Canyon, Newport Beach, Tustin, and El Toro topographic quadrangles.
Federal register listings, protocols, and species data provided by USFWS and CDFW were reviewed in
conjunction with anticipated Federally and State listed species potentially occurring within the
vicinity. In addition, numerous regional flora and fauna field guides were utilized to assist in the
identification of species and suitable habitats. Documentation of previous assessments and surveys
conducted on the project site was also reviewed.
A general biological survey and vegetation mapping was conducted by PCR biologists Steve Nelson
and Maile Tanaka on March 24, 2010 to document natural communities and existing conditions. The
vegetation mapping was updated on March 16 and April 21, 2017 by ESA biologists Maile Tanaka,
Lauren Singleton, and Amy Lee. During the course of this survey, an inventory of all plant and
wildlife species observed was compiled. Survey coverage of the entire project site, with special
attention to sensitive habitats or those areas potentially supporting sensitive flora or fauna, was
ensured using aerial photographs.
Natural communities were mapped directly in the field utilizing a 250-scale (1” = 250’) aerial
photograph. Natural community names and descriptions follow the Orange County Habitat
Classification System (OCHCS) (Gray and Bramlet 1992). After completing the fieldwork, the natural
community polygons were digitized using Geographic Information System (GIS) technology to
calculate acreages.
All plant species observed during surveys were either identified in the field or collected and later
identified using taxonomic keys. Plant taxonomy follows Hickman (1993). Common plant names,
when not available from Hickman, were taken from Munz (1974) and McAuley (1996). Because
common names vary significantly between references, scientific names are included upon initial
mention of each species; common names consistent throughout the report are employed thereafter.
27650002 • 07/2018 | 3.4-6_nccp.cdr CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Exhibit 3.4-6
Orange County Natural Community
Conservation Plan/Habitat Conservation Plan
Source: ESA, July 2018. ESRI Aerial Imagery, 2017.
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All wildlife species observed within the project site, as well as diagnostic sign (call, tracks, nests, scat,
remains, or other sign), were recorded in field notes. Binoculars and regional field guides were
utilized for the identification of wildlife, as necessary. Wildlife taxonomy follows Stebbins (2003) for
amphibians and reptiles, the American Ornithologists’ Union (1998) for birds, and Jameson and
Peeters (1988) for mammals. Scientific names are used during the first mention of a species;
common names only are used in the remainder of the text.
Jurisdictional Delineation
A jurisdictional delineation of all existing on-site drainage features was conducted by PCR
regulatory/environmental scientist Amir Morales and biologist Maile Tanaka on April 28 and May 23,
2011 and by Amir Morales and PCR biologist Ezekiel Cooley on September 26, 2012 to assess the
extent of “waters of the United States”/“waters of the State” or wetlands under the jurisdiction of
the USACE/RWQCB, or streambed and associated riparian habitat under the jurisdiction of the CDFW
Tree Survey
In accordance with the City of Orange Municipal Code, Title 12 Streets and Sidewalks and Public Places,
Chapter 12.32 Tree Preservation (Tree Preservation Ordinance), a tree survey was conducted by PCR
biologists Maile Tanaka and Zeke Cooley and PCR affiliated biologists Joanna Nigro and Gerhard Bombe
on April 9, 2010; by Joanna Nigro and Maile Tanaka on March 30, 2011; by Joanna Nigro on June 13,
2011; and by PCR biologists Bob Huttar, Ezekiel Cooley, and Maile Tanaka on September 26, 2012. Ms.
Nigro, Mr. Bombe, and Mr. Huttar are International Society of Arboriculture (ISA) Certified Arborists.
The Tree Preservation Ordinance protects all trees, regardless of species, that measure a minimum
of 10.5 inches in circumference, measured at a point 24 inches above the ground. The tree survey
consisted of walking the portion of the project site within the project development footprint (tree
survey area), which comprised approximately 71.10 acres on-site, in order to locate all regulated
trees meeting the size requirements as defined in the Tree Preservation Ordinance. PCR biologists
visually assessed the size of each tree at 24 inches above ground to determine if they were subject
to the requirements of the City of Orange Tree Preservation Ordinance; however, the DBH of each
tree was recorded at 54 inches above ground in accordance with the ISA standard. Each tree was
tagged and numbered then assessed according to ISA standards to include the DBH and height.
Trees that could not be tagged either because they were inaccessible or because of duplicate tree
numbering (trees of the same species close to each other that are individually numbered with sub-
letters) were noted. Additionally, overall health as well as aesthetics and balance were given a rating
based on the tree’s structure and presence of disease. The location of each tree was collected in the
field using a Global Positioning System handheld unit. Following data collection, the digital
information was uploaded and incorporated within PCR’s project-specific Geographic Information
System database to provide a figure with specific tree locations within the project site.
3.4.5 - Thresholds of Significance
According to Appendix G, Environmental Checklist, of the CEQA Guidelines, biological resources
impacts resulting from the implementation of the proposed project would be considered significant
if the project would:
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1. Have a substantial adverse effect, either directly or through habitat modifications, on any
species identified as a candidate, sensitive, or special status species in local or regional plans,
policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and
Wildlife Service?
2. Have a substantial adverse effect on any riparian habitat or other sensitive natural
community identified in local or regional plans, policies, and regulations or by the California
Department of Fish and Game or U.S. Fish and Wildlife Service?
3. Have a substantial adverse effect on federally protected wetlands as defined by Section 404
of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.)
through direct removal, filling, hydrological interruption, or other means?
4. Interfere substantially with the movement of any native resident or migratory fish or wildlife
species or with established native resident or migratory wildlife corridors, or impede the use
of wildlife nursery sites?
5. Conflict with any local policies or ordinances protecting biological resources, such as a tree
preservation policy or ordinance?
6. Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community
Conservation Plan, or other approved local, regional, or state habitat conservation plan?
3.4.6 - Project Impacts and Mitigation Measures
This section discusses potential impacts associated with the development of the project and
provides mitigation measures where appropriate.
Special-status Plant Species
Impact BIO-1: The proposed project would not have a substantial adverse effect on special status
plant species.
Impact Analysis
Implementation of the proposed project would result in the direct removal of existing vegetation.
Two sensitive plant species were observed within the project site during focused sensitive plant
surveys. These species are the Southern California black walnut and southern tarplant.
Southern Tarplant
Based on the 2017 special-status plant survey, it is estimated that less than 100 southern tarplants
occur on-site, and are located within the project’s development footprint (Exhibit 3.4-7). Impacts to
less than 100 southern tarplants are not expected to threaten regional populations of this species, and
in addition, the Conservation Measure applied to preserve southern tarplant by salvaging seed was
already implemented in order to prevent loss of this local population due to current on-site activities
related to existing backfilling and material recycling operations, which are not related to the proposed
project. As such, impacts to southern tarplant associated with the implementation of the proposed
project are considered less than significant and no mitigation measures would be required.
I
27650002 • 07/2018 |3.4-7_plant_impacts.cdr
Exhibit 3.4-7
Impacts to Special-Status Plant Species
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: ESA, July 2018. ESRI Aerial Imagery, 2017.
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Southern California Black Walnut
A total of 71 Southern California black walnuts occur within the southern cottonwood-willow
riparian forest and non-native herbaceous cover communities within the northwestern portion of
the project site. This area will be avoided by the proposed project; however, one walnut may
potentially be impacted by the proposed project, as shown in Exhibit 3.4-7. However, the loss of one
walnut tree, which is a CNPS Rank 4.2 species, from a population of 70 Southern California black
walnut trees that will be preserved and continue to reproduce and spread their seeds, is not
considered a significant impact. Therefore, impacts to the Southern California black walnuts are less
than significant and no mitigation measures would be required.
In addition, there are preliminary trails and their alignments for the specific plan that are conceptual in
nature, and final design will be undertaken at some future date. More specifically, with the exception
of Trail A (in Planning Area B paralleling East Santiago Canyon Road) and Trail F (in Planning Area B
north of Planning Area C and with multiple uses as recreation trail, fuel modification maintenance and
emergency vehicle access) final trail design, alignment and points of connectivity with existing and
future adjacent trails will be accomplished through a collaborative effort involving the City of Orange,
the Orange Park Acres Trail Committee, the Santiago Creek Greenway Alliance, Orange County Parks,
and representatives of the Applicant. As outlined in the Preface of this document, approximately
$4,100,000.00 in landscape and other improvements for the Santiago Creek Greenway will be funded,
as part of the proposed project. Said improvements are to be completed or funded prior to the 60th
Certificate of Occupancy.
In order to avoid or minimize trail impacts to sensitive biological resources, the following design
features are recommended for incorporation prior to final design of the trails:
1. Trail D should be designed to avoid or minimize impacts to coastal sage scrub and other
native habitats, and should be designed to traverse through vegetation communities that
already exhibit disturbance. This trail should be a seasonal trail that is closed, or partially
closed, adjacent to habitat that may support special-status birds during breeding season.
Trail C and Trail E should utilize existing trail alignments and/or areas that already exhibit
disturbance to the extent possible.
2. Educational kiosks are recommended to inform the public about the ecology, biological
resources, and special-status species of the area, as well as emphasizing the importance of
staying on designated trails, respecting seasonal trail closures, and the community’s
responsibility in protecting the natural resources.
3. Future environmental analysis will be needed at the time trail design is completed and trail
implementation is proposed.
With the adoption of the recommended design features, potentially significant impacts will be
avoided or minimized.
Level of Significance Before Mitigation
Less than significant impact.
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Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
Special-status Wildlife Species
Impact BIO-2: The proposed project may have a substantial adverse effect on special status
wildlife species.
Impact Analysis
Implementation of the proposed project would result in the direct removal of existing habitat for
wildlife species. Biological surveys for the project site indicated that sensitive wildlife species were
observed or have at least a moderate potential to occur within the project site. Observed species
include white-tailed kite, yellow-breasted chat, coastal California gnatcatcher, least Bell’s vireo,
willow flycatcher, and coyote. Species with potential to occur on-site include arboreal salamander,
coast range newt, coast patch-nosed snake, red-diamond rattlesnake, coast horned lizard, Coronado
skink, orange-throated whiptail, western mastiff bat, San Diego black-tailed jackrabbit, coastal
(western) whiptail, sharp-shinned hawk, rough-legged hawk, red-shouldered hawk, northern harrier,
burrowing owl, Southern California rufous-crowned sparrow, prairie falcon, American peregrine
falcon, loggerhead shrike, long-eared owl, southwestern willow flycatcher, pallid bat, northwestern
San Diego pocket mouse, San Diego desert woodrat, and gray fox. Focused surveys were conducted
for arroyo toad, burrowing owl, coastal California gnatcatcher, least Bell’s vireo, and southwestern
willow flycatcher.
With the exception of coast patch-nosed snake, coast range newt, white-tailed kite, prairie falcon,
burrowing owl, least Bell’s vireo, willow flycatcher, loggerhead shrike, yellow-breasted chat, long-
eared owl, western mastiff bat, pallid bat, San Diego black-tailed jackrabbit, and northwestern San
Diego pocket mouse, all the potentially present or observed species are covered species under the
NCCP/HCP, and with the implementation of the NCCP/HCP, Target Species and Identified Species are
conserved within the region in which the Central/Coastal Subregion NCCP/HCP is located. Prairie
falcon and least Bell’s vireo are conditionally covered and are discussed in further detail below.
Willow flycatcher is also discussed in further detail. Coast patch-nosed snake, coast range newt,
loggerhead shrike, yellow-breasted chat, long-eared owl, western mastiff bat, pallid bat, San Diego
black-tailed jackrabbit, and northwestern San Diego pocket mouse are considered Species of Special
Concern by the CDFW and do not carry a federal or state listing as threatened or endangered. The
project is avoiding impacts to coastal sage scrub habitats, and the proposed project was designed to
minimize impacts to Santiago Creek and the northern portion of the project site where native
habitat occurs. The majority of the suitable habitat within Santiago Creek and northern portion of
the project site, which has potential to support special-status species (i.e., southern cottonwood
willow riparian forest, coastal sage scrub, and other native habitats), will be avoided. Furthermore,
the availability of contiguous habitat within the project site will continue to provide resources and
foraging habitat for these species, if they are present. Thus, the loss of individuals as a result of the
proposed project would not be expected to reduce regional population numbers, and impacts to
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these special-status wildlife species are considered adverse but less than significant and no
mitigation measures would be required for the non-ESA listed covered species.
Special-status wildlife species with potential to occur or which were observed on-site that are
covered or conditionally covered by the NCCP/HCP include the arroyo toad, burrowing owl, coastal
California gnatcatcher, prairie falcon, least Bell’s vireo, and southwestern willow flycatcher. A
discussion of NCCP/HCP covered and conditionally covered species follows.
Arroyo Toad (Federally Endangered, Species of Special Concern, NCCP/HCP Conditionally Covered)
The arroyo toad is a conditionally covered species and requires additional mitigation measures be
satisfied under the NCCP/HCP. The on-site habitat for this species is marginal, and no arroyo toad
were observed on-site during focused surveys conducted by MBA in 2008 and PCR in 2010.
Therefore, no impacts to the arroyo toad would occur and no mitigation measures would be
required.
Burrowing Owl (Species of Special Concern)
The burrowing owl is a Species of Special Concern. Focused surveys were conducted for this species
by PCR in 2012, 2013, 2014, and ESA in 2017. No burrowing owls were observed during focused
surveys and they are not expected to occur within the project site. Therefore, no impacts to the
burrowing owl would occur and no mitigation measures would be required.
Coastal California Gnatcatcher (Federally Threatened, NCCP/HCP Identified Species)
The coastal California gnatcatcher is a covered species under the NCCP/HCP. No coastal California
gnatcatcher were observed on-site during focused surveys conducted by MBA in 2008 and PCR in
2010, 2012, 2013, 2015, and ESA in 2017. However, during focused surveys conducted in 2014, a
coastal California gnatcatcher pair was observed within the western portion of the project site on
March 27, 2014. The pair did not appear to be engaged in any definite breeding-related activity and
was not observed within the project site on subsequent surveys conducted during that season.
However, what was believed to be the same pair was later observed off-site on May 2, 2014 on the
west side of Cannon Street in a more extensive area of poor quality coastal sage scrub habitat.
In addition, an incidental sighting of one dispersing coastal California gnatcatcher was observed
outside of the breeding season on August 3, 2010, and additional incidental sightings of two
separate coastal California gnatcatcher individuals were observed on both June 9 and 27, 2017. The
habitat where all of these incidental observations were seen was disturbed/non-native herbaceous
cover or within disturbed areas perched on mule fat, and not coastal sage scrub. Because of the
locations were these incidental sightings occurred, and since results of the focused breeding season
surveys were negative in the years when each of these incidental sightings were made, it is believed
these incidental sightings were likely juveniles dispersing through the project site from suitable
habitat areas in the vicinity of the project site.
A number of coastal California gnatcatcher occurrences are documented in the USFWS occurrences
database within the vicinity of the project site; these include 59 occurrences within a 1-mile radius.
Thus, it is likely that the coastal California gnatcatchers observed on-site are foraging or dispersing
through the project site from adjacent areas, particularly off-site areas downstream of the project site
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to the west. However, no breeding pairs were found within the project site during the 2008, 2010,
2012, 2013, 2014, 2015, or 2017 focused breeding season surveys. The coastal California gnatcatcher
is a covered species with implementation of the NCCP/HCP, and although coastal California gnatcatcher
individuals have been observed on-site (likely foraging or dispersing through the project site), no
breeding pairs have been found within the project site during focused breeding season surveys, and
regardless, the proposed project will not impact any coastal sage scrub habitats. Furthermore, the
proposed project will avoid the majority of Santiago Creek and its associated native riparian and
upland habitats. Approximately 38 acres of the project site will be avoided, including 14.06 acres of
sensitive plant communities, which includes 0.57 acre of coastal sage scrub (100 percent of extant on-
site habitat) and 12.60 acres of southern cottonwood-willow riparian forest, within and/or adjacent to
Santiago Creek. Although the incidental sightings of coastal California gnatcatcher were in
disturbed/non-native herbaceous cover or within disturbed areas perched on mule fat, and not coastal
sage scrub, if these areas were used for foraging and/or dispersal, the areas of Santiago Creek and
native habitats that will be avoided by the proposed project north of the drainage will continue to
provide higher quality habitat (including coastal sage scrub dominated by California sagebrush), which
provide resources for foraging and connectivity to other open space areas for dispersal (e.g., to
Santiago Oaks Regional Park to the east). As such, no significant impacts will occur to the coastal
California gnatcatcher and no mitigation measures would be required.
In addition, the project site is not within critical habitat for this species; the nearest final critical habitat
for coastal California gnatcatcher is 0.3-mile south of the project site. Therefore, no impacts will occur
to the coastal California gnatcatcher critical habitat and no mitigation measures would be required.
Prairie Falcon (Species of Special Concern, NCCP/HCP Conditionally Covered)
The prairie falcon is a conditionally covered species and requires additional mitigation measures be
satisfied under the NCCP/HCP. However, this species is only expected to utilize the project site for
foraging. It is not anticipated that direct impacts to nesting sites would occur because of the lack of
suitable nesting habitat within the project site. No active nests or nesting habitat for prairie falcon
were identified within the project site or within one-half mile of the project site. The project site is
surrounded by residential development and no known suitable nesting habitat (i.e., sheltered ledge
of a cliff, bluff, or rock outcrop) exists within a 0.5-mile radius of the project site. Therefore, impacts
to the prairie falcon foraging habitat would be considered less than significant and no mitigation
measures would be required.
Least Bell’s Vireo (Federally and State Endangered, NCCP/HCP Conditionally Covered)
The least Bell’s vireo is a conditionally covered species under the NCCP/HCP. The least Bell’s vireo
was previously observed on-site by MBA in 2008, PCR in 2010, and ESA in 2017. The proposed
project would impact habitat supporting the least Bell’s vireo. A total of 0.10 acre of permanent
impacts will occur to an isolated patch of southern cottonwood-willow riparian forest on-site, and
0.04 acre of permanent impacts and 0.05 acre of temporary impacts will occur for the installation of
an on-site storm drain outlet; refer to Exhibit 3.4-8.
27650002 • 07/2018 |3.4-8_wildlife_impacts.cdr
Exhibit 3.4-8
Impacts to Special-Status Wildlife Species
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: ESA, July 2018. ESRI Aerial Imagery, 2017.
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Nine project design features serve to avoid or minimize impacts on the least Bell’s vireo, including:
• The proposed project will permanently retain approximately 38 acres of open space located
on both sides of Santiago Creek and bordered on the north by Mabury Avenue.
• The majority of the southern cottonwood-willow riparian forest within the project site will be
avoided (12.60 acres), with the exception of 0.10 acre of permanent impacts that will occur to
an isolated patch of southern cottonwood-willow riparian forest on-site, 0.04 acre of
permanent impact, and 0.05 acre of temporary impact from the installation of an on-site
storm drain outlet.
• The proposed project will avoid the majority of Santiago Creek and its associated native
riparian and upland habitats. Approximately 38 acres of the project site will be avoided,
including 14.06 acres of sensitive plant communities, which includes 0.57 acre of coastal sage
scrub, and 12.60 acres of southern cottonwood-willow riparian forest within and/or adjacent
to Santiago Creek.
• The proposed project will provide a 150-foot limited use (landscaping and fuel modification)
time sensitive (breeding season March 15 through September 15) setback area adjacent to
the southern cottonwood-willow riparian forest within Santiago Creek, which provides habitat
for the least Bell’s vireo.
• The proposed project will provide select landscaping, including native species, within the 150-
foot limited use setback area (to the south of Santiago Creek) that is compatible with the
adjacent open space area, its habitat, and is considerate of the fire protection (fuel modification)
zone (refer to Exhibit 3.4-8).
• The proposed project establishes development standards in the Specific Plan to reduce
sensory stimuli (e.g., noise, light), unnatural predators (e.g., domestic cats and other non-
native animals), and competitors (e.g., exotic plants, non-native animals).
• Prior to building permit issuance, the proposed project will remove the existing fence on
Orange County Flood Control District property.
• The proposed project will restrict grading and/or construction activities within the 150-foot
limited use setback area during the least Bell’s vireo breeding season; refer to Exhibit 3.4-8.
• The proposed project will limit uses within the 150-foot limited use setback area to those as
uses identified in the Specific Plan.
However, the least Bell’s vireo is a conditionally covered species under the NCCP/HCP.19. Any
potential impacts to the least Bell’s vireo would be considered potentially significant. Mitigation
Measures BIO-2a through BIO-2c are proposed to reduce impacts to a less than significant level.
Southwestern Willow Flycatcher (Federally and State Endangered, NCCP/HCP Conditionally Covered)
The southwestern willow flycatcher is a conditionally covered species and requires additional
mitigation measures be satisfied under the NCCP/HCP. No southwestern willow flycatchers were
observed on-site during focused surveys conducted by MBA in 2008 and PCR in 2010, 2012, 2013,
2014, and 2015, and ESA in 2017. Therefore, no impacts to the southwestern willow flycatcher
would occur and no mitigation measures would be required.
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Willow Flycatcher (State Endangered)
Willow flycatchers are listed as State Endangered and were observed during the 2012 survey. Two
willow flycatchers were observed within the black willow scrub/ruderal community that borders the
fallow field in the eastern portion of the project site. The habitat that these willow flycatchers were
observed within is considered unsuitable as potential nesting habitat; therefore, it is assumed that
both birds were migrants passing through the area, and are not the southwestern willow flycatcher
subspecies. In addition, one willow flycatcher was observed within southern cottonwood-willow
riparian forest within the north central portion of the project site. The habitat that this willow
flycatcher was observed in is considered suitable for nesting; however, no breeding willow
flycatchers were observed during the focused surveys. The proposed project would impact habitat
suitable to support the willow flycatcher.
A total of 0.20 acre of permanent impacts will occur to non-native herbaceous cover/black willow scrub,
and a total of 0.10 acre of permanent impacts will occur to an isolated patch of southern cottonwood-
willow riparian forest on-site, as well as 0.04 acre of permanent impacts and 0.05 acre of temporary
impacts will occur to southern cottonwood-willow riparian forest for the installation of an on-site storm
drain outlet. However, because willow flycatchers are not expected to breed within the off-site area, no
direct impacts would occur to this species and no mitigation measures would be required. Significant
impacts to foraging habitat for this species are not anticipated, as discussed below.
Although the black willow scrub/ruderal will be permanently removed, this isolated stand of willows
provides only a small, limited amount of foraging habitat for this species. The riparian habitat within
Santiago Creek that will be avoided by the proposed project will still be available to provide a greater
area of contiguous habitat for foraging opportunities.
For the southern cottonwood-willow riparian forest that will be impacted with the installation of a
storm drain outlet, temporary impacts will be restored to pre-project conditions. The 0.10 acre of
permanent impacts for an isolated patch of southern cottonwood willow riparian forest on-site, and
0.04 acre of permanent impacts where the on-site storm drain outlet will be installed will be
mitigated for at an on- and/or off-site location. Additionally, the storm drain outlet structures are
not expected to exclude continued use of the surrounding habitat for foraging should willow
flycatcher occur within these areas.
Thus, impacts to potential willow flycatcher foraging habitat are not expected to threaten regional
populations of this species and would be considered less than significant, and no mitigation
measures would be required.
White-tailed Kite (Fully Protected)
White-tailed kite was observed within the on-site portion of the project site during 2008 surveys. In
addition, this species has the potential to breed within the project site. Any potential impacts to the
white-tailed kite would be considered potentially significant. Therefore, mitigation to avoid any
nesting birds during the breeding season would be required in compliance with the California Fish
and Game Code (Sections 3503.5 and 3511) and Migratory Bird Treaty Act (16 U.S.C. 703, et seq. [see
Mitigation Measure BIO-2d]).
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In addition, there are preliminary trails and their alignments for the specific plan that are conceptual in
nature, and final design will be undertaken at some future date. As indicated previously, with the
exception of Trail A (in Planning Area B paralleling East Santiago Canyon Road) and Trail E (in Planning
Area B north of Planning Area C and with multiple uses as recreation trail, fuel modification
maintenance, and emergency vehicle access) final trail design, alignment, and points of connectivity
with existing and future adjacent trails will be accomplished through a collaborative effort involving
the City of Orange, the Orange Park Acres Trail Committee, the Santiago Creek Greenway Alliance,
Orange County Parks, and representatives of the Applicant. As outlined in the Preface of this
document, approximately $4,100,000.00 in landscape and other improvements for the Santiago
Creek Greenway will be funded as part of the proposed project. Said Improvements are to be
completed or funded prior to the 60th Certificate of Occupancy.
In order to avoid or minimize trail impacts to sensitive biological resources, design features (as
outlined on page 3.4-35 above) are recommended for incorporation prior to final design of the
trails. With the adoption of the recommended design features, potentially significant impacts will
be avoided or minimized.
Level of Significance Before Mitigation
Potentially significant impact.
Mitigation Measures
MM BIO-2a Prior to the issuance of any grading permit for areas supporting least Bell’s vireo
habitat (such as southern cottonwood-willow riparian forest), the project Applicant
shall obtain federal and state take authorizations via regulatory permits (such as a
CWA Section 404 permit issued by the USACE), which will require that the USFWS be
consulted as provided for by Section 7 of the FESA (for the federally listed least Bell’s
vireo). The federal regulatory permits (such as CWA Section 404 permit issued by
the USACE) provide a “federal nexus” by which Section 7 consultation can occur.
This statute imposes the obligation on federal agencies to ensure that their actions
(such as issuing federal CWA permits for this project) are not likely to jeopardize the
continued existence of a listed species or destroy or adversely modify its designated
critical habitat. This obligation is enforced through the procedural requirement that
agencies such as the United States Army Corps of Engineers initiate consultation
with the USFWS on any actions that may affect a threatened or endangered species.
During the FESA Section 7 consultation anticipated for this project, the USFWS will
gather all relevant information concerning the proposed project and the potential
project-related impacts on the least Bell’s vireo (i.e., the project Applicant will
submit a species-specific Biological Assessment), prepare its opinion with respect to
whether the project is likely to jeopardize the continued existence of the species
(i.e., the USFWS will issue a Biological Opinion), and recommend
mitigation/conservation measures where appropriate. Additionally, the need for
State regulatory permits (i.e., Fish and Game Code Section 1602 Streambed
Alteration Agreement issued by the CDFW) will require a Consistency Determination
from the CDFW for the State-listed least Bell’s vireo under CESA.
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In addition, the following BMPs will ensure that indirect impacts will not occur to the
least Bell’s vireo within 300 feet of occupied habitat as monitored by a certified
biologist:
1. Construction limits in and around least Bell’s vireo potential habitat shall be
delineated with flags and fencing prior to the initiation of any grading or
construction activities.
2. Prior to grading and construction a training program shall be developed and
implemented to inform all workers on the project about listed species, sensitive
habitats, and the importance of complying with avoidance and minimization
measures.
3. All construction work shall occur during the daylight hours. The construction
contractor shall limit all construction-related activities that would result in high
noise levels according to the construction hours determined by the City of Orange.
4. During all excavation and grading on-site, the construction contractors shall equip
all construction equipment, fixed or mobile, with properly operating and
maintained mufflers, consistent with manufacturers’ standards to reduce
construction equipment noise to the maximum extent possible. The construction
contractor shall place all stationary construction equipment so that emitted noise
is directed away from sensitive receptors (i.e., least Bell’s vireo territory within
Santiago Creek) nearest the project site.
5. The construction contractor shall stage equipment in areas that will create the
greatest distance between construction-related noise sources and noise sensitive
receptors nearest the project site during all project construction.
6. Noise from construction activities shall be limited to the extent possible through
the maximum use of technology available to reduce construction equipment
noise. Project-generated noise, both during construction and after the
development has been completed, shall be in compliance with the requirements
outlined in the City of Orange General Plan Noise Element to ensure that noise
levels to which the riparian area is exposed do not exceed noise standards for
residential areas.
7. The project shall be designed to minimize exterior night lighting while remaining
compliant with City of Orange ordinances related to street lighting. Any necessary
lighting (e.g., to light up equipment for security measures), both during
construction and after the development has been completed, will be shielded or
directed away from Santiago Creek and are not to exceed 0.5 foot-candles.
Monitoring by a qualified lighting engineer (attained by the project Applicant and
subject to spot checking by City Staff) shall be conducted as needed to verify light
levels are below 0.5 foot-candles required within identified, occupied least Bell’s
vireo territories, both during construction and at the onset of operations. If the 0.5
foot-candles requirement is exceeded, the lighting engineer shall make operational
changes or install a barrier to alleviate light levels during the breeding season.
8. Two brown-headed cowbird traps shall be installed and maintained within the
general vicinity of the habitat for five years. If equestrian trails are proposed within
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the project site, which may result in increased horse manure and the potential for
increased foraging resources for brown-headed cowbirds, an ongoing manure
management receptacle/maintenance plan shall be prepared and implemented.
MM BIO-2b The following shall be incorporated into the Biological Assessment as proposed
mitigation for potential impacts to least Bell’s vireo, subject to USFWS and CDFW
approval:
1. On- or off-site restoration or enhancement of least Bell’s vireo habitat at a ratio
no less than 3:1 for permanent grading impacts.
MM BIO-2c All construction, grading, and fuel modification activities (i.e., thinning) shall take
place outside of the least Bell’s vireo breeding season (March 15 to September 15)
to the greatest extent feasible. If any construction, grading, and fuel modification
activities are required during the breeding season within 300 feet of potential least
Bell’s vireo habitat, and pre-construction surveys determine least Bell’s vireo are
present, activities may continue in the presence of a biological monitor who will
confirm that no work will occur within a 300-foot buffer of least Bell’s vireo, and that
any least Bell’s vireo are not being disturbed by project activities. If any disturbance
to the least Bell’s vireo is detected by the biological monitor, the buffer will be
increased, other disturbance minimizing measures may be implemented (e.g., visual
and/or noise barrier), and/or work will cease as recommended by the monitor.
Additional measures to be taken for all construction activities within 300 feet of
potential least Bell’s vireo habitat during the breeding season (March 15 to
September 15):
1. Pre-construction surveys shall be conducted within 1 week prior to initiation of
construction activities and all results forwarded to the USFWS and CDFW. Focused
surveys shall be conducted for least Bell’s vireo during construction activities.
2. If at any time least Bell’s vireo are found to occur within 300 feet of construction
areas, the monitoring biologist shall inform the appropriate construction
supervisor to cease such work and shall consult with the USFWS and CDFW to
determine if work shall commence or proceed during the breeding season and, if
work may proceed, what specific measures shall be taken to ensure least Bell’s
vireos are not affected.
3. Installation of any noise barriers and any other corrective actions taken to
mitigate noise during the construction period shall be communicated to the
USFWS and CDFW.
MM BIO-2d Prior to the issuance of any grading permit that would remove habitats containing
raptor and songbird nests, the project Applicant shall demonstrate to the
satisfaction of the City that either of the following have been or will be
accomplished.
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1. Vegetation removal activities shall be scheduled outside the nesting season
(September 1 to February 14 for songbirds; September 1 to January 14 for
raptors) to avoid potential impacts to nesting birds.
2. Any construction activities that occur during the nesting season (February 15 to
August 31 for songbirds; January 15 to August 31 for raptors) will require that all
suitable habitat be thoroughly surveyed for the presence of nesting birds by a
qualified biologist before commencement of clearing. If any active nests are
detected, a buffer of at least 300 feet (500 feet for raptors) will be delineated,
flagged, and avoided until the nesting cycle is complete, or as determined
appropriate by the biological monitor, to minimize impacts.
Level of Significance After Mitigation
Less than significant impact.
Sensitive Natural Communities
Impact BIO-3: The project may impact sensitive natural communities.
Impact Analysis
Implementation of the proposed project would result in impacts to coast live oak woodland, mule fat
scrub, open water, ornamental, eucalyptus woodland, non-native grassland/non-native herbaceous
cover, non-native grassland/disturbed, non-native herbaceous cover, non-native herbaceous
cover/black willow scrub, non-native herbaceous cover/mule fat scrub, non-native herbaceous
cover/disturbed, disturbed, disturbed/arroyo willow scrub, disturbed/black willow scrub,
disturbed/mule fat scrub, disturbed/non-native herbaceous cover, and developed, as summarized in
Table 3.4-3. None of these natural communities represent sensitive natural communities (CDFW
2003) and their removal does not meet the significance thresholds defined previously. Therefore,
impacts to these natural communities would be considered a less than significant impact and no
mitigation measures would be required.
Table 3.4-3: Impacts to Natural Communities
Natural Community
Acres
Existing Permanent
Impacts Fuel Modification
Temporary
Impacts Avoided Total
Southern Cottonwood—Willow
Riparian Forest
12.79 0.14 — 0.05 12.60
Coastal Sage Scrub 0.57 — — — 0.57
Coastal Sage Scrub/Non-Native
Herbaceous Cover
0.19 — — — 0.19
Coast Live Oak Woodland 0.33 0.33 — — —
Blue Elderberry Scrub 0.13 — — — 0.13
California Brittlebush Scrub 0.26 — — — 0.26
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Table 3.4-3 (cont.): Impacts to Natural Communities
Natural Community
Acres
Existing Permanent
Impacts Fuel Modification
Temporary
Impacts Avoided Total
Laurel Sumac Scrub 0.38 — — — 0.38
Yerba Santa Scrub 0.31 — — — 0.31
Mule Fat Scrub 0.17 0.09 — — 0.08
Open Water 0.66 0.66 — — —
Giant Reed 0.44 — — — 0.44
Ornamental 0.49 0.13 0.04 — 0.32
Eucalyptus Woodland 0.43 0.43 — — —
Non-Native Grassland/Non-
Native Herbaceous Cover
25.47 13.06 0.30 — 12.11
Non-Native Grassland/Disturbed 3.89 3.75 — 0.03 0.11
Non-Native Herbaceous Cover 5.11 3.46 0.28 — 1.37
Non-Native Herbaceous
Cover/Black Willow Scrub
0.20 0.20 — — —
Non-Native Herbaceous
Cover/Coastal Sage Scrub
0.43 — — — 0.43
Non-Native Herbaceous
Cover/Mule Fat Scrub
0.26 0.26 — — —
Non-Native Herbaceous
Cover/Ornamental
7.05 — — — 7.05
Non-Native Herbaceous
Cover/Disturbed
0.19 0.03 0.13 — 0.03
Disturbed 19.46 17.92 0.51 — 1.03
Disturbed/Arroyo Willow Scrub 0.11 0.11 — — —
Disturbed/Black Willow Scrub 0.31 0.31 — — —
Disturbed/Coastal Sage Scrub 0.30 — — — 0.30
Disturbed/Mule Fat Scrub 0.03 0.03 — — —
Disturbed/Non-Native
Herbaceous Cover
26.22 25.46 0.08 — 0.68
Developed 3.57 3.31 — — 0.26
Total 109.75 69.68 1.34 0.08 38.65
Source: ESA, 2017.
The project site supports 0.76 acre of coastal sage scrub (0.57 acre of coastal sage scrub, 0.19 acre of
coastal sage scrub/non-native herbaceous cover). The project will avoid impacts to coastal sage
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scrub, which is a natural community covered under the NCCP; therefore, no impacts would occur to
the coastal sage scrub community, as shown in Exhibit 3.4-9.
Four sensitive communities that are considered high priority for conservation by the CDFW List of
California Terrestrial Natural Communities, include southern cottonwood-willow riparian forest
(12.79 acres), blue elderberry scrub (0.13 acre), California brittlebush scrub (0.26 acre), and yerba
santa scrub (0.31 acre). Blue elderberry scrub, California brittlebush scrub, and yerba santa scrub
will be avoided by the project. The proposed project will impact southern cottonwood-willow
riparian forest, including 0.10 acre on-site permanent impacts within the limits of grading, 0.04 acre
permanent impacts, and 0.05 acre temporary impacts due to installation of an on-site storm drain
outlet. Any impacts to sensitive communities (e.g., southern cottonwood-willow riparian forest)
would be considered potentially significant. The measures outlined in Mitigation Measure BIO-3
would reduce impacts to a less than significant level.
In addition, there are preliminary trails and their alignments for the specific plan that are conceptual in
nature, and final design will be undertaken at some future date. As indicated previously, with the
exception of Trail A (in Planning Area B paralleling East Santiago Canyon Road) and Trail E (in Planning
Area B north of Planning Area C and with multiple uses as recreation trail, fuel modification
maintenance, and emergency vehicle access) final trail design, alignment and points of connectivity
with existing and future adjacent trails will be accomplished through a collaborative effort involving the
City of Orange, the Orange Park Acres Trail Committee, the Santiago Creek Greenway Alliance, Orange
County Parks, and representatives of the Applicant. As outlined in the Preface of this document,
approximately $4,100,000.00 in landscape and other improvements for the Santiago Creek Greenway
will be funded, as part of the proposed project. Said Improvements are to be completed or funded
prior to the 60th Certificate of Occupancy.
In order to avoid or minimize trail impacts to sensitive biological resources, design features (as
outlined on page 3.4-35 above) are recommended for incorporation prior to final design of the trails.
With the adoption of the recommended design features, potentially significant impacts will be
avoided or minimized.
Level of Significance Before Mitigation
Potentially significant impact.
Mitigation Measures
MM BIO-3 Prior to the issuance of any grading permit in the areas designated as sensitive
riparian communities (e.g., southern cottonwood-willow riparian forest or black
willow scrub/ruderal), the project Applicant shall demonstrate to the satisfaction of
the City that either of the following have been or will be accomplished:
On- or off-site restoration or enhancement of sensitive riparian communities (e.g.,
southern cottonwood-willow riparian forest) at a ratio no less than 1:1 for
permanent impacts. Temporary impacts will be restored to pre-project conditions
(i.e., pre-project contours and revegetate with native species, where appropriate).
Off-site restoration or enhancement at a ratio no less than 1:1 may include the
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purchase of mitigation credits at an agency-approved off-site mitigation bank (e.g.,
Soquel Canyon Mitigation Bank).
If mitigation is to occur on-site and/or off-site (i.e., not an in-lieu fee program), a
mitigation and monitoring plan shall be prepared. The plan shall focus on the
creation of equivalent habitats within disturbed habitat areas of the project site
and/or off-site. In addition, the plan shall provide details as to the implementation
of the plan, maintenance, and future monitoring. Mitigation for impacts to sensitive
riparian communities shall be accomplished by on- or off-site restoration and/or
enhancement (e.g., transplantation, seeding, and/or planting/staking of sensitive
riparian species; salvage/dispersal of duff and seed bank; removal of large stands of
giant reed within riparian areas).
Level of Significance After Mitigation
Less than significant impact.
Wetlands
Impact BIO-4: The proposed project may impact federally protected wetlands.
Impact Analysis
The proposed project would result in impacts to approximately 170 linear feet (50 linear feet
permanent, 120 linear feet temporary) and 0.01 acre (0.01 acre permanent, and less than 0.01 acre
temporary) of USACE/RWQCB “waters of the United States”/“waters of the State,” of which less than
0.01 acre is wetland (permanent), as well as 0.07 acre (0.03 acre permanent, and 0.04 acre
temporary) of CDFW jurisdictional streambed and associated riparian habitat; refer to Exhibit 3.4-10.
Any potential impacts to jurisdictional waters are considered potentially significant. Implementation
of Mitigation Measure BIO-4 would reduce impacts to a less than significant level.
In addition, there are preliminary trails and their alignments for the specific plan that are conceptual in
nature, and final design will be undertaken at some future date. As indicated previously, with the
exception of Trail A (in Planning Area B paralleling East Santiago Canyon Road) and Trail E (in Planning
Area B north of Planning Area C and with multiple uses as recreation trail, fuel modification
maintenance, and emergency vehicle access) final trail design, alignment and points of connectivity
with existing and future adjacent trails will be accomplished through a collaborative effort involving the
City of Orange, the Orange Park Acres Trail Committee, the Santiago Creek Greenway Alliance, Orange
County Parks, and representatives of the Applicant. As outlined in the Preface of this document,
approximately $4,100,000.00 in landscape and other improvements for the Santiago Creek Greenway
will be funded, as part of the proposed project. Said Improvements are to be completed or funded
prior to the 60th Certificate of Occupancy.
In order to avoid or minimize trail impacts to sensitive biological resources, design features (as
outlined on page 3.4-35 above) are recommended for incorporation prior to final design of the
trails. With the adoption of the recommended design features, potentially significant impacts will
be avoided or minimized.
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Level of Significance Before Mitigation
Potentially significant impact.
Mitigation Measures
MM BIO-4 Prior to the issuance of any grading permit for permanent impacts in the areas
designated as jurisdictional features, the project Applicant shall obtain a CWA
Section 404 permit from the USACE, a CWA Section 401 permit from the RWQCB,
and Streambed Alteration Agreement permit under Section 1602 of the California
Fish and Game Code from the CDFW. The following would be incorporated into the
permitting, subject to approval by the regulatory agencies:
1. On- or off-site restoration or replacement of USACE/RWQCB jurisdictional waters
of the United States/waters of the State at a ratio no less than 2:1 for permanent
impacts, and for temporary impacts, restore impact area to pre-project
conditions (i.e., pre-project contours and revegetate with native species, where
appropriate). Off-site restoration or enhancement at a ratio no less than 2:1 may
include the purchase of mitigation credits at an agency-approved off-site
mitigation bank or in-lieu fee program (e.g., SAWA).
2. On- or off-site restoration or enhancement of CDFW jurisdictional streambed and
associated riparian habitat at a ratio no less than 2:1 for permanent impacts, and
for temporary impacts, restore impact area to pre-project conditions (i.e., pre-
project contours and revegetate with native species, where appropriate). Off-site
restoration or enhancement at a ratio no less than 2:1 may include the purchase
of mitigation credits at an agency-approved off-site mitigation bank (e.g., Soquel
Canyon Mitigation Bank).
Level of Significance After Mitigation
Less than significant impact.
Fish and Wildlife Movement
Impact BIO-5: The project would not interfere with fish or wildlife movement.
Impact Analysis
The Santiago Creek corridor supports live-in and movement habitat for species on a local scale and also
likely functions to facilitate wildlife movement for a number of species on a regional scale. The
proposed project was designed to avoid Santiago Creek and associated native habitat that is best suited
to support local and regional wildlife movement along the creek to the maximum extent feasible.
The proposed project was designed to avoid Santiago Creek and associated native habitat that is best
suited to support local and regional wildlife movement along the creek to the maximum extent feasible
in the following ways:
• The proposed project will permanently retain approximately 38 acres of open space located
on both sides of Santiago Creek and bordered on the north by Mabury Avenue.
27650002 • 07/2018 |3.4-9_natcom_impacts.cdr
Exhibit 3.4-9
Impacts to Sensitive Natural Communities
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: ESA, July 2018. ESRI Aerial Imagery, 2017.
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Exhibit 3.4-10
Impacts to Jurisdictional Features
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: ESA, July 2018. ESRI Aerial Imagery, 2017.
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• The majority of the southern cottonwood-willow riparian forest within the project site will be
avoided (i.e., 12.60 acres), with the exception of 0.10 acre of permanent impacts will occur to
an isolated patch of southern cottonwood-willow riparian forest on-site, and 0.04 acre of
permanent impact and 0.05 acre of temporary impact from the installation of an on-site storm
drain outlet.
• The proposed project will avoid the majority of Santiago Creek and its associated native
riparian and upland habitats. Approximately 38 acres of the project site will be avoided,
including 14.06 acres of sensitive plant communities, which includes 0.57 acre of coastal sage
scrub and 12.60 acres of southern cottonwood-willow riparian forest, within and/or adjacent
to Santiago Creek. A total of 0.04 acre of permanent impacts on-site and 0.05 acre of
temporary impacts, which will be restored to pre-project conditions, will occur to southern
cottonwood-willow riparian forest for the installation of a storm drain outlet.
• The proposed project will provide a 150-foot limited use (landscaping and fuel modification)
time sensitive (breeding season March 15 through September 15) setback area adjacent to
the southern cottonwood-willow riparian forest within Santiago Creek, which provides habitat
for the least Bell’s vireo.
• The proposed project will provide select landscaping, including native species, within the 150-
foot limited use setback area (to the south of Santiago Creek) that is compatible with the
adjacent open space area, its habitat, and is considerate of the fire protection (fuel
modification) zone (refer to Exhibit 3.4-8).
• The proposed project establishes development standards in the Specific Plan to reduce
sensory stimuli (e.g., noise, light), unnatural predators (e.g., domestic cats and other non-
native animals), and competitors (e.g., exotic plants, non-native animals).
• Prior to building permit issuance, the proposed project will remove the existing fence on
Orange County Flood Control District property.
• The proposed project will restrict grading and/or construction activities within the 150-foot
limited use setback area during the least Bell’s vireo breeding season; refer to Exhibit 3.4-8.
• The proposed project will limit uses within the 150-foot limited use setback area to those as
uses identified in the Specific Plan.
Santiago Creek within the project site does not support fish passage because of downstream
obstructions including the presence of Santiago Creek Recharge Basin.
In addition, the project is not anticipated to contribute to avian mortality due to bird strikes resulting
from window glare from structures. Although the project site includes a portion of Santiago Creek
that provides habitat for a number of wildlife species, including birds, there is already existing
residential development surrounding the creek in all directions, including Mabury Ranch
immediately adjacent to the north. The proposed project would include additional suburban
residential development of comparable heights and architectural features to those existing within
the neighboring communities. The project does not include high-rise urban buildings with large
glass windows, an architectural design with a high ratio of bird strike when compared to suburban
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residential development. In addition, lighting from the residential development would be compliant
with City of Orange ordinances related to street lighting, and would be shielded away from Santiago
Creek. Thus, light and glare impacts to birds would be less than significant with implementation of
the proposed project design features.
Impacts would be less than significant.
In addition, there are preliminary trails and their alignments for the specific plan that are conceptual in
nature, and final design will be undertaken at some future date. As indicated previously, with the
exception of Trail A (in Planning Area B paralleling East Santiago Canyon Road) and Trail E (in Planning
Area B north of Planning Area C and with multiple uses as recreation trail, fuel modification
maintenance, and emergency vehicle access) final trail design, alignment and points of connectivity
with existing and future adjacent trails will be accomplished through a collaborative effort involving the
City of Orange, the Orange Park Acres Trail Committee, the Santiago Creek Greenway Alliance, Orange
County Parks, and representatives of the Applicant. As outlined in the Preface of this document,
approximately $4,100,000.00 in landscape and other improvements for the Santiago Creek Greenway
will be funded, as part of the proposed project. Said improvements are to be completed or funded
prior to the 60th Certificate of Occupancy.
In order to avoid or minimize trail impacts to sensitive biological resources, design features (as
outlined on page 3.4-35 above) are recommended for incorporation prior to final design of the
trails. With the adoption of the recommended design features, potentially significant impacts will
be avoided or minimized.
Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
Local Biological Ordinances and Policies
Impact BIO-6: The project would not conflict with local biological ordinances or policies.
Impact Analysis
The project site contains 204 trees within the tree survey area (i.e., within the project development
footprint). Exhibit 3.4-11 depicts impacts to regulated tree species. Of the 204 trees on-site that will
be impacted within the 71.10-acre development footprint, nine trees are within the fuel
modification beyond the limits of grading so may potentially be left in place but are subject to
thinning, and two trees are within the 0.06-acre storm drain outlet footprint and one tree is within
the 0.08-acre associated temporary 30-foot construction buffer.
27650002 • 07/2018 |3.4-11_tree_impacts.cdr
Exhibit 3.4-11
Impacts to Regulated Trees
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: ESA, July 2018. ESRI Aerial Imagery, 2017.
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The Tree Preservation Ordinance requires applicants for subdivision maps or grading permits to
identify the location of trees proposed for removal and affords City staff discretion in imposing
conditions on tree removal activities and replanting. Removed trees would be conditioned on being
replaced on-site at no less than a 1:1 ratio. Impacts would be less than significant.
Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
Conservation Plan Consistency
Impact BIO-7: The project would not conflict with any applicable habitat conservation plan or
natural communities conservation plan
Impact Analysis
The project site is within the boundaries of the Orange County Central and Coastal Subregion
NCCP/HCP. The NCCP/HCP has an objective of assembling a 38,000-acre preserve in Orange County
consisting of the highest value biological habitat.
Within the project site, the Santiago Creek corridor and the upland areas north of the creek contain
riparian habitat, which are considered to have high biological value. These areas are contemplated
to be preserved as open space and, therefore, would be available for inclusion in the preserve.
Additionally, the 4.2 acres proposed for residential development coincide with the surface mining
areas and do not contain any significant biological habitat. For these reasons, no conflicts with the
NCCP/HCP would occur. Impacts would be less than significant.
Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
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3.5 - Cultural Resources
3.5.1 - Introduction
This section describes the existing cultural resources setting and potential effects from project
implementation on the site and its surrounding area that are based on the Addendum to the Phase I
Cultural Resources Assessment prepared by BCR Consulting, the Updated Native American
Consultation for the Rio Santiago Specific Plan Project prepared by BCR Consulting, and the Phase I
Cultural Resources Assessment and Paleontological Records Review prepared by Michael Brandman
Associates1. These reports are provided in Appendix H. In November and December of 2017, the
archaeological and paleontological records searches were updated and a new pedestrian survey was
conducted for the property. The results of these efforts are contained herein.
3.5.2 - Environmental Setting
Overview
The term “cultural resources” encompasses historic, archaeological, and paleontological resources,
and burial sites. Below is a brief summary of each component:
• Historic Resources: Historic resources are associated with the recent past. In California,
historic resources are typically associated with the Spanish, Mexican, and American periods in
the State’s history and are generally less than 200 years old.
• Archaeological Resources: Archaeology is the study of prehistoric human activities and
cultures. Archaeological resources are generally associated with indigenous cultures.
• Paleontological Resources: Paleontology is the study of plant and animal fossils.
• Burial Sites: Burial sites are formal or informal locations where human remains, usually
associated with indigenous cultures, are interred.
Cultural Setting
Prehistory
The ultimate purpose of establishing a cultural sequence is to allow for the meaningful comparison
of material culture attributes on an intra- and inter-site basis, and to provide the basis for culture-
model building. To this end, regional archaeologists generally follow Wallace’s Southern California
Format (1955 and 1978) for discussing the prehistoric chronology for the project area. However, the
established chronologies are often augmented or even abandoned. For example, Fagan (2003) does
not use the traditional archaeological cultural sequences for his regional analysis, instead he
described the stages as generalized models related to recent environmental change and socio-
economic models, all associated with an ever-changing environment. Thusly, it should be noted that
all of the presented cultural sequences are regularly challenged, as are the meanings of the
individual frames of reference. Wallace’s prehistoric format is as follows:
1 Michael Brandman Associates became part of FirstCarbon Solutions (FCS) in 2012; this section refers to Michael Brandman
Associates (MBA) and FCS interchangeably.
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• Early Period (before 6000 B.C.)
• Milling Stone (6000 to 3000 B.C.)
• Intermediate (3000 B.C. to A.D. 500)
• Late Prehistoric (A.D. 500 to A.D. 1769).
Wallace also argued (Wallace, in Heizer 1978) that the stages prior to 2000 B.C> in southern
California could be assigned to:
• San Dieguito Period (Period I: 9000 to 6000 B.C.)
• Standard Millingstone Period (Period II: 6000 to 3000 B.C.)
• Modifies Millingstone Period (Period III: 3000 to 2000 B.C.).
Warren (1968) uses the following terms to subdivide the periods:
• San Dieguito Tradition (Before 5500 B.C.)
• Encinitas Tradition (5500 B.C. to A.D. 600)
• Shoshonean Tradition (A.D. 600 to A.D. 1769)
The Late Period has been further subdivided into the San Luis Rey I (A.D. 500 to A.D. 1500) and the
San Luis Rey II (post 1500). The difference between the latter two is the introduction of locally made
brownware pottery, the first indigenous pottery in southern California (Cameron 1999).
Early Period (before 6000 B.C.)
Beginning with the first human presence in California, prehistoric artifacts and cultural activities
appear to represent a big-game hunting tradition. Very few sites from the Early Period exist,
especially in inland areas. Of the Early Period sites that have been excavated and dated, most exhibit
a refuse assemblage suggesting short-term occupation. Such sites have been detected in caves and
around fluvial lakes fed by streams that existed near the end of the last glaciation. Chipped stone
tools at these sites are surmised to reflect a specialized tool kit used by hunters. Large-stemmed
bifaces are common. Millingstones and dart points are not part of the Early Period tool assemblage.
Millingstone Period (6000 to 3000 B.C.)
The onset of the Millingstone Period appears to correspond with an interval of warm and dry
weather known as the Altithermal (Wallace 1978). Artifact assemblages begin to reflect an emphasis
on plant foods and foraging subsistence systems, as evidenced by the grinding tools found at these
sites, and including choppers and scraper planes. Notably, there is a reduced number of large
bifaces in the excavated assemblages. Sites are occupied for a greater duration than Early Period
sites, based on an increase in occupational debris. Although numerous Millingstone sites have been
identified in Orange County, few are actually dated. The best understood of these is CA-ORA-64,
which has been radiometrically dated to about 6000 B.C. (Breece et al. 1988 and 1989). Excavations
at this site located near Newport Bay, have been essential to the formulation of local research
models (Koerper 1981). Research at this site suggests a settlement-subsistence system during the
Millingstone Period reflecting a semi-sedentary lifestyle. The regional distribution of Millingstone
sites reflects the theory that aboriginal groups may have followed a modified central-based
wandering settlement pattern. Under this model, large groups would have occupied a base camp for
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a portion of the year, with smaller bands occupying subsidiary camps in order to exploit resources
not generally available near the base camp. Sedentism apparently increased in areas possessing an
abundance of resources that were available for longer periods. Arid inland regions would have
provided a seasonally and spatially dispersed resource base, restricting sedentary occupation,
compared to the coastal areas. Generally, the Millingstone assemblage in the Los Angeles basin is
typified by large and heavy deep-basin metates, wedge-shaped manos and large choppers and
scrapers. Flaked lithic tools are slightly larger and cruder than in later periods, and cogstones begin
to appear.
Intermediate Period (3000 B.C. to A.D. 500)
Dating between roughly 3000 B.C. and A.D. 500, the Intermediate Period represents a slow
technological transition, which is presumably related to the slowly drying and warming climate. Site
artifact assemblages retain many attributes of the Millingstone Period. Technologically speaking,
these sites are difficult to distinguish from earlier sites in the absence of radiometric dates.
Additionally, these sites generally contain a reduced number of large-stemmed or notched projectile
points but with an increase in portable mortars and pestles. The lack of large points combined with
the mortars and pestles suggest that the indigenous populations may have preferred harvesting,
processing, and consuming acorns and other seeds over hunting. Due to a general lack of data,
neither the settlement and subsistence systems nor the cultural evolution of this period are well
understood. It has been proposed by some researchers that group sedentarism increased with the
exploitation of storable, high-yield plant food resources such as acorns. The duration and intensity
of occupation at base camps increased during this period, especially in the later part of the period.
Generally, the Intermediate Period artifact assemblage in the Los Angeles basin is vague, including
elements of the Late Prehistoric Period and Millingstone Period, such as heavy grinding implements.
A higher percentage of projectile points occur and smaller chipped stone tools are used.
Late Prehistoric Period (A.D. 500 to A.D. 1769)
Extending from about A.D. 500 to Spanish contact in A.D. 1769, the Late Prehistoric Period reflects
an increased sophistication and diversity in technology. Village sites are common. Late assemblages
characteristically contain small projectile or dart points, which imply the use of the bow and arrow.
In addition, assemblages include steatite bowls, asphaltum artifacts, grave goods, and elaborate
shell ornaments. Use of bedrock milling stations is purported to have been widespread during this
period, as it was in the previous period. Increased hunting efficiency and widespread exploitation of
acorns provided reliable and storable food resources. Pottery, previously traded into the area, is
made locally during the latest stage of this Period and is of simple construction technology.
Cameron (1999) names several village sites in inland Orange County that are located within
Gabrieliño territory. These exhibited pottery, which suggests that the pre-contact Gabrieliño may
have used pottery as a part of their lifestyle. One of these Late Prehistoric Period sites, Tomato
Springs (CA-ORA-244), has been the subject of numerous excavations (Cottrell 1985) that have
continued into the 21st century.
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Native American Background
The project area is situated within an area that has been ethnographically mapped as the Gabrieliño
traditional use area. The Gabrieliño tribal territory is mapped as extending north from Aliso Creek to
just beyond the Topanga Canyon along the Pacific Coast, and inland to the City of San Bernardino
(Bean and Smith 1978). Their territory would have included portions of the Santa Ana River, and
several islands, and diffusion of ideas between neighboring groups, such as the Juaneño to the south.
The Gabrieliño
Kroeber (1925) and Bean and Smith (1978) form the primary historical references for this tribal
group. The arrival of Spanish explorers and the establishment of missions and outposts during the
eighteenth century ended the prehistoric period in California. At this time, traditional Gabrieliño
society began to fragment as a result of foreign diseases and the mass removal of local Indian
groups to the Mission San Gabriel and Mission San Juan Capistrano. The Gabrieliño spoke a
language that belongs to the Cupan group of the Takic subfamily of the Uto-Aztecan language family
(a language family that includes the Shoshonean groups of the Great Basin). The total Gabrieliño
population in about 1770 AD was roughly 5,000 persons, based on an estimate of 100 small villages,
with approximately 50 to 200 people per village. Their range is generally thought to have been
located along the Pacific coast from Malibu to San Pedro Bay, south to Aliso Creek, then east to
Temescal Canyon, then north to the headwaters of the San Gabriel River. Also included were
several islands, including Catalina. This large area encompasses the City of Los Angeles, much of
Rancho Cucamonga, Corona, Glendale, and Long Beach. By 1800, most traditional Gabrieliños had
either been killed, or subjugated by the Spanish. The first modern social analyses of Gabrieliño
culture took place in the early part of the twentieth century (Kroeber 1925). By this time,
acculturation and disease had devastated this group, and the population studied was a remnant of
their pre-contact form. Nonetheless, the early ethnographers viewed the Gabrieliño as a chief-
oriented society of semi-sedentary hunter-gatherers. Influenced by coastal and interior
environmental settings, their material culture was quite elaborate and consisted of well-made
wood, bone, stone, and shell items. Included among these was a hunting stick made to bring down
numerous types of game. Located in an area of extreme environmental diversity, large villages may
have been permanent, such as that found on or near Red Hill in Rancho Cucamonga, with satellite
villages utilized seasonally. Their living structures were large, domed, and circular thatched rooms
that may have housed multiple families. The society exhibited ranked individuals, possibly chiefs,
who possessed a much higher level of economic power than unranked persons.
Historic Background
City of Orange
The earliest European explorers to enter the Alta California region were the Spanish who navigated
along the Pacific coast during the 17th and 18th centuries. During the latter portion of the 18th
century, the Spanish sent Father Junipero Serra to Alta California to create a chain of Missions and
Mission outposts to bring Christianity to the indigenous population, and create a foundation for
colonization of the region. Between 1769 and 1823, Spanish explorers and missionaries established
21 missions, four presidios, and four pueblos between San Diego and Sonoma. Also during this
period, American explorations occurred when trappers traveled west in search of abundant sea otter
and beaver pelts. In 1805, when Lewis and Clark crossed the Rocky Mountains and continued on to
the Pacific coast, they reported that the area was richer in beaver and otter than any other country
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on earth. The fur trappers were close behind the explorers, and by 1840, the beaver was over-
exploited and was no longer worth hunting (Bean and Rawls 1983).
By the early decades of the 19th century, the Missions began establishing ranchos for the purpose of
expanding their agricultural holdings. According to the history provided on the City of Orange
website, the first landowner in this area was a retired Spanish soldier named Juan Pablo Grijalva.
Grijalva was granted permission to ranch “the place of the Arroyo de Santiago” by the Spanish
colonial government in 1801. This land ran from the Santa Ana River and the foothills above Villa
Park, to the sea at Newport Beach. Though Grijalva lived in San Diego, he built an adobe ranch
house on what is now Hoyt Hill, at the corner of Hewes and Santiago Canyon Road (City of Orange
History 2008).
Following Grijalva’s death, the rancho was taken over by his son-in-law, Jose Antonio Yorba, and
grandson, Juan Pablo Peralta. These lands then became known as the Rancho Santiago de Santa
Ana, and were granted to Yorba and Peralta on July 1, 1810. This 75,000-acre grant was made by
Governor Arrellaga, and encompassed the majority of the Santa Ana Canyon of eastern Orange
County, as well as much of northern Orange County and Newport Bay (Lech 2004). The children and
grandchildren of Yorba and Peralta moved to various parts of the sizable rancho, and through time,
the descendants absorbed additional acreage. The family holdings eventually encompassed lands
extending from Riverside to the ocean.
In the early 1860s, Leonardo Cota, an extended family member, borrowed money from the largest
landowner in southern California. Abel Stearns lent Cota money, and held his share of the Rancho as
collateral. When Cota defaulted on his loan in 1866, Stearns filed a lawsuit in the Los Angeles
Superior Court to demand a partition of the land, in order to claim Cota’s section. It took two years
to determine how much land was due to each family member, and the rancho was then divided into
1,000 units for the heirs and the claimants in the lawsuit (City of Orange 2008).
The Los Angeles attorneys involved in the lawsuit, Alfred Chapman and Andrew Glassell, received a
portion of the Rancho Santiago de Santa Ana as payment for their services. They quickly subdivided
their land into a 1-square-mile town, with surrounding 10-acre farm lots. This community was
named Richland until 1873, when the town’s application for a post office was denied due to the
existence of another Richland in Sacramento County. According to local legend, Richland was
renamed Orange after a poker game where Glassell, Chapman, and two other men allowed the
winner to decide the new town name. Though the winner is not recorded, Richland was named
Orange in January of 1875.
By 1873 Richland/Orange was beginning to grow by opening the first local store, named Fisher
Brothers, a civic organization, called the Orange Grange, and the first church, which was of the
Methodist Episcopal denomination. This was also the year that local farmers began planting orange
groves in the area. The area then continued to grow when the Southern Pacific Railroad built a
depot in Orange, in 1880, and again with the arrival of the Santa Fe railroad in 1887.
During the land boom of the 1880s, Orange attracted many travelers, founded local newspapers,
build a public library, a bank and incorporation occurred on April 6, 1888. When the boom ended,
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local farmers continued to plant orange trees. By 1929, Orange County produced more than $12
million from the sale of oranges. However, with the depression and inclement weather in the 1930s,
the industry fell into economic decline (City of Orange 2008).
By the 1950s, a second real estate boom occurred, and large tracts of houses were constructed into
the 1970s. Thereafter the City of Orange continued to grow at a steady pace, and development is
still occurring, especially at the eastern edge of the city.
Historic Era Aerial Photograph
FCS (formerly MBA) additionally conducted a historic era aerial photograph review, from an image
taken from the National Imagery Program for Orange County. This photograph was taken on
December 12, 1952. During the historic era, the project area was part of an extensive sand and
gravel mining operation, which began in approximately 1952 (LSA 1992). This process removed sand
and gravel from alluvial deposits, and then processed the sediments in an open area located to the
south of Santiago Creek. Evidence of the surface mi ning activity is observable in this photograph in
the central portion of the project area, to the south of Santiago Creek. In this area, there is an
absence of vegetation, multiple piles of soil, and numerous dirt tracks and/or unimproved access
roads. Santiago Creek borders the surface mining area to the north, and numerous citrus groves are
found to the southeast, south, and southwest along Santiago Canyon Road. In the southwestern
corner of the project area, to the north of Santiago Canyon Road, and at the southern terminus of a
windrow of eucalyptus trees is a clearing with apparent structures. These structures are situated
between citrus groves, and appear to coincide with the location of a concrete foundation and an
asphalt and concrete lot recorded during the pedestrian survey as Site 001. Additional citrus groves
are found within the project area boundaries, to the north of Santiago Creek. These citrus groves
appear to cover the recorded location of prehistoric-age site CA-ORA-369, which was detected
during the cultural resources literature search at the South Central Coastal Information Center
(SCCIC).
3.5.3 - Regulatory Framework
Federal
National Historic Preservation Act
The National Historic Preservation Act of 1966 (NHPA), as amended, established the National
Register of Historic Places (NR), which contains an inventory of the nation’s significant prehistoric
and historic properties. Under 36 CFR 60, a property is recommended for possible inclusion on the
NR if it is at least 50 years old, has integrity, and meets one of the following criteria:
• It is associated with significant events in history, or broad patterns of events.
• It is associated with significant people in the past.
• It embodies the distinctive characteristics of an architectural type, period, or method of
construction; or it is the work of a master or possesses high artistic value; or it represents a
significant and distinguishable entity whose components may lack individual distinction.
• It has yielded, or may yield, information important in history or prehistory.
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Certain types of properties are usually excluded from consideration for listing in the NR, but they can
be considered if they meet special requirements in addition to meeting the criteria listed above.
Such properties include religious sites, relocated properties, graves and cemeteries, reconstructed
properties, commemorative properties, and properties that have achieved significance within the
past 50 years.
State
Senate Bill 18
California Senate Bill (SB) 18 states that prior to a local (city or county) government’s adoption of any
general plan or specific plan, or amendment to general and specific plans, or a designation of open
space land proposed on or after March 1, 2005, the city or county shall conduct consultations with
California Native American tribes for the purpose of preserving or mitigating impacts to Cultural
Places. A Cultural Place is defined as:
Native American sanctified cemetery, place of worship, religious or ceremonial site,
or sacred shrine (PRC Section 5097.9), or;
Native American historic, cultural, or sacred site, that is listed or may be eligible for
listing in the California Register of Historic Resources pursuant to Section 5024.1,
including any historic or prehistoric ruins, any burial ground, or any archaeological or
historic site (PRC Section 5097.995).
According to the Government Code (GC) Section 65352.4, “consultation” is defined as:
The meaningful and timely process of seeking, discussing, and considering carefully
the views of others, in a manner that is cognizant of all parties’ cultural values and,
where feasible, seeking agreement. Consultation between government agencies and
Native American Tribes shall be conducted in a way that is mutually respectful of each
party’s sovereignty. Consultation shall also recognize the tribes’ potential needs for
confidentiality with respect to places that have traditional tribal cultural significance.
While consultation is required to take place on a government-to-government level, the SB 18 process
begins with a letter from the local government to the Native American Heritage Commission
requesting a list of tribal organizations appropriate to the plan or plan amendment area or proposed
open space designation. Once contacted by the local government, the tribes have up to 90 days to
respond and request consultation regarding the preservation and treatment of known cultural
place(s), if any have been identified by the tribe.
California Assembly Bill 52
Assembly Bill 52 (AB 52) was signed into law on September 25, 2014, and provides that any public or
private “project with an effect that may cause a substantial adverse change in the significance of a
tribal cultural resource is a project that may have a significant effect on the environment.” Tribal
cultural resources include “[s]ites, features, places, cultural landscapes, sacred places, and objects
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with cultural value to a California Native American tribe that are eligible for inclusion in the
California Register of Historical Resources or included in a local register of historical resources.”
This law applies to any project that has a notice of preparation, a notice of negative declaration, or
mitigated negative declaration filed on or after July 1, 2015. Under prior law, tribal cultural
resources were typically addressed under the umbrella of “cultural resources,” as discussed above.
AB 52 formally added the category of “tribal cultural resources” to CEQA, and extends the
consultation and confidentiality requirements to all projects, rather than just projects subject to SB
18 as discussed above.
The parties must consult in good faith, and consultation is deemed concluded when either (1) the
parties agree to measures to mitigate or avoid a significant effect on a tribal cultural resource (if such
a significant effect exists); or (2) when a party concludes that mutual agreement cannot be reached.
Mitigation measures agreed upon during consultation must be recommended for inclusion in the
environmental document. AB 52 also identifies mitigation measures that may be considered to
avoid significant impacts if there is no agreement on appropriate mitigation. Recommended
measures include:
• Preservation in place
• Protecting the cultural character and integrity of the resource
• Protecting the traditional use of the resource
• Protecting the confidentiality of the resource
• Permanent conservation easements with culturally appropriate management criteria
California Register of Historical Resources
As defined by Section 15064.5(a)(3)(A-D) of the CEQA Guidelines, a resource shall be considered
historically significant if the resource meets the criteria for listing on the California Register of
Historical Resources (CR). The California Register of Historical Resources and many local
preservation ordinances have employed the criteria for eligibility to the NR as a model, since the
NHPA provides the highest standard for evaluating the significance of historic resources. A resource
that meets the NR criteria is clearly significant. In addition, a resource that does not meet the NR
standards may still be considered historically significant at a local or state level.
California Environmental Quality Act
The CEQA Guidelines state that a resource need not be listed on any register to be found historically
significant. The CEQA guidelines direct lead agencies to evaluate archaeological sites to determine if
they meet the criteria for listing in the California Register. If an archaeological site is a historical
resource, in that it is listed or eligible for listing in the California Register, potential adverse impacts
to it must be considered. If an archaeological site is considered not to be an historical resource but
meets the definition of a “unique archeological resource” as defined in Public Resources Code
Section 21083.2, then it would be treated in accordance with the provisions of that section.
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Local
City of Orange
General Plan
Cultural Resources and Historic Preservation Element
• Goal 1.0: Identify and preserve potential and listed historic resources, including buildings,
structures, objects, sites, districts, and archaeological resources citywide.
• Policy 1.3: Provide long term assurance that potential and listed historic resources will be
used, maintained, and rehabilitated in conformance with Secretary of the Interior’s Standards
for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating,
Restoring and Preserving Historic Buildings (Secretary’s Standards).
• Policy 1.4: Encourage alternatives to demolition such as architecturally-compatible
rehabilitation, adaptive re-use, new construction, and relocation.
• Goal 2.0: Identify and preserve neighborhoods that are culturally and historically significant
but do not retain sufficient integrity for eligibility as a local, state, or national district.
• Goal 4.0: Identify and preserve archaeological and cultural resources.
• Policy 4.1: Identify, designate, and protect historically and culturally significant archaeological
resources or sites.
• Policy 4.2: Recognize the importance of Santiago Creek as an archaeological resource.
• Policy 4.5: Encourage private development to celebrate the cultural history of the community
through project design.
Cultural Resources and Historic Preservation Plan
The City of Orange has traditionally focused its historic preservation efforts primarily on Old Towne.
Since 1982, when the City of Orange undertook its first historic resources survey, enacted its first
historic preservation element, and established the Old Towne Historic District through a zoning overlay,
historic preservation has been a significant factor in the revitalization and economic vitality of Orange’s
historic downtown. The current process of establishing an historic district is through a zoning overlay
as outlined in the Zoning Ordinance; the City does not have a Historic Preservation Ordinance. By
combining historic district designation with design standards, design review, and preservation
incentives, the historic character of Old Towne has been maintained and preserved. As part of this
effort, the City has developed public programs that provide city residents with a variety of
informational tools advertising different options for historic preservation. The City actively promotes
the Old Towne Design Standards, educates the public regarding architectural styles found in Old Towne,
and provides public information on the Mills Act program, which provides incentives that may reduce
property taxes on historic buildings in exchange for rehabilitation and maintenance of the owner’s
historic resource. City Hall makes all of this information available, in addition to preservation maps and
brochures, and city staff include experts who work on historic preservation projects throughout the
City. A Design Review Committee reviews building projects throughout Old Towne.
3.5.4 - Methodology
Three technical studies have been previously prepared for the project site: (1) Phase I Cultural
Resources Assessment and Paleontological Records Review prepared by Michael Brandman
Associates; (2) Addendum to the Phase I Cultural Resources Assessment prepared by BCR Consulting;
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and (3) the Updated Native American Consultation for the Rio Santiago Specific Plan Project
prepared by BCR Consulting. Each report is discussed separately. These reports are provided in
Appendix H.
Phase I Cultural Resources Assessment and Paleontological Records Review
Michael Brandman Associates prepared a Phase I Cultural Resources Assessment and Paleontological
Records Review, dated December 3, 2008. Subsequently, on November 28, 2017, the records search
was updated by an FCS archaeologist. An updated paleontological records search was ordered on
November 21, 2017.
Record Search
Information Center Search
On October 7, 2008, FCS Project Archaeologist Jennifer M. Sanka conducted a records search at the
SCCIC, which is located at California State University, Fullerton. To identify any historical or
archaeological resources or historic properties, Ms. Sanka examined the current inventories of the
NR, CR, California Historical Landmarks (CHL) list, and California Points of Historical Interest (CPHI).
In addition, Ms. Sanka reviewed the HRI and archival maps for the County and the City to determine
the existence of previously documented local historical resources.
Review of the 1896 United States Geological Survey (USGS) Anaheim, CA 30-minute and the 1902
(reprinted 1946) 30-minute Corona, Calif. Quadrangle maps revealed neither structures nor any
other development within the project area boundaries. Both maps depict Santiago Canyon Road in
its present location as an unnamed road, and both maps show a moderate amount of development
associated with areas labeled Villa Park, El Modena and Orange to the west. The mountainous lands
to the east are comparatively undeveloped. The 1942 USGS Anaheim, Calif. 15-minute Quadrangle
map shows four structures along Santiago Canyon Road, alongside the southern project area
boundary. Four additional structures are depicted in the southeastern corner of the project area,
adjacent to a hammer and pick symbol. At this time, the lands to the west show an increased
amount of development in comparison to earlier maps, and the lands to the east remain minimally
developed.
According to SCCIC files, the majority of the project area has been previously surveyed, and portions
exhibit numerous archaeological studies. A linear study was conducted along Santiago Canyon Road,
and this extended across the majority of the southern project area boundary (ARMC 1999). This
study returned negative results for cultural resources near the project area. Two studies have been
conducted that assessed Santiago Creek (Drover 1976 and ECOS 1985). The ECOS (1985) testing
program did not address any resources within the project area, while Drover (1976) detected one
resource in the project area (CA-ORA-369). McKenna et al. assessed a similar project area to the
present project area in 1999 (McKenna et al. 2000). The McKenna et al. project area appears to have
excluded a negligible amount of project acreage in the westernmost and eastern-most extensions of
the project area, based upon mapped location at the SCCIC and within their report. This study
discussed the existence of previously recorded resource CA-ORA-369 in the northern portion of the
project area, and that this resource could not be relocated in 1999. The study returned negative
results for cultural resources within their project area.
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Previously recorded resource CA-ORA-369 has been the subject of several studies and was mentioned
in numerous reports. Drover (1976) located numerous shell fragments at the recorded site location,
and found the site to be a minimal deposit with no interpretive use. APC (1979) collected surface
artifacts and tested the resource for subsurface deposits. This study found that CA-ORA-369 did not
exhibit sufficient depth, midden deposits or interpretive data to warrant additional studies. LSA (1994)
and McKenna et al. (2000) could not relocate CA-ORA-369. Including all of the aforementioned
studies, a total of 36 studies have been conducted within a 1-mile radius. Despite the high number of
studies conducted, less than 50 percent of the acreage within the search radius has been assessed for
cultural resources. A majority of the unexamined areas are urbanized, and were presumably
developed prior to the more stringent cultural resource assessment requirements that currently exist.
In addition, the SCCIC records search indicated that there is one previously recorded prehistoric-age
resource mapped within the project area boundaries, and one resource mapped adjacent to the
easternmost portion of the project area. CA-ORA-1172 is a prehistoric-age artifact scatter mapped
by the SCCIC as potentially extending into the eastern portion of the project area. However, the DPR
523 Form and the corresponding report map the resource on a knoll to the southeast of the project
area boundaries (Hatheway and McKenna 1988). Thus, it does not appear that this site should
extend into the present project area, and no artifacts were observed near the eastern-most portion
during the pedestrian survey. CA-ORA-369 is mapped in the northeastern portion of the project
area, and this site has been tested for subsurface deposits (APC 1979). Including these resources,
there are eleven cultural resources known within the 1-mile search radius, including eight
prehistoric-age and three historic-age resources. Two of the historic-age resources are NR listed
properties, and these are located more than 0.25 mile from the project area. The following table
outlines these previously recorded resources, as found in the 1-mile search radius on the Orange,
California topographic quadrangle.
An updated records search was conducted at the South Central Coastal Information Center on
November 28, 2017. The results of the records search indicate that there have been at least 5
additional cultural resources investigations conducted within a 1-mile radius of the project area since
the 2008 study. Of those, none included any portion of the property. As noted in the 2008 study,
eight prehistoric archaeological sites have been recorded within a 1-mile radius of the property. One
of those, CA-ORA-369, was recorded on the property south of Maybury Street. The other, CA-ORA-
1172, is recorded immediately adjacent to the southeast corner of the property, presumably outside
the property boundary. None of the remaining six are located on or within 0.5 mile of the subject
property. Three historic homes are recorded within 1 mile of the project area, but none are on the
project area.
In summary, the results of the updated records search show that no new archaeological
investigations have been conducted on the property since 2008, and no new archaeological sites
have been recorded on or within a 1-mile radius of the property.
CA-ORA-369 was thoroughly studied in 1979 and found to yield insufficient depth, midden deposits,
or other interpretive data to warrant further investigation. Subsequently, two archaeological surveys
in 1994 and 2000 failed to locate any remains of the site. The 2008 investigation also failed to locate
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the site; however, given the dense vegetation, it was concluded that the site could be obscured,
buried, or otherwise concealed from view and monitoring was recommended.
The 2008 investigation recorded an old concrete foundation and adjacent asphalt and gravel lot. The
site was not indicated on the topographic records search map at the SCCIC, and no record of the site
is on file with SCCIC. This is likely the fenced lot access via Jamestown off of Santiago. However, at
the time of its recordation, it was deemed insignificant and no further work was recommended.
Table 3.5-1: Previously Recorded Cultural Resources
Site Name Type
Distance From Project
Site
30-179872 Historic age—A single-family craftsman-style residence built in ca.
1940. This structure was found not significant under CEQA
through evaluation by the recorder.
< 1 mile
CA-ORA-1017 Prehistoric age—Artifact scatter consisting of flakes,
hammerstones, a chopper, a metate and a core.
< 1 mile
CA-ORA-1018 Prehistoric age—Artifact scatter consisting of manos, metates, a
hammerstone and a possible stone ball.
< 1 mile
CA-ORA-1019 Prehistoric age—Artifact scatter consisting of manos, metates,
hammerstones, flakes and a core.
< 1 mile
CA-ORA-1020 Prehistoric age—Lithic scatter containing approximately 10 to 15
flakes.
< 1 mile
CA-ORA-1273 Prehistoric age—Artifact scatter and a rock ring. Noted artifacts
include mano fragments, metate fragments, cores and flakes. Site
was excavated in 1991.
< 0.5 mile
CA-ORA-1172 Prehistoric age—Artifact scatter consisting of flakes,
hammerstones, manos, metate and a “donut stone.”
< 0.25 mile
CA-ORA-369 Prehistoric age—Artifact scatter consisting of cores, shells and
flakes.
Adjacent to northern
boundary of project
site
CA-ORA-702 Prehistoric age—A scraper, a mano and a chopper found at the
surface with indication of subsurface component.
< 0.5 mile
30-176770/NR-
02001725
Historic age—NRHP listed property (Historic Property)—Villa Park
School.
< 1 mile
30-160083/NR-
83001212
Historic age—NRHP listed property (Historic Property)—Smith and
Clark Brothers Ranch.
< 0.5 mile
Source: South Central Coastal Information Center, 2008.
Native American Heritage Commission Record Search
On October 6, 2008, FCS sent a letter to the NAHC in an effort to determine whether any sacred sites
are listed in their Sacred Lands File for this portion of the City of Orange. Our efforts were associated
with CEQA-level information scoping only. The response from the NAHC was received on October
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10, 2008. To ensure that all potential Native American resources are adequately addressed, letters
to each of the 12 listed tribal contacts were sent on November 3, 2008. FCS received an emailed
response from John Tommy Rosas, the Tribal Administrator for the Tongva Ancestral Territorial Tribal
Nation on November 3, 2008. Mr. Rosas indicated that the Tribe objected to the project, and that
development in that area violated their indigenous rights. He cited the project location along
Santiago Creek as an especially sensitive issue. Further, he noted the need for additional
consultation efforts as required by law, including Section 106 of the NHPA and SB 18. He also
requested additional information on the proposed project. FCS Project Archaeologist Jennifer M.
Sanka replied to this email, providing additional information on the Conceptual Development Plan
and asking for any information that could be included in the Cultural Resources Assessment
regarding the sanctity of Santiago Creek. This information was requested, as FCS was aware that
Santiago Creek and adjacent environs would be considered a culturally sensitive area to local Tribes.
This assumption is based upon the presence of numerous prehistoric-age sites along the Creek and a
known reliance on its resources by the indigenous people as outlined in ethnographic studies.
Paleontological Records Search
The paleontological records check was requested on October 6, 2008. A response was received on
October 31, 2008 from Dr. Samuel McLeod of the Vertebrate Paleontology Section of the Natural
History Museum of Los Angeles County. The paleontological review indicated that the lowest lying
portions of the Santiago Creek drainage consist of younger Quaternary alluvium, while the majority of
the surrounding acreage has surficial deposits of older Quaternary terrace sediments. The exception
is an area found on the north side of Santiago Creek that has exposures of undifferentiated deposits
of the Oligo-Miocene Sespe/Vaqueros Formations. These exposures have marine and non-marine
components (McLeod 2008).
Younger Quaternary alluvial deposits do not typically contain fossil resources, and no localities are
known from such deposits or similar deposits nearby. In contrast, localities are known within the
City of Orange from older Quaternary deposits at depth, and numerous localities are known within
the general vicinity, as well as within the project area from the Sespe/Vaqueros Formations. The
nearest locality from older Quaternary deposits is LACM 4943. This locality is recorded between
State Route 55 and the Santa Ana River, near the intersection of Glassell Street and Fletcher Avenue.
This locality yielded the fossilized remains of a horse (Equus) at depths of about 8 to 10 feet from the
modern ground surface. LACM 5449 is recorded in the northeastern portion of the project area from
exposures of the Sespe/Vaqueros Formations. This locality yielded the fossilized remains of an
undetermined carnivore (Carnivora) and camel (Camelidae). LACM 5450, 5451, and 6927 to 6930
are all known from the Sespe/Vaqueros Formations, and are found near the project area boundaries.
These localities have produced the fossil remains of an undetermined camel, skunk, rabbit, horse,
peccary, and oreodont. The presence of one locality within the project area and numerous localities
in the vicinity from sediments similar to those found within the project area aptly demonstrate the
fossil bearing potential of these sediments.
An updated paleontological records search was requested on November 21, 2017.
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Pedestrian Survey
FCS Project Archaeologist Jennifer M. Sanka, MA and FCS Senior Archaeologist Michael H. Dice, MA
surveyed the project area on October 9, 2008. The site was examined using a block transect
technique, with 10- to 15-meter spacing, where appropriate. Transect size was increased to the
north of Santiago Creek, in the westernmost portion and in the southwestern project corner because
of the presence of thicker ruderal vegetation, which resulted in lower accessibility and negligible
surface visibility. Santiago Creek could not be surveyed because of the presence of water and thick
vegetation; however, the sides of the bluffs were visually scrutinized in areas exhibiting visibility.
The southeastern corner of the project area was not surveyed because of active concrete recycling
activities. Transect size was decreased to about 5 meter spacing near the recorded location of
CA-ORA-369.
The majority of the project area consists of previously disturbed soils that have been subject to
historic era sand and gravel mining operations, as well as processing activities. Santiago Creek
trends east-west through the northern portion of the project area, and the remains of a concrete
bridge are found in the central portion, crossing the Creek. An active concrete recycling plant is
located in the southeastern corner, and several abandoned concrete pads and metal tanks are
located directly north of this area. Additional concrete pads and asphalt surfaces are surrounded by
a chain-link fence within the southwestern project corner. This asphalt and concrete lot is found
directly east of a concrete foundation of a no longer extant structure. The concrete and asphalt lot
and the foundation are found directly to the north of Santiago Canyon Road. The project area was
easily accessible from the entrance to the concrete recycling facility along Santiago Canyon Road.
Access could also be obtained through a chain-link fence gate and a dirt access road found along the
northern project boundary.
The project area exhibited varied surface visibility, ranging from poor to good. The surface visibility
was very poor in the northern portion, in Santiago Creek, in the eastern-most and westernmost
extensions, and in the southern-most, western corner. In these areas, visibility ranged from about 0
percent to 10 percent, due to the presence of dense vegetation. Visibility increased to about 50
percent in the central portion of the project area, and to about 100 percent along the dirt access
roads found throughout.
The soils observed in the project area along the dirt access roads consisted of small gravels not more
than 3 centimeters in diameter, found within a light brown alluvium. Numerous rock inclusions were
noted throughout, ranging in size from pebbles to cobbles. These inclusions were rounded due to
water-related erosion and some were angular. Concentrations of imported angular materials were
noted in the northeast corner, to the north of Santiago Creek, in the central portion of the project
area, and along the access roads in the southwesternmost project corner, westernmost extension
and to the north of the active concrete recycling facility. Additional angular rocks were noted along
the other access roads, and appeared to have been altered due to vehicular activity. A
concentration of concrete fragments was observed in the central portion of the project area. The
surface soils have been adversely impacted by vehicular activity, heavy machinery, historic-era sand
and gravel mining operations, active concrete recycling activities, and historic-era citrus cultivation.
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Furrows were observed in the northern and eastern-most extensions of the project area, and these
presumably relate to the past use of the project area for the production of citrus crops.
Relatively minimal modern refuse was noted throughout the project area, and was more prevalent in
the northern portion, along the northern boundary and in a vegetation-laden field in the southern
central portion. Observed refuse included plastic oil containers, clothing, a Christmas ornament, and
several full plastic trash bags presumably containing modern, domestic refuse.
During the pedestrian survey, no prehistoric-age resources and one potentially historic-age
foundation and an adjacent asphalt and concrete lot were detected. Portions of the concrete and
asphalt lot may be of historic age, and were recorded in conjunction with the foundation as Site 001.
In addition, previously recorded prehistoric-age resource CA-ORA-369 could not be relocated.
CA-ORA-369
CA-ORA-369 was originally recorded on October 13, 1972 by A. Marquette and J. Houser as a
prehistoric-age artifact scatter within an area cleared of vegetation (Marquette and Houser 1972).
At that time, the site consisted of a polyhedral core, shell scatter, flake waste and additional cores,
and measured approximately 300 meters by 300 meters. The mapped location of this site is found in
the northeastern quarter of the project area, to the north of Santiago Creek. The site was relocated
in 1976 by Drover as an extremely minimal prehistoric deposit (Drover 1976). Drover notes that the
site lacks interpretive data, and that it should be subsurface tested prior to any disturbance. This site
was then surface collected and tested for the presence of subsurface artifact deposits in 1979 (APC
1979). The Archaeological Planning Collaborative (APC) mapped the presence of surface artifacts,
conducted soil pH analysis, and then excavated two test units in areas proposed to be impacted by
the Deimer Pipeline Project. A total of 11 lithics, 12 shell fragments, three fire-affected rocks, and
one hammerstone were collected at the surface. Two lithics were recovered from the subsurface,
and no diagnostic artifacts or midden deposits were detected. Based upon this data, the site was
determined to be a surface scatter with little to no depth, and of no interpretive value for the
prehistory of the area. Rather, the site appeared to be a peripheral site related to the more
permanent sites found elsewhere along Santiago Creek. For this reason, the construction of the
pipeline was found to result in no significant loss of archaeological data, and APC suggested that the
site be avoided as much as possible during the installation of the pipeline (APC 1979). Based upon
the results of this subsurface testing program the interpretation of the data, the site does not appear
to be significant under the provisions of CEQA.
Historic Age Foundation/Concrete and Asphalt Lot (Site 001)
Located in the southwestern corner of the project area is a concrete foundation from a no longer
extant building and an adjacent concrete and asphalt lot surrounded by a chain-link fence. These
features are found directly to the north of Santiago Canyon Road, and presumably relate to the
previous use of portions of the project area for the production of citrus, and then as a sand and
gravel surface mining and processing center. The foundation and some of the concrete pads may
relate to the citrus groves that once occupied portions of the project area, and structures appear to
be present at this location in the Historic Era Aerial Photograph presented as Exhibit 3.5-1. The exact
date of the currently observable features are unknown, but portions of the site are of historic age
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based upon the results of the aerial photograph review. For this reason, all of the existing features
were recorded as constituents of an archaeological site.
The concrete foundation is currently surrounded by vegetation and filled with cut eucalyptus trees
and other assorted vegetation waste. Three of the four sides of the foundation are still extant, as
the northern side appears to be missing. Modern refuse was noted to the north of the foundation,
and a dirt road is found to the east. Eucalyptus windrows are found trending north-south, within the
general vicinity of the site. A concrete pad is located approximately 15 to 20 meters to the southeast
of the foundation, and no evidence of a date stamp was observed. A utility pole is also located near
this concrete pad, and the pole exhibits the identification number 718839E. This pole also exhibits
two nails, reading 25 and 48, from left to right. These presumably indicate that the pole is 25 feet
tall, and was either erected or inspected in 1948. It is probable that these features are represented
at the southern terminus of a north-south trending eucalyptus windrow. Their presence indicates
that at least some of the features in this area were present by 1952, and may indicate their
association with citrus production within the project area. Additional concrete pads were also noted
to the east of the foundation and utility pole, and some or all of these concrete pads may have been
contemporaneous to the foundation. These pads may have been reused, as they could have been
incorporated into the existing concrete and asphalt lot.
Located to the east of the concrete foundation and utility pole is a concrete and asphalt lot
surrounded by a chain-link fence. No date stamps could be located within this lot, despite the visual
scrutiny of the entire surface. This area has painted parking spaces in the western portion, a
concrete ramp/roll-off in the southwestern corner, and abandoned soil sorting equipment in the
central portion. One of the machines exhibits a conveyor belt, presumably used to sort the
aggregate, and the other machine retained a brand name that reads “Product of Deister Machine
Company, Fort Wayne, Indiana.”
According to the Deister Machine, Inc. website, Deister Machine is a family owned business that
began in Fort Wayne, Indiana in 1912. The company began with the construction of a separating
table, which used differential motion to separate ore from lighter particles. The ridges found on the
separating table caught the heavier ore, and then water was used to wash away the lighter soil
particles (Deister Machine, Inc. 2008). The machine present within the concrete and asphalt lot is
presumably a separating machine, and appears to be consistent with a product known as a
basemounted, step-deck vibrating grizzly. The product label present within the project area appears
to be consistent with relatively modern Deister product labels. However, the website does not
provide any information on the evolution of the Deister Machine, Inc. brand-name label.
This resource was recorded onto a Department of Parks and Recreation (DPR) 523 Form and was
submitted to the SCCIC for the assignment of a primary number. The site does not appear to be
significant and is considered neither a historical nor an archaeological resource for the purposes of
CEQA.
27650002 • 07/2018 | 3.5-1_arch_m o n ito rin g.m xd
Exhibit 3.5-1Archaeo lo gical an dPaleo n to lo gical Mo n ito rin g Areas
So urce: ESRI Aerial Im agery
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN RECIRCULATED DRAFT ENV IRONMENTAL IMPACT REPORT
E S a n t i a g o C a n y o n R d
NCanonSt SerranoAveM a b u r y AveETaftAve SantiagoCreekVilla ParkLandfill (Closed)
Linda VistaElementarySchool
OakridgePrivateSchool
Salem LutheranChurch and School
1,000 0 1,000500
Feet
Legend
Project Site
Archaeological and Paleontological Monitoring Areas
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A new pedestrian survey was conducted for the property on December 1, 2017. Most of the
property south of the creek has been heavily impacted from sand and gravel activities. Only one
small area in the southwest corner immediately east of a fenced construction yard could be
surveyed. However, in the northernmost section of the property, immediately south of Mabury
Street, is a relatively narrow strip of land in that general area where CA-ORA-369 was originally
recorded, ultimately tested, and found ineligible for the CR. Most of that part of the property had
been recently graded, exposing surface soils over most of the area, which were surveyed. The new
survey located a Fletcher’s Castoria bottle (ca. 1900–1930). No other historic period artifacts were
noted in the area. In the general area where CA-ORA-369 was located, a single Argopectin spp. shell
fragment was observed. No other prehistoric artifacts were observed. Neither artifact was collected
and no further work is recommended in the area of the two items. The 2008 investigation recorded
an old concrete foundation and adjacent asphalt and gravel lot. The site was not indicated on the
topographic records search map at the SCCIC, and no record of the site is on file with SCCIC. This is
likely the fenced lot across from Jamestown Way off of E. Santiago Canyon Road. At the time of its
recordation, it was deemed insignificant and no further work was recommended. The lot is currently
used for parking and various activities related to the mining. Nothing of historic significance was
observed within the fenced lot during the new survey.
Addendum to the Phase I Cultural Resources Assessment
BCR Consulting prepared an Addendum to the Phase I Cultural Resources Assessment, dated March
25, 2011. The Addendum addressed peer review comments, a revised project description, updated
information regarding local prehistoric cultural sequence and villages, expanded city history, and
more explicitly defined recommendations with a figure depicting monitoring areas.
Updated Native American Consultation
An updated Native American Consultation for the Rio Santiago Specific Plan Project was prepared by
BCR Consulting, dated May 12, 2011. Subsequently, on March 3, 2017, the City contacted three
tribes pursuant to AB 52. Each tribe was notified in writing of the proposed project and invited to
consult with the City. The letters were sent via certified mail, but to date the City has not received
any responses.
3.5.5 - Thresholds of Significance
According to Appendix G, Environmental Checklist, of the CEQA Guidelines, cultural resources
impacts resulting from the implementation of the proposed project would be considered significant
if the project would:
a) Cause a substantial adverse change in the significance of a historical resource as defined in
§15064.5?
b) Cause a substantial adverse change in the significance of an archaeological resource
pursuant to §15064.5?
c) Directly or indirectly destroy a unique paleontological resource or site or unique geologic
feature?
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d) Disturb any human remains, including those interred outside of formal cemeteries?
Additionally, Appendix G sets forth the following thresholds of significance for tribal cultural resources:
a) Would the project cause a substantial adverse change in the significance of a tribal cultural
resource, defined in Public Resources Code section 21074 as either a site, feature, place,
cultural landscape that is geographically defined in terms of the size and scope of the
landscape, sacred place, or object with cultural value to a California Native American tribe,
and that is:
b) Listed or eligible for listing in the California Register of Historical Resources, or in a local
register of historical resources as defined in Public Resources Code section 5020.1(k), or
c) A resource determined by the lead agency, in its discretion and supported by substantial
evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public
Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public
Resource Code Section 5024.1, the lead agency shall consider the significance of the
resource to a California Native American tribe.
3.5.6 - Project Impacts and Mitigation Measures
This section discusses potential impacts associated with the development of the project and
provides mitigation measures where appropriate.
Historic Resources
Impact CUL-1: Subsurface construction activities associated with the proposed project may
damage or destroy previously undiscovered historic resources.
Impact Analysis
The results of the cultural resource record search indicate that there is one previously recorded
resource within the project area boundaries, and a total of eleven resources within the search radius.
Eight prehistoric-age and three historic-age resources are recorded within 1 mile of the project area.
Two of the historic-age resources are NR listed properties, and these are located more than 0.25 mile
from the project area. However, these resources will not be affected by the proposed project.
Review of the 1896 United States Geological Survey (USGS) Anaheim, CA 30-minute and the 1902
(reprinted 1946) 30-minute Corona, Calif. Quadrangle maps revealed neither structures nor any
other development within the project area boundaries. The 1942 USGS Anaheim, Calif. 15-minute
Quadrangle map shows four structures along Santiago Canyon Road, along the southern project area
boundary. Four additional structures are depicted in the southeastern corner of the project area,
adjacent to a hammer and pick symbol. With the exception of one potentially historic-age
foundation and an adjacent concrete and asphalt lot, no evidence of these structures were detected
during the pedestrian survey.
During the pedestrian survey, no prehistoric-age resources and one potentially historic-age
foundation and an adjacent asphalt and concrete lot were detected. Portions of the concrete and
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asphalt lot may be of historic age, and were recorded in conjunction with the foundation as Site 001.
These features presumably relate to the previous use of the project area for citrus production and as
a surface mining and processing center. This resource was recorded onto a Department of Parks and
Recreation (DPR) 523 Form and was submitted to the SCCIC for the assignment of a primary number.
The site does not appear to be significant and is considered neither a historical nor an archaeological
resource for the purposes of CEQA. Therefore, the creation and submittal of the DPR 523 Form for
this resource fully suffices for mitigating potential impacts associated with the proposed project. An
additional DPR 523 Update Form was created for previously recorded resource CA-ORA-369, in an
effort to keep their files current. This resource could not be relocated during the present survey or
during previous surveys (LSA 1994; McKenna et al. 2000). This is presumably due to the negligible
surface visibility at the mapped location, and to the collection of some or all of the surface artifacts
during a subsurface testing program (APC 1979). This testing program yielded a small amount of
debitage, no diagnostic artifacts and no observable midden deposits. The site was determined to be
a surface scatter with little to no depth, and of no interpretive value for the prehistory of the area.
Based upon the results of this subsurface testing program and the interpretation of the data, the site
does not appear to be significant under the provisions of CEQA. Presently, the mapped location of
the site is within the portion of the project area proposed as open space. Therefore, minimal
impacts would occur to the remnants of the site, as its location would be entirely avoided by
development.
Based upon the results of the records search, where a previously recorded resource is known within
the project area, the location along Santiago Creek, which exhibits numerous prehistoric-age sites in
the region, and the negligible surface visibility during the pedestrian survey, FCS finds a high
probability that significant, intact subsurface deposits could be uncovered during development. This
potential is high within undisturbed or minimally disturbed portions of the project area and
significantly lower in areas that have been subject to historic-era surface mining and processing
activities. Therefore, the project area has been generally assigned high cultural resource sensitivity,
and FCS recommends archaeological monitoring in specific portions during development.
Monitoring during development would reduce project impacts to less than significant levels.
Level of Significance Before Mitigation
Potentially significant impact.
Mitigation Measures
MM CUL-1 In the event that buried cultural resources are discovered during construction,
operations shall stop within a 50-foot radius of the find and a qualified archaeologist
shall be consulted to determine whether the resource requires further study. The
qualified archaeologist and shall make recommendations to the Lead Agency on the
measures that shall be implemented to protect the discovered resources, including
but not limited to excavation of the finds and evaluation of the finds in accordance
with Section 15064.5 of the CEQA Guidelines. Potentially significant cultural
resources consist of but are not limited to stone, bone, fossils, wood, or shell
artifacts or features, including hearths, structural remains, or historic dumpsites.
Any previously undiscovered resources found during construction within the project
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area should be recorded on appropriate Department of Parks and Recreation (DPR)
forms and evaluated for significance in terms of CEQA criteria.
If the resources are determined to be unique historic resources as defined under
Section 15064.5 of the CEQA Guidelines, mitigation measures shall be identified by
the monitor in accordance with Public Resource Code Section 21083.1 and CEQA
Guidelines Section 15126.4 and recommended to the Lead Agency. Appropriate
mitigation measures for significant resources could include avoidance or capping,
incorporation of the site in green space, parks, or open space, or data recovery
excavations of the finds.
No further grading shall occur in the area of the discovery until the Lead Agency
approves the measures to protect these resources. Any archaeological artifacts
recovered as a result of mitigation shall be donated to a qualified scientific
institution approved by the Lead Agency where they would be afforded long-term
preservation to allow future scientific study.
Level of Significance After Mitigation
Less than significant impact.
Archaeological Resources
Impact CUL-2: Subsurface construction activities associated with the proposed project may
damage or destroy previously undiscovered archaeological resources.
Impact Analysis
As addressed in Impact CUL-1, the archaeological records search identified one previously recorded
resource within the project boundary. Additionally, portions of the concrete and asphalt lot may be
of historic age. Based upon the results of the records search, where a previously recorded resource
is known within the project area, the location along Santiago Creek, which exhibits numerous
prehistoric-age sites in the region, and the negligible surface visibility during the pedestrian survey,
FCS finds a high probability that significant, intact subsurface deposits could be uncovered during
development. A qualified archaeologist shall be contacted to assess the nature and significance of a
find in the event an archaeological resource is recovered, as addressed in Mitigation Measure CUL-1.
The implementation of this mitigation measure will ensure that construction shall stop in the vicinity
of any potential resource until the significance of the resource is confirmed, and will ensure that
significant resources will be avoided or excavated and preserved. With implementation of
mitigation, impacts associated with archaeological resources would be less than significant.
Additionally, the 2011 Addendum prepared by BCR Consulting indicated that archaeological
monitoring is required during ground disturbing activities within the areas depicted on Exhibit 3.5-1.
As such, Mitigation Measure CUL-2 requires monitoring within these areas during disturbing
activities. With implementation of mitigation, impacts associated with archaeological resources
would be less than significant.
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Level of Significance Before Mitigation
Potentially significant impact.
Mitigation Measures
Implement Mitigation Measure CUL-1 and:
MM CUL-2 During the ground disturbing activities in the areas depicted in Exhibit 3.5-1, a
qualified archaeological and paleontological monitor shall be present on-site to
observe earthwork activities. In the event of a discovery of an archaeological or
paleontological resource, the monitor shall have the discretion to halt all ground
disturbing activities within 50 feet of the find until it has been evaluated for
significance. If the find is determined to have archaeological or paleontological, the
procedures in Mitigation Measure CUL-1 or Mitigation Measure CUL-3 shall be
implemented. Monitoring may cease once all of the areas depicted in Exhibit 3.5-1
have been thoroughly disturbed.
Level of Significance After Mitigation
Less than significant impact.
Paleontological Resources
Impact CUL-3: Subsurface construction activities associated with the proposed project may
damage or destroy previously undiscovered paleontological resources.
Impact Analysis
The paleontological review indicated that the lowest lying portions of the Santiago Creek drainage
consist of younger Quaternary alluvium, while the majority of the surrounding acreage has surficial
deposits of older Quaternary terrace sediments. These exposures have marine and non-marine
components. The records check indicated that localities are known from such deposits and are
known within the City of Orange.
Based upon the results of this review, it is possible that significant paleontological resources may be
adversely impacted by development-related ground disturbance. Therefore, FCS has determined
that the project area has varied paleontologic sensitivity, ranging from low to high. This potential is
considered low in the younger Quaternary deposits, and high for older Quaternary terrace deposits
at depth and for any exposures of the Sespe/Vaqueros Formations. A paleontologic monitoring
program is recommended by FCS to mitigate potential adverse impacts to paleontological resources
in the older Quaternary terrace deposits at depth and in any exposures of the Sespe/Vaqueros
Formations. A monitoring program for excavation should be developed prior to any grading within
the project area, and should be consistent with the provisions of CEQA. Implementation of the
paleontological monitoring program would reduce project impacts to less than significant levels.
Additionally, the 2011 Addendum prepared by BCR Consulting indicated that paleontological
monitoring is required during ground disturbing activities within the areas depicted on Exhibit 3.5-1.
An updated paleontological records search conducted in November of 2017 supports this conclusion.
As such, Mitigation Measure CUL-2 requires monitoring within these areas during ground-disturbing
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activities. With implementation of mitigation, impacts associated with paleontological resources
would be less than significant.
Level of Significance Before Mitigation
Potentially significant impact.
Mitigation Measures
MM CUL-3 If the subsurface excavations for this project are proposed to exceed depths of 15
feet below surface, a qualified paleontological monitor should be retained to
observe such excavations, which may breach the older Quaternary Alluvium
deposits. In this situation, a detailed Mitigation Monitoring Plan (MMP) or
Paleontological Resource Impact Management Plan (PRIMP) should be prepared in
order to set forth the observation, collection, and reporting duties of the
paleontological monitor. Additional mitigation measures and procedures will be
outlined in the MMP or PRIMP as needed.
In the event that fossils or fossil-bearing deposits are discovered during construction
activities that are shallower than 10 feet in depth, excavations within a 50-foot
radius of the find shall be temporarily halted or diverted. The project contractor
shall notify a qualified paleontologist to examine the discovery. The paleontologist
shall document the discovery as needed (in accordance with Society of Vertebrate
Paleontology standards), evaluate the potential resource, and assess the significance
of the find under the criteria set forth in CEQA Guidelines Section 15064.5.
The paleontologist shall notify the appropriate agencies to determine procedures
that would be followed before construction activities are allowed to resume at the
location of the find. If the Applicant determines that avoidance is not feasible, the
paleontologist shall prepare an excavation plan for mitigating the effect of
construction activities on the discovery. The plan shall be submitted to the Lead
Agency for review and approval prior to implementation, and the Applicant shall
adhere to the recommendations in the plan.
Level of Significance After Mitigation
Less than significant impact.
Burial Sites
Impact CUL-4: Subsurface construction activities associated with the proposed project may
damage or destroy previously undiscovered human burial sites.
Impact Analysis
There are no existing or known formal cemeteries within or adjacent to the project site. As a result,
project implementation is not anticipated to impact human remains associated with either a formal
or informal cemetery. However, there is always the possibility that ground-disturbing activities
during construction may uncover previously unknown buried human remains. Should this occur, the
procedures set forth in Public Resource Code Section 5097.98 would apply and are reflected in
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Mitigation Measure CUL-4. Implementation of this mitigation measure would reduce impacts to a
level of less than significant.
Level of Significance Before Mitigation
Potentially significant impact.
Mitigation Measures
MM CUL-4 In the event of an accidental discovery or recognition of any human remains, Public
Resource Code (PRC) Section 5097.98 must be followed. In this instance, once project-
related earthmoving begins and if there is accidental discovery or recognition of any
human remains, the following steps shall be taken:
1. There shall be no further excavation or disturbance of the site or any nearby area
reasonably suspected to overlie adjacent human remains until the County
Coroner is contacted to determine if the remains are Native American and if an
investigation of the cause of death is required. If the coroner determines the
remains to be Native American, the coroner shall contact the NAHC within 24
hours, and the Native American Heritage Commission (NAHC) shall identify the
person or persons it believes to be the “most likely descendant” of the deceased
Native American. The most likely descendant may make recommendations to
the landowner or the person responsible for the excavation work, for means of
treating or disposing of, with appropriate dignity, the human remains and any
associated grave goods as provided in PRC Section 5097.98, or
2. Where the following conditions occur, the landowner or his/her authorized
representative shall rebury the Native American human remains and associated
grave goods with appropriate dignity either in accordance with the
recommendations of the most likely descendent or on the project area in a
location not subject to further subsurface disturbance:
• The NAHC is unable to identify a most likely descendent or the most likely
descendent failed to make a recommendation within 48 hours after being
notified by the commission;
• The descendent identified fails to make a recommendation; or
• The landowner or his authorized representative rejects the recommendation
of the descendent, and the mediation by the NAHC fails to provide measures
acceptable to the landowner.
Level of Significance After Mitigation
Less than significant impact.
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3.6 - Geology and Soils
This section describes the existing geology, soils, and seismicity setting and potential effects from
project implementation on the project site and its surrounding area. Descriptions and analysis in
this section are based on information contained in the Geotechnical Investigation prepared by Ginter
& Associates, Inc., which is provided in Appendix I.
3.6.1 - Existing Conditions
Regional Geology
The project site is situated in the northeastern portion of the Peninsular Ranges Geomorphic
Province at an average elevation of approximately 400 feet above mean sea level and subjacent to
the Santa Ana Mountains, which rise to the east to more than 3,000 feet above mean sea level.
Santiago Creek, which flows through the site, transports sediments and forms coalescing alluvial
fans, resulting in a broad surface that slopes away from the hills toward the Pacific Ocean to the
southwest.
Seismic Hazards
Faulting
Faults form in rocks when stresses overcome the internal strength of the rock, resulting in a fracture.
Large faults develop in response to large regional stresses operating over a long time, such as those
stresses caused by the relative displacement between tectonic plates. According to the elastic
rebound theory, these stresses build up in the earth’s crust until enough stress has built up to exceed
the strength along a fault and cause a brittle failure. The rapid slip between the two stuck plates or
coherent blocks generates an earthquake. Following an earthquake, stress will build once again until
the occurrence of another earthquake. The magnitude of slip is related to the maximum allowable
stress that can be built up along a particular fault segment. The greatest buildup in stress due to the
largest relative motion between tectonic plates or fault blocks over the longest period will generally
produce the largest earthquakes. The distribution of these earthquakes is a study of much interest
for both hazard prediction and the study of active deformation of the earth’s crust. Deformation is a
complex process and strain caused by tectonic forces is not only accommodated through faulting,
but also by folding, uplift, and subsidence, which can be gradual or in direct response to
earthquakes.
Faults are mapped to determine earthquake hazards, since they occur where earthquakes tend to
recur. A historic plane of weakness is more likely to fail under stress than a previously unbroken
block of crust. Faults are, therefore, a prime indicator of past seismic activity, and faults with recent
activity are presumed to be the best candidates for future earthquakes. However, since slip is not
always accommodated by faults that intersect the surface along traces, and since the orientation of
stress and strain in the crust can shift, predicting the location of future earthquakes is complicated.
Earthquakes sometimes occur in areas with previously undetected faults or along faults previously
thought inactive.
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Local Faulting
The City of Orange is located in the seismically active southern California region. The largest faults in
the region include the Whittier-Elsinore fault, the Newport-Inglewood fault, the San Andreas fault,
and the San Jacinto fault. The northwestward flow of the Pacific Plate mantle is now driving the
collision between the Peninsular Ranges block and the Sierra-Great Valley provinces of the North
American plate.
There are no active faults known to pass through the project site. In addition, there are no Alquist-
Priolo Fault Zones in the immediate project vicinity. The nearest, known active faults are the Peralta
Hills thrust fault located approximately 0.1 mile northeast of the project site, and the El Modeno
fault located approximately 0.43 mile southwest of the project site.
Seismic Hazards
Potential seismic hazards resulting from a nearby moderate to major earthquake can generally be
classified as primary and secondary. The primary effect is ground rupture, also called surface
faulting. The common secondary seismic hazards include ground shaking, ground lurching, soil
liquefaction, and lateral spreading. These hazards are discussed individually.
Fault Rupture
Fault rupture is a seismic hazard that affects structures sited above an active fault. The hazard from
fault rupture is the movement of the ground surface along a fault during an earthquake. Typically,
this movement takes place during the short time of an earthquake but can also occur slowly over
many years in a process known as creep. Most structures and underground utilities cannot
accommodate the surface displacements of several inches to several feet commonly associated with
fault rupture or creep. As previously indicated, no active faults are known to pass through the
project site. In addition, there are no Alquist-Priolo Fault Zones in the immediate project vicinity.
Ground Shaking
The severity of ground shaking depends on several variables such as earthquake magnitude,
epicenter distance, local geology, thickness, and seismic wave-propagation properties of
unconsolidated materials, groundwater conditions, and topographic setting. Ground shaking
hazards are most pronounced in areas near faults or with unconsolidated alluvium.
The most common type of damage from ground shaking is structural damage to buildings, which can
range from cosmetic cracks to total collapse. The overall level of structural damage from a nearby
large earthquake would likely be moderate to heavy, depending on the characteristics of the
earthquake, the type of ground, and the condition of the building. Besides damage to buildings,
strong ground shaking can cause severe damage from falling objects or broken utility lines. Fire and
explosions are also hazards associated with strong ground shaking.
Ground Failure
Ground failure includes liquefaction and the liquefaction-induced phenomena of lateral spreading,
and lurching.
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Liquefaction is a process by which sediments below the water table temporarily lose strength during
an earthquake and behave as a viscous liquid rather than a solid. Liquefaction is restricted to certain
geologic and hydrologic environments, primarily recently deposited sand and silt in areas with high
groundwater levels. The process of liquefaction involves seismic waves passing through saturated
granular layers, distorting the granular structure, and causing the soil to densify.
Liquefaction can cause the soil beneath a structure to lose strength, which may result in the loss of
foundation-bearing capacity and which could cause a structure to settle or tip. Liquefaction can also
result in the settlement of large areas because of the densification of the liquefied deposit. Where
structures are located within liquefied deposits, the liquefaction can result in the structure to rise as
a result of buoyancy.
According to the California Geological Survey Liquefaction Hazard Zoning Map, the project site is
located within a liquefaction hazard zone. A Liquefaction Evaluation Report prepared for the Orange
7.5-minute quadrangle, Orange County, California indicated that areas where younger fan deposits
and active wash deposits are included in liquefaction hazard zones. The liquefaction potential for
the project site is low to moderate.
Lateral spreading is lateral ground movement, with some vertical component, as a result of
liquefaction. In effect, the soil rides on top of the liquefied layer. Lateral spreading can occur on
relatively flat sites with slopes less than 2 percent, under certain circumstances, and can cause
ground cracking and settlement. Lurching is the movement of the ground surface toward an open
face when the soil liquefies. An open face could be a graded slope, stream bank, canal face, gully, or
other similar feature.
Landslides and Slope Failure
Landslides and other forms of slope failure form in response to the long-term geologic cycle of uplift,
mass wasting, and disturbance of slopes. Mass wasting refers to a variety of erosional processes
from gradual downhill soil creep to mudslides, debris flows, landslides, and rock fall. These
processes are commonly triggered by intense precipitation. Seismic activity can also trigger
landslides and rockfalls.
Often, various forms of mass wasting are grouped together as landslides, which are generally used to
describe the downhill movement of rock and soil. Geologists classify landslides into several different
types that reflect differences in the type of material and type of movement. The four most common
types of landslides are translational, rotational, earth flow, and rock fall. Debris flows and earth
flows are another type of landslide that are characterized by soil and rock particles in suspension
with water and which often move with considerable speed. Debris flows often refer to flows that
contain coarser soil and rock materials while earth flows frequently refer to slides that are
predominantly finer materials. Mudslide is a term that appears in non-technical literature to
describe a variety of shallow, rapidly moving earth flows.
According to the City of Orange General Plan EIR, the project site is not located within a landslide
hazard area as mapped on the Environmental and Natural Hazard Policy map. The project site is not
located within the vicinity of large hills or steep mountainsides.
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Soils
The United States Department of Agriculture Natural Resources Conservation Service Web Soil
Survey maps the project site as containing pits, Modjeska gravelly loam, Soboba gravelly loamy sand,
and Botella clay loam. Table 3.6-1 summarizes the soils that underlie the project site.
Table 3.6-1: Soil Summary
Soil Landform Parent Material Drainage Class
Pits* — — —
Modjeska gravelly loam, 2 to 9
percent slopes
Terraces Alluvium derived from mixed Well drained
Soboba gravelly loamy sand, 0 to 5
percent slopes
Alluvial fans Sandy and gravelly alluvium
derived from mixed
Excessively drained
Botella clay loam, 2 to 9 percent
slopes
Alluvial fans Alluvium derived from
sedimentary rock
Well drained
Note:
* Signifies that area has been surface mined
Source: United States Department of Agriculture, 2016.
3.6.2 - Regulatory Setting
Federal
National Earthquake Hazards Reduction Program
The National Earthquake Hazards Reduction Program (NEHRP) was established by the U.S. Congress
when it passed the Earthquake Hazards Reduction Act of 1977, Public Law 95–124. In establishing
the NEHRP, Congress recognized that earthquake-related losses could be reduced through improved
design and construction methods and practices, land use controls and redevelopment, prediction
techniques and early warning systems, coordinated emergency preparedness plans, and public
education and involvement programs. The four basic goals remain unchanged:
• Develop effective practices and policies for earthquake loss reduction and accelerate their
implementation.
• Improve techniques for reducing earthquake vulnerabilities of facilities and systems.
• Improve earthquake hazards identification and risk assessment methods, and their use.
• Improve the understanding of earthquakes and their effects.
Several key federal agencies contribute to earthquake mitigation efforts. There are four primary
NEHRP agencies:
• National Institute of Standards and Technology of the Department of Commerce
• National Science Foundation
• United States Geological Survey (USGS) of the Department of the Interior
• Federal Emergency Management Agency (FEMA) of the Department of Homeland Security
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Implementation of NEHRP priorities is accomplished primarily through original research,
publications, and recommendations to assist and guide state, regional, and local agencies in the
development of plans and policies to promote safety and emergency planning.
State
Alquist-Priolo Earthquake Fault Zoning Act
The Alquist-Priolo Earthquake Fault Zoning Act (Public Resources Code [PRC] Sections 2621 to 2630)
was passed in 1972 to provide a statewide mechanism for reducing the hazard of surface fault
rupture to structures used for human occupancy. The main purpose of the Act is to prevent the
siting of buildings used for human occupancy across the traces of active faults. It should be noted
that the Act addresses the potential hazard of surface fault rupture and is not directed toward other
earthquake hazards, such as seismically induced ground shaking or landslides.
The law requires the State Geologist to identify regulatory zones (known as Earthquake Fault Zones
or Alquist-Priolo Zones) around the surface traces of active faults, and to depict these zones on
topographic base maps, typically at a scale of 1 inch to 2,000 feet. Earthquake Fault Zones vary in
width, although they are often 0.75 mile wide. Once published, the maps are distributed to the
affected cities, counties, and State agencies for their use in planning and controlling new or renewed
construction. With the exception of single-family wood-frame and steel-frame dwellings that are not
part of a larger development (four units or more), local agencies are required to regulate
development within the mapped zones. In general, construction within 50 feet of an active fault
zone is prohibited.
Seismic Hazards Mapping Act
The Seismic Hazards Mapping Act (PRC Sections 2690 to 2699.6), which was passed in 1990,
addresses earthquake hazards other than surface fault rupture. These hazards include strong
ground shaking, earthquake-induced landslides, liquefaction, or other ground failures. Much like the
Alquist-Priolo Earthquake Fault Zoning Act discussed above, these seismic hazard zones are mapped
by the State Geologist to assist local government in the land use planning process. The Act states, “it
is necessary to identify and map seismic hazard zones in order for cities and counties to adequately
prepare the safety element of their general plans and to encourage land use management policies
and regulations to reduce and mitigate those hazards to protect public health and safety.” The Act
also states, “cities and counties shall require, prior to the approval of a project located in a seismic
hazard zone, a geotechnical report defining and delineating any seismic hazard.”
California Building Code
The State of California provides minimum standards for building design through the California
Building Standards Code (California Code of Regulations, Title 24). Where no other building codes
apply, Chapter 29 regulates excavation, foundations, and retaining walls. The California Building
Standards Code applies to building design and construction in the state and is based on the federal
Uniform Building Code used widely throughout the country (generally adopted on a state-by-state or
district-by-district basis). The Building Code has been modified for California conditions with more
detailed and/or more stringent regulations.
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The State’s earthquake protection law (California Health and Safety Code Section 19100, et seq.)
requires that structures be designed to resist stresses produced by lateral forces caused by wind and
earthquakes. Specific minimum seismic safety and structural design requirements are set forth in
Chapter 16 of the Building Code. The Building Code identifies seismic factors that must be
considered in structural design. Chapter 18 of the Building Code regulates the excavation of
foundations and retaining walls, and Appendix Chapter A33 regulates grading activities, including
drainage and erosion control and construction on unstable soils, such as expansive soils and areas
subject to liquefaction.
The Building Code is updated every 3 years, and the current 2016 CBC took effect January 1, 2017.
Local Regulations
City of Orange
General Plan
The City of Orange set forth the following goals, objective, and policies that are relevant to geology,
soils, and seismicity:
Public Safety Element
• Goal 1.0: Protect residents and businesses from seismic hazards and other geologic constraints.
• Policy 1.1: Minimize the potential loss of life and damage to structures that may result from
an earthquake.
• Policy 1.2: Educate and train individuals and neighborhoods how to respond to emergency
situations.
Infrastructure Element
• Goal 5.0: Ensure lifeline infrastructure systems that meet the City’s public health and safety
needs.
• Policy 5.3: Identify engineering vulnerabilities in lifeline utilities exposed to human caused and
natural hazards, including seismic activity, wildland fire, and flooding.
• Policy 5.5: Review and limit the location and intensity of development and placement of
lifeline infrastructure in identified earthquake fault zones.
City of Orange Grading Requirements
The City’s Municipal Code, Section 17.10.90 describes rules and regulations to control erosion
associated with grading activities.
3.6.3 - Methodology
FCS relied upon the Geotechnical Investigation prepared by Ginter & Associates, Inc., which is
provided in Appendix I. FCS also obtained from sources including the City of Orange General Plan,
the California Department of Conservation, and the United States Department of Agriculture Natural
Resources Conservation Service Web Soil Survey. Additionally, FCS performed a preliminary site visit
in which photos and additional notes were taken about the site and its surroundings. A Geotechnical
Report was not prepared as a part of the proposed project, but future design-level geotechnical
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investigations will be required once development under the Specific Plan is ready to proceed, prior
to the issuance of building permits.
3.6.4 - Thresholds of Significance
According to the CEQA Guidelines’ Appendix G Environmental Checklist, to determine whether
impacts to geology and soils are significant environmental effects, the following questions are
analyzed and evaluated. Would the project:
a) Expose people or structures to potential substantial adverse effects, including the risk of
loss, injury or death involving:
i. Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo
Earthquake Fault Zoning Map issued by the State Geologist for the area or based on
other substantial evidence of a known fault? Refer to Division of Mines and Geology
Special Publication 42.
ii. Strong seismic ground shaking?
iii. Seismic-related ground failure, including liquefaction?
iv. Landslides?
b) Result in substantial soil erosion or the loss of topsoil?
c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a
result of the project, and potentially result in on- or off-site landslide, lateral spreading,
subsidence, liquefaction or collapse?
d) Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code
(1994), creating substantial risks to life or property?
e) Have soils incapable of adequately supporting the use of septic tanks or alternative
wastewater disposal systems where sewers are not available for the disposal of wastewater?
3.6.5 - Project Impacts and Mitigation Measures
This section discusses potential impacts associated with the proposed project and provides
mitigation measures where necessary.
Earthquakes
Impact GEO-1: The project may expose people or structures to potential substantial adverse
effects, including the risk of loss, injury or death involving seismic hazards.
Impact Analysis
This impact assesses the potential for the proposed project to expose people or structures to
potential substantial adverse effects involving seismic hazards.
Fault Rupture
As mentioned previously, no known active faults have been mapped on the project site; however,
both the El Modeno and Peralta Hills faults are located less than 0.5 mile from the project site. A
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1991 fault investigation prepared by Pacific Soils Engineering, Inc. concluded that an inferred trace of
the El Modeno Fault does not cross the project site. Furthermore, the El Modeno fault is considered
inactive. Similarly, the Peralta Hills Fault was found to not be sufficiently active under the Alquist-
Priolo Special Studies Zone Act by the California Division of Mines and Geology. For these reasons,
the development of the proposed project would not expose persons or structures to fault rupture
hazards. Impacts would be less than significant.
Strong Ground Shaking
The southern California region is considered seismically active. Small earthquakes occur within the
region every year, and large earthquakes have occurred and are expected to occur in the future.
Based on the proximity of the site to known active seismic sources, it should be expected that the
site will experience moderately strong to strong seismic ground shaking during the project’s lifetime.
To mitigate the ground shaking effects, all structures shall be designed using sound engineering
judgment and the latest Building Code requirements as a minimum. At the time of this writing, a
design-level geotechnical report for the Project was not available. Such a report would provide
recommendations on the appropriate level of soil engineering and building design necessary to
minimize ground-shaking hazards. Accordingly, Mitigation Measure GEO-1 is proposed requiring the
applicant to submit such a study to Orange County for review and approval prior to proceeding with
development consistent with the Specific Plan analyzed in this EIR. The implementation of this
mitigation measure would ensure that impacts related to strong ground shaking hazards would be
less than significant.
Ground Failure and Liquefaction
As indicated above, the potential for liquefaction for the entire project site is considered low to
moderate. The 1997 Seismic Hazard Zone prepared for the project site and its surrounding area
concluded that the liquefaction potential for the project site is nominal. However, because of the
proposed project’s location to Santiago Creek, the potential for liquefaction should be further
explored and addressed during a design-level geotechnical exploration.
Landslides
The project site is not located within the vicinity of large hills or steep mountainsides. Because of
the lack of significant topography, land sliding is not expected on the project site. Therefore, no
impact is anticipated related to land sliding.
Level of Significance Before Mitigation
Potentially significant impact.
Mitigation Measures
MM GEO-1 Prior to the issuance of building permits, the project applicant shall submit a design-
level Geotechnical Investigation to City of Orange for review and approval. The
investigation shall be prepared by a qualified engineer and identify grading and
building practices necessary to achieve compliance with the latest adopted edition
of the California Building Standards Code’s geologic, soils, and seismic requirements.
The measures identified in the approved report shall be incorporated into the
Project plans.
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Level of Significance After Mitigation
Less than significant impact.
Erosion
Impact GEO-2: The project will result in substantial soil erosion or the loss of topsoil.
Impact Analysis
The project would involve the development of residential uses on 40.7 acres of the project site and
open space and recreation uses on the remaining acreage. Development activities would involve
vegetation removal, grading, soil engineering, and other activities that have the potential to result in
erosion. If left unabated, the accumulation of sediment in downstream waterways could result in
the blockage of flows, potentially causing increased localized ponding or flooding. However, as
detailed in Section 3.9, Hydrology and Water Quality, the project will be subject to the City’s existing
regulations requiring implementation of stormwater quality control measures during construction
activities. Some pollution prevention practices include erosion control measures such as backflow
prevention devices and vegetating disturbed areas, which would prevent soil and sediment from
entering downstream waterways. These pollution prevention measures are incorporated into
Mitigation Measure HYD-1a.
In summary, through the implementation of Mitigation Measures GEO-1 and HYD-1a, impacts from
erosion would be less than significant.
Level of Significance Before Mitigation
Potentially significant impact.
Mitigation Measures
Implement Mitigation Measure GEO-1 and HYD-1a.
Level of Significance After Mitigation
Less than significant impact.
Unstable Geologic Units or Soils
Impact GEO-3: The project would not be located on a geologic unit or soil that is unstable, or that
would become unstable as a result of the project, and potentially result in on- or
off-site landslide, lateral spreading, subsidence, liquefaction or collapse.
Impact Analysis
The project site is underlain by terraces and alluvial fans near Santiago Creek. Terraces and alluvium
are considered stable and suitable to support urban development. Standard grading and soil
engineering practices would be required for compliance with state and local building code standards,
and thus are not included separately as mitigation. Compliance with these mandatory standards
would ensure that project foundations were adequately supported and are not at risk of failure due
to unstable geologic units or soils. Impacts would be less than significant.
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Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
Expansive Soil
Impact GEO-4: The project would not be located on expansive soil, as defined in Table 18-1-B of
the Uniform Building Code (1994), creating substantial risks to life or property.
Impact Analysis
The project site is underlain by Modjeska gravelly loam (2 to 9 percent slopes), which is well-drained
in mixed alluvium on terraces; Soboba gravelly loam (0 to 5 percent slopes), an excessively drained
soil formed in alluvium from granitic rocks; and Botella clay loam (2 to 9 percent slopes), a well-
drained soil formed in alluvial material from sedimentary rocks. The majority of the soils on-site
consist of gravelly and stony sands with low clay content. Moreover, the project site previously
supported aggregate mining (sand and gravel). As such, these soil types do not retain water in a
manner such that they would have a substantial shrink-swell potential. Additionally, standard
grading and soil engineering practices would be performed in accordance with state and local
building code standards to ensure that expansive soils do not pose a risk to structures developed
under the Specific Plan. Impacts would be less than significant.
Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
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3.7 - Greenhouse Gas Emissions
This section describes the existing greenhouse gas (GHG) emissions setting and potential effects
from project implementation on the project site and its surrounding area. Descriptions and analysis
in this section are based on information provided by the California Emissions Estimator Model
(CalEEMod), Version 2016.3.2 was used to quantify project-related emissions. The CalEEMod results
used to support the GHG analysis are included in this Draft EIR as part of Appendix F.
3.7.1 - Existing Conditions
Climate Change
Climate change is a change in the average weather of the earth that is measured by alterations in wind
patterns, storms, precipitation, and temperature. These changes are assessed using historical records
of temperature changes occurring in the past, such as during previous ice ages. This data is used to
extrapolate a level of statistical significance specifically focusing on temperature records from the last
150 years (the Industrial Age) that differ from previous climate changes in rate and magnitude.
The United Nations Intergovernmental Panel on Climate Change (IPCC) constructed several emission
trajectories of GHGs needed to stabilize global temperatures and climate change impacts. In its Fourth
Assessment Report, the IPCC predicted that the global mean temperature change from 1990 to 2100,
given six scenarios, could range from 1.1 degrees Celsius (°C) to 6.4°C. Regardless of analytical
methodology, global average temperatures and sea levels are expected to rise under all scenarios (IPCC
2007a). The report also concluded that “[w]arming of the climate system is unequivocal,” and that
“[m]ost of the observed increase in global average temperatures since the mid-20th century is very
likely due to the observed increase in anthropogenic greenhouse gas concentrations.”
An individual project cannot generate huge amount of GHG emissions to effect a significant change
in global climate. However, the project participates in the potential for global climate change by its
incremental contribution of GHGs combined with the cumulative increase of all other sources of
GHGs, which when taken together constitute potential influences on global climate change.
Consequences of Climate Change in California
In California, climate change may result in consequences such as the following (from CCCC 2006 and
Moser et. al 2009).
• A reduction in the quality and supply of water from the Sierra snowpack. If heat-trapping
emissions continue unabated, more precipitation will fall as rain instead of snow, and the
snow that does fall will melt earlier, reducing the Sierra Nevada spring snowpack by as much
as 70 to 90 percent. This can lead to challenges in securing adequate water supplies. It can
also lead to a potential reduction in hydropower.
• Increase risk of large wildfires. If rain increases as temperatures rise, wildfires in the
grassland and chaparral ecosystems of Southern California are estimated to increase by
approximately 30 percent toward the end of the 21st century because more winter rain will
stimulate the growth of more plant “fuel” available to burn in the fall. In contrast, a hotter,
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drier climate could promote up to 90 percent more Northern California fires by the end of the
century by drying out and increasing the flammability of forest vegetation.
• Reductions in the quality and quantity of certain agricultural products. The crops and
products likely to be adversely affected include wine grapes, fruit, nuts and milk.
• Exacerbation of air quality problems. If temperatures rise to the medium warming range,
there could be 75 to 85 percent more days with weather conducive to ozone formation in Los
Angeles and the San Joaquin Valley, relative to today’s conditions. This is more than twice the
increase expected if rising temperatures remain in the lower warming range. This increase in
air quality problems could result in an increase in asthma and other health-related problems.
• A rise in sea levels resulting in the displacement of coastal businesses and residences. During
the past century, sea levels along California’s coast have risen about seven inches. If emissions
continue unabated and temperatures rise into the higher anticipated warming range, sea level is
expected to rise an additional 22 to 35 inches by the end of the century. Elevations of this
magnitude would inundate coastal areas with salt water, accelerate coastal erosion, threaten
vital levees and inland water systems, and disrupt wetlands and natural habitats.
• An increase temperature and extreme weather events. Climate change is expected to lead to
increases in the frequency, intensity, and duration of extreme heat events and heat waves in
California. More heat waves can exacerbate chronic disease or heat-related illness.
• A decrease in the health and productivity of California’s forests. Climate change can cause
an increase in wildfires, an enhanced insect population, and establishment of non-native
species.
Consequences of Climate Change in the Orange County
Figure 3.7-1 displays a chart of measured historical and projected annual average temperatures in
the Orange County area. As shown in the figure, temperatures are expected to rise in the low and
high GHG emissions scenarios. The results indicate that temperatures are predicted to increase by
3.6 degrees Fahrenheit (°F) under the low-emissions scenario, and 6.1°F under the high emissions
scenario (Cal Adapt 2016).
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Figure 3.7-1: Observed and Projected Temperatures for Climate Change in the Orange
County Area
Source: CalAdapt 2016.
Human Health Effects of GHG Emissions
GHG emissions from development projects would not result in concentrations that would directly
impact public health. However, the cumulative effects of GHG emissions on climate change have the
potential to cause adverse effects to human health.
The U.S. Global Change Research Program in its report, Global Climate Change Impacts in the U.S.
(2009) has analyzed the degree to which impacts on human health are expected to impact the
United States.
Potential effects of climate change on public health includes:
• Direct Temperature Effects: Climate change may directly affect human health through
increases in average temperatures, which are predicted to increase the incidence of heat
waves and hot extremes.
• Extreme Events: Climate change may affect the frequency and severity of extreme weather
events, such as hurricanes and extreme heat and floods, which can be destructive to human
health and well-being.
• Climate-Sensitive Diseases: Climate change may increase the risk of some infectious diseases,
particularly those diseases that appear in warm areas and are spread by mosquitoes and
other insects, such as malaria, dengue fever, yellow fever and encephalitis.
• Air Quality: Respiratory disorders may be exacerbated by warming-included increases in the
frequency of smog (ground-level ozone) events and particulate air pollution (EPA 2009a).
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Although there could be health effects resulting from changes in the climate and the consequences
that can occur, inhalation of GHGs at levels currently in the atmosphere would not result in adverse
health effects, with the exception of ozone and aerosols (particulate matter). The potential health
effects of ozone and particulate matter are discussed in criteria pollutant analyses.
Climate Change
Global climate change is defined as the change in average meteorological conditions on the earth
with respect to temperature, precipitation, and storms. Global climate change is currently one of
the most controversial environmental issues in the United States, and much debate exists within the
scientific community about whether or not global climate change is occurring naturally or as a result
of human activity. Some data suggests that global climate change has occurred in the past over the
course of thousands or millions of years. These historical changes to Earth’s climate have occurred
naturally without human influence, as in the case of an ice age. However, many scientists believe
that the climate-shift taking place since the industrial revolution (1900) is occurring at a quicker rate
and magnitude than in the past. Scientific evidence suggests that global climate change is the result
of increased concentrations of GHGs in Earth’s atmosphere, including carbon dioxide (CO2),
methane (CH4), nitrous oxide (N2O), and fluorinated gases. Many scientists believe that this
increased rate of climate change is the result of GHGs resulting from human activity and
industrialization over the past 200 years.
An individual project like the proposed project cannot generate enough GHG emissions to effect a
discernible change in global climate. However, the project may participate in the potential for
global climate change by its incremental contribution of GHGs combined with the cumulative
increase of all other sources of GHGs, which when taken together constitute potential influences on
global climate change.
Global Climate Change Defined
Global climate change refers to the change in average meteorological conditions on the earth with
respect to temperature, wind patterns, precipitation, and storms. Global temperatures are
regulated by naturally occurring atmospheric gases such as water vapor, CO2, N2O, CH4,
hydrofluorocarbons, perfluorocarbons and sulfur hexafluoride. These particular gases are important
because of their residence time (duration they stay) in the atmosphere, which ranges from 10 years
to more than 100 years. These gases allow solar radiation into Earth’s atmosphere, but prevent
radioactive heat from escaping, thus warming Earth’s atmosphere. Global climate change can occur
naturally as it has in the past with the previous ice ages. According to the California Air Resources
Board (ARB), the climate change since the industrial revolution differs from previous climate changes
in both rate and magnitude.
Gases that trap heat in the atmosphere are often referred to as GHGs. GHGs are released into the
atmosphere by both natural and anthropogenic (human) activity. Without the natural GHG effect,
Earth’s average temperature would be approximately 61°F cooler than it is currently. The cumulative
accumulation of these gases in the earth’s atmosphere is considered to be the cause for the
observed increase in Earth’s temperature.
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Greenhouse Gases
For the purposes of this analysis, emissions of carbon dioxide, methane, and nitrous oxide were
evaluated because these gases are the primary contributors to global climate change from
development projects. Although other substances such as fluorinated gases also contribute to global
climate change, sources of fluorinated gases are not well defined and no accepted emissions factors
or methodology exist to accurately calculate these gases.
Individual GHG compounds have varying global warming potential and atmospheric lifetimes. CO2, the
reference gas for global warming potential, has a global warming potential of one. The global warming
potential of a GHG is a measure of how much a given mass of a GHG is estimated to contribute to
global warming. To describe how much global warming a given type and amount of GHG may cause,
global warming potential (GWP) values are used to convert GHG emission values to “carbon dioxide
equivalent” (CO2e) units. The calculation of CO2e is a consistent methodology for comparing GHG
emissions since it normalizes various GHG emissions to a consistent reference gas. For example, CH4’s
warming potential of 21 indicates that CH4 has 21 times greater warming effect than CO2 on a
molecule-per-molecule basis. Table 3.7-1 describes select GHGs, including their global warming
potentials. The global warming potential amounts are from IPCC Second Assessment Report. IPCC
Fourth Assessment Report introduced updated global warming potentials. The new amounts have not
been used in order to remain consistent with the amounts used to develop the ARB 2008 Scoping Plan
and the draft South Coast Air Quality Management District (SCAQMD) thresholds.
Table 3.7-1: Description of Select GHGs
GHG Description and Physical Properties Sources
Nitrous oxide (N2O) Nitrous oxide (laughing gas) is a colorless
GHG. It has a lifetime of 114 years. Its
global warming potential is 310.
Microbial processes in soil and water,
fuel combustion, and industrial
processes.
Methane (CH4) Methane is a flammable gas and is the
main component of natural gas. It has a
lifetime of 12 years. Its global warming
potential is 21.
Methane is extracted from geological
deposits (natural gas fields). Other
sources are landfills, fermentation of
manure, and decay of organic matter.
Carbon dioxide (CO2) CO2 is an odorless, colorless, natural GHG.
Carbon dioxide’s global warming potential
is 1. The concentration in 2005 was 379
parts per million (ppm), which is an
increase of about 1.4 ppm per year since
1960.
Natural sources include decomposition
of dead organic matter; respiration of
bacteria, plants, animals, and fungus;
evaporation from oceans; and volcanic
outgassing. Anthropogenic sources are
from burning coal, oil, natural gas, and
wood.
Chlorofluorocarbons
(CFCs)
These are gases formed synthetically by
replacing all hydrogen atoms in methane
or ethane with chlorine and/or fluorine
atoms. They are nontoxic, nonflammable,
insoluble, and chemically unreactive in the
troposphere (the level of air at the earth’s
surface). Global warming potentials range
from 3,800 to 8,100.
Chlorofluorocarbons were synthesized
in 1928 for use as refrigerants, aerosol
propellants, and cleaning solvents.
They destroy stratospheric ozone. The
Montreal Protocol on Substances that
Deplete the Ozone Layer prohibited
their production in 1987.
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Table 3.7-1 (cont.): Description of Select GHGs
GHG Description and Physical Properties Sources
Perfluorocarbons
(PFCs)
Perfluorocarbons have stable molecular
structures and only break down by
ultraviolet rays about 60 kilometers above
Earth’s surface. Because of this, they have
long lifetimes, between 10,000 and 50,000
years. Global warming potentials range
from 6,500 to 9,200.
Two main sources of perfluorocarbons
are primary aluminum production and
semiconductor manufacturing.
Sulfur hexafluoride
(SF6)
Sulfur hexafluoride (SF6) is an inorganic,
odorless, colorless, and nontoxic,
nonflammable gas. It has a lifetime of
3,200 years. It has a high global warming
potential of 23,900.
This gas is man-made and used for
insulation in electric power
transmission equipment, in the
magnesium industry, in semiconductor
manufacturing, and as a tracer gas.
Nitrogen trifluoride
(NF3)
Nitrogen trifluoride (NF3) was added to
Health and Safety Code section 38505(g)(7)
as a GHG of concern. It has a high global
warming potential of 17,200.
This gas is used in electronics
manufacture for semiconductors and
liquid crystal displays.
Sources: Compiled from a variety of sources, primarily Intergovernmental Panel on Climate Change 2007a and 2007b.
Greenhouse Gas Emissions Inventories
Global
An emissions inventory is a database that lists, by source, the amount of air pollutants discharged into
the atmosphere of a geographic area during a given time period. Emissions worldwide were
approximately 43,286 million metric tons of carbon dioxide equivalents (MMTCO2e) in 2012. As shown
in Figure 3.7-2, China was the largest GHG emitter with over 10 billion metric tons of CO2e, and the
United States was the second-largest GHG emitter with over 6 billion metric tons of CO2e (WRI 2014).
The GHG emissions in more recent years may differ from the inventories presented in Figure 3.7-2;
however, the data are representative of currently available inventory data.
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Figure 3.7-2: GHG Emissions by Geographic Area
Source: WRI 2014.
United States
As shown in Figure 3.7-1, the United States, as a single country, was the number two producer of
GHG emissions in 2012. The primary GHG emitted by human activities in the United States was CO2.
Specifically, CO2 from fossil fuel combustion was the largest source of US GHG emissions.
State of California
Although California’s rate of growth of GHG emissions is slowing, the State is still a substantial
contributor to the United States emissions inventory total. The ARB compiles GHG inventories for
the State of California. Figure 3.7-3 shows the contributors of GHG emissions in California between
years 2000 and 2016 by Scoping Plan category. In 2016, the highest sector was transportation,
contributing approximately 38 percent of total GHG emissions. The second highest sector was
industrial, which includes sources from refineries, general fuel use, oil and gas extraction, cement
plants, and cogeneration heat output. As shown in Figure 3.7-3, ARB reported that California’s GHG
emissions inventory was 429.4 MMTCO2e in 2016 (ARB 2018).
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Figure 3.7-3: GHG Emission Trends by Scoping Plan Category in California
Source: ARB 2018.
Environmental Effects of Climate Change in California
The California Environmental Protection Agency (CalEPA) published a report titled, “Scenarios of
Climate Change in California: An Overview,” (Climate Scenarios report) in February, 2006, that while
not adequate for a California Environmental Quality Act (CEQA) project-specific or cumulative
analysis, is generally instructive about the statewide impacts of global warming.
The Climate Scenarios report uses a range of emissions scenarios developed by the IPCC to project a
series of potential warming ranges (i.e., temperature increases) that may occur in California during
the 21st century: lower warming range (3.0–5.5 Fahrenheit (°F)); medium warming range (5.5–8.0°F);
and higher warming range (8.0–10.5°F). The Climate Scenarios report then presents an analysis of
future climate in California under each warming range, that while uncertain, present a picture of the
impacts of global climate change trends in California.
In addition, most recently on August 5, 2009, the State’s Natural Resources Agency released a public
review draft of its “California Climate Adaptation Strategy” report that details many vulnerabilities
arising from climate change with respect to matters such as temperature extremes, sea level rise,
wildfires, floods and droughts, and precipitation changes. This report responds to the Governor’s
Executive Order S-13-2008 that called on State agencies to develop California’s strategy to identify
and prepare for expected climate impacts.
According to the reports, substantial temperature increases arising from increased GHG emissions
potentially could result in a variety of impacts to the people, economy, and environment of California
associated with a projected increase in extreme conditions, with the severity of the impacts
depending upon actual future emissions of GHGs and associated warming. Under the emissions
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scenarios of the Climate Scenarios report, the impacts of global warming in California have the
potential to include but are not limited to the following areas:
• Air Quality/General Thermal Effects
• Water Resources
• Agriculture
• Forest and Landscapes
• Rising Sea Levels
Human Health Effects of GHG Emissions
The potential health effects related directly to the emissions of carbon dioxide, methane, and nitrous
oxide as they relate to development projects such as the project are still being debated in the
scientific community. Their cumulative effects to global climate change have the potential to cause
adverse effects to human health. Increases in Earth’s ambient temperatures would result in more
intense heat waves, causing more heat-related deaths. Scientists also purport that higher ambient
temperatures would increase disease survival rates and result in more widespread disease. Climate
change will likely cause shifts in weather patterns, potentially resulting in devastating droughts and
food shortages in some areas.
3.7.2 - Regulatory Setting
International
Kyoto Protocol
In 1988, the United Nations established the Intergovernmental Panel on Climate Change to evaluate
the impacts of global warming and to develop strategies that nations could implement to curtail
global climate change. In 1992, the United States joined other countries around the world in signing
the United Nations’ Framework Convention on Climate Change (UNFCCC) agreement with the goal of
controlling GHG emissions. As a result, the Climate Change Action Plan was developed to address
the reduction of GHGs in the United States. The Plan currently consists of more than 50 voluntary
programs for member nations to adopt.
The Kyoto protocol is a treaty made under the UNFCCC and was the first international agreement to
regulate GHG emissions. Some have estimated that if the commitments outlined in the Kyoto
protocol are met, global GHG emissions could be reduced an estimated five percent from 1990 levels
during the first commitment period of 2008-2012. Notably, while the United States is a signatory to
the Kyoto protocol, Congress has not ratified the Protocol and the United States is not bound by the
Protocol’s commitments. In December 2009, international leaders from 192 nations met in
Copenhagen to address the future of international climate change commitments post-Kyoto.
Federal
Clean Air Act
Coinciding 2009 meeting in Copenhagen, on December 7, 2009, the United States Environmental
Protection Agency (EPA) issued an Endangerment Finding under Section 202(a) of the Clean Air Act,
opening the door to federal regulation of GHGs. The Endangerment Finding notes that GHGs
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threaten public health and welfare and are subject to regulation under the Clean Air Act. To date,
the EPA has not promulgated regulations on GHG emissions, but it has already begun to develop
them.
Previously the EPA had not regulated GHGs under the Clean Air Act because it asserted that the Act
did not authorize it to issue mandatory regulations to address global climate change and that such
regulation would be unwise without an unequivocally established causal link between GHGs and the
increase in global surface air temperatures. In Massachusetts v. EPA et al. (127 S. Ct. 1438 (2007),
however, the United States Supreme Court held that GHGs are pollutants under the Clean Air Act
and directed the EPA to decide whether the gases endangered public health or welfare.
The EPA had also not moved aggressively to regulate GHGs because it expected Congress to make
progress on GHG legislation, primarily from the standpoint of a cap-and-trade system. However,
proposals circulated in both the House of Representative and Senate have been controversial and it
may be some time before the United States Congress adopts major climate change legislation. The
EPA’s Endangerment Finding paves the way for federal regulation of GHGs with or without Congress.
Although global climate change did not become an international concern until the 1980s, efforts to
reduce energy consumption began in California in response to the oil crisis in the 1970s, resulting in
the incidental reduction of GHG emissions. In order to manage the State’s energy needs and promote
energy efficiency, Assembly Bill (AB) 1575 created the California Energy Commission (CEC) in 1975.
State
Title 24 Energy Standards
The CEC first adopted Energy Efficiency Standards for Residential and Nonresidential Buildings
(California Code of Regulations, Title 24, Part 6) in 1978 in response to a legislative mandate to
reduce energy consumption in the State. Although not originally intended to reduce GHG emissions,
increased energy efficiency, and reduced consumption of electricity, natural gas, and other fuels
would result in fewer GHG emissions from residential and nonresidential buildings subject to the
standard. The standards are updated periodically to allow for the consideration and inclusion of new
energy efficiency technologies and methods. The most current 2016 Building Energy Efficiency
Standards went into effect on January 1, 2017 (CEC 2016).
Part 11 of the Title 24 Building Standards Code is referred to as the California Green Building
Standards Code (CALGreen Code). The purpose of the CALGreen Code is to “improve public health,
safety and general welfare by enhancing the design and construction of buildings through the use of
building concepts having a positive environmental impact and encouraging sustainable construction
practices in the following categories: (1) Planning and design; (2) Energy efficiency; (3) Water
efficiency and conservation; (4) Material conservation and resource efficiency; and (5)
Environmental air quality.” The CALGreen Code is not intended to substitute or be identified as
meeting the certification requirements of any green building program that is not established and
adopted by the California Building Standards Commission. Unless otherwise noted in the regulation,
all newly constructed buildings in California are subject of the requirements of the CALGreen Code.
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CALGreen contains both mandatory and voluntary measures; for non-residential land uses there are
39 mandatory measures including, but not limited to exterior light pollution reduction, wastewater
reduction by 20 percent, and commissioning of projects over 10,000 square feet. There are two tiers
of voluntary measures for non-residential land uses, for a total of 36 additional elective measures.
California’s Building Energy Efficiency Standards are updated on an approximately three-year cycle.
The code is updated on a regular basis, with the most recent update consisting of the 2016 California
Green Building Code Standards that became effective January 1, 2017. Local jurisdictions are
permitted to adopt more stringent requirements, as state law provides methods for local
enhancements. The Code recognizes that many jurisdictions have developed existing construction
and demolition ordinances, and defers to them as the ruling guidance provided they provide a
minimum 50-percent diversion requirement. The code also provides exemptions for areas not
served by construction and demolition recycling infrastructure. State building code provides the
minimum standard that buildings need to meet in order to be certified for occupancy, which is
generally enforced by the local building official.
California Assembly Bill No. 1493 (AB 1493)
AB 1493 requires ARB to develop and adopt the nation’s first GHG emission standards for
automobiles. The Legislature declared in AB 1493 that global warming was a matter of increasing
concern for public health and environment in California. Further, the legislature stated that
technological solutions to reduce GHG emissions would stimulate the California economy and
provide jobs.
To meet the requirements of AB 1493, ARB approved amendments to the California Code of
Regulations (CCR) adding GHG emission standards to California’s existing motor vehicle emission
standards in 2004. Amendments to CCR Title 13 Sections 1900 (CCR 13 1900) and 1961 (CCR 13
1961) and adoption of Section 1961.1 (CCR 13 1961.1) require automobile manufacturers to meet
fleet average GHG emission limits for all passenger cars, light-duty trucks within various weight
criteria, and medium-duty passenger vehicle weight classes beginning with the 2009 model year.
Emission limits are further reduced each model year through 2016.
In December 2004, a group of car dealerships, automobile manufacturers, and trade groups
representing automobile manufacturers filed suit against ARB to prevent enforcement of CCR 13
1900 and CCR 13 1961 as amended by AB 1493 and CCR 13 1961.1 (Central Valley Chrysler-Jeep et al.
v. Catherine E. Witherspoon, in her official capacity as Executive Director of the California Air
Resources Board, et al.). The suit, heard in the U.S. District Court for the Eastern District of
California, contended that California’s implementation of regulations that in effect regulate vehicle
fuel economy violates various federal laws, regulations, and policies. In January 2007, the judge
hearing the case accepted a request from the State Attorney General’s office that the trial be
postponed until a decision is reached by the U.S. Supreme Court on a separate case addressing
GHGs. In the Supreme Court Case, Massachusetts vs. EPA, the primary issue in question is whether
the federal CAA provides authority for the EPA to regulate CO2 emissions. In April 2007, the U.S.
Supreme Court ruled in Massachusetts’ favor, holding that GHGs are air pollutants under the CAA.
On December 11, 2007, the judge in the Central Valley Chrysler-Jeep case rejected each plaintiff’s
arguments and ruled in California’s favor. On December 19, 2007, the EPA denied California’s waiver
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request. California filed a petition with the Ninth Circuit Court of Appeals challenging EPA’s denial on
January 2, 2008.
The Obama administration subsequently directed the EPA to re-examine their decision. On May 19,
2009, challenging parties, automakers, the State of California, and the federal government reached
an agreement on a series of actions that would resolve these current and potential future disputes
over the standards through model year 2016. In summary, the EPA and the U.S. Department of
Transportation agreed to adopt a federal program to reduce GHGs and improve fuel economy,
respectively, from passenger vehicles in order to achieve equivalent or greater GHG benefits as the
AB 1493 regulations for the 2012–2016 model years. Manufacturers agreed to ultimately drop
current and forego similar future legal challenges, including challenging a waiver grant, which
occurred on June 30, 2009. The State of California committed to (1) revise its standards to allow
manufacturers to demonstrate compliance with the fleet-average GHG emission standard by
“pooling” California and specified State vehicle sales; (2) revise its standards for 2012–2016 model
year vehicles so that compliance with EPA-adopted GHG standards would also comply with
California’s standards; and (3) revise its standards, as necessary, to allow manufacturers to use
emissions data from the federal Corporate Average Fuel Economy (CAFE) program to demonstrate
compliance with the AB 1493 regulations.
Executive Order S-3-05
Executive Order S-3-05, which was signed by Governor Schwarzenegger in 2005, proclaims that
California is vulnerable to the impacts of climate change. It declares that increased temperatures
could reduce the Sierra’s snowpack, further exacerbate California’s air quality problems, and
potentially cause a rise in sea levels. To combat those concerns, the Executive Order established
total GHG emission targets. Specifically, emissions are to be reduced to the 1990 level by 2020, and
to 80 percent below the 1990 level by 2050. The Executive Order directed the Secretary of the
CalEPA to coordinate a multi-agency effort to reduce GHG emissions to the target levels. The
Secretary also is required to submit biannual reports to the Governor and state Legislature
describing: (1) progress made toward reaching the emission targets; (2) impacts of global warming
on California’s resources; and (3) mitigation and adaptation plans to combat these impacts. To
comply with the Executive Order, the Secretary of the CalEPA created a Climate Action Team (CAT)
made up of members from various state agencies and commission. CAT released its first report in
March 2006. The report proposed to achieve the targets by building on voluntary actions of
California businesses, local government and community actions, as well as through state incentive
and regulatory programs.
California Assembly Bill 32 (AB 32)
In September 2006, Governor Arnold Schwarzenegger signed AB 32, the California Climate Solutions
Act of 2006. AB 32 requires that statewide GHG emissions be reduced to 1990 levels by the year
2020.
This reduction will be accomplished through an enforceable statewide cap on GHG emissions that
will be phased in starting in 2012. To effectively implement the cap, AB 32 directs ARB to develop
and implement regulations to reduce statewide GHG emissions from stationary sources. AB 32
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specifies that regulations adopted in response to AB 1493 should be used to address GHG emissions
from vehicles. However, AB 32 also includes language stating that if the AB 1493 regulations cannot
be implemented, then ARB should develop new regulations to control vehicle GHG emissions under
the authorization of AB 32.
AB 32 requires that ARB adopt a quantified cap on GHG emissions representing 1990 emissions
levels and disclose how it arrives at the cap; institute a schedule to meet the emissions cap; and
develop tracking, reporting, and enforcement mechanisms to ensure that the State achieves
reductions in GHG emissions necessary to meet the cap. AB 32 also includes guidance to institute
emissions reductions in an economically efficient manner and conditions to ensure that businesses
and consumers are not unfairly affected by the reductions.
In November 2007, ARB completed its estimates of 1990 GHG levels. Net emission 1990 levels were
estimated at 427 MMT CO2e (emission sources by sector were transportation at 35 percent,
electricity generation at 26 percent, industrial at 24 percent, residential at 7 percent, agriculture at 5
percent, and commercial at 3 percent). Accordingly, 427 MMT CO2e was established as the
emissions limit for 2020. For comparison, ARB’s estimate for baseline GHG emissions was 473 MMT
CO2e for 2000 and 532 MMT CO2e for 2010. “Business as usual” conditions (without the 30 percent
reduction to be implemented by ARB regulations) for 2020 were projected to be 596 MMT CO2e.
In December 2007, ARB approved a regulation for mandatory reporting and verification of GHG
emissions for major sources. This regulation covered major stationary sources such as cement plans,
oil refineries, electric generating facilities/providers, and co-generation facilities, which comprise 94
percent of the point source CO2 emissions in the State.
On December 11, 2008, ARB adopted a scoping plan to reduce GHG emissions to 1990 levels. The
Scoping Plan’s recommendations for reducing GHG emissions to 1990 levels by 2020 include
emission reduction measures, including a cap-and-trade program linked to Western Climate Initiative
partner jurisdictions, green building strategies, recycling and waste-related measures, as well as
Voluntary Early Actions and Reductions. Implementation of individual measures must begin no later
than January 1, 2012, so that the emissions reduction target can be fully achieved by 2020.
While local government operations were not accounted for in achieving the 2020 emissions
reduction, local land use changes are estimated to result in a reduction of 5 MMT CO2e, which is
approximately 3 percent of the 2020 GHG emissions reduction goal. In recognition of the critical role
local governments will play in successful implementation of AB 32, ARB is recommending GHG
reduction goals of 15 percent of 2006 levels by 2020 to ensure that municipal and community-wide
emissions match the State’s reduction target. According to the Measure Documentation Supplement
to the Scoping Plan, local government actions and targets are anticipated to reduce vehicle miles by
approximately 2 percent through land use planning, resulting in a potential GHG reduction of 2 MMT
CO2e (or approximately 1.2 percent of the GHG reduction target).
ARB approved the First Update to the Scoping Plan (Update) on May 22, 2014. The Update identifies
the next steps for California’s climate change strategy. The Update shows how California continues
on its path to meet the near-term 2020 GHG limit, but also sets a path toward long-term, deep GHG
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emission reductions. The report establishes a broad framework for continued emission reductions
beyond the year 2020, on the path to 80 percent below 1990 levels by the year 2050. The Update
identifies progress made to meet the near-term objectives of AB 32 and defines California’s climate
change priorities and activities for the next several years. The Update does not set new targets for
the State, but describes a path that would achieve the long-term 2050 goal of Executive Order S-05-
03 for emissions to decline to 80 percent below 1990 levels by the year 2050.
AB 32 does not give ARB a legislative mandate to set a target beyond the 2020 target from AB 32 or
to adopt additional regulations to achieve a post-2020 target. The Update estimates that reductions
averaging 5.2 percent per year would be required after 2020 to achieve the 2050 goal (ARB 2014).
The 2017 Scoping Plan Update is discussed under Senate Bill (SB) 32.
California Senate Bill No. 1368 (SB 1368)
In 2006, the State Legislature adopted SB 1368, which was subsequently signed into law by the
Governor. SB 1368 directs the California Public Utilities Commission to adopt a GHG emission
performance standard (EPS) for the future power purchases of California utilities. SB 1368 seeks to
limit carbon emissions associated with electrical energy consumed in California by forbidding
procurement arrangements for energy longer than five years from resources that exceed the
emissions of a relatively clean, combined cycle natural gas power plant. Because of the carbon
content of its fuel source, a coal-fired plant cannot meet this standard because such plants emit
roughly twice as much carbon as natural gas, combined cycle plants. Accordingly, the new law will
effectively prevent California’s utilities from investing in, otherwise financially supporting, or
purchasing power from new coal plants located in or out of the State. Thus, SB 1368 will lead to
dramatically lower GHG emissions associated with California energy demand, as SB 1368 will
effectively prohibit California utilities from purchasing power from out of state producers that
cannot satisfy the EPS standard required by SB 1368.
Senate Bill 97 (SB 97)
Pursuant to the direction of SB 97, the Governor’s Office of Planning and Research (OPR) released
preliminary draft CEQA Guidelines amendments for GHG emissions on January 8, 2009, and
submitted its final proposed guidelines to the Secretary for Natural Resources on April 13, 2009. The
Natural Resources Agency adopted the Guideline amendments and they became effective on March
18, 2010.
Of note, the new guidelines state that a lead agency shall have discretion to determine whether to
use a quantitative model or methodology, or in the alternative, rely on a qualitative analysis or
performance-based standards. CEQA Guideline Section 15064.4(a) states:
A lead agency shall have discretion to determine, in the context of a particular
project, whether to: (1) Use a model or methodology to quantify greenhouse gas
emissions resulting from a project, and which model or methodology to use . . .; or
(2) Rely on a qualitative analysis or performance based standards.
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CEQA emphasizes that the effects of GHG emissions are cumulative, and should be analyzed in the
context of CEQA’s requirements for cumulative impacts analysis (see CEQA Guidelines Section
15130(f)).
Section 15064.4(b) of the CEQA Guidelines provides direction for lead agencies for assessing the
significance of impacts of GHG emissions:
• The extent to which the project may increase or reduce GHG emissions as compared to the
existing environmental setting;
• Whether the project emissions exceed a threshold of significance that the lead agency
determines applies to the project; or
• The extent to which the project complies with regulations or requirements adopted to
implement a statewide, regional, or local plan for the reduction or mitigation of GHG
emissions. Such regulations or requirements must be adopted by the relevant public agency
through a public review process and must include specific requirements that reduce or
mitigate the project’s incremental contribution of GHG emissions. If there is substantial
evidence that the possible effects of a particular project are still cumulatively considerable
notwithstanding compliance with the adopted regulations or requirements, an EIR must be
prepared for the project.
The CEQA Guidelines amendments do not identify a threshold of significance for GHG emissions, nor
do they prescribe assessment methodologies or specific mitigation measures. Instead, they call for a
“good-faith effort, based on available information, to describe, calculate, or estimate the amount of
greenhouse gas emissions resulting from a project.” The amendments encourage lead agencies to
consider many factors in performing a CEQA analysis and preserve lead agencies’ discretion to make
their own determinations based upon substantial evidence. The amendments also encourage public
agencies to make use of programmatic mitigation plans and programs from which to tier when they
perform individual project analyses.
Executive Order S-01-07
On January 18, 2007, California Governor Arnold Schwarzenegger, through Executive Order S-01-07,
mandated a statewide goal to reduce the carbon intensity of California’s transportation fuel by at
least ten percent by 2020. The order also requires that a California specific Low Carbon Fuel
Standard be established for transportation fuels.
Senate Bills 1078 and 107 and Executive Order S-14-08
SB 1078 (Chapter 516, Statutes of 2002) requires retail sellers of electricity, including investor-owned
utilities and community choice aggregators, to provide at least 20 percent of their supply from
renewable sources by 2017. SB 107 (Chapter 464, Statutes of 2006) changed the target date to
2010. In November 2008 Governor Schwarzenegger signed Executive Order S-14-08, which expands
the State’s Renewable Energy Standard to 33 percent renewable power by 2020.
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Senate Bill 375
SB 375, signed in September 2008 (Chapter 728, Statutes of 2008), aligns regional transportation
planning efforts, regional GHG reduction targets, and land use and housing allocation. SB 375
requires metropolitan planning organizations (MPOs) to adopt a sustainable community strategy
(SCS) or alternative planning strategy (APS) that will prescribe land use allocation in that MPO’s
regional transportation plan. ARB, in consultation with MPOs, will provide each affected region with
reduction targets for GHGs emitted by passenger cars and light trucks in the region for the years
2020 and 2035. These reduction targets will be updated every 8 years but can be updated every 4
years if advancements in emissions technologies affect the reduction strategies to achieve the
targets. ARB is also charged with reviewing each MPO’s SCS or APS for consistency with its assigned
targets. If MPOs do not meet the GHG reduction targets, transportation projects will not be eligible
for funding programmed after January 1, 2012.
This law also extends the minimum time period for the regional housing needs allocation cycle from
5 years to 8 years for local governments located within an MPO that meets certain requirements.
City or county land use policies (including general plans) are not required being consistent with the
regional transportation plan (and associated SCS or APS). However, new provisions of CEQA would
incentivize (through streamlining and other provisions) qualified projects that are consistent with an
approved SCS or APS, categorized as “transit priority projects.”
California Senate Bill 32 (SB 32)
Effective January 1, 2017, SB 32 (Chapter 249, Statutes of 2016, ) added a new section 38566 to the
Health and Safety Code. It provides that “[i]n adopting rules and regulations to achieve the
maximum technologically feasible and cost-effective greenhouse gas emissions reductions
authorized by [Division 25.5 of the Health and Safety Code], [ARB] shall ensure that statewide
greenhouse gas emissions are reduced to at least 40 percent below the statewide greenhouse gas
emissions limit no later than December 31, 2030.” In other words, SB 32 requires California, by the
year 2030, to reduce its statewide GHG emissions so that they are 40 percent below those that
occurred in 1990.
The 2017 Climate Change Scoping Plan Update addressing the SB 32 targets was adopted on December
14, 2017. The major elements of the framework proposed to achieve the 2030 target are as follows:
1. SB 350
• Achieve 50 percent Renewables Portfolio Standard (RPS) by 2030.
• Doubling of energy efficiency savings by 2030.
2. Low Carbon Fuel Standard (LCFS)
• Increased stringency (reducing carbon intensity 18 percent by 2030, up from 10 percent
in 2020).
3. Mobile Source Strategy (Cleaner Technology and Fuels Scenario)
• Maintaining existing GHG standards for light- and heavy-duty vehicles.
• Put 4.2 million zero-emission vehicles (ZEVs) on the roads.
• Increase ZEV buses, delivery and other trucks.
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4. Sustainable Freight Action Plan
• Improve freight system efficiency.
• Maximize use of near ZEVs and equipment powered by renewable energy.
• Deploy over 100,000 ZEV trucks and equipment by 2030.
5. Short-Lived Climate Pollutant (SLCP) Reduction Strategy
• Reduce emissions of methane and hydrofluorocarbons 40 percent below 2013 levels by
2030.
• Reduce emissions of black carbon 50 percent below 2013 levels by 2030.
6. SB 375 Sustainable Communities Strategies
• Increased stringency of 2035 targets.
7. Post-2020 Cap-and-Trade Program
• Declining caps, continued linkage with Québec, and linkage to Ontario, Canada.
• ARB will look for opportunities to strengthen the program to support more air quality
co-benefits, including specific program design elements. In Fall 2016, ARB staff
described potential future amendments including reducing the offset usage limit,
redesigning the allocation strategy to reduce free allocation to support increased
technology and energy investment at covered entities and reducing allocation if the
covered entity increases criteria or toxics emissions over some baseline.
8. 20 percent reduction in GHG emissions from the refinery sector.
9. By 2018, develop Integrated Natural and Working Lands Action Plan to secure California’s
land base as a net carbon sink (ARB 2017c).
Between AB 32 (2006) and SB 32 (2016), the Legislature has codified some of the ambitious GHG
reduction targets included within certain high-profile Executive Orders issued by the last two
Governors. The 2020 statewide GHG reduction target in AB 32 was consistent with the second of
three statewide emissions reduction targets set forth in former Governor Arnold Schwarzenegger’s
2005 Executive Order known as S-3-05, which is expressly mentioned in AB 32. (See Health & Safety
Code, § 38501, subdivision (i)). That Executive Branch document included the following GHG
emission reduction targets: by year 2010, reduce GHG emissions to 2000 levels; by year 2020,
reduce GHG emissions to 1990 levels; and by year 2050, reduce GHG emissions to 80 percent below
1990 levels. To meet the targets, the Governor directed several State agencies to cooperate in the
development of a climate action plan. The Secretary of CalEPA leads the CAT, whose goal is to
implement global warming emission reduction programs identified in the Climate Action Plan, and to
report on the progress made toward meeting the emission reduction targets established in the
executive order.
In 2015, Governor Brown issued another Executive Order, B-30-15, which created a “new interim
statewide greenhouse gas emission reduction target to reduce greenhouse gas emissions to 40
percent below 1990 levels by 2030 is established in order to ensure California meets its target of
reducing greenhouse gas emissions to 80 percent below 1990 levels by 2050.” SB 32 codified this
target.
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Notably, the Legislature has not yet set a 2050 target in the manner done for 2020 and 2030 through
AB 32 and SB 32, though references to a 2050 target can be found in statutes outside the Health and
Safety Code. In the 2015 legislative session, the Legislature passed SB 350 (Chapter 547, Statute of
2015) (discussed in more detail below). This legislation added language to the Public Utilities Code
that essentially puts into statute the 2050 GHG reduction target already identified in Executive Order S-
3-05, albeit in the limited context of new state policies (i) increasing the overall share of electricity that
must be produced through renewable energy sources and, (ii) directing certain state agencies to begin
planning for the widespread electrification of the California vehicle fleet. Section 740.12(a)(1)(D) of
the Public Utilities Code now states that “[t]he Legislature finds and declares [that] . . . [r]educing
emissions of [GHGs] to 40 percent below 1990 levels by 2030 and to 80 percent below 1990 levels by
2050 will require widespread transportation electrification.” Furthermore, Section 740.12(b) now
states that the California Public Utilities Commission (PUC), in consultation with ARB and the California
Energy Commission (CEC), must “direct electrical corporations to file applications for programs and
investments to accelerate widespread transportation electrification to reduce dependence on
petroleum, meet air quality standards, . . . and reduce emissions of greenhouse gases to 40 percent
below 1990 levels by 2030 and to 80 percent below 1990 levels by 2050.”
Local
City of Orange
General Plan
The City of Orange General Plan sets forth the following goal and policies that are relevant to GHG
emissions:
• Goal 3.0: Prepare for and adapt to the effects of climate change and promote practices that
decrease the City’s contribution to climate change.
• Policy 3.1: Evaluate the potential effects of climate change on the City’s human and natural
systems and prepare strategies that allow the City to appropriately respond and adapt.
• Policy 3.2: Develop and adopt a comprehensive strategy to reduce GHGs within Orange by at
least 15 percent from current levels by 2020.
3.7.3 - Thresholds of Significance
CEQA Guidelines define a significant effect on the environment as “a substantial, or potentially
substantial, adverse change in the environment.” To determine if a project would have a significant
impact on GHGs, the type, level, and impact of emissions generated by the project must be evaluated.
The following GHG significance thresholds are contained in Appendix G of the CEQA Guidelines,
which were amendments adopted into the Guidelines on March 18, 2010, pursuant to SB 97. A
significant impact would occur if the project would:
a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant
impact on the environment (See Impact GHG-1 below.); or
b) Conflict with any applicable plan, policy or regulation of an agency adopted for the purpose
of reducing the emissions of greenhouse gases (See Impact GHG-2 below.).
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On December 5, 2008, the SCAQMD Governing Board adopted interim GHG significance thresholds.
Although these thresholds are still “interim” thresholds at the time of this analysis, the thresholds
represent the most applicable thresholds supported by substantial evidence. These thresholds are
widely accepted by lead agencies in the region and by SCAQMD. The current SCAQMD interim
thresholds are administered through the following tiered approach:
• Tier 1 consists of evaluating whether or not the project qualifies for any applicable exemption
under CEQA;
• Tier 2 consists of determining whether the project is consistent with a GHG reduction plan. If
a project is consistent with a qualifying local GHG reduction plan, it does not have significant
greenhouse gas emissions;
• Tier 3 consists of screening values, and the lead agency can choose either option #1 or option
#2, but must be consistent with all projects within its jurisdiction. A project’s construction
emissions are averaged over 30 years and are added to a project’s operational emissions. If a
project’s emissions are under one of the following screening thresholds, then the project is
less than significant:
- Option #1: All residential or commercial land use types: 3,000 metric tons of carbon dioxide
equivalents (MT CO2e) per year and industrial land uses: 10,000 MT CO2e, or
- Option #2: Based on land use type—residential: 3,500 MT CO2e per year; commercial: 1,400
MT CO2e per year; industrial: 10,000 MT CO2e; or mixed use: 3,000 MT CO2e per year
• Tier 4 has the following options:
- Option 1: Reduce emissions from business as usual by a certain percentage; this percentage
is currently undefined;
- Option 2: Early implementation of applicable AB 32 Scoping Plan measures;
- Option 3, 2020 target for service populations (SP), which includes residents and employees:
4.8 MT CO2e/SP/year for projects and 6.6 MT CO2e/SP/year for plans; 2035 target: 3.0 MT
CO2e/SP/year for projects and 4.1 MT CO2e/SP/year for plans.
• Tier 5 involves mitigation offsets to achieve target significance threshold.
If a project generates GHG emissions below the applicable thresholds described above, its GHG
emissions would be considered a less than significant impact on the environment. To determine
whether the project is significant, this analysis uses the residential-specific draft SCAQMD threshold:
• 3,500 MT CO2e per year for annual operational emissions and amortized construction
emissions.
3.7.4 - Project Impacts and Mitigation Measures
This section discusses potential impacts associated with the project and provides mitigation
measures where necessary.
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Greenhouse Gas Emissions
Impact GHG-1: The project would not generate greenhouse gas emissions, either directly or
indirectly, that may have a significant impact on the environment.
Impact Analysis
Both construction period and operational period activities have the potential to generate GHG
emissions. The project would result in direct and indirect emissions from construction activities,
area sources, and mobile sources. CalEEMod (Version 2016.3.2) was used to estimate GHG
emissions resulting from the project’s construction and operational activities.
Construction
The project would involve the construction of single-family residential units on the project site.
Construction-related GHG emissions are primarily generated from fossil fuel combustion associated
with construction equipment, material delivery trucks, and construction worker vehicles.
A summary of the estimated emissions that would result from construction of the project is shown in
Table 3.7-2. As recommended by the SCAQMD, the amortized construction emissions were added to
annual operational emissions to compare with SCAQMD’s applicable threshold of significance.
Table 3.7-2: Construction GHG Emissions—Unmitigated
Construction Activity GHG Emissions (MT CO2e per year)
Site Preparation/Grading—2020 7,858
Site Preparation/Grading—2021 3,826
Paving 49
Building Construction—2021 282
Building Construction—2022 831
Building Construction—2023 813
Building Construction—2024 400
Architectural Coating 24
Total Construction Emissions 14,082
Amortized over 30 years1 469
Note:
1 Construction GHG emissions are amortized over the 30-year life of the project.
Source: CalEEMod and FCS 2018, see Appendix F
Operations
Operational GHG emissions are generated by the following emission sources:
• Motor Vehicles—These emissions refer to GHG emissions contained in the exhaust from the
cars and trucks that would travel to and from the project site;
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• Natural Gas—These emissions refer to the GHG emissions that occur when natural gas is
burned on the project site. Natural gas uses include heating water, space heating, dryers,
stoves, or other uses;
• Indirect Electricity—These emissions refer to those generated by off-site power plants to
supply electricity required for the project;
• Water Transport—These emissions refer to those generated by the electricity required to
transport and treat the water to be used on the project site; and
• Waste—These emissions refer to the GHG emissions produced by decomposing waste
generated by the project.
Table 3.7-3 presents the project’s annual long-term operational emissions by emissions source. The
sum of annual operational emissions and amortized construction emissions are compared with the
applicable threshold of significance.
Table 3.7-3: Operational GHG Emissions—Unmitigated
Emissions Source GHG Emissions (MT CO2e per year)
Area 2
Energy 509
Mobile 698
Waste 82
Water 160
Amortized Construction 469
Total Project Emissions 1,921
SCAQMD Threshold 3,500
Exceed Significant? No
Note:
MT CO2e = metric tons of carbon dioxide equivalent
Source of emissions: CalEEMod and FCS 2018, see Appendix F
Source of thresholds: SCAMD 2008c.
As shown in Table 3.7-3, the proposed project’s long-term GHG emissions (along with amortized
construction emissions) would generate approximately 1,921 MT CO2e per year, which would not
exceed the applicable SCAQMD’s draft thresholds of 3,500 MT CO2e per year. Therefore, the
project’s generation of GHG emissions would not result in a significant impact on the environment.
Level of Significance Before Mitigation
Less than significant impact.
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Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
Conflict with Plan, Policy, or Regulation that Reduces Emissions
Impact GHG-2: The project would not conflict with any applicable plan, policy or regulation of an
agency adopted for the purpose of reducing the emissions of greenhouse gases.
Impact Analysis
At the time of this analysis, the City of Orange has not yet adopted a GHG reduction plan that the
project can be evaluated against. In addition, the City has not completed the GHG inventory,
benchmarking, and goal-setting process required to identify a reduction target and to take
advantage of the streamlining provisions contained in the CEQA Guidelines amendments adopted for
SB 97. Since no other local or regional climate action plan is in place, the project is assessed for its
consistency with ARB’s adopted AB 32 2008 Scoping Plan. This would be achieved with an
assessment of the project’s compliance with Scoping Plan measures.
Although the City of Orange General Plan does not meet the CEQA Guidelines 15064.4(b)(3)
requirements for an applicable plan to reduce GHG emissions, it contains policies intended to reduce
vehicle travel and energy use that would provide GHG reductions. Therefore, the project’s
consistency with the General Plan policies is also assessed.
Scoping Plan
The Scoping Plan identifies recommended measures for multiple GHG emission sectors and the
associated emission reductions needed to achieve the year 2020 emissions target—each sector has a
different emission reduction target. Most of the measures target the transportation and electricity
sectors. As shown in Table 3.7-4, the project is consistent with many of the strategies, while others
are not applicable to the project.
Table 3.7-4: Scoping Plan Reduction Measures Consistency Analysis
Scoping Plan Reduction Measure Consistency/Applicability Determination
1. California Cap-and-Trade Program Linked to
Western Climate Initiative. Implement a
broad-based California cap-and-trade program
to provide a firm limit on emissions. Link the
California cap-and-trade program with other
Western Climate Initiative Partner programs to
create a regional market system to achieve
greater environmental and economic benefits
for California. Ensure California’s program
meets all applicable AB 32 requirements for
market-based mechanisms.
Not applicable. Although the cap-and-trade system is
ongoing, the project is not one targeted by the cap-and-
trade system regulations, and, therefore, this measure
does not apply to the project.
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Table 3.7-4 (cont.): Scoping Plan Reduction Measures Consistency Analysis
Scoping Plan Reduction Measure Consistency/Applicability Determination
2. California Light-Duty Vehicle GHG Standards.
Implement adopted standards and planned
second phase of the program. Align ZEV,
alternative and renewable fuel and vehicle
technology programs with long-term climate
change goals.
Not directly applicable. This is a statewide measure
that cannot be implemented by a project applicant or
lead agency. However, vehicles accessing residences at
the project site would be subject to the standards.
Therefore, it is expected that trips made to the project
site would be done with increasingly efficient vehicles.
3. Energy Efficiency. Maximize energy efficiency
building and appliance standards; pursue
additional efficiency including new
technologies, policy, and implementation
mechanisms. Pursue comparable investment
in energy efficiency from all retail providers of
electricity in California.
Consistent. This is a measure for the State to increase
its energy efficiency standards in new buildings. The
project is required to build to the latest standards and
would increase its energy efficiency through
compliance.
4. Renewable Portfolio Standard. Achieve 33
percent renewable energy mix statewide.
Renewable energy sources include (but are not
limited to) wind, solar, geothermal, small
hydroelectric, biomass, anaerobic digestion,
and landfill gas.
Not applicable. This is a statewide measure that
cannot be implemented by a project applicant or lead
agency. Southern California Edison is required to
increase this percentage to 33 percent by the year 2020
pursuant to the Renewable Portfolio Standard. The
project would purchase power that is comprised of a
greater amount of renewable sources and could install
renewable solar power systems that will assist the
utility in achieving the mandate.
5. Low Carbon Fuel Standard. Develop and adopt
the Low Carbon Fuel Standard.
Not directly applicable. This is a statewide measure
that cannot be implemented by a project applicant or
lead agency. All fuel consumption associated with the
project’s construction and operational activities would
use fuel that meets these standards.
6. Regional Transportation-Related GHG Targets.
Develop regional GHG emissions reduction
targets for passenger vehicles. This measure
refers to SB 375.
Not applicable. The project is not related to
developing GHG emission reduction targets.
7. Vehicle Efficiency Measures. Implement light-
duty vehicle efficiency measures.
Not directly applicable. The standards would be
applicable to the light-duty vehicles that would access
the project site.
8. Goods Movement. Implement adopted
regulations for the use of shore power for ships
at berth. Improve efficiency in goods
movement activities.
Not applicable. The project does not propose any
changes to maritime, rail, or intermodal facilities or
forms of transportation.
9. Million Solar Roofs Program.
Install 3,000 megawatts of solar-electric
capacity under California’s existing solar
programs.
Consistent. This measure is to increase solar throughout
California, which is being done by various electricity
providers and existing solar programs. The project would
comply with Title 24, which requires new non-residential
buildings to be “solar ready” and requires solar
photovoltaic systems for new homes. The project would
not preclude the implementation of this strategy.
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Table 3.7-4 (cont.): Scoping Plan Reduction Measures Consistency Analysis
Scoping Plan Reduction Measure Consistency/Applicability Determination
10. Medium/Heavy-Duty Vehicles. Adopt medium
and heavy-duty vehicle efficiency measures.
Not directly applicable. This is a statewide measure
that cannot be implemented by a project applicant or
lead agency. The standards phase in over model years
2014 through 2018 and would be applicable to the
vehicles that access the project site.
11. Industrial Emissions. Require assessment of
large industrial sources to determine whether
individual sources within a facility can cost-
effectively reduce GHG emissions and provide
other pollution reduction co-benefits. Reduce
GHG emissions from fugitive emissions from oil
and gas extraction, and gas transmission.
Adopt and implement regulations to control
fugitive CH4 emissions and reduce flaring at
refineries.
Not applicable. This measure would apply to the direct
GHG emissions at major industrial facilities. The project
would not be considered an industrial land use.
12. High Speed Rail. Support implementation of a
high-speed rail system.
Not applicable. This is a statewide measure that
cannot be implemented by a project applicant or lead
agency. The proposed project would not preclude the
implementation of this strategy.
13. Green Building Strategy. Expand the use of
green building practices to reduce the carbon
footprint of California’s new and existing
inventory of buildings.
Consistent. The project would comply with the
California Energy Code, and thus incorporate applicable
energy efficiency features designed to reduce project
energy consumption.
14. High GWP Gases. Adopt measures to reduce
high GWP gases.
Not applicable. This measure is applicable to the high
GWP gases that would be used by sources with large
equipment (such as in commercial air conditioning and
commercial refrigerators) that are not part of this
residential project.
15. Recycling and Waste. Reduce CH4 emissions at
landfills. Increase waste diversion, composting,
and commercial recycling. Move toward zero
waste.
Consistent. The project would not contain a landfill.
The State is to help increase waste diversion. The
project would reduce waste with implementation of
state mandated recycling and reuse mandates.
16. Sustainable Forests. Preserve forest
sequestration and encourage the use of forest
biomass for sustainable energy generation.
Not applicable. The project site is not forested;
therefore, no preservation is possible.
17. Water. Continue efficiency programs and use
cleaner energy sources to move and treat
water.
Consistent. This is a measure for state and local
agencies. However, the project would comply with the
California Green Building Standards Code and the
California Updated Model Landscape Ordinance. With
adherence to these regulations, the project will
consume energy and water in an efficient manner.
18. Agriculture. In the near-term, encourage
investment in manure digesters and at the five-
year Scoping Plan update determine if the
program should be made mandatory by 2020.
Not applicable. The project site is not designated or in
use for agriculture purposes. No grazing, feedlot, or
other agricultural activities that generate manure occur
on-site or are proposed to be implemented by the
project.
Source of ARB Scoping Plan Reduction Measure: ARB 2008.
Source of Project Consistency or Applicability: FCS.
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General Plan Compliance
As part of the City of Orange’s 2010 General Plan, the Natural Resources Element includes goals and
policies related to reducing GHG emissions and responding to climate change listed below.1
• Goal 3.0: Prepare for and adapt to the effects of climate change and promote practices that
decrease the City’s contribution to climate change.
• Policy 3.1: Evaluate the potential effects of climate change on the City’s human and natural
systems and prepare strategies that allow the City to appropriately respond and adapt.
• Policy 3.2: Develop and adopt a comprehensive strategy to reduce GHGs within Orange by at
least 15 percent from current levels by 2020.
The project would be consistent with the General Plan designation for the project site for “Low
Density Residential,” “Resource Area,” and “Open Space.” Thus, the project would help preserve
areas of the City designated for “Resource Area” and “Open Space,” which would be consistent with
Goal 3.0 to decrease the City’s contribution to climate change. In other words, by preserving a
majority of the project site as open space and recreational uses, the project would avoid additional
GHG emissions from those areas and provide recreational opportunities to the proposed and nearby
existing residents. Furthermore, the project site is located in an infill area, which would add
residential density to the local area. The increased density of the local neighborhood would help
support the Southern California Association of Governments’ (SCAG) regional land use and
transportation GHG reduction goals mandated by SB 375, which relies on additional residential
density coupled with nearby amenities to reduce vehicle miles traveled and encourage alternative
modes of transportation.
Given that the project would comply with the land use designations of the project site, increase
residential density in a developed area, and preserve open space and recreational land—which
would reduce GHG emissions produced on those areas—the project would be consistent with the
goals and policies adopted for the purpose of reducing the emissions of GHGs contained within the
City’s General Plan. Furthermore, it is not anticipated that the project would conflict with an
applicable GHG reduction plan.
Summary
The project would not conflict with the ARB Scoping Plan or the City of Orange General Plan.
Furthermore, as described in Impact GHG-1, the project’s combined long-term operational and
amortized construction emissions would not exceed the applicable SCAQMD’s threshold of
significance. Although these thresholds had not been formally adopted at the time of this analysis,
they are considered the allowable amount of emissions for each project, under which the project
would not impede regional and state GHG reduction goals. Therefore, considering the
aforementioned information, the project would not conflict with any applicable plan, policy, or
regulation adopted for the purpose of reducing the emissions of GHGs. Therefore, this impact would
be less than significant.
1 City of Orange. 2010. 2010 General Plan. March 9. Website: http://www.cityoforange.org/DocumentCenter/Home/View/571.
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Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
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3.8 - Hazards and Hazardous Materials
3.8.1 - Introduction
This section describes the existing hazards and hazardous materials setting and potential effects
from project implementation on the site and its surrounding area. Descriptions and analysis in this
section are based on the Phase I Environmental Site Assessment prepared by Michael Brandman
Associates and the Phase II Environmental Site Assessment prepared by Tait Environmental Services.
Both reports are provided in Appendix F.
3.8.2 - Environmental Setting
Hazardous Materials
Hazardous materials, as defined by the California Code of Regulations, are substances with certain
physical properties that could pose a substantial present or future hazard to human health or the
environment when improperly handled, disposed, or otherwise managed. Hazardous materials are
grouped into the following four categories, based on their properties:
• Toxic—causes human health effects.
• Ignitable—has the ability to burn.
• Corrosive—causes severe burns or damage to materials.
• Reactive—causes explosions or generates toxic gases.
A hazardous waste is any hazardous material that is discarded, abandoned, or slated to be recycled.
The criteria that define a material as hazardous also define a waste as hazardous. If handled,
disposed, or otherwise handled improperly, hazardous materials and hazardous waste can result in
public health hazards if released into the soil or groundwater or through airborne releases in vapors,
fumes, or dust. Soil and groundwater having concentrations of hazardous constituents higher than
specific regulatory levels must be handled and disposed of as hazardous waste when excavated or
pumped from an aquifer. The California Code of Regulations, Title 22, Sections 66261.20-24 contains
technical descriptions of toxic characteristics that could cause soil or groundwater to be classified as
hazardous waste.
Phase I/II Environmental Site Assessments
Three previous Phase I or Phase II Environmental Site Assessments (Phase I/II ESAs) were prepared
for the project site in 2000, 2009, and 2011. Because the 2009 Phase I ESA was prepared after the
2000 Phase I ESA, it provided a more accurate and current assessment of potential hazards and, thus
its findings take precedence. The findings of the 2009 Phase I ESA and 2011 Phase II ESA are
summarized in Table 3.8-1.
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Table 3.8-1: Previous Phase I/II Environmental Site Assessment Findings
Firm Findings
Michael Brandman
Associates—Phase I
ESA (2009)
1. All appropriate safeguards and analysis shall be conducted to mitigate any potential
risks associated with the proposed project in regards to the adjacent former Villa
Park Landfill. California Code of Regulations (CCR), Title 27, Section 21190,
Postclosure Land Use applies to all construction within 1,000 feet of the boundary of
any disposal area to prevent gas migration into buildings. Examples of safeguards
include a geomembrane between the concrete floor slab and subgrade; periodic
methane gas monitoring inside all buildings and underground utilities; a subsurface
venting system beneath each building; and automatic methane sensors beneath and
inside each building. (CCR Title 27, Section 21190 is included as an attachment to the
County of Orange Health Care Agency correspondence contained in Appendix E.)
Compatibility of proposed project land uses within 1,000 feet of the boundary of the
former Villa Park Landfill shall be properly evaluated.
2. Design plans for: 1) any occupied structures within 1,000 feet of the landfill
boundary; and 2) structural systems to prevent gas-related hazards are required to
be reviewed and approved by the County of Orange Health Care Agency/Local
Enforcement Agency.
3. The proposed occupied structures shall be situated strategically to allow for future
remediation of any potential landfill gas migration.
4. Prior to commencement of any construction activities that would impact the
landfill or related gas monitoring equipment, the City Engineer shall consult with
and obtain approval from the Orange County Integrated Waste Management
Department for the relocation of any monitoring wells or probes that would be
impacted by development on the project site.
5. Mitigation Measures 5.6-1 through 5.6-5, as outlined in the EIR for the Sully Miller
Fieldstone Communities Project, Hazards and Hazardous Materials Section 5.6,
shall be incorporated into proposed project design and Mitigation Monitoring and
Reporting Program.
6. Written and verbal disclosures regarding landfill gas shall be provided to lot and
homeowners within 1,000 feet of the landfill boundary.
7. All environmental investigations, sampling and/or remediation for the project site
shall be conducted under a Workplan approved and overseen by a regulatory
agency with jurisdiction to oversee hazardous substance cleanup.
8. Further testing and analysis shall be conducted for the on-site Potential Areas of
Environmental Concern identified in Section 7.1 of the 2000 Geomatrix Phase I ESA
that have not yet been addressed and remediated:
• Soils beneath the former diesel-affected soil stockpile located previously at the
western end of the site: Concentrations of total petroleum hydrocarbons
quantified against a diesel standard (TPHd) occurring above the regulatory
clean-up level of 1,000 mg/kg.
• Soils within the western sidewall of a former emulsion tank UST excavation
located in the central portion of the site: Concentrations of TPHd slightly above
the regulatory clean-up level.
• On-site areas that previously included agriculture: Level of pesticide and
herbicide residue in the soil.
• Asbestos or asbestos-containing materials: Reportedly buried on-site within a
designated area.
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Table 3.8-1 (cont.): Previous Phase I/II Environmental Site Assessment Findings
Firm Findings
Tait Environmental
Services—Phase II ESA
(2011)
1. One soil vapor sample (C-6-5@15’) collected in Planning Area C contained
trichloroethylene (TCE) at a concentration that could potentially pose a significant
human health risk to users of residential buildings located in the area where
sample C-6-5@15’ was collected. Mitigation and/or remedial actions to address
potential vapor intrusion risks to residential users’ potential risk may be needed.
The need for the mitigation and/or remedial actions will depend on the final grade
elevations for the area of concern (the greater the distance between the detected
TCE-impacted soil vapor and the final grade, the less chance that mitigation and/or
remedial actions will be required). Mitigation measures could include vapor
barriers or passive/active venting systems beneath Site buildings in the affected
area. Remedial actions could include mechanical stripping of TCE-impacted soil in
the affected area.
2. Five soil vapor samples (C-1-1@15’, C-1-3@15’, C-1-6@8’, C-3-2@15’, and C-6-
7@15’) collected in Planning Area C contained methane at concentrations below
one percent by volume. The possibility exists that this methane could infiltrate
future Site buildings in the affected areas and concentrate in rooms with limited
air exchanges. Should this occur, the methane concentration could exceed its
lower explosive limit (5% by volume), creating a potentially explosive mixture.
Mitigation and/or remedial actions to address this potential risk may be needed.
The need for the mitigation and/or remedial actions will depend on the final grade
elevations for the area of concern (the greater the distance between the detected
methane containing soil vapor and the final grade, the less chance that mitigation
and/or remedial actions will be required). Mitigation measures could include
vapor barriers or passive/active venting systems beneath Site buildings in the
affected area. Remedial actions could include mechanical stripping of methane-
containing soil vapor in the affected areas.
3. None of the soil matrix core samples collected at the Site contained detectable
concentrations of VOCs or pesticide compounds that could potentially pose a
significant human health risk to future Site users. Accordingly, TAIT makes no
recommendation for remedial actions and/or mitigation measures.
4. Fourteen soil matrix core samples (A-5-3@5’, C-1-1@5’, C-1-1 @10’, C-1-3@5’, C-
1-3@10’, C-1-4@5’, C-1-4@8’, C-1-5@5’, C-1-5@8’, C-1-6@5’, C-3-1@5’, C-3-
1@10’, C-3-2@5’, and C-3-2@10’) collected in Planning Areas C and D (both
planned residential areas) contained TPH-mo at concentrations that exceeded the
respective ESL. Nine of these samples also contained TPH-d at concentrations
exceeding the respective ESL. Remedial actions to address potential soil ingestion
and dermal contact risk to future Site users may be needed. The need for the
remedial actions will depend on final surface cover and final grade elevations for
the areas of concern (the greater the distance between the detected TPH-
impacted soil and the final grade, the less chance that remedial actions will be
required). Remedial actions could include excavation and off-site disposal.
Source: FCS, 2016.
It should be noted that the 2011 Tait Phase II ESA was prepared to address the findings of the 2009
Phase I ESA by way of subsurface investigation and sampling and, thus, its findings are most relevant
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in terms of identifying potential hazards to future occupants and users of the site. The key findings
and potential risks from the 2011 Tait Phase II ESA are as follows:
• Potential vapor intrusion of trichloroethylene (TCE) and methane into future dwelling units
• Elevated petroleum hydrocarbon concentrations in soil
Tait Environmental Services determined that all other potential hazards and hazardous materials that
may have previously been located on the project site as indicated by the 2000 and 2009 Phase I ESAs
no longer exist, including asbestos.
Database Search
FCS performed a search of the State Water Resources Control Board GeoTracker database to identify
known hazardous materials sites in the project vicinity. The results are summarized in Table 3.8-2.
Table 3.8-2: GeoTracker Search Results Summary
Site Address
Relationship to
Project Site Database(s) Status
Villa Park Landfill 5545 E. Santiago
Canyon Road
Adjacent (west) Land Disposal
Site
Closed With
Monitoring (2014)
Orange County Fire
Station No. 23
5020 E. Santiago
Canyon Road
0.25 mile
(southwest)
LUST Cleanup
Site
Closed (1999)
Diocese of Orange 7845 E. Santiago
Canyon Road
0.5 mile (east) LUST Cleanup
Site
Closed (1999)
Note:
LUST = Leaking Underground Storage Tank
Source: State Water Resources Control Board, 2016.
The site of most concern to the project site is the adjacent Villa Park Landfill, which is discussed in
detail in the following section. The remaining two sites were leaking underground tank sites that are
listed as “Closed” signifying that they have been remediated to the satisfaction of the regulatory
agency.
Villa Park Landfill
The Villa Park Landfill site was originally a sand and gravel mine until 1962 when the site was
repurposed as a landfill. The Villa Park Landfill was operated by Orange County (OC) Waste &
Recycling as a Class III municipal solid waste landfill from 1962 to 1966. The landfill property is
approximately 18 acres, of which approximately 11 acres were used for waste disposal. The landfill
was closed in 1966 in accordance with closure regulation in effect at the time. OC Waste & Recycling
has since been implementing post-closure monitoring and maintenance of the Villa Park Landfill.
The Villa Park Landfill is not equipped with an engineered artificial liner or with a leachate collection
and removal system because this landfill predates regulatory requirements for these measures. An
active gas collection system has been installed at the site to control, collect, and flare landfill gas
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generated in the buried refuse. Groundwater monitoring, vadose zone perimeter gas probe
monitoring, and site maintenance is conducted by OC Waste & Recycling on a regular basis.
Hazardous Building Materials
Asbestos
Asbestos is the name given to a number of naturally occurring, fibrous silicate minerals mined for
their useful properties, such as thermal insulation, chemical and thermal stability, and high tensile
strength. Asbestos is commonly used as an acoustic insulator, thermal insulation, fireproofing, and
in other building materials. Asbestos is made up of microscopic bundles of fibers that may become
airborne when asbestos-containing materials are damaged or disturbed. When these fibers get into
the air, they may be inhaled into the lungs, where they can cause significant health problems. The
California Occupational Health and Safety Administration (CalOSHA) defines asbestos-containing
construction materials as any material that contains more than 0.1 percent asbestos by weight.
The Phase II ESA determined that asbestos is not present on the project site.
Lead
Lead is a highly toxic metal that was used until the late 1970s in a number of products, most notably
in paint. Lead may cause a range of health effects, from behavioral problems and learning
disabilities to seizures and death. Primary sources of lead exposure are deteriorating lead-based
paint, lead-contaminated dust, and lead-contaminated soil. Both the United States Environmental
Protection Agency (USEPA) and the California Department of Health Services define lead paint as
containing a minimum of 0.5 percent lead by weight. Lead-containing waste materials with a
concentration greater than 0.1 percent are considered hazardous waste by California law. Both the
federal and California OSHA maintain regulations regarding the disturbance of paints that contain
any amount of lead.
The Phase II ESA determined that lead-containing materials are not present on the project site.
Materials Recycling
Approximately 5 acres in the southeastern portion of the project site were used as a materials
recycling area. Within this area, an apparatus was used for the crushing of boulders, bricks, rocks,
etc. for recycling. Additionally, operations that provide for the cement treatment of base materials
occurred within this area. Access to the materials recycling area is from a controlled entrance along
East Santiago Canyon Road. Historically, the materials generated by this operation have been used
on and transported off the project site.
Backfilling Operation
The project site has been previously backfilled as a permitted use to restore previously mined
portions of the site. As previously noted, the project site was used from 1919 to 1995 for surface
mining of sand, gravel, and other aggregates. Previously mined portions of the project site were
used for residue silt deposition, otherwise known as silt ponds. The backfilling operation addressed
both mined and silt pond areas.
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Radon
Radon is a carcinogenic radioactive gas resulting from the natural breakdown of uranium in soil, rock,
and water. Radon gas enters a building through cracks in foundations and walls. Once inside the
building, radon decay products may become attached to dust particles and inhaled, or the decayed
radioactive particles alone may be inhaled and cause damage to lung tissue. The EPA has established
safe radon exposures to threshold of 4 picocuries per liter of air (pCi/l). Table 3.8-3 summarizes
indoor radon test results for several zip codes in the project vicinity.
Table 3.8-3: Indoor Radon Testing Summary
Zip Code (Area)
Total Indoor Radon
Samples No. Exceeding 4.0 pCi/l Percent Exceeding 4.0 pCi/l
92807 (Anaheim Hills) 59 5 8.5
92861 (Villa Park) 12 4 33.3
92867 (Orange) 49 4 8.2
92869 (Orange Park Acres)* 39 1 2.6
Total 159 14 8.8
Note:
* Project site is located in the 92869 zip code.
Source: California Department of Public Health, 2016.
As shown in Table 3.8-3, the California Department of Public Health has conducted 159 indoor radon
tests in four zip codes in the project vicinity. Of this figure, 14 yield concentrations in excess of 4.0
pCi/l, which is equivalent to 8.8 percent. The California Department of Public Health indicates that
areas between 7.0 to 20.0 percent have a “moderate” radon potential.
3.8.3 - Regulatory Framework
Federal
Hazardous Materials Laws
The EPA is the lead agency responsible for enforcing federal laws and regulations governing
hazardous materials that affect public health or the environment. The major federal laws and
regulations enforced by the EPA include the Resource Conservation and Recovery Act (RCRA), the
Toxic Substances Control Act, the Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA), and the Superfund Amendments and Reauthorization Act.
In 1976, the RCRA was enacted to provide a general framework for the EPA to regulate hazardous
waste from the time it is generated until its ultimate disposal. In accordance with RCRA, facilities
that generate, treat, store, or dispose of hazardous waste are required to ensure that the wastes are
properly managed from “cradle to grave.”
Also in 1976, the Toxic Substances Control Act was enacted to provide the EPA authority to regulate
the production, importation, use, and disposal of chemicals that pose a risk of adversely impacting
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public health and the environment, such as polychlorinated biphenyls (PCBs), asbestos-containing
materials, and lead-based paint. The Toxic Substances Control Act also gives the EPA authority to
regulate the cleanup of sites contaminated with specific chemicals, such as PCBs.
In 1980, CERCLA, commonly known as the Superfund, was enacted to ensure that a source of funds
was available for the EPA to remediate uncontrolled or abandoned hazardous materials release sites
that pose a risk of adversely impacting public health and the environment. Prohibitions and
requirements regarding closed or abandoned hazardous waste sites and liability standards for
responsible parties were also established by CERCLA. In 1986, the Superfund Amendments and
Reauthorization Act amended CERCLA to increase the Superfund budget, modify contaminated site
cleanup criteria and schedules, and revise settlement procedures.
Other relevant federal laws include the Hazardous and Solid Waste Amendments Act regarding
hazardous waste management; the Toxic Substances Control Act, pertaining to the tracking and
screening of industrial chemicals; and the Federal Insecticide, Fungicide, and Rodenticide Act, which
controls pesticide distribution, sale, and use. Applicable federal regulations and guidelines are
contained primarily in Code of Federal Regulations (CFR) Titles 10, 29, 40, and 49.
Comprehensive Environmental Response, Compensation and Liability Act
The Comprehensive Environmental Response, Compensation, and Liability Act of 1980 introduces
active Federal involvement to emergency response, site remediation, and spill prevention, most
notably with the Superfund program. The Act was intended to be comprehensive in encompassing
both the prevention of and response to uncontrolled hazardous substances releases. The Act deals
with environmental response, providing mechanisms for reacting to emergencies and chronic
hazardous material releases. In addition to establishing procedures to prevent and remedy problems,
it establishes a system for compensating appropriate individuals and assigning appropriate liability. It
is designed to plan for, and respond to, failure in other regulatory programs and to remedy problems
resulting from action taken before the era of comprehensive regulatory protection.
State
California Health and Safety Code
The California Environmental Protection Agency (CalEPA) has established rules governing the use of
hazardous materials and the management of hazardous wastes. California Health and Safety Code
Sections 25531, et seq. incorporates the requirements of Superfund Amendments and Reauthorization
Act and the Clean Air Act as they pertain to hazardous materials. Health and Safety Code Section
25534 directs facility owners storing or handling acutely hazardous materials in reportable quantities
to develop a Risk Management Plan. The plan must be submitted to the appropriate local authorities,
the designated local administering agency, and the EPA for review and approval.
CEQA and the Cortese List
The Cortese List (Hazardous Waste and Substances Site List) is a planning document used by the
State, local agencies, and developers to comply with CEQA requirements to consider Government
Code Section 5962.5 in evaluating proposed development projects. Section 65962.5 states that:
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The list should contain all hazardous waste facilities subject to corrective action, all
hazardous waste property or border zone property designations, all information
received on hazardous waste disposals on public land, all hazardous substance
release sites listed pursuance to Government Code Section 25356, and all sites that
were included in the former Abandonment Site Assessment Program.
California Environmental Protection Agency (CalEPA)
Government Code Section 65962.5 requires CalEPA to develop a Cortese List at least annually. The
Department of Toxic Substances Control (DTSC) is responsible for a portion of the information on the
list, and other local and state government agencies are required to provide additional information.
CalEPA operates the Air Resources Board, the Department of Pesticide Regulation, the DTSC, the
Integrated Waste Management Board, the Office of Environmental Health Hazard Assessment, and
the State Water Resources Control Board (SRWQCB). The function of each of these six offices is
discussed below.
Air Resources Board (ARB): To promote and protect public health, welfare, and ecological resources
through the effective and efficient reduction of air pollutants in recognition and consideration of the
effects on the economy of the State.
Department of Pesticide Regulation (DPR): Regulates all aspects of pesticide sales and use to
protect the public health and the environment for the purpose of evaluating and mitigating impacts
of pesticide use, maintaining the safety of the pesticide workplace, ensuring product effectiveness,
and encouraging the development and use of reduced-risk pest control practices.
Department of Toxic Substances Control (DTSC): The Department’s mission is to restore, protect,
and enhance the environment, to ensure public health, environmental quality, and economic vitality
by regulating hazardous waste, conducting and overseeing cleanups, and developing and promoting
pollution prevention. DTSC protects residents from exposures to hazardous wastes. DTSC operates
programs to:
• Deal with the aftermath of improper hazardous waste management by overseeing site cleanups.
• Prevent releases of hazardous waste by ensuring that those who generate, handle, transport,
store, and dispose of wastes do so properly.
• Take enforcement actions against those who fail to manage hazardous wastes appropriately.
• Explore and promote means of preventing pollution, and encourage reuse and recycling.
• Evaluate soil, water, and air samples taken at sites, and develop new analytical methods.
Cal Recycle: Protects the public health and safety and the environment through waste prevention,
waste diversion, and safe waste processing and disposal. Cal Recycle is responsible for managing
California’s solid waste stream. Cal Recycle is helping California divert waste from landfills by:
• Developing waste reduction programs.
• Providing public education and outreach.
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• Assisting local governments and businesses.
• Fostering market development for recyclable materials.
• Encouraging used oil recycling.
• Regulating waste management facilities.
• Cleaning up abandoned and illegal dumpsites.
Office of Environmental Health Hazard Assessment (OEHHA): The OEHHA is responsible for
developing and providing risk managers in state and local government agencies with toxicological
and medical information relevant to decisions involving public health. OEHHA also works with
federal agencies, the scientific community, industry, and the general public on issues of
environmental as well as public health. Specific examples of OEHHA responsibilities include:
• Developing health-protective exposure standards for air, water, and land to recommend to
regulatory agencies, including ambient air quality standards for the Air Resources Board and
drinking water chemical contaminant standards for the Department of Health Services.
• Assessing health risks to the public from air pollution, pesticide and other chemical
contamination of food, seafood, drinking water, and consumer products.
• Providing guidance to local health departments, environmental departments, and other
agencies with specific public health problems, including appropriate actions to take in
emergencies that may involve chemicals.
State Water Resources Control Board (SWRCB): Preserves and enhances the quality of California’s
water resources, and ensure their proper allocation and efficient use for the benefit of present and
future generations. The SRWQCB maintains the Leaking Underground Storage Tank Information
System Database, which contains information on registered leaking underground storage tanks in the
State.
California Occupational Safety and Health Agency (CalOSHA)
CalOSHA sets and enforces standards that insure safe and healthy working conditions for California’s
workers. The Division of Occupational Safety & Health is charged with the jurisdiction and
supervision over workplaces in California that are not under federal jurisdiction. CalOSHA regulates
issues involving unsafe workplace conditions, worker exposure to chemicals, illness due to workplace
exposure, or improper training.
Local
City of Orange
General Plan
The City of Orange General Plan sets forth the following goals and policies relevant to hazards and
hazardous materials.
Public Safety Element
• Goal 4.0: Minimize risks to life, property, and the environment associated with producing,
using, storing, or transporting hazardous materials.
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• Policy 4.1: Assess the potential risks of disposing, transporting, manufacturing and storing
existing hazardous materials, and develop appropriate mitigation measures in case of accidents.
• Policy 4.2: Prohibit new disposal, transport, manufacture, and storage of hazardous materials
within the City without a mitigation plan in case of accidents. Hospitals meeting current state
and federal standards are exempt.
• Policy 4.3: Identify hazardous materials dumpsites, and ensure that the sites are cleaned in
conformance with applicable federal and state laws prior to the establishment of new uses.
• Policy 4.4: Ensure that the public is protected from fires, noxious fumes, and other hazards
within the City’s industrial area.
• Goal 8.0: Emphasize emergency preparedness both within City Hall and throughout the
community.
• Policy 8.1: Sponsor and support public education programs for emergency preparedness and
disaster response.
• Policy 8.2: Coordinate disaster preparedness with other public and private agencies.
• Policy 8.3: Coordinate emergency response and preparedness planning with other cities and
public agencies in the region.
• Policy 8.4: Develop and maintain a fully functioning Emergency Operations Center, and
adequate and up-to-date emergency preparedness resources and plans.
3.8.4 - Methodology
The following analysis is based, in part, on the City of Orange General Plan, the City of Orange
General Plan EIR, and a database search conducted by FCS on December 14, 2016. The information
obtained from these resources and other relevant materials was reviewed and evaluated to establish
potential presence of hazards and hazardous materials on the project site.
Three previous Phase I or Phase II Environmental Site Assessments (Phase I/II ESAs) were prepared for
the project site in 2000, 2009, and 2011. Because the 2009 Phase I ESA was prepared after the 2000
Phase I ESA, it provided a more accurate and current assessment of potential hazards and, thus its
findings take precedence. The 2009 Phase I ESA and 2011 Phase II ESA are provided in Appendix F.
3.8.5 - Thresholds of Significance
According to Appendix G, Environmental Checklist, of the CEQA Guidelines, hazards and hazardous
materials impacts resulting from the implementation of the proposed project would be considered
significant if the project would:
a) Create a significant hazard to the public or the environment through the routine transport,
use, or disposal of hazardous materials?
b) Create a significant hazard to the public or the environment through reasonably foreseeable
upset and accident conditions involving the likely release of hazardous materials into the
environment?
c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or
waste within one-quarter mile of an existing or proposed school?
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d) Be located on a site which is included on a list of hazardous materials sites compiled pursuant
to Government Code Section 65962.5 and, as a result, would it create a significant hazard to
the public or the environment?
e) For a project located within an airport land use plan or, where such a plan has not been
adopted, within two miles of a public airport or public use airport, would the project result in
a safety hazard for people residing or working the project area? (Refer to Section 7, Effects
Found Not To Be Significant.)
f) For a project within the vicinity of a private airstrip, would the project result in a safety
hazard for people residing or working in the project area? (Refer to Section 7, Effects Found
Not To Be Significant.)
g) Impair implementation of or physically interfere with an adopted emergency response plan
or emergency evacuation plan?
h) Expose people or structures to a significant risk of loss, injury, or death involving wildland
fires, including where wildlands are adjacent to urbanized areas or where residences are
intermixed with wildlands?
3.8.6 - Project Impacts and Mitigation Measures
This section discusses potential impacts associated with the development of the project and
provides mitigation measures where appropriate.
Routine Transport, Use or Disposal of Hazardous Materials
Impact HAZ-1: The project would not create a significant hazard to the public or the environment
through the routine transport, use, or disposal of hazardous materials.
Impact Analysis
Short-term Construction Impacts
During construction of the residential area and related infrastructure, staging areas, trail, and other
proposed improvements, hazardous materials would be handled on the project site. These
hazardous materials would include gasoline, diesel fuel, lubricants, and other petroleum-based
products used to operate and maintain construction equipment and vehicles. This handling of
hazardous materials would be a temporary activity and coincide with the short-term construction
phase of the proposed project. Although hazardous materials associated with the operation and
maintenance of construction equipment and vehicles may be stored on the project site, it is
expected that only the amounts needed would be kept on-site, and any handling of such materials
will be limited in both quantities and concentrations. Removal and disposal of hazardous materials
from the project site would be conducted by a permitted and licensed contractor. Any handling,
transporting, use, or disposal would comply with applicable laws, policies, and programs set forth by
various federal, state, and local agencies and regulations, including the EPA, RCRA, Caltrans, and the
local Hazardous Materials Program. Required compliance with applicable hazardous material laws
and regulations would ensure that construction-related hazardous material use would not result in
significant impacts.
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Long-term Operational Impacts
During the operational phase of the project, hazardous materials may be handled on the project site.
Because of the nature of the project, hazardous materials used on-site may vary, but would likely be
limited to fertilizers, herbicides, pesticides, solvents, cleaning agents, and similar materials used for
daily residential operations and maintenance activities. These types of materials are common and
represent a low risk to people and the environment when used as intended. Therefore, long-term
operational impacts associated with hazardous materials would be less than significant.
Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
Risk of Upset
Impact HAZ-2: The project may create a significant hazard to the public or the environment
through reasonably foreseeable upset and accident conditions involving the likely
release of hazardous materials into the environment.
Impact Analysis
The project site previously supported agricultural and mining activities and is adjacent to the closed
Villa Park Landfill. Therefore, there is the potential that the development and operation of the
proposed project may expose persons to hazards from these past uses.
As previously discussed, Tait Environmental Services conducted a Phase II ESA of the project site that
evaluated potential exposure to hazardous materials from the past land use activities and the
neighboring landfill. Tait Environmental Services found that there was the potential for (1) vapor
intrusion of TCE and methane into future dwelling units and (2) elevated levels of Total Petroleum
Hydrocarbons in soil. However, the proposed occupied structures will be situated strategically to
allow for future remediation of any potential landfill gas migration, consistent with the California
Department of Toxic Substances Control (DTSC) or other applicable regulatory agency. Accordingly,
Mitigation Measures HAZ-2a to HAZ-2c are proposed to abate these conditions to a level of less than
significant.
The project site is located in a “moderate” area for indoor radon exposure in excess of 4.0 pCi/l.
Indoor radon exposure is most susceptible in subsurface, enclosed spaces such as basements or
parking garages. The proposed residential uses are anticipated to employ conventional slab on-
grade construction and would not feature subsurface, enclosed spaces. As such, impacts related to
radon would be less than significant.
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Level of Significance Before Mitigation
Potentially significant impact.
Mitigation Measures
MM HAZ-2a The proposed enclosed structures shall be situated strategically to allow for future
remediation of any potential landfill gas migration. Prior to issuance of building
permits for dwelling units in areas of the project site where vapor intrusion has the
potential to occur, the applicant shall prepare and submit plans to the City of Orange
identifying vapor intrusion abatement measures for trichloroethylene (TCE) and
methane. Areas where vapor intrusion has the potential to occur are those
identified in the Phase II Environmental Site Assessment. Such abatement measures
may include but are not limited to vapor barriers or passive/active venting systems,
as determined by the appropriate regulatory agency. The approved abatement
measures shall be incorporated into project building plans. Design plans for: 1) any
occupied structures within 1,000 feet of the landfill boundary; and/or 2) structural
systems to prevent gas-related hazards are required to be reviewed and approved by
the County of Orange Health Care Agency/Local Enforcement Agency.
MM HAZ-2b Prior to issuance of grading permits, the project applicant shall retain a qualified
hazardous materials contractor to remove all soil containing Total Petroleum
Hydrocarbons in excess of residential development standards set forth by the
California Department of Toxic Substances Control (DTSC) or other applicable
regulatory agency. Soil removal and disposal shall occur in accordance with DTSC (or
other applicable agency) guidelines. The applicant shall submit documentation to
the City of Orange in the form of confirmatory soil sampling results verifying that
this mitigation measure was successfully implemented as part of the grading permit
application for this property. All environmental investigations, sampling and/or
remediation for the project site shall be conducted under a workplan approved and
overseen by a regulatory agency with jurisdiction to oversee hazardous substance
cleanup, such as the Regional Water Quality Control Board (RWQCB). As part of
proper construction operations and maintenance, any construction areas that are
found to contain contaminated soils shall be excluded using a security fence. All
contaminated soils shall then be excavated and disposed of off-site in accordance
with the rules and regulations of: US Department of Transportation (USDOT), USEPA,
CalEPA, CalOSHA, and any local regulatory agencies. All retention and detention
features used during construction would be lined to prevent infiltration through
contaminated soils. Post-construction retention features shall be lined to prevent
infiltration of groundwater.
MM HAZ-2c Prior to commencement of any construction activities that would impact existing
landfill or related gas monitoring equipment, the project applicant shall contact the
City Engineer to consult with and obtain approval from the Orange County
Integrated Waste Management Department for the relocation of any monitoring
wells or probes that would be impacted by development on the project site.
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Level of Significance After Mitigation
Less than significant impact.
Exposure of Schools to Hazardous Materials
Impact HAZ-3: The project would not emit hazardous emissions or handle hazardous or acutely
hazardous materials, substances, or waste within one-quarter mile of an existing
or proposed school.
Impact Analysis
The Salem Lutheran Church and School (6500 E. Santiago Canyon Road, Orange, CA 92869) is located
within 0.25 mile of the project site. The proposed project would develop residential, open space, and
recreational uses on the project site. None of these uses would involve routine use of hazardous or
acutely hazardous materials, substances or waste. Additionally, the proposed project’s uses would not
involve activities that would routinely emit toxic air contaminants (e.g., diesel particulate matter).
In summary, the proposed land uses and development within 0.25 mile of an existing or proposed
school would not emit or handle substantial amounts of hazardous materials or waste. As such,
impacts would be less than significant.
Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
Government Code Section 65962.5 Hazardous Materials Sites
Impact HAZ-4: The project may be located on a site which is included on a list of hazardous
materials sites compiled pursuant to Government Code Section 65962.5 and, as a
result, would it create a significant hazard to the public or the environment.
Impact Analysis
The project site is not listed on any hazardous materials databases compiled pursuant to
Government Code Section 65962.5.
The closed Villa Park Landfill is immediately adjacent to the project site and is listed on hazardous
materials databases compiled pursuant to Government Code Section 65962.5. The landfill employs
an active gas collection system to control, collect, and flare landfill gas generated in the buried
refuse. Because of its age, the landfill is unlined and does not have a leachate collection and
removal system. OC Waste & Recycling conducts groundwater monitoring, vadose zone perimeter
gas probe monitoring, and site maintenance.
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As previously discussed, the Phase II ESA indicated that elevated levels of methane had the potential
to occur in project site soils and set forth recommended mitigation (see Mitigation Measure HAZ-
2a)to abate this hazard to a level of less than significant.
Finally, the proposed project would locate open space and recreation uses within the portion of the
site that abuts the Villa Park Landfill. These uses would serve as a buffer between the former landfill
and the residential uses that would be located in the eastern portion of the site. Therefore,
development and operation of the proposed project would not expose persons to residual
hazardous materials from past uses of the Villa Park Landfill. Impacts would be less than significant.
Level of Significance Before Mitigation
Potentially significant impact.
Mitigation Measures
Implement Mitigation Measure HAZ-2a.
Level of Significance After Mitigation
Less than significant impact.
Emergency Response and Evacuation
Impact HAZ-5: The project may impair implementation of or physically interfere with an adopted
emergency response plan or emergency evacuation plan.
Impact Analysis
The proposed project would take vehicular access from E. Santiago Canyon Road via a full-access
signalized driveway aligned with Nicky Way. The Fire Department noted that the project would be
required to provide two points of emergency access in accordance with Fire Code requirements.
Mitigation Measure HAZ-5 requires the applicant to demonstrate compliance with all Fire Code
emergency access requirements prior to issuance of building permits.
Additionally, the proposed project would not modify any surrounding roadways in a manner that could
impair emergency response or evacuation (road closures, lane narrowing, etc.). Thus, the proposed
project would not impair implementation of or physically interfere with an adopted emergency
response plan or emergency evacuation plan. Therefore, impacts would be less than significant.
Level of Significance Before Mitigation
Potentially significant impact.
Mitigation Measures
MM HAZ-5 Prior to issuance of the first building permit, the applicant shall prepare and submit
plans to the City of Orange for review and approval demonstrating compliance with
all applicable emergency access provisions of the Fire Code. The approved plan shall
be incorporated into the proposed project.
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Level of Significance After Mitigation
Less than significant impact.
Wildland Fires
Impact HAZ-6: The project may expose persons or property to wildland fire hazards.
Impact Analysis
The eastern portion of the project site abuts Santiago Oak Regional Park and contains the wooded
Santiago Creek Corridor. The Orange Fire Department noted that the project site is located at the
wildland/urban interface and indicated that the project would be subject to the City’s fuel
modification requirements. The project proposes to strategically place approximately 68.5 acres of
open space/grasslands and greenway with managed vegetation within the western, northern, and
eastern portions of the project site, to provide sufficient protection from wildland fires, and alleviate
related impacts. However, Mitigation Measure HAZ-6 will be applied to require the applicant to
prepare a Fuel Modification Plan and submit it to the City of Orange for review and approval prior to
issuance of building permits, consistent with the Fire Departments recommendation.
Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
MM HAZ-6 Prior to issuance of the first building permit, the applicant shall retain a qualified fire
safety consultant to prepare a Fuel Modification Plan for the proposed project. The
plan shall identify defensible space around dwelling units in accordance with City
requirements. The plan shall be submitted to the City of Orange for review and
approval. The approved plan shall be incorporated into the proposed project.
Level of Significance After Mitigation
Less than significant impact.
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3.9 - Hydrology and Water Quality
3.9.1 - Introduction
This section describes the existing hydrology and water quality setting and potential effects from
project implementation on the site and its surrounding area. Descriptions and analysis in this
section are based on the Preliminary Hydrology and Hydraulic Report prepared by Fuscoe
Engineering, which is provided as Appendix K.
3.9.2 - Environmental Setting
Climate and Meteorology
The coastal plain of Orange County is characterized by a Mediterranean climate, with mild winters
and warm summers. Temperatures range from an average low of 46.9 degrees Fahrenheit (°F) in
December to an average high of 87.1°F in August. Average rainfall is 14.09 inches. Table 3.9-1
summarizes local meteorology, as measured in Anaheim, California (approximately 4.35 miles south
of the project site).
Table 3.9-1: Orange Meteorological Summary
Month
Average Temperature (°F)
Precipitation (Inches) Low High
January 47.5 70.0 3.34
February 48.2 70.0 3.47
March 50.4 72.4 1.86
April 52.8 74.7 0.83
May 57.3 77.1 0.53
June 60.5 80.1 0.15
July 64.2 85.2 0.07
August 64.5 87.1 0.01
September 62.7 86.5 0.10
October 57.7 81.2 0.72
November 51.8 75.4 0.99
December 46.9 69.7 2.02
Annual Average 55.4 77.4 14.09
Note:
Measurements taken at the Anaheim weather station between August 1, 1989 and June 9, 2016.
Source: Western Regional Climate Center, 2016.
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Surface Water Bodies
The project site is located within the Santiago Creek watershed, which is tributary to the Santa Ana
River. Both watersheds are discussed separately.
Santiago Creek
The Santiago Creek watershed is approximately 110 square miles and encompasses portions of the
cities of Anaheim, Orange, Santa Ana, and Villa Park, as well as the northern Santa Ana Mountains in
unincorporated Orange County. The creek originates on the slopes of Santiago Peak and Modjeska
Peak in the Santa Ana Mountains, and meanders approximately 29 miles to its confluence with the
Santa Ana River. The Santiago Creek watershed is depicted in Exhibit 3.9-1.
The creek is impounded at Irvine Lake by Santiago Dam, constructed in 1931. Most of the creek’s
flows are diverted at Irvine Lake for potable use by the Serrano Water District, and non-potable use
by the Irvine Ranch Water District. Downstream of Santiago Dam, the creek is usually dry outside of
the wet season.
Approximately 3.5 miles downstream of Santiago Dam, the creek is impounded again at the Villa
Park Reservoir by the Villa Park Dam, constructed in 1963. The Villa Park Reservoir is a flood control
facility and does not store water for potable or non-potable use. Between Villa Park Dam and the
Santiago Creek Recharge Basin, the waterway is contained in a natural channel. From the recharge
basin to the Santa Ana River, the creek is mostly contained in a concrete-lined channel.
Santa Ana River
The Santa Ana River watershed is approximately 2,650 square miles and encompasses portions of
Los Angeles, Riverside, San Bernardino, and Orange counties. The river originates in the San
Bernardino Mountains and discharges into the Pacific Ocean at Huntington Beach, a distance of 96
miles. Major tributaries include Bear Creek (which originates at Big Bear Lake), City Creek, Lytle
Creek, Cucamonga/Mill Creek, Temescal Creek, Chino Creek, and Santiago Creek. More than 4.5
million people reside within the watershed.
According to the Santa Ana River Basin Plan, the river slows as it reaches the City of Anaheim, where
Orange County Water District (OCWD) diverts and recharges essentially all the dry weather flows.
Outside the wet season, the Santa Ana River is dry downstream of Anaheim. The Santa Ana River
watershed is depicted in Exhibit 3.9-2.
Table 3.9-2: Expected Pollutants of Concern
Pollutant
E= Expected to be of Concern
N= Not Expected to be of
Concern Additional Information and Comments
Suspended
Solid/Sediment E —
Nutrients E —
Heavy Metals E —
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Table 3.9-2 (cont.): Expected Pollutants of Concern
Pollutant
E= Expected to be of Concern
N= Not Expected to be of
Concern Additional Information and Comments
Pathogens
(Virus/Bacteria)
E 303(d) listed impairment (Santa Ana River, Reach 2)
—Recommended Delist in 2016 draft
Pesticides E —
Oil & Grease E —
Toxic Organic Compounds E —
Trash & Debris E —
Surface Water Quality
Santiago Creek and the Santa Ana River are listed as impaired water bodies on the currently adopted
Regional Board’s 303(d) list. Table 3.9-3 summarizes the characteristics of the impaired water
bodies. The proposed 2016 303(d) List proposes to add Benthic Community Effects and Toxicity to
Santiago Creek Reach 4 and delist indicator bacteria from the Santa Ana River Reach 2. No TMDLs
have been assigned to either receiving waters. Additionally, there are no Environmentally Sensitive
Areas (ESAs) or Areas of Special Biological Significance (ASBS) within the project site or within the
project vicinity.
Table 3.9-3: Impaired Water Body Summary
Waterway Reach Stressors Sources
Santiago Creek Reach 4: Santa Ana Mountains Salinity/Total Dissolved
Solids/Chlorides
Unknown
Santa Ana River Reach 2: Prado Dam to 17th Street
(Santa Ana)
Indicator Bacteria Unknown
Source: Santa Ana RWQCB, 2017.
Santiago Creek Water Quality Monitoring
As part of the County-wide stormwater program, surface water monitoring is conducted along
Santiago Creek. Currently, there are no monitoring locations for Santiago Creek Reach 1 within the
proximity of the proposed project site. However, sampling in the project vicinity has been
performed in the past. Field screening data and channel monitoring data were collected at two
monitoring stations; one upstream and one downstream of the project site, during the periods of
1967 to 1994, and 1992 to 1996 respectively. The County ’s field screening program includes on-site
physical and chemical evaluations including dry weather and storm event sampling, as part of an
effort to detect illicit connections and illegal discharges. The channel monitoring was conducted
using automated samplers, and typically on a monthly basis. A summary of the selected data is
provided in Table 3.9-4 and Table 3.9-5.
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Table 3.9-4: Santiago Creek Field Screening Data
Parameter Santiago Creek/Bristol Street (Downstream) Villa Park Dam (Upstream)
Sampling Date 2/13/1992 1/6/1993 5/5/1993 3/7/1994 1/16/1996 3/3/1992 6/8/1992 3/7/1995
Flow (cfs) 5.3 200 2 100 5.3 — — 700
pH 7.8 7.9 8.5 9.1 7.6 7.2 7.3 8.1
Conductivity
(µmhos) 327 182 912 145 158 863 598 710
Temperature (°C) 17.4 13.8 22 17.8 16.1 16.3 22 15.5
Dissolved
Oxygen (mg/l) 10.5 7.8 8.6 17.9 7.8 5.1 1.4 12.2
Notes:
cfs = cubic feet per second µmhos = micromhos °C = degrees Celsius mg/l = milligrams per liter
Source: Fuscoe Engineering, 2013.
Table 3.9-5: Santiago Creek Channel Monitoring Data
Parameter
Santiago Canyon Road Bridge
Sampling
Period Maximum Minimum Mean
Basin Plan
Objective
Temperature (°C) 1977–1994 22 8 14.36 —
Flow (cfs) 1964–1994 1,500 0.5 180.24 —
Conductivity (µmhos) 1978–1994 912 145 442.57 —
Dissolved Oxygen (mg/l) 1978–1994 17.9 7.8 12.48 >5
pH 1978–1994 9.1 7.4 8.05 6.5-8.5
Oil and Grease (mg/l) 1978–1980 18.8 3 9.08 —
Total Dissolved Solids (mg/l) 1967–1974 368 328 353.4 600
Nitrate (mg/l) 1967–1980 26.4 0 7.34 <45
Dissolved Boron (mg/l) 1967–1974 200 16 93.2 750
Dissolved Fluoride (mg/l) 1967–1974 0.3 0.2 0.24 0.9
Total Coliform (MPN/100ml) 1978–1980 240,000 90 46,747 100
Notes:
cfs = cubic feet per second µmhos = micromhos °C = degrees Celsius mg/l = milligrams per liter
Source: Fuscoe Engineering, 2013.
I
27650002 • 07/2018 |3.9-1_santiago_watershed.cdr
Exhibit 3.9-1
Santiago Creek Watershed
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Fuscoe Engineering
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27650002 • 07/2018 |3.9-2_santaana_watershed.cdr
Exhibit 3.9-2
Santa Ana River Watershed
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Fuscoe Engineering
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City of Orange—Trails at Santiago Creek Specific Plan
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Drainage
In the project vicinity, stormwater runoff is collected and disposed of through an integrated system of
curbside gutters, catch basins, drainage ditches, man-made channels, and creeks. The City of Orange
and Orange County Flood Control District oversee and manage municipal storm drainage facilities
within the City of Orange. Drainage characteristics of the project site are summarized below.
Project Site
The project site does not have any storm drainage facilities. Runoff generally ponds on-site, sheet
flows to Santiago Creek, or sheet flows off-site into inlets along adjoining roadways. The latter flows
are eventually discharged into the waterway via the municipal storm drainage system. The existing
drainage patterns are shown in Exhibit 3.9-3.
Handy Creek Storm Drain
The Handy Creek storm drain operated by the Orange County Flood Control District is located
underground in the central portion of the project site. The storm drain enters the project site from
the south at the intersection of North Nicky Way/East Santiago Canyon Road. The storm drain
conveys stormwater collected in areas south of East Santiago Canyon Road into Santiago Creek.
Within the project site, the storm drain consists of a double 12-foot by 9-foot reinforced concrete
box structure. Runoff from the project site enters the Handy Creek storm drain through several on-
site sump inlets. In 2011, the County of Orange advised that the Handy Creek storm drain was a
deficient flood control facility and not capable of conveying runoff from a 100-year storm event.
Unnamed Storm Drain
Two unnamed storm drains are located in the northwestern portion of the project site and convey
stormwater collected in the Mabury Ranch neighborhood directly into Santiago Creek. Note that the
project site does not directly discharge runoff into either storm drain.
Groundwater
The City of Orange overlies the Orange County Groundwater Basin (OC Basin). The OC Basin
underlies the northerly half of Orange County beneath broad lowlands. The OC Basin is managed by
OCWD and covers an area of approximately 350 square miles, bordered by the Coyote and Chino
Hills to the north, the Santa Ana Mountains to the northeast, and the Pacific Ocean to the
southwest. The OC Basin boundary extends to the Orange County-Los Angeles Line to the
northwest, where groundwater flows across the county line into the Central Groundwater Basin of
Los Angeles County. The total thickness of sedimentary rocks in the OC Basin is over 20,000 feet,
with only the upper 2,000 to 4,000 feet containing fresh water. The Pleistocene or younger aquifers
that make up this Basin are over 2,000 feet deep, and form a complex series of interconnected sand
and gravel deposits. The OC Basin’s full volume is approximately 66 million acre-feet.
Groundwater levels are managed within a safe basin operating range to protect the long-term
sustainability of the OC Basin, and to protect against land subsidence. OCWD regulates groundwater
levels in the OC Basin by regulating the annual amount of pumping.
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The OC Basin is not adjudicated; as such, pumping from the OC Basin is managed through a process
that uses financial incentives to encourage groundwater producers to pump a sustainable amount of
water. The framework for the financial incentives is based on establishing the basin production
percentage, the percentage of each Producer’s total water supply that comes from groundwater
pumped from the OC Basin. Groundwater production at or below the basin production percentage is
assessed a Replenishment Assessment. While there is no legal limit as to how much an agency pumps
from the OC Basin, there is a financial disincentive to pump above the basin production percentage.
Agencies that pump above the basin production percentage are charged the Replenishment
Assessment plus the Basin Equity Assessment, which is calculated so that the cost of groundwater
production is greater than Municipal Water District of Orange County’s full service rate. The Basin
Equity Assessment can be increased to discourage production above the basin production percentage.
The basin production percentage is set uniformly for all producers by OCWD on an annual basis.
Flood Hazard Areas
The National Flood Insurance Act (1968) established the National Flood Insurance Program (NFIP),
which provides for the minimal requirements for floodplain management and is designed to
minimize flood drainage within Special Flood Hazard Areas. The Federal Emergency Management
Agency (FEMA) is the agency that administrates the NFIP. The Special Flood Hazard Area is the area
subject to flooding by the 1 percent annual chance flood. The 1 percent annual flood (100-year
flood), also known as the base flood, is the flood that has a 1 percent chance of being equaled or
exceeded in any given year. Areas of Special Flood Hazard include Zones: A, AE, AH, AO, AR, A99, V,
and VE. The Base Flood Elevation (BFE) is the water-surface elevation of the 1 percent annual
chance flood. Flood Insurance Rate Maps (FIRMs) were developed by the NFIP to identify areas of
flood hazards within a community.
Exhibit 3.9-1 depicts FEMAs floodplain mapping for the project vicinity. As shown in Exhibit 3.9-4,
the project site contains 100-year and 500-year flood hazard areas. The 100-year flood hazard areas
within the project site overlap with the Santiago Creek channel. The 500-year flood hazard areas
overlap with areas south of the creek, including areas that were previously mined.
Santiago Dam
Santiago Dam is located 5.0 miles upstream of the project site and, along with Irvine Lake, is jointly
owned and operated by the Serrano Water District and Irvine Ranch Water District. The dam was
completed in 1931 and impounds Irvine Lake. Santiago Dam is an earth/rock-fill structure that is 136
feet tall and 1,425 feet long. The dam is designed to contain up to a 50-year flood and withstand a
500-year flood of over 30,000 cubic feet per second.
Villa Park Dam
Villa Park Dam is located approximately 1.5 miles upstream of the project site and is owned and
operated by the Orange County Flood Control District. The dam was completed in 1963 and is used
for flood control purposes; it does not store water for municipal use. Villa Park Dam is an
earth/rock-fill structure that has a capacity of 15,600 acre-feet.
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27650002 • 07/2018 |3.9-3_drainage.cdr
Exhibit 3.9-3
Existing Drainage Patterns
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Fuscoe Engineering
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27650002 • 07/2018 | 3.9-4_fem a.m xd
Exh ibit 3.9-4100-Year Flood Hazard Areas
S ource: CA Dept of Conservatoin, 2014
CITY OF ORANGE • TRAILS AT S ANTIAGO CREEK S PECIFIC PLAN RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
E S a n t i a g o C a n y o n R d
NCanonSt SerranoAveOrangeParkBlvdM a b u r y AveETaftAve SantiagoCreekVilla ParkLandfill (Closed)
Linda VistaElementarySchool
OakridgePrivateSchool
Salem LutheranChurch and School
1,000 0 1,000500
Feet
Legend
Project Site
Special Flood Hazard Areas
Zone AE - Within 0.1% chance annual Flood, base flood elevations determined
Zone AE - Within 0.1% chance annual flood. Within floodway.
Other Flood Hazard Areas
Zone X - Areas of 0.2% chance annual flood
Other Areas
Zone X - Areas outside the 0.2% annual chance floodplain.
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3.9.3 - Regulatory Framework
Federal
Clean Water Act
Section 303 of the Clean Water Act (CWA) requires states to adopt water quality standards for all
surface waters of the United States. Water quality standards are typically numeric, although
narrative criteria based upon biomonitoring methods may be employed where numerical standards
cannot be established or where they are needed to supplement numerical standards (see
description the Porter-Cologne Water Quality Control Act, below). Standards are based on the
designated beneficial use(s) of the water body. Where multiple uses exist, water quality standards
must protect the most sensitive use.
Section 401 of the CWA requires any person applying for a federal permit or license that may result
in the discharge of pollutants into waters of the United States (including wetlands) to obtain a state
certification. In California, certifications are administered by the State Water Resources Control
Board (SWRCB) through nine Regional Water Quality Control Boards (RWQCBs) (see a description of
state regulations below). In order to acquire certification, it must be demonstrated that the activity
complies with all applicable water quality standards, limitations, and restrictions. No license or
permit by a federal agency may be granted until 401 certification has been granted. Section 401
water quality certifications are typically required prior to obtaining a Section 404 permit from the
United States Army Corps of Engineers (USACE).
Section 402 of the CWA mandates that certain types of construction activity comply with the
requirements of National Pollutant Discharge Elimination System (NPDES) stormwater program. In
California, any construction activity (with the exception of certain industrial activities, none of which
are proposed for this project) that disturbs at least one acre is covered under the Construction
General Permit issued by the SWRCB and implemented and enforced by RWQCBs.
Floodplains
FEMA oversees floodplains and administers the NFIP adopted under the National Flood Insurance
Act of 1968. The program makes federally subsidized flood insurance available to property owners
within communities who participate in the program. Areas of special flood hazard (those subject to
inundation by a 100-year flood) are identified by FEMA through regulatory flood maps titled Flood
Insurance Rate Maps. The NFIP mandates that development cannot occur within the regulatory
floodplain (typically the 100-year floodplain) if that development results in more than 1-foot
increase in flood elevation. In addition, development is not allowed in delineated floodways within
the regulatory floodplain.
Executive Order 11988 (Floodplain Management) addresses floodplain issues related to public safety,
conservation, and economics. It generally requires federal agencies constructing, permitting, or
funding a project in a floodplain to do the following:
• Avoid incompatible floodplain development,
• Be consistent with the standards and criteria of the NFIP, and
• Restore and preserve natural and beneficial floodplain values.
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Executive Order 11990 requires federal agencies to follow avoidance, mitigation, and preservation
procedures, with public input, before proposing new construction in wetlands. It generally requires:
• Avoidance of wetlands,
• Minimization of activities in wetlands, and
• Coordination with the USACE and CWA Section 404 regarding wetlands mitigation.
State
Water Quality Statutes and Regulations
Section 303(d) of the CWA requires that SWRCB identify surface water bodies within California that
do not meet established water quality standards. Once identified, the affected water body is
included in the SWRCB’s “303(d) Listing of Impaired Water Bodies” and a comprehensive program
must then be developed to limit the amount of pollutant discharges into that water body. This
program includes the establishment of “total maximum daily loads” for pollutant discharges into the
designated water body. The most recent 303(d) listing for California was approved by the United
States Environmental Protection Agency (EPA) in 2012.
The Porter-Cologne Water Quality Control Act of 1969 authorized the SWRCB to provide
comprehensive protection for California’s waters through water allocation and water quality
protection. The SWRCB implements the requirements of Clean Water Act Section 303, indicating
that water quality standards have to be set for certain waters by adopting water quality control plans
under the Porter-Cologne Act. The Porter-Cologne Act established the responsibilities and
authorities of the nine RWQCBs, which include preparing water quality plans for areas in the region,
identifying water quality objectives, and issuing NPDES permits and Waste Discharge Requirements.
Water quality objectives are defined as limits or levels of water quality constituents and
characteristics established for reasonable protection of beneficial uses or prevention of nuisance.
The Porter-Cologne Act was later amended to provide the authority delegated from the EPA to issue
NPDES permits. The RWQCB for the project site is the Santa Ana River Region.
Post-construction stormwater controls to satisfy requirements of the NPDES Program are permitted
under the Phase I Large Municipal Separate Storm Sewer System (MS4) Permit (Order No. R8-2009-
0030 as amended by Order No. 2010-0063).
Projects disturbing more than one acre of land during construction are required to comply with the
Construction General Permit (Order No. 2009-0009-DWQ as amended by 2010-0014-DWQ, effective
February 14, 2011; NPDES No. CAS000002). Construction General Permit activities are regulated at a
local level by the RWQCB. To obtain coverage under the Construction General Permit, a project
applicant must provide a Notice of Intent, a Storm Water Pollution Prevention Plan (SWPPP), and
other documents required by Attachment B of the Construction General Permit. Activities subject to
the Construction General Permit include clearing, grading, and disturbances to the ground, such as
grubbing or excavation.
The Construction General Permit uses a risk-based permitting approach and mandates certain
requirements based on the project risk level (Level 1, Level 2, or Level 3). The project risk level is based
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on the risk of sediment discharge and the receiving water risk. The sediment discharge risk depends on
project location and timing (such as wet season versus dry season activities). The receiving water risk
depends on whether the project would discharge to a sediment-sensitive receiving water. The
determination of the project risk level would be made by project applicant when the Notice of Intent is
filed (and when more details of the timing of the construction activity are known).
The performance standard in the Construction General Permit is that dischargers minimize or
prevent pollutants in stormwater discharges and authorized non-stormwater discharges through the
use of controls, structures, and best management practices (BMPs). An SWPPP must be prepared by
a qualified SWPPP developer that meets the certification requirements in the Construction General
Permit. The purpose of the SWPPP is (1) to help identify the sources of sediment and other
pollutants that could affect the quality of stormwater discharges, and (2) to describe and ensure the
implementation of BMPs to reduce or eliminate sediment and other pollutants in stormwater as well
as non-stormwater discharges resulting from construction activity. Operation of BMPs must be
overseen by a qualified SWPPP practitioner who meets the requirements outlined in the permit.
Local
City of Orange
General Plan
The City of Orange General Plan sets forth the following goals and policies relevant to hydrology and
water quality:
Natural Resources Element
• Goal 2.0: Protect air, water, and energy resources from pollution and overuse.
• Policy 2.4: Encourage the production, distribution, and use of recycled and reclaimed water
for landscaping projects, while maintaining urban runoff water quality objectives.
• Policy 2.12: Cooperate with water supply agencies to protect the quantity and quality of local
groundwater supplies.
• Policy 2.13: Control surface runoff water discharges into the stormwater conveyance system
to comply with the City’s NPDES Municipal Permit and other regional permits issued by the
Santa Ana Regional Water Quality Control Board.
• Policy 2.14: Reduce pollutant runoff from new development by requiring use of the most low
development impact practices and effective BMPs currently available.
• Policy 2.15: Minimize the amount of impervious surfaces and associated urban runoff
pollutants in new development and significant redevelopment throughout the community.
• Policy 2.16: Protect in-stream habitat and natural stream and channel features.
Infrastructure Element
• Goal 1.0: Ensure water, sewer, and storm drain systems that meet the needs of residents and
businesses.
• Policy 1.1: Provide sufficient levels of water, sewer, and storm drain service throughout the
community.
• Policy 1.2: Correct known deficiencies in the City’s sewer, storm drain, and water systems and
work toward environmentally sustainable systems.
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• Policy 1.6: Require that new developments fund fair-share costs associated with City provision
of water, sewer, and storm drain service and are consistent with City and service provider
plans to complete needed improvements and funding capacity for such improvements.
Drainage Area Management Plan
The Drainage Area Management Plan (DAMP) is Orange County’s principal policy and guidance
document for the NPDES program. The plan has been in effect since 1993, with subsequent updated
elements. A revised DAMP was submitted to the Santa Ana Regional Water Quality Control Board in
July 2006, known as the 2007 DAMP. In May 2009, the Santa Ana RWQCB re-issued the MS4 Permit
for the Santa Ana Region of Orange County (fourth term permit), which will result in future changes
to the Drainage Area Management Plan and City of Orange Local Implementation Plan and
stormwater program. In addition to the previous requirements under the third term permit, the
requirements of the new 4th term permit include requirements pertaining to hydromodification and
low impact development features associated with new developments and redevelopments.
3.9.4 - Methodology
FirstCarbon Solutions obtained information from the Hydrologic Assessment Report and the Water
Quality Technical Report, both prepared by Fuscoe Engineering, Inc. The Fuscoe reports are provided
in Appendix K.
Additional information was provided by the City of Orange General Plan, City of Orange General Plan
EIR, the City of Orange 2015 Urban Water Management Plan, and the Orange County Sheriff’s
Department Orange County Operational Area Emergency Action Plan Dam/Reservoir Failure Annex.
3.9.5 - Thresholds of Significance
According to Appendix G, Environmental Checklist, of the CEQA Guidelines, hydrology and water
quality impacts resulting from the implementation of the proposed project would be considered
significant if the project would:
a) Violate any water quality standards or waste discharge requirements?
b) Substantially deplete groundwater supplies or interfere substantially with groundwater
recharge such that there would be a net deficit in aquifer volume or a lowering of the local
groundwater table level (e.g., the production rate of pre-existing nearby wells would drop to
a level which would not support existing land uses or planned uses for which permits have
been granted?
c) Substantially alter the existing drainage pattern of area, including through the alteration of
the course of a stream or river, in a manner which would result in substantial erosion or
siltation on- or off-site?
d) Substantially alter the existing drainage pattern of the site or area, including through the
alteration of the course of a stream or river, or substantially increase the rate or amount of
surface runoff in a manner, which would result in flooding on- or off-site?
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e) Create or contribute runoff water which would exceed the capacity of existing or planned
stormwater drainage systems or provide substantial additional sources of polluted runoff?
f) Otherwise substantially degrade water quality?
g) Place housing within a 100-year flood hazard area as mapped on a federal Flood Hazard
Boundary or Flood Insurance Rate Map or other flood hazard delineation map?
h) Place within a 100-year flood hazard area structures, which would impede or redirect flood
flows?
i) Expose people or structures to a significant risk of loss, injury or death involving flooding,
including flooding as a result of the failure of a levee or dam?
j) Inundation by seiche, tsunami, or mudflow? (Refer to Section 7, Effects Found Not To Be
Significant.)
3.9.6 - Project Impacts and Mitigation Measures
This section discusses potential impacts associated with the development of the project and
provides mitigation measures where appropriate.
Water Quality
Impact HYD-1: Construction and operational activities associated with the proposed project may
potentially degrade water quality in downstream water bodies.
Impact Analysis
This impact addresses whether the proposed project would violate any water quality standards or
waste discharge requirements (Checklist Item a); substantially alter the existing drainage pattern of
area, including through the alteration of the course of a stream or river, in a manner which would
result in substantial erosion or siltation on- or off-site (Checklist Item c); or otherwise substantially
degrade water quality (Checklist Item f) during construction activities.
Short-Term Water Quality
Project implementation would require grading, building construction, and paving activities on the
40.7 acres proposed for residential development and portions of the remaining 68.5 acres proposed
for open space and recreation. During construction activities, there would be the potential for
surface water to carry sediment from on-site erosion and other pollutants into the stormwater
system and local waterways.
Construction of the proposed project would also require the use of gasoline- and diesel-powered
heavy equipment such as bulldozers, backhoes, water pumps, and air compressors. Chemicals such
as gasoline, diesel fuel, lubricating oil, hydraulic oil, lubricating grease, automatic transmission fluid,
paints, solvents, glues, and other substances would be utilized during construction. An accidental
release of any of these substances could degrade the water quality of the surface water runoff and
add additional sources of pollution into the drainage system.
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NPDES stormwater permitting is required by the State Water Board’s Construction General
Stormwater Permit (General Permit). The General Permit regulates stormwater discharges from
construction sites. Under the General Permit, the preparation and implementation of SWPPPs are
required for construction activities more than 1 acre in area. The SWPPP must identify potential
sources of pollution that may be reasonably expected to affect the quality of stormwater discharges
as well as identify and implement BMPs that ensure the reduction of these pollutants during
stormwater discharges.
Mitigation Measure HYD-1a is proposed, which would require the project applicant to prepare and
implement an SWPPP. The implementation of this mitigation measure would ensure that potential,
short-term, construction water quality impacts are reduced to a level of less than significant.
Long-Term Water Quality
The project site contains mostly pervious surfaces. Runoff either sheet flows into Santiago Creek or
sheet flows into inlets along onto adjoining roadways, where it enters the creek via the municipal
storm drainage system.
The proposed project would result in the removal of the existing improvements, the grading of the
site, and the development of up to 128 dwelling units and associated infrastructure and open space
and recreation facilities. The proposed project would increase the amount of impervious surface
coverage on the project site and would create the potential for discharge of urban pollutants into
downstream waterways. Such pollutants would include sediment and turbidity, nutrients, organic
compounds, oxygen demanding substances, trash and debris, bacteria and viruses, oil and grease,
pesticides, and metals. Expected generated pollutants are in Table 3.9-2, while runoff volumes and
treatment for the generated runoff and pollutants are outlined in Section IV of the Water Quality
Management Plan (WQMP). Additionally, because the project site is located in an area of potential
susceptibility to hydromodification and the overall project site’s imperviousness will increase in post-
development conditions, hydromodification calculations will be performed for the 2-year, 24-hour
rain events to assess for hydromodification requirements. Refer to Section II.4 of the WQMP in
Appendix K for Hydrologic Conditions for Concern (COC) criteria.
To ensure that stormwater quality measures are implemented to mitigate any associated generated
pollutants and runoff peak flows and volumes listed in the WQMP in Appendix K, Mitigation
Measure HYD-1b is proposed, which would require the project applicant to prepare and submit a
WQMP to the City of Orange for review and approval. Typical elements within a stormwater
management plan include identifying pollution prevention measures and practices that comply with
the most recently adopted provisions of the Municipal Regional Permit. The implementation of this
mitigation measure would ensure that potential, long-term, operational water quality impacts are
reduced to a level of less than significant.
Level of Significance Before Mitigation
Potentially significant impact.
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Mitigation Measures
MM HYD-1a Prior to the issuance of grading permits, the project applicant shall file a Notice of
Intent with and obtain a facility identification number from the State Water
Resources Control Board. The project applicant shall also submit an SWPPP to the
California State Water Resources Control Board/Santa Ana Regional Water Quality
Control Board. The SWPPP that identifies specific actions and BMPs to prevent
stormwater pollution during construction activities. The SWPPP shall identify a
practical sequence for BMP implementation, site restoration, contingency measures,
responsible parties, and agency contacts. The SWPPP shall include but not be limited
to the following elements:
• Comply with the requirements of the State of California’s most current
Construction Stormwater Permit.
• Temporary erosion control measures shall be implemented on all disturbed areas.
• Sediment shall be retained on-site by a system of sediment basins, traps, or other
BMPs.
• The construction contractor shall prepare Standard Operating Procedures for the
handling of hazardous materials on the construction site to eliminate discharge of
materials to storm drains.
• BMP performance and effectiveness shall be determined either by visual means
where applicable (e.g., observation of above-normal sediment release), or by actual
water sampling in cases where verification of contaminant reduction or elimination
(such as inadvertent petroleum release) is required by the Santa Ana Regional
Water Quality Control Board to determine adequacy of the measure.
• In the event of significant construction delays or delays in final landscape
installation, native grasses or other appropriate vegetative cover shall be
established on the construction site as soon as possible after disturbance, as an
interim erosion control measure throughout the wet season.
MM HYD-1b Prior to the issuance of building permits, the project applicant shall submit a WQMP
to the City of Orange for review and approval. The plan shall be developed using the
Orange County Model Water Quality Management Plan and Technical Guidance
Document. The WQMP shall identify pollution prevention measures, low impact
development features, and BMPs necessary to control stormwater pollution from
operational activities and facilities, identify hydromodification flow controls, and
provide for appropriate maintenance over time. The WQMP shall include design
concepts and BMPs that are intended to address the Design Capture Volume, more
commonly referred to as the “first flush,” and remove pollutants from the design
system event before entering the MS4. In accordance with the Regional MS4 Permit
and City of Orange WQMP requirements, the use of low impact development
features will be consistent with the prescribed hierarchy of treatment provided in
the Permit: including techniques to infiltrate, filter, store, evaporate, or retain runoff
close to the source of runoff. For those areas of the project where infiltration is not
recommended or acceptable and harvest/reuse demands are insufficient,
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biofiltration features will be designed to treat runoff and discharge controlled
effluent flows to downstream receiving waters. The project WQMP shall also
include an operations and maintenance plan for the prescribed Low Impact
Development (LID) features, structural BMPs, and any hydromodification controls to
ensure their long-term performance. A funding mechanism for operations and
maintenance shall also be prescribed.
Level of Significance After Mitigation
Less than significant impact.
Groundwater
Impact HYD-2: The proposed project would not contribute to groundwater overdraft or impair
groundwater recharge.
Impact Analysis
This impact assesses whether project would substantially deplete groundwater supplies or interfere
substantially with groundwater recharge, and the related issue of groundwater impairment from
underground storage tanks.
Groundwater Supplies
The proposed project would result in a net increase in demand for potable water from the City of
Orange. The proposed project is anticipated to demand 99.5 acre-feet of water annually; refer to
Section 3.17, Utilities and Service Systems for further detail regarding the demand estimate. The
City’s 2015 Urban Water Management Plan indicates that groundwater constitutes approximately 72
percent of the City’s potable water supply. The 2015 Urban Water Management Plan contemplates
up to 20,650 acre-feet of groundwater production from the OC Basin annually through 2040. Thus,
the proposed project’s demand would be equivalent to 0.5 percent of the total volume of city
groundwater production contemplated by the 2015 Urban Water Management Plan. Moreover, the
proposed project’s demand is accounted for by the 2015 Urban Water Management Plan and, thus,
reflected in the demand estimates.
The OC Basin is managed by OCWD, which assess fees to agencies that pump from the basin. The
fees are structured in a manner that penalizes pumping above the basin production percentage
threshold. Once the threshold is exceeded, additional fees are assessed that make the per unit cost
of groundwater production costlier than other sources of water (i.e., imported water). The OC Basin
is not classified as being in a state of overdraft by the California Department of Water Resources,
which serves as evidence that OCWD’s management efforts have been successful is preserving the
sustainability of the resource.
Because project demand would represent a very small percent of total groundwater supply and due
to the success of OCWD’s groundwater management efforts, impacts on groundwater resources
would be considered less than significant.
Local groundwater quality and methane levels at the adjacent Villa Park Landfill are monitored by
the OC Waste & Recycling division via monitoring wells. Additionally, the proposed project site is not
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expected to impact groundwater quality. Per Section III.3 and IV.3.2 of the WQMP in Appendix K,
infiltration has been deemed infeasible per findings by Ginter & Associates, Inc. in a 2012 study.
Therefore, infiltration shall not be promoted on-site.
Groundwater Recharge
The project site is bisected by Santiago Creek, which provides for groundwater recharge within its
channels. The proposed project would develop residential uses on 40.7 acres of the project site,
with open space and recreation uses on the remaining 68.5 acres. The entire Santiago Creek
corridor would be protected as a greenway and, thus, would be available for continued groundwater
recharge. As the project site is located in close proximity to the Villa Park landfill site, no infiltration
for groundwater recharge will be promoted on-site, and only incidental infiltration will occur on
landscaped areas. Therefore, the proposed project would not interfere with groundwater recharge
efforts. Impacts would be less than significant.
Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
Drainage
Impact HYD-3: The proposed project would not contribute runoff to downstream storm drainage
facilities that would result in the potential for flooding.
Impact Analysis
The proposed project would result in the development of up to 128 dwelling units and infrastructure
on 40.7 acres of the project site. The remaining acreage would be dedicated for open space and
recreation use. Thus, the proposed project would increase the amount of impervious surface
coverage on the project site, and would create the potential for increased runoff leaving the project
site that may create potential flooding conditions in downstream waterways.
Of particular concern is the Handy Creek storm drain, which currently accepts runoff from the project
site under existing conditions. The County of Orange has previously identified the storm drain as a
deficient flood control facility that is not capable of conveying runoff from a 100-year storm event.
The proposed project would install a network of storm drainage facilities within the project site
consisting of inlets, underground piping, and basins. This system would serve 72.58 acres of the site
and direct runoff to a 3.7-acre foot capacity stormwater detention basin in the western portion of
the site. A flow control structure will be installed within the detention system to meter the outflow
from the site to below predevelopment levels. This system is not intended for groundwater recharge
and will be lined to prevent infiltration. Catch basins will be located at various points within the site
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to capture subarea flows. The system is designed to detain flows from a 100-year storm event as
required by the Orange County Hydrology Manual.
Two sub drainage areas will flow directly to Santiago Creek without detention. One of these areas is
approximately 1.46 acres directly over the Handy Creek Channel. This flow will be directed to the
Handy Creek Channel. The other area is the trail system adjacent to Santiago Creek and totals 6.20
acres. This flow will be picked up via a storm drain system, which will outlet at the same location as
the detention basin outlet. The outlet structure from the detention basin to Santiago Creek will be
protected by riprap and an energy dissipater.
Table 3.9-6 summarizes existing and proposed discharge rates into Santiago Creek from the main
drainage area for the 2-year and 100-year storm events. As shown in the table, the project would
achieve a net reduction of stormwater discharge during storm events.
Table 3.9-6: Existing and Proposed Discharge Rates—Proposed Storm Drainage System
Storm Event Drainage Area
Cubic Feet/Second
Change Existing Proposed Difference
2-Year
72.58 acres
44.46 28.72 -15.74 -35.4%
100-Year 180.05 82.72 -97.33 -54.1%
Source: Fuscoe Engineering, 2016.
Table 3.9-7 summarizes existing and proposed discharge rates into the Handy Creek storm drain for
the 2-year and 100-year storm events. As shown in the table, the project would achieve no net
increase discharge of stormwater into the Handy Creek storm drain during storm events. Peak flows
to Handy Creek channel through will not be altered through implementation of the project and will
not pose any additional hazards or risks to downstream residents. This drainage area is not
proposed to receive any increases in impervious area as it is designated as open space. Refer to the
Hydrology Report in Appendix K for full calculations compiled via AES Hydrology Software and
HydroCAD Detention Modeling Software.
Table 3.9-7: Existing and Proposed Discharge Rates—Handy Creek Storm Drainage
Storm Event Drainage Area
Cubic Feet/Second
Change Existing Proposed Difference
2-Year
1.46 acres
1.41 1.41 — —
100-Year 4.43 4.43 — —
Source: Fuscoe Engineering, 2016.
This serves to illustrate that the proposed storm drainage system would slow, reduce, and meter the
volume of runoff leaving the project site and ensure that downstream storm drainage facilities are
not inundated with project-related stormwater. Impacts would be less than significant. Refer to
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Appendices 2, 3, &5 within the Hydrology Report in Appendix K for calculations compiled via AES
Hydrology Software and HydroCAD Detention Modeling Software.
Finally, the proposed project would not alter the two unnamed storm drains located in the
northwestern portion of the project site. Flow patterns in the project site’s post-development
conditions will continue to be conveyed in a similar manner to existing conditions. Refer to the
existing and proposed hydrology maps in Appendix 7 of the Hydrology Report in Appendix K for
further information on existing and proposed runoff patterns.
Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
100-Year Flood Hazard Areas
Impact HYD-4: The proposed project would not place housing or structures within a 100-year
flood hazard area.
Impact Analysis
As shown in Exhibit 3.9-1, the 100-year flood hazard areas within the project site overlap with the
Santiago Creek channel. The proposed project would establish a greenway along the creek corridor
and, thus, would not alter the existing 100-year flood hazard areas. Furthermore, the proposed
residential uses would be located outside of the 100-year flood hazard areas.
The areas mapped as 500-year flood hazard areas mostly coincide with areas proposed for open
space and recreation, although approximately 15 acres of the residential area overlaps with this
area. However, current federal regulations only require that “critical facilities” be located above the
500-year flood elevation; residential uses are permitted within this area.
Impacts would be less than significant.
Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
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Levee or Dam Failure
Impact HYD-5: The project may be susceptible to inundation from dam failure.
Impact Analysis
Santiago Dam is located 1.3 miles upstream of the project site. The dam was completed in 1931 and
impounds Irvine Lake. Santiago Dam is an earth/rock-fill structure that is 136 feet tall and 1,425 feet
long. The dam designed to contain up to a 50-year flood and withstand a 500-year flood of over
30,000 cubic feet per second.
Villa Park Dam is located approximately 1.5 miles upstream of the project site and is owned and
operated by the Orange County Flood Control District. The dam was completed in 1963 and is used
for flood control purposes; it does not store water for municipal use. Villa Park Dam is an
earth/rock-fill structure that has a capacity of 15,600 acre-feet.
The California Department of Water Resources Division of Safety of Dams oversees dam safety and
requires local dam operators to maintain records concerning maintenance, operation, staffing, and
engineering and geologic investigations that pertain to their facilities. Division of Safety of Dams
personnel have the ability inspect dams for safety and require operators to implement corrective
measures if deficiencies are found. Additionally, the Division of Safety of Dams oversees alteration
and repair of dams. The agencies that own and operate Santiago Dam and Villa Park Dam are
responsible for compliance with State laws that pertain to the safety of the facilities.
Additionally, at least one staff person from the Orange County Flood Control District is stationed at
each facility 24 hours a day, 7 days a week to monitor dam and reservoir conditions. Staff members
are trained in the operation of the facilities and would be able to identify and respond to indications
of adverse conditions; initial alerting of a dam failure would come from these dam keepers.
Furthermore, the Orange County Sheriff’s Department oversees the County’s Emergency Operations
Center and has modeled dam failure scenarios for both Villa Park Dam and Santiago Dam based on
FEMA Flood Maps (Exhibit 3.9-4). The Sheriff’s Department has developed plans to provide timely
notification to affected parties and implement an orderly evacuation in the event dam failure
indications are observed, such as the AlertOC mass notification system that provides time-sensitive
messages to residents from the City of County in which they live or work. The Orange County
Operational Area Emergency Action Plan Dams/Reservoir Failure Annex indicates that it would take a
dam failure flood wave 105 minutes to reach the project site from Villa Park Dam and 255 minutes
from Santiago Dam. Emergency response times vary on average from 4 to 7 minutes for the City of
Orange Police Department and 3 minutes, 45 seconds for the City of Orange Fire Department.
Further discussion on the City of Orange Police and Fire Departments can be found in Section 3.14,
Public Services of this Draft EIR.
In the interests of promoting awareness about the potential for dam failure and making future
residents aware of evacuation procedures, Mitigation Measure HYD-5 requires the applicant to
prepare and implement an emergency evacuation plan. With the implementation of mitigation,
impacts would be less than significant.
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Level of Significance Before Mitigation
Potentially significant impact.
Mitigation Measures
MM HYD-5 Prior to issuance of the first certificate of occupancy, the applicant shall retain a
qualified consultant to prepare and implement an Emergency Evacuation Plan. The
plan shall identify the various types of emergency that could affect the proposed
project (e.g., dam failure, earthquake, flooding, etc.) and identify procedures for the
safe and orderly evacuation of the project. The plan shall require that streets be
identified with clear and visible signage and, if necessary, wayfinding signage be
provided to identify exit points.
Level of Significance After Mitigation
Less than significant impact.
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3.10 - Land Use and Planning
3.10.1 - Introduction
This section describes the existing land use and potential effects from project implementation on the
site and its surrounding area. Descriptions and analysis in this section are based on site
reconnaissance, and review of the City of Orange General Plan, the Orange Municipal Code, the East
Orange Plan, and the Orange Park Acres Plan.
3.10.2 - Environmental Setting
Land Use
Project Site
The approximately 109.2-acre project site contains disturbed, privately owned undeveloped land
that previously supported mining activities and currently supports a sand gravel operator in
accordance with the existing Sand and Gravel zoning (Orange Municipal Code Chapter 17.32). The
project site is comprised of 12 parcels and is bisected by Santiago Creek in an east-west direction.
The site contains gently sloping terrain, with an overall change in elevation from 456 feet above
mean sea level in the northeast corner to 344 feet above mean sea level in the southwest corner.
An approximately 10-acre, semi-oval-shaped raised pad is located in the eastern portion of the site.
The pad sits roughly 15 feet higher than the mining area to the west.
Approximately 40 acres between Santiago Creek and East Santiago Canyon Road contains remnants
of the mining operation and is the location of the ongoing sand and gravel operation. This area is
characterized by soil piles, berms, and unpaved roads. Adjacent to East Santiago Canyon Road is an
approximately 5-acre area that supports a materials recycling operation that included apparatus for
the crushing of boulders, bricks, rocks, and similar materials for recycling. Materials used for these
operations originated primarily from off-site sources, and the materials generated by these
operations have historically been used both on-site and transported off-site. Ancillary uses included
administration and maintenance buildings, caretaker residence, material testing laboratory, driver’s
shack, rock crushing facilities, several aboveground and belowground fuel storage tanks, and two
hot-mix asphalt plants.
Additionally, the previously mined portions of the site were “backfilled,” in which unsuitable
materials are excavated and replaced with fill, pursuant to a grading permit issued by the City of
Orange in 2011. It was anticipated that approximately 223,000 cubic yards of material would be
imported to the site during the process, including concrete, asphalt, and rock that would be crushed
on-site. Approximately 2,000 cubic yards of material was anticipated to be excavated from the site
for reuse and would be blended with the crushed import material for a total of 225,000 cubic yards
of backfill. In 2015, in a “good faith” gesture, the operator voluntarily temporarily suspended
operations on the site, and limited rock crushing operations to a total of 15 consecutive business
days in any 6-month period. The operator reserved the right to resume all operations consistent
with the Sand and Gravel zoning.
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Santiago Creek enters the site at the eastern boundary, flows west, and exits the western boundary
at North Cannon Street. The creek originates at Irvine Lake and is tributary to the Santa Ana River.
The drainage feature splits near the central portion of the project site, with an upland area
separating Santiago Creek into two rivulets. The average width of the drainage feature is
approximately 55 feet, which includes the area between the ordinary high water mark and the
adjacent defined wetland areas. Wetland areas are generally located on either side of the active
channel. The creek corridor is privately owned and is not accessible to the public.
Natural vegetation within the site is primarily located along Santiago Creek. Plant communities
include coast live woodland, coastal sage scrub, eucalyptus woodland, non-native grassland,
ornamental, southern cottonwood-willow riparian forest, and undifferentiated open woodland.
There are 323 trees located with the project site, of which the most common species are blue gum
(eucalyptus), oak, willow, and palm.
The Handy Creek storm drain operated by the Orange County Flood Control District (Facility No.
E08S06) is located in the central portion of the project site. The storm drain enters the project site
from the south at the intersection of North Nicky Way/East Santiago Canyon Road. The storm drain
coveys stormwater collected in areas south of East Santiago Canyon Road into Santiago Creek. An
unnamed storm drain located in the northwestern portion of the project site conveys stormwater
collected in the Mabury Ranch neighborhood directly into Santiago Creek.
The Allen McCulloch Pipeline trunk water distribution line operated by the Metropolitan Water
District (MWD) traverses the easterly portion of the project site and is located entirely below grade.
The pipeline traverses the site within a 50-foot-wide easement. The easement crosses through the
site in a northwest-southeast direction, entering the site from the north at the intersection of
Mabury Avenue/Yellowstone Boulevard, and exiting at the single-family residential subdivision to the
south. The pipe measures 109 inches in diameter and is part of the MWD transmission system that
supplies potable water to southern Orange County.
There are historic ground water and methane monitoring wells associated with the closed adjoining
Villa Park Landfill that are located on the western portion of the project site.
Surrounding Area
West
The closed Villa Park Landfill and North Cannon Street form the western boundary of the project site.
The 18-acre County Villa Park Landfill property occupies the northeast quadrant of the intersection of
East Santiago Canyon Road/North Cannon Street and is owned by the County of Orange. The landfill
operated from 1962 through 1966. The site is enclosed with a fence and contains groundwater
monitoring wells and a landfill gas disposal system. Areas to the west also include detached, single-
family dwelling units related to West of Cannon (typical lot size 7,800–10,000 square feet).
North Cannon Street is a four-lane divided roadway and crosses Santiago Creek via a concrete bridge.
A paved Class I bicycle/pedestrian path (Santiago Creek Bike Trail) is located along the west side of
North Cannon Street south of Santiago Creek. See Exhibit 2-5 in Section 2, Project Description of this
City of Orange—Trails at Santiago Creek Specific Plan
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Draft Environmental Impact Report (EIR) for the locations of surrounding residential uses with typical
lot sizes less than 10,000 square feet.
North
Single-family residential uses are located to the north of the project site, including Creekside Ranch
(typical lot size 9,200–12,000 square feet), The Colony-North (typical lot size 8,600–12,000 square
feet), Mabury Ranch (typical lot size 7,600–11,000 square feet), Hidden Creek (typical lot size
20,000–24,500 square feet), Serrano Heights (typical lot size 4,500–9,000 square feet), and Parkridge
(typical lot size 8,000–12,000 square feet). Detached, single-family dwelling units are located along
the north bank of Santiago Creek.
Mabury Avenue is a two-lane undivided roadway. An unpaved trail (Santiago Creek Trail) is located
along the north bank of the creek, parallel to Mabury Avenue.
East
Santiago Oaks Regional Park and detached, single-family residential uses associated with The
Reserve (typical lot size 20,000–44,000 square feet) form the eastern boundary of the project site.
The regional park contains the Santiago Creek corridor, which consists of the waterway and dense
vegetation. Detached, single-family dwelling units are located east of the project site.
South
East Santiago Canyon Road, a four-lane, divided roadway, forms the southern boundary of the
project site. Detached single-family dwelling units associated with the Jamestown neighborhood
(typical lot size 8,000–11,000 square feet), Orange Park Acres (typical lot size 50,000 to 1 acre plus
square feet), Eichler Homes (typical lot size 7,600–12,000 square feet), and The Colony-South
(typical lot size 7,000–10,000 square feet) are located south of the roadway. The Mara Brandman
Arena is located at the intersection of East Santiago Canyon Road and North Nicky Way.
Land Use Designations
Project Site
The City of Orange General Plan designates portions of the project site “Low Density Residential,”
“Resource Area,” and “Open Space.” The City of Orange Zoning Ordinance zones the project site “S-
G (Sand and Gravel Extraction)” and “R-1-8 (Single-Family Residential 8,000 square-feet).”
Surrounding Land Uses
Table 3.10-1 summarizes surrounding City of Orange General Plan, City of Orange zoning, East
Orange General Plan, and Orange Park Acres Plan land use designations in the project vicinity.
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Table 3.10-1: Surrounding Land Use Designations
Land Use
Relationship to
Project Site
Land Use Designation
General Plan Zoning
East Orange
General Plan
Orange Park
Acres Plan
Villa Park Landfill
(Closed)
West Open Space S-G (Sand and Gravel) N/A N/A
Single-family
residential
neighborhood
North Low Density
Residential
R-1-8 (Single-family
residential; 8,000 square feet)
N/A N/A
Santiago Oaks
Regional Park
East Open Space
Park
R-O (Recreation Open Space) N/A N/A
Single-family
residential
neighborhood
East Estate Low
Density
Residential
R-1-40 (Single-family
residential; 40,000 square feet)
N/A Low
Density
Residential
Salem Lutheran
Church and School
South Public
Facilities
Institutions
SP-P-I (Specific Plan Public
Institution)
N/A Church
Mara Brandman
Arena
South Estate Low
Density
Residential
R-1-40 (Single-family
residential; 40,000 square feet)
Low
Density
Residential
Low
Density
Residential
Single-family
residential
neighborhood
South Estate Low
Density
Residential
R-1-8 (Single-family residential;
8,000 square feet)/R-1-20
(Single-family residential;
20,000 square feet)
Low
Density
Residential
Low
Density
Residential
Source: City of Orange, 2016.
East Orange General Plan
The East Orange General Plan was adopted in 1975 and encompasses approximately 1,900 acres. In
accordance with the City of Orange Planning Division, approximately 37 acres of the project site are
located within the boundaries of the 1975 East Orange General Plan. The project site constitutes
approximately 2 percent of the overall East Orange General Plan acreage. The East Orange General
Plan designates the project site as “Regional Park.” Exhibit 3.10-1 depicts the portion of the
proposed project that is within the East Orange General Plan.
Orange Park Acres Plan
The Orange Park Acres Plan (OPA Plan) was adopted on December 26, 1973. In accordance with the
City of Orange Planning Division, approximately 39 acres of the project site are presently located
within the boundaries of the existing OPA Plan. There are approximately 1,794 total acres in the OPA
Plan. The project site is approximately 3 percent of the overall OPA Plan acreage. The OPA Plan
designates this area as “Open Space.” Exhibit 3.10-2 depicts the portion of the proposed project
that is within the OPA Plan.
I
27650002 • 07/2018 |3.10-1_EO_gp.cdr
Exhibit 3.10-1
East Orange General Plan
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: City of Orange
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I
27650002 • 07/2018 |3.10-2_orange_park.cdr
Exhibit 3.10-2
Orange Park Acres Plan
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: City of Orange
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Central/Coastal Natural Community Conservation Plan and Habitat Conservation Plan
The project site is within the central subregion of the County of Orange Central/Coastal Subregion
Natural Community Conservation Plan/Habitat Conservation Plan (NCCP/HCP). The NCCP/HCP is
intended to protect and manage coastal sage scrub habitat and coastal sage scrub-obligate species,
as well as other covered habitats and species, and mitigate anticipated impacts on those habitats
and species on a programmatic, subregional level.
3.10.3 - Regulatory Framework
Regional
Central/Coastal Natural Community Conservation Plan and Habitat Conservation Plan
The project site is within the central subregion of the County of Orange Central/Coastal Subregion
NCCP/HCP (Exhibit 3.4-6). The NCCP/HCP was reviewed and approved by the United States Fish and
Wildlife Service (USFWS) and the California Department of Fish and Wildlife (CDFW) in 1996 to
address protection and management of coastal sage scrub habitat and coastal sage scrub-obligate
species, as well as other covered habitats and species, and mitigate anticipated impacts on those
habitats and species on a programmatic, subregional level rather than on a project-by-project,
single-species basis. A habitat reserve in excess of 37,000 acres was established for the protection of
coastal sage scrub, other upland habitats, the coastal California gnatcatcher, and the other primarily
coastal sage scrub-dependent species identified in the NCCP/HCP. Specifically, the NCCP/HCP, the
USFWS, and the CDFW authorized take of 39 identified species of plants and wildlife (including
covered and conditionally covered species). Further, the NCCP/HCP contains requirements for
adaptive management, interim management, and funding management for the reserve as well as
procedures and minimization measures related to the take of identified species and habitat. Thus,
the NCCP/HCP provides for the protection and management of a broad range of plant and wildlife
populations while providing certainty to the public and affected landowners with respect to the
location of future development and open space in the subregion.
The NCCP/HCP provides for the protection of a number of plant and animal species, referred to as
Target Species and Identified Species. There are also identified NCCP/HCP species that have
conditional regulatory coverage under the NCCP/HCP referred to as conditionally covered Identified
Species. The conservation and management of these species is provided for under the NCCP. A
development activity authorized under the NCCP/HCP necessarily includes protection of these
species and also means that no further action under CESA or FESA is required for the approved
activity should any of the Target or Identified Species be subsequently listed as endangered or
threatened under either of these Acts. As a consequence, Target and Identified Species are
considered sensitive.
Local
City of Orange
General Plan
The City of Orange General Plan serves as the City of Orange’s land use and development policy
document and identifies how the City will grow and conserve its resources. The City of Orange
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General Plan contains the following elements: Land Use, Circulation and Mobility, Growth
Management, Natural Resources, Public Safety, Noise, Cultural Resources and Historic Preservation,
Infrastructure, Urban Design, and Economic Development. Within each element, the City of Orange
General Plan sets forth goals and policies to guide future development and land use activities.
The project site is currently designated “Resource Area,” “Low Density Residential,” and “Open
Space” by the City of Orange General Plan. In accordance with the proposed project: The portion of
the site north of Santiago Creek, currently designated as “Low Density Residential,” is proposed to be
re-designated as “Open Space” and the portion of the site currently designated as “Resource Area” is
proposed to be re-designated to “Low Density Residential,” and “Open Space.” Refer to Impact LUP-
1 for further discussion of the proposed City of Orange General Plan Amendment.
Municipal Code
The City of Orange Municipal Code governs development and land use activities within the Orange
City limits. Within the Municipal Code is the Zoning Code (Title 17), which establishes zoning
districts and associated development standards and allowable/conditional uses.
The project site is zoned “S-G (Sand and Gravel)” and “R-1-8 (Single Family Residential 8,000 square
feet)” by the Zoning Code. The site is proposed to be rezoned to “SP (Specific Plan).” Refer to
Impact LUP-2 for further discussion of the proposed rezoning.
3.10.4 - Methodology
FirstCarbon Solutions (FCS) personnel performed site reconnaissance of the project site in December
2016. FCS documented existing conditions with digital photographs and notes. FCS reviewed the
City of Orange General Plan, the City of Orange Municipal Code, the East Orange General Plan, and
the Orange Park Acres Plan for provisions applicable to the proposed project. Finally, FCS reviewed
project plans for consistency with the relevant provisions of the General Plan and Municipal Code.
3.10.5 - Thresholds of Significance
According to the CEQA Guidelines’ Appendix G Environmental Checklist, to determine whether land
use and planning impacts are significant environmental effects, the following questions are analyzed
and evaluated. Would the project:
a) Physically divide an established community? (Refer to Section 7, Effects Found Not To Be
Significant)
b) Conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction
over the project (including, but not limited to the general plan, specific plan, local coastal
program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an
environmental effect?
c) Conflict with any applicable habitat conservation plan or natural communities conservation
plan?
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3.10.6 - Project Impacts Mitigation Measures
This section discusses potential impacts associated with the proposed project and provides
mitigation measures where necessary.
General Plan Consistency
Impact LUP-1: The project would not conflict with any of the applicable provisions of the City of
Orange General Plan.
Impact Analysis
This impact evaluates (1) the proposed General Plan Amendment’s compatibility with the City of
Orange General Plan and surrounding land uses and (2) the proposed project’s consistency with the
applicable goals and policies of the General Plan.
General Plan Amendment
The project site is currently designated “Resource Area,” “Low Density Residential,” and “Open
Space . . .” The “Resource Area” land use designation reflects the current surface mining activities
that occurred on the south side of Santiago Creek. The “Low Density Residential” designation
applies to the portion of the site north of Santiago Creek, adjacent to Mabury Avenue. The “Open
Space” designation applies to a relatively narrow strip running through the site from east to west
and roughly following Santiago Creek.
The proposed project involves the development of 128 dwelling units on approximately 40.7 acres
within the area currently designated “Resource Area” and the preservation of the remaining 68.5
acres (which overlap with the “Resource Area” and “Low Density Residential” designations) as open
space and recreation uses. Accordingly, the applicant is proposing to change the “Resource Area”
designation to a combination of “Low Density Residential,” and “Open Space”; and the “Low Density
Residential” designation to “Open Space.” The area currently designated “Open Space” will remain
“Open Space.”
These land use changes are necessary to allow the proposed development on the site, and are
consistent and compatible with the other surrounding residential land use designations; refer to
Table 3.10-1. With implementation of the General Plan Amendment, the project will be consistent
with the City of Orange General Plan.
General Plan Consistency Analysis
Table 3.10-2 evaluates project consistency with the applicable goals and policies of the City of
Orange General Plan.
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Table 3.10-2: General Plan Consistency Analysis
Element
Goal/Policy
Consistency Determination No. Text
Land Use Goal 1.0 Meet the present and future needs
of all residential and business
sectors with a diverse and balanced
mix of land uses.
Consistent: The proposed project
would redevelop a site previously
used for surface mining activities to
support up to 128 dwelling units
and open space and recreation
uses. This is consistent with the
goal of meeting current and future
needs with a diverse and balanced
mixed of land uses.
Policy 1.1 Maintain a land use structure that
balances jobs and housing with
available infrastructure and public
and human services.
Consistent: The proposed project
would develop up to 128 dwelling
units in a city and county that are
considered “jobs rich.” Thus, the
project would promote jobs-
housing balance.
Policy 1.2 Balance economic gains from new
development while preserving the
character and densities of
residential neighborhoods.
Consistent: The proposed project
promotes land use compatibility
with surrounding residential
development by clustering the new
dwelling units on 40.7 acres of the
site adjacent to East Santiago
Canyon Road and preserving the
remaining acreage for open space
and recreation use. This is
consistent with the policy of
balancing economic benefits with
the preservation of neighborhood
character.
Policy 1.3 Provide a range of housing
densities and types to meet the
diverse needs and lifestyles of
residents.
Consistent: The proposed project
would develop 128 new single-
family dwelling units and, thus,
provide new housing opportunities.
Policy 1.4 Ensure that new development
reflects existing design standards,
qualities, and features that are in
context with nearby development.
Consistent: The proposed project
promotes land use compatibility
with surrounding residential
development by clustering the new
dwelling units on 40.7 acres of the
site adjacent to East Santiago
Canyon Road and preserving the
remaining acreage for open space
and recreation use. Additionally,
the density and housing products
are similar to the residential uses to
the north, east, and south.
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Table 3.10-2 (cont.): General Plan Consistency Analysis
Element
Goal/Policy
Consistency Determination No. Text
Policy 1.7 Provide a range of open space and
park amenities to meet the diverse
needs of current and new
residents.
Consistent: The proposed project
would provide publicly accessible
open space and recreation uses,
including a trail network.
Goal 6.0 Advance development activity that
is mutually beneficial to both the
environment and the community.
Consistent: The proposed project
would cluster the new dwelling
units on 40.7 acres of the site near
East Santiago Canyon Road and
preserve the remaining acreage as
open space and recreation. The
latter uses include the Santiago
Creek corridor, which would be
preserved as a greenway.
Policy 6.1 Ensure that new development is
compatible with the style and
design of established structures
and the surrounding environment.
Consistent: The proposed project
promotes land use compatibility
with surrounding residential
development by clustering the new
dwelling units on 40.7 acres of the
site adjacent to East Santiago
Canyon Road and preserving the
remaining acreage for open space
and recreation use. Additionally,
the density and housing products
are similar to the residential uses to
the north, east, and south.
Policy 6.3 Establish and maintain greenways,
and pedestrian and bicycle
connections that complement the
residential, commercial and open
space areas they connect.
Consistent: The proposed project
would protect the Santiago Creek
corridor as a greenway and develop
a trail network that would connect
North Cannon Street to Santiago
Oaks Regional Park.
Policy 6.5 Reduce pollutant runoff from new
development and urban runoff to
the maximum extent practicable.
Consistent: The proposed project’s
storm drainage system would
incorporate Low Impact
Development concepts that
promote on-site percolation
instead of off-site discharge.
Policy 6.6 Enhance the walkability of both
new and current development.
Consistent: The proposed project
would include sidewalks along
internal streets and a trail network
that would connect North Cannon
Street to Santiago Oaks Regional
Park.
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Table 3.10-2 (cont.): General Plan Consistency Analysis
Element
Goal/Policy
Consistency Determination No. Text
Policy 6.10 Mitigate adverse air, noise,
circulation, and other
environmental impacts caused by
new development adjacent to
existing neighborhoods through use
of sound walls, landscaping buffers,
speed limits, and other traffic
control measures.
Consistent: The proposed project
promotes land use compatibility
with surrounding residential
development by clustering the new
dwelling units on approximately 40.7
acres of the site adjacent to East
Santiago Canyon Road and
preserving the remaining acreage for
open space and recreation use.
Additionally, the proposed project
would employ a landscaped buffer
with the residential uses to the east.
Circulation Goal 1.0 Provide a safe, efficient, and
comprehensive circulation system
that serves local needs, meets
forecasted demands, and sustains
quality of life in neighborhoods.
Consistent: The proposed project
would develop an internal street
network that connects to East
Santiago Canyon Road. The
proposed project would also
include pedestrian facilities
consisting of a trail network.
Policy 1.1 Plan, build, and maintain an
integrated, hierarchical, and multi-
modal system of roadways,
pedestrian walkways, and bicycle
paths throughout the City.
Consistent: The proposed project
would develop new internal
roadways and pedestrian facilities
consisting of a trail network that
would connect North Cannon
Street to Santiago Oaks Regional
Park. Additionally, project streets
and the trail network would be
accessible to bicycles. These
attributes are consistent with the
policy of developing a multi-modal
transportation system.
Policy 1.7 Consolidate driveways along
roadways that provide access to
commercial uses to minimize side
street interruption and promote
smooth traffic flows.
Consistent: The proposed project
would have only two vehicular
access points on East Santiago
Canyon Road.
Goal 4.0 Provide efficient and accessible
modes of pedestrian, bicycle, and
equestrian transportation and
improved facilities and amenities.
Consistent: The proposed project
would develop pedestrian facilities
consisting of a trail network that
would connect North Cannon
Street to Santiago Oaks Regional
Park. Additionally, project streets
and the trails would be accessible
to bicycles. Equestrians would also
be able to use the trails.
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Table 3.10-2 (cont.): General Plan Consistency Analysis
Element
Goal/Policy
Consistency Determination No. Text
Policy 4.1 Create a comprehensive bicycle
network that is integrated with other
transportation systems by
establishing complementary on-
street and off-street facilities as
identified in the City of Orange
Bikeways Master Plan and OCTA
Commuter Bikeways Strategic Plan,
including Santiago Creek, the Santa
Ana River, and the Tustin Branch Trail.
Consistent: The proposed trail
network includes facilities
contemplated by the City’s and
OCTA’s bikeways plans.
Growth
Management
Goal 1.0 Reduce traffic congestion within
the City.
Consistent: The proposed project’s
impacts on traffic are evaluated in
Section 3.16, Transportation. Local
intersections were evaluated
against the City’s adopted
performance standards and
mitigation measures were
proposed to improve deficient
operations to acceptable levels.
This is consistent with the goal of
reducing traffic congestion.
Policy 1.1 Establish Level of Service (LOS) D as
the level of service standard for
traffic circulation within the City for
both roadway segments and peak-
hour signalized intersection
movements.
Consistent: LOS D was used as the
basis for evaluating project impacts
on intersection operations. Refer
to Section 3.16, Transportation for
further discussion.
Policy 1.2 Ensure completion of
transportation improvements as
agreed upon by the City and
developer prior to completion of a
development project.
Consistent: All vehicular access
points (including the improved
intersection of East Santiago
Canyon Road/North Nicky Way)
would be required to be completed
in accordance with City standards
prior to issuance of the first
certificate of occupancy.
Policy 1.3 Ensure that new development pays
its fair share of street improvement
costs, including regional traffic
mitigation. New revenues
generated from Measure M, if
available, shall not be used to
replace private developer funding
which has been omitted for any
project.
Consistent: The project applicant
would install a signal and
intersection improvements at the
entrance to the project on East
Santiago Canyon Road/North Nicky
Way and contribute fair-share fees to
improvements at Orange Park
Boulevard/East Santiago Canyon
Road and Chapman Avenue/East
Santiago Canyon Road. Refer to
Section 3.16, Transportation for
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Table 3.10-2 (cont.): General Plan Consistency Analysis
Element
Goal/Policy
Consistency Determination No. Text
further discussion.
Policy 1.4 Continue to collect transportation
impact fees for improvements
within the City boundaries and work
with adjacent jurisdictions to
determine that an appropriate level
of transportation impact fees are
maintained within the established
County GMAs.
Consistent: The project applicant
will pay all adopted transportation
fees at the time building permits
are sought.
Policy 1.9 Ensure that new developments
incorporate non-motorized and
alternative transit amenities such as
bike racks, bus benches and shelters,
and pedestrian connections.
Consistent: The proposed project
would develop pedestrian facilities
consisting of sidewalks along streets
and a new creek trail that would
connect North Cannon Street to
Santiago Oaks Regional Park.
Policy 2.3 Continue to work toward achieving
a balance between residential,
industrial, commercial, and public
land uses. Support programs that
match Orange residents with local
jobs to reduce long commutes and
improve the fiscal and public health
of the community.
Consistent: The proposed project
would develop 128 new dwelling
units in a City and County that are
“jobs rich.” Thus, the new housing
opportunities would promote the
objective of balancing residential
and non-residential development.
Policy 2.4 Explore infill development or
mixed-use opportunities wherever
possible as developable space
becomes more limited.
Consistent: The project site is
located within the Orange City
limits on a major arterial roadway
and is surrounded by existing
residential uses on three sides.
Thus, the proposed project would
be considered an “infill project.”
Natural
Resources
Goal 1.0 Provide recreational use, scenic
enjoyment, and the protection of
natural resources and features in
open space areas.
Consistent: The proposed project
would provide acreage for open
space and recreation use, which
would include a creek trail. This
acreage encompasses the Santiago
Creek corridor, the most significant
natural feature within the project
site.
Policy 1.3 Promote development of additional
open spaces and access points
adjacent to waterways and planned
trails.
Consistent: The proposed project
would provide acreage for open
space and recreation use, including
a greenway along Santiago Creek.
Within the greenway would be a
trail network, which would allow
public access to the waterway.
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Table 3.10-2 (cont.): General Plan Consistency Analysis
Element
Goal/Policy
Consistency Determination No. Text
Goal 2.0 Protect air, water, and energy
resources from pollution and
overuse.
Consistent: This EIR evaluates
project impacts associated with air
quality, hydrology and water
quality, and utility systems and sets
forth mitigation measures where
necessary to protect resources.
Policy 2.1 Cooperate with the South Coast Air
Quality Management District
(SCAQMD) and other regional
agencies to implement and enforce
regional air quality management
plans.
Consistent: This EIR uses
SCAQMD’s guidance to assess air
quality impacts. Refer to Section
3.3, Air Quality for further
discussion.
Policy 2.2 Support alternative transportation
modes, alternative technologies,
and bicycle- and pedestrian-friendly
neighborhoods to reduce emissions
related to vehicular travel.
Consistent: The proposed project
would develop pedestrian facilities
consisting of sidewalks along
streets and a trail network that
would connect North Cannon
Street to Santiago Oaks Regional
Park. These facilities would
facilitate alternative transportation
modes of travel.
Policy 2.13 Control surface runoff water
discharges into the stormwater
conveyance system to comply with
the City’s National Pollutant
Discharge Elimination System
(NPDES) Municipal Permit and
other regional permits issued by
the Santa Ana Regional Water
Quality Control Board.
Consistent: The proposed project’s
storm drainage system would
comply with the applicable
provisions of the regional permits
for stormwater management.
Refer to Section 3.9, Hydrology and
Water Quality for further
discussion.
Policy 2.14 Reduce pollutant runoff from new
development by requiring use of
the most low development impact
practices and effective Best
Management Practices (BMPs)
currently available.
Consistent: The proposed project’s
storm drainage system would
incorporate Low Impact
Development concepts that
promote on-site percolation instead
of off-site discharge. Refer to
Section 3.9, Hydrology and Water
Quality, for further discussion.
Policy 2.15 Minimize the amount of impervious
surfaces and associated urban
runoff pollutants in new
development and significant
redevelopment throughout the
community.
Consistent: The proposed project
would cluster residential
development on approximately
40.7 acres of the site and preserve
the remaining acreage as open
space and recreational uses. These
latter uses would be expected to be
primarily natural, pervious surfaces
and, thus, they would generate
very little to no polluted runoff.
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Table 3.10-2 (cont.): General Plan Consistency Analysis
Element
Goal/Policy
Consistency Determination No. Text
Policy 2.16 Protect in-stream habitat and
natural stream and channel
features.
Consistent: The proposed project
would establish a greenway along
Santiago Creek, which would
facilitate the protection of riparian
habitat.
Goal 4.0 Conserve and protect wildlife
habitat, plant and animal species of
concern, and general biodiversity.
Consistent: The proposed project
would preserve more than half the
site for open space and recreational
use. This includes a greenway
along Santiago Creek, which is the
most significant biological feature
within the project site.
Policy 4.1 Preserve and protect native and
habitat-supporting plant resources
throughout the City.
Consistent: The proposed project
would preserve more than half the
site for open space and recreational
use. This includes area that
provides suitable habitat for
special-status plant species.
Policy 4.2 Work with agencies, including the
Orange County Flood Control
District, to identify opportunities to
enhance the natural qualities of
Santiago Creek to protect habitat
and reintroduce native plants and
animals.
Consistent: The proposed project
would establish a greenway along
Santiago Creek, which would
permanently protect the creek
habitat.
Policy 4.4 Repair or improve ecological and
biological conditions in the urban
and natural environments when
reviewing proposals for site
development and redevelopment,
as well as public improvements.
Consistent: The proposed project
would preserve more than half the
site for open space and recreational
use. This includes a greenway
along Santiago Creek, which is the
most significant biological feature
within the project site.
Policy 4.5 Protect the Santiago Creek and
Santa Ana River corridors from
premature urbanization to ensure
the continued availability of
important sand and gravel, flood
control, water recharge, biological,
and open space resources.
Consistent: The proposed project
would establish a greenway along
Santiago Creek, which would
permanently protect the waterway
within the project site. Additionally,
the economically recoverable
mineral resources within the project
site have largely been depleted and,
thus, the redevelopment of the site
to support residential, open space,
and recreational uses would not be
premature.
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Table 3.10-2 (cont.): General Plan Consistency Analysis
Element
Goal/Policy
Consistency Determination No. Text
Goal 6.0 Provide for alternative modes of
transportation and access to
recreational resources through a
multi-use trail system that links the
City’s parks and regional open
space amenities.
Consistent: The proposed project
would develop a trail network that
would connect North Cannon Street
to Santiago Oaks Regional Park.
Policy 6.4 Link existing equestrian trails and
provide outlets to open space
areas, particularly in the northeast
region of the City, to reach regional
parks such as Santiago Oaks, Irvine,
Peters Canyon, and the Cleveland
National Forest.
Consistent: The proposed project
would develop a trail network that
would connect North Cannon Street
to Santiago Oaks Regional Park.
Public Safety Goal 2.0 Protect the City from flood-related
risks and hazards.
Consistent: The Santiago Creek
channel contains 100-year flood
hazard areas. The proposed project
would establish a greenway along
the creek corridor and locate new
residential development a
minimum of 50 feet from the creek
centerline in order to protect
hydrological values of the creek.
Additionally, all dwelling units
would be located above the 100-
year flood elevation. Thus, the
proposed project would not
increase the risk for flooding along
Santiago Creek.
Goal 4.0 Minimize risks to life, property, and
the environment associated with
producing, using, storing, or
transporting hazardous materials.
Consistent: The project site was
previously used for surface mining
activities and contains Total
Petroleum Hydrocarbon—(TPH)
and trichloroethylene—(TCE)
impacted soils. This Draft EIR
requires that these existing
conditions be abated in accordance
with California Department of Toxic
Substances Control (DTSC)
standards as part of the
development of new residential
uses. Refer to Section 3.8, Hazards
and Hazardous Materials for
further discussion.
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Table 3.10-2 (cont.): General Plan Consistency Analysis
Element
Goal/Policy
Consistency Determination No. Text
Policy 4.3 Identify hazardous materials
dumpsites, and ensure that the
sites are cleaned in conformance
with applicable federal and state
laws prior to the establishment of
new uses.
Consistent: The project site
contains TPH- and TCE-impacted
soil. This Draft EIR requires that
these existing conditions be abated
to DTSC standards as part of the
development of new residential
uses. Refer to Section 3.8, Hazards
and Hazardous Materials for
further discussion.
Goal 7.0 Improve community safety and
reduce opportunities for criminal
activity.
Consistent: The proposed project’s
open space and recreational facilities
would be visible from surrounding
land uses and would employ
appropriate safety and security
measures to deter criminal activity.
Policy 7.4 Ensure that community areas and
amenities such as transit stops,
sidewalks, plazas, parks, trails, and
bike paths are appropriately
lighted, free of hiding places, and
frequently patrolled.
Consistent: The proposed project’s
open space and recreational facilities
would be visible from surrounding
land uses and would employ
appropriate safety and security
measures to deter criminal activity.
Goal 9.0 Provide safe pedestrian and bicycle
environments.
Consistent: The proposed project
would develop pedestrian facilities
consisting of sidewalks along streets
and a trail network that would
connect North Cannon Street to
Santiago Oaks Regional Park.
Additionally, project streets and the
trails would be accessible to bicycles.
Noise Goal 1.0 Promote a pattern of land uses
compatible with current and future
noise levels.
Consistent: This EIR evaluates
project-related noise impacts on
surrounding land uses and requires
mitigation to achieve acceptable
standards. Refer to Section 3.12,
Noise for further discussion.
Policy 1.1 Consider potential excessive noise
levels when making land use
planning decisions.
Consistent: This EIR evaluates
project-related noise impacts on
surrounding land uses and requires
mitigation to achieve acceptable
standards. Refer to Section 3.12,
Noise for further discussion.
Policy 1.6 Require an acoustical study for
proposed developments in areas
where the existing and projected
Consistent: This EIR includes an
acoustical study that prepared in
accordance with the Noise Element
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Table 3.10-2 (cont.): General Plan Consistency Analysis
Element
Goal/Policy
Consistency Determination No. Text
noise level exceeds or would exceed
the maximum allowable levels
identified in Table N-3. The
acoustical study shall be performed
in accordance with the requirements
set forth within this Noise Element.
requirements. Refer to Section
3.12, Noise for further discussion.
Goal 2.0 Minimize vehicular traffic noise in
residential areas and near noise-
sensitive land uses.
Consistent: The proposed project
minimizes vehicular traffic noise
impacts on surrounding residential
uses by taking access from East
Santiago Canyon Road, an arterial
roadway. No vehicular access would
be taken from surrounding
residential streets, thereby avoiding
an increase in traffic noise levels in
the most noise sensitive areas.
Policy 2.1 Encourage noise-compatible land
uses along existing and future
roadways, highways, and freeways.
Consistent: The proposed
residential uses would be set back
from East Santiago Canyon Road
and would employ a solid noise
barrier along the roadway to
reduce exposure to traffic noise.
Goal 7.0 Minimize construction,
maintenance vehicle, and nuisance
noise in residential areas and near
noise-sensitive land uses.
Consistent: Construction activities
would be limited to the hours
prescribed by the Municipal Code
and would use temporary noise
barriers to protect nearby
residential uses from excessive
noise. Refer to Section 3.12, Noise
for further discussion.
Policy 7.3 Limit the hours of construction and
maintenance operations located
adjacent to noise-sensitive land uses.
Consistent: Construction activities
would be limited to the hours
prescribed by the Municipal Code.
Cultural
Resources and
Historic
Preservation
Goal 4.0 Identify and preserve
archaeological and cultural
resources.
Consistent: This EIR included a field
survey for archaeological resources
and sets forth mitigation measures
for the inadvertent discovery of
such resources during construction.
Refer to Section 3.4, Cultural
Resources for further discussion.
Policy 4.2 Recognize the importance of
Santiago Creek as an archaeological
resource.
Consistent: The proposed project
would establish a greenway along
Santiago Creek, which would protect
any archaeological resources located
with the creek corridor.
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Table 3.10-2 (cont.): General Plan Consistency Analysis
Element
Goal/Policy
Consistency Determination No. Text
Infrastructure Goal 1.0 Ensure water, sewer, and storm
drain systems that meet the needs
of residents and businesses.
Consistent: The proposed project
would be served with potable water
service provided by the City of
Orange and sewer service provided
by Orange County Sanitation District
(OCSD). The proposed project
would install a storm drainage
system that adheres to City design
standards. These characteristics are
consistent with the goal of providing
utility systems that meet the needs
of residents.
Policy 1.6 Require that new developments
fund fair-share costs associated
with City provision of water, sewer,
and storm drain service and are
consistent with City and service
provider plans to complete needed
improvements and funding capacity
for such improvements.
Consistent: The proposed project
would be responsible for the full
cost of all requisite water, sewer,
and storm drainage facilities
necessary to serve the project.
Goal 4.0 Ensure adequate provision of
electricity, natural gas, telephone
and data services and cable
television.
Consistent: The proposed project
would be served with electricity
service provided by Southern
California Edison and natural gas
service provided by the Southern
California Gas Company. These
characteristics are consistent with
the goal of ensuring the adequate
provision of utilities.
Policy 4.2 Continue to require utilities to be
placed underground for new
development.
Consistent: All electrical and
telecommunications connections
would be located underground; no
overhead facilities are proposed.
Urban Design Goal 6.0 Encourage contextually appropriate
infill development projects and
property renovations.
Consistent: The proposed project
would be of an appropriate density
and would provide a housing
product similar to surrounding
residential uses.
Policy 6.1 Encourage consistent high quality
design of development projects,
and provide development
standards that ensure building and
site design that is well integrated
with infrastructure and circulation
systems.
Consistent: The proposed site plan
is intended to promote land use
compatibility with adjoining
residential uses by clustering
residential development on
approximately 40 acres near East
Santiago Canyon Road and
preserving the remaining acreage
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Table 3.10-2 (cont.): General Plan Consistency Analysis
Element
Goal/Policy
Consistency Determination No. Text
as open space and recreational
uses. The proposed project would
provide an internal street network,
pedestrian facilities, and a trail
network from North Cannon Street
to Santiago Oaks Regional Park.
Additionally, vehicular access
would be taken from East Santiago
Canyon Road, thereby avoiding
adding vehicle trips to nearby
residential streets. These
attributes are consistent with the
policy of encouraging high-quality,
well-integrated projects.
Policy 6.2 Ensure that new infill development
contributes positively to the quality
of the surrounding corridor or
neighborhood, including the
potential to provide additional park
space, and minimize the visibility of
on-site parking.
Consistent: The proposed project
would enhance the surrounding
area by redeveloping a former
surface mining site to support
residential, open space, and
recreational uses. The project
includes a greenway along Santiago
Creek and a trail network
connecting North Cannon Street
and Santiago Oaks Regional Park.
Source: FCS, 2016.
As shown in the Impact Analysis discussion and Table 3.10-2, the proposed project is consistent with
the City of Orange General Plan and all applicable goals and policies. As such, impacts from the
General Plan Amendment would be less than significant.
East Orange General Plan and Orange Park Acres Plan
The proposed project entitlements would include a General Plan Amendment that would amend
both the East Orange General Plan and Orange Park Acres Plan to incorporate the Trails at Santiago
Creek Specific Plan. By doing so, the Trails at Santiago Creek Specific Plan would be included as part
of these two existing plans, which would create vertically consistent documents that cover and
include the proposed project.
Plan Amendments Analysis
East Orange General Plan
The East Orange General Plan, amended in 1976, was developed to guide future development
patterns in the East Orange Area, it encompasses approximately 1,900 acres. Approximately 37
acres of the project site are located within the boundaries of the East Orange General Plan and are
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designated “Regional Park.” While the proposed project would amend the approximately 37 acres
that are within the East Orange General Plan to include the Trails at Santiago Creek Specific Plan, the
37 acres are approximately 2 percent of the East Orange General Plan total area, along with being on
the fringe of the East Orange General Plan area, and would be consistent with the most recent City
of Orange General Plan.
Additionally, the proposed project includes 68.5 acres of open park space, split into 40.2 acres of
Greenway Open Space/Santiago Creek Riparian Corridor and 28.3 acres of Grasslands Open Space.
Therefore, the proposed project would include 68.5 acres of open space/park uses adjacent to, and
partially within, the East Orange General Plan; creating more open space in the vicinity than the 37
acres of the project site that are within the East Orange General Plan.
While the East Orange General Plan does not outline goals and policies similar to contemporary
General Plans, concepts are proposed as part of the Proposed Plan. Table 3.10-3 evaluates project
consistency with the applicable concepts of the East Orange General Plan.
Table 3.10-3: East Orange General Plan Consistency Analysis
Plan Section
Concept
Consistency Determination Name Text
Proposed Plan Land Use It is believed that be designing,
where possible, new developments
to be compatible with existing
residential densities, that
appropriate continuity of
architectural style, house size, and
price range may be maintained.
Consistent: The proposed project’s
residential area would have a
similar density to the nearby
Jamestown, Mabury Ranch,
Broadmoor Homes, Leadership
Housing Specific Plan, and
Pacesetter Homes area.
Additionally, the proposed project
would be built using the cluster
concept described in the OPA Plan.
Analysis of the residential area is
provided below under “Proposed
Residential Analysis.”
Proposed Plan Open Space When the proposed Concept Plan is
fully implemented, East Orange will
contain an assortment of open
space categories.
Consistent: The proposed project
would include 68.5 acres of open
space, split into 40.2 acres of
Greenway Open Space/Santiago
Creek Riparian Corridor and 28.3
acres of Grasslands Open Space.
Proposed Plan Open Space At another and much larger scale
would be the Santiago Creek
Greenbelt designated for the area
currently used for sand and gravel
extraction.
Consistent: The area described in
the section is the proposed project
site, and the project proposes a
40.2-acre Greenway Open
Space/Santiago Creek Riparian
Corridor as part of the larger 68.5
acres of open space.
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Table 3.10-3 (cont.): East Orange General Plan Consistency Analysis
Plan Section
Concept
Consistency Determination Name Text
Proposed Plan Circulation Although the design of the Plan
limits vehicular access between
residential areas, it emphasized
pedestrian and equestrian
movements between
neighborhoods.
Consistent: The proposed project
would include a multitude of trails
(Trail A through Trail F), which
would serve to connect the
proposed project and existing
community to existing and future
trails and bicycle lanes for
recreation and commuting
purposes, including equestrian use.
Additionally, the proposed project
would provide a sidewalk for
pedestrian use along the frontage
on East Santiago Canyon Road,
where none currently exists.
Proposed Plan Trail System The trail system designed for the
East Orange Area includes
equestrian/hiking trails and bicycle
trails…Although the primary
orientation of the equestrian/hiking
trails is to serve the recreational
needs of the East Orange Area, it is
anticipated that equestrian/hiking
trails may furnish and alternative to
the automobile, at least for some
travel within the Study area.
Consistent: The proposed project
would include a multitude of trails
(Trail A through Trail F), which
would serve to connect the
proposed project and existing
community to existing and future
trails and bicycle lanes for
recreation and commuting
purposes.
Source: FCS 2018.
As shown in the discussion in Table 3.10-3, the proposed project is consistent with the East Orange
General Plan and all applicable concepts. As such, impacts to the East Orange General Plan would be
less than significant.
Orange Park Acres Plan
The OPA Plan was adopted on December 26, 1973, it encompasses approximately 1,794 acres.
Approximately 39 acres of the project site are located within the boundaries of the OPA Plan, and are
designated as “Open Space.” While the proposed project would amend the approximately 39 acres
that are within the OPA Plan to include the Trails at Santiago Creek Specific Plan, the 39 acres are
approximately 3 percent of the OPA Plan total area, along with being on the fringe of the OPA Plan
area, and would be consistent with the most recent City of Orange General Plan.
Additionally, the proposed project includes 68.5 acres of open park space, split into 40.2 acres of
Greenway Open Space/Santiago Creek Riparian Corridor and 28.3 acres of Grasslands Open Space.
Therefore, the proposed project would include 68.5 acres of open space/park uses adjacent to, and
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partially within, the OPA Plan; creating more open space in the vicinity than the 39 acres of the
project site that are within the OPA Plan.
While the OPA Plan does not outline goals and policies similar to contemporary General Plans, the
OPA Plan does outline goals, objectives, and policies. Table 3.10-4 evaluates project consistency with
the applicable objectives and policies of the OPA Plan.
Table 3.10-4: OPA Plan Consistency Analysis
Goal
Objective/Policy
Consistency Determination Type Text
Establish a
Distinctive
Community
Theme
Objective Provide a wholesome rural
atmosphere emphasizing a quiet
seclusion close to nature.
Consistent: The proposed project
area encompasses approximately
109.2 acres, 68.5 acres of which
would be dedicated to open space.
The residential area of the project
would be separated from adjacent
residential developments by open
space, emphasizing a quiet
seclusion and close to the nature of
the open space area. Additionally,
the rural aspect would be
maintained by the inclusion of an
equestrian trail system.
Objective Foster compatible residential
development within the area
visually and functionally.
Consistent: The proposed project’s
residential area would have a
similar density to the nearby
Jamestown, Mabury Ranch,
Broadmoor Homes, Leadership
Housing Specific Plan, and
Pacesetter Homes, located in OPA.
Additionally, the proposed project
would be built using the cluster
concept described in the OPA Plan.
Analysis of the residential area is
provided below under “Proposed
Residential Analysis.”
Objective Link the various areas through a
system of trails and identifiable
streetscape landscaping.
Consistent: The proposed project
would include a multitude of trails
(Trail A through Trail F), which
would serve to connect the
proposed project and existing
community to existing and future
trails and bicycle lanes for
recreation and commuting
purposes, including equestrian use.
Additionally, the proposed project
would provide a sidewalk for
pedestrian use along the frontage
on East Santiago Canyon Road,
where none currently exists.
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Table 3.10-4 (cont.): OPA Plan Consistency Analysis
Goal
Objective/Policy
Consistency Determination Type Text
Objective Promote a distinctive “lifestyle”
which allows for a diversity of
activities.
Consistent: The proposed project
would include a multitude of trails
(Trail A through Trail F), which
would serve to connect the
proposed project and existing
community to existing and future
trails and bicycle lanes for
recreation and commuting
purposes, including equestrian use.
Additionally, the proposed project
would provide a sidewalk for
pedestrian use along the frontage
on East Santiago Canyon Road,
where none currently exists.
Therefore, the proposed project
would serve a diversity of activities
from walking to horse riding.
Preserve and
Enhance
Natural
Features
Objective Identify and preserve the positive
features of the major drainage
courses and bodies of water within
the area utilizing them for
recreational purposes where
appropriate.
Consistent: The Santiago Creek and
Handy Creek are two drainage
courses within the proposed project
area, the project proposes a 40.2-
acre Greenway Open
Space/Santiago Creek Riparian
Corridor, including preserving the
Handy Creek drainage area as
greenspace, as part of the larger
68.5 acres of open space.
Policies for
Orange Park
Acres
Policy Provide for continuous trail linkages
throughout OPA connecting to
County proposed trails, major land
use elements, and natural features
such as Santiago Creek and Handy
Creek.
Consistent: The proposed project
would include a multitude of trails
(Trail A through Trail F), which
would serve to connect the
proposed project and existing
community to existing and future
trails and bicycle lanes for
recreation and commuting
purposes, including equestrian use.
Additionally, the project proposes a
40.2-acre Greenway Open
Space/Santiago Creek Riparian
Corridor, including preserving the
Handy Creek drainage area as
greenspace, as part of the larger
68.5 acres of open space.
Policy Preserve Santiago Creek as a
balanced ecological system and
riparian area, maintaining the
diversity of plant and vertebrate
Consistent: The proposed project
includes a 40.2-acre Greenway
Open Space/Santiago Creek
Riparian Corridor, as part of the
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Table 3.10-4 (cont.): OPA Plan Consistency Analysis
Goal
Objective/Policy
Consistency Determination Type Text
species while allowing for light
recreational uses such as equestrian
and hiking trails.
larger 68.5 acres of open space.
Light recreational uses will be
allowed through the proposed trail
system.
Policy Promote the phasing-out of gravel
pit operations along Santiago Creek
and promote restoration of natural
amenities in the area.
Consistent: The area described in
the policy is the proposed project
site, and the project proposes a
40.2-acre Greenway Open
Space/Santiago Creek Riparian
Corridor as part of the larger 68.5
acres of open space.
Policy Provide for landscape, greenbelt or
open space buffer between
differing housing types.
Consistent: The proposed project
area encompasses approximately
109.2 acres, 68.5 acres of which
would be dedicated to open space.
The residential area of the project
would be separated from adjacent
residential developments by open
space, emphasizing a quiet
seclusion and close to the nature of
the open space area. Additionally,
the rural aspect would be
maintained by the inclusion of an
equestrian trail system.
Source: FCS 2018.
As shown in the discussion in Table 3.10-4, the proposed project is consistent with the OPA Plan and
all applicable objectives and policies. As such, impacts to the OPA Plan would be less than
significant.
Proposed Residential Area Analysis
The proposed project would cluster the residential area on approximately 40.7 acres of the area,
leaving approximately 68.5 acres as open space. Clustering the residential area on 37.3 percent of
the project site allows for the majority of the site, 62.7 percent, to be preserved as open space.
Consolidating this portion of the proposed project will enhance the equestrian and rural lifestyle of
the area. In order to ensure the proposed project follows the City of Orange Zoning Code, the
residential area would follow R-1-8 and R-1-10 (single-family residential) zoning. Additionally, both
the Development Agreement and the Trails at Santiago Creek Specific Plan cap the number of
residential units at 128, allowing for no more than 128 units to be built. Table 3.10-5 shows the
Development Standards for R-1-8 and R-1-10 (Single-Family Residential) development in detail.
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Table 3.10-5: City of Orange Zoning Code R-1-8 and R-1-10 Development Standards
Zoning
Units
Per Lot
Minimum
Lot Area
(Sq. Ft.)
Minimum
Lot
Frontage
(Feet)
Minimum
Lot Depth
(Feet)
Minimum Yard Setback
(Feet)
Maximum
Height
(Feet)
Maximum
Floor
Area
Ratio
Minimum
Usable
Open
Space
(Sq. Ft.) Front Side Rear
R-1-8 1 8,000 60 100 20 5 20 32—
2 stories
0.60 1,000
R-1-10 1 10,000 80 100 20 5 20 32—
2 stories
0.50 1,000
Source: City of Orange Zoning Code, version: June 30, 2018.
Table 3.10-6 provides a breakdown of the proposed project’s residential lots and lot sizes, and which
City of Orange Development Standards will apply.
Table 3.10-6: Residential Lot Sizes and Applicable Zoning
Planning Area Location Lots Lot Size Applicable Zoning
C1 82 8,000 R-1-8
C1 and C2 17 9,200 R-1-8
C2 29 10,000 R-1-10
Source: City of Orange Zoning Code, version: June 30, 2018.
The precedence for allowing residential developments in the Orange Park Acres Plan with less-than-
one-acre minimum lots under clustered zoning has been established by the Orange Park Association’s
previous support for Broadmoor Homes, Leadership Housing Specific Plan (Pheasant Run), and
Pacesetter Homes (The Wilderness) projects (Appendix D). More specifically, in May 2003, the Orange
Park Acres Board of Directors Supported the Fieldstone/Sully Miller Project consisting of 189 8,000-
square-foot lot minimum homes. OPA felt this was a good project that had gotten better with time.
Additional information on the Broadmoor Homes, Leadership Housing Specific Plan (Pheasant Run),
and Pacesetter Homes (The Wilderness) projects is provided below, note that the project lots are all
less-than-one-acre:
Broadmoor Homes
The Broadmoor Homes development, located on the northwest portion of Chapman Avenue and
Newport Boulevard, within the Orange Park Acres Plan, was approved by the City of Orange City
Council on August 27, 1974. The approved project was for 237 units total, with 35 units on an R-1-40
zoning with 0.8 dwellings per acre and 202 units on an R-1-15 (single-family homes on 15,000-
square-foot lots) zoning with 2.66 dwellings per acre.
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Appendix L.1 provides the City Council Approval and Staff Report for the Broadmoor Homes
development.
Leadership Housing Specific Plan (Pheasant Run)
The Leadership Housing Specific Plan, located on the northeast portion of Orange Park Boulevard
and Chapman Avenue, within the Orange Park Acres Plan, was approved through a Conditional Use
Permit for a Planned Unit Development by the City of Orange City Council on March 11, 1975. The
approved project was for 83 units total, with 35 units on an R-1-40 zoning with one dwelling per
acre, and 48 units on an R-1-10 zoning with 2.4 dwellings per acre. Homes on the R-1-10 zoning
have lots that vary from 6,000 to 10,000 square feet.
Appendix L.2 provides the City Council Approval and Staff Report for the Leadership Housing Specific
Plan.
Pacesetter Homes (The Wilderness)
The Pacesetter Homes development, located on the northeast corner of Windes Drive and East
Santiago Canyon Road, was first approved by the City of Orange City Council on July 9, 1974. The
approved project was for 48 attached single-family dwelling units and eight detached single-family
dwelling units, located on a 28.3-acre site, yielding 1.87 units per acre on a site that was rezoned from
R-1-40 (single-family homes on 40,000-square-foot lots) to R-1-20 (single-family homes on 20,000-
square foot-lots).
Appendix L.3 provides the City Council Approval and CUP for the Pacesetter Homes development.
Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
Municipal Code Consistency
Impact LUP-2: The project would not conflict with the applicable provisions of the Orange Municipal
Code.
Impact Analysis
The project site is currently zoned “S-G (Sand and Gravel)” and “R-1-8 (Single Family Residential
8,000 square feet)” by the Orange Zoning Code. The “S-G (Sand and Gravel)” land use designation
reflects the previous surface mining activities and the current sand and gravel operations that occur
on the south side of Santiago Creek. The “R-1-8 (Single Family Residential 8,000 square feet)”
applies to the portion of the site north of Santiago Creek, adjacent to Mabury Avenue.
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The proposed project involves the development of 128 dwelling units on 40.7 acres within the area
designated “S-G (Sand and Gravel)” and the preservation of the remaining acreage (which overlap
with the “S-G (Sand and Gravel)” and “R-1-8 (Single Family Residential 8,000 square feet)”
designations) as open space and recreation uses. Accordingly, the applicant is proposing to rezone
the entire site to “SP (Specific Plan).”
These land use changes are necessary to allow the proposed development on the site, and are
consistent and compatible with the other surrounding residential land use designations; refer to
Table 3.10-2. With implementation of the proposed Zone Change, the project will be consistent with
the Orange Municipal Code.
Impacts would be less than significant.
Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
Conservation Plan Consistency
Impact LUP-3: The project would not conflict with any applicable habitat conservation plan or
natural communities conservation plan.
Impact Analysis
The project site is within the boundaries of the Orange County Central and Coastal Subregion
NCCP/HCP (Exhibit 3.4-6). The NCCP/HCP has an objective of assembling a 38,000-acre preserve in
Orange County consisting of the highest value biological habitat.
Within the project site, the Santiago Creek corridor contain riparian habitat and the upland areas north
of the creek contain marginal Coastal Sage Scrub habitat, which are considered to have high biological
value. These areas are contemplated to be preserved as open space and, therefore, would be available
for inclusion in the preserve. Additionally, the 40.7 acres proposed for residential development
coincide with the surface mining areas and do not contain any significant biological habitat. For these
reasons, no conflicts with the NCCP/HCP would occur. Impacts would be less than significant.
Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
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3.11 - Mineral Resources
3.11.1 - Introduction
This section describes the existing mineral resources setting and potential effects from project
implementation on the site and its surrounding area. Descriptions and analysis in this section are
based on information provided by the California State Mining and Geology Board and the City of
Orange.
3.11.2 - Environmental Setting
Mineral Resource Extraction Activities
The project site was used primarily for surface mining of sand and gravel, aggregates mining, and
ancillary uses starting from 1919, and ceased before January 1, 1976. Surface mining activities ceased
before January 1, 1976, and all ancillary uses were removed in the same year. The project site
currently supports a sand and gravel operator in accordance with the existing Sand and Gravel zoning.
Approximately 40 acres between Santiago Creek and East Santiago Canyon Road, remnants of the
mining operation remain, and it is the location of the ongoing sand and gravel operation. This area is
characterized by soil piles, berms, and unpaved roads. An approximately 5-acre area near East
Santiago Canyon Road supports a materials recycling operation that includes apparatus for crushing
boulders, bricks, rocks, and similar materials for recycling. Materials used for these operations
originated primarily from off-site sources. The materials generated by these operations have
historically been used both on-site, and transported off-site. Ancillary uses included administration
and maintenance buildings, caretaker residence, material testing laboratory, driver’s shack, rock
crushing facilities, several above-ground and below-ground fuel storage tanks, and two hot-mix
asphalt plants.
Additionally, the previously mined portions of the site were “backfilled,” in which unsuitable
materials were excavated and replaced with fill, pursuant to a grading permit issued by the City of
Orange in 2011. It was anticipated that approximately 223,000 cubic yards of material would be
imported to the site during the process, including concrete, asphalt, and rock that would be crushed
on-site. Approximately 2,000 cubic yards of material was anticipated to be excavated from the site
for reuse and would be blended with the crushed import material for a total of 225,000 cubic yards
of backfill. In 2015, the operator voluntarily temporarily suspended operations on the site, and
limited rock crushing operations to a total of 15 consecutive business days in any 6-month period.
The operator reserved the right to resume all operations consistent with the Sand and Gravel zoning.
Mineral Resource Designations
The California State Mining and Geology Board “Regionally Significant Construction Aggregation
Resource Areas in the Orange County-Temescal Valley and San Gabriel Valley Production-
Consumption Region, Santa Ana River and Lower Santiago Creek Resource Areas” indicates that the
project site is within Mineral Resource Zone 2 for aggregate.
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The City of Orange General Plan maps a portion of the project site as “Resource Area” and the
Orange Zoning Ordinance zones a portion of the site as “S-G (Sand and Gravel Extraction).”
3.11.3 - Regulatory Framework
State
Surface Mining and Reclamation Act
The Surface Mining and Reclamation Act (SMARA) provides guidelines for the classification and
designation of mineral lands. The California Geological Survey has produced a report and a Mineral
Land Classification Map. The Classification Map designates areas where important Production-
Consumption deposits occur, and are categorized in Mineral Resource Zones (MRZs). MRZs are
defined as follows:
• MRZ-1: Areas where adequate information indicates that no significant mineral deposits are
present, or where it is judged that little likelihood exists for their presence.
• MRZ-2: Areas where adequate information indicates that significant mineral deposits are
present, or where it is judged that a high likelihood for their presence exists.
• MRZ-3: Areas containing mineral deposits, the significance of which cannot be evaluated from
available data.
• MRZ-4: Areas where available information is inadequate for assignment to another MRZ zone.
According to SMARA, mineral lands include areas containing sand and gravel; related materials are
known collectively as aggregate resources. SMARA requires all cities to contain a mineral resource
management policy that:
1. Recognizes mineral information transmitted by the State Mining and Geology Boards;
2. Assists in the management of land use affecting areas of regional significance; and,
3. Emphasizes the conservation and development of identified mineral resources.
Local
City of Orange
General Plan
The City of Orange General Plan recognizes the State’s Mineral Resource Zone 2 designations along
Santiago Creek and designates these areas as “Resource Area,” which allow for aggregate extraction
or recreation uses.
3.11.4 - Methodology
FCS reviewed the California State Mining and Geology Board “Regionally Significant Construction
Aggregation Resource Areas in the Orange County-Temescal Valley and San Gabriel Valley
Production-Consumption Region, Santa Ana River and Lower Santiago Creek Resource Areas” and
the City of Orange General Plan for information about mineral resources.
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3.11.5 - Thresholds of Significance
According to the CEQA Guidelines’ Appendix G Environmental Checklist, to determine whether land
use and planning impacts are significant environmental effects, the following questions are analyzed
and evaluated. Would the project:
a) Result in the loss of availability of a known mineral resource that would be of value to the
region and the residents of the state?
b) Result in the loss of availability of a locally-important mineral resource recovery site
delineated on a local general plan, specific plan, or other local land use plan?
3.11.6 - Project Impacts and Mitigation Measures
Loss of Minerals of Statewide Importance
Impact MIN-1: The proposed project would not result the in the loss of availability of a known
mineral resource that would be of value to the region and the residents of the state.
Impact Analysis
The project site is located within Mineral Resource Zone 2 for aggregate as designated by the State
Mining and Geology Board. However, in 2003, the Office of Mine Reclamation concluded that
surface mining operations ceased on the project site prior to January 1, 1976 (Appendix M).
Under SMARA, operators of surface mining operations are required to obtain a permit for operations
post-1976, and are required to file a mining reclamation plan for post-1975 mining operations. As
such, a mining reclamation plan under SMARA is not required for the project site. Additionally,
mined areas of the site have been backfilled, which effectively precludes the resumption of surface
mining operations.
The Geotechnical Investigation prepared for the project site indicates that it has been mined of
economic aggregate deposits, and the remaining deposits that are of potential economic value are
infeasible to mine because of the limited volume of the localized deposits, expense of removing the
overburden (pond deposits), and difficulty associated with excavation logistics. Thus, resuming
aggregate mining operations on the project site would not be economically feasible and the resource
is effectively depleted.
In summary, the development of the proposed project would not result in the loss of availability of a
known mineral resource that would be of value to the region or the residents of the State because
the economically recoverable aggregate has been previously mined and put to beneficial use. The
remaining aggregate is not economically recoverable and therefore would not be available to benefit
the region or the residents of the State. Therefore, the loss of mineral resources would be
considered a less than significant impact.
Level of Significance Before Mitigation
Less than significant impact.
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Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
Loss of Mineral Resources of Local Importance
Impact MIN-2: The proposed project would not result in the loss of availability of a locally-
important mineral resource recovery site delineated on a local general plan,
specific plan, or other local land use plan.
Impact Analysis
The City of Orange General Plan maps a portion of the project site as “Resource Area” and the
Orange Zoning Ordinance zones a portion of the site as “S-G (Sand and Gravel Extraction).” These
designations reflect the project site’s past support of surface mining activities, which ceased prior to
January 1, 1976. However, while the City of Orange General Plan and Zoning Ordinance designates
the site to allow for the historical pre-1976 surface mining uses to occur, they do not signify whether
the project site has economically recoverable aggregate deposits. The Geotechnical Investigation for
the project site indicates that it has been mined of economic aggregate deposits, and the remaining
deposits that are of potential economic value are not feasible to mine because of the limited volume
of the localized deposits, expense of removing the overburden (pond deposits), and difficulty
associated with excavation logistics. Thus, resuming aggregate mining operations on the project site
would not be economically feasible and the resource is effectively depleted.
As such, the proposed General Plan Amendment and Rezone would remove these designations and
replace them with designations that are non-mining in nature. Impacts would be less than
significant.
Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
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3.12 - Noise
3.12.1 - Introduction
This section describes the existing hydrology and water quality setting and potential effects from
project implementation on the site and its surrounding area. Descriptions and analysis in this
section are based on noise modeling performed by FirstCarbon Solutions (FCS). The noise modeling
input assumptions and output data used in this analysis are provided in Appendix N.
3.12.2 - Environmental Setting
Noise Fundamentals
Noise is defined as unwanted sound. Sound becomes unwanted when it interferes with normal
activities, when it causes actual physical harm, or when it has adverse effects on health. Sound is
produced by the vibration of sound pressure waves in the air. Sound pressure levels are used to
measure the intensity of sound and are described in terms of decibels. The decibel (dB) is a
logarithmic unit that expresses the ratio of the sound pressure level being measured to a standard
reference level. A-weighted decibels (dBA) approximate the subjective response of the human ear to
a broad frequency noise source by discriminating against very low and very high frequencies of the
audible spectrum. They are adjusted to reflect only those frequencies that are audible to the human
ear. Table 3.12-1 shows some representative noise sources and their corresponding noise levels in
dBA.
Table 3.12-1: Typical A-Weighted Noise Levels
Indoor Noise Source Noise Level (dBA) Outdoor Noise Sources
(Threshold of Hearing in Laboratory) 0 —
Library 30 Quiet Rural Nighttime
Refrigerator Humming 40 Quiet Suburban Nighttime
Quiet Office 50 Quiet Urban Daytime
Normal Conversation at 3 feet 60 Normal Conversation at 3 feet
Vacuum Cleaner at 10 feet 70 Gas Lawn Mower at 100 feet
Hair Dryer at 1 foot 80 Freight Train at 50 feet
Food Blender at 3 feet 90 Heavy-duty Truck at 50 feet
Inside Subway Train (New York) 100 Jet Takeoff at 2,000 feet
Smoke Detector Alarm at 3 feet 110 Unmuffled Motorcycle
Rock Band near stage 120 Chainsaw at 3 feet
— 130 Military Jet Takeoff at 50 feet
— 140 (Threshold of Pain)
Source: Compiled by FirstCarbon Solutions, 2014.
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Noise Descriptors
Noise equivalent sound levels are not measured directly but are calculated from sound pressure
levels typically measured in A-weighted decibels (dBA). The equivalent sound level (Leq) represents a
steady-state sound level containing the same total energy as a time-varying signal over a given
sample period. The peak traffic hour Leq is the noise metric used by the California Department of
Transportation (Caltrans) for traffic noise impact analyses.
The Day-Night Average Level (Ldn) is the weighted average of the intensity of a sound, with
corrections for time of day and averaged over 24 hours. The time of day corrections require the
addition of 10 decibels to sound levels at night between 10:00 p.m. and 7:00 a.m. While the
Community Noise Equivalent Level (CNEL) is similar to the Ldn, it has another addition of 4.77
decibels to sound levels during the evening hours between 7:00 p.m. and 10:00 p.m. These
additions are made to the sound levels at these periods because, compared with daytime hours,
there is a decrease in the ambient noise levels during the evening and nighttime hours, which
creates an increased sensitivity to sounds. For this reason, the sound seems louder in the evening
and nighttime hours and is weighted accordingly. Due to the additional evening penalty CNEL values
are always higher than Ldn values; however, the difference is usually between 0 and 1 dB.
Other noise rating scales of importance when assessing the annoyance factor include the maximum
noise level (Lmax), which is the highest exponential time-averaged sound level that occurs during a
stated time period. The noise environments discussed in this analysis are specified in terms of
maximum levels denoted by Lmax for short-term noise impacts. Lmax reflects peak operating
conditions and addresses the annoying aspects of intermittent noise.
Noise standards in terms of percentile exceedance levels, Ln, are often used together with the Lmax
for noise enforcement purposes. When specified, the percentile exceedance levels are not to be
exceeded by an offending sound over a stated time period. For example, the L10 noise level
represents the level exceeded 10 percent of the time during a stated period. The L50 noise level
represents the median noise level (which means that the noise level exceeds the L50 noise level half
of the time, and is less than this level half of the time). The L90 noise level represents the noise level
exceeded 90 percent of the time and is considered the lowest noise level experienced during a
monitoring period. The L90 noise level is normally referred to as the background noise level. For a
relatively steady noise, the measured Leq and L50 are approximately the same.
Tone Noise
A pure tone noise is a noise produced at a single frequency, and laboratory tests have shown that
humans are more perceptible to changes in noise levels of a pure tone. For a noise source to contain a
“pure tone,” there must be a significantly higher A-weighted sound energy in a given frequency band
than in the neighboring bands, thereby causing the noise source to “stand out” against other noise
sources. A pure tone occurs if the sound pressure level in the one-third octave band with the tone
exceeds the average of the sound pressure levels of the two contiguous one-third octave bands by:
• 5 dB for center frequencies of 500 hertz (Hz) and above
• 8 dB for center frequencies between 160 and 400 Hz
• 15 dB for center frequencies of 125 Hz or less
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Noise Propagation
From the noise source to the receiver, noise changes both in level and frequency spectrum. The
most obvious is the decrease in noise as the distance from the source increases. The manner in
which noise reduces with distance depends on whether the source is a point or line source, ground
absorption, atmospheric effects and refraction, and shielding by natural and man-made features.
Sound from point sources such as air conditioning condensers radiate uniformly outward as it travels
away from the source in a spherical pattern. The noise drop-off rate associated with this geometric
spreading is 6 dBA per each doubling of the distance (dBA/DD). However, in order for the point
source drop-off rate to provide accurate results, the nearest receiver needs to be placed a minimum
distance away from the source that is greater than double the width of the noise source.
Transportation noise sources such as roadways are typically analyzed as line sources, since at any
given moment the receiver may be impacted by noise from multiple vehicles at various locations
along the roadway. Because of the geometry of a line source, the noise drop-off rate associated with
the geometric spreading of a line source is 3 dBA/DD.
Ground Absorption
The sound drop-off rate is highly dependent on the conditions of the land between the noise source
and receiver. To account for this ground-effect attenuation (absorption), two types of site conditions
are commonly used in traffic noise models: soft-site and hard-site conditions. Soft-site conditions
account for the sound propagation loss over natural surfaces such as normal earth and ground
vegetation. For point sources, a drop-off rate of 7.5 dBA/DD is typically observed over soft ground with
landscaping, compared with a 6.0 dBA/DD drop-off rate over hard ground such as asphalt, concrete,
stone, and very hard packed earth. For line sources, a 4.5 dBA/DD is typically observed for soft-site
conditions compared with the 3.0 dBA/DD drop-off rate for hard-site conditions. Caltrans research has
shown that the use of soft-site conditions is more appropriate for the application of the Federal
Highway Administration (FHWA) traffic noise prediction model used in this analysis. Further, the study
area is located in a semi-rural environment, and either landscaping or native vegetation exists along
the sides of all analyzed roadways, which is more appropriately represented by soft-site conditions.
Traffic Noise Prediction
The level of traffic noise depends on the three primary factors: (1) the volume of the traffic, (2) the
speed of the traffic, and (3) the number of trucks in the flow of traffic. Generally, the loudness of
traffic noise is increased by heavier traffic volumes, higher speeds, and greater number of trucks.
Vehicle noise is a combination of the noise produced by the engine, exhaust, and tires. Because of
the logarithmic nature of traffic noise levels, a doubling of the traffic volume (assuming that the
speed and truck mix do not change) results in a noise level increase of 3 dBA. Based on the FHWA
community noise assessment criteria, this change is “barely perceptible.” For reference, a doubling
of perceived noise levels would require an increase of approximately 10 dBA. The truck mix on a
given roadway also has an effect on community noise levels. As the number of heavy trucks
increases and becomes a larger percentage of the vehicle mix, adjacent noise levels increase.
Construction Noise Fundamentals
Construction is performed in discrete steps or phases, each of which has its own mix of equipment,
and consequently, its own noise characteristics. Typical phases of construction include demolition,
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excavation, grading, and building construction. These various sequential phases would change the
character of the noise generated on each construction site and, therefore, would change the noise
levels as construction progresses. Despite the variety in the type and size of construction
equipment, similarities in the dominant noise sources and patterns of operation allow construction
related noise ranges to be categorized by work phase. Construction-period noise levels are higher
than background ambient noise levels, but eventually cease once construction is complete. Table
3.12-2 shows typical noise levels of construction equipment as measured at a distance of 50 feet
from the operating equipment.
Table 3.12-2: Typical Construction Equipment Maximum Noise Levels, Lmax
Type of Equipment Impact Device? (Yes/No)
Specification Maximum Sound Levels
for Analysis
(dBA at 50 feet)
Pickup Truck No 55
Pumps No 77
Air Compressors No 80
Backhoe No 80
Front-End Loaders No 80
Portable Generators No 82
Dump Truck No 84
Tractors No 84
Auger Drill Rig No 85
Concrete Mixer Truck No 85
Cranes No 85
Dozers No 85
Excavators No 85
Graders No 85
Jackhammers Yes 85
Man Lift No 85
Paver No 85
Pneumatic Tools No 85
Rollers No 85
Scrapers No 85
Concrete/Industrial Saws No 90
Impact Pile Driver Yes 95
Vibratory Pile Driver No 95
Source: FHWA, 2006.
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Groundborne Vibration Fundamentals
Groundborne vibrations consist of rapidly fluctuating motions within the ground that have an
average motion of zero. The effects of groundborne vibrations typically only cause a nuisance to
people, but at extreme vibration levels, damage to buildings may occur. Although groundborne
vibration can be felt outdoors, it is typically only an annoyance to people indoors where the
associated effects of the shaking of a building can be notable. Groundborne noise is an effect of
groundborne vibration and only exists indoors, since it is produced from noise radiated from the
motion of the walls and floors of a room and may consist of the rattling of windows or dishes on
shelves.
Vibration Descriptors
Several different methods are used to quantify vibration amplitude, such as the maximum
instantaneous peak in the vibrations velocity, which is known as the peak particle velocity (PPV) or
the root mean square (rms) amplitude of the vibration velocity. Because of the typically small
amplitudes of vibrations, vibration velocity is often expressed in decibels; it is denoted as (Lv) and is
based on the rms velocity amplitude. A commonly used abbreviation is “VdB,” which in this text, is
when Lv is based on the reference quantity of 1 microinch per second.
Vibration Perception
Typically, developed areas are continuously affected by vibration velocities of 50 VdB or lower. These
continuous vibrations are not noticeable to humans, whose threshold of perception is around 65
VdB. Common sources that may produce perceptible vibrations are construction equipment, steel-
wheeled trains, and traffic on rough roads, while traffic on smooth roads rarely produces perceptible
groundborne noise or vibration.
Vibration Propagation
The propagation of groundborne vibration is not as simple to model as airborne noise. This is
because noise in the air travels through a relatively uniform medium, while groundborne vibrations
travel through the earth, which may contain significant geological differences. There are three main
types of vibration propagation: surface, compression, and shear waves. Surface waves, or Rayleigh
waves, travel along the ground’s surface. These waves carry most of their energy along an expanding
circular wave front, similar to ripples produced by throwing a rock into a pool of water. P-waves, or
compression waves, are body waves that carry their energy along an expanding spherical wave front.
The particle motion in these waves is longitudinal (i.e., in a push-pull fashion). P-waves are
analogous to airborne sound waves. S-waves, or shear waves, are also body waves that carry energy
along an expanding spherical wave front. However, unlike P-waves, the particle motion is transverse
or side-to-side and perpendicular to the direction of propagation. All three types of vibration
propagation result in earth movement that can be measured through the use of a vibration meter;
however, a vibration meter only captures the amount of movement and cannot decipher between
the different types of propagation.
As vibration waves propagate from a source, the vibration energy decreases in a logarithmic nature,
and the vibration levels typically decrease by 6 VdB per doubling of the distance from the vibration
source. As stated above, this drop-off rate can vary greatly depending on the soil, but has been
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shown to be effective enough for screening purposes, in order to identify potential vibration impacts
that may need to be studied through actual field tests.
Propagation of vibration through soil can be calculated using the vibration reference equation of
PPV = PPV ref * (25/D)^n (in/sec)
Where:
PPV = reference measurement at 25 feet from vibration source
D = distance from equipment to property line
n = vibration attenuation rate through ground
According to Chapter 12 of the Federal Transit Administration (FTA) Transit Noise and Vibration
Impact Assessment (Federal Transit Administration, 2006) manual, an “n” value of 1.5 is
recommended to calculate vibration propagation through typical soil conditions.
Construction Vibration Fundamentals
Common sources of groundborne vibration include construction activities such as blasting, pile
driving and operating heavy earthmoving equipment. However, construction vibration impacts on
building structures are generally assessed in terms of peak particle velocity (PPV). For purposes of
this analysis, project-related impacts are expressed in terms of PPV. Typical vibration source levels
from construction equipment are shown in Table 3.12-3.
Table 3.12-3: Vibration Levels of Construction Equipment
Construction Equipment PPV at 25 Feet (inches/second)
RMS Velocity in Decibels (VdB) at
25 Feet
Water Trucks 0.001 57
Scraper 0.002 58
Bulldozer—small 0.003 58
Jackhammer 0.035 79
Concrete Mixer 0.046 81
Concrete Pump 0.046 81
Paver 0.046 81
Pickup Truck 0.046 81
Auger Drill Rig 0.051 82
Backhoe 0.051 82
Crane (Mobile) 0.051 82
Excavator 0.051 82
Grader 0.051 82
Loader 0.051 82
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Table 3.12-3 (cont.): Vibration Levels of Construction Equipment
Construction Equipment PPV at 25 Feet (inches/second)
RMS Velocity in Decibels (VdB) at
25 Feet
Loaded Trucks 0.076 86
Bulldozer—Large 0.089 87
Caisson drilling 0.089 87
Vibratory Roller (small) 0.101 88
Compactor 0.138 90
Clam shovel drop 0.202 94
Vibratory Roller (large) 0.210 94
Pile Driver
(impact-typical)
0.644 104
Pile Driver
(impact-upper range)
1.518 112
Source: Compilation of scientific and academic literature, generated by FTA and FHWA.
Existing Conditions
The project site consists of 12 parcels and is bisected by Santiago Creek in an east-west direction.
The approximately 109.2-acre project site is located at 6118 East Santiago Canyon Road in the
Orange Park Acres neighborhood of the City of Orange, Orange County, California. The project site is
surrounded by the Villa Park Landfill Site, and North Cannon Street (west), single-family residential
and Mabury Avenue (north), the Santiago Creek corridor and single-family residential (east), and
East Santiago Canyon Road (south). The approximately 109.2-acre project site contains disturbed,
gently sloping undeveloped land that previously supported mining activities.
Existing Noise Sources
The predominant existing noise source at the project site would be on-site activities of aggregate
mining, materials recycling, and backfilling and firewood storage activities. Traffic noise along East
Santiago Canyon Road is the dominant noise source in the project vicinity. To a lesser extent, other
noise sources in the project vicinity include stationary noise sources such as typical neighbor
maintenance and leisure activities, recreational activity at the school to the south and Santiago Creek
open space to the north and equestrian facilities to the south. The existing ambient noise environment
is considered relative quiet in the existing residential areas located further away from East Santiago
Canyon Road.
Existing Traffic Noise
The most significant noise source in the project vicinity is traffic on East Santiago Canyon Road. In
order to provide a baseline of the existing traffic noise levels in the proposed project study area, the
SoundPlan Model was used to calculate the existing noise levels along roadway segments in the
project vicinity, which are summarized below in Table 3.12-4. This model requires parameters,
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including traffic volumes, vehicle mix, vehicle speed, and roadway geometry to compute typical
equivalent noise levels during daytime, evening, and nighttime hours. The daily traffic volumes were
obtained from The Trails at Santiago Creek Draft Traffic Impact Analysis, (Traffic Analysis) prepared
by Linscott Law & Greenspan, December 2017, as presented in Section 3.16, Transportation and
Traffic. The model’s inputs and outputs and summary of the modeling results for Existing traffic
conditions—are provided in Appendix N of this document. The SoundPlan model was also used to
produce a noise contour map showing the existing dBA CNEL in the project vicinity and is shown
below in Exhibit 3.12-1, Existing Noise Contour Map (dBA CNEL).
Table 3.12-4: Existing Traffic Noise Levels Along Modeled Roadways
Roadway—Segment Description
CNEL (dBA) at 50 feet from
outermost travel lane
Cannon Street—North of Santiago Canyon Road 67
Santiago Canyon Road—East of Cannon Street 65
Mabury Avenue—East of Serrano Avenue 53
Source: FCS, 2017.
3.12.3 - Regulatory Framework
Federal
United States Environmental Protection Agency (EPA)
In 1972, Congress enacted the Noise Control Act. This act authorized the EPA to publish descriptive
data on the effects of noise and establish levels of sound “requisite to protect the public welfare with
an adequate margin of safety.” These levels are separated into health (hearing loss levels) and welfare
(annoyance levels) categories, as shown in Table 3.12-5. The EPA cautions that these identified levels
are not standards because they do not take into account the cost or feasibility of achieving the levels.
Table 3.12-5: Summary of EPA Recommended Noise Levels to Protect Public Welfare
Effect Level Area
Hearing loss Leq(24) < 70 dB All areas.
Outdoor activity interference and
annoyance
Ldn < 55 dB Outdoors in residential areas and farms and
other outdoor areas where people spend
widely varying amounts of time and other
places in which quiet is a basis for use.
Leq(24) < 55 dB Outdoor areas where people spend limited
amounts of time, such as schoolyards,
playgrounds, etc.
Indoor activity interference and
annoyance
Leq < 45 dB Indoor residential areas.
Leq(24) < 45 dB Other indoor areas with human activities
such as schools, etc.
Source: EPA, 1974.
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27650002 • 07/2018 |3.12-1_existing_contours.cdr
Exhibit 3.12-1
Existing Noise Contour Map (dBA CNEL)
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: SoundPlan Version 7.4
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For protection against hearing loss, 96 percent of the population would be protected if sound levels
are less than or equal to an Leq(24) of 70 dBA. The “(24)” signifies an Leq duration of 24 hours. The
EPA activity and interference guidelines are designed to ensure reliable speech communication from
a distance of approximately 5 feet in the outdoor environment. For outdoor and indoor
environments, interference with activity and annoyance should not occur if levels are below 55 dBA
and 45 dBA, respectively.
Federal Transit Administration (FTA)
The proposed project is not subject to the regulation requirements of the FTA; however, the FTA’s
vibration impact criteria are accepted industrywide as the best vibration impact guidelines when a
local governing agency does not have vibration standards of its own.
The FTA’s vibration impact criteria and impact assessment guidelines are published in its Transit
Noise and Vibration Impact Assessment document. The FTA guidelines include thresholds for
construction vibration impacts for various structural categories as shown in Table 3.12-6.
Table 3.12-6: Construction Vibration Impact Criteria
Structure and Condition
Maximum Peak Particle
Velocity (inches/second)
Reinforced-concrete, steel or timber structures
(e.g., industrial buildings) 0.5
Engineered concrete and masonry 0.3
Non-engineered timber and masonry buildings
(e.g., residential) 0.2
Buildings extremely susceptible to vibration damage
(e.g., historic or very old buildings) 0.12
Source: FTA, 2006.
State
The State of California has established regulations that help prevent adverse impacts to occupants of
buildings located near noise sources. Referred to as the “State Noise Insulation Standard,” it
requires buildings to meet performance standards through design and/or building materials that
would offset any noise source in the vicinity of the receptor. State regulations include requirements
for the construction of new hotels, motels, apartment houses, and dwellings other than detached
single-family dwellings that are intended to limit the extent of noise transmitted into habitable
spaces. The State also includes noise requirements in the California Code of Regulations, Title 24
(known as the Building Standards Administrative Code), Part 11 (known as the California Green
Building Standards Code). The noise insulation standards require that the wall and roof-ceiling
assemblies of new non-residential developments that are exposed to exterior noise in excess of 65
dBA CNEL shall meet a composite Standard Transmission Class (STC) rating of at least 50, with
exterior windows of a minimum STC rating of 40. In addition, the standards require preparation of
an acoustical analysis demonstrating the manner in which dwelling units have been designed to
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meet this standard, where such development is proposed in an area with exterior noise levels
greater than 65 dBA CNEL.
Government Code Section 65302 mandates that the legislative body of each county and city in
California adopt a noise element as part of its comprehensive general plan. The local noise element
must recognize the land use compatibility guidelines published by the State Department of Health
Services. The guidelines rank noise and land use compatibility in terms of normally acceptable,
conditionally acceptable, normally unacceptable, and clearly unacceptable. The City of Orange has
adopted and modified the State’s land use compatibility guidelines, as discussed in the local
regulatory section below.
Local
City of Orange
General Plan
The City of Orange General Plan sets forth the following goals and policies that are relevant to noise.
Orange has developed its own land use compatibility standards that rate compatibility in terms of
only normally acceptable. Using these land use compatibility guidelines, the City has established
interior and exterior noise standards. Higher exterior noise levels are permitted for multiple-family
housing and housing in mixed-use contexts than for single-family houses. This is because multiple-
family complexes are generally located in transitional areas between single family and commercial
districts or in proximity to major arterials served by transit, and a more integrated mix of residential
and commercial activity (accompanied by higher noise levels) is often desired in mixed-use areas
close to transit routes. The following are the goals, policies, and land use compatibility standards
relevant to the project:
• Goal 1.0: Promote a pattern of land uses compatible with current and future noise levels.
• Policy 1.1: Consider potential excessive noise levels when making land use planning decisions.
• Policy 1.2: Encourage new development projects to provide sufficient spatial buffers to
separate excessive noise generating land uses and noise-sensitive land uses.
• Policy 1.4: Ensure that acceptable noise levels are maintained near noise-sensitive uses.
• Policy 1.6: Require an acoustical study for proposed developments in areas where the existing
and projected noise level exceeds or would exceed the maximum allowable levels identified in
Table 3.12-7 (Table N-3 of the General Plan). The acoustical study shall be performed in
accordance with the requirements set forth within this Noise Element.
• Goal 2.0: Minimize vehicular traffic noise in residential areas and near noise-sensitive land
uses.
• Policy 2.2: Encourage coordinated site planning and traffic control measures that minimize
traffic noise in noise-sensitive land use areas.
• Goal 7.0: Minimize construction, maintenance vehicle, and nuisance noise in residential areas
and near noise-sensitive land uses.
• Policy 7.1: Schedule City maintenance and construction projects so that they generate noise
during less sensitive hours.
• Policy 7.2: Require developers and contractors to employ noise minimizing techniques during
construction and maintenance operations.
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• Policy 7.3: Limit the hours of construction and maintenance operations located adjacent to
noise-sensitive land uses.
• Policy 7.4: Encourage limitations on the hours of operations and deliveries for commercial,
mixed-use, and industrial uses abutting residential zones.
Table 3.12-7: Maximum Allowable Noise Exposure—Transportation Sources
Land Use CNEL (dBA)
Designations
(as shown on Figure LU-5) Uses Interior1,3 Exterior2
Estate Low Density Residential
Low Density Residential
Low Medium Density Residential
Single-family, duplex, and multiple-family 45 65
Mobile home park N/A 65
Medium Density Residential
Neighborhood
Mixed-use
Neighborhood Office
Professional
Old Towne Mixed-use
General Commercial
Yorba Commercial Overlay
Urban Mixed-use
Urban Office Professional
Single-family 45 65
Mobile home park N/A 65
Multiple-family, mixed-use 45 654,5
Transient lodging—motels, hotels 45 65
Sports arenas, outdoor spectator sports N/A N/A
Auditoriums, concert halls, amphitheaters 4 5 N/A
Office buildings, business, commercial and
professional 50 N/A
Light Industrial
Industrial Manufacturing, utilities, agriculture N/A N/A
Public Facilities and Institutions Schools, nursing homes, day care facilities,
hospitals, convalescent facilities,
dormitories
45 65
Government Facilities—offices, fire stations,
community buildings 45 N/A
Places of Worship, Churches 45 N/A
Libraries 45 N/A
Utilities N/A N/A
Cemeteries N/A N/A
Recreation Commercial
Open Space
Open Space—Park
Open Space—Ridgeline
Resource Area
Playgrounds, neighborhood parks N/A 70
Golf courses, riding stables, water
recreation, cemeteries N/A N/A
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Table 3.12-7 (cont.): Maximum Allowable Noise Exposure—Transportation Sources
Land Use CNEL (dBA)
Designations
(as shown on Figure LU-5) Uses Interior1,3 Exterior2
Notes:
1 Interior habitable environment excludes bathrooms, closets and corridors.
2 Exterior noise level standard to be applied at outdoor activity areas; such as private yards, private patio or balcony of
a multi-family residence. Where the location of an outdoor activity area is unknown or not applicable, the noise
standard shall be applied inside the property line of the receiving land use.
3 Interior noise standards shall be satisfied with windows in the closed position. Mechanical ventilation shall be
provided per Uniform Building Code (UBC) requirements.
4 Within the Urban Mixed-Use, Neighborhood Mixed-Use, Old Towne Mixed-use, and Medium Density Residential land
use designations, exterior space standards apply only to common outdoor recreational areas.
5 Within Urban Mixed-Use and Medium Density Residential land use designations, exterior noise levels on private patios
or balconies located within 250 feet of freeways (I-5, SR-57, SR-55, SR-22, or SR-241) and Smart Streets and Principal
Arterials identified in the Circulation & Mobility Element that exceed 70 dB should provide additional common open
space.
N/A=Not Applicable to specified land use category or designation
Source: Table N-3 of the City of Orange General Plan Noise Element.
When non-transportation (stationary) noise is the primary noise source, the City applies a second set
of standards when planning and making development decisions. These hourly and maximum
performance standards (expressed in Leq and Lmax, respectively) for non-transportation or stationary
noise sources are designed to protect noise sensitive land uses adjacent to stationary sources from
excessive noise. Table 3.12-8 (Table N-4 of the General Plan) summarizes City stationary source
noise standards for various land use types. These standards represent the acceptable exterior noise
levels at the sensitive receptor.
Table 3.12-8: Maximum Allowable Noise Exposure—Stationary Noise Sources
Noise Level Descriptor Daytime (7 a.m. to 10 p.m.) Nighttime (10 p.m. to 7 a.m.)
Hourly Equivalent Level (Leq), dBA 55 45
Maximum Level (Lmax), dBA 70 65
Notes:
1 These standards apply to new or existing noise sensitive land uses affected by new or existing non-transportation
noise sources, as determined at the outdoor activity area of the receiving land use. However, these noise level
standards do not apply to residential units established in conjunction with industrial or commercial uses (e.g.,
caretaker dwellings).
2 Each of the noise levels specified above should be lowered by five dB for simple tone noises, noises consisting
primarily of speech or music, or for recurring impulsive noises. Such noises are generally considered by residents to
be particularly annoying and are a primary source of noise complaints. These noise level standards do not apply to
residential units established in conjunction with industrial or commercial uses (e.g. caretaker dwellings).
3 No standards have been included for interior noise levels. Standard construction practices that comply with the
exterior noise levels identified in this table generally result in acceptable interior noise levels.
4 The City may impose noise level standards which are more or less restrictive than those specified above based upon
determination of existing low or high ambient noise levels. If the existing ambient noise level exceeds the standards
listed in Table N-4, then the noise level standards shall be increased at 3 dB increments to encompass the ambient
environment. Noise level standards incorporating adjustments for existing ambient noise levels shall not exceed a
maximum of 70 dB Leq
Source: Table N-4 of the City of Orange General Plan Noise Element.
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In addition to the maximum allowable noise level standards outlined in Tables 3.12-7 and 3.12-8, an
increase in ambient noise levels is assumed to be a significant noise impact if a project causes
ambient noise levels to exceed the following:
• Where the existing ambient noise level is less than 65 dBA, a project related permanent
increase in ambient noise levels of 5 dBA CNEL or greater.
• Where the existing ambient noise level is greater than 65 dBA, a project related permanent
increase in ambient noise levels of 3 dBA CNEL or greater.
City of Orange Municipal Code
The City’s Municipal Code Title 8, Health and Safety, Chapter of 8.24, Noise Control, states:
Section 8.24.050 Exterior Noise Standards
A. The following noise standards (Table 3.12-9, City of Orange Municipal Code Exterior
Noise Standards), unless otherwise specifically indicated, shall apply to all residential
property within a designated noise zone:
Table 3.12-9: City of Orange Municipal Code Exterior Noise Standards
Noise Zone Noise Level Time Period
1 55 dB (A) 7:00 a.m.–10:00 p.m.
1 50 dB (A) 10:00 p.m.–7:00 a.m.
Source: City of Orange Municipal Code Section 8.24.050.
B. It is unlawful for any person at any location within the City to create any noise, or to
allow the creation of any noise on property owned, leased, occupied or otherwise
controlled by such person, which causes the noise level when measured on any other
residential property to exceed:
1. The noise standard for a cumulative period of more than thirty minutes in any hour;
or
2. The noise standard plus five dB(A) for a cumulative period of more than fifteen
minutes in any hour; or
3. The noise standard plus ten dB(A) for a cumulative period of more than five
minutes in any hour; or
4. The noise standard plus fifteen dB(A) for a cumulative period of more than one
minute in any hour; or,
5. The noise standard plus twenty dB(A) for any period of time.
C. In the event the ambient noise level exceeds any of the five noise limit categories,
designated in Subsection B of this section, the cumulative period applicable to said
category shall be increased to reflect the ambient noise level. Furthermore, the
maximum permissible noise level shall never exceed the maximum ambient noise level.
D. Each of the noise limits specified in Subsection B shall be reduced by five dB(A) for
impact or simple tone noises, or for noises consisting of speech or music.
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Section 8.24.060 Interior Noise Standards
A. The following noise standards (Table 3.12-10, City of Orange Municipal Code Interior
Noise Standards), unless otherwise specifically indicated, shall apply to all residential
property within a designated noise zone:
Table 3.12-10: City of Orange Municipal Code Interior Noise Standards
Noise Zone Noise Level Time Period
1 55 dB (A) 7:00 a.m.–10:00 p.m.
1 45 dB (A) 10:00 p.m.–7:00 a.m.
Source: City of Orange Municipal Code Section 8.24.050.
B. It is unlawful for any person at any location within the City to create any noise or to
allow the creation of any noise, or to allow the creation of any noise on property
owned, leased, occupied or otherwise controlled by such person which causes the
noise level when measured within a dwelling unit on any residential property to
exceed:
1. The noise standard for a cumulative period of more than five minutes in any hour; or
2. The noise standard plus five dB(A) for a cumulative period of more than one minute
in any hour; or,
3. The noise standard plus ten dB(A) for any period of time.
C. In the event the ambient noise level exceeds any of the above three noise limit
categories designated in Subsection B of this section, the cumulative period applicable
to the category shall be increased to reflect the ambient noise level. Furthermore, the
maximum permissible noise level shall never exceed the maximum ambient noise level.
D. Each of the noise limits specified above shall be reduced by five dB(A) for impact or
simple tone noises, or for noises consisting of speech or music.
Section 8.24.070 Exemptions from Chapter Provisions states the following activities shall be
exempted from the provisions of this chapter:
a) School bands, school athletic and school entertainment events;
b) Outdoor gatherings, public dances, shows and sporting and entertainment events provided
such events are conducted pursuant to any permit requirements established by the City;
c) Activities conducted on public parks, public playgrounds, and public or private school
grounds;
d) Any mechanical device, apparatus or equipment used, related to or connected with
emergency machinery, vehicle or work;
e) Noise sources associated with construction, repair, remodeling, or grading of any real
property, provided said activities do not take place between the hours of 8:00 P.M. and 7:00
A.M. on weekdays, including Saturday, or at any time on Sunday or a Federal holiday;
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f) All mechanical devices, apparatus or equipment which are utilized for the protection or
salvage of agricultural crops during periods of potential or actual frost damage or other
adverse weather conditions;
g) Mobile noise sources associated with agricultural operations provided such operations do not
take place between the hours of 8:00 P.M. and 7:00 A.M. on weekdays including Saturday, or
at any time on Sunday or a Federal holiday;
h) Mobile noise sources associated with agricultural pest control through pesticide application,
provided that the application is made in accordance with restricted material permits issued
by or regulations enforced by the Agricultural Commissioner;
i) Noise sources associated with the maintenance of real property, provided such activities take
place between the hours of 7:00 A.M. and 8:00 P.M. on any day except Sunday or a Federal
holiday, or between the hours of 9:00 A.M. and 8:00 P.M. on Sunday or a Federal holiday;
j) Any activity to the extent regulation thereof has been preempted by State or Federal Law.
3.12.4 - Methodology
Traffic Noise Modeling Methodology
SoundPlan
Since the project vicinity is impacted by multiple roadways, the SoundPlan Version 7.4 noise
modeling software was used. SoundPlan’s road noise algorithms are based on the FHWA Traffic
Noise Model (FHWA TNM Model). The SoundPlan Model requires the input of roadways and the
locations of modeled receivers. In addition, sound barriers, terrain contour lines, building
placement, and specific ground coverage zones may be incorporated as well. The grading plan with
elevation lines and aerial photos were used to determine the placement of the roadways and to
establish the terrain in the project vicinity. The ground coverage of forest 25 feet high was used in
the area immediately adjacent to Santiago Creek and loose soil was used throughout the remainder
of the study area and the default temperature of 20 degrees Celsius (68 degrees Fahrenheit) and
default humidity of 50 percent were used in the analysis. The modeling input assumptions and
output data are provided in Appendix N.
Roadway Assumptions
The model analyzed the noise impacts from the nearby roadways onto the project vicinity. All
analyzed roadways were based on a single lane equivalent noise source combining both directions of
travel. The study area roadway parameters have been based on the roadway classification provided
in the City’s General Plan Circulation Element. The resultant traffic volumes and roadway
parameters used for this study are presented in Table 3.12-11.
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Table 3.12-11: SoundPlan Model Roadway Parameters
Roadway—Segment Description
General Plan
Classification
Vehicle Speed
(MPH)
Cannon Street—North of Taft Avenue Major Arterial 45
Cannon Street—North of Santiago Canyon Road Major Arterial 45
Cannon Street—South of Santiago Canyon Road Secondary Arterial 35
Orange Park Boulevard—South of Santiago Canyon Road Collector 40
Serrano Avenue—East of Cannon Street Secondary 40
Santiago Canyon Road—West of Cannon Street Augmented Primary 45
Santiago Canyon Road—East of Cannon Street Augmented Primary 50
Santiago Canyon Road—East of Orange Park Boulevard Augmented Primary 50
Mt McKinley Boulevard/Mabury Avenue—East of Serrano Avenue Local 25
Source: FirstCarbon Solutions, 2017.
In order to determine the off-site project generated traffic noise impacts, the average daily traffic
volumes on the study area local roadways were obtained from the traffic analysis) prepared for this
project by Linscott Law & Greenspan (December, 2017). Most of the average daily traffic (ADT)
volumes were taken directly from the Traffic Analysis, however the Traffic Analysis only provided AM
and PM peak hour volumes for the roadway segment of Serrano Avenue east of Cannon Street and
the ADT volume for this roadway segment was calculated by multiplying the PM peak hour volumes
by 10, which was the closest PM Peak to ADT multiplier available to all of the roadway segments
analyzed where both the PM Peak and ADT volumes were provided. Since the Traffic Study did not
provide the traffic volumes for Mount McKinley Boulevard/Mabury Avenue, the traffic volume of
1,000 ADT was estimated from field observations during the noise measurements. The model
requires the separate input of autos, medium trucks, and heavy trucks. The vehicle mix was based
on the vehicle mix used in the City of Orange General Plan Program Environment Impact Report for
the city’s roadways
The resultant noise levels were weighed and summed over a 24-hour period in order to determine
the CNEL values. Adjustments are then made to account for the roadway active width (i.e., the
distance between the center of the outermost travel lanes on each side of the roadway); the total
average daily traffic (ADT); and the percentage of ADT that flows during the day, evening, and night;
the travel speed; the vehicle mix on the roadway; and the site conditions (“hard” or “soft”) as they
relate to the absorption of the ground, pavement, or landscaping.
Vehicle noise is a combination of the noise produced by the engine, exhaust and tires. The level of
traffic noise depends on three primary factors (1) the volume of traffic, (2) the speed of traffic, and
(3) the number of trucks in the flow of traffic. The proposed project does not propose any uses that
would require a substantial number of truck trips and the proposed project would not alter the
speed limit on any existing roadway so the proposed project’s potential off-site noise impacts have
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been focused on the noise impacts associated with the change of volume of traffic that would occur
with development of the proposed project.
Stationary Operational Noise Impacts
The proposed project could include new stationary noise sources, such as typical parking lot
activities, and new mechanical ventilation equipment. These activities are potential point sources of
noise that could affect noise-sensitive receptors in the project vicinity. At the time of preparation of
this analysis, details were not available pertaining to mechanical ventilation systems; therefore, a
reference noise level for typical rooftop mechanical ventilation systems was used.
Permanent Increase in Ambient Noise Levels
The project would not result in a substantial permanent increase in ambient noise levels in the
project vicinity above levels existing without the project.
As noted in the characteristics of noise discussion, audible increases in noise levels generally refer to
a change of 3 dBA or more, as this level has been found to be barely perceptible to the human ear in
outdoor environments. A change of 5 dBA is considered to be the minimum change considered
readily perceptible to the human ear in outdoor environments. In order for proposed project’s
operations to be considered significant, the proposed project would need to increase the noise
levels on a residential or school land use above 65 dBA CNEL where the without project noise level is
below 65 dBA CNEL, or by (1) 5 dBA CNEL where the without project noise level is less than 65 dBA
CNEL, or (2) 3 dBA CNEL where the without project noise level is greater than 65 dBA CNEL. A
significant impact would also occur if the proposed project provides any increase to a residential or
school use receptor location which already exceeds 75 dBA CNEL.
3.12.5 - Thresholds of Significance
According to Appendix G, Environmental Checklist, of the CEQA Guidelines, noise impacts resulting
from the implementation of the proposed project would be considered significant if the project
would cause:
a) Exposure of persons to or generation of noise levels in excess of standards established in the
local general plan or noise ordinance, or applicable standards of other agencies?
b) Exposure of persons to or generation of excessive groundborne vibration or groundborne
noise levels?
c) A substantial permanent increase in ambient noise levels in the project vicinity above levels
existing without the project?
d) A substantial temporary or periodic increase in ambient noise levels in the project vicinity
above levels existing without the project?
e) For a project located within an airport land use plan or, where such a plan has not been
adopted, within two miles of a public airport or public use airport, would the project expose
people residing or working in the project area to excessive noise levels?
f) For a project within the vicinity of a private airstrip, would the project expose people residing
or working in the project area to excessive noise levels?
City of Orange—Trails at Santiago Creek Specific Plan
Noise Recirculated Draft EIR
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3.12.6 - Project Impacts and Mitigation Measures
This section discusses potential impacts associated with the development of the project and
provides mitigation measures where appropriate. The 128 residential parcels would occupy the 40.7
acres in the southern and western portion of the site between Santiago Creek and E. Santiago
Canyon Road. Open space and recreational uses would occupy the balance of the project site.
Santiago Creek and the area north of the creek would be permanently preserved as greenway. The
area located south of the creek and west of the residential uses would be occupied by a community
activity center that includes uses such as, but not limited to, gardens, 4-H, farmers market, and flex
activities.
Noise in Excess of Adopted Standards
Impact NOI-1: The proposed project will result in exposure of persons to or generation of noise
levels in excess of standards established in the local general plan or noise
ordinance, or applicable standards of other agencies.
Impact Analysis
Construction Noise Impacts
Implementation of the proposed project will be primarily dictated by economic conditions and may
occur on a phased basis over a period of years. However, for the purposes of providing a
conservative, reasonable worst-case analysis in this EIR, it will be assumed that the entire project
would be developed in a single phase that takes 12 months to complete.
Two types of short-term noise impacts could occur during the construction of the proposed project.
First, construction crew commutes and the transport of construction equipment and materials to the
project site would incrementally increase noise levels on access roads leading to the project site.
Although there would be a relatively high single-event noise exposure potential causing intermittent
noise nuisance, the effect on longer-term (hourly or daily) ambient noise levels would be small.
Therefore, short-term construction-related impacts associated with worker commute and
equipment transport to the project site would be less than significant.
The second type of short-term noise impact is related to noise generated during construction on the
project site. Construction is completed in discrete steps, each of which has its own mix of
equipment and, consequently, its own noise characteristics. These various sequential phases would
change the character of the noise generated on the site and, therefore, the noise levels surrounding
the site as construction progresses. Despite the variety in the type and size of construction
equipment, similarities in the dominant noise sources and patterns of operation allow construction
related noise ranges to be categorized by work phase. Typical operating cycles for these types of
construction equipment may involve 1 or 2 minutes of full-power operation followed by 3 or 4
minutes at lower power settings. Impact equipment such as pile drivers is not expected to be used
during construction of this project.
The highest construction-related noise levels would be generated during ground clearing, excavation,
and grading, as these phases require the use of the heaviest, and loudest, pieces of construction
equipment. Large pieces of earth-moving equipment, such as graders, excavators, and bulldozers,
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generate maximum noise levels of 80 dBA to 85 dBA Lmax at a distance of 50 feet. These noise levels
drop off at a rate of about 6 dBA per doubling of distance between the noise source and receptor.
As construction moves away from noise-sensitive receptors, noise levels generated by heavy
construction will be lower. A characteristic of noise is that each doubling of the sound sources with
equal strength increases the noise level by 3 dBA. Assuming that each piece of construction
equipment operates at some distance from the other equipment, the reasonable worst-case
combined noise level during this phase of construction would be 90 dBA Lmax at a distance of 50 feet
from an active construction area.
The residential uses to the east are the closest off-site sensitive receptors to where construction
equipment would be operating during the site preparation for the proposed residential unit
development. These homes would be located as near as 100 feet from the center of the nearest
construction footprint where multiple pieces of heavy equipment could be operating simultaneously.
At this distance, these loudest construction activities could be expected to result in noise levels
ranging up to approximately 84 dBA Lmax intermittently when multiple pieces of heavy construction
equipment operate simultaneously at the nearest center of construction activity.
Although there would be single-event noise exposure potential to cause intermittent noise nuisance
from project construction activity, the effect on longer-term (hourly or daily) ambient noise levels
would be small, but could result in annoyance or even sleep disturbance of nearby sensitive
receptors if operating outside daytime hours. The noise ordinance of the Municipal Code limits
noise producing construction activity to between the hours of 7:00 a.m. and 8:00 p.m. Monday
through Saturday; these activities are not permitted on Sundays or federal holidays. Thus,
compliance with the City’s permissible hours of construction, as well as compliance with best
management practices, construction noise reduction measures outlined in Mitigation Measure (MM)
NOI-1a, would ensure that construction noise would not result in sleep disturbance of sensitive
receptors or exposure of persons to noise levels in excess of established standards. With the
incorporation of mitigation, short-term construction impacts associated with applicable noise
standards established by the City of Orange will be less than significant.
Traffic Noise Impacts
Vehicle noise is a combination of the noise produced by the engine, exhaust and tires. The level of
traffic noise depends on three primary factors (1) the volume of traffic, (2) the speed of traffic, and
(3) the number of trucks in the flow of traffic. The proposed project does not propose any uses that
would require a substantial number of truck trips and the proposed project would not alter the
speed limit on any existing roadway so the proposed project’s potential off-site noise impacts have
been focused on the noise impacts associated with the change of volume of traffic that would occur
with development of the proposed project.
The potential off-site noise impacts caused through the increase in vehicular traffic from the on-
going operations from the proposed project on to the project study area roadways have been
analyzed for the following five traffic scenarios:
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• Existing With Project: This scenario refers to the existing traffic noise conditions, plus the net
traffic generated from the on-going operations of the proposed project without the traffic
generated from the materials recycling and backfilling operations.
• Year 2022 Baseline: This scenario refers to the future traffic noise conditions based on the
existing conditions that includes daily trips generated from the existing materials recycling and
backfilling operations on the project site plus an area growth rate of 2.8 percent per year and
traffic from cumulative projects, without construction of the proposed project.
• Year 2022 With Project: This scenario refers to the future traffic noise conditions based on the
Year 2022 Baseline conditions plus the net traffic, which consists of the traffic generated from
the on-going operations of the proposed project minus the traffic generated from the existing
materials recycling and backfilling operations.
• Year 2040 Baseline: This scenario refers to the future traffic noise conditions provided in the
OTAM traffic model, which is based on the year 2040 Existing General Plan traffic projections
for the project site that includes 126 single-family homes on the project site, without
construction of the proposed project.
• Year 2040 With Project: This scenario refers to the future traffic noise conditions based on the
Year 2040 Baseline conditions, plus the net traffic, which consists of the traffic generated from
the on-going operations of the proposed project minus the traffic generated from the 126
single-family homes in Planning Area A.
To quantify the traffic noise impacts along the analyzed roadways, the roadway noise contours were
calculated for Existing (Exhibit 3.12-1), Existing with Project (Exhibit 3.12-2), year 2022 baseline
(Exhibit 3.12-3), year 2022 with project (Exhibit 3.12-4), year 2040 baseline (Exhibit 3.12-5), and year
2040 with project (Exhibit 3.12-6) project noise contour maps.
In order for off-site roadway noise impacts created by the proposed project’s operations to be
considered significant, the proposed project would need to increase the noise levels on a residential
or school land use above 65 dBA CNEL where the without project noise level is below 65 dBA CNEL
or by (1) 5 dBA CNEL, where the without project noise level is less than 65 dBA CNEL or (2) 3 dBA
CNEL, where the without project noise level is greater than 65 dBA CNEL. A significant impact would
also occur if the proposed project provides any increase to a residential or school use that already
exceeds 75 dBA CNEL. The proposed project’s on-site and off-site noise impacts have been analyzed
for the existing, year 2022, and year 2040 conditions, which are discussed below.
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27650002 • 07/2018 |3.12-2_project_contours.cdr
Exhibit 3.12-2
Existing with Project Noise Contour Map (dBA CNEL)
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: SoundPlan Version 7.4
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27650002 • 07/2018 |3.12-3_2022_contours.cdr
Exhibit 3.12-3
Year 2022 Baseline Noise Contour Map (dBA CNEL)
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: SoundPlan Version 7.4
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27650002 • 07/2018 |3.12-4_2022project_contours.cdr
Exhibit 3.12-4
Year 2022 with Project Noise Contour Map (dBA CNEL)
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: SoundPlan Version 7.4
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27650002 • 07/2018 |3.12-5_2040_contours.cdr
Exhibit 3.12-5
Year 2040 Baseline Contour Map (dBA CNEL)
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: SoundPlan Version 7.4
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27650002 • 07/2018 |3.12-6_2040project_contours.cdr
Exhibit 3.12-6
Year 2040 with Project Contour Map (dBA CNEL)
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: SoundPlan Version 7.4
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Existing Conditions
The proposed project’s potential off-site noise impacts have been calculated through a comparison
of the existing scenario to the existing with project scenario. The results of this comparison are
shown in Table 3.12-12. The SoundPlan Model printouts are provided in Appendix N.
Table 3.12-12: Roadway Noise Impacts to Nearby Sensitive Receptors—Existing Conditions
Receiver1
Existing (dBA CNEL)2
Increase Threshold3
Exceed City
Standard? No Project With Project Increase
1 68.3 68.3 0.0 +3 dBA No
2 57.9 58.0 0.1 +5 dBA No
3 57.1 57.1 0.0 +5 dBA No
4 53.6 53.6 0.0 +5 dBA No
5 54.5 54.6 0.1 +5 dBA No
6 56.1 56.1 0.0 +5 dBA No
7 53.3 53.3 0.0 +5 dBA No
8 49.0 49.0 0.0 +5 dBA No
9 50.1 50.1 0.0 +5 dBA No
10 52.1 52.1 0.0 +5 dBA No
11 65.9 66.0 0.1 +3 dBA No
12 63.9 64.0 0.1 +5 dBA No
13 65.4 65.5 0.1 +3 dBA No
14 66.3 66.4 0.1 +3 dBA No
15 64.4 64.5 0.1 +5 dBA No
Notes:
All noise levels that exceed the City’s 65 dBA CNEL residential standard shown in Bold
1 Receiver locations shown in Exhibits 3.12-1 and 3.12-2.
2 Noise level includes a 4.77 dBA penalty to account for the noise sensitive evening hours and a 10 dBA penalty to
account for the noise sensitive nighttime hours.
3 Increase threshold obtained from City of Orange General Plan, 2010.
Source: FCS, 2017.
Table 3.12-12 above shows that for the existing conditions, noise level contributions from the
proposed project to the representative nearby sensitive receptors would range from 0.0 to 0.1 dBA
CNEL, which is below the 5 dBA increase threshold for roadways below 65 dBA CNEL and below the 3
dBA increase threshold for roadways that exceed 65 dBA CNEL. In this scenario, no analyzed
sensitive receptors would exceed the City’s residential or school noise standard of 65 dBA CNEL
when compared to existing without project conditions. In addition, no sensitive receptors would
exceed the 75 dBA CNEL maximum noise exposure level. Therefore, for the existing conditions, no
significant long-term off-site noise impacts from project-related vehicle noise would occur at the
nearby homes and schools.
City of Orange—Trails at Santiago Creek Specific Plan
Noise Recirculated Draft EIR
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Year 2022 Conditions
The proposed project’s potential off-site noise impacts have been calculated through a comparison
of the year 2022 baseline scenario to the year 2022 with project scenario. The results of this
comparison are shown in Table 3.12-13. The SoundPlan Model printouts are provided in Appendix N
for the year 2022 baseline conditions and year 2022 with project conditions.
Table 3.12-13: Roadway Noise Impacts to Nearby Sensitive Receptors—Year 2022
Conditions
Receiver1
Year 2022 (dBA CNEL)
Increase Threshold2
Exceed City
Standard? No Project With Project Increase
1 68.6 68.6 0.0 +3 dBA No
2 58.2 58.3 0.1 +5 dBA No
3 57.4 57.5 0.1 +5 dBA No
4 53.9 53.9 0.0 +5 dBA No
5 54.7 54.7 0.0 +5 dBA No
6 56.3 56.3 0.0 +5 dBA No
7 53.4 53.4 0.0 +5 dBA No
8 49.1 49.1 0.0 +5 dBA No
9 50.3 50.3 0.0 +5 dBA No
10 52.4 52.4 0.0 +5 dBA No
11 66.3 66.4 0.1 +3 dBA No
12 64.3 64.4 0.1 +5 dBA No
13 65.8 65.9 0.1 +3 dBA No
14 66.7 66.8 0.1 +3 dBA No
15 64.8 64.8 0.0 +5 dBA No
Notes:
All noise levels that exceed the City’s 65 dBA CNEL residential standard shown in Bold
1 Receiver locations shown in Exhibits 3.12-3 and 3.12-4.
2 Increase threshold obtained from City of Orange General Plan, 2010.
Source: FCS, 2017.
Table 3.12-13 above shows that for the year 2022 conditions, noise level contributions from the
proposed project to the representative nearby sensitive receptors would range from 0.0 to 0.1 dBA
CNEL, which is below the 5 dBA increase threshold for roadways below 65 dBA CNEL and below the 3
dBA increase threshold for roadways that exceed 65 dBA CNEL. In this scenario, no analyzed
sensitive receptors would exceed the City’s residential or school noise standard of 65 dBA CNEL
when compared to existing without project conditions. In addition, no sensitive receptors would
exceed the 75 dBA CNEL maximum noise exposure level. Therefore, for the year 2022 conditions, no
significant long-term off-site noise impacts from project-related vehicle noise would occur at the
nearby homes and schools.
City of Orange—Trails at Santiago Creek Specific Plan
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Year 2040 Conditions
The proposed project’s potential off-site noise impacts have been calculated through a comparison
of the year 2040 baseline scenario to the year 2040 with project scenario. The results of this
comparison are shown in Table 3.12-14. The SoundPlan Model printouts are provided in Appendix N
for the year 2040 baseline conditions and year 2040 baseline with project conditions.
Table 3.12-14: Roadway Noise Impacts to Nearby Sensitive Receptors—Year 2040
Conditions
Receiver1
Year 2040 (dBA CNEL)
Increase Threshold2
Exceed City
Standard? No Project With Project Increase
1 70.1 70.2 0.1 +3 dBA No
2 59.8 59.8 0.0 +5 dBA No
3 58.9 59.0 0.1 +5 dBA No
4 55.2 55.3 0.1 +5 dBA No
5 55.4 55.4 0.0 +5 dBA No
6 57.3 57.3 0.0 +5 dBA No
7 53.9 53.9 0.0 +5 dBA No
8 49.9 49.9 0.0 +5 dBA No
9 51.2 51.2 0.0 +5 dBA No
10 53.7 53.7 0.0 +5 dBA No
11 68.0 68.1 0.1 +3 dBA No
12 66.0 66.0 0.0 +3 dBA No
13 67.5 67.5 0.0 +3 dBA No
14 68.4 68.4 0.0 +3 dBA No
15 66.4 66.4 0.0 +3 dBA No
Notes:
All noise levels that exceed the City’s 65 dBA CNEL residential standard shown in Bold
1 Receiver locations shown in Exhibit 5 and 6.
2 Increase threshold obtained from City of Orange General Plan, 2010.
Source: FCS, 2017.
Table 3.12-14 above shows that for the year 2040 conditions, noise level contributions from the
proposed project to the representative nearby sensitive receptors would range from 0.0 to 0.1 dBA
CNEL, which is below the 5 dBA increase threshold for roadways below 65 dBA CNEL and below the 3
dBA increase threshold for roadways that exceed 65 dBA CNEL. In this scenario, no analyzed
sensitive receptors would exceed the City’s residential or school noise standard of 65 dBA CNEL
when compared to existing without project conditions. In addition, no sensitive receptors would
exceed the 75 dBA CNEL maximum noise exposure level. Therefore, for the year 2040 conditions, no
significant long-term off-site noise impacts from project-related vehicle noise would occur at the
nearby homes, churches and schools.
City of Orange—Trails at Santiago Creek Specific Plan
Noise Recirculated Draft EIR
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Potential On-site Exterior Traffic Noise Impacts
The proposed residential, community center and open space uses may be exposed to noise levels in
excess of City standards. According to the City’s General Plan, noise levels at new residential uses
shall be limited to 65 dBA CNEL for exterior living areas and 45 dBA CNEL for interior living areas. In
addition, exterior noise levels at neighborhood centers and parks shall be limited to 70 dBA CNEL.
To evaluate the noise exposure levels that would impact the proposed residential and community
uses along East Santiago Canyon Road, the year 2040 with project scenario was utilized for
calculating the exterior noise impacts at those proposed uses. As shown in Exhibit 3.12-6, The 65
dBA and 70 dBA CNEL traffic noise level contour extend 352 feet and 163 feet onto the project site,
respectively. A detailed site plan has yet to be drafted, however, for this analysis it is assumed that
residential uses would be located within 163 feet of East Santiago Canyon Road. Therefore, all
residential structures within 352 feet of the centerline of East Santiago Canyon Road would be
exposed to traffic noise levels in excess of the City ’s “normally compatible” standard of 65 dBA CNEL
for new single-family residential land use development. Therefore, mitigation must be incorporated
into the Project to reduce on-site traffic noise impacts.
It should be noted that existing noise sensitive residential uses located along East Santiago Canyon
Road to the east and south of the project site are immediately adjacent the four-lane roadway.
These noise sensitive receptors are shielded from East Santiago Canyon Road traffic noise by a 6-foot
noise barrier. This 6-foot noise barrier was accounted for in SoundPlan modeling and Exhibit 3.12-6
shows that noise levels at these existing noise sensitive residences are below 65 dBA CNEL within
backyard areas.
Potential On-site Interior Traffic Noise Impacts
According to the City’s land use compatibility standards, when new residential development is
proposed in areas with a noise environment ranging from 65 dBA to 70 dBA CNEL, a detailed noise
impact analysis must be performed and needed noise insulation features must be included in the
design to ensure that the interior noise standard of 45 dBA CNEL is maintained. This requirement is
also consistent with General Plan Policy 1.6.
Based on the EPA’s Protective Noise Levels (EPA 550/9-79-100, November 1978), with a combination
of walls, doors and windows, standard construction for northern California residential buildings
would provide approximately 25 dBA in exterior to interior noise reduction with windows closed,
and approximately 15 dBA with windows open. These exterior to interior noise reduction rates are
also consistent with the exterior to interior noise reduction rates provided in Table N-5 from the
General Plan (City of Orange, 2010).
Beyond approximately 560 feet from the centerline of East Santiago Canyon Road, exterior traffic
noise levels would attenuate to below 60 dBA CNEL, and therefore, interior noise levels would
attenuate to the interior residential living space noise level standard of 45 dBA CNEL (65 dBA-15 dBA
= 45 dBA). In other words, beyond 560 feet from the center line of East Santiago Canyon Road,
standard residential construction methods would provide sufficient reduction to meet the interior
residential living space noise level standard of 45 dBA CNEL.
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However, with windows open, interior living spaces for the proposed residential land uses located
within approximately 560 feet of the center line of East Santiago Canyon Road would not meet the
interior noise standard of 45 dBA CNEL (60+ dBA–15 dBA = 45+ dBA). With windows closed, the
interior noise standard would be met for the area between 164 and 560 feet from the centerline of
East Santiago Canyon Road (60 to 70 dBA–25 dBA = 35 to 45 dBA). In such cases, it is standard
procedure to require that an alternative ventilation system, such as air conditioning, be provided to
ensure that windows can remain closed for a prolonged period of time in order to meet interior
noise standards. Although detailed design plans are not available at this time, it is assumed for this
climate that all proposed residences would include, as a project design feature, a heating/air
conditioning ventilation system (HVAC) that would allow for a windows closed condition. For any
homes located closer than 164 feet from the centerline of East Santiago Canyon Road, additional
mitigation is required to meet the interior noise standard, which could be achieved through the use
of upgraded windows and doors.
Off-site Stationary Noise Impacts
On the southwestern area of the project site, 128 single-family residences are proposed for
construction within the Residential Development Area. This residential portion of the Project would
include new stationary noise sources such as new mechanical ventilation system equipment on the
outside of the proposed residential units. In order for operational stationary noise impacts created by
the proposed project to be considered significant, the project-related operational noise level would
have to exceed 55 dBA Leq and 70 dBA Lmax between 7:00 a.m. and 10:00 p.m. or exceed 50 dBA Leq and
65 dBA Lmax between 10:00 p.m. and 7:00 p.m. at the exterior façade of nearby sensitive receptors.
Typical new residential mechanical ventilation systems (such as exterior air conditioning units)
generate noise levels from approximately 50 dBA to 65 dBA Leq at 10 feet (Noise NavigatorTM Sound
Level Database 2015). The residential uses to the east are the closest off-site sensitive receptors,
and are located approximately 65 feet from the Project’s nearest property line. At this distance,
these noise levels would attenuate to 49 dBA Leq. Therefore, noise levels from mechanical
ventilation systems operations would not exceed the City’s standard of 55 dBA Leq and 70 dBA Lmax
between 7:00 a.m. and 10:00 p.m. or exceed 50 dBA Leq and 65 dBA Lmax between 10:00 p.m. and
7:00 p.m. at the exterior façade of nearby sensitive receptors.
The area located south of the creek and west of the proposed residential uses would be occupied by
recreational uses. These land uses/improvements could result in new stationary noise sources
primarily associated with the activities at the parking lot and related to community activities. Parking
lot activities, such as people conversing or doors slamming, typically generate noise levels of
approximately 60 dBA to 70 dBA Lmax at 50 feet and would most likely be located along East Santiago
Canyon Road. The nearest off-site sensitive receptors to a potential parking lot would be the
residential land uses located approximately 125 feet to south across the four lane East Santiago Canyon
Road. Noise levels from these parking lot activities at this distance could range up to approximately 62
dBA Lmax. Therefore, when averaged over a 24-hour period, noise levels from community center
activities would not exceed the City’s standard of 55 dBA Leq and 70 dBA Lmax between 7:00 a.m. and
10:00 p.m. or exceed 50 dBA Leq and 65 dBA Lmax between 10:00 p.m. and 7:00 p.m. at the exterior
façade of nearby sensitive receptors.
City of Orange—Trails at Santiago Creek Specific Plan
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Potentially significant impacts could occur if parking lot activities exceeded existing maximum noise
levels in the Project vicinity. However, maximum noise levels along East Santiago Canyon Road and
in the Project vicinity exceed 70 dBA Lmax and there is an existing noise barrier located along noise
sensitive residential property lines south of East Santiago Canyon Road. In addition, although there
could be occasional single-event noise exposure of over 70 dBA Lmax from parking lot activities as
measured at 50 feet, these single-event maximum noise levels are not expected to occur for more
than a cumulative 1 minute within any hour. Therefore, when averaged over a 24-hour period, noise
levels from parking lot activities would not exceed the City’s standard of 55 dBA Leq and 70 dBA Lmax
between 7:00 a.m. and 10:00 p.m. or exceed 50 dBA Leq and 65 dBA Lmax between 10:00 p.m. and
7:00 p.m. at the exterior façade of nearby sensitive receptors. As a result, Project-related parking lot
activities would not result in exposure of persons to noise levels in excess of existing noise levels nor
result in noise levels that would exceed established standards.
Noise sources associated with recreational activities would primarily be comprised of human speech.
There could be periods of intensive activity prior to a farmers market with setup and tear down
activities. Activities associated with recreational uses would not require the use of heavy noise
producing equipment. The nearest noise-sensitive residential uses to the proposed recreational uses
are those located to the north over 300 feet away. The residential uses to the south benefit from an
existing noise barrier and recreational activities would be dominated by East Santiago Canyon Road
traffic noise. Therefore, when averaged over a 24-hour period, noise levels from community center
activities would not exceed the City’s standard of 55 dBA Leq and 70 dBA Lmax between 7:00 a.m. and
10:00 p.m. or exceed 50 dBA Leq and 65 dBA Lmax between 10:00 p.m. and 7:00 p.m. at the exterior
façade of nearby sensitive receptors. As a result, project-related parking lot activities would not
result in exposure of persons to noise levels in excess of existing noise levels nor result in noise levels
that would exceed established standards.
In summary, on-site stationary operational noise levels would not exceed existing ambient noise
levels in the Project vicinity nor be expected to exceed the City’s maximum allowable noise exposure
standards for receiving land uses. Related impacts would be less than significant.
Level of Significance Before Mitigation
Potentially significant impact.
Mitigation Measures
MM NOI-1a To reduce potential construction noise impacts, the following multi-part mitigation
measure shall be implemented for the proposed project:
• The construction contractor shall ensure that all equipment driven by internal
combustion engines shall be equipped with mufflers, which are in good condition
and appropriate for the equipment.
• The construction contractor shall locate stationary noise-generating equipment as
far as possible from sensitive receptors when sensitive receptors adjoin or are
near a construction project area. In addition, the project contractor shall place
such stationary construction equipment so that emitted noise is directed away
from sensitive receptors nearest the project site.
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• The construction contractor shall ensure that unnecessary idling of internal
combustion engines (i.e., idling in excess of 5 minutes) is prohibited.
• The construction contractor shall utilize “quiet” models of air compressors and
other stationary noise sources where technology exists.
• The construction contractor shall, to the maximum extent practical, locate on-site
equipment staging areas to maximize the distance between construction-related
noise sources and noise-sensitive receptors nearest the project site during all
project construction.
• The construction contractor shall ensure that the construction staging areas shall
be located to create the greatest feasible distance between the staging area and
noise-sensitive receptors nearest the project site.
• The construction contractor shall designate a noise disturbance coordinator who
would be responsible for responding to any local complaints about construction
noise. The disturbance coordinator would determine the cause of the noise
complaints (starting too early, bad muffler, etc.) and establishment reasonable
measures necessary to correct the problem. The construction contractor shall
visibly post a telephone number for the disturbance coordinator at the
construction site.
• All on-site construction activities, including deliveries and engine warm-up, shall
be restricted to the hours between 7:00 a.m. and 8:00 p.m. Monday through
Saturday. Construction, except emergency work, shall not be permitted on
Sunday or federal holidays.
MM NOI-1b To reduce potential future on-site exterior traffic noise impacts at on-site receptors
adjacent to East Santiago Canyon Road, the following multi-part mitigation measure
shall be implemented for the proposed project:
• Based on SoundPlan model runs, a 6-foot high noise barrier, relative to the
receptor elevation, is required to comply with the City’s exterior noise standard
for proposed residential uses located adjacent to Santiago Canyon Road. The
calculated noise contours are shown in Exhibit 3.12-7. In order to meet the City’s
exterior noise standard for community uses, a 4-foot high berm would be required
along Santiago Canyon Road; or
• A minimum setback distance of 164 feet from the centerline of East Santiago
Canyon Road shall be incorporated into the design feature. The first row of
residential uses constructed 164 feet from the centerline will also have front yards
facing East Santiago Canyon Road.
MM NOI-1c To reduce potential future on-site interior traffic noise impacts at on-site receptors
adjacent to East Santiago Canyon Road, the following multi-part mitigation measure
shall be implemented for the proposed project:
• All proposed residential units located within 560 feet of the centerline of East
Santiago Canyon Road shall include an alternate form of ventilation, such as an air
conditioning system, in order to ensure that windows can remain closed for a
City of Orange—Trails at Santiago Creek Specific Plan
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prolonged period of time. The building plans approved by the County shall reflect
this requirement.
• All second story habitable rooms of proposed residential units located within 164
feet of the centerline of East Santiago Canyon Road shall include STC 30 rated
windows in facades that would be parallel and perpendicular to East Santiago
Canyon Road; or,
• Upon completion of the architectural plans, a detailed acoustical study shall be
prepared by a qualified noise analyst that analyzes the interior noise levels of the
proposed residential units and provides design features to reduce the interior
noise levels to within the 45 dBA CNEL standard.
Level of Significance After Mitigation
Less than significant impact.
Vibration
Impact NOI-2: The project would not expose persons to or generation of excessive groundborne
vibration or groundborne noise levels.
Impact Analysis
Construction-Related Vibration
Construction activities can produce vibration that may be felt by adjacent uses. The primary sources
of vibration during construction would be during grading activities. The closest vibration sensitive
land uses are the nearby single-family homes, with the nearest residential structures located
approximately 50 east feet from the proposed area to be graded. It is anticipated that the vibration
levels caused by a vibratory roller operating on the edge of the area to be graded during
construction of the proposed project at the nearest structure will be around 0.098 PPV would be
readily perceptible for a person sitting or lying down and may create groundborne noise such as the
rattling of loose windows or dishes. However, the vibration impacts would only occur when heavy
construction equipment is operating in the immediate vicinity of a sensitive receptor, which would
only occur intermittently for a limited duration. In addition, this vibration level is below the 0.2 PPV
FTA threshold. Therefore, the short-term construction-related vibration from the proposed project
would result in a less than significant short-term vibration impact.
Operational-Related Vibration Impacts
Residential units could be located as near as 50 feet from the edge of East Santiago Canyon Road.
According to Table 4.12-1, Vibration Source Levels for Construction Equipment, a truck typically
produces a vibration level of 0.076 inch per second PPV at 25 feet from a roadway. Based on the
typical propagation of vibration this would result in reasonable worst-case vibration level of 0.035
inch per second PPV at the nearest proposed residential unit to East Santiago Canyon Road. A
vibration level of 0.035 inch per second PPV would be slightly above the level of perception for a
person sitting or lying down and may create groundborne noise such as the rattling of loose windows
or dishes, if East Santiago Canyon Road is not properly maintained in the future. This vibration level
is below the 0.2 PPV FTA threshold. Therefore, a less than significant vibration impact is anticipated
from the on-going operations of the proposed project.
Santia
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R
d.Cannon St.1
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2
3
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5 6
7
8
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11
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13
14
15
10
6' Wall
4' Berm
I
27650002 • 07/2018 |3.12-7_2040mitigated_contours.cdr
Exhibit 3.12-7
Year 2040 with Project Sound Walls/Berms Noise Contour Map (dBA CNEL)
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: SoundPlan Version 7.4
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Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
Permanent Increase in Ambient Noise Levels
Impact NOI-3: The proposed project would not result in a substantial permanent increase in
ambient noise levels in the project vicinity.
Impact Analysis
Potential Off-Site Road Noise Impacts
In order for off-site roadway noise impacts created by the proposed project’s operations to be
considered significant, the proposed project would need to increase the noise levels on a residential
or school land use above 65 dBA CNEL where the without project noise level is below 65 dBA CNEL,
or by (1) 5 dBA CNEL where the without project noise level is less than 65 dBA CNEL, or (2) 3 dBA
CNEL where the without project noise level is greater than 65 dBA CNEL. A significant impact would
also occur if the proposed project provides any increase to a residential or school use that already
exceeds 75 dBA CNEL. The proposed project’s on-site and off-site noise impacts have been analyzed
for the existing, year 2022, and 2040 conditions, which are discussed below.
Existing Conditions
The analysis in Impact NOI-1 found that for the existing conditions, noise level contributions from
the proposed project to the study area roadways would range from 0.0 to 0.1 dBA CNEL, which is
below the 5 dBA increase threshold for roadways below 65 dBA CNEL and below the 3 dBA increase
threshold for roadways that exceed 65 dBA CNEL. In this scenario, no additional roadway segments
would exceed the City’s residential or school noise standard of 65 dBA CNEL when compared to
existing without project conditions. In addition, no roadways would exceed the 75 dBA CNEL
maximum noise exposure level. Therefore, for the existing plus project conditions, no significant
long-term off-site noise impacts from project-related vehicle noise would occur along the study area
roadways segments.
Year 2022 Conditions
The analysis in Impact NOI-1 found that for the year 2022 conditions, noise level contributions from
the proposed project to the study area roadways would range from 0.0 to 0.1 dBA CNEL, which is
below the 5 dBA increase threshold for roadways below 65 dBA CNEL and below the 3 dBA increase
threshold for roadways that exceed 65 dBA CNEL. In this scenario, no additional roadway segments
would exceed the City’s residential or school noise standard of 65 dBA CNEL when compared to year
2022 baseline conditions. In addition, no roadways would exceed the 75 dBA CNEL maximum noise
exposure level. Therefore, for the year 2022 plus project conditions, no significant long-term off-site
noise impacts from project-related vehicle noise would occur along the study area roadways segments.
City of Orange—Trails at Santiago Creek Specific Plan
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Year 2040 Conditions
The analysis in Impact NOI-1 found that for the year 2040 conditions, noise level contributions from
the proposed project to the study area roadways would range from 0.0 to 0.1 dBA CNEL, which is
below the 5 dBA increase threshold for roadways below 65 dBA CNEL and below the 3 dBA increase
threshold for roadways that exceed 65 dBA CNEL. In this scenario, no additional roadway segments
would exceed the City’s residential or school noise standard of 65 dBA CNEL when compared to year
2040 baseline conditions. In addition, no roadways would exceed the 75 dBA CNEL maximum noise
exposure level. Therefore, for the year 2040 plus project conditions, no significant long-term off-site
noise impacts from project-related vehicle noise would occur along the study area roadways
segments.
Potential Stationary Noise Impacts
The analysis in Impact NOI-1 found that for the most noise intensive use proposed, the stationary
noise levels at the nearby sensitive receptors would be below the City’s 55 dBA Leq daytime and 50
dBA Leq nighttime exterior stationary noise standards. Therefore, a less than significant stationary
average noise impact would occur from the ongoing operations of the proposed project at the
nearby sensitive receptors.
Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
Temporary Increase in Ambient Noise Levels
Impact NOI-4: The proposed project will result in a substantial temporary increase in ambient
noise levels in the project vicinity.
Impact Analysis
The proposed project would not create a substantial temporary or periodic increase in ambient noise
levels in the proposed project vicinity above noise levels existing without the proposed project.
The analysis in Impact NOI-1 found that, although there would be single-event noise exposure
potential to cause intermittent noise nuisance from project construction activity, the effect on
longer-term (hourly or daily) ambient noise levels would be small, but could result in annoyance or
even sleep disturbance of nearby sensitive receptors if operating outside daytime hours. Therefore,
compliance with the City’s permissible hours of construction, as well as compliance with best
management practices, construction noise reduction measures outlined in Mitigation Measure
NOI-1a, would ensure that construction noise would not result in sleep disturbance of sensitive
receptors or result in a substantial temporary increase in ambient noise levels as measured at nearby
sensitive receptors.
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Level of Significance Before Mitigation
Potentially significant impact.
Mitigation Measures
Implement Mitigation Measure NOI-1a.
Level of Significance After Mitigation
Less than significant impact.
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3.13 - Population and Housing
This section describes population and housing and potential effects from project implementation on
the affected area and its surroundings. Descriptions and analysis in this section are based on
population and housing information provided by the California Department of Finance and the City
of Orange.
3.13.1 - Existing Conditions
Current Population and Housing Characteristics
The City of Orange’s population was estimated to be 141,240 as of January 1, 2016 by the California
Department of Finance. Table 3.13-1 summarizes the current population and housing characteristics
of the City of Orange.
Table 3.13-1: City of Orange Population and Housing Summary (2016)
Population Housing Units Persons Per Household
141,240 45,272 3.07
Source: California Department of Finance, 2016.
Historic Population Growth
The City of Orange’s population growth has increased by 63,497 persons during the 45 years
between 1970 and 2015. Table 3.13-2 summarizes the population growth that occurred between
1970 and 2015.
Table 3.13-2: Population Growth (1970–2015)
Year Population Change from Previous
1970 77,365 —
1975 83,100 7.4%
1980 91,440 10.0%
1985 100,600 10.0%
1990 110,658 10.0%
1995 117,174 16.5%
2000 128,868 10.0%
2005 133,542 3.6%
2010 136,386 2.1%
2015 140,862 3.3%
Source: California Department of Finance, 2016.
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3.13.2 - Methodology
Impacts on population and housing were assessed by reviewing existing and anticipated population
and housing figures provided by the California Department of Finance and the City of Orange
General Plan. The proposed project’s impacts were evaluated by determining their consistency with
these estimates and projections.
3.13.3 - Thresholds of Significance
According to the CEQA Guidelines’ Appendix G Environmental Checklist, to determine whether
impacts to population and housing are significant environmental effects, the following questions are
analyzed and evaluated. Would the project:
a) Induce substantial population growth in an area, either directly (for example, by proposing
new homes and businesses) or indirectly (for example, through extension of roads or other
infrastructure)?
b) Displace substantial numbers of existing housing, necessitating the construction of
replacement housing elsewhere? (Refer to Section 7, Effects Found Not To Be Significant.)
c) Displace substantial numbers of people, necessitating the construction of replacement
housing elsewhere? (Refer to Section 7, Effects Found Not To Be Significant.)
3.13.4 - Project Impacts and Mitigation Measures
This section discusses potential impacts associated with the proposed project and provides
mitigation measures where necessary.
Growth Inducement
Impact POP-1: The project would not induce substantial population growth in an area, either
directly (for example, by proposing new homes and businesses) or indirectly (for
example, through extension of roads or other infrastructure).
Impact Analysis
CEQA Guidelines 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. The CEQA Guidelines provide the
example of a major expansion of a wastewater treatment plant that may allow for more construction
within the service area. The CEQA Guidelines also note that the evaluation of growth inducement
should consider the characteristics of a project that may encourage or facilitate other activities that
could significantly affect the environment.
The proposed project would develop 128 dwelling units and, therefore, has the potential to directly
induce population growth. Table 3.13-3 summarizes the population growth attributable to the
proposed project.
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Table 3.13-3: Population Growth
Dwelling
Units
Persons Per
Dwelling Unit
Project Population
Growth
City of Orange’s
Population
Project Population Growth as a
Percentage of City Population
128 3.07 393 141,420 0.3%
Source: FCS, 2018
As shown in Table 3.13-3, the proposed project would increase the City’s population by 393 persons,
which would represent a less than 1 percent increase relative to the City’s 2016 population estimate
of 141,420. This would not be considered a significant population increase.
Furthermore, a portion of the project site is currently designated for residential use by the City of
Orange General Plan and Orange Zoning Ordinance. This indicates that the project site has been
contemplated to support residential development and, by extension, future population growth.
Although the proposed project would include a General Plan Amendment and Rezone to change the
land use designations, these changes would merely serve to allow for the master planning of the site
to allow a combination of residential, open space, and recreational uses. Thus, the project site
would continue to be designated for residential development.
Lastly, the project site is within an urbanized portion of the City of Orange where infrastructure and
utilities including roadways, potable water, sewer, electricity, and natural gas are currently available.
Thus, the development of the proposed project would not remove a physical barrier to growth that
would allow for unplanned growth to occur.
Impacts would be less than significant.
Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
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3.14 - Public Services
3.14.1 - Introduction
This section describes the existing public services and potential effects from project implementation
on the project site and its surrounding area. Descriptions and analysis in this section are based in
part on information provided by the City of Orange General Plan, City of Orange Fire Department,
City of Orange Police Department, City of Orange Public Works, and the Orange Unified School
District (OUSD). Written comments from service providers are provided in Appendix O.
3.14.2 - Environmental Setting
Fire Protection and Emergency Medical Services
The project site is located in an area served by the City of Orange Fire Department. The City of
Orange Fire Department provides the City with full fire protection services and emergency medical
service (EMS). The Fire Department is headquartered at 176 S. Grand Street, Orange, California.
Fire Stations
The Orange Fire Department emergency responders work out of eight fire stations strategically
located throughout the City. The closest fire station to the project site is Orange Fire Station No. 8,
located approximately 1.75 miles north of the project site at 5725 Carver Lane; there is also an
Orange County Fire Authority Fire Station, 23, approximately 0.64 mile east of the project site at
5020 Santiago Canyon Road, Villa Park, CA 92869 (Table 3.14-1).
Table 3.14-1: Fire Station Summary
Station No. Address Distance From Project Site
Orange Fire Department Station No. 8 5725 Carver Lane 1.75 miles
Orange County Fire Authority Station 23 5020 Santiago Canyon Road
Villa Park, CA 92869 0.64 mile
Source: City of Orange, 2016.
Staffing and Organization
The Orange Fire Department consists of two sections: Services and Operations. The department
provides emergency response, administrative, fire prevention, disaster preparedness, and arson
investigation services. The Orange Fire Department employs approximately 137 personnel, including
124 sworn emergency responders.
The Orange Fire Department provides fire paramedic and ambulance service with an integrated
paramedic/transportation system. This system uses front line engine, truck, and rescue ambulance
companies to provide these emergency medical services. Every fire station houses at least one
“paramedic assessment unit” (PAU) that is normally staffed with at least one paramedic. PAUs are
normally in the form of an engine company. PAUs are at every station to achieve the goal of an
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initial on-scene time for EMS intervention of less than 6 minutes. Then, the rescue ambulances
located at Stations 1, 3, 4, and 5 arrive to complete a paramedic team.
The Orange Fire Department Headquarters at 176 South Grand Street, approximately 3.83 miles
southwest of the project site, houses the Urban Search and Rescue Emergency Operation.
Calls for Service
In 2016, the Orange Fire Department responded to approximately 15,048 incidents, of which 80
percent (12,048 calls) were medical in nature. This reflects a call load virtually equal to 2015, in
which the Fire Department responded to 15,090 incidents. Station No. 8 responded to 631 incidents
in 2016.
Response Time
The Orange Fire Department’s average response time was 3 minutes, 45 seconds in 2016.
Mutual Aid
The Orange Fire Department has automatic aid agreements with the cities of Anaheim, Santa Ana,
Garden Grove and the Orange County Fire Authority.
As noted above, the Orange County Fire Authority Station 23 is located 0.64 mile west the project
site. In 2016, the Orange County Fire Authority responded to approximately 136,934 incidents, of
which 76 percent (104,153) were medical in nature. The Orange County Fire Authority’s average
response time was less than 7 minutes in 2016.
Law Enforcement
The Orange Police Department provides law enforcement to the City of Orange. The Police
Department is headquartered at 1107 N. Batavia Street, which is approximately 4.6 miles west of the
project site. The Police Department also maintains substations in Santiago Canyon and at the
Outlets at Orange. The City of Orange is divided into 97 police reporting districts. The project is
within police reporting district No. 94 with boundaries of Santiago Canyon Road and the Santiago
Creek.
Operation
The Police Department has 167 sworn police officers, 60 full-time civilian support staff and 15
reserve officers. The response area is approximately 27 square miles with future expansion of up to
55 square files.
The Police Department does not use a standard officer-to-population or standard response time
objective ratio to measure the adequacy of policing levels in the City of Orange. Instead, the Police
Department analyzes demographics, service calls, population, crime trends and other changing
factors to determine the level of police services needed.
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Response Times
Emergency response times vary on average from 4 to 7 minutes, depending on other call priorities
and location of police vehicles in relation to call location. The call response time accounts for the
department’s policy requiring that two officers be available before responding to an emergency call.
Each new development has a potential impact on response times and increased demand on police
services. Using design mitigations and adding security measures could help reduce the number of
times the Police Department responds to the project area.
Schools
The Orange Unified School District (OUSD) provides K-12 public school services to the City of Orange
as well as portions of neighboring cities of Anaheim, Garden Grove, Santa Ana, and Villa Park. OUSD
serves over 31,300 students with 29 elementary schools; five middle schools (two of which are
charter schools), two high schools, a continuation high school, a K-8 math and science magnet
school, and two special schools.
Linda Vista Elementary School, Santiago Middle School, and El Modena High School are the closest
schools to the project site and are summarized in Table 3.14-2.
Table 3.14-2: Orange Unified School District Facilities
School Address Enrollment
Average Class
Size
Pupil/Teacher
Ratio
Linda Vista Elementary School 1200 N. Cannon Street 486 29.4 22.0
Santiago Middle School 515 North Rancho Santiago
Boulevard 967 28.4 22.0
El Modena High School 3920 Spring Street 2,169 24.7 20.1
Source: California Department of Education, 2016.
Parks
The City of Orange owns and currently maintains 24 parks, which consist of approximately 251 acres
of parkland. The following three types of park facilities are available for recreational use by the
City’s residents and could be subject to impact from increased demand for recreational use as the
City’s population increases:
• Neighborhood Parks (4 to 10 acres with a 0.5- to 1-mile radius service area) provide for the
daily recreation needs of residents in the immediate area. Olive Park, El Modena Park, and
Killefer Park are typical examples of the City’s neighborhood parks, which may include
landscaped picnic areas, tot lots, hard court areas, multipurpose ball fields, and limited
parking.
• Community Parks (15 to 40 acres with 1- to 2-mile radius service area) are larger in scale and
provide a greater variety of recreational opportunities and facilities. Hart Park, Grijalva Park,
and El Camino Real Park are typical examples of the City’s community parks, which host active
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organized sports leagues, have lighted sports fields, may provide recreational instruction, and
have sufficient area for larger community events.
• Regional Parks are typically 200 acres or larger and provide a greater diversity of recreational
activities that cannot be fully met by neighborhood or community parks. For Orange
residents, the three county regional parks that serve these needs are Irvine Park, Peters
Canyon Park, and Santiago Oaks Park.
In addition to these three types of parks that provide opportunity for active recreation, the City also
maintains Special Use Facilities that provide passive uses and historic or aesthetic amenities. These
facilities include historic community assets such as Plaza Park, Pitcher Park, and Depot Park. The
City’s community gardens and senior center also provide specialized activities.
Library
The Orange Public Library & Historic Center (Main Library) is located at 407 E. Chapman Avenue. The
library closed in May 2005 for major construction and expansion, and was reopened in April 2007.
The expansion added 28,000 square feet of space and now provides twice as many books, a
homework center, a Teen Zone, a Children’s Library, a literacy center, a local history room, a Friends
of the Orange Public Library bookstore, community meeting space, study room space, and 100
public-use computers.
Two branch libraries also serve the planning area. The El Modena Branch Library is located at 380 S.
Hewes Street and the Taft Branch Library is located at 740 E. Taft Avenue. Each library is operated as
a community resource and gathering place to provide library materials, computer access, meeting
room space, and family programs to serve residents within the area.
3.14.3 - Regulatory Framework
Federal and State
California Fire Code and California Building Code
The International Fire Code and the International Building Code established by the International
Code Council (ICC) and amended by the State of California prescribe performance characteristics and
materials to be used to achieve acceptable levels of fire protection.
Senate Bill 50
Senate Bill (SB) 50 (funded by Proposition 1A, approved in 1998) limits the power of cities and
counties to require mitigation of school facilities impacts as a condition of approving new
development, and provides instead for a standardized developer fee. SB 50 generally provides for a
50/50 state and local school facilities funding match. SB 50 also provides for three levels of statutory
impact fees. The application level depends on whether state funding is available, whether the school
district is eligible for state funding, and whether the school district meets certain additional criteria
involving bonding capacity, year-round school, and the percentage of moveable classrooms in use.
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California Government Code, Section 65995(b) and Education Code, Section 17620
SB 50 amended Section 65995 of the California Government Code, which contains limitations on
Section 17620 of the Education Code, the statute that authorizes school districts to assess
development fees within school district boundaries. Section 65995(b)(3) of the Government Code
requires the maximum square footage assessment for development to be increased every 2 years,
according to inflation adjustments. On January 22, 2014, the State approved increasing the allowable
amount of statutory school facilities fees (Level I School Fees) from $3.20 to $3.36 per square foot of
assessable space for residential development of 500 square feet or more, and from $0.51 to $0.54 per
square foot of chargeable covered and enclosed space for commercial/industrial development.
School districts may levy higher fees if they apply to the State and meet certain conditions.
Quimby Act
The Quimby Act (Government Code Section 66477) allows local governments to require developers
to dedicate land, donate conservation easements, or pay fees to fund parkland development. The
Quimby Act has a standard of 3.5 acres of parkland per 1,000 residents.
Local
City of Orange
The City of Orange General Plan sets forth the following goals and policies that are relevant to public
services:
Land Use Element
• Goal 1: Meet the present and future needs of all residential and business sectors with a
diverse and balanced mix of land uses.
• Policy 1.7: Provide a range of open space and park amenities to meet the diverse needs of
current and new residents.
• Goal 6.0: Advance development activity that is mutually beneficial to both the environment
and the community.
• Policy 6.3: Establish and maintain greenways, and pedestrian and bicycle connections that
complement the residential, commercial and open space areas they connect.
• Policy 6.4: Create and maintain open space resources that provide recreational opportunities,
protect hillside vistas and ridgelines, and conserve natural resources.
• Policy 7.1: Coordinate with the Orange Unified School District and Community College District
regarding future plans for their facilities.
Public Safety Element
• Goal 3.0: Protect lives and property of Orange residents and businesses from urban and
wildlife fire hazards.
• Policy 3.1: Continue to identify and evaluate new potential fire hazards and fire hazard areas.
• Policy 3.4: Provide adequate fire equipment access and fire suppression resources to all
developed and open space areas.
• Policy 3.5: Establish and maintain optimal emergency response times for fire safety. Require
new development to ensure that City response times and service standards are maintained.
• Goal 6.0: Provide public safety services of the highest quality.
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• Policy 6.1: Provide the Police Department with adequate personnel, equipment and state-of-
the-art technology to effectively combat crime, meet existing and projected service demands,
and provide crime prevention programs. These resources should be provided prior to
anticipated needs.
• Policy 6.2: Provide resources for additional police services as needed to maintain average
response times.
• Policy 6.4: Continue to support, develop, and implement programs which improve the City’s
approach to fighting crime.
• Goal 7.0: Improve community safety and reduce opportunities for criminal activity.
• Policy 7.1: Provide crime prevention, community service, and education programs designed to
prevent crime.
• Policy 7.2: Promote and integrate crime-preventive characteristics and design features into all
phases of the planning and development process.
• Policy 7.3: Maximize natural surveillance through physical design features, including but not
limited to, visible entryways from surrounding structures and businesses: well-defined and
visible walkways and gates: well-lighted driveways, walkways, and exteriors: and landscaping
that preserves or enhances visibility.
• Policy 7.4: Ensure that community areas and amenities such as transit stops, sidewalks, plazas,
parks, trails, and bike paths are appropriately lighted, free of hiding places, and frequently
patrolled.
• Policy 7.5: Maximize security of public places, recreation facilities, and new development by
encouraging complementary uses that support a safe environment.
• Policy 7.6: Continue to involve the Orange Police Department in the project design and review
process.
3.14.4 - Methodology
FCS reviewed information about public service and recreation providers in the project vicinity. The
City of Orange General Plan and agency websites were reviewed for relevant information. FCS sent
letters to service providers requesting information about their ability to serve the proposed project.
The responses are provided in Appendix O.
3.14.5 - Thresholds of Significance
Public Services
According to the CEQA Guidelines’ Appendix G Environmental Checklist, to determine whether
environmental effects to public services are significant, the following questions are analyzed and
evaluated.
Would the project result in substantial adverse physical impacts associated with the
provision of new or physically altered governmental facilities, need for new or
physically altered governmental facilities, the construction of which could cause
significant environmental impacts, in order to maintain acceptable service ratios,
response times or other performance objectives for any of the public services:
a) Fire protection?
b) Police protection?
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c) Schools?
d) Parks?
e) Other public facilities?
3.14.6 - Project Impacts and Mitigation Measures
Fire Protection
Impact PS-1: The proposed project may result in a need for new or expanded fire protection
facilities.
Impact Analysis
The City of Orange Fire Department would serve the project with fire protection and emergency
medical services. The proposed project would develop up to 128 dwelling units, which would add
393 new residents to the City’s population.
The nearest fire station to the project site is Orange Fire Station No. 8, located 1.75 miles from the
project site at 5725 Carver Lane. Using an average travel speed of 25 miles per hour, it would take a
fire engine responding from Station No. 8 to the project site 4 minutes, 12 seconds. For comparison
purposes, the Fire Departments average response time was 3 minutes, 45 seconds in 2016.
The Fire Department provided written comments (Appendix O) in May 2017 indicating that the
proposed project would cause a substantial increase in calls for service relative to the existing sand
and gravel operations on the project site. The Fire Department noted that the call volume for the
project area was low, and, thus, Station No. 8 would be able to handle the increase in calls
attributable to the proposed project with its existing resources.
However, the Fire Department noted the status of Orange County Fire Authority Station No. 23,
which serves the City of Villa Park, was uncertain, and there is the possibility that Villa Park may elect
to contract with the City of Orange for fire services, which would increase the number of calls for
service from Station No. 8. At the time of this writing, Orange County Fire Authority Station No. 23 is
still open and serving Villa Park; thus, it would be speculative to engage in further discussion of this
topic.
The proposed project would take vehicular access from E. Santiago Canyon Road via a full-access
signalized driveway aligned with Nicky Way. The Fire Department noted that the project would be
required to provide two points of emergency access in accordance with Fire Code requirements.
Mitigation Measure HAZ-5 requires the applicant to demonstrate compliance with all Fire Code
emergency access requirements prior to issuance of building permits.
The eastern portion of the project site abuts Santiago Oak Regional Park and contains the wooded
Santiago Creek Corridor. The Fire Department noted that the project site is located at the
wildland/urban interface and indicated that the project would be subject to the City’s fuel
modification requirements. The project proposes to strategically place approximately 68.5 acres of
open space/grasslands and greenway with managed vegetation within the western, northern, and
eastern portions of the project site, to provide sufficient protection from wildland fires, and alleviate
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related impacts. However, Mitigation Measure HAZ-6 will be applied to require the applicant to
prepare a Fuel Modification Plan and submit it to the City of Orange for review and approval prior to
issuance of building permits, consistent with the Fire Department’s recommendation.
With the implementation of mitigation, the project would not directly create a need to construct
new or expand existing fire protection or emergency medical services facilities. Impacts would be
less than significant.
Level of Significance Before Mitigation
Potentially significant impact.
Mitigation Measures
Implement Mitigation Measures HAZ-5 and HAZ-6.
Level of Significance After Mitigation
Less than significant impact.
Law Enforcement
Impact PS-2: The proposed project would not result in a need for new or expanded police
protection facilities.
Impact Analysis
The City of Orange Police Department would provide law enforcement services to the project site.
The proposed project would develop up to 128 dwelling units, which would add 393 new residents
to the City’s population. This nominal increase in population would be expected to result in a minor
increase in calls for law enforcement services.
The project site is located approximately 4.6 miles from Police Department headquarters; however,
police officers continuously patrol the city limits 24 hours per day, 7 days per week and would likely
to be able to respond from closer distances.
The Police Department provided written comments (Appendix O) in June 2017 indicating that
construction sites can be sources of attractive nuisances, providing hazards, and inviting theft and
vandalism. The Police Department noted that the project applicant would be required to employ
construction security features, as set forth in Orange Municipal Code Chapter 15.52.110, including
fencing, lighting, and other features that would secure the project site during construction, to reduce
the likelihood of criminal activity.
The Police Department also noted that although the project could increase demand for additional
police service; payment of the Police Facility Development Fee in accordance with Orange Municipal
Code Section 3.13.020 would offset the increase attributable to the proposed project.
Lastly, the Police Department noted that the proposed project can minimize demand for police
services by incorporating Crime Prevention through Environmental Design (CPTED) concepts into the
proposed project. This involves considerations such as placement and orientation of structures;
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access and visibility of common areas; and placement of doors, windows, addressing, and
landscaping. Orange Municipal Code Chapter 15.52 requires CPTED design requirements and
Building Security Standards to be incorporated into new projects. In summary, the proposed project
would be required to comply with various Municipal Code requirements that pertain to security and
safety and, therefore, the project would not create a need to construct new or expand existing police
protection. Impacts would be less than significant.
Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
Schools
Impact PS-3: The proposed project would not result in a need for new or expanded school facilities.
Impact Analysis
The Orange Unified School District would provide K-12 education to the proposed project. The
proposed project would develop up to 128 dwelling units, which would add 393 new residents to the
City’s population. Using a standard student generation rate of 0.5 student/dwelling unit, the
proposed project would add 64 new students to the School District’s enrollment.
The school district assesses development fees to new residential projects to fund capital
improvements to school facilities. Pursuant to Government Code Section 65995 payment of adopted
development fees is the “full and complete mitigation” for impacts to school facilities and local
governments are prohibited from assessing additional fees or exactions for school impacts.
Accordingly, the applicant will pay the current fees at the time building permits are sought.
Impacts would be less than significant.
Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
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Parks
Impact PS-4: The project would not result in a need for new or expanded park facilities.
Impact Analysis
The proposed project would develop up to 128 dwelling units, which would add 393 new residents
to the City’s population. The population growth facilitated by the project would increase demand for
parks.
The proposed project would provide 68.5 acres of open space and recreation uses, including
greenways, open space, and trails. The provision of these facilities would be expected to offset the
increased demand for such facilities because project residents would be expected to use the facilities
closest to where they live.
The impacts associated with construction of these open space and recreational facilities have been
evaluated throughout this Draft EIR. The project would not result in the off-site construction of new
or expanded existing park facilities. Therefore, impacts associated with the construction or
expansion of park and recreational facilities would be less than significant.
Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
Other Public Facilities
Impact PS-5: The proposed project would not result in a need for new or expanded public
facilities such as libraries.
Impact Analysis
The proposed project would develop up to 128 dwelling units, which would add 393 new residents
to the City’s population. The population growth facilitated by the project would increase demand for
other public facilities.
The Orange Public Library & Historic Center provides library services to the City of Orange. The
closest library to the project site is the Charles P. Taft Library, located at 740 E. Taft Avenue. The
City’s General Plan does not include any standards or goals for the provision of library services.
The project’s potential increase in population is a nominal increase compared with the existing
population served by local libraries, and would not be expected to require new or substantially
altered library facilities. Thus, the project would not result in the construction of new or expanded
library branches. Therefore, impacts associated with other public facilities such as public libraries
would be less than significant.
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Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
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3.15 - Recreation
3.15.1 - Introduction
This section describes the existing public services and potential effects from project implementation
on the project site and its surrounding area. Descriptions and analysis in this section are based, in
part, on information provided by the Orange County Parks (OC Parks) website and the City of Orange
General Plan.
3.15.2 - Environmental Setting
Parks
Regional
OC Parks operates 22 regional parks and preserves throughout Orange County. The closest park to
the project site is Santiago Oaks Regional Park, which is located 0.25 mile to the east.
Santiago Oaks Regional Park
The 1,269-acre Santiago Oaks Regional Park encompasses Santiago Creek and the lower slopes of the
Santa Ana Mountains. The regional park offers trails available for hiking, biking, or horseback riding.
Local
The City of Orange owns and currently maintains 24 parks, which consist of approximately 251 acres
of parkland. The following three types of park facilities are available for recreational use by City
residents and could be subject to impact from increased demand for recreational use as the City
population increases:
• Neighborhood Parks (4 to 10 acres with a 0.5- to 1-mile radius service area) provide for the
daily recreation needs of residents in the immediate area. Olive Park, El Modena Park, and
Killefer Park are typical examples of the City’s neighborhood parks, which may include
landscaped picnic areas, tot lots, hard court areas, multipurpose ball fields, and limited
parking.
• Community Parks (15 to 40 acres with a service area radius of 1 to 2 miles) are larger in scale
and provide a greater variety of recreational opportunities and facilities. Hart Park, Grijalva
Park, and El Camino Real Park are typical examples of the City’s community parks, which host
active organized sports leagues, have lighted sports fields, may provide recreational
instruction, and have sufficient area for larger community events.
• Regional Parks are typically 200 acres or larger in size and provide a greater diversity of
recreational activities that cannot be fully met by neighborhood or community parks. For
Orange residents, the three county regional parks that serve these needs are Irvine Park,
Peters Canyon Park, and Santiago Oaks Park.
In addition to these three types of parks that provide opportunity for active recreation, the City also
maintains Special Use Facilities that provide passive uses and historic or aesthetic amenities. These
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facilities include historic community assets such as Plaza Park, Pitcher Park, and Depot Park. The
City’s community gardens and senior center also provide specialized activities.
Trails
Santiago Creek Bike Trail
The Santiago Creek Bike Trail, a paved Class I multi-use path, follows Santiago Creek from N.
Broadway to N. Cannon Street, a distance of approximately 6 miles.
Santiago Creek Trail
The unpaved Santiago Creek Trail extends along the north bank of the creek from N. Cannon Street
to Santiago Oaks Regional Park.
3.15.3 - Regulatory Framework
State
Quimby Act
The Quimby Act (Government Code Section 66477) allows local governments to require developers
to dedicate land, donate conservation easements, or pay fees to fund parkland development. The
Quimby Act has a standard of 3.5 acres of parkland per 1,000 residents.
Local
City of Orange
The City of Orange General Plan sets forth the following goals and policies that are relevant to
recreation:
Land Use Element
• Goal 1: Meet the present and future needs of all residential and business sectors with a
diverse and balanced mix of land uses.
• Policy 1.7: Provide a range of open space and park amenities to meet the diverse needs of
current and new residents.
• Goal 6.0: Advance development activity that is mutually beneficial to both the environment
and the community.
• Policy 6.3: Establish and maintain greenways, and pedestrian and bicycle connections that
complement the residential, commercial and open space areas they connect.
• Policy 6.4: Create and maintain open space resources that provide recreational opportunities,
protect hillside vistas and ridgelines, and conserve natural resources.
3.15.4 - Methodology
FCS reviewed information about recreation providers in the project vicinity. The OC Parks website
and City of Orange General Plan were reviewed for relevant information.
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3.15.5 - Thresholds of Significance
According to the CEQA Guidelines’ Appendix G Environmental Checklist, to determine whether impacts
to recreation are significant environmental effects, the following questions are analyzed and evaluated.
a) Would the project increase the use of existing neighborhood and regional parks or other
recreational facilities such that substantial physical deterioration of the facility would occur
or be accelerated?
b) Does the project include recreational facilities or require the construction or expansion of
recreational facilities, which might have an adverse physical effect on the environment?
3.15.6 - Project Impacts and Mitigation Measures
Increase Use of Parks
Impact REC-1: The project would not increase the use of existing neighborhood and regional
parks or other recreational facilities such that substantial physical deterioration of
the facility would occur or be accelerated.
Impact Analysis
The proposed project would develop up to 128 dwelling units, which would add 393 new residents
to the City’s population. The population growth facilitated by the project would increase demand for
recreational facilities.
The proposed project would provide 68.5 acres of open space and recreation uses, including active
use facilities (trail network) and passive use areas (open space and greenway). The provision of
these facilities would be expected to offset the increased demand for such facilities because project
residents would be expected to use the facilities closest to where they live.
The impacts associated with construction of this open space and recreational facilities have been
evaluated throughout this Draft EIR. The project would not result in the off-site construction of new
or expanded existing park facilities. Therefore, impacts associated with the construction or
expansion of park and recreational facilities would be less than significant.
Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
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Recreational Facilities Physical Effect on Environment
Impact REC-2: The project would not include recreational facilities or require the construction or
expansion of recreational facilities which might have an adverse physical effect on
the environment.
Impact Analysis
The proposed project would provide 68.5 acres of open space and recreation uses, including active
use facilities (trail network) and passive use areas (open space and greenway). The impacts
associated with construction of this open space and recreational facilities have been evaluated
throughout this Draft EIR. The project would not result in the off-site construction of new or
expanded existing park facilities. Therefore, impacts associated with the construction or expansion
of park and recreational facilities would be less than significant.
Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
City of Orange—Trails at Santiago Creek Specific Plan
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3.16 - Transportation and Traffic
This section describes the transportation and traffic setting and potential effects from project
implementation on the site and its surrounding area. Descriptions and analysis in this section are
based on the Traffic Impact Analysis (TIA) prepared by Linscott, Law, & Greenspan, Engineers, which
is provided in Appendix P.
3.16.1 - Existing Conditions
Roadway Network
Regional access to the site is provided via the State Route 55 (SR-55) and the SR-241 freeways. The
principal local network of streets serving the proposed project includes East Santiago Canyon Road
and Cannon Street. The following discussion provides a brief synopsis of these key area streets. The
descriptions are based on an inventory of existing roadway conditions. Exhibit 3.16-1 depicts the
street system, including study facilities. Exhibit 3.16-2 presents an inventory of the existing roadway
conditions for the arterials and intersections evaluated in this section; this exhibit identifies the
number of travel lanes for key arterials, as well as intersection configurations and controls for the key
area study intersections.
East Santiago Canyon Road
East Santiago Canyon Road is generally a four-lane divided roadway that borders the project site on
the south. Between Newport Boulevard and Jamboree Road, East Santiago Canyon Road is a six-lane
roadway. East Santiago Canyon Road will provide ingress/egress to the project site via one full
access signalized driveway, located directly opposite Nicky Way. On-street parking is generally not
permitted along this roadway within the vicinity of the project. The posted speed limit on East
Santiago Canyon Road is 55 miles per hour (mph) west of Hewes Street, 45 mph between Hewes
Street and Cannon Street and 50 mph east of Cannon Street. Traffic signals control the study
intersections of East Santiago Canyon Road at Hewes Street, Cannon Street, Orange Park Boulevard,
Meads Avenue, Newport Boulevard, and Jamboree Road.
Cannon Street
Cannon Street is a four-lane divided roadway oriented in the north-south direction. On-street
parking is generally not permitted along this roadway within the vicinity of the project. The posted
speed limit on Cannon Street is 45 mph north of East Santiago Canyon Road and 40 mph south of
East Santiago Canyon Road. Traffic signals control the study intersections of Cannon Street at
Serrano Avenue, Taft Avenue and East Santiago Canyon Road.
Study Facilities
Ten key study intersections and 17 key roadway segments selected for evaluation were determined
based on coordination with City of Orange Traffic Engineering staff and application of the “51 or
more peak-hour trip threshold” outlined in the City of Orange Traffic Impact Analysis Guidelines,
dated August 15, 2007. The intersections and roadway segments listed below provide local access to
the study area and define the extent of the boundaries for this traffic impact investigation. The
study facilities are summarized in Table 3.16-1.
City of Orange—Trails at Santiago Creek Specific Plan
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Table 3.16-1: Study Facilities Summary
ID. Facility Type Name Jurisdiction
1 Intersection Cannon Street/Serrano Avenue City of Orange
2 Intersection Cannon Street/Taft Avenue City of Orange
3 Intersection Hewes Street/Villa Park Road City of Orange
4 Intersection Cannon Street/East Santiago Canyon Road City of Orange
5 Intersection Orange Park Boulevard/East Santiago Canyon Road City of Orange
6 Intersection Meads Avenue/East Santiago Canyon Road City of Orange
7 Intersection Newport Boulevard/East Santiago Canyon Road City of Orange
8 Intersection Jamboree Road/East Santiago Canyon Road City of Orange
9 Intersection Jamboree Road/East Santiago Canyon Road—Chapman Avenue City of Orange
10 Intersection Orange Park Boulevard/Chapman Avenue City of Orange
A Roadway Segment Cannon Street north of Serrano Avenue City of Orange
B Roadway Segment Cannon Street between Serrano Avenue and Taft Avenue City of Orange
C Roadway Segment Cannon Street between Taft Avenue and East Santiago Canyon
Road
City of Orange
D Roadway Segment Cannon Street south of East Santiago Canyon Road City of Orange
E Roadway Segment Villa Park Road west of Hewes Street City of Orange
F Roadway Segment Hewes Street south of Villa Park Road City of Orange
G Roadway Segment East Santiago Canyon Road between Hewes Street and Cannon
Street
City of Orange
H Roadway Segment East Santiago Canyon Road between Nicky Way and Orange Park
Boulevard
City of Orange
I Roadway Segment East Santiago Canyon Road between Orange Park Boulevard and
Meads Avenue
City of Orange
J Roadway Segment East Santiago Canyon Road between Meads Avenue and
Newport Boulevard
City of Orange
K Roadway Segment East Santiago Canyon Road between Newport Boulevard and
Jamboree Road
City of Orange
L Roadway Segment Jamboree Road between East Santiago Canyon Road and
Chapman Avenue
City of Orange
M Roadway Segment Jamboree Road south of Chapman Avenue/East Santiago Canyon
Road
City of Orange
N Roadway Segment East Santiago Canyon Road east of Jamboree Road City of Orange
O Roadway Segment Chapman Avenue between Cannon Street and Orange Park
Boulevard
City of Orange
P Roadway Segment Chapman Avenue between Orange Park Boulevard and Newport
Boulevard
City of Orange
Q Roadway Segment Orange Park Boulevard between East Santiago Canyon Road and
Chapman Avenue
City of Orange
Source: Linscott, Law, and Greenspan, 2017.
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27650002 • 07/2018 |3.16-1_roadwaynetwork.cdr
Exhibit 3.16-1
Roadway Network
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Linscott, Law & Greenspan, Engineers 2017
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Exhibit 3.16-2
Existing Roadway Conditions and Intersection Controls
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Linscott, Law & Greenspan, Engineers 2017
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The Level of Service (LOS) investigations at these key locations were used to evaluate the potential
traffic-related impacts associated with area growth, cumulative projects and the proposed project.
When necessary, the TIA recommends intersection and/or roadway segment improvements that
may be required to accommodate future traffic volumes and restore/maintain an acceptable Level of
Service and/or mitigate the impact of the project.
Existing Traffic Volumes
Ten key study intersections and 17 key roadway segments have been identified as the locations at
which to evaluate existing and future traffic operating conditions. Some portion of potential project-
related traffic will pass through each of these intersections/roadway segments, and their analysis
will reveal the expected relative impacts of the project. These key intersections and key roadway
segments were selected for evaluation based on coordination with City of Orange Traffic Engineering
staff and application of the “51 or more peak-hour trip threshold” outlined in the City of Orange
Traffic Impact Analysis Guidelines, dated August 15, 2007.
Existing daily, AM and PM peak-hour traffic volumes for the 10 key study intersections and 17 key
roadway segments evaluated in the TIA were obtained from daily machine and manual peak-hour
turning movement counts conducted by Transportation Studies Inc. in January 2017. Exhibit 3.16-3
and Exhibit 3.16-4 illustrate the existing AM and PM peak-hour traffic volumes at the 10 key study
intersections evaluated in the TIA, respectively. Exhibit 3.16-4 also presents the existing average daily
traffic volumes for the 14 roadway segments in the vicinity of the project.
Appendix P contains the detailed peak-hour count sheets for the key intersections evaluated in the
TIA. Appendix P also contains the average daily traffic volumes for the key roadway segments.
Intersection Operations
Existing AM and PM peak-hour operating conditions for the 10 key study intersections were
evaluated using the Intersection Capacity Utilization (ICU) methodology for signalized intersections.
Intersection Capacity Utilization Method of Analysis (Signalized Intersections)
In conformance with City of Orange and County of Orange requirements, existing AM and PM peak-
hour operating conditions for the key signalized study intersections were evaluated using the ICU
method. The ICU technique is intended for signalized intersection analysis and estimates the volume
to capacity (V/C) relationship for an intersection based on the individual V/C ratios for key conflicting
traffic movements. The ICU numerical value represents the percent signal (green) time and thus
capacity, required by existing and/or future traffic. It should be noted that the ICU methodology
assumes uniform traffic distribution per intersection approach lane and optimal signal timing.
Consistent with City of Orange and County of Orange requirements, the ICU calculations use a lane
capacity of 1,700 vehicles per hour (vph) for through and all turn lanes. A clearance adjustment
factor of 0.05 was added to each Level of Service calculation. Consistent with Orange County
Congestion Management Plan requirements, the ICU calculations use a lane capacity of 1,700 vph
for left-turn, through, and right-turn lanes. A clearance adjustment factor of 0.05 was added to each
Level of Service calculation.
City of Orange—Trails at Santiago Creek Specific Plan
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The ICU value translates to a LOS estimate, which is a relative measure of the intersection
performance. The ICU value is the sum of the critical V/C ratios at an intersection; it is not intended
to be indicative of the LOS of each of the individual turning movements. The six qualitative
categories of Level of Service have been defined along with the corresponding ICU value range and
are shown in Table 3.16-2.
Table 3.16-2: Level of Service Criteria for Signalized Intersections
Level of Service
(LOS)
Intersection Capacity
Utilization Value (V/C) Level of Service Description
A < 0.60 EXCELLENT. No vehicle waits longer than one red light, and no
approach phase is fully used.
B 0.61–0.70 VERY GOOD. An occasional approach phase is fully utilized; many
drivers begin to feel somewhat restricted within groups of vehicles.
C 0.71–0.80 GOOD. Occasionally drivers may have to wait through more than
one red light; backups may develop behind turning vehicles.
D 0.81–0.90 FAIR. Delays may be substantial during portions of the rush hours,
but enough lower volume periods occur to permit clearing of
developing lines, preventing excessive backups.
E 0.91–1.00 POOR. Represents the most vehicles intersection approaches can
accommodate; may be long lines of waiting vehicles through several
signal cycles.
F > 1.00 FAILURE. Backups from nearby locations or on cross streets may
restrict or prevent movement of vehicles out of the intersection
approaches. Potentially very long delays with continuously
increasing queue lengths.
Source: Linscott, Law & Greenspan, Engineers, 2017.
Volume to Capacity Ratio Method of Analysis (Roadway Segments)
Existing daily operating conditions for the 17 key roadway segments have been investigated
according to the daily V/C ratio of each link. The daily V/C relationship is used to estimate the LOS of
the roadway segment with the volume based on 24-hour traffic count data and the capacity based
on the street classifications contained within the City of Orange General Plan Circulation and
Mobility Element. The daily roadway link capacity of each street classification according to the City
of Orange General Plan Circulation and Mobility Element is presented in Table 3.16-3, along with the
six corresponding service levels and associated V/C ratios.
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27650002 • 07/2018 |3.16-3_existingAMvols.cdr
Exhibit 3.16-3
Existing AM Peak Hour Traffic Volumes
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Linscott, Law & Greenspan, Engineers 2017
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Exhibit 3.16-4
Existing PM Peak Hour and Daily Traffic Volumes
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Linscott, Law & Greenspan, Engineers 2017
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Table 3.16-3: Roadway Link Capacities
Facility Type
Number of
Lanes
Level of Service Criteria with Associated Roadway Capacity
Daily Values (VPD)
Level of Service (LOS)
A B C D E F
Principal 8 lanes
divided
45,000 52,500 60,000 67,500 75,000 —
Major 6 lanes
divided
33,900 39,400 45,000 50,700 56,300 —
Primary 4 lanes
divided
22,500 26,300 30,000 33,750 37,500 —
Secondary 4 lanes
undivided
14,400 16,800 19,200 21,600 24,000 —
Collector 2 lanes
undivided
7,200 8,400 9,600 10,800 12,000 —
V/C Ratio ≤ 0.60 0.61–0.70 0.71–0.80 0.81–0.90 0.91–1.00 ≥ 1.00
Note:
VPD = vehicles per day
Source: Linscott, Law & Greenspan, Engineers, 2017.
Level of Service Criteria
City of Orange Locations
According to the City of Orange General Plan Circulation Element and stated in the City of Orange
Traffic Impact Analysis Guidelines, dated August 15, 2007, LOS D is the minimum acceptable
condition that should be maintained during the morning and evening peak commute hours on all
intersections and LOS D is the minimum acceptable condition that should be maintained on all
roadway segments.
County of Orange Locations
According to the County of Orange criteria, LOS D is the minimum acceptable condition that should
be maintained during the morning and evening peak commute hours on all intersections and LOS C
is the minimum acceptable condition that should be maintained on all roadway segments.
Existing Level of Service Results
Given that the project applicant voluntarily postponed operation of the permitted sand and gravel
operation in October 2015 as part of an agreement with the surrounding community, the TIA
analyzes two baseline conditions; 1) without trip credit for the permitted/entitled sand and gravel
operation; and 2) with trip credit for the permitted/entitled sand and gravel operation.
With Trip Credit Existing Traffic Conditions
As discussed with City of Orange staff, given that the site’s existing operation is currently dormant,
the trips generated by the existing entitled land use (i.e. 686 daily trips, 63 AM peak-hour trips and
32 PM peak-hour trips) have been added to the existing daily, AM peak-hour and PM peak-hour
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traffic condition resulting in a “With Trip Credit Existing” traffic condition. Exhibits 3.16-8 and 3.16-9
present the With Trip Credit Existing AM and PM peak-hour traffic volumes at the 10 key study
intersections. Exhibit 3.16-9 also presents the With Trip Credit Existing daily traffic volumes.
Intersections
Table 3.16-4 summarizes the peak-hour level of service results at the 10 key study intersections for
Existing and With Trip Credit Existing traffic conditions. Column (1) of ICU/LOS values in Table 3.16-4
presents a summary of existing AM and PM peak-hour traffic conditions. Column (2) presents With
Trip Credit Existing traffic conditions, which includes trips generated by the existing entitled land use.
Table 3.16-4: Existing and With Trip Credit Existing Peak-Hour Intersection Capacity
Analysis
Key Intersections
Time
Period
Minimum
Acceptable
LOS
(1)
Existing
Traffic Conditions
(2)
With Trip Credit
Existing
Traffic Conditions
ICU LOS ICU LOS
1. Cannon Street at Serrano Avenue
AM
D
0.847 D 0.847 D
PM 0.912 E 0.912 E
2. Cannon Street at Taft Avenue
AM
D
0.983 E 0.983 E
PM 0.869 D 0.869 D
3. Hewes Street at Villa Park Road
AM
D
0.742 C 0.748 C
PM 0.627 B 0.630 B
4. Cannon Street at East Santiago Canyon
Road
AM
D
0.749 C 0.755 C
PM 0.739 C 0.743 C
5. Orange Park Boulevard at East Santiago
Canyon Road
AM
D
0.838 D 0.841 D
PM 0.881 D 0.883 D
6. Meads Avenue at East Santiago Canyon
Road
AM
D
0.784 C 0.787 C
PM 0.768 C 0.769 C
7. Newport Boulevard at East Santiago
Canyon Road
AM
D
0.767 C 0.770 C
PM 0.832 D 0.834 D
8. Jamboree Road at East Santiago
Canyon Road
AM
D
0.641 B 0.644 B
PM 0.647 B 0.648 B
9. Jamboree Road at Chapman
Avenue/East Santiago Canyon Road
AM
D
0.533 A 0.535 A
PM 0.845 D 0.848 D
10. Orange Park Boulevard at Chapman
Avenue
AM
D
0.418 A 0.418 A
PM 0.530 A 0.530 A
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Review of Column (1) and Column (2) of Table 3.16-4 indicates that two of the 10 key study
intersections are forecast to operate at unacceptable levels of service during the AM and/or PM
peak-hours under Existing and With Trip Credit Existing traffic conditions. The remaining eight key
study intersections are forecast to operate at an acceptable service level during the AM and PM
peak-hours. The locations projected to operate at an adverse LOS under Existing and With Trip
Credit Existing traffic conditions are shown in the first two rows of Table 3.16-4.
Roadway Segments
Table 3.16-5 summarizes the roadway segment level of service results at the 17 key roadway segments
for Existing and With Trip Credit Existing traffic conditions. Column (1) shows the number of lanes,
Column (2) shows the arterial classification and Column (3) shows the existing LOS “E” capacity.
Column (4) presents a summary of existing daily traffic conditions. Column (5) lists With Trip Credit
Existing daily traffic conditions, which includes trips generated by the existing entitled land use.
Review of Column (4) and Column (5) of Table 3.16-5 indicates that one of the 17 key roadway
segments is forecast to operate at an unacceptable level of service on a daily basis under Existing
and With Trip Credit Existing traffic conditions. Roadway Segment B (Cannon Street between
Serrano Avenue and Taft Avenue) is forecast to operate at unacceptable LOS F on a daily basis under
Existing and With Trip Credit Existing traffic conditions. The remaining 16 key roadway segments are
forecast to operate at an acceptable service level on a daily basis under Existing and With Trip Credit
Existing traffic conditions.
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Transportation and Traffic FirstCarbon Solutions 3.16-16 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec03-16 Transportation.docx Table 3.16-5: Existing and With Trip Credit Existing Roadway Segment Level of Service Summary Key Roadway Segment (1) No. of Existing Lanes (2) Arterial Classification (3) Existing Capacity at LOS “E” (4) Existing Traffic Conditions (5) With Trip Credit Existing Traffic Conditions Daily Volume V/C Ratio LOS Daily Volume V/C Ratio LOS A. Cannon Street north of Serrano Avenue 4D Primary Arterial 37,500 20,171 0.538 A 20,171 0.538 A B. Cannon Street between Serrano Avenue and Taft Avenue 4D Primary Arterial 37,500 39,787 1.061 F 39,787 1.061 F C. Cannon Street between Taft Avenue and East Santiago Canyon Road 4D Primary Arterial 37,500 31,799 0.848 D 31,799 0.848 D D. Cannon Street south of East Santiago Canyon Road 4D Primary Arterial 37,500 8,940 0.238 A 8,940 0.238 A E. Villa Park Road west of Hewes Street 4D Primary Arterial 37,500 24,423 0.651 B 24,869 0.663 B F. Hewes Street south of Villa Park Road 4U Secondary Arterial 24,000 8,807 0.367 A 8,807 0.367 A G. East Santiago Canyon Road between Hewes Street and Cannon Street 4D Primary Arterial 37,500 26,118 0.696 B 26,564 0.708 C H. East Santiago Canyon Road between Nicky Way and Orange Park Boulevard 4D Primary Arterial 37,500 29,009 0.774 C 29,249 0.780 C I. East Santiago Canyon Road between Orange Park Boulevard and Meads Avenue 4D Primary Arterial 37,500 26,936 0.718 C 27,176 0.725 C J. East Santiago Canyon Road between Meads Avenue and Newport Boulevard 4D Primary Arterial 37,500 26,303 0.701 C 26,543 0.708 C
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Public Transit
Orange County Transportation Authority (OCTA) provides bus service within Orange County. The
closest OCTA bus route to the project site is Route 54, which travels between Santiago Canyon
College in Orange, and Eastgate Plaza Shopping Center in Garden Grove. The closest Route 54 stop is
on East Santiago Canyon Road in the vicinity of Santiago Canyon College, approximately 2 miles from
the project site.
Route 54 provides service 7 days a week, with service between 4:40 a.m. and 11:43 p.m. on
weekdays, 5:59 a.m. to 10:04 p.m. on Saturdays, and 6:29 a.m. and 9:24 p.m. on Sundays and
holidays.
Bicycle Circulation
Class II bike lanes (on-road bike lanes delineated by painted strips and other features) exist along the
following roadway segments within the vicinity of the project:
• East Santiago Canyon Road
• Serrano Avenue
• Taft Avenue
• Cannon Street
• Newport Avenue
• Chapman Avenue
• Jamboree Road
Additionally, Class I bike paths (off-road bike paths) exist west of Jamboree Road, extending from
Chapman Avenue to the Irvine Park, west of Hewes Street, extending from Bond Avenue to Villa Park
Road, north of Villa Park Road, extending from Hewes Street to Cannon Street, and west of Cannon
Street, extending approximately 1,000 feet north of East Santiago Canyon Road.
Pedestrian Circulation
Pedestrian circulation is provided via existing public sidewalks along East Santiago Canyon Road,
Chapman Avenue, Jamboree Road, and other key roadway segments. Portions of East Santiago
Canyon Road (i.e., between Newport Boulevard and Meads Avenue) do not provide consistent
sidewalks. Additionally, equestrian paths are provided throughout the vicinity of the project,
particularly along East Santiago Canyon Road.
3.16.2 - Regulatory Setting
Local
City of Orange
General Plan
The City of Orange General Plan sets forth the following goals and policies associated with
transportation that are relevant to the proposed project:
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Circulation Element
• Goal 1.0: Provide a safe, efficient, and comprehensive circulation system that serves local
needs, meets forecasted demands, and sustains quality of life in neighborhoods.
• Policy 1.1: Plan, build, and maintain an integrated, hierarchical, and multi-modal system of
roadways, pedestrian walkways, and bicycle paths throughout the City.
• Policy 1.7: Consolidate driveways along roadways that provide access to commercial uses to
minimize side street interruption and promote smooth traffic flows.
• Goal 4.0: Provide efficient and accessible modes of pedestrian, bicycle, and equestrian
transportation and improved facilities and amenities.
• Policy 4.1: Create a comprehensive bicycle network that is integrated with other
transportation systems by establishing complementary on-street and off-street facilities as
identified in the City of Orange Bikeways Master Plan and OCTA Commuter Bikeways Strategic
Plan, including Santiago Creek, the Santa Ana River, and the Tustin Branch Trail.
Growth Management Element
• Goal 1.0: Reduce traffic congestion within the City.
• Policy 1.1: Establish LOS D as the level of service standard for traffic circulation within the City
for both roadway segments and peak-hour signalized intersection movements.
• Policy 1.2: Ensure completion of transportation improvements as agreed upon by the City and
developer prior to completion of a development project.
• Policy 1.3: Ensure that new development pays its fair share of street improvement costs,
including regional traffic mitigation. New revenues generated from Measure M, if available,
shall not be used to replace private developer funding which has been omitted for any project.
• Policy 1.4: Continue to collect transportation impact fees for improvements within the City
boundaries and work with adjacent jurisdictions to determine that an appropriate level of
transportation impact fees are maintained within the established County Growth
Management Areas.
• Policy 1.9: Ensure that new developments incorporate non-motorized and alternative transit
amenities such as bike racks, bus benches and shelters, and pedestrian connections.
Performance Standards
The City of Orange sets forth the following performance standards for intersections and roadway
segments. A project may have a significant impact if any of the following occur:
Intersections
• An unacceptable peak-hour LOS at any of the key intersections is projected. According to the
City’s Circulation Element and stated in the City of Orange Traffic Impact Analysis Guidelines,
dated August 15, 2007, LOS D is the minimum acceptable condition that should be maintained
during the morning and evening peak commute hours on all intersections; and
• The project increases traffic demand at the study intersection by 1 percent of capacity (ICU
increase ≥ 0.010), causing or worsening LOS E or LOS F (ICU > 0.900).
Roadway Segments
• An unacceptable daily LOS at any of the key roadway segments is projected. According to the
City of Orange General Plan Circulation Element and stated in the City of Orange Traffic Impact
City of Orange—Trails at Santiago Creek Specific Plan
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Analysis Guidelines, dated August 15, 2007, LOS D is the minimum acceptable condition that
should be maintained on all roadway segments; and
• The project increases traffic demand at the roadway segment by 1 percent of capacity (V/C
increase ≥ 0.010), causing or worsening LOS E or LOS F (V/C > 0.900).
County of Orange
Performance Standards
The County of Orange sets forth the following performance standards for intersections and roadway
segments. A project may have a significant impact if any of the following occur:
Intersections
• The County of Orange along with City of Orange considers LOS D to be the minimum
acceptable condition that should be maintained during the AM and PM peak-hours for all
intersections. For the TIA, impacts to local and regional transportation systems shall be
considered significant if the project increases traffic demand at a key study intersection by 1.0
percent of capacity (ICU increase ≥ 0.01), causing or worsening LOS E or F (ICU > 0.90). This
criterion is based on the “1 percent measurable impact criteria” contained in the County of
Orange Transportation Implementation Manual (TIM) guidelines.
Roadway Segments:
• An unacceptable daily LOS at any of the key roadway segments is projected. According to the
Guidance for Administration of the Orange County Master Plan of Arterial Highways, dated
October 22, 2012, LOS C is the minimum acceptable condition that should be maintained on
all roadway segments; and
• The project increases traffic demand at the roadway segment by 1 percent of capacity (V/C
increase ≥ 0.010), causing or worsening LOS D, LOS E or LOS F (V/C > 0.800).
3.16.3 - Methodology
Linscott, Law, & Greenspan, Engineers prepared a TIA. The methodology of the analysis is described
as follows. The report is provided in Appendix P.
Traffic Forecasting Methodology
In order to estimate the traffic impact characteristics of the proposed project, a multi-step process
has been utilized. The first step is trip generation, which estimates the total arriving and departing
traffic on a peak-hour and daily basis. The traffic generation potential is forecast by applying the
appropriate vehicle trip generation equations or rates to the project development tabulation.
The second step of the forecasting process is trip distribution, which identifies the origins and
destinations of inbound and outbound project traffic. These origins and destinations are typically
based on demographics and existing/anticipated travel patterns in the study area.
The third step is traffic assignment, which involves the allocation of project traffic to study area
streets and intersections. Traffic assignment is typically based on minimization of travel time, which
may or may not involve the shortest route, depending on prevailing operating conditions and travel
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speeds. Traffic distribution patterns are indicated by general percentage orientation, while traffic
assignment allocates specific volume forecasts to individual roadway links and intersection turning
movements throughout the study area.
With the forecasting process complete and project traffic assignments developed, the impact of the
proposed project is isolated by comparing operational LOS conditions at selected key intersections
using expected future traffic volumes with and without forecast project traffic. The need for site-
specific and/or cumulative local area traffic improvements can then be evaluated and the
significance of the project’s impacts identified.
Project Traffic Generation
Traffic generation is expressed in vehicle trip ends, defined as one-way vehicular movements, either
entering or exiting the generating land use. Generation equations and/or rates used in the traffic
forecasting procedure are found in the 9th Edition of Trip Generation, published by the Institute of
Transportation Engineers (ITE) [Washington D.C., 2012].
Given that the project Applicant voluntarily postponed operation of the permitted sand and gravel
operation in October 2015 as part of an agreement with the surrounding community, the TIA
analyzes two baseline conditions; 1) without trip credit for the permitted/entitled sand and gravel
operation; and 2) with trip credit for the permitted/entitled sand and gravel operation.
Table 3.16-6 summarizes the trip generation rates used in forecasting the vehicular trips generated
by the proposed project and also presents the project’s forecast peak-hour and daily traffic volumes
“Without Sand and Gravel Credit.” As shown in the upper portion of Table 3.16-6, the trip
generation potential of the proposed project was estimated using trip rates for ITE Land Use Code
210: Single-Family Detached Housing.
Review of Table 3.16-6 shows that the proposed project is forecast to generate 1,219 daily trips, with
97 trips (24 inbound, 73 outbound) produced in the AM peak-hour and 128 trips (81 inbound, 48
outbound) produced in the PM peak-hour on a “typical” weekday. The potential traffic impacts of
the aforementioned net project trips are evaluated in the “Without Sand and Gravel Credit” traffic
impact analysis section of the TIA. It should be noted that the trip generation methodology and
forecasts were approved by City of Orange staff prior to proceeding with further analysis.
Table 3.16-7 summarizes the trip generation rates used in forecasting the vehicular trips generated
by the proposed project and the existing entitled land use (i.e. the Existing Materials Recycling and
Backfilling Operation) and also presents the project’s forecast peak-hour and daily traffic volumes
“With Sand and Gravel Credit.” As shown in the upper portion of Table 3.16-7, the trip generation
potential of the proposed project was estimated using trip rates for ITE Land Use Code 210: Single-
Family Detached Housing. The trip generation potential of the existing/entitled land use is based on
traffic counts conducted during normal operation in October/November 2010 and adjusted to
account for the entitled 7:00 a.m. to 7:00 p.m. operation.
City of Orange—Trails at Santiago Creek Specific Plan
Recirculated Draft EIR Transportation and Traffic
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Review of the middle portion of Table 3.16-7 shows that the proposed project is forecast to generate
1,219 daily trips, with 97 trips (24 inbound, 73 outbound) produced in the AM peak-hour and 128
trips (81 inbound, 48 outbound) produced in the PM peak-hour on a “typical” weekday.
For the existing entitled land use, a review of the lower portion of Table 3.16-7 shows that the
existing trip generation potential of the Existing Materials Recycling and Backfilling Operation based
on existing counts totals 686 daily trips, with 63 trips (34 inbound, 29 outbound) produced in the AM
peak-hour and 32 trips (15 inbound, 17 outbound) produced in the PM peak-hour. It should be
noted that the Daily and PM peak-hour trips include additional traffic generation based on an
extrapolation of the existing site traffic count data to 7:00 p.m.
Review of the last row of Table 3.16-7 shows that with application of existing trip credits, the
proposed project is forecast to generate a net of 542 daily trips, a net of 34 AM peak-hour trips (-10
inbound, 44 outbound) and a net of 97 PM peak-hour trips (66 inbound, 31 outbound). The
potential traffic impacts of the aforementioned net project trips are evaluated in the “With Sand and
Gravel Credit” traffic impact analysis section of Appendix P. It should be noted that the trip
generation methodology and forecasts were approved by City of Orange staff prior to proceeding
with further analysis.
It should be noted that considering the significant amount of truck traffic associated with the entitled
use on the site, the net project traffic generation forecast for the project could include the application
of passenger car equivalents (PCE’s) for the trucks that utilized the site as part of the entitled Materials
Recycling and Backfilling Operation that has been operating on the site. The volume and type (axles) of
trucks was derived from the traffic counts conducted in 2011 when the site operation was at its peak.
As such, the net project traffic generation forecast, based on PCE factors, results in -251 net daily trips,
with -33 net AM peak-hour trips (-44 inbound, 11 outbound) and 62 net PM peak-hour trips (50
inbound, 12 outbound). Compared with the net traffic generation forecast presented in Table 3.16-6,
the net project traffic generation has 784 fewer daily trips, 66 fewer AM peak-hour trips, and 34 fewer
PM peak-hour trips with the application of the PCE factors.
Table 3.16-6: Project Traffic Generation Forecast (Without Sand and Gravel Credit)
ITE Land Use Code/Project Description
Daily
Two-Way
AM Peak Hour PM Peak Hour
Enter Exit Total Enter Exit Total
Generation Factors
210: Single-Family Detached Housing (TE/DU) 9.52 25
percent
75
percent
0.75 63
percent
37
percent
1.00
Proposed Project Generation Forecast
Rio Santiago Residential (128 DU) 1,219 24 72 96 81 47 128
Note:
1 Based on traffic counts conducted during normal operation in October/November 2010 and adjusted to account for a
7:00 a.m. to 7:00 p.m. operation. These entitled trips will be added to the existing traffic.
Source: Linscott, Law & Greenspan, Engineers, 2017.
City of Orange—Trails at Santiago Creek Specific Plan
Transportation and Traffic Recirculated Draft EIR
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Table 3.16-7: Project Traffic Generation Forecast (With Sand and Gravel Credit)
ITE Land Use Code/Project Description
Daily
Two-Way
AM Peak Hour PM Peak Hour
Enter Exit Total Enter Exit Total
Generation Factors
210: Single-Family Detached Housing (TE/DU) 9.52 25
percent
75
percent
0.75 63
percent
37
percent
1.00
Proposed Project Generation Forecast
Rio Santiago Residential (128 DU) 1,219 24 72 96 81 47 128
Existing Entitled Land Use
Existing Materials Recycling and Backfilling
Operation1
686 34 29 63 15 17 32
Total Net Traffic Generation Forecast 542 -10 43 33 66 30 96
Note:
1 Based on traffic counts conducted during normal operation in October/November 2010 and adjusted to account for a
7:00 a.m. to 7:00 p.m. operation. These entitled trips will be added to the existing traffic.
Source: Linscott, Law & Greenspan, Engineers, 2017.
Project Traffic Distribution and Assignment
Exhibit 3.16-5 illustrates the general, directional traffic distribution pattern for the proposed project.
Project traffic volumes both entering and exiting the project site have been distributed and assigned
to the adjacent street system based on the following considerations:
• Directional flows on the freeways in the immediate vicinity of the project site (i.e., SR-55 and
SR-241 freeways),
• The site’s proximity to major traffic carriers (i.e., East Santiago Canyon Road),
• Expected localized traffic flow patterns based on adjacent street channelization and presence
of traffic signals,
• Ingress/egress availability at the project site, and
• Trip distribution information contained within the Rio Santiago TIA, prepared by Vista
Environmental, dated January 2013.
The anticipated AM and PM peak-hour project traffic volumes associated with the project “Without
Sand and Gravel Credit” are presented in Exhibits 3.16-6A and 3.16-6B, respectively. Exhibit 3.16-6B
also presents the daily project traffic volumes. The traffic volume assignments presented in Exhibits
3.16-6A and 3.16-6B reflect the traffic distribution characteristics shown in Exhibit 3.16-5 and the
traffic generation forecast presented in Table 3.16-6.
The anticipated AM and PM peak-hour project traffic volumes associated with the project “With
Sand and Gravel Credit” are presented in Exhibits 3.16-7A and 3.16-7B, respectively. Exhibit 3.16-7B
City of Orange—Trails at Santiago Creek Specific Plan
Recirculated Draft EIR Transportation and Traffic
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also presents the daily project traffic volumes. The traffic volume assignments presented in Exhibits
3.16-7A and 3.16-7B reflect the traffic distribution characteristics shown in Exhibit 3.16-5 and the
traffic generation forecast presented in Table 3.16-7.
With Trip Credit Existing Traffic Conditions
As discussed with City of Orange staff, given that operations at the site are currently limited and
unpredictable, the trips generated by the existing entitled land use (i.e., 686 daily trips, 63 AM peak-
hour trips and 32 PM peak-hour trips) have been added to the existing daily, AM peak-hour and PM
peak-hour traffic condition resulting in a “With Trip Credit Existing” traffic condition. Exhibit 3.16-8 and
Exhibit 3.16-9 present the With Trip Credit Existing AM and PM peak-hour traffic volumes at the 10 key
study intersections. Exhibit 3.16-9 also presents the With Trip Credit Existing daily traffic volumes.
Existing With Project Traffic Conditions (Without Sand and Gravel Credit)
The Existing With project “Without Sand and Gravel Credit” traffic conditions have been generated
based upon existing conditions and the estimated project traffic. These forecast traffic conditions have
been prepared pursuant to the California Environmental Quality Act (CEQA) guidelines, which require
that the potential impacts of a project be evaluated upon the circulation system as it currently exists.
This traffic volume scenario and the related intersection capacity analyses will identify the roadway
improvements necessary to mitigate the direct traffic impacts of the project, if any.
Exhibits 3.16-10A and 3.16-11A present projected AM and PM peak-hour traffic volumes at the 10
key study intersections and project driveway with the addition of the trips generated by the project
“Without Sand and Gravel Credit” to existing traffic volumes respectively. Exhibit 3.16-11A also
presents the existing with project daily traffic volumes.
Existing With Project Traffic Conditions (With Sand and Gravel Credit)
The Existing With Project “With Sand and Gravel Credit” traffic conditions have been generated based
upon existing conditions and the estimated project traffic. These forecast traffic conditions have been
prepared pursuant to the CEQA guidelines, which require that the potential impacts of a project be
evaluated upon the circulation system as it currently exists. This traffic volume scenario and the
related intersection capacity analyses will identify the roadway improvements necessary to mitigate
the direct traffic impacts of the project, if any.
Exhibits 3.16-10B and 3.16-11B present projected AM and PM peak-hour traffic volumes at the 10
key study intersections and project driveway with the addition of the trips generated by the project
“With Sand and Gravel Credit” to existing traffic volumes (i.e. With Trip Credit existing traffic
volumes), respectively. Exhibit 3.16-11B also presents the existing with project daily traffic volumes.
Future Traffic Conditions
Year 2022 Without Project Traffic Conditions
Ambient Growth Traffic
Horizon year, background traffic growth estimates have been calculated using an ambient traffic
growth factor. The ambient traffic growth factor is intended to include unknown and future
cumulative projects in the study area, as well as account for regular growth in traffic volumes due to
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the development of projects outside the study area. The future growth in traffic volumes has been
calculated at 1 percent per year. Applied to the Year 2017 existing traffic volumes, this factor results
in a 5 percent growth in existing volumes to the near-term horizon Year 2022. It should be noted
that the five percent growth was applied to the With Trip Credit Existing traffic volumes shown
previously in Exhibit 3.16-8 and Exhibit 3.16-9.
Cumulative Projects Traffic
In order to make a realistic estimate of future on-street conditions prior to implementation of the
proposed project, the status of other known development projects (cumulative projects) in the
vicinity of the proposed project has been researched at the City of Orange. With this information,
the potential impact of the proposed project can be evaluated within the context of the cumulative
impact of all ongoing development. Based on our research, there are four cumulative projects in the
City of Orange within the vicinity of the subject site that have either been built but not yet fully
occupied, or are being processed for approval. These four cumulative projects have been included
as part of the cumulative background setting.
Table 3.16-8 provides a brief description and location for each of the four cumulative projects.
Exhibit 3.16-12 graphically illustrates the location of the four cumulative projects. These cumulative
projects are expected to generate vehicular traffic, which may affect the operating conditions of the
key study intersections and key roadway segments.
Table 3.16-9 presents the development totals and resultant trip generation for the four cumulative
projects. As shown in Table 3.16-9, the cumulative projects are forecast to generate a total of 11,969
daily trips, with 960 trips (282 inbound and 678 outbound) forecast during the AM peak-hour and
1,192 trips (832 inbound and 360 outbound) forecast during the PM peak-hour.
The AM and PM peak-hour traffic volumes associated with the four cumulative projects are
presented in Exhibit 3.16-13 and Exhibit 3.16-14, respectively. Exhibit 3.16-14 also presents the daily
cumulative project traffic volumes.
Table 3.16-8: Location and Description of Cumulative Projects
No. Cumulative Project Location/Address Description
City of Orange Development
1 Salem Lutheran Church
Expansion
Southwest corner of Orange Park Boulevard
and East Santiago Canyon Road
7.388 TSF church expansion
2 Arena Site Single-
Family Homes
Southeast corner of East Santiago Canyon
Road and Nicky Way
7 single-family homes
3 Santiago Hills II North and south sides of East Santiago Canyon
Road, west of SR-241
1,066 single-family homes
114 condominiums
9.4-acre park
4 Olson Project South of Washington Avenue and Hamlin Street 37 townhomes
Source: Linscott, Law & Greenspan, Engineers, 2017.
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Exhibit 3.16-5
Project Trip Distribution Pattern
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Linscott, Law & Greenspan, Engineers 2017
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Exhibit 3.16-6A
AM Peak Hour Project Traffic Volumes (Without Sand & Gravel Credit)
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Linscott, Law & Greenspan, Engineers, August 2018
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Exhibit 3.16-6B
AM Peak Hour Project Traffic Volumes (With Sand & Gravel Credit)
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Linscott, Law & Greenspan, Engineers, August 2018
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Exhibit 3.16-7A
PM Peak Hour Project Traffic Volumes (Without Sand & Gravel Credit)
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Linscott, Law & Greenspan, Engineers, August 2018
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Exhibit 3.16-7B
PM Peak Hour Project Traffic Volumes (With Sand & Gravel Credit)
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Linscott, Law & Greenspan, Engineers, August 2018
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Exhibit 3.16-8
With Trip Credit Existing AM Peak Hour Traffic Volumes
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Linscott, Law & Greenspan, Engineers, September 2018.
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Exhibit 3.16-9
With Trip Credit Existing PM Peak Hour and Daily Traffic Volumes
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Linscott, Law & Greenspan, Engineers, September 2018.
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Exhibit 3.16-10A
Existing With Project AM Peak Hour Traffic Volume (Without Sand & Gravel Credit)
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Linscott, Law & Greenspan, Engineers, August 2018
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Exhibit 3.16-10B
Existing With Project AM Peak Hour Traffic Volume (With Sand & Gravel Credit)
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Linscott, Law & Greenspan, Engineers, August 2018
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Exhibit 3.16-11A
Existing With Project PM Peak Hour and Daily Traffic Volume
(Without Sand & Gravel Credit)
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Linscott, Law & Greenspan, Engineers, August 2018
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Exhibit 3.16-11B
Existing With Project PM Peak Hour and Daily Traffic Volume
(With Sand & Gravel Credit)
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Linscott, Law & Greenspan, Engineers, August 2018
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Exhibit 3.16-12
Cumulative Project Location Map
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Linscott, Law & Greenspan, Engineers 2017
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Exhibit 3.16-13
AM Peak Hour Cumulative Projects Traffic Volumes
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Linscott, Law & Greenspan, Engineers 2017
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Exhibit 3.16-14
PM Peak Hour and Daily Cumulative Projects Traffic Volumes
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Linscott, Law & Greenspan, Engineers 2017
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City of Orange—Trails at Santiago Creek Specific Plan
Recirculated Draft EIR Transportation and Traffic
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Table 3.16-9: Cumulative Projects Traffic Generation Forecast
Cumulative Project Description
Daily
2-Way
AM Peak Hour PM Peak Hour
Enter Exit Total Enter Exit Total
1 Salem Lutheran Church Expansion 67 3 2 5 3 2 5
2 Arena Site Single-Family Homes 67 1 4 5 4 3 7
3 Santiago Hills II 11,620 275 659 934 812 349 1,161
4 Olson Project 215 3 13 16 13 6 19
Cumulative Projects
Total Trip Generation Potential
11,969 282 678 960 832 360 1,192
Source: Linscott, Law & Greenspan, Engineers, 2017.
Year 2022 Traffic Volumes
Exhibits 3.16-15A and 3.16-16A present the AM and PM peak-hour cumulative traffic volumes
“Without Sand and Gravel Credit” (existing traffic + ambient growth traffic + cumulative project
traffic) at the 10 key study intersections for the Year 2022, respectively. Exhibit 3.16-16A also
presents the Year 2022 daily cumulative traffic volumes “Without Sand and Gravel Credit” for the key
roadway segments.
Exhibits 3-16-15B and 3.16-16B present the AM and PM peak-hour cumulative traffic volumes “With
Sand and Gravel Credit” (existing traffic + ambient growth traffic + cumulative project traffic) at the
10 key study intersections for the Year 2022, respectively. Exhibit 3.16-16B also presents the Year
2022 daily cumulative traffic volumes “With Sand and Gravel Credit” for the key roadway segments.
Exhibits 3.16-17A and 3.16-18A illustrate the Year 2022 forecast AM and PM peak-hour traffic
volumes, with the inclusion of the trips generated by the proposed project “Without Sand and
Gravel Credit,” respectively. Exhibit 3.16-18A also presents the Year 2022 With project “Without
Sand and Gravel Credit” traffic volumes for the key roadway segments.
Exhibits 3.16-17B and 3.16-18B illustrate the Year 2022 forecast AM and PM peak-hour traffic
volumes, with the inclusion of the trips generated by the proposed project “With Sand and Gravel
Credit,” respectively. Exhibit 3.16-18B also presents the Year 2022 With Project “With Sand and
Gravel Credit” traffic volumes for the key roadway segments.
Year 2040 Buildout Traffic Volumes
As directed by City of Orange staff, Year 2035 buildout traffic volumes for the 10 key study
intersections and 17 key roadway segments were obtained from the Santiago Hills II Traffic Study,
prepared by Stantec Consulting Services Inc., dated May 6, 2016. Specifically, the “Year 2035 With
Proposed SHIIPC and No EOPC Development” Orange Transportation Analysis Model (OTAM) runs
from the Santiago Hills II Traffic Study were utilized, which includes elimination of the Jamboree
Road Extension. The Santiago Hills II Traffic Study provided Year 2035 daily, AM peak-hour and PM
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peak-hour background traffic volume data for all key study locations, except for the following
locations:
1) Cannon Street at Serrano Avenue
2) Cannon Street at Taft Avenue
5) Orange Park Boulevard at East Santiago Canyon Road
6) Meads Avenue at East Santiago Canyon Road
A) Nicky Way at East Santiago Canyon Road
In order to develop Year 2035 traffic volume forecasts for the aforementioned locations, AM peak-
hour and PM peak-hour growth factors were derived by comparing the overall growth between
existing traffic volumes and Year 2035 traffic volumes at common locations (i.e., Cannon Street at
East Santiago Canyon Road) from the Santiago Hills II Traffic Study. The traffic volume comparisons
resulted in a 1.8 percent per year AM peak-hour growth factor and a 2.2 percent per year PM peak-
hour growth factor. These growth factors were applied to the With Trip Credit existing traffic
volumes for the aforementioned locations to develop Year 2035 AM peak-hour and PM peak-hour
background traffic volumes. It should be noted that adjustments were applied as warranted to
ensure that through traffic along East Santiago Canyon Road and Cannon Street reasonably tracked
between each key study intersection.
After developing all Year 2035 daily, AM peak-hour and PM peak-hour background traffic volumes
for the 10 key study intersections and 17 key roadway segments, a 1 percent per year growth factor
was applied, as directed by City of Orange staff to develop Year 2040 daily, AM peak-hour, and PM
peak-hour background traffic volumes.
Exhibits 3.16-19 and 3.16-20 present the AM and PM peak-hour Year 2040 buildout without project
traffic volumes at the 10 key study intersections, respectively. Exhibit 3.16-20 also presents the Year
2040 daily buildout without project traffic volumes for the key roadway segments.
Exhibits 3.16-19A and 3.16-20A illustrate the Year 2040 forecast AM and PM peak-hour traffic
volumes, with the inclusion of the trips generated by the proposed project “Without Sand and
Gravel Credit,” respectively. Exhibit 3.16-20A also presents the Year 2040 daily with project
“Without Sand and Gravel Credit” traffic volumes for the key roadway segments.
Exhibits 3.16-19B and 3.16-20B illustrate the Year 2040 forecast AM and PM peak-hour traffic
volumes, with the inclusion of the trips generated by the proposed project “With Sand and Gravel
Credit,” respectively. Exhibit 3.16-20B also presents the Year 2040 daily with project “With Sand and
Gravel Credit” traffic volumes for the key roadway segments.
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Exhibit 3.16-15A
Year 2022 Without Project AM Peak Hour
Traffic Volumes (Without Sand & Gravel Credit)
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Linscott, Law & Greenspan, Engineers, August 2018
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Exhibit 3.16-15B
Year 2022 Without Project AM Peak Hour
Traffic Volumes (With Sand & Gravel Credit)
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Linscott, Law & Greenspan, Engineers, August 2018
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27650002 • 08/2018 |3.16-16A_2022_PMpeak_vols_wo_sand_gravel.cdr
Exhibit 3.16-16A
Year 2022 Without Project PM Peak Hour and Daily
Traffic Volumes (Without Sand & Gravel Credit)
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Linscott, Law & Greenspan, Engineers, August 2018
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27650002 • 08/2018 |3.16-16B_2022_PMpeak_vols_w_sand_gravel.cdr
Exhibit 3.16-16B
Year 2022 Without Project PM Peak Hour and Daily
Traffic Volumes (With Sand & Gravel Credit)
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Linscott, Law & Greenspan, Engineers, August 2018
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27650002 • 08/2018 |3.16-17A_2022_wAMpeak_vols_wo_sand_gravel.cdr
Exhibit 3.16-17A
Year 2022 With Project AM Peak Hour
Traffic Volumes (Without Sand & Gravel Credit)
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Linscott, Law & Greenspan, Engineers, August 2018
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27650002 • 08/2018 |3.16-17B_2022_wAMpeak_vols_w_sand_gravel.cdr
Exhibit 3.16-17B
Year 2022 With Project AM Peak Hour
Traffic Volumes (With Sand & Gravel Credit)
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Linscott, Law & Greenspan, Engineers, August 2018
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27650002 • 08/2018 |3.16-18A_2022_wPMpeak_vols_wo_sand_gravel.cdr
Exhibit 3.16-18A
Year 2022 With Project PM Peak Hour and Daily
Traffic Volumes (Without Sand & Gravel Credit)
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Linscott, Law & Greenspan, Engineers, August 2018
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27650002 • 08/2018 |3.16-18B_2022_wPMpeak_vols_w_sand_gravel.cdr
Exhibit 3.16-18B
Year 2022 With Project PM Peak Hour and Daily
Traffic Volumes (With Sand & Gravel Credit)
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Linscott, Law & Greenspan, Engineers, August 2018
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27650002 • 08/2018 |3.16-19A_2040_woAMpeak_vols_wo_sand_gravel.cdr
Exhibit 3.16-19A
Year 2040 Buildout With Project AM Peak Hour
Traffic Volumes (Without Sand & Gravel Credit)
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Linscott, Law & Greenspan, Engineers, August 2018
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27650002 • 08/2018 |3.16-19B_2040_woAMpeak_vols_w_sand_gravel.cdr
Exhibit 3.16-19B
Year 2040 Buildout With Project AM Peak Hour
Traffic Volumes (With Sand & Gravel Credit)
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Linscott, Law & Greenspan, Engineers, August 2018
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27650002 • 08/2018 |3.16-20A_2040_woPMpeak_vols_wo_sand_gravel.cdr
Exhibit 3.16-20A
Year 2040 Buildout With Project PM Peak Hour and Daily
Traffic Volumes (Without Sand & Gravel Credit)
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Linscott, Law & Greenspan, Engineers, August 2018
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27650002 • 08/2018 |3.16-20B_2040_w_PMpeak_vols_w_sand_gravel.cdr
Exhibit 3.16-20B
Year 2040 Buildout With Project PM Peak Hour and Daily
Traffic Volumes (With Sand & Gravel Credit)
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Linscott, Law & Greenspan, Engineers, August 2018
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City of Orange—Trails at Santiago Creek Specific Plan
Recirculated Draft EIR Transportation and Traffic
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3.16.4 - Thresholds of Significance
According to the CEQA Guidelines’ Appendix G Environmental Checklist, to determine whether
transportation and traffic impacts are significant environmental effects, the following questions are
analyzed and evaluated. Would the project:
a) Conflict with an applicable plan, ordinance or policy establishing measures of effectiveness
for the performance of the circulation system, taking into account all modes of
transportation including mass transit and non-motorized travel and relevant components of
the circulation system, including but not limited to intersections, streets, highways and
freeways, pedestrian and bicycle paths, and mass transit?
b) Conflict with an applicable congestion management program, including, but not limited to
level of service standards and travel demand measures, or other standards established by
the county congestion management agency for designated roads or highways?
c) Result in a change in air traffic patterns, including either an increase in traffic levels or a
change in location that results in substantial safety risks?
d) Substantially increase hazards due to a design feature (e.g., sharp curves or dangerous
intersections) or incompatible uses (e.g., farm equipment)?
e) Result in inadequate emergency access?
f) Conflict with adopted policies, plans, or programs regarding public transit, bicycle, or
pedestrian facilities, or otherwise decrease the performance or safety of such facilities?
3.16.5 - Project Impacts and Mitigation Measures
This section discusses potential impacts associated with the proposed project and provides
mitigation measures where necessary.
Existing With Project Traffic
Impact TRANS-1: The project may conflict with an applicable plan, ordinance or policy establishing
measures of effectiveness for the performance of the circulation system under
Existing With Project Traffic Conditions.
Impact Analysis
This impact evaluates Existing With Project traffic conditions.
Intersections
With Trip Credit Existing Traffic Conditions
Table 3.16-10 summarizes the peak-hour level of service results at the 10 key study intersections for
With Trip Credit Existing traffic conditions. Column (1) of ICU/LOS values in Table 3.16-10 presents a
summary of existing AM and PM peak-hour traffic conditions. Column (2) presents With Trip Credit
Existing traffic conditions, which includes trips generated by the existing entitled land use.
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Transportation and Traffic Recirculated Draft EIR
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Table 3.16-10 indicates that two of the 10 key study intersections are forecast to operate at
unacceptable levels of service during the AM and/or PM peak-hours under With Trip Credit Existing
traffic conditions. The remaining eight key study intersections are forecast to operate at an
acceptable service level during the AM and PM peak-hours.
Table 3.16-10: With Trip Credit Existing Peak-Hour Intersection Capacity Analysis
Key Intersections
Time
Period
Minimum
Acceptable
LOS
(1)
Existing Traffic
Conditions
(2)
With Trip Credit
Existing Traffic
Conditions
ICU LOS ICU LOS
1 Cannon Street at Serrano Avenue AM
PM
D 0.847
0.912
D
E
0.847
0.912
D
E
2 Cannon Street at Taft Avenue AM
PM
D 0.983
0.869
E
D
0.983
0.869
E
D
3 Hewes Street at Villa Park Road AM
PM
D 0.742
0.627
C
B
0.748
0.630
C
B
4 Cannon Street at East Santiago
Canyon Road
AM
PM
D 0.749
0.739
C
C
0.755
0.743
C
C
5 Orange Park Blvd at East Santiago
Canyon Road
AM
PM
D 0.838
0.881
D
D
0.841
0.883
D
D
6 Meads Avenue at East Santiago
Canyon Road
AM
PM
D 0.784
0.768
C
C
0.787
0.769
C
C
7 Newport Blvd at East Santiago
Canyon Road
AM
PM
D 0.767
0.832
C
D
0.770
0.834
C
D
8 Jamboree Road at East Santiago
Canyon Road
AM
PM
D 0.641
0.647
B
B
0.644
0.648
B
B
9
Jamboree Road at Chapman
Avenue/East Santiago Canyon
Road
AM
PM
D 0.533
0.845
A
D
0.535
0.848
A
D
10 Orange Park Boulevard/Chapman
Avenue
AM
PM
D 0.418
0.530
A
A
0.418
0.530
A
A
Note:
A significant impact would occur if the project causes ICU to increase by 0.010 or more.
Source: Linscott, Law & Greenspan, Engineers, 2017.
Existing With Project Traffic Conditions
Existing With Project Traffic Conditions (Without Sand and Gravel Credit)
Table 3.16-11 summarizes the peak-hour level of service results at the 10 key study intersections and
the proposed project driveway for Existing With project “Without Sand and Gravel Credit” traffic
conditions. Column (1) of ICU/LOS values in Table 3.16-11 presents a summary of With Trip Credit
Existing AM and PM peak-hour traffic conditions. Column (2) lists Existing With Project “Without
Sand and Gravel Credit” traffic conditions. Column (3) shows the increase in ICU value due to the
added peak-hour project trips and indicates whether the traffic associated with the project “Without
City of Orange—Trails at Santiago Creek Specific Plan
Recirculated Draft EIR Transportation and Traffic
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Sand and Gravel Credit” will have a significant impact based on the LOS standards and significant
impact criteria defined in the TIA.
Review of Columns (2) and (3) of Table 3.16-11 indicates that traffic associated with the proposed
project “Without Sand and Gravel Credit” will not significantly impact any of the 10 key study
intersections when compared to the LOS standards and significant impact criteria specified in the
TIA. Although the intersections of Cannon Street/Serrano Avenue and Cannon Street/Taft Avenue
are forecast to operate at unacceptable LOS E during the AM and/or PM peak-hours with the
addition of project traffic, the proposed project “Without Sand and Gravel Credit” is expected to add
less than 0.010 to the ICU value. The remaining eight key study intersections and the proposed
project driveway are forecast to operate at acceptable levels of service during the AM and PM peak-
hours with the addition of project-generated traffic to existing traffic “Without Sand and Gravel
Credit.”
Appendix C and D of the Traffic Impact Analysis (Appendix P) presents the Existing With Project
ICU/LOS calculations for the 10 key study intersections and the proposed project driveway for the
AM peak-hour and PM peak-hour “Without Sand and Gravel Credit.”
With Trip Credit Existing With Project Traffic Conditions (With Sand and Gravel Credit)
Table 3.16-12 summarizes the peak-hour level of service results at the 10 key study intersections and
the proposed project driveway for Existing With Project “With Sand and Gravel Credit” traffic
conditions. Column (1) of ICU/LOS values in Table 3.16-12 presents a summary of With Trip Credit
Existing AM and PM peak-hour traffic conditions. Column (2) lists Existing With Project “With Sand
and Gravel Credit” traffic conditions. Column (3) shows the increase in ICU value due to the added
peak-hour project trips and indicates whether the traffic associated with the project “With Sand and
Gravel Credit” will have a significant impact based on the LOS standards and significant impact
criteria defined in the TIA.
Review of Columns (2) and (3) of Table 3.16-12 indicates that traffic associated with the proposed
project “With Sand and Gravel Credit” will not significantly impact any of the 10 key study
intersections when compared to the LOS standards and significant impact criteria specified in the
TIA. Although the intersections of Cannon Street/Serrano Avenue and Cannon Street/Taft Avenue
are forecast to operate at unacceptable LOS E during the AM and/or PM peak-hours with the
addition of project traffic, the proposed project “With Sand and Gravel Credit” is expected to add
less than 0.010 to the ICU value. The remaining eight key study intersections and the proposed
project driveway are forecast to operate at acceptable levels of service during the AM and PM peak-
hours with the addition of project-generated traffic to existing traffic “With Sand and Gravel Credit.”
Appendix C and D of the Traffic Impact Analysis (Appendix P) presents the Existing With Project
ICU/LOS calculations for the 10 key study intersections and the proposed project driveway for the
AM peak-hour and PM peak-hour “With Sand and Gravel Credit.”
City of Orange—Trails at Santiago Creek Specific Plan
Transportation and Traffic Recirculated Draft EIR
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Roadway Segments
With Trip Credit Existing Traffic Conditions
Table 3.16-13 summarizes the roadway segment level of service results at the 17 key roadway
segments for With Trip Credit Existing traffic conditions. Column (1) shows the number of lanes,
Column (2) shows the arterial classification, and Column (3) shows the existing LOS “E” capacity.
Column (4) presents a summary of existing daily traffic conditions. C Column (5) lists With Trip Credit
Existing daily traffic conditions, which includes trips generated by the existing entitled land use.
Table 3.16-13 indicates that one of the 17 key roadway segments is forecast to operate at an
unacceptable level of service under With Trip Credit Existing traffic conditions. Roadway Segment B
(Cannon Street between Serrano Avenue and Taft Avenue) is forecast to operate at unacceptable LOS
F under With Trip Credit Existing traffic conditions. The remaining 16 key roadway segments are
forecast to operate at an acceptable service level under With Trip Credit Existing traffic conditions.
Existing With Project Traffic Conditions
Existing With Project Traffic Conditions (Without Sand and Gravel Credit)
Table 3.16-14summarizes the roadway segment level of service results at the 17 key roadway
segments for Existing With Project “Without Sand and Gravel Credit” traffic conditions. Column (1)
shows the number of lanes, Column (2) shows the arterial classification and Column (3) shows the
existing LOS “E” capacity. Column (4) presents a summary of Existing daily traffic conditions.
Column (5) lists Existing With Project “Without Sand and Gravel Credit” daily traffic conditions.
Column (5) also shows the increase in V/C ratio value due to the added daily project trips and
indicates whether the traffic associated with the project “Without Sand and Gravel Credit” will have
a significant impact based on the LOS standards and significant impact criteria defined in the TIA.
Review of Column (5) of Table 3.16-14 indicates that traffic associated with the proposed project
“Without Sand and Gravel Credit” will not significantly impact any of the 17 key roadway segments,
when compared to the LOS standards and significant impact criteria specified in the TIA. Although
Roadway Segment B (Cannon Street between Serrano Avenue and Taft Avenue) currently operates at
unacceptable LOS F under existing conditions, this key roadway segment is forecast to operate at
acceptable LOS D with the proposed project “Without Sand and Gravel Credit” (with inclusion of the
project-specific improvements). The remaining 16 key roadway segments currently operate and are
forecast to continue to operate at an acceptable service level on a daily basis with the addition of
project generated traffic to existing traffic “Without Sand and Gravel Credit.”
With Trip Credit Existing With Project Traffic Conditions (With Sand and Gravel Credit)
Table 3.16-15 summarizes the roadway segment level of service results at the 17 key roadway
segments for Existing With Project “With Sand and Gravel Credit” traffic conditions. Column (1)
shows the number of lanes, Column (2) shows the arterial classification and Column (3) shows the
existing LOS “E” capacity. Column (4) presents a summary of With Trip Credit Existing daily traffic
conditions. Column (5) lists Existing With Project “With Sand and Gravel Credit” daily traffic
conditions. Column (5) also shows the increase in V/C ratio value due to the added daily project trips
and indicates whether the traffic associated with the project “With Sand and Gravel Credit” will have
a significant impact based on the LOS standards and significant impact criteria defined in the TIA.
City of Orange—Trails at Santiago Creek Specific Plan
Recirculated Draft EIR Transportation and Traffic
FirstCarbon Solutions 3.16-83
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Review of Column (5) of Table 3.16-15 indicates that traffic associated with the proposed project
“With Sand and Gravel Credit” will not significantly impact any of the 17 key roadway segments,
when compared to the LOS standards and significant impact criteria specified in the TIA. Although
Roadway Segment B (Cannon Street between Serrano Avenue and Taft Avenue) currently operates at
unacceptable LOS F under existing conditions, this key roadway segment is forecast to operate at
acceptable LOS D with the proposed project “Without Sand and Gravel Credit” (with inclusion of the
project-specific improvements). The remaining 16 key roadway segments currently operate and are
forecast to continue to operate at an acceptable service level on a daily basis with the addition of
project generated traffic to existing traffic “With Sand and Gravel Credit.”
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Transportation and Traffic FirstCarbon Solutions 3.16-84 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec03-16 Transportation.docx Table 3.16-11: Existing With Project Peak-Hour Intersection Capacity Analysis (Without Sand and Gravel Credit) Key Intersections Time Period Minimum Acceptable LOS (1) Existing Traffic Conditions (2) Existing With Project Traffic Conditions (3) Project Significant Impact ICU LOS ICU LOS Increase Yes/No 1 Cannon Street at Serrano Avenue AM D 0.847 D 0.848 D 0.001 No PM 0.912 E 0.912 E 0.000 No 2 Cannon Street at Taft Avenue AM D 0.983 B 0.655 B1 0.000 No PM 0.869 D 0.870 D 0.001 No 3 Hewes Street at Villa Park Road AM D 0.742 C 0.744 C 0.002 No PM 0.627 B 0.635 B 0.008 No 4 Cannon Street at East Santiago Canyon Road AM D 0.749 C 0.754 C 0.005 No PM 0.739 C 0.747 C 0.008 No 5 Orange Park Boulevard at East Santiago Canyon Road AM D 0.838 D 0.849 D 0.011 No PM 0.881 D 0.895 D 0.014 No 6 Meads Avenue at East Santiago Canyon Road AM D 0.784 C 0.795 C 0.011 No PM 0.768 C 0.779 C 0.011 No 7 Newport Boulevard at East Santiago Canyon Road AM D 0.767 C 0.777 C 0.010 No PM 0.832 D 0.844 D 0.012 No 8 Jamboree Road at East Santiago Canyon Road AM D 0.641 B 0.651 B 0.010 No PM 0.647 B 0.657 B 0.010 No 9 Jamboree Road at Chapman Avenue/East Santiago Canyon Road AM D 0.533 A 0.541 A 0.008 No PM 0.845 D 0.864 D 0.019 No 10 Orange Park Boulevard at Chapman Avenue AM D 0.418 A 0.420 A 0.002 No PM 0.530 A 0.531 A 0.001 No
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Transportation and Traffic FirstCarbon Solutions 3.16-85 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec03-16 Transportation.docx Table 3.16-11 (cont.): Existing With Project Peak-Hour Intersection Capacity Analysis (Without Sand and Gravel Credit) Key Intersections Time Period Minimum Acceptable LOS (1) Existing Traffic Conditions (2) Existing With Project Traffic Conditions (3) Project Significant Impact ICU LOS ICU LOS Increase Yes/No — Project Driveway/Nicky Way at East Santiago Canyon Road AM D — — 0.791 C — — PM — — 0.585 A — — Notes: 1 The LOS calculations for this intersection include the following improvements that will be constructed as part of the proposed Project: Provide a third northbound through-lane.
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Transportation and Traffic FirstCarbon Solutions 3.16-86 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec03-16 Transportation.docx Table 3.16-12: With Trip Credit Existing With Project Peak-Hour Intersection Capacity Analysis (With Sand and Gravel Credit) Key Intersections Time Period Minimum Acceptable LOS (1) With Trip Credit Existing Traffic Conditions (2) Existing With Project Traffic Conditions (3) Project Significant Impact ICU LOS ICU LOS Increase Yes/No 1 Cannon Street at Serrano Avenue AM PM D 0.847 0.912 D E 0.847 0.912 D E 0.000 0.000 No No 2 Cannon Street at Taft Avenue AM PM D 0.983 0.869 E D 0.984 0.655 E B1 0.001 0.000 No No 3 Hewes Street at Villa Park Road AM PM D 0.748 0.630 C B 0.748 0.636 C B 0.000 0.006 No No 4 Cannon Street at East Santiago Canyon Road AM PM D 0.755 0.743 C C 0.756 0.748 C C 0.001 0.005 No No 5 Orange Park Boulevard at East Santiago Canyon Road AM PM D 0.841 0.883 D D 0.846 0.894 D D 0.005 0.011 No No 6 Meads Avenue at East Santiago Canyon Road AM PM D 0.787 0.769 C C 0.794 0.779 C C 0.007 0.010 No No 7 Newport Boulevard at East Santiago Canyon Road AM PM D 0.770 0.834 C D 0.776 0.844 C D 0.006 0.010 No No 8 Jamboree Road at East Santiago Canyon Road AM PM D 0.644 0.648 B B 0.650 0.657 B B 0.006 0.009 No No 9 Jamboree Road at Chapman Avenue/East Santiago Canyon Road AM PM D 0.535 0.848 A D 0.540 0.864 A D 0.005 0.016 No No 10 Orange Park Boulevard/Chapman Avenue AM PM D 0.418 0.530 A A 0.419 0.531 A A 0.001 0.001 No No — Project Driveway—Nicky Way/East Santiago Canyon Road AM PM D — — — — 0791 0.585 D A — — — — Notes: 1 The LOS calculations for this intersection include the following improvements that will be constructed as part of the proposed project: Provide a third northbound through-lane. A significant impact would occur if the project causes ICU to increase by 0.010 or more. Source: Linscott, Law & Greenspan, Engineers, 2017.
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Transportation and Traffic FirstCarbon Solutions 3.16-87 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec03-16 Transportation.docx Table 3.16-13: With Trip Credit Existing Roadway Segment Level of Service Summary Key Roadway Segment (1) No. of Existing Lanes (2) Arterial Classification (3) Existing Capacity at LOS “E” (4) Existing Traffic Conditions (5) With Trip Credit Existing Traffic Conditions Daily Volume V/C Ratio LOS Daily Volume V/C Ratio LOS A Cannon Street north of Serrano Avenue 4D Primary Arterial 37,500 20,171 0.538 A 20,171 0.538 A B Cannon Street between Serrano Avenue and Taft Avenue 4D Primary Arterial 37,500 39,787 1.061 F 39,787 1.061 F C Cannon Street between Taft Avenue and East Santiago Canyon Road 4D Primary Arterial 37,500 31,799 0.848 D 31,799 0.848 D D Cannon Street south of East Santiago Canyon Road 4D Primary Arterial 37,500 8,940 0.238 A 8,940 0.238 A E Villa Park Road west of Hewes Street 4D Primary Arterial 37,500 24,423 0.651 B 24,869 0.663 B F Hewes Street south of Villa Park Road 4U Secondary Arterial 24,000 8,807 0.367 A 8,807 0.367 A G East Santiago Canyon Road between Hewes Street and Cannon Street 4D Primary Arterial 37,500 26,118 0.696 B 26,564 0.708 C H East Santiago Canyon Road between Nicky Way and Orange Park Boulevard 4D Primary Arterial 37,500 29,009 0.774 C 29,249 0.780 C I East Santiago Canyon Road between Orange Park Boulevard and Meads Avenue 4D Primary Arterial 37,500 26,936 0.718 C 27,176 0.725 C J East Santiago Canyon Road between Meads Avenue and Newport Boulevard 4D Primary Arterial 37,500 26,303 0.701 C 26,543 0.708 C K East Santiago Canyon Road between Newport Boulevard and Jamboree Road 6D Major Arterial 56,300 20,861 0.371 A 21,101 0.375 A L Jamboree Road between East Santiago Canyon Road and Chapman Avenue 6D Major Arterial 56,300 20,820 0.370 A 21,060 0.374 A M Jamboree Road south of Chapman Avenue/East Santiago Canyon Road 6D Major Arterial 56,300 20,533 0.365 A 20,533 0.365 A N East Santiago Canyon Road east of Jamboree Road 4D Major Arterial 37,500 22,526 0.601 B 22,766 0.607 B
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Transportation and Traffic FirstCarbon Solutions 3.16-88 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec03-16 Transportation.docx Table 3.16-13 (cont.): With Trip Credit Existing Roadway Segment Level of Service Summary Key Roadway Segment (1) No. of Existing Lanes (2) Arterial Classification (3) Existing Capacity at LOS “E” (4) Existing Traffic Conditions (5) With Trip Credit Existing Traffic Conditions Daily Volume V/C Ratio LOS Daily Volume V/C Ratio LOS O Chapman Avenue between Cannon Street and Orange Park Boulevard 4D Primary Arterial 37,500 19,482 0.520 A 19,482 0.520 A P Chapman Avenue between Orange Park Boulevard and Newport Boulevard 4D Primary Arterial 37,500 23,154 0.617 B 23,154 0.617 B Q Orange Park Boulevard between East Santiago Canyon Road and Chapman Avenue 2D Collector 12,000 4,311 0.359 A 4,311 0.359 A Note: A significant impact would occur if the project causes V/C to increase by 0.010 or more Source: Linscott, Law & Greenspan, Engineers, 2017.
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Transportation and Traffic FirstCarbon Solutions 3.16-89 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec03-16 Transportation.docx Table 3.16-14: Existing With Project Roadway Segment Level of Service Summary (Without Sand and Gravel Credit) Key Roadway Segment (1) No. of Existing Lanes (2) Arterial Classification (3) Existing Capacity at LOS “E” (4) Existing Traffic Conditions (5) Existing With Project Traffic Conditions Daily Volume V/C Ratio LOS Daily Volume V/C Ratio LOS Incr. Sign. Imp. (Yes/No) A Cannon Street north of Serrano Avenue 4D Primary Arterial 37,500 20,171 0.538 A 20,293 0.541 A 0.003 No B Cannon Street between Serrano Avenue and Taft Avenue 4D Primary Arterial 37,500 39,787 1.061 F 39,945 0.852 D1 0.000 No C Cannon Street between Taft Avenue and East Santiago Canyon Road 4D Primary Arterial 37,500 31,799 0.848 D 31,982 0.682 B3 0.000 No D Cannon Street south of East Santiago Canyon Road 4D Primary Arterial 37,500 8,940 0.238 A 9,025 0.241 A 0.003 No E Villa Park Road west of Hewes Street 4D Primary Arterial 37,500 24,423 0.651 B 24,703 0.659 B 0.008 No F Hewes Street south of Villa Park Road 4U Secondary Arterial 24,000 8,807 0.367 A 8,831 0.368 A 0.001 No G East Santiago Canyon Road between Hewes Street and Cannon Street 4D Primary Arterial 37,500 26,118 0.696 B 26,423 0.705 C 0.009 No H East Santiago Canyon Road between Nicky Way and Orange Park Boulevard 4D Primary Arterial 37,500 29,009 0.774 C 29,655 0.791 C 0.017 No I East Santiago Canyon Road between Orange Park Blvd and Meads Ave 4D Primary Arterial 37,500 26,936 0.718 C 27,521 0.734 C 0.016 No J East Santiago Canyon Road between Meads Avenue and Newport Boulevard 4D Primary Arterial 37,500 26,303 0.701 C 26,888 0.717 C 0.016 No K East Santiago Canyon Road between Newport Boulevard and Jamboree Road 6D Major Arterial 56,300 20,861 0.371 A 21,410 0.380 A 0.009 No
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Transportation and Traffic FirstCarbon Solutions 3.16-90 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec03-16 Transportation.docx Table 3.16-14 (cont.): Existing With Project Roadway Segment Level of Service Summary (Without Sand and Gravel Credit) Key Roadway Segment (1) No. of Existing Lanes (2) Arterial Classification (3) Existing Capacity at LOS “E” (4) Existing Traffic Conditions (5) Existing With Project Traffic Conditions Daily Volume V/C Ratio LOS Daily Volume V/C Ratio LOS Incr. Sign. Imp. (Yes/No) L Jamboree Road between East Santiago Canyon Road and Chapman Avenue 6D Major Arterial 56,300 20,820 0.370 A 21,369 0.380 A 0.010 No M Jamboree Road south of Chapman Avenue/East Santiago Canyon Road 6D Major Arterial 56,300 20,533 0.365 A 20,691 0.368 A 0.003 No N East Santiago Canyon Road east of Jamboree Road 4D Major Arterial 37,500 22,526 0.601 B 22,953 0.612 B 0.011 No O Chapman Avenue between Cannon Street and Orange Park Boulevard 4D Primary Arterial 37,500 19,482 0.520 A 19,482 0.520 A 0.000 No P Chapman Avenue between Orange Park Boulevard and Newport Boulevard 4D Primary Arterial 37,500 23,154 0.617 B 23,215 0.619 B 0.002 No Q Orange Park Boulevard between East Santiago Canyon Road and Chapman Avenue 2D Collector 12,000 4,311 0.359 A 4,372 0.364 A 0.005 No Note: 1 The LOS calculations for this intersection include the following improvements that will be constructed as part of the proposed project: Provide a third northbound through-lane.
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Transportation and Traffic FirstCarbon Solutions 3.16-91 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec03-16 Transportation.docx Table 3.16-15: With Trip Credit Existing With Project Roadway Segment Level of Service Summary (With Sand and Gravel Credit) Key Roadway Segment (1) No. of Existing Lanes (2) Arterial Classification (3) Existing Capacity at LOS “E” (4) With Trip Credit Existing Traffic Conditions (5) With Trip Credit Existing With Project Traffic Conditions Daily Volume V/C Ratio LOS Daily Volume V/C Ratio LOS Incr. Sign. Imp. (Yes/No) A Cannon Street north of Serrano Avenue 4D Primary Arterial 37,500 20,171 0.538 A 20,224 0.539 A 0.001 No B Cannon Street between Serrano Avenue and Taft Avenue 4D Primary Arterial 37,500 39,787 1.061 F 39,856 0.850 D1 0.000 No C Cannon Street between Taft Avenue and East Santiago Canyon Road 4D Primary Arterial 37,500 31,799 0.848 D 31,879 0.680 B1 0.000 No D Cannon Street south of East Santiago Canyon Road 4D Primary Arterial 37,500 8,940 0.238 A 8,977 0.239 A 0.001 No E Villa Park Road west of Hewes Street 4D Primary Arterial 37,500 24,869 0.663 B 24,992 0.666 B 0.003 No F Hewes Street south of Villa Park Road 4U Secondary Arterial 24,000 8,807 0.367 A 8,818 0.367 A 0.000 No G East Santiago Canyon Road between Hewes Street and Cannon Street 4D Primary Arterial 37,500 26,564 0.708 C 26,697 0.712 C 0.004 No H East Santiago Canyon Road between Nicky Way and Orange Park Boulevard 4D Primary Arterial 37,500 29,249 0.780 C 29,531 0.787 C 0.007 No I East Santiago Canyon Road between Orange Park Boulevard and Meads Avenue 4D Primary Arterial 37,500 27,176 0.725 C 27,432 0.732 C 0.007 No J East Santiago Canyon Road between Meads Avenue and Newport Boulevard 4D Primary Arterial 37,500 26,543 0.708 C 26,799 0.715 C 0.007 No K East Santiago Canyon Road between Newport Boulevard and Jamboree Road 6D Major Arterial 56,300 21,101 0.375 A 24,992 0.666 B 0.003 No
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Transportation and Traffic FirstCarbon Solutions 3.16-92 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec03-16 Transportation.docx Table 3.16-15 (cont.): With Trip Credit Existing With Project Roadway Segment Level of Service Summary (With Sand and Gravel Credit) Key Roadway Segment (1) No. of Existing Lanes (2) Arterial Classification (3) Existing Capacity at LOS “E” (4) With Trip Credit Existing Traffic Conditions (5) With Trip Credit Existing With Project Traffic Conditions Daily Volume V/C Ratio LOS Daily Volume V/C Ratio LOS Incr. Sign. Imp. (Yes/No) L Jamboree Road between East Santiago Canyon Road and Chapman Avenue 6D Major Arterial 56,300 21,060 0.374 A 21,300 0.378 A 0.004 No M Jamboree Road south of Chapman Avenue/East Santiago Canyon Road 6D Major Arterial 56,300 20,533 0.365 A 20,602 0.366 A 0.001 No N East Santiago Canyon Road east of Jamboree Road 4D Major Arterial 37,500 22,766 0.607 B 22,953 0.612 B 0.005 No O Chapman Avenue between Cannon Street and Orange Park Boulevard 4D Primary Arterial 37,500 19,482 0.520 A 19,482 0.520 A 0.000 No P Chapman Avenue between Orange Park Boulevard and Newport Boulevard 4D Primary Arterial 37,500 23,154 0.617 B 23,181 0.618 B 0.001 No Q Orange Park Boulevard between East Santiago Canyon Road and Chapman Avenue 2D Collector 12,000 4,311 0.359 A 4,338 0.362 A 0.003 No Note: 1 The LOS calculations for this intersection include the following improvements that will be constructed as part of the proposed project: Provide a third northbound through-lane. A significant impact would occur if the project causes V/C to increase by 0.010 or more. Source: Linscott, Law & Greenspan, Engineers, 2017.
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Recirculated Draft EIR Transportation and Traffic
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Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
Year 2022 Traffic
Impact TRANS-2: The project may conflict with an applicable plan, ordinance or policy establishing
measures of effectiveness for the performance of the circulation system under
Year 2022 Traffic Conditions.
Impact Analysis
This impact evaluates Year 2022 Traffic Conditions.
Intersections
Table 3.16-16 summarizes the peak-hour level of service results at the 10 key study intersections and
the proposed project driveway for Year 2022 traffic conditions “Without Sand and Gravel Credit.”
Column (1) of ICU/LOS values in Table 3.16-16 presents a summary of Existing AM and PM peak-hour
traffic conditions. Column (2) lists projected cumulative traffic conditions (existing plus ambient
traffic plus cumulative project traffic) based on existing intersection geometry, but without any
traffic generated from the proposed project. Column (3) presents forecast Year 2022 near-term
traffic conditions with the addition of project traffic “Without Sand and Gravel Credit.” Column (4)
shows the increase in ICU value due to the added peak-hour project trips and indicates whether the
traffic associated with the project “Without Sand and Gravel Credit” will have a significant impact
based on the LOS standards and significant impact criteria defined in the TIA. Column (5) presents
the resultant level of service with the inclusion of recommended traffic improvements, where
needed, to achieve an acceptable level of service.
Table 3.16-17 summarizes the peak-hour level of service results at the 10 key study intersections and
the proposed project driveway for Year 2022 traffic conditions “With Sand and Gravel Credit.”
Column (1) of ICU/LOS values in Table 3.16-17 presents a summary of With Trip Credit Existing AM
and PM peak-hour traffic conditions. Column (2) lists projected cumulative traffic conditions
(existing plus ambient traffic plus cumulative project traffic) based on existing intersection geometry,
but without any traffic generated from the proposed project. Column (3) presents forecast Year
2022 near-term traffic conditions with the addition of project traffic “With Sand and Gravel Credit.”
Column (4) shows the increase in ICU value due to the added peak-hour project trips and indicates
whether the traffic associated with the project “With Sand and Gravel Credit” will have a significant
impact based on the LOS standards and significant impact criteria defined in the TIA. Column (5)
presents the resultant level of service with the inclusion of recommended traffic improvements,
where needed, to achieve an acceptable level of service.
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Year 2022 Without Project Traffic Conditions
Year 2022 Without Project Traffic Conditions (Without Sand and Gravel Credit)
An analysis of future (Year 2022) cumulative traffic conditions “Without Sand and Gravel Credit”
indicates that the addition of ambient traffic growth and cumulative project traffic will adversely
impact three of the 10 key study intersections. The remaining seven key study intersections are
forecast to continue to operate at acceptable levels of service during the AM and PM peak-hours
with the addition of ambient traffic growth and cumulative project traffic. The locations projected to
operate at an adverse LOS are shown in Rows 1, 2, and 5 of Table 3.16-16.
It should be noted that the intersection of Jamboree Road at Chapman Avenue/East Santiago Canyon
Road will be improved to include a second westbound right turn lane in conjunction with the
proposed Santiago Hills II Project.
Year 2022 Without Project Traffic Conditions (With Sand and Gravel Credit)
An analysis of future (Year 2022) cumulative traffic conditions “With Sand and Gravel Credit”
indicates that the addition of ambient traffic growth and cumulative project traffic will adversely
impact three of the 10 key study intersections. The remaining seven key study intersections are
forecast to continue to operate at acceptable levels of service during the AM and PM peak-hours
with the addition of ambient traffic growth and cumulative project traffic. The locations projected to
operate at an adverse LOS are shown in Rows 1, 2, and 5 of Table 3.16-17.
It should be noted that the intersection of Jamboree Road at Chapman Avenue/East Santiago Canyon
Road will be improved to include a second westbound right turn lane in conjunction with the
proposed Santiago Hills II Project.
Year 2022 With Project Traffic Conditions
Year 2022 With Project Traffic Conditions (Without Sand and Gravel Credit)
Review of Columns (3) and (4) of Table 3.16-16 indicates that traffic associated with the proposed
project “Without Sand and Gravel Credit” will significantly impact one of the 10 key study
intersections, when compared to the LOS standards and significant impact criteria specified in the TIA.
Although the intersections of Cannon Street/Serrano Avenue and Cannon Street/Taft Avenue are
forecast to operate at unacceptable LOS E or LOS F during the AM and/or PM peak-hours with the
addition of project traffic, the proposed project “Without Sand and Gravel Credit” is expected to add
less than 0.010 to the ICU value. The remaining seven key study intersections and the proposed
project driveway are forecast to continue to operate at an acceptable LOS with the addition of project
generated traffic in the Year 2022 “Without Sand and Gravel Credit.” The location significantly
impacted by the proposed project in the Year 2022 is as shown in Row 5 of Table 3.16-16.
As shown in Column (5), the implementation of improvements at the impacted key study
intersections completely offsets the impact of project traffic “Without Sand and Gravel Credit” and
the key study intersection is forecast to operate at an acceptable LOS during the AM and PM peak-
hours. Appendix C and D presents the Year 2022 With Project ICU/LOS calculations for the 10 key
study intersections and the proposed project driveway “Without Sand and Gravel Credit.”
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Year 2022 With Project Traffic Conditions (With Sand and Gravel Credit)
Review of Columns (3) and (4) of Table 3.16-17 indicates that traffic associated with the proposed
project “With Sand and Gravel Credit” will significantly impact one of the 10 key study intersections,
when compared to the LOS standards and significant impact criteria specified in the TIA. Although
the intersections of Cannon Street/Serrano Avenue and Cannon Street/Taft Avenue are forecast to
operate at unacceptable LOS E or LOS F during the AM and/or PM peak-hours with the addition of
project traffic, the proposed project “With Sand and Gravel Credit” is expected to add less than
0.010 to the ICU value. The remaining seven key study intersections and the proposed project
driveway are forecast to continue to operate at an acceptable LOS with the addition of project
generated traffic in the Year 2022 “With Sand and Gravel Credit.” The location significantly impacted
by the proposed project in the Year 2022 is as shown in Row 5 of Table 3.16-17.
As shown in Column (5), the implementation of improvements at the impacted key study
intersections completely offsets the impact of project traffic “With Sand and Gravel Credit” and the
key study intersection is forecast to operate at an acceptable LOS during the AM and PM peak-hours.
Appendix C and D presents the Year 2022 With Project ICU/LOS calculations for the te10 key study
intersections and the proposed project driveway “With Sand and Gravel Credit.”
Roadway Segments
Table 3.16-18 summarizes the roadway segment level of service results at the 17 key roadway
segments for Year 2022 traffic conditions “Without Sand and Gravel Credit.” Column (1) shows the
number of lanes, Column (2) shows the arterial classification, and Column (3) shows the existing LOS
“E” capacity. Column (4) presents a summary of projected Year 2022 cumulative daily traffic
conditions. Column (5) lists Year 2022 With Project daily traffic conditions. Column (5) also shows
the increase in V/C ratio value due to the added daily project trips and indicates whether the traffic
associated with the project “Without Sand and Gravel Credit” will have a significant impact based on
the LOS standards and significant impact criteria defined in the TIA.
Table 3.16-19 summarizes the roadway segment level of service results at the 17 key roadway
segments for Year 2022 traffic conditions “With Sand and Gravel Credit.” Column (1) shows the
number of lanes, Column (2) shows the arterial classification, and Column (3) shows the existing LOS
“E” capacity. Column (4) presents a summary of projected Year 2022 cumulative daily traffic
conditions. Column (5) lists Year 2022 With Project daily traffic conditions. Column (5) also shows
the increase in V/C ratio value due to the added daily project trips and indicates whether the traffic
associated with the project “With Sand and Gravel Credit” will have a significant impact based on the
LOS standards and significant impact criteria defined in the TIA.
Year 2022 Without Project Traffic Conditions
Year 2022 Without Project Traffic Conditions (Without Sand and Gravel Credit)
An analysis of future (Year 2022) cumulative traffic conditions “Without Sand and Gravel Credit”
indicates that with the addition of ambient traffic growth and cumulative project traffic, two of the
17 key roadway segments are forecast to operate at unacceptable levels of service. Roadway
Segment B (Cannon Street between Serrano Avenue and Taft Avenue) and Roadway Segment C
(Cannon Street between Taft Avenue and East Santiago Canyon Road) are forecast to operate at
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unacceptable LOS E and/or LOS F on a daily basis in the Year 2022. The remaining 15 key roadway
segments are forecast to continue to operate at acceptable levels of service on a daily basis with the
addition of ambient traffic growth and cumulative project traffic “Without Sand and Gravel Credit.”
Year 2022 Without Project Traffic Conditions (With Sand and Gravel Credit)
An analysis of future (Year 2022) cumulative traffic conditions “With Sand and Gravel Credit”
indicates that with the addition of ambient traffic growth and cumulative project traffic, two of the
17 key roadway segments are forecast to operate at unacceptable levels of service. Roadway
Segment B (Cannon Street between Serrano Avenue and Taft Avenue) and Roadway Segment C
(Cannon Street between Taft Avenue and East Santiago Canyon Road) are forecast to operate at
unacceptable LOS E and/or LOS F on a daily basis in the Year 2022. The remaining 15 key roadway
segments are forecast to continue to operate at acceptable levels of service on a daily basis with the
addition of ambient traffic growth and cumulative project traffic “With Sand and Gravel Credit.”
Year 2022 With Project Traffic Conditions
Year 2022 With Project Traffic Conditions (Without Sand and Gravel Credit)
Review of Column (5) of Table 3.16-18 indicates that traffic associated with the proposed project
“Without Sand and Gravel Credit” will not significantly impact any of the 17 key roadway segments,
when compared to the LOS standards and significant impact criteria specified in the TIA. Although
Roadway Segment B (Cannon Street between Serrano Avenue and Taft Avenue) is forecast to operate
at unacceptable LOS F on a daily basis in the Year 2022 without project traffic, the level of service for
this key roadway segment improves to LOS E with the proposed project “Without Sand and Gravel
Credit” (with inclusion of the project-specific improvements). Although Roadway Segment C (Cannon
Street between Taft Avenue and East Santiago Canyon Road) is forecast to operate at unacceptable LOS
E on a daily basis in the Year 2022 without project traffic, this key roadway segment is forecast to
operate at acceptable LOS C with the proposed project “Without Sand and Gravel Credit” (with
inclusion of the project-specific improvements). The remaining 15 key roadway segments are forecast
to continue to operate at an acceptable service level on a daily basis with the addition of project
generated traffic in the Year 2022 traffic condition “Without Sand and Gravel Credit.”
Year 2022 With Project Traffic Conditions (With Sand and Gravel Credit)
Review of Column (5) of Table 3.16-19 indicates that traffic associated with the proposed project
“With Sand and Gravel Credit” will not significantly impact any of the 17 key roadway segments,
when compared to the LOS standards and significant impact criteria specified in the TIA. Although
Roadway Segment B (Cannon Street between Serrano Avenue and Taft Avenue) is forecast to
operate at unacceptable LOS F on a daily basis in the Year 2022 without project traffic, the level of
service for this key roadway segment improves to LOS E with the proposed project “With Sand and
Gravel Credit” (with inclusion of the project-specific improvements). Although Roadway Segment C
(Cannon Street between Taft Avenue and East Santiago Canyon Road) is forecast to operate at
unacceptable LOS E on a daily basis in the Year 2022 without project traffic, this key roadway
segment is forecast to operate at acceptable LOS C with the proposed project “With Sand and Gravel
Credit” (with inclusion of the project-specific improvements). The remaining 15 key roadway
segments are forecast to continue to operate at an acceptable service level on a daily basis with the
addition of project generated traffic in the Year 2022 traffic condition “With Sand and Gravel Credit.”
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Transportation and Traffic FirstCarbon Solutions 3.16-97 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec03-16 Transportation.docx Table 3.16-16: Year 2022 Peak-Hour Intersection Capacity Analysis (Without Sand and Gravel Credit) Key Intersections Time Period Minimum Acceptable LOS (1) Existing Traffic Conditions (2) Year 2022 Without Project Traffic Conditions (3) Year 2022 With Project Traffic Conditions (4) Project Significant Impact (5) Year 2022 With Project With Mitigation ICU LOS ICU LOS ICU LOS Increase Yes/No ICU LOS 1 Cannon Street at Serrano Avenue AM D 0.847 D 0.891 D 0.891 D 0.000 No — — PM 0.912 E 0.955 E 0.955 E 0.000 No — — 2 Cannon Street at Taft Avenue AM D 0.983 E 1.034 F 1.036 F1 0.002 No — — PM 0.869 D 0.914 E 0.688 B1 0.000 No — — 3 Hewes Street at Villa Park Road AM D 0.742 C 0.785 C 0.788 C 0.003 No — — PM 0.627 B 0.677 B 0.684 B 0.007 No — — 4 Cannon Street at East Santiago Canyon Road AM D 0.749 C 0.789 C 0.794 C 0.005 No — — PM 0.739 C 0.788 C 0.796 C 0.008 No — — 5 Orange Park Boulevard at East Santiago Canyon Road AM D 0.838 D 0.887 D 0.898 D 0.011 No 0.848 D PM 0.881 D 0.936 E 0.949 E 0.013 Yes 0.889 D 6 Meads Avenue at East Santiago Canyon Road AM D 0.784 C 0.830 D 0.840 D 0.010 No — — PM 0.768 C 0.815 D 0.826 D 0.011 No — — 7 Newport Boulevard at East Santiago Canyon Road AM D 0.767 C 0.812 D 0.822 D 0.010 No — — PM 0.832 D 0.883 D 0.895 D 0.012 No — — 8 Jamboree Road at East Santiago Canyon Road AM D 0.641 B 0.680 B 0.689 B 0.009 No — — PM 0.647 B 0.689 B 0.700 C 0.011 No — — 9 Jamboree Road at Chapman Avenue/East Santiago Canyon Road AM D 0.533 A 0.587 A 0.595 A 0.008 No — — PM 0.845 D 0.769 C 0.776 C 0.007 No — —
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Transportation and Traffic FirstCarbon Solutions 3.16-98 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec03-16 Transportation.docx Table 3.16-16 (cont.): Year 2022 Peak-Hour Intersection Capacity Analysis (Without Sand and Gravel Credit) Key Intersections Time Period Minimum Acceptable LOS (1) Existing Traffic Conditions (2) Year 2022 Without Project Traffic Conditions (3) Year 2022 With Project Traffic Conditions (4) Project Significant Impact (5) Year 2022 With Project With Mitigation ICU LOS ICU LOS ICU LOS Increase Yes/No ICU LOS 10 Orange Park Boulevard at Chapman Avenue AM D 0.418 A 0.456 A 0.459 A 0.003 No — — PM 0.530 A 0.577 A 0.578 A 0.001 No — — — Project Driveway/Nicky Way at East Santiago Canyon Road AM D — — — — 0.836 D — — — — PM — — — — 0.623 B — — — — Note: 1 The LOS calculations for this intersection include the following improvements that will be constructed as part of the proposed project: Provide a third northbound through-lane.
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Transportation and Traffic FirstCarbon Solutions 3.16-99 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec03-16 Transportation.docx Table 3.16-17: Year 2022 Peak-Hour Intersection Capacity Analysis (With Sand and Gravel Credit) Key Intersections Time Period Minimum Acceptable LOS (1) With Trip Credit Existing Traffic Conditions (2) Year 2022 Without Project Traffic Conditions (3) Year 2022 With Project Traffic Conditions (4) Project Significant Impact (5) Year 2022 With Project With Mitigation ICU LOS ICU LOS ICU LOS Increase Yes/No ICU LOS 1 Cannon Street at Serrano Avenue AM PM D 0.847 0.912 D E 0.891 0.955 D E 0.890 0.955 D E 0.000 0.000 No No — — — — 2 Cannon Street at Taft Avenue AM PM D 0.983 0.869 E D 1.034 0.914 F E 1.034 0.688 F1 B1 0.000 0.000 No No — — — — 3 Hewes Street at Villa Park Road AM PM D 0.748 0.630 C B 0.792 0.680 C B 0.792 0.686 C B 0.002 0.006 No No — — — — 4 Cannon Street at East Santiago Canyon Road AM PM D 0.755 0.743 C C 0.796 0.792 C C 0.797 0.797 C C 0.001 0.005 No No — — — — 5 Orange Park Boulevard at East Santiago Canyon Road AM PM D 0.841 0.883 D D 0.890 0.937 D E 0.896 0.948 D E 0.006 0.011 No Yes 0.846 0.888 D D 6 Meads Avenue at East Santiago Canyon Road AM PM D 0.787 0.769 C C 0.833 0.816 D D 0.839 0.826 D D 0.006 0.010 No No — — — — 7 Newport Boulevard at East Santiago Canyon Road AM PM D 0.770 0.834 C D 0.815 0.885 D D 0.820 0.895 D D 0.005 0.010 No No — — — — 8 Jamboree Road at East Santiago Canyon Road AM PM D 0.644 0.648 B B 0.683 0.691 B B 0.689 0.700 B C 0.006 0.009 No No — — — — 9 Jamboree Road at Chapman Avenue/East Santiago Canyon Road AM PM D 0.535 0.848 A D 0.590 0.771 A C 0.594 0.777 A C 0.005 0.006 No No — — — — 10 Orange Park Boulevard/Chapman Avenue AM PM D 0.418 0.530 A A 0.456 0.577 A A 0.458 0.578 A A 0.002 0.001 No No — — — — — Project Driveway—Nicky Way/East Santiago Canyon Road AM PM D — — — — — — — — 0.836 0.623 D B — — — — — — — — Note: 1 The LOS calculations for this intersection include the following improvements that will be constructed as part of the proposed project: Provide a third northbound through-lane. A significant impact would occur if the project causes ICU to increase by 0.010 or more. Source: Linscott, Law & Greenspan, Engineers, 2017.
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Transportation and Traffic FirstCarbon Solutions 3.16-100 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec03-16 Transportation.docx Table 3.16-18: Year 2022 Roadway Segment Level of Service Summary (Without Sand and Gravel Credit) Key Roadway Segment (1) No. of Existing Lanes (2) Arterial Classification (3) Existing Capacity at LOS “E” (4) Year 2022 Without Project Traffic Conditions (5) Year 2022 With Project Traffic Conditions Daily Volume V/C Ratio LOS Daily Volume V/C Ratio LOS Incr. Sign. Imp. (Yes/No) A Cannon Street north of Serrano Avenue 4D Primary Arterial 37,500 21,698 0.579 A 21,820 0.582 A 0.003 No B Cannon Street between Serrano Avenue and Taft Avenue 4D Primary Arterial 37,500 42,297 1.128 F 42,455 0.906 E1 0.000 No C Cannon Street between Taft Avenue and East Santiago Canyon Road 4D Primary Arterial 37,500 33,917 0.904 E 34,100 0.727 C1 0.000 No D Cannon Street south of East Santiago Canyon Road 4D Primary Arterial 37,500 9,394 0.251 A 9,479 0.253 A 0.002 No E Villa Park Road west of Hewes Street 4D Primary Arterial 37,500 26,560 0.708 C 26,840 0.716 C 0.008 No F Hewes Street south of Villa Park Road 4U Secondary Arterial 24,000 9,372 0.391 A 9,396 0.392 A 0.001 No G East Santiago Canyon Road between Hewes Street and Cannon Street 4D Primary Arterial 37,500 28,335 0.756 C 28,640 0.764 C 0.008 No H East Santiago Canyon Road between Nicky Way and Orange Park Boulevard 4D Primary Arterial 37,500 31,806 0.848 D 32,452 0.865 D 0.017 No I East Santiago Canyon Road between Orange Park Boulevard and Meads Avenue 4D Primary Arterial 37,500 29,578 0.789 C 30,163 0.804 D 0.015 No J East Santiago Canyon Road between Meads Avenue and Newport Boulevard 4D Primary Arterial 37,500 28,913 0.771 C 29,498 0.787 C 0.016 No
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Transportation and Traffic FirstCarbon Solutions 3.16-101 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec03-16 Transportation.docx Table 3.16-18 (cont.): Year 2022 Roadway Segment Level of Service Summary (Without Sand and Gravel Credit) Key Roadway Segment (1) No. of Existing Lanes (2) Arterial Classification (3) Existing Capacity at LOS “E” (4) Year 2022 Without Project Traffic Conditions (5) Year 2022 With Project Traffic Conditions Daily Volume V/C Ratio LOS Daily Volume V/C Ratio LOS Incr. Sign. Imp. (Yes/No) K East Santiago Canyon Road between Newport Boulevard and Jamboree Road 6D Major Arterial 56,300 23,199 0.412 A 23,748 0.422 A 0.010 No L Jamboree Road between East Santiago Canyon Road and Chapman Avenue 6D Major Arterial 56,300 23,156 0.411 A 23,705 0.421 A 0.010 No M Jamboree Road south of Chapman Avenue/East Santiago Canyon Road 6D Major Arterial 56,300 21,562 0.383 A 21,720 0.386 A 0.003 No N East Santiago Canyon Road east of Jamboree Road 4D Major Arterial 37,500 29,288 0.781 C 29,715 0.792 C 0.011 No O Chapman Avenue between Cannon Street and Orange Park Boulevard 4D Primary Arterial 37,500 22,711 0.606 B 22,711 0.606 B 0.000 No P Chapman Avenue between Orange Park Boulevard and Newport Boulevard 4D Primary Arterial 37,500 26,806 0.715 C 26,867 0.716 C 0.001 No Q Orange Park Boulevard between East Santiago Canyon Road and Chapman Avenue 2D Collector 12,000 4,774 0.398 A 4,835 0.403 A 0.005 No Note: 1 The LOS calculations for this intersection include the following improvements that will be constructed as part of the proposed project: Provide a third northbound through-lane.
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Transportation and Traffic FirstCarbon Solutions 3.16-102 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec03-16 Transportation.docx Table 3.16-19: Year 2022 Roadway Segment Level of Service Summary (With Sand and Gravel Credit) Key Roadway Segment (1) No. of Existing Lanes (2) Arterial Classification (3) Existing Capacity at LOS “E” (4) Year 2022 Without Project Traffic Conditions (5) Year 2022 With Project Traffic Conditions Daily Volume V/C Ratio LOS Daily Volume V/C Ratio LOS Incr. Sign. Imp. (Yes/No) A Cannon Street north of Serrano Avenue 4D Primary Arterial 37,500 21,698 0.579 A 21,751 0.580 A 0.001 No B Cannon Street between Serrano Avenue and Taft Avenue 4D Primary Arterial 37,500 42,297 1.128 F 42,366 0.904 E1 0.000 No C Cannon Street between Taft Avenue and East Santiago Canyon Road 4D Primary Arterial 37,500 33,917 0.904 E 33,997 0.725 C1 0.000 No D Cannon Street south of East Santiago Canyon Road 4D Primary Arterial 37,500 9,394 0.251 A 21,751 0.580 A 0.001 No E Villa Park Road west of Hewes Street 4D Primary Arterial 37,500 27,028 0.721 C 42,366 1.130 F 0.002 No F Hewes Street south of Villa Park Road 4U Secondary Arterial 24,000 9,372 0.391 A 33,997 0.907 E 0.003 No G East Santiago Canyon Road between Hewes Street and Cannon Street 4D Primary Arterial 37,500 28,803 0.768 C 21,751 0.580 A 0.001 No H East Santiago Canyon Road between Nicky Way and Orange Park Boulevard 4D Primary Arterial 37,500 32,058 0.855 D 42,366 1.130 F 0.002 No I East Santiago Canyon Road between Orange Park Boulevard and Meads Avenue 4D Primary Arterial 37,500 29,830 0.795 C 33,997 0.907 E 0.003 No J East Santiago Canyon Road between Meads Avenue and Newport Boulevard 4D Primary Arterial 37,500 29,165 0.778 C 21,751 0.580 A 0.001 No K East Santiago Canyon Road between Newport Boulevard and Jamboree Road 6D Major Arterial 56,300 23,451 0.417 A 21,751 0.580 A 0.001 No
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Transportation and Traffic FirstCarbon Solutions 3.16-103 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec03-16 Transportation.docx Table 3.16-19 (cont.): Year 2022 Roadway Segment Level of Service Summary (With Sand and Gravel Credit) Key Roadway Segment (1) No. of Existing Lanes (2) Arterial Classification (3) Existing Capacity at LOS “E” (4) Year 2022 Without Project Traffic Conditions (5) Year 2022 With Project Traffic Conditions Daily Volume V/C Ratio LOS Daily Volume V/C Ratio LOS Incr. Sign. Imp. (Yes/No) L Jamboree Road between East Santiago Canyon Road and Chapman Avenue 6D Major Arterial 56,300 23,408 0.416 A 42,366 1.130 F 0.002 No M Jamboree Road south of Chapman Avenue/East Santiago Canyon Road 6D Major Arterial 56,300 21,562 0.383 A 33,997 0.907 E 0.003 No N East Santiago Canyon Road east of Jamboree Road 4D Major Arterial 37,500 29,540 0.788 C 21,751 0.580 A 0.001 No O Chapman Avenue between Cannon Street and Orange Park Boulevard 4D Primary Arterial 37,500 22,711 0.606 B 22,711 0.606 B 0.000 No P Chapman Avenue between Orange Park Boulevard and Newport Boulevard 4D Primary Arterial 37,500 26,806 0.715 C 26,833 0.716 C 0.001 No Q Orange Park Boulevard between East Santiago Canyon Road and Chapman Avenue 2D Collector 12,000 4,774 0.398 A 4,801 0.400 A 0.002 No Note: 1 The LOS calculations for this intersection include the following improvements that will be constructed as part of the proposed project: Provide a third northbound through-lane. A significant impact would occur if the project causes V/C to increase by 0.010 or more. Source: Linscott, Law & Greenspan, Engineers, 2017.
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To mitigate the proposed project’s impacts at Orange Park Boulevard/East Santiago Canyon Road,
Mitigation Measure TRANS-2 would require improvements to each intersection. The improvements
are depicted in Exhibit 3.16-21. Because the project contributes to pre-existing deficient conditions,
it is only required to mitigate for its fair share of the impact. The fair share calculations are
summarized in Table 3.16-20.
Table 3.16-20: Year 2022 Project Fair Share Contribution
Key Intersection
Impacted
Time
Period
(1)
Project
Only
Volume
(2)
Existing
Volume
(3)
Year 2022
With Project
Volume
(4)
Project Fair
Share
Responsibility
Orange Park Boulevard at East Santiago
Canyon Road (Without Sand and Gravel Credit)
AM
PM
—
68
—
3,436
—
3,810
—
18.2 percent
Orange Park Boulevard at East Santiago
Canyon Road (With Sand and Gravel Credit)
AM
PM
—
51
—
3,447
—
3,805
—
14.2 percent
Notes:
Net Project Percent Increase (4) = Column (1)/[Column (3)–Column (2)]
Bold Project Fair Share Responsibility is based on worst-case scenario.
Source: Linscott, Law & Greenspan, Engineers, 2017.
Despite the fair share contribution provided through Mitigation Measure TRANS-2 mitigating the
proposed project’s impacts at Orange Park Boulevard/East Santiago Canyon Road, impacts would be
significant and unavoidable as the Orange Park Boulevard/East Santiago Canyon Road intersection is
not listed in the City of Orange MPAH, or any similar plans.
Level of Significance Before Mitigation
Potentially significant impact.
Mitigation Measures
MM TRANS-2 Prior to issuance of building permits, the project Applicant shall provide the City of
Orange with fair share fees to restripe the northbound approach of Orange Park
Boulevard at East Santiago Canyon Road to provide one exclusive left-turn lane and
one shared left-turn/right-turn lane. The Applicant’s fair share responsibility for
these improvements is 18.2 percent.
Level of Significance After Mitigation
Significant and unavoidable impact.
I
27650002 • 09/2018 |3.16-21_2022_improve.cdr
Exhibit 3.16-21
Year 2022 Planned and Recommended Improvements
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Linscott, Law & Greenspan, Engineers, September 2018.
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Year 2040 Traffic
Impact TRANS-3: The project would not conflict with an applicable plan, ordinance or policy
establishing measures of effectiveness for the performance of the circulation
system under Year 2040 Traffic Conditions.
Impact Analysis
The following summarizes the “Year 2040 Buildout With Project” level of service results for the 10
key study intersections and 17 key roadway segments for the “Without Sand and Gravel Credit” and
“With Sand and Gravel Credit” baseline traffic conditions. Consistent with the Santiago Hills II Traffic
Study, prepared by Stantec Consulting Services Inc., the level of service results for the key study
intersections and key roadway segments include improvements planned by the City of Orange. In
addition, the circulation network utilized in the Year 2040 analysis reflects the buildout of the City of
Orange Master Plan of Arterial Highways (MPAH) that was approved as part of the 2010 City of
Orange General Plan Update.
Planned Improvements
The following improvements are included in the Year 2040 Buildout traffic analysis and reflect the
City’s MPAH. It should be noted that the improvements listed below are consistent with those
contained in the Santiago Hills II Traffic Study, prepared by Stantec Consulting Services Inc., dated
May 6, 2016. Exhibit 3.16-22 depicts planned improvements to the roadway network.
• Cannon Street at Serrano Avenue: Widen and/or restripe Cannon Street to provide a third
southbound through lane.
• Cannon Street at Taft Avenue: Widen and/or restripe Canon Street to provide a third
southbound through lane.
• Cannon Street at East Santiago Canyon Road: Widen and/or restripe Cannon Street to provide
a second northbound left-turn lane. Widen and/or restripe the southbound approach of
Cannon Street to provide three southbound left-turn lanes, three southbound through lanes
and a southbound free right-turn lane. Widen and/or restripe East Santiago Canyon Road to
provide a third eastbound through lane and an exclusive eastbound right-turn lane. Widen
and/or restripe East Santiago Canyon Road to provide a second westbound left-turn lane and
a third westbound through lane.
• Orange Park Boulevard at East Santiago Canyon Road: Widen and/or restripe East Santiago
Canyon Road to provide a third eastbound through lane and a third westbound through lane.
• Meads Avenue at East Santiago Canyon Road: Widen and/or restripe East Santiago Canyon
Road to provide a third eastbound through lane and a third westbound through lane.
Newport Boulevard at East Santiago Canyon Road: Widen and/or restripe East Santiago
Canyon Road to provide a third eastbound through lane and a third westbound through lane.
• Jamboree Road at Chapman Avenue/East Santiago Canyon Road: Widen and/or restripe East
Santiago Canyon Road to provide a second westbound right-turn lane.
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• Project Driveway/Nicky Way at East Santiago Canyon Road: Widen and/or restripe East
Santiago Canyon Road to provide a third eastbound through lane.
Intersections
Table 3.16-21 summarizes the peak-hour level of service results at the 10 key study intersections and
the proposed project driveway for Year 2040 Buildout traffic conditions “Without Sand and Gravel
Credit.” The structure of this table is similar to the near-term (Year 2022) capacity analysis summary
presented in Table 3.16-16.
Table 3.16-22 summarizes the peak-hour level of service results at the 10 key study intersections and
the proposed Project driveway for Year 2040 Buildout traffic conditions “With Sand and Gravel
Credit.” The structure of this table is similar to the near-term (Year 2022) capacity analysis summary
presented in Table 3.16-17.
Year 2040 Buildout Without Project Traffic Conditions
Review of Column (2) of Table 3.16-21 and Table 3.16-22 shows that projected Year 2040 buildout
without project traffic will adversely impact two of the 10 key study intersections. The remaining
eight key study intersections are forecast to operate at an acceptable LOS under Year 2040 buildout
without project traffic conditions. The locations projected to operate at an adverse LOS are shown in
Rows 1 and 9 of Table 3.16-22.
Year 2040 Buildout With Project Traffic Conditions
Year 2040 Buildout With Project Traffic Conditions (Without Sand and Gravel Operation)
Review of Columns (3) and (4) of Table 3.16-21 indicates that traffic associated with the proposed
project “Without Sand and Gravel Credit” will not significantly impact any of the 10 key study
intersections when compared to the LOS standards and significant impact criteria specified in the
TIA. Although the intersections of Cannon Street/Serrano Avenue and Jamboree Road/Chapman
Avenue-East Santiago Canyon Road are forecast to operate at unacceptable LOS E and/or LOS F
during the AM and/or PM peak-hours with and without the addition of project traffic, the proposed
project “Without Sand and Gravel Credit” is expected to add less than 0.010 to the ICU value. The
remaining eight key study intersections and the proposed project driveway are forecast to continue
to operate at an acceptable LOS with the addition of project generated traffic in the Year 2040
“Without Sand and Gravel Credit.”
Appendix C and D of the Traffic Impact Analysis (Appendix P) presents the Year 2040 Buildout
ICU/LOS calculations for the 10 key study intersections and the proposed project driveway “Without
Sand and Gravel Credit.”
I
27650002 • 09/2018 |3.16-22_2040_improve.cdr
Exhibit 3.16-22
Year 2040 Planned Improvements
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: Linscott, Law & Greenspan, Engineers, September 2018.
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Year 2040 Buildout With Project Traffic Conditions (With Sand and Gravel Operation)
Review of Columns (3) and (4) of Table 3.16-22 indicates that traffic associated with the proposed
project “With Sand and Gravel Credit” will not significantly impact any of the 10 key study
intersections when compared to the LOS standards and significant impact criteria specified in the
TIA. Although the intersections of Cannon Street/Serrano Avenue and Jamboree Road/Chapman
Avenue-East Santiago Canyon Road are forecast to operate at unacceptable LOS E and/or LOS F
during the AM and/or PM peak-hours with and without the addition of project traffic, the proposed
project “With Sand and Gravel Credit” is expected to add less than 0.010 to the ICU value. The
remaining eight key study intersections and the proposed project driveway are forecast to continue
to operate at an acceptable LOS with the addition of project generated traffic in the Year 2040 “With
Sand and Gravel Credit.”
Appendix C and D of the Traffic Impact Analysis (Appendix P) presents the Year 2040 Buildout
ICU/LOS calculations for the 10 key study intersections and the proposed project driveway “With
Sand and Gravel Credit.”
Roadway Segments
Table 3.16-23 summarizes the roadway segment level of service results at the 17 key roadway
segments for Year 2040 traffic conditions “Without Sand and Gravel Credit.” The structure of this
table is similar to the Year 2022 daily capacity analysis summary presented in Table 3.16-18.
Table 3.16-24 summarizes the roadway segment level of service results at the 17 key roadway
segments for Year 2040 traffic conditions “With Sand and Gravel Credit.” The structure of this table
is similar to the Year 2022 daily capacity analysis summary presented in Table 3.16-19.
Year 2040 Buildout Without Project Traffic Conditions
An analysis of future (Year 2040) buildout traffic conditions indicates that two of the 17 key roadway
segments are forecast to operate at unacceptable levels of service. Roadway Segment B (Cannon
Street between Serrano Avenue and Taft Avenue) and Roadway Segment E (Villa Park Road west of
Hewes Street) are forecast to operate at unacceptable LOS E and/or LOS F in the Year 2040. The
remaining 15 key roadway segments are forecast to continue to operate at acceptable levels of
service in the Year 2040.
Year 2040 With Project Traffic Conditions
Year 2040 With Project Traffic Conditions (Without Sand and Gravel Credit)
Review of Column (5) of Table 3.16-23 indicates that traffic associated with the proposed project
“Without Sand and Gravel Credit” will not significantly impact any of the 17 key roadway segments,
when compared to the LOS standards and significant impact criteria specified in the TIA. Although
Roadway Segment B (Cannon Street between Serrano Avenue and Taft Avenue) and Roadway
Segment E (Villa Park Road west of Hewes Street) are forecast to operate at unacceptable LOS E
and/or LOS F on a daily basis in the Year 2040 with and without the addition of project traffic, the
proposed project “Without Sand and Gravel Credit ” is expected to add less than 0.010 to the V/C
ratio. The remaining 15 key roadway segments are forecast to continue to operate at an acceptable
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service level on a daily basis with the addition of project generated traffic in the Year 2040 traffic
condition “Without Sand and Gravel Credit.”
Year 2040 With Project Traffic Conditions (With Sand and Gravel Credit)
Review of Column (5) of Table 3.16-24 indicates that traffic associated with the proposed project
“With Sand and Gravel Credit” will not significantly impact any of the 17 key roadway segments,
when compared to the LOS standards and significant impact criteria specified in the TIA. Although
Roadway Segment B (Cannon Street between Serrano Avenue and Taft Avenue) and Roadway
Segment E (Villa Park Road west of Hewes Street) are forecast to operate at unacceptable LOS E
and/or LOS F on a daily basis in the Year 2040 with and without the addition of project traffic, the
proposed project “With Sand and Gravel Credit” is expected to add less than 0.010 to the V/C ratio.
The remaining 15 key roadway segments are forecast to continue to operate at an acceptable service
level on a daily basis with the addition of project generated traffic in the Year 2040 traffic condition
“With Sand and Gravel Credit.”
City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Transportation and Traffic FirstCarbon Solutions 3.16-113 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec03-16 Transportation.docx Table 3.16-21: Year 2040 Buildout Peak-Hour Intersection Capacity Analysis (Without Sand and Gravel) Key Intersections Time Period Minimum Acceptable LOS (1) Existing Traffic Conditions (2) Year 2040 Buildout Without Project Traffic Conditions (3) Year 2040 Buildout With Project Traffic Conditions (4) Project Significant Impact (5) Year 2040 Buildout With Project With Mitigation ICU LOS ICU LOS ICU LOS Increase Yes/No ICU LOS 1 Cannon Street at Serrano Avenue AM D 0.847 D 0.960 E 0.962 E 0.002 No — — PM 0.912 E 1.314 F 1.314 F 0.000 No — — 2 Cannon Street at Taft Avenue AM D 0.983 E 0.872 D 0.873 D 0.001 No — — PM 0.869 D 0.879 D 0.881 D 0.002 No — — 3 Hewes Street at Villa Park Road AM D 0.742 C 0.634 B 0.637 B 0.003 No — — PM 0.627 B 0.826 D 0.833 D 0.007 No — — 4 Cannon Street at East Santiago Canyon Road AM D 0.749 C 0.832 D 0.837 D 0.005 No — — PM 0.739 C 0.856 D 0.863 D 0.007 No — — 5 Orange Park Boulevard at East Santiago Canyon Road AM D 0.838 D 0.790 C 0.798 C 0.008 No — — PM 0.881 D 0.755 C 0.762 C 0.007 No — — 6 Meads Avenue at East Santiago Canyon Road AM D 0.784 C 0.630 B 0.633 B 0.003 No — — PM 0.768 C 0.638 B 0.646 B 0.008 No — — 7 Newport Boulevard at East Santiago Canyon Road AM D 0.767 C 0.880 D 0.888 D 0.008 No — — PM 0.832 D 0.845 D 0.853 D 0.008 No — — 8 Jamboree Road at East Santiago Canyon Road AM D 0.641 B 0.790 C 0.799 C 0.009 No — — PM 0.647 B 0.844 D 0.854 D 0.010 No — — 9 Jamboree Road at Chapman Avenue/East Santiago Canyon Road AM D 0.533 A 0.748 C 0.756 C 0.008 No — — PM 0.845 D 0.911 E 0.918 E 0.007 No — —
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City of Orange—Trails at Santiago Creek Specific Plan Recirculated Draft EIR Transportation and Traffic FirstCarbon Solutions 3.16-115 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\12 - Recirc EIR\27650002 Sec03-16 Transportation.docx Table 3.16-22: Year 2040 Buildout Peak-Hour Intersection Capacity Analysis (With Sand and Gravel) Key Intersections Time Period Minimum Acceptable LOS (1) With Trip Credit Existing Traffic Conditions (2) Year 2040 Buildout Without Project Traffic Conditions (3) Year 2040 Buildout With Project Traffic Conditions (4) Project Significant Impact (5) Year 2040 Buildout With Project With Mitigation ICU LOS ICU LOS ICU LOS Increase Yes/No ICU LOS 1 Cannon Street at Serrano Avenue AM PM D 0.847 0.912 D E 0.960 1.314 E F 0.961 1.314 E F 0.001 0.000 No No — — — — 2 Cannon Street at Taft Avenue AM PM D 0.983 0.869 E D 0.872 0.879 D D 0.873 0.881 D D 0.001 0.002 No No — — — — 3 Hewes Street at Villa Park Road AM PM D 0.748 0.630 C B 0.634 0.826 B D 0.634 0.831 B D 0.000 0.005 No No — — — — 4 Cannon Street at East Santiago Canyon Road AM PM D 0.755 0.743 C C 0.832 0.856 D D 0.834 0.861 D D 0.002 0.005 No No — — — — 5 Orange Park Boulevard at East Santiago Canyon Road AM PM D 0.841 0.883 D D 0.790 0.755 C C 0.794 0.759 C C 0.004 0.004 No No — — — — 6 Meads Avenue at East Santiago Canyon Road AM PM D 0.787 0.769 C C 0.630 0.638 B B 0.635 0.645 B B 0.005 0.007 No No — — — — 7 Newport Boulevard at East Santiago Canyon Road AM PM D 0.770 0.834 C D 0.880 0.845 D D 0.884 0.852 D D 0.004 0.007 No No — — — — 8 Jamboree Road at East Santiago Canyon Road AM PM D 0.644 0.648 B B 0.790 0.844 C D 0.795 0.853 C D 0.005 0.009 No No — — — — 9 Jamboree Road at Chapman Avenue/East Santiago Canyon Road AM PM D 0.535 0.848 A D 0.748 0.911 C E 0.752 0.916 C E 0.004 0.005 No No — — — — 10 Orange Park Boulevard at Chapman Avenue AM PM D 0.418 0.530 A A 0.561 0.718 A C 0.563 0.719 C C 0.002 0.001 No No — — — — — Project Driveway—Nicky Way at East Santiago Canyon Road AM PM D — — — — — — — — 0.636 0.642 B — — — — — — — — Note: A significant impact would occur if the project causes ICU to increase by 0.010 or more. Source: Linscott, Law & Greenspan, Engineers, 2017.
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Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
Congestion Management Program
Impact TRANS-4: The project would not conflict with an applicable congestion management
program, including, but not limited to level of service standards and travel
demand measures, or other standards established by the county congestion
management agency for designated roads or highways.
Impact Analysis
East Santiago Canyon Road is a facility that is identified in the Orange County Congestion
Management Program. As discussed in Impacts TRANS-1 through TRANS-3, the proposed project
can mitigate all of its impacts associated with deficient traffic conditions on East Santiago Canyon
Road. Thus, no conflicts with the Congestion Management Plan would occur. Impacts would be less
than significant.
Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
Roadway Safety
Impact TRANS-5: The project may substantially increase hazards due to a design feature (e.g., sharp
curves or dangerous intersections) or incompatible uses (e.g., farm equipment).
Impact Analysis
Linscott, Law, & Greenspan evaluated the proposed access point on East Santiago Canyon Road for
safety and operational efficiency. The results are summarized as follows.
Site Access Evaluation
Access to the proposed project will be provided via one proposed full-access signalized driveway,
located directly opposite Nicky Way, along East Santiago Canyon Road. An internal network of
roadways would provide vehicular access to each individual dwelling unit.
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Table 3.16-25 summarizes the intersection operations at the proposed project driveway for Existing,
Near-Term (Year 2022), and Buildout (Year 2040) traffic conditions at completion and full occupancy
of the proposed project. Review of Table 3.16 -25 shows that the proposed project driveway is
forecast to operate at acceptable LOS D or better during the AM and PM peak-hours for Existing plus
Project, Year 2022 plus Project and Year 2040 plus Project traffic conditions. As such, project access
will be adequate. Motorists entering and exiting the project site will be able to do so comfortably,
safely, and without undue congestion.
Appendix D presents the existing plus project, Year 2022 plus project and Year 2040 plus project level
of service calculation worksheets for the proposed project driveway.
Table 3.16-25: Project Driveway Peak-Hour Levels of Service Summary
Project Driveway
Time
Period
Intersection
Control
Existing With
Project
Traffic Conditions
Year 2022 With
Project
Traffic Conditions
Year 2040 With
Project
Traffic Conditions
ICU LOS ICU LOS ICU LOS
Project Driveway/Nicky
Way at East Santiago
Canyon Road
AM
PM
5∅
Traffic
Signal
0.791
0.585
C
A
0.836
0.623
D
B
0.636
0.642
B
B
Note:
∅ = phase
Source: Linscott, Law & Greenspan, Engineers, 2017.
Mitigation Measure TRANS-5 requires the Applicant to improve project driveway/Nicky Way at East
Santiago Canyon Road, along with Cannon Street at Taft Avenue, to allow for safe and efficient
access to the proposed project prior to the issuance of the first certificate of occupancy. With the
implementation of mitigation, impacts would be less than significant.
Level of Significance Before Mitigation
Potentially significant impact
Mitigation Measures
MM TRANS-5 Prior to issuance of the first certificate of occupancy, the City of Orange shall verify
that the Applicant has made improvements to traffic circulation in the area and
ensured that adequate ingress and egress to the project site is provided, as follows:
• Project Driveway/Nicky Way at East Santiago Canyon Road:
- Construct the north leg of the intersection and provide one inbound lane and
two outbound lanes (i.e., one dedicated left turn lane and one shared
through/right-turn lane).
- Widen and/or restripe East Santiago Canyon Road to provide one eastbound left-
turn lane, one westbound right-turn lane and a third westbound through-lane.
- A five-phase signal has been installed with protected left-turn phasing in the
east-west direction and permissive phasing in the north-south direction.
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• Cannon Street at Taft Avenue:
- Widen and/or restripe Canon Street to provide a third northbound through
lane.
Level of Significance After Mitigation
Less than significant impact.
Emergency Access
Impact TRANS-6: The project would not result in inadequate emergency access.
Impact Analysis
The proposed project would take vehicular access from East Santiago Canyon Road via a full-access
signalized driveway aligned with Nicky Way. All internal roadways would comply with applicable Fire
Code requirements, including those that pertain to access for large emergency vehicles.
Additionally, the proposed project would not modify any surrounding roadways in a manner that
could impair emergency response or evacuation (road closures, lane narrowing, etc.). Therefore,
adequate emergency access would be provided. Impacts would be less than significant.
Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
Conflict with Alternative Transportation
Impact TRANS-7: The project would not conflict with adopted policies, plans, or programs regarding
public transit, bicycle, or pedestrian facilities, or otherwise decrease the
performance or safety of such facilities.
Impact Analysis
This impact will address conflicts with alternative transportation, including public transit, bicycles,
and pedestrians.
Public Transit
The closest OCTA bus stop is located approximately 2 miles from the project site at East Santiago
Canyon College. At the time of this writing, there are no plans to introduce bus service to the
segments of East Santiago Canyon Road or Cannon Street that abut the project site. Furthermore,
the proposed project does not have any features that preclude or otherwise impede bus service
should it be proposed in the future. Impacts would be less than significant.
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Bicycles and Pedestrians
The Class I Santiago Creek Bike Path follows the Santiago Creek corridor before terminating at
Cannon Street. The proposed project would extend the trail through the project site to Santiago
Oaks Regional Park. This would close a gap in the regional bicycle and pedestrian network.
Additionally, the Santiago Creek Trail along the north bank of Santiago Creek within the project site
would remain unchanged. Furthermore, a network of trails would be developed within the project
site that would provide linkages between the aforementioned trails and street frontages.
Class II bicycle lanes currently exist along the segments of East Santiago Canyon Road or Cannon
Street that abut the project site, and these facilities would be maintained by the proposed project.
In addition, the Class II bicycle lanes will be maintained with the proposed widening improvements
along East Santiago Canyon Road and Cannon Street.
An off-street recreational trail would be installed along the project frontage with East Santiago Canyon
Road and connect to an internal network of pedestrian facilities within the residential portion of the
project site. The existing sidewalk along the Cannon Street frontage would be maintained.
Note that there are no existing sidewalks along the Villa Park Landfill frontage with either East
Santiago Canyon Road or Cannon Street. The landfill is owned by the County of Orange, and,
therefore, the Applicant does not have the legal ability to install sidewalks along its street frontage.
As such, this existing condition would remain unchanged. Impacts would be less than significant.
Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
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3.17 - Tribal Cultural Resources
3.17.1 - Introduction
This section describes the existing Tribal Cultural Resources (TCRs) setting and potential effects from
project implementation on the site and its surrounding area. Conclusions are based on initial
consultation with the Native American Heritage Commission (NAHC) and subsequent consultation
with tribal representatives identified by the NAHC who may have interest in or additional
information on TCRs that may be impacted by project development. The review presents the
methods employed to identify TCRs, assesses potential impacts to those resources, and presents
recommendations to address potential impacts.
3.17.2 - Environmental Setting
Overview
The term “cultural resources” encompasses historic, archaeological, and paleontological resources,
and burial sites. Below is a brief summary of each component:
• Historic Resources: Historic resources are associated with the recent past. In California,
historic resources are typically associated with the Spanish, Mexican, and American periods in
the State’s history and are generally less than 200 years old.
• Archaeological Resources: Archaeology is the study of prehistoric human activities and
cultures. Archaeological resources are generally associated with indigenous cultures.
• Paleontological Resources: Paleontology is the study of plant and animal fossils.
• Burial Sites: Burial sites are formal or informal locations where human remains, usually
associated with indigenous cultures, are interred.
Cultural Setting
Prehistory
The ultimate purpose of establishing a cultural sequence is to allow for the meaningful comparison
of material culture attributes on an intra- and inter-site basis, and to provide the basis for culture-
model building. To this end, regional archaeologists generally follow Wallace’s Southern California
Format (1955 and 1978) for discussing the prehistoric chronology for the project area. However, the
established chronologies are often augmented or even abandoned. For example, Fagan (2003) does
not use the traditional archaeological cultural sequences for his regional analysis, instead he
described the stages as generalized models related to recent environmental change and socio-
economic models, all associated with an ever-changing environment. Thusly, it should be noted that
all of the presented cultural sequences are regularly challenged, as are the meanings of the
individual frames of reference. Wallace’s prehistoric format is as follows:
• Early Period (before 6000 B.C.)
• Milling Stone (6000 to 3000 B.C.)
• Intermediate (3000 B.C. to A.D. 500)
• Late Prehistoric (A.D. 500 to A.D. 1769).
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Wallace also argued (Wallace, in Heizer 1978) that the stages prior to 2000 B.C> in southern
California could be assigned to:
• San Dieguito Period (Period I: 9000 to 6000 B.C.)
• Standard Millingstone Period (Period II: 6000 to 3000 B.C.)
• Modifies Millingstone Period (Period III: 3000 to 2000 B.C.).
Warren (1968) uses the following terms to subdivide the periods:
• San Dieguito Tradition (Before 5500 B.C.)
• Encinitas Tradition (5500 B.C. to A.D. 600)
• Shoshonean Tradition (A.D. 600 to A.D. 1769)
The Late Period has been further subdivided into the San Luis Rey I (A.D. 500 to A.D. 1500) and the
San Luis Rey II (post 1500). The difference between the latter two is the introduction of locally made
brownware pottery, the first indigenous pottery in southern California (Cameron 1999).
Early Period (before 6000 B.C.)
Beginning with the first human presence in California, prehistoric artifacts and cultural activities
appear to represent a big-game hunting tradition. Very few sites from the Early Period exist,
especially in inland areas. Of the Early Period sites that have been excavated and dated, most exhibit
a refuse assemblage suggesting short-term occupation. Such sites have been detected in caves and
around fluvial lakes fed by streams that existed near the end of the last glaciation. Chipped stone
tools at these sites are surmised to reflect a specialized tool kit used by hunters. Large-stemmed
bifaces are common. Millingstones and dart points are not part of the Early Period tool assemblage.
Millingstone Period (6000 to 3000 B.C.)
The onset of the Millingstone Period appears to correspond with an interval of warm and dry
weather known as the Altithermal (Wallace 1978). Artifact assemblages begin to reflect an emphasis
on plant foods and foraging subsistence systems, as evidenced by the grinding tools found at these
sites, and including choppers and scraper planes. Notably, there is a reduced number of large
bifaces in the excavated assemblages. Sites are occupied for a greater duration than Early Period
sites, based on an increase in occupational debris. Although numerous Millingstone sites have been
identified in Orange County, few are actually dated. The best understood of these is CA-ORA-64,
which has been radiometrically dated to about 6000 B.C. (Breece et al. 1988 and 1989). Excavations
at this site located near Newport Bay, have been essential to the formulation of local research
models (Koerper 1981). Research at this site suggests a settlement-subsistence system during the
Millingstone Period reflecting a semi-sedentary lifestyle. The regional distribution of Millingstone
sites reflects the theory that aboriginal groups may have followed a modified central-based
wandering settlement pattern. Under this model, large groups would have occupied a base camp for
a portion of the year, with smaller bands occupying subsidiary camps in order to exploit resources
not generally available near the base camp. Sedentism apparently increased in areas possessing an
abundance of resources that were available for longer periods. Arid inland regions would have
provided a seasonally and spatially dispersed resource base, restricting sedentary occupation,
compared to the coastal areas. Generally, the Millingstone assemblage in the Los Angeles basin is
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typified by large and heavy deep-basin metates, wedge-shaped manos and large choppers and
scrapers. Flaked lithic tools are slightly larger and cruder than in later periods, and cogstones begin
to appear.
Intermediate Period (3000 B.C. to A.D. 500)
Dating between roughly 3000 B.C. and A.D. 500, the Intermediate Period represents a slow
technological transition, which is presumably related to the slowly drying and warming climate. Site
artifact assemblages retain many attributes of the Millingstone Period. Technologically speaking,
these sites are difficult to distinguish from earlier sites in the absence of radiometric dates.
Additionally, these sites generally contain a reduced number of large-stemmed or notched projectile
points but with an increase in portable mortars and pestles. The lack of large points combined with
the mortars and pestles suggest that the indigenous populations may have preferred harvesting,
processing, and consuming acorns and other seeds over hunting. Because of a general lack of data,
neither the settlement and subsistence systems nor the cultural evolution of this period is well
understood. It has been proposed by some researchers that group sedentarism increased with the
exploitation of storable, high-yield plant food resources such as acorns. The duration and intensity
of occupation at base camps increased during this period, especially in the later part of the period.
Generally, the Intermediate Period artifact assemblage in the Los Angeles basin is vague, including
elements of the Late Prehistoric Period and Millingstone Period, such as heavy grinding implements.
A higher percentage of projectile points occur and smaller chipped stone tools are used.
Late Prehistoric Period (A.D. 500 to A.D. 1769)
Extending from about A.D. 500 to Spanish contact in A.D. 1769, the Late Prehistoric Period reflects
an increased sophistication and diversity in technology. Village sites are common. Late assemblages
characteristically contain small projectile or dart points, which imply the use of the bow and arrow.
In addition, assemblages include steatite bowls, asphaltum artifacts, grave goods, and elaborate
shell ornaments. Use of bedrock milling stations is purported to have been widespread during this
period, as it was in the previous period. Increased hunting efficiency and widespread exploitation of
acorns provided reliable and storable food resources. Pottery, previously traded into the area, is
made locally during the latest stage of this Period and is of simple construction technology.
Cameron (1999) names several village sites in inland Orange County that are located within
Gabrieliño territory. These exhibited pottery, which suggests that the pre-contact Gabrieliño may
have used pottery as a part of their lifestyle. One of these Late Prehistoric Period sites, Tomato
Springs (CA-Ora-244), has been the subject of numerous excavations (Cottrell 1985) that have
continued into the 21st century.
Native American Background
The project area is situated within an area that has been ethnographically mapped as the Gabrieliño
traditional use area. The Gabrieliño tribal territory is mapped as extending north from Aliso Creek to
just beyond the Topanga Canyon along the Pacific Coast, and inland to the City of San Bernardino
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(Bean and Smith 1978). Their territory would have included portions of the Santa Ana River, and
several islands, and diffusion of ideas between neighboring groups, such as the Juaneño to the south.
The Gabrieliño
Kroeber (1925) and Bean and Smith (1978) form the primary historical references for this tribal
group. The arrival of Spanish explorers and the establishment of missions and outposts during the
eighteenth century ended the prehistoric period in California. At this time, traditional Gabrieliño
society began to fragment as a result of foreign diseases and the mass removal of local Indian
groups to the Mission San Gabriel and Mission San Juan Capistrano. The Gabrieliño spoke a
language that belongs to the Cupan group of the Takic subfamily of the Uto-Aztecan language family
(a language family that includes the Shoshonean groups of the Great Basin). The total Gabrieliño
population in about 1770 AD was roughly 5,000 persons, based on an estimate of 100 small villages,
with approximately 50 to 200 people per village. Their range is generally thought to have been
located along the Pacific coast from Malibu to San Pedro Bay, south to Aliso Creek, then east to
Temescal Canyon, then north to the headwaters of the San Gabriel River. Also included were
several islands, including Catalina. This large area encompasses the City of Los Angeles, much of
Rancho Cucamonga, Corona, Glendale, and Long Beach. By 1800, most traditional Gabrieliños had
either been killed, or subjugated by the Spanish. The first modern social analyses of Gabrieliño
culture took place in the early part of the twentieth century (Kroeber 1925). By this time,
acculturation and disease had devastated this group, and the population studied was a remnant of
their pre-contact form. Nonetheless, the early ethnographers viewed the Gabrieliño as a chief-
oriented society of semi-sedentary hunter-gatherers. Influenced by coastal and interior
environmental settings, their material culture was quite elaborate and consisted of well-made
wood, bone, stone, and shell items. Included among these was a hunting stick made to bring down
numerous types of game. Located in an area of extreme environmental diversity, large villages may
have been permanent, such as that found on or near Red Hill in Rancho Cucamonga, with satellite
villages utilized seasonally. Their living structures were large, domed, and circular thatched rooms
that may have housed multiple families. The society exhibited ranked individuals, possibly chiefs,
who possessed a much higher level of economic power than unranked persons.
Historic Background
City of Orange
The earliest European explorers to enter the Alta California region were the Spanish who navigated
along the Pacific coast during the 17th and 18th centuries. During the latter portion of the 18th
century, the Spanish sent Father Junipero Serra to Alta California to create a chain of Missions and
Mission outposts to bring Christianity to the indigenous population, and create a foundation for
colonization of the region. Between 1769 and 1823, Spanish explorers and missionaries established
21 missions, four presidios, and four pueblos between San Diego and Sonoma. Also during this
period, American explorations occurred when trappers traveled west in search of abundant sea otter
and beaver pelts. In 1805, when Lewis and Clark crossed the Rocky Mountains and continued on to
the Pacific coast, they reported that the area was richer in beaver and otter than any other country
on earth. The fur trappers were close behind the explorers, and by 1840, the beaver was over-
exploited and was no longer worth hunting (Bean and Rawls 1983).
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By the early decades of the 19th century, the Missions began establishing ranchos for the purpose of
expanding their agricultural holdings. According to the history provided on the City of Orange
website, the first landowner in this area was a retired Spanish soldier named Juan Pablo Grijalva.
Grijalva was granted permission to ranch “the place of the Arroyo de Santiago” by the Spanish
colonial government in 1801. This land ran from the Santa Ana River and the foothills above Villa
Park, to the sea at Newport Beach. Though Grijalva lived in San Diego, he built an adobe ranch
house on what is now Hoyt Hill, at the corner of Hewes and Santiago Canyon Road (City of Orange
History 2008).
Following Grijalva’s death, the rancho was taken over by his son-in-law, Jose Antonio Yorba, and
grandson, Juan Pablo Peralta. These lands then became known as the Rancho Santiago de Santa
Ana, and were granted to Yorba and Peralta on July 1, 1810. This 75,000-acre grant was made by
Governor Arrellaga, and encompassed the majority of the Santa Ana Canyon of eastern Orange
County, as well as much of northern Orange County and Newport Bay (Lech 2004). The children and
grandchildren of Yorba and Peralta moved to various parts of the sizable rancho, and through time,
the descendants absorbed additional acreage. The family holdings eventually encompassed lands
extending from Riverside to the ocean.
In the early 1860s, Leonardo Cota, an extended family member, borrowed money from the largest
landowner in southern California. Abel Stearns lent Cota money, and held his share of the Rancho as
collateral. When Cota defaulted on his loan in 1866, Stearns filed a lawsuit in the Los Angeles
Superior Court to demand a partition of the land, in order to claim Cota’s section. It took two years
to determine how much land was due to each family member, and the rancho was then divided into
1,000 units for the heirs and the claimants in the lawsuit (City of Orange 2008).
The Los Angeles attorneys involved in the lawsuit, Alfred Chapman and Andrew Glassell, received a
portion of the Rancho Santiago de Santa Ana as payment for their services. They quickly subdivided
their land into a 1-square-mile town, with surrounding 10-acre farm lots. This community was
named Richland until 1873, when the town’s application for a post office was denied due to the
existence of another Richland in Sacramento County. According to local legend, Richland was
renamed Orange after a poker game where Glassell, Chapman, and two other men allowed the
winner to decide the new town name. Though the winner is not recorded, Richland was named
Orange in January of 1875.
By 1873 Richland/Orange was beginning to grow by opening the first local store, named Fisher
Brothers, a civic organization, called the Orange Grange, and the first church, which was of the
Methodist Episcopal denomination. This was also the year that local farmers began planting orange
groves in the area. The area then continued to grow when the Southern Pacific Railroad built a
depot in Orange, in 1880, and again with the arrival of the Santa Fe railroad in 1887.
During the land boom of the 1880s, Orange attracted many travelers, founded local newspapers,
build a public library, a bank and incorporation occurred on April 6, 1888. When the boom ended,
local farmers continued to plant orange trees. By 1929, Orange County produced more than $12
million from the sale of oranges. However, with the depression and inclement weather in the 1930s,
the industry fell into economic decline (City of Orange 2008).
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By the 1950s, a second real estate boom occurred, and large tracts of houses were constructed into
the 1970s. Thereafter the City of Orange continued to grow at a steady pace, and development is
still occurring, especially at the eastern edge of the city.
Historic Era Aerial Photograph
FCS (formerly MBA) additionally conducted a historic era aerial photograph review, from an image
taken from the National Imagery Program for Orange County. This photograph was taken on
December 12, 1952. During the historic era, the project area was part of an extensive sand and
gravel mining operation, which began in approximately 1952 (LSA 1992). This process removed sand
and gravel from alluvial deposits, and then processed the sediments in an open area located to the
south of Santiago Creek. Evidence of the surface mi ning activity is observable in this photograph in
the central portion of the project area, to the south of Santiago Creek. In this area, there is an
absence of vegetation, multiple piles of soil, and numerous dirt tracks and/or unimproved access
roads. Santiago Creek borders the surface mining area to the north, and numerous citrus groves are
found to the southeast, south, and southwest along Santiago Canyon Road. In the southwestern
corner of the project area, to the north of Santiago Canyon Road, and at the southern terminus of a
windrow of eucalyptus trees is a clearing with apparent structures. These structures are situated
between citrus groves, and appear to coincide with the location of a concrete foundation and an
asphalt and concrete lot recorded during the pedestrian survey as Site 001. Additional citrus groves
are found within the project area boundaries, to the north of Santiago Creek. These citrus groves
appear to cover the recorded location of prehistoric-age site CA-Ora-369, which was detected during
the cultural resources literature search at the South Central Coastal Information Center (SCCIC).
3.17.3 - Regulatory Framework
State
California Assembly Bill 52
Assembly Bill 52 (AB 52) was signed into law on September 25, 2014, and provides that any public or
private “project with an effect that may cause a substantial adverse change in the significance of a
tribal cultural resource is a project that may have a significant effect on the environment.” Tribal
Cultural Resources include “[s]ites, features, places, cultural landscapes, sacred places, and objects
with cultural value to a California Native American tribe that are eligible for inclusion in the California
Register of Historical Resources or included in a local register of historical resources.” Under prior law,
Tribal Cultural Resources were typically addressed under the umbrella of “cultural resources,” as
discussed above. AB 52 formally added the category of “tribal cultural resources” to CEQA, and
extends the consultation and confidentiality requirements to all projects, rather than just projects
subject to Senate Bill (SB) 18 as discussed above.
The parties must consult in good faith, and consultation is deemed concluded when either: (1) the
parties agree to measures to mitigate or avoid a significant effect on a tribal cultural resource (if such
a significant effect exists); or (2) when a party concludes that mutual agreement cannot be reached.
Mitigation measures agreed upon during consultation must be recommended for inclusion in the
environmental document. AB 52 also identifies mitigation measures that may be considered to
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avoid significant impacts if there is no agreement on appropriate mitigation. Recommended
measures include:
• Preservation in place
• Protecting the cultural character and integrity of the resource
• Protecting the traditional use of the resource
• Protecting the confidentiality of the resource
• Permanent conservation easements with culturally appropriate management criteria.
3.17.4 - Methodology
NAHC Sacred Lands File Record Search and Tribal Consultation
On October 6, 2008, FCS sent a letter to the NAHC in an effort to determine whether any sacred sites
are listed in its Sacred Lands File for this portion of the City of Orange. FCS’s efforts were associated
with CEQA-level information scoping only. The response from the NAHC was received on October
10, 2008. To ensure that all potential Native American resources are adequately addressed, letters
to each of the 12 listed tribal contacts were sent on November 3, 2008. FCS received an emailed
response from John Tommy Rosas, the Tribal Administrator for the Tongva Ancestral Territorial Tribal
Nation on November 3, 2008. Mr. Rosas indicated that the Tribe objected to the project, and that
development in that area violated their indigenous rights. He cited the project location along
Santiago Creek as an especially sensitive issue. Further, he noted the need for additional
consultation efforts as required by law, including Section 106 of the National Historic Preservation
Act (NHPA) and SB 18. He also requested additional information on the proposed project. FCS
Project Archaeologist Jennifer M. Sanka replied to this email, providing additional information on the
Conceptual Development Plan and asking for any information that could be included in the Cultural
Resources Assessment regarding the sanctity of Santiago Creek. This information was requested, as
FCS was aware that Santiago Creek and adjacent environs would be considered a culturally sensitive
area to local Tribes. This assumption is based upon the presence of numerous prehistoric-age sites
along the Creek and a known reliance on its resources by the indigenous people as outlined in
ethnographic studies.
Updated Native American Consultation
An updated Native American Consultation for the Rio Santiago Project was prepared by BCR
Consulting, dated May 12, 2011. Subsequently, on March 3, 2017, the City contacted three tribes
pursuant to AB 52. Each tribe was notified in writing of the proposed project and invited to consult
with the City. The letters were sent via certified mail; to date, the City has not received any
responses.
Pedestrian Survey
A pedestrian survey was conducted on the property on December 1, 2017. The property appeared
to be in the same condition as described in the 2008 survey report. Most of the property has been
heavily impacted from sand and gravel activities. In the northernmost section of the property,
immediately south of Mabury Street, is a relatively narrow strip of heavily vegetated land. It is in
that general area where CA-ORA-369 was originally recorded and ultimately tested and found
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ineligible for the CRHR. An intensive effort was made to see if any remains of the site were present.
None were observed. The 2008 investigation recorded an old concrete foundation and adjacent
asphalt and gravel lot. The site was not indicated on the topographic records search map at the
SCCIC, and no record of the site is on file with SCCIC. This is likely the fenced lot access via
Jamestown off Santiago. However, at the time of its recordation, it was deemed insignificant and no
further work was recommended.
3.17.5 - Thresholds of Significance
According to Appendix G, Environmental Checklist, of the CEQA Guidelines, tribal cultural resources
impacts resulting from the implementation of the proposed project would be considered significant
if the project would cause a substantial adverse change in the significance of a tribal cultural
resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural
landscape that is geographically defined in terms of the size and scope of the landscape, sacred
place, or object with cultural value to a California Native American tribe, and that is:
a. Listed or eligible for listing in the California Register of Historical Resources, or in a local
register of historical resources as defined in Public Resources Code section 5020.1(k), or
b. A resource determined by the lead agency, in its discretion and supported by substantial
evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public
Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public
Resource Code Section 5024.1, the lead agency shall consider the significance of the
resource to a California Native American tribe.
3.17.6 - Project Impacts and Mitigation Measures
This section discusses potential impacts associated with the development of the construction and
operation and provides feasible mitigation measures where appropriate.
Eligibility for California Register Listing
Impact TCR-1: The project would not cause a substantial adverse change in the significance of a
tribal cultural resource listed or eligible for listing in the California Register of
Historical Resources, or in a local register of historical resources as defined in
Public Resources Code section 5020.1(k).
Impact Analysis
On July 1, 2015, an amendment to Public Resources Code 21074 took effect, which created a new
category of cultural resources: “Tribal Cultural Resources.” These resources are defined as:
• Sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a
California Native American tribe that are either of the following:
- Included or determined to be eligible for inclusion in the California Register of Historical
Resources (Analyzed in Impact TCR-1).
- Included in a local register of historical resources.
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• A resource determined by the lead agency, in its discretion and supported by substantial
evidence, to be significant (Analyzed in Impact TCR-2).
The project site is not listed on any national, state, or local registers of historic places (including
those for tribal cultural resources). Additionally, no tribal cultural resources were observed during
the field survey. Because the project site contains undeveloped land, it does not possess any
attributes that would make it eligible for such a listing. Impacts would be less than significant.
Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
Eligibility as Determined by Lead Agency
Impact TCR-2: The project would not cause a substantial adverse change in the significance of a
tribal cultural resource determined by the lead agency, in its discretion and
supported by substantial evidence, to be significant pursuant to criteria set forth
in subdivision (c) of Public Resources Code Section 5024.1.
Impact Analysis
The City of Orange sent a letter to the following tribes in March 2017 notifying them of the proposed
project and advising that any tribal consultation request should be made within 30 days:
• San Gabriel Band of Mission Indians
• Torres Martinez Desert Cahuilla Indians
• Gabrieleno Band of Mission Indians
To date, the City of Orange has not received a tribal consultation request from any of the tribes and,
therefore, there is no basis for the City to conclude that the project site supports tribal cultural
resources. Impacts would be less than significant.
Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
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3.18 - Utilities and Service Systems
3.18.1 - Introduction
This section describes the utilities and service systems setting and potential effects from project
implementation on the site and its surrounding area. Descriptions and analysis in this section are
based on information provided in the Preliminary Hydrology and Hydraulic Report prepared by
Fuscoe Engineering, which is provided as Appendix K. Additional information was provided by the
City of Orange website, the City of Orange 2015 Urban Water Management Plan, the Orange County
Sanitation District website, the California Department of Resources Recovery and Recycling website,
the Edison International (Southern California Edison) 10-K Annual Report, and the Sempra Energy
(SoCalGas) 10-K Annual Report.
3.18.2 - Environmental Setting
Potable Water
The City of Orange Water Division provides potable water service to 36,347 customer accounts
within the Orange city limits and nearby areas outside the city limits. Approximately 97 percent of
customer accounts are within the Orange city limits.
Water System
The City’s water system consists of 15 active groundwater wells, 16 reservoirs (with more than 40
million gallons of storage capacity), 16 pump stations, and 450 miles of pipeline.
Water Supply
The City of Orange obtains potable water from two primary sources (groundwater and imported)
that account for 96 percent of supply and an additional source (surface) that accounts for 4 percent
of supply. Groundwater is pumped from 15 active wells located throughout the City. Imported
water is obtained from Metropolitan Water District (Metropolitan) via Municipal Water District of
Orange County (MWDOC) and is delivered to the City through eight water connections. Surface
water from Irvine Lake is obtained from Serrano Water District.
The City of Orange 2015 Urban Water Management Plan provides detailed descriptions of
groundwater and imported water, which are summarized briefly in the following section. Recycled
water is not currently available to the service area, nor is it contemplated to be available in the
future by the 2015 Urban Water Management Plan.
Groundwater
Historically, local groundwater has been the cheapest and most reliable source of supply for the City.
The City currently relies on approximately 20,623 acre-feet/year of groundwater from the Orange
County (OC) Basin.
The OC Basin underlies the northerly half of Orange County beneath broad lowlands. The OC Basin
is managed by Orange County Water District (OCWD) and covers an area of approximately 350
square miles, bordered by the Coyote and Chino Hills to the north, the Santa Ana Mountains to the
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northeast, and the Pacific Ocean to the southwest. The OC Basin boundary extends to the Orange
County-Los Angeles Line to the northwest, where groundwater flows across the county line into the
Central Groundwater Basin of Los Angeles County. The total thickness of sedimentary rocks in the
OC Basin is over 20,000 feet, with only the upper 2,000 to 4,000 feet containing fresh water. The
Pleistocene or younger aquifers comprising this Basin are over 2,000 feet deep and form a complex
series of interconnected sand and gravel deposits. The OC Basin’s full volume is approximately 66
million acre-feet.
Groundwater levels are managed within a safe basin operating range to protect the long-term
sustainability of the OC Basin and to protect against land subsidence. OCWD regulates groundwater
levels in the OC Basin by regulating the annual amount of pumping.
The OC Basin is not adjudicated; as such, pumping from the OC Basin is managed through a process
that uses financial incentives to encourage groundwater producers to pump a sustainable amount of
water. The framework for the financial incentives is based on establishing the basin production
percentage, the percentage of each Producer’s total water supply that comes from groundwater
pumped from the OC Basin. Groundwater production at or below the basin production percentage
is assessed a Replenishment Assessment. While there is no legal limit as to how much an agency
pumps from the OC Basin, there is a financial disincentive to pump above the basin production
percentage. Agencies that pump above the basin production percentage are charged the
Replenishment Assessment plus the Basin Equity Assessment, which is calculated so that the cost of
groundwater production is greater than MWDOC’s full service rate. The Basin Equity Assessment
can be increased to discourage production above the basin production percentage. The basin
production percentage is set uniformly for all producers by OCWD on an annual basis.
Imported Water
The City supplements its local groundwater with imported water purchased from Metropolitan
through MWDOC. Imported water represents approximately 30 percent of the City’s total water
supply. Metropolitan’s principal sources of water are the Colorado River via the Colorado River
Aqueduct and the Lake Oroville watershed in Northern California through the State Water Project.
The raw water obtained from these sources is, for Orange County, treated at the Robert B. Diemer
Filtration Plant located north of Yorba Linda. Typically, the Diemer Filtration Plant receives a blend of
Colorado River water from Lake Mathews through the Metropolitan Lower Feeder and State Water
Project water through the Yorba Linda Feeder.
2015 Water Supply
The 2015 Urban Water Management Plan indicated that actual water supplies totaled 28,643 acre-
feet in 2015. Table 3.18-1 summarizes the 2015 actual supply sources.
Table 3.18-1: Actual Water Supply (2015)
Source Acre-Feet
Groundwater 20,372
Purchased or Imported Water 6,514
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Table 3.18-1 (cont.): Actual Water Supply (2015)
Source Acre-Feet
Surface Water 1,757
Total 28,643
Source: City of Orange, 2016.
Long-Term Water Supply
The 2015 Urban Water Management Plan projects future water supplies and demand through 2040.
Table 3.18-2 summarizes the projections.
Table 3.18-2: Long-Term Water Supply Projections
Source
Year
2020 2025 2030 2035 2040
Groundwater 19,600 20,650 20,650 20,650 20,650
Purchased or Imported Water 7,200 7,650 7,650 7,650 7,650
Surface 1,200 1,200 1,200 1,200 1,200
Total 28,000 29,500 29,500 29,500 29,500
Source: City of Orange, 2016.
Wastewater
Wastewater service in the City of Orange is provided by two public agencies: the City of Orange
Public Works Department, which provides local collection services; and OCSD, which provides
regional collection, treatment, and disposal services.
City of Orange
The City maintains and operates pipeline 315 miles of sewer pipeline. The City discharges effluent
into OCSD regional trunk lines.1
Orange County Sanitation District
OCSD is a public agency that provides wastewater collection, treatment, and disposal services for
approximately 2.6 million people within a 479-square-mile service area within central and northwest
Orange County. OCSD is a special district that is governed by a Board of Directors consisting of local
elected officials from jurisdictions within the service area.
1 OCSD maintains and operates 386 miles of trunk line in its service area.
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Treatment Plants
OCSD operates two treatment plants: Plant No. 1 in Fountain Valley and Plant No. 2 in Huntington
Beach.
Plant No. 1 provides secondary treatment and has a primary treatment capacity of 198 million gallons
per day (mgd) and a secondary treatment capacity of 110 mgd. The plant treats approximately 130
mgd. All of the treated effluent from Plant No. 1 is piped to OCWD for further processing for the
Groundwater Replenishment Program, which involves groundwater recharge along the Santa Ana
River.
Plant No. 2 provides secondary treatment and has a primary treatment capacity of 168 mgd and a
secondary treatment capacity of 90 mgd. The plant treats approximately 100 mgd. All of the treated
effluent from Plant No. 2 is discharged into the Pacific Ocean via an outfall consisting of a 10-foot
diameter pipeline that extends 5 miles from shore to the point approximately 200 feet below the
ocean surface.
Storm Drainage
The City of Orange Public Works Department and the Orange County Flood Control District oversee
stormwater drainage within the Orange city limits. The municipal storm drainage system consists of
an integrated system of curbside gutters, catch basins, drainage ditches, man-made channels, and
creeks. Stormwater is managed pursuant to the National Pollutant Discharge Elimination System
(NPDES) municipal stormwater permit issued on May 22, 2009 (Order No. R8-2009-0030) by the
Santa Ana Regional Water Quality Control Board (RWQCB).
The project site is located in the Santiago Creek Watershed, which is tributary to the Santa Ana River.
The Handy Creek storm drain operated by the Orange County Flood Control District is located
underground in the central portion of the project site. The storm drain enters the project site from
the south at the intersection of N. Nicky Way/E. Santiago Canyon Road. The storm drain conveys
stormwater collected in areas south of E. Santiago Canyon Road into Santiago Creek. Within the
project site, the Handy Creek storm drain accepts runoff from the eastern portion of the site via
several inlets. Runoff from other portions sheet flow to Santiago Creek or pond on-site and
percolate into the soil.
An unnamed storm drain located in the northwestern portion of the project site conveys stormwater
collected in the Mabury Ranch neighborhood directly into Santiago Creek. Note that the project site
does not directly discharge runoff into either storm drain.
Solid Waste
CR&R Incorporated provides franchise solid waste collection to residential and commercial
customers in Orange. Solid waste collected in Orange is transported to the CR Transfer and Material
Recovery Facility in Stanton for processing.
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Landfills
Non-recoverable solid waste from Orange is disposed of at the three landfills listed in Table 3.18-3.
As shown in the table, the landfills have 384.7 million cubic yards of combined remaining capacity.
Table 3.18-3: Landfill Summary
Facility Location
Permitted Daily
Throughput (tons)
Cubic Yards
Permitted
Capacity
Remaining
Capacity
Frank Bowerman Sanitary Landfill Irvine 11,500 266.0 million 205.0 million
Olinda Alpha Sanitary Landfill Brea 8,000 148.8 million 34.2 million
El Sobrante Landfill Corona 16,054 184.9 million 145.5 million
Total Remaining Capacity 384.7 million
Source: California Department of Resources Recovery and Recycling, 2016.
Energy
Southern California Edison (SCE) provides electrical service and Southern California Gas Company
(SoCalGas) provides natural gas service to customers in the City of Orange.
Electricity
SCE, a unit of Edison International, provides electricity to approximately 5 million metered customers
within a 50,000-square-mile service area of Southern California. SCE obtains electricity from a
variety of sources, including its own generation plants and purchased power from outside sources.
SCE has an ownership stake in the Palo Verde Nuclear Generating Station (Arizona) and owns the Big
Creek Hydroelectric System (Fresno County). SCE purchases electricity from a variety of outside
sources, including natural gas, wind, geothermal, solar, and biomass generation facilities. SCE is
currently in the process of implementing several major transmission system improvements in its
service area to meet the electrical needs of planned growth.
Natural Gas
SoCalGas, a unit of Sempra Energy, provides natural gas service to 5.9 million metered customers
within an approximately 20,000-square-mile service area located throughout Central and Southern
California, excluding San Diego County, Long Beach, and the desert area of San Bernardino County.
(The population of the service area is estimated to be 21.6 million.) SoCalGas has interstate pipeline
capacity contracts with El Paso Natural Gas Company, Transwestern Pipeline Company, Gas
Transmission Northwest, Pacific Gas and Electric Company, and Kern River Gas Transmission
Company to supply natural gas. The utility’s system consists of 2,964 miles of transmission and
storage pipelines, 49,874 miles of distribution pipelines, and 47,413 miles of service pipelines.
SoCalGas operates four underground natural gas storage reservoirs with a combined working
capacity of 137 billion cubic feet.
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3.18.3 - Regulatory Framework
California Urban Water Management Planning Act
The Urban Water Management Planning Act (California Water Code Sections 10610–10656) requires
that all urban water suppliers with at least 3,000 customers prepare urban water management plans
and update them every 5 years. The act requires that urban water management plans include a
description of water management tools and options used by that entity that will maximize resources
and minimize the need to import water from other regions. Specifically, urban water management
plans must:
• Provide current and projected population, climate, and other demographic factors affecting
the supplier’s water management planning;
• Identify and quantify, to the extent practicable, the existing and planned sources of water
available to the supplier;
• Describe the reliability of the water supply and vulnerability to seasonal or climatic shortage;
• Describe plans to supplement or replace that source with alternative sources or water
demand management measures;
• Describe the opportunities for exchanges or transfers of water on a short-term or long-term
basis (associated with systems that use surface water);
• Quantify past and current water use;
• Provide a description of the supplier’s water demand management measures, including
schedule of implementation, program to measure effectiveness of measures, and anticipated
water demand reductions associated with the measures; and
• Assess the water supply reliability.
Pursuant to the Urban Water Management Planning Act, the City of Orange maintains an Urban
Water Management Plan.
Model Water Efficient Landscape Ordinance
The Model Water Efficient Landscape Ordinance was adopted by the Office of Administrative Law in
September 2009, and requires local agencies to implement water efficiency measures as part of its
review of landscaping plans. Local agencies can either adopt the Model Water Efficient Landscape
Ordinance or incorporate provisions of the ordinance into its own code requirements for
landscaping. For new landscaping projects of 2,500 square feet or more that require a discretionary
or ministerial approval, the applicant is required to submit a detailed “Landscape Documentation
Package” that discusses water efficiency, soil management, and landscape design elements.
California Integrated Waste Management Act
To minimize the amount of solid waste that must be disposed of by transformation and land
disposal, the State Legislature passed Assembly Bill (AB) 939, the California Integrated Waste
Management Act of 1989, effective January 1990. The legislation required each local jurisdiction in
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the State to set diversion requirements of 25 percent in 1995 and 50 percent in 2000; established a
comprehensive statewide system of permitting, inspections, enforcement, and maintenance for solid
waste facilities; and authorized local jurisdictions to impose fees based on the types or amounts of
solid waste generated. In 2007, amendments to the California Integrated Waste Management Act
introduced a new per capita disposal and goal measurement system that moves the emphasis from
an estimated diversion measurement number to using an actual disposal measurement number as a
per capita disposal rate factor. As such, the new disposal-based indicator (pounds per person per
year) uses only two factors: a jurisdiction’s population (or in some cases, employment) and its
disposal as reported by disposal facilities.
California Public Utilities Commission
The California Public Utilities Commission (CPUC) regulates privately owned telecommunication,
electric, natural gas, water, railroad, rail transit, and passenger transportation companies. It is the
responsibility of the CPUC to (1) assure California utility customers safe, reliable utility service at
reasonable rates; (2) protect utility customers from fraud; and (3) promote a healthy California
economy. The Public Utilities Code, adopted by the legislature, defines the jurisdiction of the CPUC.
Title 24, California’s Energy Efficiency Standards for Residential and Nonresidential Buildings
Title 24, Part 6, of the California Code of Regulations establishes California’s Energy Efficiency
Standards for Residential and Nonresidential Buildings. The 2013 Building Energy Efficiency
Standards (which are updated on an approximately three-year cycle) went into effect on July 1, 2014.
The Energy Commission then developed 2016 Standards, which continue to improve upon the 2013
Standards for new construction of, and additions and alterations to, residential and nonresidential
buildings. The 2016 Standards went into effect on January 1, 2017. Single-family homes built to the
2016 standards will use about 28 percent less energy for lighting, heating, cooling, ventilation, and
water heating than those built to the 2013 standards. In 30 years, California will have saved enough
energy to power 2.2 million homes, reducing the need to build 12 additional power plants. Over
time, the energy savings will accumulate as the Standards affect each subsequent year of
construction. The savings result from changes to both the residential and nonresidential standards.
The Standards affect both newly constructed buildings and alterations to existing buildings. These
savings result from retrofit insulation requirements for existing roofs and the energy requirement for
renovated lighting systems to meet the updated Standards.
Local
City of Orange
General Plan
The City of Orange General Plan sets forth the following goals and policies relevant to utility and
service systems:
Infrastructure Element
• Goal 1.0: Ensure water, sewer, and storm drain systems that meet the needs of residents and
businesses.
• Policy 1.1: Provide sufficient levels of water, sewer, and storm drain service throughout the
community.
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• Policy 1.2: Correct known deficiencies in the City’s sewer, storm drain, and water systems and
work toward environmentally sustainable systems.
• Policy 1.6: Require that new developments fund fair-share costs associated with City provision
of water, sewer, and storm drain service and are consistent with City and service provider
plans to complete needed improvements and funding capacity for such improvements.
• Goal 2.0: Reduce the amount of waste material entering regional landfills with an efficient and
innovative waste management program.
• Policy 2.1: Provide sufficient levels of solid waste service throughout the community.
• Goal 4.0: Ensure adequate provision of electricity, natural gas, telephone and data services
and cable television.
• Policy 4.2: Continue to require utilities to be placed underground for new development.
Storm Drainage Requirements
All projects requiring discretionary City approval are required to prepare a Water Quality
Management Plan in accordance with the Orange County Drainage Area Master Plan and City of
Orange Local Implementation Plan. Chapter 7 of both documents contain information on the types
of projects requiring Water Quality Management Plans, which include new development and
redevelopment projects in both the private and public sector.
The Water Quality Management Plan is intended to provide information related to the project’s
generation and mitigation of water quality pollutants and assessment of hydrological impacts. The
Water Quality Management Plan contains project information related to site characteristics,
expected pollutants, hydrology impacts, incorporation of structural and non-structural best
management practices, Low Impact Development design features, operation and maintenance, and
public education and training. The purpose of the Water Quality Management Plan is to minimize
water quality impacts to downstream water bodies.
3.18.4 - Methodology
FCS reviewed several sources for information about utilities and service systems including the City of
Orange website, City of Orange 2015 Urban Water Management Plan, the Orange County Sanitation
District website, the California Department of Resources Recovery and Recycling website, the Edison
International (SCE) 10-K Annual Report, and Sempra Energy (SoCalGas) 10-K Annual Report.
3.18.5 - Thresholds of Significance
According to the CEQA Guidelines’ Appendix G Environmental Checklist, to determine whether
impacts to utilities and service systems are significant environmental effects, the following questions
are analyzed and evaluated.
Would the project:
a) Exceed wastewater treatment requirements of the applicable Regional Water Quality Control
Board?
b) Require or result in the construction of new water or wastewater treatment facilities or expansion
of existing facilities, the construction of which could cause significant environmental effects?
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c) Require or result in the construction of new storm water drainage facilities or expansion of
existing facilities, the construction of which could cause significant environmental effects?
d) Have sufficient water supplies available to serve the project from existing entitlements and
resources, or are new or expanded entitlements needed?
e) Result in a determination by the wastewater treatment provider which serves or may serve
the project that it has adequate capacity to serve the project’s projected demand in addition
to the provider’s existing commitments?
f) Be served by a landfill with sufficient permitted capacity to accommodate the project’s solid
waste disposal needs?
g) Comply with federal, state, and local statutes and regulations related to solid waste?
3.18.6 - Project Impacts and Mitigation Measures
Potable Water
Impact USS-1: The proposed project would be served with adequate water supplies and would not
require additional entitlements or the construction or expansion of water facilities.
Impact Analysis
The proposed project would be served with potable water provided by the City of Orange. There are
two existing water mains located within E. Santiago Canyon Road that measure 18 inches and 24
inches in diameter, respectively.
The proposed project would install a network of underground water lines within the project site that
would connect to one or both of the existing water mains within E. Santiago Canyon Road.
Underground service laterals would be extended to each dwelling unit. Using the Average Baseline
Per Capital water demand rate set forth in Table 2-9 of the City’s 2015 Urban Water Management
Plan, project water demand is estimated in Table 3.18-4. As shown in the table, the proposed
project would demand 99.5 acre-feet on an annual basis.
Table 3.18-4: Estimated Water Demand
Dwelling Units Population Demand Rate
Water Demand
Daily Annual
128 393 226 gallons/capita/day 88,818 gallons
0.3 acre-foot
32.4 million gallons
99.5 acre-feet
Note:
Population estimate derived from Table 3.13-3 in Section 3.13, Population and Housing.
Source: City of Orange 2016; FirstCarbon Solutions, 2018.
The 2015 Urban Water Management Plan is based on demand between 2020 and 2040 under all water
year scenarios being fully met by available supplies (28,000 to 29,500 acre-feet). The demand
projections in the 2015 Urban Water Management Plan accounted for future residential development
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on the project site. The Urban Water Management Plan used the previous Rio Santiago application to
estimate this usage, and assumed 460 dwelling units consisting of a combination of townhomes and
senior units on 30 acres and passive and active recreation and open space on 80 acres.
In summary, the proposed project’s demand is captured in future demand projections set forth in
the 2015 Urban Water Management Plan and can be met under all scenarios. Thus, the City would
not need to secure additional water supplies to serve the proposed project. Impacts would be less
than significant.
Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
Wastewater
Impact USS-2: The proposed project would be served by a wastewater treatment plant with
adequate capacity and would not require the construction of new or expanded
facilities.
Impact Analysis
The proposed project would be served with wastewater collection and treatment provided by OCSD.
There is an existing OCSD trunk sewer main located within E. Santiago Canyon Road that measures
18 inches in diameter.
The proposed project would install a network of underground sewer piping within the project site
that would connect to the existing sewer main within E. Santiago Canyon Road. Underground
service laterals would be extended to each dwelling unit. Using OCSD’s single-family residential
wastewater generation rate, project wastewater generation is estimated in Table 3.18-5. As shown
in the table, the proposed project would generate 0.060 mgd.
Table 3.18-5: Estimated Wastewater Generation
Single-Family Residential Wastewater
Generation Rate Acres Daily Wastewater Generation
1,488 gallons/acre/day 40.7 60,562 gallons (0.060 mgd)
Note:
mgd = million gallons per day
Source: City of Orange 2016; FirstCarbon Solutions, 2018.
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OCSD Plant No. 1 has a primary treatment capacity of 198 mgd and Plant No. 2 has a primary
treatment capacity of 168 mgd. The proposed project’s daily effluent generation of 0.060 mgd
represents less than 0.01 percent of the primary treatment capacity at either plant.
In summary, adequate wastewater collection and treatment would be available to serve the
proposed project and new or expanded wastewater facilities would not be necessary. Impacts
would be less than significant.
Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
Storm Drainage
Impact USS-3: The proposed project would not create a need for new or expanded downstream
storm drainage facilities.
Impact Analysis
The proposed project would result in the development of up to 128 dwelling units and infrastructure
on 40.7 acres of the project site. The remaining acreage would be dedicated for open space and
recreation use. Thus, the proposed project would increase the amount of impervious surface
coverage on the project site, and would create the potential for increased runoff leaving the project
site that may create potential flooding conditions in downstream waterways.
Of particular concern is the Handy Creek storm drain, which currently accepts runoff from the project
site under existing conditions. The County of Orange has previously identified the storm drain as a
deficient flood control facility that is not capable of conveying runoff from a 100-year storm event.
The proposed project would install a network of storm drainage facilities within the project site
consisting of inlets, underground piping, and basins. This system would serve 72.58 acres of the site
and direct runoff to a 3.7-acre foot capacity stormwater detention basin in the western portion of
the site. A flow control structure will be installed within the detention system to meter the outflow
from the site to below predevelopment levels. Catch basins will be located at various points within
the site to capture subarea flows. The system is designed to detain flows from a 100-year storm
event as required by the Orange County Hydrology Manual.
Two sub drainage areas will flow directly to Santiago Creek without detention. One of these areas is
approximately 1.46 acres directly over the Handy Creek Channel. This flow will be directed to the
Handy Creek Channel. The other area is the trail system adjacent to Santiago Creek and totals 6.20
acres. This flow will be picked up via a storm drain system, which will outlet at the same location as
the detention basin outlet. The outlet structure from the detention basin to Santiago Creek will be
protected by riprap and an energy dissipater.
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As discussed in greater detail in Impact HYD-3 in Section 3.9, Hydrology and Water Quality, the
proposed project would achieve net reduction in 2-year and 100-year storm event discharge into
Santiago Creek and no net increase in 2-year and 100-year storm event discharge into the Handy
Creek storm drain.
This serves to illustrate that the proposed storm drainage system would slow, reduce, and meter the
volume of runoff leaving the project site and ensure that downstream storm drainage facilities are
not inundated with project-related stormwater. Impacts would be less than significant.
Finally, the proposed project would not alter the two unnamed storm drains located in the
northwestern portion of the project site.
Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
Solid Waste
Impact USS-4: The project would be served with adequate landfill capacity and will comply with
federal, state, and local statutes and regulations related to solid waste.
Impact Analysis
This impact assesses whether the proposed project would be served by a landfill with adequate
capacity or comply with federal, state, and local statutes and regulations related to solid waste. Solid
waste would be generated by construction and operational activities. Each is discussed below.
Construction Solid Waste
Short-term construction waste generation is summarized in Table 3.18-6. The estimate of 1,380
cubic feet was calculated using an average of 4.38 pounds of debris per square foot of residential
construction, as provided by the United States Environmental Protection Agency.
Table 3.18-6: Estimated Construction Waste Generation
Project Square Feet Construction Waste Generation Rate
Construction Waste Generation
Tons Cubic Yards
450,000 4.38 pounds/square foot 986 1,380
Notes:
Each dwelling unit estimated to be an average of 3,000 square feet
1 ton = 2,000 pounds 1 ton = 1.4 cubic yards
Source: U.S. Environmental Protection Agency, 1998; FirstCarbon Solutions, 2016.
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The estimate of 1,380 cubic yards of construction waste would be an extremely small amount (less
than 0.01 percent) relative to the remaining capacity at the landfills that serve Orange (384.7 million
cubic yards). Therefore, impacts would be less than significant.
Operational Waste
Operational solid waste generation for residential uses was calculated using the City of Orange’s
residential waste generation figures provided by Cal Recycle. The project’s waste generation
calculations are provided in Table 3.18-7. As shown in the table, the proposed project is expected to
create 142.1 cubic yards of waste annually.
Table 3.18-7: Estimated Operational Waste Generation
Dwelling Units Operational Waste Generation Rate
Operational Waste Generation
Tons Cubic Yards
128 1,586 pounds/year/dwelling unit 101.5 142.1
Notes:
1 ton = 2,000 pounds 1 ton = 1.4 cubic yards
Sources: Cal Recycle, 2015; FirstCarbon Solutions, 2018.
The estimate of 142.1 cubic yards of operational waste would be an extremely small amount (less than
0.01 percent) relative to the remaining capacity at the landfills that serve Orange (384.7 million cubic
yards). Moreover, the proposed project would be served with solid waste and recycling collection
services provided by a contracted solid waste hauler. Recoverable materials would be separated from
the waste stream either at the project site or at a materials recovery facility in accordance with state
and local solid waste regulations. Therefore, solid waste impacts would be less than significant.
Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
Energy
Impact USS-5: The project would not result in the inefficient, unnecessary, or wasteful use of
energy.
Impact Analysis
SCE would provide electrical service and the SoCalGas would provide natural gas service to the
proposed project.
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A network of underground electrical lines would be installed within the project site and connect to
existing SCE facilities along E. Santiago Canyon Road. Underground service laterals would be
extended to each dwelling unit.
A network of underground natural gas lines would be installed within the project site and connect to
existing SoCalGas facilities along E. Santiago Canyon Road. Underground service laterals would be
extended to each dwelling unit.
Table 3.18-8 provides an estimate of the proposed project’s annual energy consumption. These
figures were derived from residential energy consumption rates observed in California. These
estimates likely overstate actual consumption, because they include structures located in different
climate regions or states with less stringent energy efficiency standards than California.
Table 3.18-8: Energy Consumption Estimate
Energy Source Dwelling Units Consumption Rate Annual Consumption
Electricity
128
6,294 kWh/dwelling unit 805,632 kWh
Natural Gas 35,000 cubic feet/dwelling unit 4.5 million cubic-feet
Note:
kWh = kilowatt hours
Source: FirstCarbon Solutions, 2018.
As shown in the table, the proposed project is estimated to demand 805,632 kWh of electricity and
4.5 million cubic feet of natural gas at buildout on an annual basis. All new non-residential
development would be subject to the latest adopted edition of the Title 24 energy efficiency
standards, which are among the most stringent in the U.S.
In addition, as outlined within Section 6.4, Energy Conservation of this Draft EIR, Public Resources
Code Section 21100(b)(3) and CEQA Guidelines Section 15126.4 require EIRs to describe, where
relevant, the wasteful, inefficient, and unnecessary consumption of energy caused by a project. In
1975, largely in response to the oil crisis of the 1970s, the State Legislature adopted AB 1575, which
created the California Energy Commission (CEC). The statutory mission of the CEC is to forecast
future energy needs, license thermal power plants of 50 megawatts or larger, develop energy
technologies and renewable energy resources, plan for and direct state responses to energy
emergencies, and—perhaps most importantly—promote energy efficiency through the adoption and
enforcement of appliance and building energy efficiency standards. AB 1575 also amended Public
Resources Code Section 21100(b)(3) to require EIRs to consider the wasteful, inefficient, and
unnecessary consumption of energy caused by a project. Thereafter, the State Resources Agency
created Appendix F of the CEQA Guidelines. Appendix F is an advisory document that assists EIR
preparers in determining whether a project will result in the inefficient, wasteful, and unnecessary
consumption of energy. For the reasons set forth in Section 6.4, Energy Conservation, this EIR
concludes that the proposed project will not result in the wasteful, inefficient, and unnecessary
consumption of energy, will not cause the need for additional natural gas or electrical energy-
producing facilities, and, therefore, will not create a significant impact on energy resources.
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As such, the proposed project would not result in the unnecessary, wasteful, or inefficient use of
energy. Impacts would be less than significant.
Level of Significance Before Mitigation
Less than significant impact.
Mitigation Measures
No mitigation is necessary.
Level of Significance After Mitigation
Less than significant impact.
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SECTION 4: CUMULATIVE EFFECTS
4.1 - Introduction
CEQA Guidelines Section 15130 requires the consideration of cumulative impacts within an EIR when a
project’s incremental effects are cumulatively considerable. Cumulatively considerable means that
“. . . the incremental effects of an individual project are considerable when viewed in connection with
the effects of past projects, the effects of other current projects, and the effects of probable future
projects.” In identifying projects that may contribute to cumulative impacts, the CEQA Guidelines allow
the use of a list of past, present, and reasonably anticipated future projects, producing related or
cumulative impacts, including those which are outside of the control of the lead agency.
In accordance with CEQA Guidelines Section 15130(b), “. . . the discussion of cumulative impacts
shall reflect the severity of the impacts and their likelihood of occurrence, the discussion need not
provide as great [a level of] detail as is provided for the effects attributable to the project alone.”
The discussion should be guided by standards of practicality and reasonableness, and it should focus
on the cumulative impact to which the identified other projects contribute rather than on the
attributes of other projects that do not contribute to the cumulative impact.
The proposed project’s cumulative impacts were considered in conjunction with other proposed and
approved projects in the City of Orange. Table 4-1 provides a list of the other projects considered in
the cumulative analysis.
Table 4-1: Cumulative Projects
Jurisdiction Project Characteristics Location Status
City of
Orange
Salem Lutheran
Church Expansion
7,388 square-foot
expansion
6500 East Santiago
Canyon Road
Approved; not
built
Arena Site Single-
Family Homes
7 single-family homes 6422 East Santiago
Canyon Road
Permitted; not
approved
Santiago Hills II 1,066 single-family
homes
114 condominiums
9.4-acre park
East Santiago Canyon
Road/West of State
Route 241
Approved; not
built
Olson Project 37 townhomes Washington Avenue/
South Hamlin Street
Approved; under
construction
Ridgeline 39 single-family
dwelling units
1051 North Meads
Avenue
Rescinded by City
Council
Source: City of Orange, 2017.
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4.2 - Cumulative Impact Analysis
The cumulative impact analysis below is guided by the requirements of CEQA Guidelines Section
15130. Key principles established by this section include:
• A cumulative impact only occurs from impacts caused by the proposed project and other
projects. An EIR should not discuss impacts that do not result from the proposed project.
• When the combined cumulative impact from the increment associated with the proposed
project and other projects is not significant, an EIR need only briefly explain why the impact is
not significant; detailed explanation is not required.
• An EIR may determine that a project’s contribution to a cumulative effect impact would be
rendered less than cumulatively considerable if a project is required to implement or fund its
fair share of mitigation intended to alleviate the cumulative impact.
The cumulative impact analysis that follows relies on these principles as the basis for determining
the significance of the proposed project’s cumulative contribution to various impacts.
4.2.1 - Aesthetics, Light, and Glare
The geographic scope of the cumulative aesthetics, light, and glare analysis is the area surrounding
the project site. This is the area within view of the project and, therefore, the area most likely to
experience changes in visual character or experience light and glare impacts.
Two of the projects listed in Table 4-1 are within view of the project site (Salem Lutheran Church
Expansion and Arena Site Single Family Homes). The proposed project consists of the development
of 128 dwelling units on 40.7 acres of the site and preservation of the remaining acreage as open
space. The project vicinity is characterized by suburban development and open space, including
single-family residential uses, the closed Villa Park Landfill, and Santiago Oaks Regional Park. Much
of the surrounding project area has been developed within the past 50 years in compliance with the
General Plan, and the City’s current municipal code requirements related to design and visual
character. Compliance with these standards, as well as the City’s review and approval role in the
planning process has ensured a visually compatible and cohesive development pattern in the
surrounding area. Therefore, there is currently no existing cumulatively significant visual aesthetic
impact within the project area.
As stated previously, two of the projects listed in Table 4-1 are within view of the project site. The
project vicinity has existing sources of light and glare. All new light fixtures associated with the
project would be subject to the provisions of the Orange Municipal Code, which requires that new
lighting must be directed, controlled, screened, or shaded in such a manner as not to shine directly
on surrounding premises. As such, no significant change in light and glare levels would occur as a
result of the proposed project. Other projects that involve the installation of new exterior lighting
fixtures would be required to implement similar devices to prevent light spillage.
Therefore, the proposed project, in conjunction with other planned and approved projects, would
not have a cumulatively significant impact relating to aesthetics, light, and glare.
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4.2.2 - Agriculture Resources and Forest Resources
There are no agricultural or forestry resources within the project site or on surrounding land uses.
This condition precludes the possibility of the proposed project contributing to a cumulative impact
in this regard. No impacts would occur.
4.2.3 - Air Quality
The geographic scope of the cumulative greenhouse gas emissions analysis is the South Coast Air
Basin, which encompasses Orange County, Los Angeles County (excluding the Antelope Valley),
Ventura County, Riverside County (excluding the Coachella Valley and the desert region) and San
Bernardino County (excluding the desert region). Air quality is impacted by topography, dominant
air flows, atmospheric inversions, location, and season; therefore, using the Air Basin represents the
area most likely to be impacted by air emissions.
All of the projects listed in Table 4-1 would result in new air emissions, during construction or
operations (or both). The air basin is currently in non-attainment of the federal standards for ozone,
PM10 and PM2.5, and is in nonattainment of the state standards for ozone and PM2.5. Therefore,
there is an existing cumulatively significant air quality impact with respect to these pollutants.
The proposed project would emit construction and operational criteria pollutant emissions at levels
that would exceed the South Coast Air Quality Management District (SCAQMD) thresholds.
Mitigation is proposed requiring the implementation of criteria pollutant emissions (i.e., ozone
precursors) reduction measures and would serve to reduce construction and operational emissions
to below SCAQMD thresholds. Thus, the proposed project would not have a cumulatively
considerable contribution to criterial pollutant emissions.
As discussed in Section 3.3, Air Quality, cumulative cancer, non-cancer chronic and acute health
impacts, and PM2.5 concentrations were evaluated at the most impacted off-site sensitive receptor
from all sources of toxic air contaminant (TAC) emissions located within 1,000 feet of the project site.
The project’s individual contribution to cancer risk for all phases is below the SCAQMD’s 10 in a
million threshold for individual project impacts; therefore, the project would not result in a
cumulatively considerable contribution to the existing, cumulatively significant TAC cancer risk.
All other project-related air quality impacts were found to be less than significant and did not
require mitigation. Other projects that result in similar impacts would be required to mitigate for
their impacts. Because the proposed project can mitigate all of these remaining air quality impacts
to a level of less than significant, it would not have a related cumulatively significant impact with
respect to these impact areas.
4.2.4 - Biological Resources
The geographic scope of the cumulative biological resources analysis is the region surrounding the
project site. The project site is located in an area characterized by urban development and
infrastructure; accordingly, habitats in these areas tend to be characterized as highly disturbed, and
impacts would be localized. Recent development patterns and anticipated future growth in the
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Orange region is considered an existing cumulatively significant impact to biological resources due to
the loss of potential habitat for rare species.
The proposed project has the potential to have a significant impact on the least Bell’s vireo and
nesting birds. Mitigation Measures BIO-2a through BIO-2d are proposed requiring pre-construction
surveys for these species and implementation of protection measures if they are found to be
present. Some of the other projects listed in Table 4-1 are located on sites with similar biological
attributes and, therefore, would be required to mitigate for impacts on special-status wildlife species
in a manner similar to the proposed project. The required mitigation would reduce the project’s
contribution to any significant cumulative impact on special-status wildlife species to less than
cumulatively considerable.
The proposed project has the potential to have a significant impact on sensitive riparian
communities and wetlands. Mitigation Measures BIO-3 and BIO-4 are proposed requiring
restoration or replacement of disturbed features. Some of the other projects listed in Table 4-1 are
located on sites with similar biological attributes and, therefore, would be required to mitigate for
impacts on sensitive riparian communities and wetlands. The required mitigation would reduce the
project’s contribution to any significant cumulative impact on sensitive riparian communities and
wetlands to less than cumulatively considerable.
All other project-related biological resource impacts (e.g., wildlife movement, conservation plans)
were found to be less than significant and did not require mitigation. Other projects that result in
similar impacts would be required to mitigate for their impacts. Because the proposed project’s
impact on all of these remaining biological resources is less than significant, it would not have a
cumulatively considerable contribution to any existing significant cumulative impact.
4.2.5 - Cultural Resources
The geographic scope of the cumulative cultural resources analysis is the project vicinity. Cultural
resource impacts tend to be localized because the integrity of any given resource depends on what
occurs only in the immediate vicinity around that resource, such as disruption of soils; therefore, in
addition to the project site itself, the area near the project site would be the area most affected by
project activities (generally within a 500-foot radius).
Construction activities associated with development projects in the project vicinity may have the
potential to encounter undiscovered cultural resources. These projects would be required to
mitigate for impacts through compliance with applicable federal and state laws governing cultural
resources. Even if a significant cumulative impact could be found, the proposed project would not
make a cumulatively considerable impact with required mitigation. The likelihood of any significant
cultural resources on the project site are very low given the developed nature of the site, previous
disruptions to its ground and the lack of any known resource within its boundaries. Although there
is the possibility that previously undiscovered resources could be encountered by subsurface
earthwork activities, the implementation of standard construction mitigation measures would
ensure that undiscovered cultural resources are not adversely affected by project-related
construction activities, which would prevent the destruction or degradation of potentially significant
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cultural resources in the project vicinity. Given the low potential for disruption, and the
comprehensiveness of mitigation measures that would apply to this project and those in the vicinity,
the proposed project would not make a cumulatively considerable contribution to any potentially
significant cumulative impact on cultural resources.
Therefore, the proposed project, in conjunction with other planned and approved projects, would
not have a cumulatively significant impact related to cultural resources.
4.2.6 - Geology and Soils
The geographic scope of the cumulative geology, soils, and seismicity analysis is the project vicinity.
Adverse effects associated with geologic, soil, and seismic hazards tend to be localized, and the area
near the project site would be the area most affected by project activities (generally within a 0.25-
mile radius). Development in the project vicinity has not included any uses or activities which would
result in geology, soils or seismicity impacts (such as mining or other extraction activities), and there
is no existing cumulatively significant impact.
Development projects in the project vicinity may have the potential to be exposed to seismic
hazards. However, there is a less than significant potential of the projects in combination to expose
people or structure to substantial adverse effects, including the risk of loss, injury, or death in the
event of a major earthquake; fault rupture; ground shaking; seismic-related ground failure; landslide;
or liquefaction. Some or all of the other projects listed in Table 4-1 would be exposed to similar
seismic hazards and, therefore, would be expected to implement similar regulatory requirements
and mitigation measures. As such, the proposed project, in conjunction with other projects, would
not have a cumulatively significant impact associated with seismic hazards.
Regarding soil erosion, development activities could lead to increased erosion rates on-site soils,
which could cause unstable ground surfaces and increased sedimentation in nearby streams and
drainage channels. Mitigation Measure HYD-1a requires implementation of standard stormwater
pollution prevention measures to ensure that earthwork activities do not result in substantial
erosion off-site. This mitigation, in turn, would have to comply with the National Pollution Discharge
Elimination System (NPDES) stormwater permitting program, which regulates water quality
originating from construction sites. The NPDES program, which governs projects statewide (and
nationwide), requires the preparation and implementation of Stormwater Pollution Prevention
Programs for construction activities that disturb more than 1 acre, and the implementation of Best
Management Practices that ensure the reduction of pollutants during stormwater discharges, as well
as compliance with all applicable water quality requirements. Since the proposed project would
have to comply with federal and state regulations and required mitigation measures that are
designed to minimize impacts to projects on a wide geographic scale, the project’s contribution to
any significant cumulative erosion impact would be less than cumulatively considerable.
Finally, the project site contains fill soils that that may not be suitable to support urban
development. Standard grading and soil engineering practices would abate these issues. Some or all
of the other projects listed in Table 4-1 would be exposed to expansive soil hazards or unstable
geologic units and, therefore, would be expected to implement similar grading and soil engineering
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practices to address those impacts. The proposed project would not contribute to any significant
cumulative impact due to expansive soils or unstable soil units.
Therefore, the proposed project, in conjunction with other planned and approved projects, would
not have a cumulatively significant impact related to geology, soils, and seismicity, assuming
compliance with regulatory requirements.
4.2.7 - Greenhouse Gas Emissions
The geographic scope of the cumulative greenhouse gas emissions analysis is the South Coast Air
Basin, which encompasses Orange County, Los Angeles County (excluding the Antelope Valley),
Ventura County, Riverside County (excluding the Coachella Valley and the desert region) and San
Bernardino County (excluding the desert region). Air quality is impacted by topography, dominant
air flows, atmospheric inversions, location, and season; therefore, using the Air Basin represents the
area most likely to be impacted by air emissions.
Greenhouse gas emissions are inherently cumulative in nature, and the appropriate scope of analysis
is the global climate. The proposed project and other projects would emit new greenhouse gas
emissions. The proposed project’s greenhouse gas emissions would not exceed the SCAQMD
threshold of 3,500 metric tons of carbon dioxide equivalents after implementation of mitigation
measures and project design features. Therefore, the project’s contribution of greenhouse gas
emissions would not be cumulatively significant.
4.2.8 - Hazards and Hazardous Materials
The geographic scope of the cumulative hazards and hazardous materials analysis is the project area.
Adverse effects of hazards and hazardous materials tend to be localized; therefore, the area near the
project area would be most affected by project activities. Hazards and hazardous materials are
extensively regulated at the federal, state and local levels. There are no land uses in the project
vicinity that are known to utilize large quantities of hazardous materials or involve hazardous
activities, and there is no existing cumulatively significant impact.
The project site is adjacent to the closed Villa Park Landfill and previously supported uses that
involved regular petroleum usage. Thus, the proposed would implement mitigation for vapor
intrusion and remediation of petroleum-impacted soils. Other projects listed in Table 4-1 that have
become contaminated from past uses or possess characteristics that involve the routine handling of
large quantities of hazardous materials, would be required to mitigate for their impacts. Because
hazards and hazardous materials exposure is generally localized and development activities
associated with the other projects listed in Table 4-1 may not coincide with the proposed project,
this effectively precludes the possibility of cumulative exposure.
The project site is adjacent to Santiago Oaks Regional Park and contains the wooded Santiago Creek
Corridor. Thus, it is susceptible to wildland fires and would need to provide adequate emergency
access. The proposed project would be required to prepare and implement a fuel modification plan
and comply with all applicable Fire Code requirements for emergency access. Other projects listed
in Table 4-1 that are susceptible to wildland fires would be required to implement similar mitigation.
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Because wildland fire exposure is dependent on location and development activities associated with
the other projects listed in Table 4-1 may not occur in areas susceptible to such hazards, this
effectively precludes the possibility of cumulative exposure.
Because the proposed project’s impact due to hazards and hazardous materials is less than significant,
it would not have a cumulatively considerable contribution to any significant cumulative impact.
4.2.9 - Hydrology and Water Quality
The geographic scope of the cumulative hydrology and water quality analysis is the project vicinity,
generally areas within 0.5 mile of the project site for stormwater impacts due to natural drainage
patterns, drainage infrastructure, and impervious surfaces, which all contribute to limit the distance
of stormwater flows. Hydrologic and water quality impacts tend to be localized; therefore, the area
near the project site would be most affected by project activities. The nature and types of
surrounding development, existing stormwater infrastructure and regulatory requirements have
ensured that no cumulatively significant impacts related to water pollutants or flooding exist within
the project vicinity.
The proposed project would involve short-term construction and long-term operational activities
that would have the potential to degrade water quality in downstream water bodies. Mitigation
Measures HYD-1a and HYD-1b are proposed that would require implementation of various
construction and operational water quality control measures to prevent the release of pollutants
into downstream waterways. Other projects that propose new development are required to
implement similar mitigation measures in accordance with adopted regulations. The required
mitigation would reduce the project’s contribution to any significant cumulative water quality impact
to less than cumulatively considerable.
The project site is within the dam failure inundation area of Villa Park Dam and Santiago Dam.
Mitigation Measure HYD-5 is proposed requiring the applicant to implement an Emergency
Evacuation Plan that identifies procedures for an orderly evacuation of the project in the event
indications of failure occur at either facility. Other projects that are within the dam failure
inundation area would be required to comply with applicable emergency evacuation regulations.
The required mitigation would reduce the project’s contribution to any significant cumulative dam
failure impact to less than cumulatively considerable.
All other project-related hydrology impacts (e.g., groundwater, drainage and 100-year flood hazards)
were found to be less than significant and do not require mitigation. Because all project-related
hydrology impacts are less than significant, the project would not have a cumulatively considerable
contribution to any significant cumulative impact for these impacts.
4.2.10 - Land Use and Planning
The geographic scope of the cumulative land use analysis is the Orange area. Land use decisions are
made at the city level; therefore, the Orange area is an appropriate geographic scope. Development
within Orange is governed by the City’s General Plan and the Municipal Code, which ensure logical
and orderly development and require discretionary review to ensure that projects do not result in
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land use impacts due to inconsistency with the General Plan and other regulations. As a result, there
is no existing cumulatively significant land use impact.
The project site is currently designated for LDR, RA, and OS by the General Plan and zoned S-G and R-
1-8. The proposed project involves the development of up to 128 dwelling units on 40.7 acres within
the area designated RA and the preservation of the remaining 68.5 acres (which overlap with the RA
and LDR designations) as open space and recreation uses. Accordingly, the applicant is proposing to
change the RA designation to a combination of LDR and OS; and the LDR designation to OS. Thus,
the proposed land use changes would serve to relocate the residential use and replace the resource
use with open space use, which was found to be a less than significant impact.
Development projects in the Orange area would continue to be required to demonstrate consistency
with all applicable City of Orange General Plan and Municipal Code requirements. This would ensure
that these projects comply with applicable planning regulations. Those projects listed in Table 4-1
that have been previously approved have been deemed consistent with all applicable General Plan
and Specific Plan requirements. For pending projects, the lead agency would be required to issue
findings demonstrating consistency with the applicable General Plan and Municipal Code
requirements if they are ultimately approved.
Therefore, the proposed project, in conjunction with other planned and approved projects, would
not have a cumulatively significant impact related to land use.
4.2.11 - Mineral Resources
The geographic scope of the cumulative mineral resource analysis is Orange County-Temescal Valley
Region, which encompasses Orange County and western Riverside County. This region was defined
by the California State Mining and Geology Board for the purposes of identifying mineral resource
zones.
The Orange County-Temescal Valley Region was identified by the California Geological Survey as
having only an 11 to 20 year supply of aggregate left in 2012. Thus, there an existing cumulative
impact in terms of regional availability of aggregate resources.
The project site was surfaced mined for aggregate between 1919 and 1995. Following the cessation
of mining activities, mined areas of the site have been backfilled, which effectively precludes the
resumption of aggregate mining operations. Furthermore, the Geotechnical Investigation prepared
for the project site indicates that it has been mined of economic aggregate deposits and the
remaining deposits that are of potential economic value are infeasible to mine, due to limited
volume of the localized deposits, expense of removing the overburden (pond deposits), and
difficulty associated with excavation logistics. Thus, resuming aggregate mining operations on the
project site would not be economically feasible and the resource is effectively depleted. Accordingly,
the conversion of the project site to residential and open space/recreational use would not
cumulatively contribute to the loss mineral resources of value to the State or region because the site
has been depleted of all economically recoverable aggregate materials.
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4.2.12 - Noise
The geographic scope of the cumulative noise analysis is the project vicinity, including surrounding
sensitive receptors. Noise impacts tend to be localized; therefore, the analysis in Section 3.12, Noise
includes a cumulative analysis of existing, proposed, and anticipated future noise levels near the
project site. Outdoor noise measurements taken at the project site indicate that the average
ambient noise levels are within the “normally acceptable” or “conditionally acceptable” range for all
land uses. Therefore, there is no existing cumulatively significant noise impact in the project vicinity.
The proposed project’s construction noise levels may cause a temporary substantial increase in noise
levels at nearby receptors. Mitigation is included that would require implementation of construction
noise attenuation measures to reduce noise levels; however, construction noise levels may exceed
adopted standards at certain nearby receptors and, therefore, is considered a significant unavoidable
impact. Other projects listed in Table 4-1 would be required to implement similar mitigation and
adhere to Municipal Code restrictions regarding construction noise. It is highly unlikely that a
substantial number of the cumulative projects would be constructed simultaneously and close
enough to one another for noise impacts to be compounded, given that the projects are at widely
varying stages of approval and development. Therefore, it is reasonable to conclude that construction
noise from the proposed project would not combine with noise from other development projects to
cause cumulatively significant noise impacts.
The proposed project’s construction and operational vibration levels would not exceed annoyance
thresholds, and impacts would be less than significant. Because vibration is a highly localized
phenomenon, there would be no possibility for vibration associated with the project to combine
with vibration from other projects because of their distances from the project site. Therefore, the
proposed project would not contribute to a cumulatively significant vibration impact.
The proposed project’s contribution to vehicular noise levels would not exceed the applicable
thresholds of significance, which take into account existing noise levels as well as noise from trips
associated with other planned or approved projects. Thus, the proposed project would not combine
with other projects to cause a cumulatively considerable increase in ambient roadway noise.
Other projects listed in Table 4-1 would be required to evaluate noise and vibration impacts and
implement mitigation, if necessary, to minimize noise impacts pursuant to local regulations.
Therefore, the proposed project, in conjunction with other planned and approved projects, would
not have a cumulatively significant impact related to noise.
4.2.13 - Population and Housing
The geographic scope of the cumulative population and housing analysis is the City of Orange.
Population growth is typically measured in relation to the size of the applicable jurisdiction and,
thus, the City of Orange is appropriate geographical area. No existing cumulatively significant
impacts have been identified for this topic.
The proposed project would develop 128 dwelling units, which would add 393 persons to the City of
Orange’s population, which represents an increase of 0.3 percent relative to the City’s population of
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141,420. The project site is currently designated for residential use by the City of Orange General Plan
and Orange Zoning Ordinance and, thus, is contemplated to support population growth. Growth
inducement impacts were found to be less than significant. Other development projects in the City of
Orange would be reviewed for impacts on population growth and would be required to address any
potential impacts with mitigation. Therefore, the proposed project, in conjunction with other future
projects, would not have a cumulatively significant impact related to growth inducement.
4.2.14 - Public Services
The geographic scope of the cumulative public services analysis is the service area of each of the
providers serving the proposed project. Because of differences in the nature of the public service
and utility topical areas, they are discussed separately. No existing cumulatively significant impacts
have been identified for any of these areas, as all service providers are able to achieve the requisite
level of service, capacity or response times.
Fire Protection and Emergency Medical Services
The geographic scope of the cumulative fire protection and emergency medical services analysis is
the Orange Fire Department’s service area, which consists of the Orange city limits.
The proposed project would develop 128 dwelling units on 40.7 acres of the project site and
preserve the remaining acreage as open space. The proposed project is estimated to add 393 new
residents to the City’s population. The project site is located within 1.75 miles of the nearest fire
station and is within an acceptable response time for fire protection. As such, the proposed project
would not create a need for new or expanded fire protection facilities and would not result in a
physical impact on the environment.
The project site is adjacent to Santiago Oaks Regional Park and contains the wooded Santiago Creek
Corridor. Thus, it is susceptible to wildland fires and would need to provide adequate emergency
access. The proposed project would be required to prepare and implement a fuel modification plan
and comply with all applicable Fire Code requirements for emergency access. Other projects listed
in Table 4-1 that are susceptible to wildland fires would be required to implement similar mitigation.
Because wildland fire exposure is dependent on location and development activities associated with
the other projects listed in Table 4-1 may not occur in areas susceptible to such hazards, this
effectively precludes the possibility of cumulative exposure.
Other development projects in the Fire Department’s service area would be reviewed for impacts on
fire protection and emergency medical services and would be required to address any potential
impacts with mitigation. According to the Fire Department, existing facilities are sufficient to serve
the proposed project in conjunction with existing and cumulative projects. Therefore, the proposed
project, in conjunction with other future projects, would not have a cumulatively significant impact
related to fire protection and emergency medical services.
Police Protection
The geographic scope of the cumulative police protection analysis is the service area of the Orange
Police Department, which consist of the Orange city limits.
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The proposed project would develop 128 dwelling units on 40.7 acres of the project site and
preserve the remaining acreage as open space. The proposed project is estimated to add 363 new
residents to the City’s population. The Police Department indicated that it could serve the proposed
project without needing new or expanded police protection facilities. Other development projects
within the Police Department service area would be reviewed for impacts on police protection and
would be required to address any potential impacts with mitigation. According to the Police
Department, existing facilities are sufficient to serve the proposed project in conjunction with
existing and cumulative projects. Therefore, the proposed project, in conjunction with other future
projects, would not have a cumulatively significant impact related to police protection.
Schools
The geographic scope of the cumulative school analysis is the Orange Unified School District (OUSD),
which encompasses the City of Orange, and all or portions of Anaheim, Garden Grove, Santa Ana,
and Villa Park.
The proposed project would develop 128 dwelling units on 40.7 acres of the project site and
preserve the remaining acreage as open space. The proposed project is estimated to add 64 new
students to OUSD. The proposed project would pay development fees to OUSD to fund capital
improvements to school facilities. Other development projects within OUSD would be reviewed for
impacts on schools and would be required to pay development fees. Therefore, the proposed
project, in conjunction with other future projects, would not have a cumulatively significant impact
related to schools.
Parks
The geographic scope of the cumulative park analysis is the Orange city limits. Within the city limits
are neighborhood parks, community parks, regional parks, trails, community gardens, and historic
sites.
The proposed project would develop 128 dwelling units on 40.7 acres of the project site and
preserve the remaining acreage as open space. The proposed project is estimated to add 393 new
residents to the City’s population. The proposed project would provide a trail network and passive
use areas (open space and greenway). The provision of these facilities would be expected to offset
the increased demand for such facilities because project residents would be expected to use the
facilities closest to where they live. Other development projects within the city limits would be
reviewed for impacts on parks and would be required to dedicate new public facilities or pay
development fees. Therefore, the proposed project, in conjunction with other future projects,
would not have a cumulatively significant impact related to parks.
4.2.15 - Recreation
The geographic scope of the cumulative recreation analysis is the Orange city limits. Within the city
limits are neighborhood parks, community parks, regional parks, trails, community gardens, and
historic sites.
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The proposed project would develop 128 dwelling units on 40.7 acres of the project site and
preserve the remaining acreage as open space. The proposed project is estimated to add 393 new
residents to the City’s population. The proposed project would provide a trail network and passive
use areas (open space and greenway). The provision of these facilities would be expected to offset
the increased demand for such facilities because project residents would be expected to use the
facilities closest to where they live. Other development projects within the city limits would be
reviewed for impacts on parks and would be required to dedicate new public facilities or pay
development fees. Therefore, the proposed project, in conjunction with other future projects,
would not have a cumulatively significant impact related to recreation.
4.2.16 - Transportation and Traffic
The geographic scope of the cumulative transportation analysis is the roadway network within the
eastern portion of the City of Orange. As discussed in the Transportation Section 3.16 of this EIR,
study facilities consist of ten study intersections and 17 roadway segments.
All of the new development projects listed in Table 4-1 would generate new vehicle trips that may
trigger or contribute to unacceptable intersection operations and freeway operations. All projects
would be required to mitigate for their fair share of impacts. The proposed project would result in
542 net new daily trips, including 34 net new trips during the weekday morning peak hour, and 97 net
new trips during the weekday afternoon peak hour. Project-related trips would not cause any
facilities operating at deficient levels to significantly deteriorate further under With Trip Credit Existing
Traffic Conditions, Existing Plus Project Traffic Conditions, and Cumulative (2040) conditions. Project-
related trips would cause one facility operating at deficient levels to significantly deteriorate further
under Year 2022 conditions. While the proposed project would have a significant and unavoidable
impact due to the facility not being in a City of Orange plan, such as the MPAH, mitigation is proposed
that would require the project applicant to contribute to planned improvements at this location that
would restore operations to acceptable levels. Therefore, the proposed project, in conjunction with
other projects, would not result in a cumulatively significant impact to unacceptable traffic
operations.
For other transportation-related areas (roadway safety; emergency access; public transit, bicycles
and pedestrians), the proposed project would have potentially significant impacts related to
roadway hazards, but after the implementation of mitigation, these impacts would be reduced to a
level of less than significant. Other projects that result in similar impacts would be required to
mitigate for their impacts. Because the proposed project can mitigate all other transportation
impacts to a level of less than significant, it would not have a related cumulatively significant impact
with respect to these other topics.
4.2.17 - Tribal Cultural Resources
Eligibility for California Register Listing
The geographic scope of the cumulative registered historical resources analysis is the project vicinity.
Registered historical resource impacts tend to be localized because the integrity of any given
resource depends on what occurs only in the immediate vicinity around that resource, such as
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construction; therefore, in addition to the project site itself, the area near the project site would be
the area most affected by project activities (generally within a 500-foot radius).
Construction activities associated with development projects in the project vicinity may have the
potential to remove or damage registered historical resources. Given that neither the project site
nor any other project site in the vicinity is listed on any national, state, or local registers of historic
places (including those for tribal cultural resources), the proposed project would not make a
cumulatively considerable contribution to any potentially significant cumulative impact or registered
historical resources.
Therefore, the proposed project, in conjunction with other planned and approved projects, would
not have a cumulatively significant impact related to registered historical resources.
Eligibility as Determined by Lead Agency
The geographic scope of the cumulative tribal cultural resources analysis is the project vicinity. Tribal
cultural resource impacts tend to be localized because the integrity of any given resource depends
on what occurs only in the immediate vicinity around that resource, such as disruption of soils;
therefore, in addition to the project site itself, the area near the project site would be the area most
affected by project activities (generally within a 500-foot radius).
Construction activities associated with development projects in the project vicinity may have the
potential to encounter undiscovered tribal cultural resources. These projects would be required to
mitigate for impacts through compliance with applicable federal and state laws governing tribal
cultural resources. Even if a significant cumulative impact could be found, the proposed project
would not make a cumulatively considerable impact with required compliance. The likelihood of any
significant tribal cultural resources on the project site are very low given the developed nature of the
site, previous disruptions to its ground, and the lack of any known resource within its boundaries.
Although there is the possibility that previously undiscovered resources could be encountered by
subsurface earthwork activities, the implementation of standard construction mitigation measures
would ensure that undiscovered tribal cultural resources are not adversely affected by project-
related construction activities, which would prevent the destruction or degradation of potentially
significant tribal cultural resources in the project vicinity. Given the low potential for disruption, and
compliance with construction best management practices that would apply to this project and those
in the vicinity, the proposed project would not make a cumulatively considerable contribution to any
potentially significant cumulative impact on tribal cultural resources.
Therefore, the proposed project, in conjunction with other planned and approved projects, would
not have a cumulatively significant impact related to tribal cultural resources.
4.2.18 - Utilities and Service Systems
Water
The geographic scope of the cumulative potable water analysis is the City of Orange Water Division
service area, which encompasses the Orange city limits and nearby unincorporated areas of Orange
County. The City of Orange water service area has 36,347 customer accounts. Water supply impacts
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are analyzed in Section 3.17, Utilities and Service Systems of this EIR, which concluded that the City
of Orange has adequate potable water supplies to serve the proposed project, as well as other
existing and future users. Therefore, there is no existing cumulatively significant impact related to
potable water supply.
The proposed project is estimated to demand 99.5 acre-feet per year of potable water. The City of
Orange 2015 Urban Water Management Plan indicates that potable water supplies were estimated
to be 28,000 acre-feet in 2020 and are expected to increase to 29,500 acre-feet in 2040. The City of
Orange has two supply sources (groundwater and imported water) and thus does not rely on a single
water source. The proposed project’s increase in demand would represent less than 1 percent of
potable water supplies under all scenarios between 2015 and 2035. Furthermore, the City of Orange
2015 Urban Water Management Plan assumed that 460 dwelling units and open space uses would
be developed on the project site and, therefore, accounted for demand from the proposed project in
its long-term demand projections.
It should be noted that not all of the projects listed in Table 4-1 are located within the City of Orange
water service area. However, for those projects that are located with the City of Orange water
service area, the 2015 Urban Water Management Plan anticipates adequate water supplies for all
water year scenarios through 2040. These projects also would be required to demonstrate that they
would be served with potable water service as a standard requirement of the development review
process, and these projects may be required to implement water conservation measures to the
extent they are required. Therefore, the proposed project, in conjunction with other planned and
approved projects, would not have a cumulatively significant impact related to water supply.
Wastewater
The geographic scope of the cumulative wastewater analysis is the areas tributary to Orange County
Sanitation District (OCSD) Plant No. 1 and Plant No. 2. The two plants treat all of the effluent
generated with the OCSD service area, which covers 479 square miles of central and northwest
Orange County.
All future projects would be required to demonstrate that sewer service is available to ensure that
adequate sanitation can be provided. The proposed project is estimated to generate 74,400 gallons
of wastewater on a daily basis (0.060 million gallons per day [mgd]). Plant No. 1 and Plant No. 2
have a combined treatment capacity of 366 mgd of primary treatment capacity and 200 mgd of
secondary treatment capacity. The increase of 0.060 mgd attributable to the proposed project
represents less than 1 percent of available primary or secondary treatment capacity at the two
plants and, thus, would not exceed the capacity of either plant. As such, the plants would be
expected to accept the proposed project’s increase in effluent without needing to expand existing or
construct new facilities, as the treatment capacity is sufficient to serve both the project and planned
future development in the area. Therefore, the proposed project, in conjunction with other planned
and approved projects, would not have a cumulatively significant impact related to wastewater.
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Storm Drainage
The geographic scope of the cumulative storm drainage analysis is Santiago Creek, which currently
receives runoff from the project site and would continue to do so in the future.
All future development projects in the project vicinity would be required to provide drainage
facilities that collect and detain runoff such that off-site releases are controlled and do not create
flooding. The proposed project would install a network of storm drainage facilities within the project
site consisting of inlets, underground piping, and basins. This system would serve 72.58 acres of the
site and direct runoff to a 3-acre on-site stormwater detention basin in the western portion of the
site. A flow control structure will be installed within the detention system to meter the outflow from
the site to below predevelopment levels. Catch basins will be located at various points within the
site to capture subarea flows. The system is designed to detain flows from a 100-year storm event as
required by the Orange County Hydrology Manual. Two sub drainage areas will flow directly to
Santiago Creek without detention. One of these areas is approximately 1.46 acres directly over the
Handy Creek Channel. This flow will be directed to the Handy Creek Channel. The other area is the
trail system adjacent to Santiago Creek and totals 6.20 acres. This flow will be picked up via a storm
drain system, which will outlet at the same location as the detention basin outlet. The outlet
structure from the detention basin to Santiago Creek will be protected by riprap and an energy
dissipater. This would ensure that the proposed project would not contribute to downstream
flooding conditions during peak storm events and would avoid cumulatively significant stormwater
impacts to downstream waterways at times when capacity is most constrained. The proposed
project would also implement pollution prevention measures during construction and operations to
ensure that downstream water quality impacts are minimized to the greatest extent possible.
Therefore, the proposed project, in conjunction with other planned and approved projects, would
not have a cumulatively significant impact related to storm drainage.
Solid Waste
The geographic scope of the cumulative solid waste analysis is the areas served by the Frank
Bowerman Sanitary Landfill, Olinda Alpha Sanitary Landfill, and the El Sobrante Landfill. The three
landfills have a combined remaining capacity of 384.7 million cubic yards.
Future development projects would generate construction and operational solid waste and,
depending on the volumes and end uses, would be required to implement recycling and waste
reduction measures. The proposed project is anticipated to generate 1,380 cubic yards of solid
waste during construction and a net increase of 142.1 cubic yards annually during operations. Both
waste generation values represent less than 1 percent of the remaining capacity figure at the three
landfills. As such, sufficient capacity is available to serve the proposed project as well as existing and
planned land uses in the City of Orange for the foreseeable future. Accordingly, the proposed
project, in conjunction with other future projects, would not have a cumulatively significant impact
related to solid waste.
Energy
The geographic scope of the cumulative energy analysis is the Southern California Edison (SCE)
service area (electricity) and the Southern California Gas Company service area (natural gas). SCE’s
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electrical service area consists of approximately 50,000 square miles and 5 million metered
customers. The Gas Company’s natural gas service area encompasses the southern San Joaquin
Valley, the Los Angeles Basin, the Inland Empire, and the Coachella Valley, and has approximately 5.9
million metered customers.
The proposed project would demand an estimated 805,632 million kilowatt-hours (kWh) of
electricity and 4.5 million cubic-feet of natural gas on an annual basis. The proposed project’s
structures would be designed in accordance with Title 24, California’s Energy Efficiency Standards for
Residential and Nonresidential Buildings. These standards include minimum energy efficiency
requirements related to building envelope, mechanical systems (e.g., HVAC and water heating
systems), indoor and outdoor lighting, and illuminated signs. The incorporation of the Title 24
standards into the project would ensure that the project would not result in the inefficient,
unnecessary, or wasteful consumption of energy. Therefore, the proposed project, in conjunction
with other future projects, would not have a cumulatively significant impact related to energy
consumption.
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SECTION 5: ALTERNATIVES TO THE PROPOSED PROJECT
5.1 - Introduction
In accordance with California Environmental Quality Act (CEQA) Guidelines Section 15126.6, this
Recirculated Draft Environmental Impact Report (RDEIR) contains a comparative impact assessment
of alternatives to the proposed project. The primary purpose of this section is to provide decision
makers and the general public with a reasonable number of feasible project alternatives that could
attain most of the basic project objectives, while avoiding or reducing any of the project’s significant
adverse environmental effects. Important considerations for these alternatives analyses are noted
below (as stated in CEQA Guidelines Section 15126.6).
• An EIR need not consider every conceivable alternative to a project;
• An EIR should identify alternatives that were considered by the lead agency, but rejected as
infeasible during the scoping process;
• Reasons for rejecting an alternative include:
- Failure to meet most of the basic project objectives;
- Infeasibility; or
- Inability to avoid significant environmental effects.
5.1.1 - Significant Unavoidable Impacts
Significant and unavoidable impacts identified in this RDEIR, include the following:
• As discussed in Impact AIR-1, the maximum daily construction emissions after the
implementation of Mitigation Measures AIR-1a through AIR-1g would continue to exceed the
South Coast Air Quality Management District’s (SCAQMD) regional significance thresholds.
Because no additional feasible mitigation measures are available, the project’s regional
operational emissions of NOX would continue to exceed the applicable SCAQMD regional
construction significance threshold even after implementation of all feasible mitigation. This
represents a significant and unavoidable impact.
• As discussed in Impact AIR-2, the project’s construction activities are estimated to generate a
maximum of 199.47 pounds of NOX per day with implementation of mitigation measures AIR-1a
through AIR-1g. As such, the project’s construction would continue to exceed the SCAQMD’s
recommended regional threshold of significance for NOX even after implementation of
Mitigation Measures AIR-1a through AIR-1g. The project’s construction activities are only
anticipated to exceed any of SCAQMD’s regional thresholds of significance during the combined
site preparation and grading period. A review of the detailed emissions estimates, contained in
Appendix F, show that 196.17 of the 199.47 pounds of NOX are from off-site sources. As
previously discussed, the project is anticipated to require up to 275,400 total haul trips during
the grading period. Because the exceedance is largely a result of the anticipated haul trips,
feasible and enforceable mitigation measures to reduce the impact are limited. Based on the
total haul trucks required each day and the fact that specific make and model of haul trucks can
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vary by contractor and within each contractor fleet, it would not be feasible to mandate the use
of specific vehicles to haul soil for the proposed project. Because no additional feasible
mitigation measures are available beyond those already quantified in Impact AIR-2, the project’s
regional operational emissions of NOX would continue to exceed the applicable SCAQMD
regional construction significance threshold even after implementation of all feasible mitigation.
This represents a significant and unavoidable impact.
• As discussed in Impact AIR-3, the region is non-attainment for the federal and State ozone
standards, the State PM10 standards, and the federal and state PM2.5 standards. Therefore, a
project that would not exceed the SCAQMD thresholds of significance on a project-level would
also not result in a cumulatively considerable contribution to these regional air quality
impacts. The impacts from the project would, therefore, be cumulatively less than significant
during project operations and significant and unavoidable during project construction.
• As discussed in Impact TRANS-2, while the fair share contribution provided through Mitigation
Measure TRANS-2 would mitigate the proposed project’s impacts at the intersection of
Orange Park Boulevard/East Santiago Canyon Road, impacts would be significant and
unavoidable as the Orange Park Boulevard/East Santiago Canyon Road intersection is not
listed in the City of Orange MPAH, or any similar plans.
All additional impacts analyzed within the Draft EIR were found to be less than significant after
mitigation or less than significant with no mitigation required.
5.1.2 - Alternatives to the Proposed Project
The four alternatives to the proposed project analyzed in this section are as follows:
• Development within the Existing Land Use Designations Alternative:
This alternative consists of new residential development and the continuation of existing sand
and gravel operations in accordance with the existing City of Orange General Plan
designations. Residential uses would be developed on 15.4 acres north of Santiago Creek (77
dwelling units), with sand and gravel activities occurring on 77.3 acres on both sides of the
waterway. The existing R-1-8 Zoning for the residential area would provide a maximum of 77
single-family dwelling units based on acre density and would yield approximately 40 to 50
single-family dwelling units (although a range of 32 to 92 dwelling units could be developed
under the existing land use designations). The Santiago Creek corridor would be designated
for open space (16.5 acres). The Development within the Existing Land Use Designations
Alternative is depicted in Exhibit 5-1.
• No Project Alternative/Existing Land Use Activities Alternative:
This alternative consists of the continuation of the sand and gravel operations on
approximately 77.3 acres of the project site. No dwelling units would be constructed on-site.
The project site would remain inaccessible to the public under this alternative.
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• Collaborative Group Alternative:
The Collaborative Group Alternative was developed in response to a series of meetings
between the Applicant representatives and the Collaborative Group, consisting of
representatives from Orange Park Acres, Mabury Ranch, and The Reserve.
The Collaborative Group Alternative consists of 47 lots, and 47 dwelling units of varying sizes,
on approximately 40 acres. The remaining 69.2 acres would be turned into the Santiago
Greenway Open Space area. Overall, the Collaborative Group Alternative would have 81
fewer dwellings, and would develop the residential on approximately 0.7 less acres than the
proposed project.
This alternative would not permit all items listed in the preface to the Draft EIR, which are a
part of the proposed project.
The Collaborative Liaison Committee Alternative is depicted in Exhibit 5-2.
• 122-Unit Alternative:
The 122-Unit Alternative was developed in response to a series of meetings between the
Applicant representatives and the Collaborative Group, consisting of representatives from
Orange Park Acres, Mabury Ranch, and The Reserve.
The 122-Unit Alternative consists of 122 lots, with an average lot size of 11,200-square-feet, on
40.9 acres of the project site. The remaining 68.3 acres of the project site would be turned into
open space consisting of 40.2 acres of Greenway Open Space, and 28.1 acres of Grasslands
Open Space. This alternative differs from the proposed project in that it would develop ten 0.5-
acre equestrian lots on the eastern border of the residential envelope, and twenty-four 10,000-
square-foot lots adjacent to East Santiago Canyon Road. Moreover, in response to input the
Applicant received during meetings with the Collaborative Group, this alternative proposes
larger lot sizes adjacent to the Preserve and portions of Orange Park Acres.
Overall, the 122-Unit Alternative would have six less dwellings than the proposed project, but
would develop approximately 0.2 additional acres of the project site for residential, thereby
reducing open space by approximately 0.2 acres in comparison to the proposed project.
Additionally, this alternative would have $1,000,000 less in local trail improvements from the
Development Agreement.
The 122-Unit Alternative is depicted in Exhibit 5-3.
Four alternatives to the proposed project are analyzed in the following section. These analyses
compare the proposed project and each individual project alternative. In several cases, the
description of the impact may be the same under each alternative when compared with the CEQA
Thresholds of Significance (i.e., both the project and the alternative would result in a less than
significant impact). The actual degree of impact may be slightly different between the proposed
project and each alternative, and this relative difference is the basis for a conclusion of greater or
lesser impacts.
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5.2 - Project Objectives
As stated in Section 2, Project Description, the objectives of the proposed project are to:
OBJ-1. Locate single-family detached residential units in the most suitable areas of the
project site and preserve other areas for open space and greenway.
OBJ-2. Preserve and protect Santiago Creek by abating the remnants of the resource
extraction activities and establishing a greenway along the creek corridor.
OBJ-3. Promote land use compatibility with neighboring residential uses through the use
of locating landscaped setbacks, and the development of a compatible housing
product and lot size to the adjoining uses.
OBJ-4. Develop a network of publicly accessible trails within the project site that provide
access to Santiago Creek and Santiago Oaks Regional Park.
OBJ-5. Lessen the noise, improve air quality, and reduce traffic impacts from the existing
materials recycling and backfilling operations within the project site.
OBJ-6. Provide a circulation system that will minimize adverse effects on local residential
neighborhoods and encourage pedestrian and bicycle circulation.
OBJ-7. Provide an infrastructure system, including sewer, water, and storm drain systems
that will adequately serve full build-out of the proposed project.
OBJ-8. Improve local circulation by widening of East Santiago Canyon Road and restriping
Cannon Road prior to the first certificate of occupancy.
5.3 - Alternative 1—Development within the Existing Land Use Designations
CEQA Guidelines Section 15126.6(e) requires that an EIR evaluate a “No Project Alternative,” which is
intended to allow decision-makers to compare the impacts of approving the proposed project with
the impacts of not approving the proposed project. In cases where the project constitutes a land
development project, the No Project Alternative is the “circumstance under which the project does
not proceed.” For many projects, the No Project Alternative represents a “No Development” or an
“Existing Conditions” scenario, in which the project site remains in its existing condition and no new
development occurs for the foreseeable future. However, CEQA Guidelines Section 15126.6(e)(3)(B)
establishes that “If disapproval of the project under consideration would result in predictable actions
by others such as the proposal of some other project, this ‘no project’ consequence should be
discussed.”
In this case, the No Project Alternative consists of development and land use activities that would
occur pursuant to the existing City of Orange General Plan land use designations of low-density
residential, resource, and open space for the project site.
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Exhibit 5-1
Development Within The Existing Land Use Designations Alternative
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source:
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Exhibit 5-2
Collaborative Group Alternative
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: July 20, 2018.
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Exhibit 5-3
122-Unit Alternative
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: May 2018.
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Residential uses would be developed on 15.4 acres north of Santiago Creek, with resource land use
activities (sand, gravel, and materials recycling) occurring on 77.3 acres on both sides of the waterway.1
Consistent with the City of Orange General Plan’s density range of 2.1 to 6.0 units per acre, there is an
allowable range of 32 to 92 residential homes, and a target of 77 residential homes on this 15.4-acre
residential land use parcel. The existing R-1-8 Zoning for the residential area would provide a
maximum of 77 single-family dwelling units based on acre density and would yield approximately 40 to
50 single-family dwelling units (although a range of 32 to 92 dwelling units could be developed under
the existing land use designations). Vehicular access would be taken from two points on Mabury Drive.
The intersection of East Santiago Canyon Road/Nicky Way would be improved to provide turn lanes
and improved access to the materials recycling and backfilling operation.
The total number of dwelling units that would be developed under this alternative would be 90.
Resource land use activities would be located on 77.3 acres on both sides of the waterway. These
activities would consist of the continuation of the existing materials recycling and backfilling operation.
The Santiago Creek corridor would be designated for open space (16.5 acres). However, no
community or recreational uses would be developed.
This alternative would require a General Plan Amendment to remove the project site from the East
Orange General Plan and Orange Park Acres Plan.
Table 5-1 summarizes the Development within the Existing Land Use Designations Alternative. The
Development within the Existing Land Use Designations Alternative is depicted in Exhibit 5-1.
Table 5-1: Development within the Existing Land Use Designations Alternative Summary
Scenario Land Use Acres Dwelling Units
Development within the Existing Land
Use Designations Alternative
Residential (North Bank) 15.4 77
Materials Recycling and
Backfilling/Sand and Gravel 77.3 —
Santiago Creek Greenway Open
Space 16.5 —
Subtotal 109.2 77
Proposed Project Residential 40.7 128
Santiago Creek Greenway Open
Space/Passive Green Area 68.5 —
Subtotal 109.2 128
Source: FCS, 2016.
1 The No Project Alternative/Existing Land Use Designations Alternative corresponds to Alternative F in the Pre-Development
Agreement (PDA). Refer to Section 2, Project Description for further discussion of the PDA.
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5.3.1 - Impact Analysis
Aesthetics, Light, and Glare
The Development within the Existing Land Use Designations Alternative consists of developing 77
dwelling units on 15.4 acres on the north side of Santiago Creek, and maintaining the existing resource
extraction activities on 77.3 acres of the project site. The addition of residential units on 15.4 acres on
the north bank of Santiago Creek alongside the existing 77.3 acres of resource extraction on the south
bank represents a net increase in development and disturbance relative to the proposed project, which
would result in greater visual change and more sources of light and glare. In contrast, the proposed
project would avoid any significant changes to the north bank of Santiago Creek and 68.5 acres of open
space overall and, thus, would not alter the existing visual or light and glare conditions of these areas.
Therefore, the Development within the Existing Land Use Designations Alternative would have greater
aesthetics, light, and glare impacts than the proposed project.
Agriculture Resources and Forest Resources
There are no agriculture or forest resources on the project site. Therefore, the Development within
the Existing Land Use Designations Alternative would have impacts on agriculture resources and
forest resources similar to the proposed project.
Air Quality
The Development within the Existing Land Use Designations Alternative consists of developing 77
dwelling units on 15.4 acres on the north side of Santiago Creek, and maintaining the existing
resource extraction activities on 77.3 acres of the project site. Overall, this represents a net
decrease in development activity relative to the proposed project and, thus, fewer construction
emissions of criteria pollutants would occur. Additionally, this alternative would generate 839 fewer
daily trips, which would result in fewer operational emissions of criteria pollutants. Therefore, the
Development within the Existing Land Use Designations Alternative would have fewer air quality
impacts than the proposed project.
Biological Resources
The Development within the Existing Land Use Designations Alternative consists of developing 77
dwelling units on 15.4 acres on the north side of Santiago Creek, and maintaining the existing
resource extraction activities on 77.3 acres of the project site. Overall, this represents a net increase
in disturbance relative to the proposed project, including to the most biologically sensitive areas on
the north bank of Santiago Creek. In contrast, the proposed project would avoid any disturbance to
the north bank of Santiago Creek and, thus, would not disturb any biological resources within this
area. Therefore, the Development within the Existing Land Use Designations Alternative would have
greater biological resources impacts than the proposed project.
Cultural Resources
The Development within the Existing Land Use Designations Alternative consists of developing 77
dwelling units on 15.4 acres on the north side of Santiago Creek, and maintaining the existing
resource extraction activities on 77.3 acres of the project site. Overall, this represents a net increase
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in development and disturbance relative to the proposed project, particularly within the undisturbed
areas on the north side of Santiago Creek. As noted in Section 3.5, Cultural Resources, the north side
of Santiago Creek that has exposures of undifferentiated deposits of the Oligo-Miocene Sespe/
Vaqueros Formations; these exposures have marine and non-marine components. In contrast, the
proposed project would avoid any disturbance to the north bank of Santiago Creek and, thus, would
not disturb any cultural resources within this area. Therefore, the Development within the Existing
Land Use Designations Alternative would have greater cultural resources impacts than the proposed
project.
Geology and Soils
The Development within the Existing Land Use Designations Alternative consists of developing 77
dwelling units on 15.4 acres on the north side of Santiago Creek, and maintaining the existing resource
extraction activities on 77.3 acres of the project site. Overall, this represents a net increase in
development and disturbance relative to the proposed project and, thus, greater potential for
exposure to seismic hazards and the potential for erosion. In contrast, the proposed project would
only develop and disturb 40.2-acres within the current resource extraction area and conserve the
north side of Santiago Creek as open space. Therefore, the Development within the Existing Land Use
Designations Alternative would have greater geology and soils impacts than the proposed project.
Greenhouse Gas Emissions
The Development within the Existing Land Use Designations Alternative consists of developing 77
dwelling units on 15.4 acres on the north side of Santiago Creek, and maintaining the existing
resource extraction activities on 77.3 acres of the project site. Overall, this represents a net
decrease in development activity relative to the proposed project and, thus, fewer construction
emissions of greenhouse gas (GHG) emissions would occur. Additionally, this alternative would
generate 839 fewer daily trips, which would result in fewer operational emissions of GHG emissions.
Therefore, the Development within the Existing Land Use Designations Alternative would have fewer
GHG emissions impacts than the proposed project.
Hazards and Hazardous Materials
The Development within the Existing Land Use Designations Alternative consists of developing 77
dwelling units on 15.4 acres on the north side of Santiago Creek, and maintaining the existing
resource extraction activities on 77.3 acres of the project site. Because the resource extraction
operation would continue, no mitigation for soil vapors (trichloroethylene and methane) or
petroleum-impacted soil would be implemented since these conditions do not pose a safety risk to
this land use activity. Furthermore, both the north side of Santiago Creek and the Mara Brandman
Arena do not contain any existing land use activities that involve the regular use of large qualities of
hazardous materials and are not listed on hazardous materials databases; thus, they are suitable to
support new residential development. Therefore, the Development within the Existing Land Use
Designations Alternative would have hazards and hazardous materials impacts similar to the
proposed project.
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Hydrology and Water Quality
The Development within the Existing Land Use Designations Alternative consists of developing 77
dwelling units on 15.4 acres on the north side of Santiago Creek, and maintaining the existing
resource extraction and backfilling activities on 77.3 acres of the project site. The existing resource
extraction and backfilling activities would continue to discharge into the Handy Creek storm drain.
The residential development would increase hydrology and water quality impacts north of Santiago
Creek, as the proposed project proposes Greenway Open Space north of Santiago Creek and moves
residential development to the south side of Santiago Creek. However, while the increase in
residential development would create greater impacts north of Santiago Creek, the extraction and
backfilling activities have a current grading permit, any change, update, or renewal of the permit
would need to be reviewed and approved as part of the permit process to ensure water quality
compliance. Therefore, Development within the Existing Land Use Activities Alternative would have
hydrology and water quality impacts similar to the proposed project.
Land Use and Planning
The Development within the Existing Land Use Designations Alternative consists of developing 77
dwelling units on 15.4 acres on the north side of Santiago Creek, and maintaining the existing
resource extraction activities on 77.3 acres of the project site. This alternative would maintain the
existing General Plan and zoning for the project site, whereas the proposed project would amend
the existing land use designations. Although the proposed amendments were found to be
compatible with the General Plan, Municipal Code, and surrounding land uses, this alternative would
avoid the need to do so. Therefore, the Development within the Existing Land Use Designations
Alternative would have fewer land use and planning impacts than the proposed project.
Mineral Resources
The Development within the Existing Land Use Designations Alternative consists of developing 77
dwelling units on 15.4 acres on the north side of Santiago Creek, and maintaining the existing
resource extraction activities on 77.3 acres of the project site. This alternative would retain 71
percent of the site for resource extraction activities. Thus, this alternative would lessen the severity
of impacts associated with the loss of mineral resources of statewide or local importance.
Therefore, the Development within the Existing Land Use Designations Alternative would have fewer
mineral resource impacts than the proposed project.
Noise
The Development within the Existing Land Use Designations Alternative consists of developing 77
dwelling units on 15.4 acres on the north side of Santiago Creek, and maintaining the existing
resource extraction activities on 77.3 acres of the project site. Under this Alternative, the north
bank of Santiago Creek would see an increase in noise levels from construction compared with the
proposed project, which does not place development in this area. However, overall, this represents
a net decrease in development activity relative to the proposed project and, thus, less construction
noise would occur. Additionally, this alternative would generate 839 fewer daily trips, which would
result in slightly less roadway noise. Therefore, the Development within the Existing Land Use
Designations Alternative would have fewer noise impacts than the proposed project.
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Population and Housing
The Development within the Existing Land Use Designations Alternative consists of developing 77
dwelling units within the project site, a net decrease of 66 dwelling units relative to the proposed
project. The reduction in dwelling units would decrease the population growth attributable to this
alternative by 195 persons relative to the proposed project. Additionally, both the portion of the
project site that would support residential uses under this alternative and the Mara Brandman Arena
are designated for residential uses, and, therefore, this population increase would be considered
“planned growth.” Therefore, the Development within the Existing Land Use Designations
Alternative would have fewer population and housing impacts than the proposed project.
Public Services
The Development within the Existing Land Use Designations Alternative consists of developing 77
dwelling units within the project site, a net decrease of 66 dwelling units relative to the proposed
project. The reduction in dwelling units would reduce the population growth attributable to this
alternative by 195 persons relative to the proposed project. This would result in a decrease in
demand for fire, police, schools, parks, and other public facilities. Furthermore, the existing resource
extraction operation, which has negligible demand for public services, would continue as a land use
activity. Therefore, the Development within the Existing Land Use Designations Alternative would
have fewer public services impacts than the proposed project.
Recreation
The Development within the Existing Land Use Designations Alternative consists of developing 77
dwelling units within the project site, a net decrease of 66 dwelling units relative to the proposed
project. The reduction in dwelling units would reduce the population growth attributable to this
alternative by 195 persons relative to the proposed project. This would result in a decrease in
demand for recreation. Furthermore, the proposed project’s recreational uses would not be
developed under this alternative. While this would result in fewer new recreational opportunities, it
would also avoid creating any impacts associated with the development of these facilities.
Therefore, the Development within the Existing Land Use Designations Alternative would have fewer
recreation impacts than the proposed project.
Transportation
The Development within the Existing Land Use Designations Alternative consists of developing 40
dwelling units on 15.4 acres on the north side of Santiago Creek, and maintaining the existing
resource extraction activities on 77.3 acres of the project site. Table 5-2 summarizes the trip
generation associated with this alternative. As shown in the table, this alternative would result in a
net decrease of 839 daily trips, a net decrease of 65 AM peak-hour trips, and a net decrease of 88
PM peak-hour trips. The proposed project was found to contribute to deficient operations at one
intersection (East Santiago Canyon Road/Orange Park Boulevard) during the PM peak-hour and
would implement mitigation in form of fair-share payments to fund improvements to restore
operations to acceptable levels. Thus, this alternative would implement similar mitigation and yield
a similar conclusion; however, because it generates fewer trips during the impacted peak-hour, it
would lessen the severity of impacts.
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Table 5-2: Development within the Existing Land Use Designations Alternative Trip
Generation Comparison
Scenario
Net Change in Trips
Daily AM Peak PM Peak
Development within the Existing Land Use
Designations Alternative
380 31 40
Proposed Project 1,219 96 128
Difference (839) (65) (88)
Note:
The Development within the Existing Land Use Designations Alternative excludes existing materials and recycling trip
generation as this is an existing use that would be maintained. Additionally, the 16.5-acre open space area along
Santiago Creek would not generate any trips because it would not be publicly accessible.
Source: FCS, 2017.
This alternative would also require improvements to the East Santiago Canyon Road/Nicky Way
intersection, which would provide access to the resource extraction operations on the project site.
Additionally, improvements would be required to Mabury Drive to allow for access to the residential
uses developed on the north side of Santiago Creek.
Overall, this alternative would generate fewer trips than the proposed project. Therefore, the
Development within the Existing Land Use Designations Alternative would have fewer transportation
impacts than the proposed project.
Tribal Cultural Resources
The Development within the Existing Land Use Designations Alternative consists of developing 77
dwelling units on 15.4 acres on the north side of Santiago Creek, and maintaining the existing
resource extraction activities on 77.3 acres of the project site. Overall, this represents a net increase
in development and disturbance relative to the proposed project, particularly within the undisturbed
areas on the north side of Santiago Creek. In contrast, the proposed project would avoid any
disturbance to the north bank of Santiago Creek and, thus, would not disturb any potential tribal
cultural resources within this area. Therefore, the Development within the Existing Land Use
Designations Alternative would have greater tribal cultural resources impacts than the proposed
project.
Utilities and Service Systems
The Development within the Existing Land Use Designations Alternative consists of developing 77
dwelling units within the project site, a net decrease of 72 dwelling units relative to the proposed
project. The reduction in dwelling units would decrease the population growth attributable to this
alternative by 195 persons relative to the proposed project. This would result in less demand than
the proposed project for water, wastewater, solid waste, electricity, and natural gas.
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For storm drainage, the net increase in development and disturbance relative to the proposed
project would have a greater potential for additional runoff to be added to downstream waterways.
In particular, the existing resource extraction activities would continue to discharge into the Handy
Creek storm drain, which lacks sufficient capacity for a 100-year storm event. In contrast, the
proposed project would result in a net decrease in discharge to the Handy Creek storm drain, which
would serve to lessen the severity of this existing deficient condition.
Therefore, the Development within the Existing Land Use Designations Alternative would have fewer
utilities and service system impacts than the proposed project.
5.3.2 - Conclusion
The Development within the Existing Land Use Designations Alternative would increase the severity
of the proposed project’s aesthetics, light, and glare; biological resources; cultural resources;
geology and soils; tribal cultural resources; and hydrology and water quality. However, it would
lessen the severity of the proposed project’s air quality, GHG, land use, mineral resources, noise,
population and housing, public services, recreation, transportation, and utilities and service systems
impacts. This alternative would yield similar impacts for all other topics.
The Development within the Existing Land Use Designations Alternative would advance some, but
not all of the project objectives. This alternative would advance the objectives that concern
clustering residential development in the most suitable areas of the project site; and promoting land
use compatibility with surrounding land uses. However, none of these objectives would be
advanced to the same degree as the proposed project because (1) fewer dwelling units would be
developed; (2) the resource extraction land use activities would be retained; (3) less open space
would be provided; and (4) no public recreational facilities would be provided.
Furthermore, this alternative would not advance the objectives that concern facilitating the
redevelopment of an unsightly, underused resource extraction site; guiding the transition of an infill
site with a Specific Plan; protecting Santiago Creek by abating the remnants of the resource
extraction activities; strategically locating the adjoining Villa Park Landfill and the proposed
residential uses; and developing a logical internal circulation system for pedestrians, bicyclists,
equestrians, and motorists.
5.4 - Alternative 2—No Project Alternative/Existing Land Use Activities
Alternative
The No Project Alternative/Existing Land Use Activities Alternative consists of the continuation of the
existing sand and gravel operations on approximately 77.3 acres of the project site. Approximately
40 acres between Santiago Creek and East Santiago Canyon Road are characterized by soil piles and
berms, unpaved roads. An approximately 5-acre area near East Santiago Canyon Road supports a
materials recycling operation that includes apparatus for crushing boulders, bricks, rocks, and similar
materials for recycling. Since 2015, backfilling operations have been limited to 15 consecutive
business days in any 6-month period; this alternative would allow backfilling operations to resume
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year-round as allowed by the current grading permit. The project site would remain inaccessible to
the public under this alternative.
5.4.1 - Impact Analysis
Aesthetics, Light, and Glare
The No Project Alternative/Existing Land Use Activities Alternative consists of maintaining the
existing resource extraction activities on 77.3 acres of the project site. Overall, this represents a net
increase in disturbance relative to the proposed project, because the 77.3-acre backfilling operations
would resume year-round as allowed by the grading permit and the proposed project would disturb
only 40.7-acres, which would result in greater visual change and more sources of light and glare.
Therefore, the No Project Alternative/Existing Land Use Activities Alternative would have greater
aesthetics, light, and glare impacts than the proposed project.
Agriculture Resources and Forest Resources
There are no agriculture or forest resources on the project site. Therefore, the No Project
Alternative/Existing Land Use Activities Alternative would have no impacts on agriculture resources
and forest resources similar to the proposed project.
Air Quality
The No Project Alternative/Existing Land Use Activities Alternative consists of maintaining the
existing resource extraction activities on 77.3 acres of the project site. Compared with the
continuation of backfilling operations as allowed by the current grading permit that would take place
under the continued resource extraction activities, this alternative would generate 533 fewer daily
trips, which would result in fewer operational emissions of criteria pollutants. Therefore, the No
Project Alternative/Existing Land Use Activities Alternative would have fewer air quality impacts than
the proposed project.
Biological Resources
The No Project Alternative/Existing Land Use Activities Alternative consists of maintaining the
existing resource extraction activities on the full 77.3 acres of the project site. Overall, this
represents a net increase in disturbance relative to the proposed project, as the proposed project
would create 68.5-acres of open space and only disturb 40.7-acres. Therefore, the No Project
Alternative/Existing Land Use Activities Alternative would have greater biological resources impacts
than the proposed project.
Cultural Resources
The No Project Alternative/Existing Land Use Activities Alternative consists of maintaining the
existing resource extraction activities on 77.3 acres of the project site. Since current resource
extraction activities have already disturbed the 77.3 acres, the No Project Alternative/Existing Land
Use Activities Alternative would have fewer cultural resources impacts than the proposed project.
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Geology and Soils
The No Project Alternative/Existing Land Use Activities Alternative consists of maintaining the
existing resource extraction activities on 77.3 acres of the project site. Since the No Project
Alternative/Existing Land Use Activities Alternative does not include residential development, there
would be fewer impacts related to seismic hazards. However, overall, this represents a net increase
in disturbance relative to the proposed project and, thus, greater potential for exposure to seismic
hazards and the potential for erosion. Therefore, the No Project Alternative/Existing Land Use
Activities Alternative would have greater geology and soils impacts than the proposed project.
Greenhouse Gas Emissions
The No Project Alternative/Existing Land Use Activities Alternative consists of maintaining the
existing resource extraction activities on 77.3 acres of the project site. This alternative would
generate 533 fewer daily trips, which would result in fewer operational emissions of GHG emissions.
Therefore, the No Project Alternative/Existing Land Use Activities Alternative would have fewer GHG
emissions impacts than the proposed project.
Hazards and Hazardous Material
The No Project Alternative/Existing Land Use Activities Alternative consists of maintaining the
existing resource extraction activities on 77.3 acres of the project site. Because the resource
extraction operation would continue, no mitigation for soil vapors (trichloroethylene and methane)
or petroleum-impacted soil would be implemented since these conditions do not pose a safety risk
to this land use activity. Therefore, the No Project Alternative/Existing Land Use Activities
Alternative would result in hazards and hazardous materials impacts similar to the proposed project.
Hydrology and Water Quality
The No Project Alternative/Existing Land Use Activities Alternative consists of maintaining the
existing resource extraction activities on 77.3 acres of the project site. The existing resource
extraction and backfilling activities would continue to discharge into the Handy Creek storm drain.
The extraction and backfilling activities have a current grading permit, any change, update, or
renewal of the permit would need to be reviewed and approved as part of the permit process to
ensure water quality compliance. Therefore, the No Project Alternative/Existing Land Use Activities
Alternative would have fewer hydrology and water quality impacts than the proposed project.
Land Use and Planning
The No Project Alternative/Existing Land Use Activities Alternative consists of maintaining the
existing resource extraction activities on 77.3 acres of the project site. This alternative would
maintain the existing City of Orange General Plan and zoning for the project site, whereas the
proposed project would amend the existing land use designations. Although the proposed
amendments were found to be compatible with the City of Orange General Plan, Municipal Code,
and surrounding land uses, this alternative would avoid the need to do so. Therefore, the No Project
Alternative/Existing Land Use Activities Alternative would have fewer land use and planning impacts
than the proposed project.
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Mineral Resources
The No Project Alternative/Existing Land Use Activities Alternative consists of maintaining the
existing resource extraction activities on 77.3 acres of the project site. This alternative would retain
71 percent of the site for resource extraction activities; hence, extraction and backfilling operations
would resume year-round as allowed by the grading permit. Thus, this alternative would lessen the
severity of impacts associated with the loss of mineral resources of statewide or local importance.
Therefore, the No Project Alternative/Existing Land Use Activities Alternative would have fewer
mineral resource impacts than the proposed project.
Noise
The No Project Alternative/Existing Land Use Activities Alternative consists of maintaining the
existing resource extraction activities on 77.3 acres of the project site. Overall, this represents a net
increase in disturbance relative to the proposed project. This alternative would generate 533 fewer
daily trips than the proposed project, which would result in slightly less roadway noise. However,
this alternative would result in a greater number of operational heavy-duty vehicles on-site, since
extraction and backfilling operations would resume year-round as allowed by the grading permit.
Therefore, the No Project Alternative/Existing Land Use Activities Alternative would have greater
impacts than the proposed project.
Population and Housing
The No Project Alternative/Existing Land Use Activities Alternative consists of maintaining the existing
resource extraction activities on 77.3 acres of the project site. No dwelling units would be built on the
project site under this alternative. Therefore, the No Project Alternative/Existing Land Use Activities
Alternative would have fewer population and housing impacts than the proposed project.
Public Services
The No Project Alternative/Existing Land Use Activities Alternative consists of maintaining the
existing resource extraction activities on 77.3 acres of the project site. No dwelling units would be
built on the project site under this alternative. This would result in a decrease in demand for fire,
police, schools, parks, and other public facilities. Furthermore, the existing resource extraction
operation, which has negligible demand for public services, would continue as a land use activity.
Therefore, the No Project Alternative/Existing Land Use Activities Alternative would have fewer
public services impacts than the proposed project.
Recreation
The No Project Alternative/Existing Land Use Activities Alternative consists of maintaining the
existing resource extraction activities on 77.3 acres of the project site. No dwelling units would be
built on the project site under this alternative. This would result in a decrease in demand for
recreation. Furthermore, the proposed project’s recreational uses would not be developed under
this alternative. While this would result in fewer new recreational opportunities, it would also avoid
creating any impacts associated with the development of these facilities. Therefore, the No Project
Alternative/Existing Land Use Activities Alternative would have fewer recreation impacts than the
proposed project.
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Transportation and Traffic
The No Project Alternative/Existing Land Use Activities Alternative consists of maintaining the existing
resource extraction activities on 77.3 acres of the project site. Table 5-3 summarizes the trip
generation associated with this alternative. As shown in the table, this alternative would result in a net
decrease of 533 daily trips, a net decrease of 33 AM peak-hour trips, and a net decrease of 96 PM
peak-hour trips.
The proposed project was found to contribute to deficient operations at one intersection (East
Santiago Canyon Road/Orange Park Boulevard) during the PM peak-hour and would implement
mitigation in form of fair-share payments to fund improvements to restore operations to acceptable
levels. Because this alternative generates fewer trips, it would result in less severe impacts.
Therefore, the No Project Alternative/Existing Land Use Activities Alternative would have fewer
transportation impacts than the proposed project.
Table 5-3: No Project Alternative/Existing Land Use Activities Alternative Trip Generation
Comparison
Scenario
Net Change in Trips
Daily AM Peak PM Peak
No Project Alternative/Existing Land Use
Activities Alternative 686 63 32
Proposed Project 1,219 96 128
Difference (533) (33) (96)
Source: Elfend & Associates, 2017
Tribal Cultural Resources
The No Project Alternative/Existing Land Use Activities Alternative consists of maintaining the existing
resource extraction activities on 77.3 acres of the project site. As the current resource extraction
activities have already disturbed the 77.3 acres, the No Project Alternative/Existing Land Use Activities
Alternative would have tribal cultural resources impacts similar to the proposed project.
Utilities and Service Systems
The No Project Alternative/Existing Land Use Activities Alternative consists of maintaining the
existing resource extraction activities on 77.3 acres of the project site. No dwelling units would be
built on the project site under this alternative. This would result in less demand for water,
wastewater, solid waste, electricity, and natural gas. In particular, the existing resource extraction
activities would continue to discharge into the Handy Creek storm drain, which lacks sufficient
capacity for a 100-year storm event. In contrast, the proposed project would result in a net decrease
in discharge to the Handy Creek storm drain, which would serve to lessen the severity of this existing
deficient condition. Therefore, the No Project Alternative/Existing Land Use Activities Alternative
would have greater utilities and service system impacts than the proposed project.
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5.4.2 - Conclusion
The No Project Alternative/Existing Land Use Activities Alternative would increase the severity of the
proposed project’s aesthetics, light, and glare; biological resources; cultural resources; geology and
soils; noise and utilities and service systems impacts. However, it would lessen the severity of the
proposed project’s air quality, GHGs, hydrology and water quality, mineral resources, population and
housing, public services, recreation, and transportation and traffic impacts. This alternative would
yield similar impacts for agricultural resources and hazards and hazardous materials.
The No Project Alternative/Existing Land Use Activities Alternative would advance some, but not all,
of the project objectives. This alternative would advance the objectives that concern positively
contributing to the local economy through ongoing mineral extraction. However, none of the
objectives would be advanced to the same degree as the proposed project because (1) no dwelling
units would be developed; (2) the resource extraction land use activities would be retained; (3) less
open space would be provided; and (4) no public recreational facilities would be provided.
Furthermore, this alternative would not advance the objectives that concern facilitating the
redevelopment of an unsightly, underused resource extraction site; guiding the transition of an infill
site with a Specific Plan; protecting Santiago Creek by abating the remnants of the resource
extraction activities; strategically locating the adjoining Villa Park Landfill and the proposed
residential uses; and developing a logical internal circulation system for pedestrians, bicyclists,
equestrians, and motorists.
5.5 - Alternative 3—Collaborative Group
The Collaborative Group Alternative was developed in response to meetings between the Applicant
representatives and the Collaborative Group, consisting of representatives from Orange Park Acres,
Mabury Ranch, and The Reserve.
The Collaborative Group Alternative consists of 47 lots and 47 dwelling units of varying sizes, on
approximately 40 acres. The remaining 69.2 acres would be turned into Santiago Greenway Open
Space area. Overall, the Collaborative Group Alternative would have 81 fewer dwellings and would
develop the residential on approximately 0.7 less acres than the proposed project.
This alternative would not permit all items listed in the preface to the Draft EIR, which are a part of
the proposed project. These items include the following improvements and related considerations:
1. The Specific Plan and associated project accommodates a maximum number of 128 single-
family detached lots located in the southerly portion of the property and will consist of
housing types and lot sizes compatible with the surrounding neighborhoods as depicted in
the Trails at Santiago Creek Specific Plan, Exhibits 3.1-3.4 and consistent with the
development standards and guidelines set forth in the Specific Plan.
2. The implementation of the Specific Plan and associated project will fund up to $1,000,000.00
for traffic improvements to widen East Santiago Canyon Road and restripe Cannon Road prior
to the issuance of the first Certificate of Occupancy of any housing units for the project. Please
refer to the Trails at Santiago Creek Specific Plan, Exhibit 4.1, Areas of Traffic Congestion—Pre-
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Project, Exhibit 4.2, Area of Project Related Traffic Improvements, and Exhibit 4.3, Additional
Project Related Traffic Improvements, and Section 4.2.3, Circulation Plan.
3. The implementation of the Specific Plan and associated project will fund approximately up to
a maximum of $4,100,000.00 in landscape and other improvements for the Santiago Creek
Greenway. Said Improvements are to be completed or funded prior to the issuance of the
60th Certificate of Occupancy for the Project. Please refer to the Trails at Santiago Creek
Specific Plan, Section 4.2.4, Trails, Open Space and Recreation Plan, and Exhibit 4.14,
Preliminary Greenway, Open Space and Trails Plan.
4. The implementation of the Specific Plan and associated project will fund $1,000,000.00 to be
used for in local area-wide equestrian trail purposes prior to the issuance of the first
Certificate of Occupancy for the project.
5. The implementation of the Specific Plan and associated project will finance and fund the
City’s acquisition of the Ridgeline Property, which will provide the community an additional
50 acres of public open space to the issuance of the first Certificate of Occupancy for the
Project. Please refer to the Trails at Santiago Creek Specific Plan, Exhibit 4.4, Sully Miller,
Arena and Ridgeline Properties.
6. The implementation of the Specific Plan and associated project will provide $2,000,000.00 for
equestrian and recreational purposes in the East Orange Area as determined by the City prior
to the issuance of the first Certificate of Occupancy for the project.
This alternative would require the same discretionary permits as the proposed project.
Table 5-4 summarizes the Collaborative Group Alternative. The Collaborative Group Alternative is
depicted in Exhibit 5-2.
Table 5-4: Collaborative Group Alternative Summary
Scenario Land Use Acres Dwelling Units
Collaborative Group Alternative Residential 40 47
Open Space 69.2 —
Subtotal 109.2 47
Proposed Project Residential 40.7 128
Santiago Creek Greenway Open
Space/Passive Green Area 68.5 —
Subtotal 109.2 128
Source: FCS, 2016.
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5.5.1 - Impact Analysis
Aesthetics, Light, and Glare
The Collaborative Group Alternative consists of 47 lots and 42 dwelling units of varying sizes, on
approximately 40 acres. The remaining 69.2 acres would be turned into the Santiago Greenway
Open Space area. Overall, the Collaborative Group Alternative would have 81 fewer dwellings, and
would develop the residential on approximately 0.7 less acres than the proposed project. As the
Collaborative Group Alternative would only develop residential uses on approximately 0.7 less acres
than the proposed project, a marginal amount, impacts to aesthetics, light, and glare would be similar
to the proposed project.
Agriculture Resources and Forest Resources
There are no agriculture or forest resources on the project site. Therefore, the Collaborative Group
Alternative would have impacts on agriculture resources and forest resources similar to the
proposed project.
Air Quality
The Collaborative Group Alternative consists of 47 lots and 47 dwelling units of varying sizes, on
approximately 40 acres. The remaining 69.2 acres would be turned into the Santiago Greenway
Open Space area. Overall, the Collaborative Group Alternative would have 81 fewer dwellings, and
would develop residential property on approximately 0.7 less acres than the proposed project;
therefore, construction emissions of this alternative are similar to the proposed project. However,
this alternative would generate 774 fewer daily trips, which would result in fewer operational
emissions of criteria pollutants. Therefore, the Collaborative Group Alternative would have fewer air
quality impacts than the proposed project.
Biological Resources
The Collaborative Group Alternative consists of 47 lots and 47 dwelling units of varying sizes, on
approximately 40 acres. The remaining 69.2 acres would be turned into the Santiago Greenway
Open Space area. Overall, the Collaborative Group Alternative would have 81 fewer dwellings, and
would develop residential uses on approximately 0.7 less acres than the proposed project. As the
Collaborative Group Alternative would only develop residential on approximately 0.7 less acres less
than the proposed project, a marginal amount, impacts to biological resources would be similar to the
proposed project.
Cultural Resources
The Collaborative Group Alternative consists of 47 lots and 47 dwelling units of varying sizes, on
approximately 40 acres. The remaining 69.2 acres would be turned into the Santiago Greenway
Open Space area. Overall, the Collaborative Group Alternative would have 81 fewer dwellings, and
would develop residential uses on approximately 0.7 less acres than the proposed project. As the
Collaborative Group Alternative would only develop residential on approximately 0.7 less acres less
than the proposed project, a marginal amount, impacts to cultural resources would be similar to the
proposed project.
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Geology and Soils
The Collaborative Group Alternative consists of 47 lots and 47 dwelling units of varying sizes, on
approximately 40 acres. The remaining 69.2 acres would be turned into the Santiago Greenway
Open Space area. Overall, the Collaborative Group Alternative would have 81 fewer dwellings, and
would develop residential uses on approximately 0.7 less acres than the proposed project. As the
Collaborative Group Alternative would only develop residential on approximately 0.7 less acres less
than the proposed project, a marginal amount, impacts to geology and soils would be similar to the
proposed project.
Greenhouse Gas Emissions
The Collaborative Group Alternative consists of 47 lots and 47 dwelling units of varying sizes, on
approximately 40 acres. The remaining 69.2 acres would be turned into the Santiago Greenway
Open Space area. Overall, the Collaborative Group Alternative would have 81 fewer dwellings, and
would develop residential uses on approximately 0.7 less acres than the proposed project; therefore,
construction emissions of this alternative are similar than the proposed project. However, this
alternative would generate 774 fewer daily trips, which would result in fewer operational emissions
of criteria pollutants. Therefore, the Collaborative Group Alternative would have fewer air quality
impacts than the proposed project.
Hazards and Hazardous Materials
The Collaborative Group Alternative consists of 47 lots and 47 dwelling units of varying sizes, on
approximately 40 acres. The remaining 69.2 acres would be turned into the Santiago Greenway
Open Space area. Overall, the Collaborative Group Alternative would have 81 fewer dwellings, and
would develop residential uses on approximately 0.7 less acres than the proposed project. As the
Collaborative Group Alternative would only develop residential on approximately 0.7 less acres less
than the proposed project, a marginal amount that would still require similar mitigation measures from
the residential development envelope. Impacts to hazards, and hazardous materials, would be similar
to the proposed project.
Hydrology and Water Quality
The Collaborative Group Alternative consists of 47 lots and 47 dwelling units of varying sizes, on
approximately 40 acres. The remaining 69.2 acres would be turned into the Santiago Greenway
Open Space area. Overall, the Collaborative Group Alternative would have 81 fewer dwellings, and
would develop the residential uses on approximately 0.7 less acres than the proposed project. As
the Collaborative Group Alternative would only develop residential on approximately 0.7 less acres
less than the proposed project, a marginal amount would still require similar mitigation measures from
the residential development envelope. Impacts to hydrology and water quality would be similar to the
proposed project.
Land Use and Planning
This alternative would require discretionary permits similar to those required for the proposed
project, a General Plan Amendment, and Rezone. Therefore, the Collaborative Group Alternative
would have land use and planning impacts similar to the proposed project.
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Mineral Resources
This alternative would develop the area currently designated for resource extraction activities, to the
same extent as the proposed project. Therefore, the Collaborative Group Alternative would have
mineral resource impacts similar to the proposed project.
Noise
The Collaborative Group Alternative consists of 47 lots and 47 dwelling units of varying sizes, on
approximately 40 acres. The remaining 69.2 acres would be turned into the Santiago Greenway
Open Space area. Overall, the Collaborative Group Alternative would have 81 fewer dwellings, and
would develop the residential on approximately 0.7 less acres than the proposed project. This
alternative would generate 774 fewer daily trips from having 81 fewer homes than the proposed
project, which would result in less roadway noise. Therefore, the Collaborative Group Alternative
would have fewer noise impacts than the proposed project.
Population and Housing
The Collaborative Group Alternative consists of 47 lots and 47 dwelling units of varying sizes, on
approximately 40 acres. The remaining 69.2 acres would be turned into the Santiago Greenway
Open Space area. Overall, the Collaborative Group Alternative would have 81 fewer dwellings. The
reduction in dwelling units would decrease the population growth attributable to this alternative by
243 persons relative to the proposed project. Therefore, the Collaborative Group Alternative would
have fewer population and housing impacts than the proposed project.
Public Services
The Collaborative Group Alternative consists of 47 lots and 47 dwelling units of varying sizes, on
approximately 40 acres. The remaining 69.2 acres would be turned into the Santiago Greenway
Open Space area. Overall, the Collaborative Group Alternative would have 81 fewer dwellings. The
reduction in dwelling units would decrease the population growth attributable to this alternative by
243 persons relative to the proposed project. This would result in a decrease in demand for fire,
police, schools, parks, and other public facilities. Therefore, the Collaborative Group Alternative
would have fewer public services impacts than the proposed project.
Recreation
The Collaborative Group Alternative consists of 47 lots and 47 dwelling units of varying sizes, on
approximately 40 acres. The remaining 69.2 acres would be turned into the Santiago Greenway
Open Space area. Overall, the Collaborative Group Alternative would have 81 fewer dwellings. The
reduction in dwelling units would decrease the population growth attributable to this alternative by
243 persons relative to the proposed project. This would result in a decrease in demand for
recreation. Therefore, the Collaborative Group Alternative would have fewer recreation impacts
than the proposed project.
Transportation
The Collaborative Group Alternative consists of 47 lots and 47 dwelling units of varying sizes, on
approximately 40 acres. The remaining 69.2 acres would be turned into the Santiago Greenway
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Open Space area. Overall, the Collaborative Group Alternative would have 81 fewer dwellings. Table
5-5 summarizes the trip generation associated with this alternative. As shown in the table, this
alternative would result in a net decrease of 774 daily trips, a net decrease of 61 AM peak-hour trips,
and a net decrease of 81 PM peak-hour trips.
Table 5-5: Collaborative Group Alternative Trip Generation Comparison
Scenario
Net Change in Trips
Daily AM Peak PM Peak
Collaborative Group Alternative 445 36 47
Proposed Project 1,219 96 128
Difference (774) (60) (81)
Source: FCS, 2018.
This alternative would require the same transportation improvements as the proposed project,
which was found to contribute to deficient operations at one intersection (East Santiago Canyon
Road/Orange Park Boulevard) during the PM peak-hour, and would implement mitigation in the form
of fair-share payments to fund improvements to restore operations to acceptable levels. As such,
this alternative would require similar mitigation as the proposed project.
Overall, this alternative would generate fewer trips than the proposed project. Therefore, the
Collaborative Group Alternative would have fewer transportation impacts than the proposed project.
Tribal Cultural Resources
The Collaborative Group Alternative consists of 47 lots of varying sizes, on approximately 40 acres. The
remaining 69.2 acres would be turned into the Santiago Greenway Open Space area. Overall, the
Collaborative Group Alternative would have 81 fewer dwellings, and would develop the residential
uses on approximately 0.7 less acres than the proposed project. Overall, this represents a net marginal
decrease in development and disturbance relative to the proposed project. The Collaborative Group
alternative would require mitigation similar to the proposed project. Therefore, the Collaborative
Group Alternative would have similar tribal cultural resources impacts than the proposed project.
Utilities and Service Systems
The Collaborative Group Alternative consists of 47 lots of varying sizes, on approximately 40 acres.
The remaining 69.2 acres would be turned into the Santiago Greenway Open Space area. Overall,
the Collaborative Group Alternative would have 81 fewer dwellings. The reduction in dwelling units
would decrease the population growth attributable to this alternative by 243 persons relative to the
proposed project. This would result in less demand than the proposed project for water,
wastewater, solid waste, electricity, and natural gas.
For storm drainage, the net decrease in development and disturbance relative to the proposed
project would have a greater potential for additional runoff to be added to downstream waterways.
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Therefore, overall, the Collaborative Group Alternative would have fewer utilities and service system
impacts than the proposed project.
5.5.2 - Conclusion
The Collaborative Group Alternative would lessen the severity of the proposed project’s air quality,
GHG, population and housing, noise, public services, recreation, transportation, and utilities and
service systems impacts. This alternative would yield similar impacts for all other topics.
The Collaborative Group Alternative would advance some, but not all of the project objectives. This
alternative would advance the objectives that concern clustering residential development in the most
suitable areas of the project site; and promoting land use compatibility with surrounding land uses.
This alternative would not advance the objectives that concern guiding the transition of an infill site with
a Specific Plan; developing a logical internal circulation system for pedestrians, bicyclists, equestrians,
and motorists; and would not include the Development Agreement benefits to the community.
5.6 - Alternative 4—122-Unit
The 122-Unit Alternative was developed in response to a series of meetings between the Applicant
representatives and the Collaborative Group, consisting of representatives from Orange Park Acres,
Mabury Ranch, and The Reserve.
The 122-Unit Alternative consists of 122 lots with an average lot size of 11,200-square-feet on 40.9
acres of the project site. The remaining 68.3 acres of the project site would be turned into 68.3
acres of open space consisting of 40.2 acres of Greenway Open Space, and 28.1 acres of Grasslands
Open Space. This alternative differs from the proposed project in that it would develop ten 0.5-acre
equestrian lots on the eastern border of the residential envelope and twenty-four 10,000-square-
foot lots adjacent to East Santiago Canyon Road. Moreover, in response to input, the Applicant
representatives received during meetings with the Collaborative Group, this alternative proposes
larger lot sizes adjacent to The Preserve and portions of Orange Park Acres.
Table 5-6 summarizes the residential lots of the 122-Unit Alternative.
Table 5-6: 122-Unit Alternative Residential Lot Sizes
Lot Size Number of Lots
Half-Acre Equestrian 10
80 x 125 (10,000 square feet) 24
80 x 100 (8,000 square feet) 29
70 x 115 (8,000 square feet) 43
65 x 125 (8,000 square feet) 16
Source: Milan REI X, 2018
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Overall, the 122-Unit Alternative would have six less dwellings than the proposed project, but would
develop, approximately, an additional 0.2 acres of the project site for residential, reducing open
space by approximately 0.2 acres in comparison to the proposed project.
Additionally, this alternative would have $1,000,000 less in local trail improvements from the
Development Agreement.
This alternative would require the same discretionary permits as the proposed project.
Table 5-7 summarizes the 122-Unit Alternative. The 122-Unit Alternative is depicted in Exhibit 5-3.
Table 5-7: 122-Unit Alternative Summary
Scenario Land Use Acres Dwelling Units
122-Unit Alternative Residential 40.9 122
Santiago Creek Greenway Open
Space/Passive Green Area 68.3 —
Subtotal 109.2 122
Proposed Project Residential 40.7 128
Santiago Creek Greenway Open
Space/Passive Green Area 68.5 —
Subtotal 109.2 128
Source: MMA Planning & Design, FCS. May, 2018.
5.6.1 - Impact Analysis
Aesthetics, Light, and Glare
The 122-Unit Alternative consists of a 122-unit residential development on 40.9 acres with an
average lot size of 11,200-square-feet. 68.3 acres of the development will remain open space. The
development envelope of the residential area is greater than the proposed project, developing
residential on 0.2 acres more than the proposed project. Additionally, there would be six less
dwelling units than the proposed project, however, the dwelling unit reduction would only negligibly
reduce impacts to aesthetics, light, and glare. Therefore, impacts to aesthetics, light, and glare would
be similar to the proposed project.
Agriculture Resources and Forest Resources
There are no agriculture or forest resources on the project site. Therefore, the 122-Unit Alternative
would have impacts on agriculture resources and forest resources similar to the proposed project.
Air Quality
The 122-Unit Alternative consists of a 122-unit residential development on 40.9 acres with an
average lot size of 11,200-square-feet. 68.3 acres of the development will remain open space.
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Overall, this alternative would have six less dwelling units, 0.2 acres of more residential, and 0.2 acres of
less open space; therefore, construction emissions of this alternative are similar to the proposed
project. However, this alternative would generate 62 fewer daily trips, which would result in fewer
operational emissions of criteria pollutants. Therefore, the 122-Unit Alternative would have fewer
air quality impacts than the proposed project.
Biological Resources
The 122-Unit Alternative consists of a 122-unit residential development on 40.9 acres with an
average lot size of 11,200-square-feet. 68.3 acres of the development will remain open space on the
same development envelope as the proposed project. The development envelope of the residential
area is greater than the proposed project, developing residential on 0.2 acres more than the
proposed project. However, the 0.2-acre expansion of residential would not impact sensitive
biological communities. Therefore, the 122-Unit Alternative would have similar biological resources
impacts to the proposed project.
Cultural Resources
The 122-Unit Alternative consists of a 122-unit residential development on 40.9 acres with an average
lot size of 11,200-square-feet. 68.3 acres of the development will remain open space. The
development envelope of the residential area is greater than the proposed project, with residential
development on 0.2 acres more than the proposed project. As such, there could be impacts to cultural
resources and mitigation measures similar to the proposed project would be required. Therefore, the
122-Unit Alternative would have cultural resources impacts similar to the proposed project.
Geology and Soils
The 122-Unit Alternative consists of a 122-unit residential development on 40.9 acres with an average
lot size of 11,200-square-feet. 68.3 acres of the development will remain open space. The
development envelope of the residential area is greater than the proposed project, with residential
development on 0.2 acres more than the proposed project. As such, there could be impacts to geology
and soils and mitigation measures similar to the proposed project would be required. Therefore, the
122-Unit Alternative would have similar geology and soils impacts than the proposed project.
Greenhouse Gas Emissions
The 122-Unit Alternative consists of a 122-unit residential development on 40.9 acres with an
average lot size of 11,200-square-feet. 68.3 acres of the development will remain open space.
Overall, this alternative would have seven less dwelling units, 0.2 acres more residential, and 0.2 acres
less open space; therefore, construction emissions of this alternative would be similar to the
proposed project. However, this alternative would generate 62 fewer daily trips, which would result
in fewer operational emissions of criteria pollutants. Therefore, the 122-Unit Alternative would have
fewer air quality impacts than the proposed project.
Hazards and Hazardous Materials
The 122-Unit Alternative consists of a 122-unit residential development on 40.9 acres with an average
lot size of 11,200-square-feet. 68.3 acres of the development will remain open space. This alternative
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would have similar impacts to the proposed project and as such, would require similar mitigation
measures. Therefore, the 122-Unit Alternative would have hazards and hazardous materials impacts
similar to the proposed project.
Hydrology and Water Quality
The 122-Unit Alternative consists of a 122-unit residential development on 40.9 acres with an
average lot size of 11,200-square-feet. 68.3 acres of the development will remain open space. The
development envelope of the residential area is greater than the proposed project, developing
residential on 0.2 acres more than the proposed project. As such, there could be more impacts to
hydrology and water quality and mitigation measures similar to the proposed project would be
required. Therefore, 122-Unit Alternative would have hydrology and water quality impacts similar to
the proposed project.
Land Use and Planning
The 122-Unit Alternative consists of a 122-unit residential development on 40.9 acres with an
average lot size of 11,200-square-feet. 68.3 acres of the development will remain open space. This
alternative would require discretionary permits similar to those required for the proposed project, a
General Plan Amendment, and Rezone. Therefore, the 122-Unit Alternative would have land use and
planning impacts similar to the proposed project.
Mineral Resources
The 122-Unit Alternative consists of a 122-unit residential development on 40.9 acres with an average
lot size of 11,200-square-feet. 68.3 acres of the development will remain open space. This alternative
would develop the area currently designated for resource extraction activities, to the same extent as
the proposed project. Therefore, the 122-Unit Alternative would have mineral resource impacts
similar to the proposed project.
Noise
The 122-Unit Alternative consists of a 122-unit residential development on 40.9 acres with an
average lot size of 11,200-square-feet. 68.3 acres of the development will remain open space. As
such, construction noise impacts would be similar and operational noise impacts would be negligible
with the reduction of six dwelling units. Therefore, the 122-Unit Alternative would have noise
impacts similar to the proposed project.
Population and Housing
The 122-Unit Alternative consists of a 122-unit residential development on 40.9 acres with an
average lot size of 11,200-square-feet. 68.3 acres of the development will remain open space. The
reduction of six dwelling units would decrease the population growth attributable to this alternative
by 20 persons relative to the proposed project; population growth from the 122-Unit Alternative
would be similar to the proposed project. Therefore, the 122-Unit Alternative would have
population and housing impacts similar to the proposed project.
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Public Services
The 122-Unit Alternative consists of a 122-unit residential development on 40.9 acres with an
average lot size of 11,200-square-feet. 68.3 acres of the development will remain open space. The
reduction of six dwelling units would decrease the population growth attributable to this alternative
by 20 persons relative to the proposed project. This would result in a similar demand for fire, police,
schools, parks, and other public facilities. Therefore, the 122-Unit Alternative would have public
services impacts similar to the proposed project.
Recreation
The 122-Unit Alternative consists of a 122-unit residential development on 40.9 acres with an
average lot size of 11,200-square-feet. 68.3 acres of the development will remain open space. The
reduction of six dwelling units would decrease the population growth attributable to this alternative
by 20 persons relative to the proposed project. This would result in a similar demand for recreation.
Therefore, the 122-Unit Alternative would have recreation impacts similar to the proposed project.
Transportation
The 122-Unit Alternative consists of a 122-unit residential development on 40.9 acres with an average
lot size of 11,200-square-feet. 68.3 acres of the development will remain open space. Table 5-8
summarizes the trip generation associated with this alternative. As shown in the table, this alternative
would result in a net decrease of 62 daily trips, a net decrease of 2 AM peak-hour trips, and a net
decrease of 6 PM peak-hour trips.
Table 5-8: 122-Unit Alternative Trip Generation Comparison
Scenario
Net Change in Trips
Daily AM Peak PM Peak
122-Unit Alternative 1,157 94 122
Proposed Project 1,219 96 128
Difference (62) (2) (6)
Source: FCS, 2018.
This alternative would require the same transportation improvements as the proposed project: the
proposed project was found to contribute to deficient operations at one intersection (East Santiago
Canyon Road/Orange Park Boulevard) during the PM peak-hour, and would implement mitigation in
form of fair-share payments to fund improvements to restore operations to acceptable levels. As
such, this alternative would require the same mitigation as the proposed project.
Therefore, the 122-Unit Alternative would have transportation impacts similar to the proposed
project.
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Tribal Cultural Resources
The 122-Unit Alternative consists of a 122-unit residential development on 40.9 acres with an
average lot size of 11,200-square-feet. 68.3 acres of the development will remain open space. The
development envelope of the residential area is greater than the proposed project, developing
residential on 0.2 acres more than the proposed project. As such, there could be impacts to tribal
cultural resources and mitigation measures similar to the proposed project would be required.
Therefore, the 122-Unit Alternative would have tribal cultural resources impacts similar to the
proposed project.
Utilities and Service Systems
The 122-Unit Alternative consists of a 122-unit residential development on 40.9 acres with an
average lot size of 11,200-square-feet. 68.3 acres of the development will remain open space. This
alternative would have six less dwelling units than the proposed project. The reduction in dwelling
units would decrease the population growth attributable to this alternative by 20 persons relative to
the proposed project. This would result in negligible decrease in demand compared to the proposed
project for water, wastewater, solid waste, electricity, and natural gas.
For storm drainage, the net increase in development and disturbance relative to the proposed
project would have negligible additional runoff to be added to downstream waterways. The 122-
Unit Alternative and the proposed project would result in a similar increase in discharge to the
Handy Creek storm drain.
Therefore, overall, the 122-Unit Alternative would have utilities and service system impacts similar
to the proposed project.
5.6.2 - Conclusion
The 122-Unit Alternative would yield similar impacts to the proposed project for all topics.
The 122-Unit Alternative would advance all of the project objectives, similar to the proposed project.
This alternative would advance the objectives that concern guiding the transition of an infill site with
a Specific Plan; developing a logical internal circulation system for pedestrians, bicyclists,
equestrians, and motorists; clustering residential development in the most suitable areas of the
project site; and promoting land use compatibility with surrounding land uses.
However, this alternative would have $1,000,000 less in community benefits from the Development
Agreement.
5.7 - Environmentally Superior Alternative
The qualitative environmental effects of each alternative in relation to the proposed project are
summarized in Table 5-9.
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Table 5-9: Summary of Alternatives
Environmental Topic Area Alternative 1 Alternative 2 Alternative 3 Alternative 4
Aesthetics, Light, and Glare Greater impact Greater impact Similar impacts Similar impacts
Agriculture Resources and
Forest Resources Similar impacts Similar impacts Similar impacts Similar impacts
Air Quality Fewer impact Fewer impacts Fewer impacts Fewer impacts
Biological Resources Greater impact Greater impact Similar impacts Similar impacts
Cultural Resources Greater impact Fewer impact Similar impacts Similar impacts
Geology/Soils Greater impact Greater impact Similar impacts Similar impacts
Greenhouse Gas Emissions Fewer impact Fewer impact Fewer impacts Fewer impacts
Hydrology and Water
Quality Similar Impacts Fewer impacts Similar impacts Similar impacts
Land Use and Planning Fewer impacts Fewer impacts Similar impacts Similar impacts
Mineral Resources Fewer impacts Fewer impacts Similar impacts Similar impacts
Noise Fewer impacts Greater impact Fewer impacts Similar impacts
Population and Housing Fewer impacts Fewer impacts Fewer impacts Similar impacts
Public Services Fewer impacts Fewer impacts Fewer impacts Similar impacts
Recreation Fewer impacts Fewer impacts Fewer impacts Similar impacts
Tribal Cultural Resources Greater Impacts Similar Impacts Similar Impacts Similar impacts
Transportation and Traffic Fewer impacts Fewer impacts Fewer impacts Similar impacts
Utilities and Service Systems Fewer impacts Greater Impact Fewer impacts Similar impacts
CEQA Guidelines Section 15126(e)(2) requires an EIR to identify an environmentally superior
alternative. If the No Project Alternative is the environmentally superior alternative, the EIR must
also identify an environmentally superior alternative from among the other alternatives.
In this case, the No Project Alternative/Existing Land Use Activities Alternative achieves reductions in
the severity of proposed project’s impacts across the same number of topical areas. Of the four
alternatives, the No Project Alternative/Existing Land Use Activities Alternative achieves the greatest
reduction in daily and peak-hour trip generation because it would develop the fewest dwelling units.
Therefore, the No Project Alternative/Existing Land Use Activities Alternative is the Environmentally
Superior Alternative.
As the No Project Alternative/Existing Land Use Activities Alternative is the Environmentally Superior
Alternative, the DEIR must identify an Environmentally Superior Alternative from among the other
alternatives that is not a No Project Alternative. In this case, the Collaborative Group Alternative is
the environmentally superior alternative as it achieves impact reductions in the severity of Air
Quality, GHG Emissions, Noise, Population and Housing, Public Services, Recreation, Transportation
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and Traffic, and Utilities and Service Systems; all other topical areas would be similar to the
proposed project. The impact reductions to the eight topical areas would be achieved as the
Collaborative Group Alternative would develop 81 fewer dwelling units in comparison to the
proposed project.
While the Collaborative Group Alternative is the Environmentally Superior Alternative, it would not
advance following project objectives: transition of an infill site with a Specific Plan; developing a logical
internal circulation system for pedestrians, bicyclists, equestrians, and motorists; and would not permit
the Development Agreement benefits to the community.
In addition, the Collaborative Group Alternative is not financially feasible.
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SECTION 6: OTHER CEQA CONSIDERATIONS
6.1 - Significant Unavoidable Impacts
California Environmental Quality Act (CEQA) Guidelines Section 15126.2(a)(b) requires an EIR to
identify and focus on the significant environmental effects of the proposed project, including effects
that cannot be avoided if the proposed project were implemented.
Significant and unavoidable impacts identified in this Recirculated Draft Environmental Impact
Report (RDEIR), include the following:
• As discussed in Impact AIR-1, the maximum daily construction emissions after the
implementation of Mitigation Measures AIR-1a through AIR-1g would continue to exceed the
South Coast Air Quality Management District’s (SCAQMD) regional significance thresholds.
Because no additional feasible mitigation measures are available, the project’s regional
operational emissions of NOX would continue to exceed the applicable SCAQMD regional
construction significance threshold even after implementation of all feasible mitigation. This
represents a significant and unavoidable impact.
• As discussed in Impact AIR-2, the project’s construction activities are estimated to generate a
maximum of 199.47 pounds of NOX per day with implementation of mitigation measures AIR-1a
through AIR-1g. As such, the project’s construction would continue to exceed the SCAQMD’s
recommended regional threshold of significance for NOX even after the implementation of
Mitigation Measures AIR-1a through AIR-1g. The project’s construction activities are only
anticipated to exceed any of SCAQMD’s regional thresholds of significance during the combined
site preparation and grading period. A review of the detailed emissions estimates, contained in
Appendix F, shows that 196.17 pounds of the 199.47 pounds of NOX are from off-site sources. As
previously discussed, the project is anticipated to require up to 275,400 total haul trips during
the grading period. Because the exceedance is largely a result of the anticipated haul trips,
feasible and enforceable mitigation measures to reduce the impact are limited. Based on the
total haul trucks required each day and the fact that specific make and model of haul trucks can
vary by contractor and within each contractor fleet, it would not be feasible to mandate the use
of specific vehicles to haul soil for the proposed project. Because no additional feasible
mitigation measures are available beyond those already quantified in Impact AIR-2, the project’s
regional operational emissions of NOX would continue to exceed the applicable SCAQMD
regional construction significance threshold even after implementation of all feasible mitigation.
This represents a significant and unavoidable impact.
• As discussed in Impact AIR-3, the region is non-attainment for the federal and state ozone
standards, the state PM10 standards, and the federal and state PM2.5 standards. Therefore, a
project that would not exceed the SCAQMD thresholds of significance on a project-level would
also not result in a cumulatively considerable contribution to these regional air quality
impacts. The impacts from the project would, therefore, be cumulatively less than significant
during project operations and significant and unavoidable during project construction.
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• As discussed in Impact TRANS-2, while the fair share contribution provided through Mitigation
Measure TRANS-2 would mitigate the proposed project’s impacts at the intersection of
Orange Park Boulevard/East Santiago Canyon Road, impacts would be significant and
unavoidable as the Orange Park Boulevard/East Santiago Canyon Road intersection is not
listed in the City of Orange MPAH, or any similar plans.
All additional impacts analyzed within the Draft EIR were found to be less than significant after
mitigation or less than significant with no mitigation required.
6.2 - Growth-Inducing Impacts
There are two types of growth-inducing impacts that a project may have: direct and indirect. To
assess the potential for growth-inducing impacts, the project’s characteristics that may encourage
and facilitate activities that individually or cumulatively may affect the environment must be
evaluated (CEQA Guidelines Section 15126.2(d)).
Direct growth-inducing impacts occur when the development of a project imposes new burdens on a
community by directly inducing population growth, or by leading to the construction of additional
developments in the same area. Also included in this category are projects that remove physical
obstacles to population growth (such as a new road into an undeveloped area or a wastewater
treatment plant with excess capacity that could allow additional development in the service area).
Construction of these types of infrastructure projects cannot be considered isolated from the
development they facilitate and serve. Projects that physically remove obstacles to growth, or projects
that indirectly induce growth may provide a catalyst for future unrelated development in an area such
as a new residential community that requires additional commercial uses to support residents.
The proposed project would develop 128 dwelling units and, therefore, has the potential to directly
induce population growth. Table 6-1 summarizes the population growth attributable to the
proposed project.
Table 6-1: Population Growth
Dwelling Units
Persons per Dwelling
Unit
Project Population
Growth
City of Orange’s
Population
Project Population Growth as a
Percentage of City Population
128 3.07 393 141,420 0.3 percent
Source: FCS, 2016.
As shown in Table 6-1, the proposed project would increase the City’s population by 393 persons,
which would represent less than a 1 percent increase relative to the City’s 2016 population estimate
of 141,420. This would not be considered a significant population increase.
Furthermore, a portion of the project site is currently designated for residential use by the City of
Orange General Plan and Orange Zoning Ordinance. This indicates that the project site has been
contemplated to support residential development and, by extension, future population growth.
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Although the proposed project would include a General Plan Amendment and Rezone to change the
land use designations, these changes would merely bolster the master planning of the site to allow a
combination of residential, open space, and recreational uses. Thus, the project site would continue
to be designated for residential development.
Lastly, the project site is within an urbanized portion of the City of Orange where infrastructure and
utilities including roadways, potable water, sewer, electricity, and natural gas are currently available.
Thus, the development of the proposed project would not remove a physical barrier to growth that
would allow for unplanned growth to occur.
Impacts would be less than significant.
6.3 - Significant Irreversible Changes
The environmental effects of the proposed projects are summarized in Section ES, Executive
Summary and are analyzed in detail in Section 3, Environmental Impact Analysis of this EIR.
As mandated by the CEQA Guidelines, the EIR must address any significant irreversible
environmental change that would result from implementation of the proposed project. Specifically,
pursuant to the CEQA Guidelines (Section 15126.2(c)), such an impact would occur if:
• The project would involve a large commitment of nonrenewable resources;
• Irreversible damage can result from environmental accidents associated with the project; and
• The proposed consumption of resources is not justified (e.g., the project results in the
wasteful use of energy).
The proposed project consists of the development of new residential, open space, and recreational
uses on a 109-acre site within the Orange City limits. Development activities would involve
vegetation removal, grading, and the construction of the residential uses. Construction and
demolition debris recycling practices would be expected to allow for the recovery and reuse of
building materials such as concrete, lumber, and steel and would limit disposal of these materials,
some of which are non-renewable.
Day-to-day activities would involve the use of non-renewable resources such as petroleum and
natural gas during operations. The new residential uses would be required to adhere to the latest
adopted edition of the California Building Standards Code, which includes a number of standards
that would reduce energy demand, water consumption, wastewater generation, and solid waste
generation that would collectively reduce the demand for resources. This would result in the
emission and generation of less pollution and effluent and lessen the severity of corresponding
environmental effects. Although the proposed projects would result in an irretrievable commitment
of non-renewable resources, the commitment of these resources would not be significantly
inefficient, unnecessary, or wasteful.
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The proposed residential uses do not have the potential to cause significant environmental accidents
through releases into the environment, as they would not that handle large quantities of hazardous
materials.
6.4 - Energy Conservation
Public Resources Code Section 21100(b)(3) and CEQA Guidelines Section 15126.4 require EIRs to
describe, where relevant, the wasteful, inefficient, and unnecessary consumption of energy caused
by a project. In 1975, largely in response to the oil crisis of the 1970s, the State Legislature adopted
Assembly Bill (AB) 1575, which created the California Energy Commission (CEC). The statutory
mission of the CEC is to forecast future energy needs, license thermal power plants of 50 megawatts
or larger, develop energy technologies and renewable energy resources, plan for and direct State
responses to energy emergencies, and—perhaps most importantly—promote energy efficiency
through the adoption and enforcement of appliance and building energy efficiency standards. AB
1575 also amended Public Resources Code Section 21100(b)(3) to require EIRs to consider the
wasteful, inefficient, and unnecessary consumption of energy caused by a project. Thereafter, the
State Resources Agency created Appendix F of the CEQA Guidelines. Appendix F is an advisory
document that assists EIR preparers in determining whether a project will result in the inefficient,
wasteful, and unnecessary consumption of energy. For the reasons set forth below, this EIR
concludes that the proposed project will not result in the wasteful, inefficient, and unnecessary
consumption of energy, will not cause the need for additional natural gas or electrical energy-
producing facilities, and, therefore, will not create a significant impact on energy resources.
6.4.1 - Regulatory Setting
Federal and state agencies regulate energy use and consumption through various means and
programs. At the federal level, the United States Department of Transportation, the United States
Department of Energy, and the United States Environmental Protection Agency are three federal
agencies with substantial influence over energy policies and programs. Generally, federal agencies
influence and regulate transportation energy consumption through establishment and enforcement
of fuel economy standards for automobiles and light trucks, through funding of energy-related
research and development projects, and through funding for transportation infrastructure
improvements. At the State level, the California Public Utilities Commission (CPUC) and the CEC are
two agencies with authority over different aspects of energy. The CPUC regulates privately owned
utilities in the energy, rail, telecommunications, and water fields. The CEC collects and analyzes
energy-related data, prepares statewide energy policy recommendations and plans, promotes and
funds energy efficiency programs, and adopts and enforces appliance and building energy efficiency
standards. California is exempt under federal law from setting State fuel economy standards for new
on-road motor vehicles. Some of the more relevant federal and State energy-related laws and plans
are discussed below.
Title 24, Energy Efficiency Standards
Title 24, which was promulgated by the CEC in 1978 in response to a legislative mandate to create
uniform building codes to reduce California’s energy consumption, provides energy efficiency standards
for residential and nonresidential buildings. According to the CEC, since the energy efficiency
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standards went into effect in 1978, it is estimated that California residential and nonresidential
consumers have reduced their utility bills by at least $15.8 billion. The latest Title 24 energy
efficiency standards went into effect on January 1, 2017.
Pursuant to the California Building Standards Code and the Title 24 Energy Efficiency Standards, the
City will review the design and construction components of the project’s Title 24 compliance when
specific building plans are submitted.
6.4.2 - Energy Requirements of the Proposed Project
Short-term construction and long-term operational energy consumption are discussed below.
Short-term Construction
The United States Environmental Protection Agency (EPA) regulates nonroad diesel engines that
power both mobile equipment (e.g., bulldozers, scrapers, front end loaders, etc.) and stationary
equipment (e.g., generators, pumps, compressors, etc.). The EPA has no formal fuel economy
standards for nonroad (e.g., construction) diesel engines but does regulate diesel emissions, which
indirectly affects fuel economy. In 1994, EPA adopted the first set of emission standards (“Tier 1”)
for all new nonroad diesel engines greater than 37 kilowatts (kW) or 50 horsepower. The Tier 1
standards were phased in for different engine sizes between 1996 and 2000, reducing nitrogen oxide
(NOX) emissions from these engines by 30 percent. Subsequently, the EPA adopted more stringent
emission standards for NOX, hydrocarbons, and particulate matter from new nonroad diesel engines.
This program included the first set of standards for nonroad diesel engines less than 37 kW. It also
phased in more stringent “Tier 2” emission standards from 2001 to 2006 for all engine sizes and
added yet more stringent “Tier 3” standards for engines between 37 and 560 kW (50 and 750
horsepower) from 2006 to 2008. These standards further reduced nonroad diesel engine emissions
by 60 percent for NOX and 40 percent for particulate matter (PM) from Tier 1 emission levels. In
2004, EPA issued the Clean Air Nonroad Diesel Rule. This rule cut emissions from nonroad diesel
engines by more than 90 percent, and was phased in between 2008 and 2014. These emission
standards are intended to promote advanced clean technologies for nonroad diesel engines that
improve fuel combustion, but they also result in slight decreases in fuel economy.
The proposed project would entail short-term construction activities that would consume energy,
primarily in the form of diesel fuel (e.g., mobile construction equipment) and electricity (e.g., power
tools). Construction activities would be subject to applicable regulations such as anti-idling
measures, limits on duration of activities, and the use of alternative fuels, thereby reducing energy
consumption.
The project site is located within the five-county Los Angeles metropolitan region. Construction
equipment is widely available throughout the region and is subject to the aforementioned EPA
emissions standards. There are no unusual project characteristics that would necessitate the use of
construction equipment that would be less energy-efficient than at comparable construction sites in
the region. Therefore, it is expected that construction fuel consumption associated with the project
would not be any more inefficient, wasteful, or unnecessary than at other construction sites in the
region.
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Long-term Operations
Transportation Energy Demand
Vehicle fuel efficiency is regulated at the federal level. Pursuant to the Federal Energy Policy and
Conservation Act of 1975, the National Highway Traffic Safety Administration (NHTSA) is responsible
for establishing additional vehicle standards and for revising existing standards. As of December
2014, NHTSA indicated that the fuel economy of passenger vehicles averaged 34.2 miles per gallon
and light trucks averaged 26.2 miles per gallon. Fuel economy for heavy trucks averages 6.5 miles
per gallon, although this is not regulated by the NHTSA.
Table 6-2 summarizes annual transportation fuel consumption for all project-related trips at
buildout. On an annual basis at buildout, project-related trips would consume 276,430 gallons of
gasoline or diesel.
Table 6-2: Transportation Fuel Consumption
Vehicle Class Percent of Fleet
Average Fuel
Economy
Vehicle Miles
Traveled
Fuel
Consumption
Passenger Vehicles 55.9 34.2 2,819,333 82,437
Light Trucks/Sport Utility Vehicles 25.4 26.2 1,281,057 48,895
Heavy Trucks/Other 18.7 6.5 943,140 145,098
Total 100.0 — 5,043,530 276,430
Note:
Other includes urban buses, school buses, and motorhomes.
Source: FCS, 2017.
Building Energy Demand
Southern California Edison (SCE) provides electrical service and Southern California Gas Company
(SoCalGas) provides natural gas service to customers in the City of Orange.
Electricity
SCE, a unit of Edison International, provides electricity to approximately 5 million metered customers
within a 50,000 square-mile service area of Southern California. SCE obtains electricity from a
variety of sources, including its own generation plants and purchased power from outside sources.
SCE has an ownership stake in the Palo Verde Nuclear Generating Station (Arizona) and owns the Big
Creek Hydroelectric System (Fresno County). SCE purchases electricity from a variety of outside
sources, including natural gas, wind, geothermal, solar, and biomass generation facilities. SCE is
currently in the process of implementing several major transmission system improvements in its
service area to meet the electrical needs of planned growth.
As discussed in Impact USS-5 in Section 3.17, Utilities and Service Systems, the proposed project is
estimated to demand 944,100 kWh of electricity and 5.25 million cubic feet of natural gas at buildout on
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an annual basis. All new non-residential development would be subject to the latest adopted edition of
the Title 24 energy efficiency standards, which are among the most stringent in the United States.
Natural Gas
SoCalGas, a unit of Sempra Energy, provides natural gas service to 5.9 million metered customers
within an approximately 20,000 square mile service area located throughout Central and Southern
California, excluding San Diego County, Long Beach, and the desert area of San Bernardino County.
(The population of the service area is estimated to be 21.6 million.) SoCalGas has interstate pipeline
capacity contracts with El Paso Natural Gas Company, Transwestern Pipeline Company, Gas
Transmission Northwest, Pacific Gas and Electric Company, and Kern River Gas Transmission
Company to supply natural gas. The utility’s system consists of 2,964 miles of transmission and
storage pipelines, 49,874 miles of distribution pipelines, and 47,413 miles of service pipelines.
SoCalGas operates four underground natural gas storage reservoirs with a combined working
capacity of 137 billion cubic feet.
As discussed in Impact USS-5 in Section 3.17, Utilities and Service Systems, the proposed project is
estimated to demand 944,100 kWh of electricity and 5.25 million cubic feet of natural gas at buildout on
an annual basis. All new non-residential development would be subject to the latest adopted edition of
the Title 24 energy efficiency standards, which are among the most stringent in the United States.
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SECTION 7: EFFECTS FOUND NOT TO BE SIGNIFICANT
7.1 - Introduction
This section is based on the Notice of Preparation (NOP), dated March 3, 2017, and contained in
Appendix C of this Environmental Impact Report (EIR). The NOP was prepared to identify the
potentially significant effects of the proposed projects and was circulated for public review between
March 3, 2017 and April 3, 2017. In the course of this evaluation, certain impacts were found to be
less than significant because the proposed project’s characteristics would not create such impacts.
This section provides a brief description of effects found not to be significant or less than significant,
based on the NOP comments or more detailed analysis conducted as part of the EIR preparation
process. Note that a number of impacts that are found to be less than significant are addressed in
the various EIR topical sections (Sections 3.1 through 3.18) to provide more comprehensive
discussion of why impacts are less than significant, in order to better inform decision makers and the
general public.
7.2 - Effects Found Not To Be Significant
7.2.1 - Aesthetics, Light, and Glare
State Scenic Highways
The nearest officially designated State Scenic Highway to the project site is a 4-mile segment of State
Route 91 (SR-91) in Anaheim, located approximately 5 miles to the north. Because of distance and
the presence of intervening topography and urban development, the project site is not visible from
this segment of SR-91. This condition precludes the possibility of the proposed project adversely
affecting scenic resources within view of a State Scenic Highway. No impacts would occur.
7.2.2 - Geology and Soils
Septic or Alternative Wastewater Disposal Systems
The proposed project would be served by sanitary sewer service provided by Orange County
Sanitation District; no septic or alternative wastewater disposal systems would be used. This
condition precludes the possibility of impacts in this regard. No impacts would occur.
7.2.3 - Hazards and Hazardous Materials
Airports
The project site is 10 miles from the closest airport, Orange County John Wayne Airport. This
distance precludes the possibility of exposing persons residing or working in the project vicinity to
aviation safety hazards. No impacts would occur.
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Private Airstrips
There are no private airstrips in the project vicinity. This condition precludes the possibility of
exposing persons residing or working in the project vicinity to aviation safety hazards. No impacts
would occur.
7.2.4 - Hydrology and Water Quality
Seiches, Tsunamis, or Mudflows
There are no large inland bodies of water near the project site, a condition that precludes the
possibility of seiche inundation. The project site is 16 miles from the Pacific Ocean and therefore is
not susceptible to tsunami inundation. The project site does not contain any steep slopes that may
be susceptible to mudflows. No impacts would occur.
7.2.5 - Land Use and Planning
Division of an Established Community
The project site contains undeveloped land, remnants of past mining surface operations, and
Santiago Creek. There are no dwelling units on the project site. This condition precludes the
possibility of division of an established community.
7.2.6 - Noise
Aviation Noise
The project site is 10 miles from the closest airport, Orange County John Wayne Airport.
Additionally, there are no private airstrips in the project vicinity. This distance precludes the
possibility of exposing persons residing or working in the project vicinity to excessive aviation noise.
No impacts would occur.
7.2.7 - Population and Housing
Displacement of Persons or Housing
There are no dwelling units on the project site. This condition precludes the possibility of
displacement of persons or housing. No impacts would occur.
7.2.8 - Transportation and Traffic
Air Traffic Patterns
The project site is 10 miles from the closest airport, Orange County John Wayne Airport. This
distance precludes the possibility of alterations to air traffic patterns. No impacts would occur.
City of Orange—Trails at Santiago Creek Specific Plan Persons and Organizations Consulted/
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SECTION 8: PERSONS AND ORGANIZATIONS CONSULTED/LIST OF
PREPARERS
8.1 - Persons and Organizations Consulted
8.1.1 - Lead Agency
City of Orange
Community Development Department
Community Development Director .................................................................................. W illiam Crouch
Senior Planner .................................................................................................................... Robert Garcia
Senior Planner ...................................................................................................................... Chad Ortlieb
Fire Department
Captain .............................................................................................................................. Ian MacDonald
Police Department
CPS/TLO ................................................................................................................................... Brad Beyer
8.1.2 - Private Parties and Organizations
City of Orange Sully Miller Liaison Committee
Member ........................................................................................................................... Addison Adams
Member .............................................................................................................................. Tom Davidson
Member ....................................................................................................................................... Nick Lall
Member ....................................................................................................................... Stephanie Lesinski
Member .................................................................................................................................. Dan Martin
Member .............................................................................................................................. Theresa Sears
8.2 - List of Preparers
8.2.1 - Lead Agency
City of Orange
Community Development Department
Community Development Director .................................................................................. W illiam Crouch
Senior Planner .................................................................................................................... Robert Garcia
Senior Planner ...................................................................................................................... Chad Ortlieb
8.2.2 - Lead Consultant
FirstCarbon Solutions
Project Director .............................................................................................................. Jason Brandman
Senior Project Manager ............................................................................................... Charles Holcombe
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Project Manager .................................................................................................................. Grant Gruber
Assistant Project Manager ............................................................................................... Bryan S. Moller
Senior Biologist .......................................................................................................... Kim berly Boydstun
Senior Air Scientist ................................................................................................................... George Lu
Air Scientist ..................................................................................................................................... Ella Li
Senior Noise Analyst ................................................................................................................... Phil Ault
Noise Analyst ...................................................................................................................... Maya Tjahjadi
Archaeologist ................................................................................................................... Michael Macko
Environmental Analyst ...................................................................................................... Pa ul Smallman
Environmental Analyst ...................................................................................................... Connor Tindall
Technical Editor ................................................................................................................... Ed Livingston
Word Processor .............................................................................................................. E ricka Rodriguez
Graphic/GIS .................................................................................................................... John De Martino
Reprographics ..................................................................................................................... Octavio Perez
8.2.3 - Technical Consultants
Fuscoe Engineering
Project Manager ....................................................................................................... Dino Ca pannelli, P.E.
Linscott, Law, and Greenspan
Principal ........................................................................................................................ Keil Maberry, P.E.
Senior Transportation Engineer .................................................................................... Daniel Kloos, P.E.
Transportation Engineer II .............................................................................................. Garrett Milovich
PCR Services
Senior Biologist ................................................................................................................... Maile Tanaka
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SECTION 9: REFERENCES
BCR Consulting. 2011. Addendum to a Phase I Cultural Resources Assessment and Paleontological
Records Review Rio Santiago Specific Plan Project. March 25.
BCR Consulting. 2011. Updated Native American Consultation for the Rio Santiago Specific Plan
Project. May 12.
California Air Resources Board. 2015. Staff Report 2015 update to the South Coast Air Basin 24-hour
PM2.5 plan. February 18. Website: http://www.arb.ca.gov/planning/sip/planarea
/scabsip/PM25supp.pdf. Accessed February 22, 2017.
California Department of Conservation. 1988. Christopher J. Wills, Associate Geologist. California
Division of Mines and Geology Fault Evaluation Report FER-194, Peralta Hills Fault, Orange
County.
California Department of Conservation. 2015. Radon Potential in Orange County, California.
California Department of Conservation. 2016. “Important Farmland Finder.” Website:
http://maps.conservation.ca.gov/ciff/ciff.html.
California Department of Finance. 2016. E-5 Population and Housing Estimates for Cities, Counties,
and the State, 2011–2014. May.
California Department of Health Services. 2016. California Indoor Radon Levels Sorted by Zip Code.
February.
California Department of Resources Recycling and Recovery. 2016. Facility/Site Summary Details:
Olinda Alpha Sanitary Landfill (30-AB-0035). Website: http://www.calrecycle.ca.gov
/SWFacilities/Directory/30-AB-0035/Detail/.
California Department of Resources Recycling and Recovery. 2016. Facility/Site Summary Details:
Frank R. Bowerman Sanitary LF (30-AB-0360). Website: http://www.calrecycle.ca.gov
/SWFacilities/Directory/30-AB-0360/Detail/.
California Department of Resources Recycling and Recovery. 2016. Facility/Site Summary Details: El
Sobrante Landfill (33-AA-0217). Website: http://www.calrecycle.ca.gov/SWFacilities
/Directory/33-AA-0217/Detail/.
California Department of Toxic Substances Control. 2016. EnviroStor Data Management System.
Website: http://www.envirostor.dtsc.ca.gov/public/mapfull.asp?.
California Department of Transportation. 2016. “Officially Designated State Scenic Highways.”
Website: http://www.dot.ca.gov/hq/LandArch/scenic_highways/.
California Geological Survey. 2012. Aggregate Sustainability in California. Website:
http://www.conservation.ca.gov/cgs/information/publications/ms/Documents/MS_52.pdf.
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California State Mining and Geology Board. 1983. Regionally Significant Construction Aggregation
Resource Areas in the Orange County-Temescal Valley and San Gabriel Valley Production-
Consumption Region, Santa Ana River and Lower Santiago Creek Resource Areas.
California State Water Resources Control Board. 2016. GeoTracker Data Management System.
Website: http://geotracker.waterboards.ca.gov/.
City of Orange. 2010. City of Orange General Plan. March.
City of Orange. 2016. City of Orange 2015 Urban Water Management Plan. June.
County of Orange. 2014. County of Orange Emergency Operations Plan. May.
Edison International. 2016. 10-K Annual Report. February 23.
ESA. 2017. Trails at Santiago Creek Specific Plan Biological Resources Assessment. August.
FirstCarbon Solutions. 2017. Air Quality Modeling Output. April.
FirstCarbon Solutions. 2017. Health Risk Assessment. April.
FirstCarbon Solutions. 2017. Noise Modeling Output. March.
Fuscoe Engineering. 2017. Preliminary Hydrology and Hydraulic Report. March 7.
Fuscoe Engineering. 2017. Preliminary Water Quality Management Plan. March 6.
Ginter & Associates, Inc. 2011. Preliminary Geologic and Geotechnical Engineering Investigation
and Grading Plan Review for Tentative Tract 17344, Rio Santiago Development Site, City of
Orange, California. October.
Linscott, Law, & Greenspan Engineers. 2017. Traffic Impact Analysis. September 7.
Michael Brandman Associates. 2008. Phase I Cultural Resources Assessment and Paleontological
Records Review Rio Santiago Specific Plan Project. December 3.
Michael Brandman Associates. 2009. Phase I Environmental Site Assessment, Rio Santiago Specific
Plan Project Site, 6118 East Santiago Canyon Road, Orange, Orange County, California.
August 6.
National Highway Traffic Safety Administration. 2014. Summary of Fuel Economy Performance.
December 15.
Orange County Sanitation District. 2014. Annual Report 2013/14.
Orange County Sanitation District. 2015. Capital Improvement Program Fiscal Year 2014/15 Update.
Orange County Sheriff Department. 2011. Orange County Operational Area Emergency Action Plan,
Dam/Reservoir Failure Annex. October 4.
City of Orange—Trails at Santiago Creek Specific Plan
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Orange County Waste & Recycling. 2016. Annual Monitoring Report October 2015 to September
2016 Villa Park Landfill Orange County, California. November 30. Website:
https://geotracker.waterboards.ca.gov/esi/uploads/geo_report/3657884597/L10009578462.
PDF.
Pacific Gas and Electric Company. 2016. 10-K Annual Report. February 18.
PCR. 2013. Biological Resources Assessment, Rio Santiago, City of Orange, Orange County,
California. January.
PCR. 2013. Investigation of Jurisdictional Waters and Wetlands, Rio Santiago, City of Orange, Orange
County, California. January.
PCR. 2013. Tree Survey Report, Rio Santiago, City of Orange, Orange County, California. January.
Santa Ana Regional Water Quality Control Board. 2010. 2010 Santa Ana Region 303(d) List of Water
Quality Limited Segments. Website: http://www.waterboards.ca.gov/santaana
/water_issues/programs/tmdl/docs/303d/2010_303d.pdf.
Sempra Energy. 2016. 10-K Annual Report. February 26.
South Coast Air Quality Management District. 1993. Air Quality Handbook. Website:
http://www.aqmd.gov/home/regulations/ceqa/air-quality-analysis-handbook/ceqa-air-
quality-handbook-(1993).
South Coast Air Quality Management District. 2017. Final 2016 Air Quality Management Plan.
March . Website: http://www.aqmd.gov/home/library/clean-air-plans/air-quality-mgt-
plan/final-2016-aqmp.
Southern California Earthquake Data Center. 2016. Website: http://scedc.caltech.edu/.
State Water Resources Control Board. 2012. “Impaired Water Bodies.” Website:
http://www.waterboards.ca.gov/water_issues/programs/tmdl/integrated2012.shtml.
Accessed February 11, 2016.
State Water Resources Control Board. 2016. GeoTracker. Website:
https://geotracker.waterboards.ca.gov/.
Tait Environmental Services. 2011. Report of Phase II Environmental Site Assessment Activities
Conducted at Rio Santiago Project Site, 6145 East Santiago Canyon Road, Orange, California.
May 16.
United States Environmental Protection Agency. 1998. Characterization of Building Related
Construction and Demolition Debris in the United States. June.
United States Geological Survey. 1981. Orange, California 7.5-Minute Topographic Quadrangle.
Western Regional Climate Center. 2016. Website: http://www.wrcc.dri.edu/. Accessed December
15, 2016.
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NORTH AMERICA | EUROPE | AFRICA | AUSTRALIA | ASIA
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FINAL
Environmental Impact Report
Trails at Santiago Creek Specific Plan
City of Orange, Orange County, California
State Clearinghouse No: 2017031020
Prepared for:
City of Orange
Community Development Department, Planning Division
300 East Chapman Avenue, Orange, CA 92866
714.744.7231
Contact: Robert Garcia, Senior Planner
Prepared by:
FirstCarbon Solutions
250 Commerce, Suite 250
Irvine, CA 92602
714.508.4100
Contact: Jason Brandman, Project Director
Cecilia So, Project Manager
Date: September 16, 2019
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Final EIR Table of Contents
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Table of Contents
Section 1: Introduction ............................................................................................................... 1-1
Section 2: Master Responses ....................................................................................................... 2-1
2.1 - List of Master Responses ................................................................................................ 2-1
2.2 - Master Responses .......................................................................................................... 2-1
Section 3: Responses to Written Comments ................................................................................ 3-1
3.1 - List of Authors ................................................................................................................ 3-1
3.2 - Responses to Comments ................................................................................................ 3-6
Section 4: Errata.......................................................................................................................... 4-1
4.1 - Changes in Response to Specific Comments .................................................................. 4-1
Appendix F: Air Quality and Greenhouse Gas Supporting Information
Appendix R: Ordinance No 3915
Appendix S: April 1, 2019 Open Space Greenway Memo
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SECTION 1: INTRODUCTION
In accordance with the California Environmental Quality Act (CEQA) Guidelines Section 15088, the
City of Orange has evaluated the comments received on the Trails at Santiago Creek Specific Plan
Recirculated Draft Environmental Impact Report (RDEIR). The responses to the comments and errata,
which are included in this document, together with the Mitigation Monitoring and Reporting
Program, form the Final EIR for use by the City of Orange in its review.
This document is organized into four sections:
• Section 1—Introduction.
• Section 2—Master Responses. Provides a single, comprehensive response to similar
comments about a particular topic.
• Section 3—Responses to Written Comments. Provides a list of the agencies, organizations,
and individuals who commented on the RDEIR. Copies of all of the letters received regarding
the RDEIR and responses thereto are included in this section.
• Section 4—Errata. Includes an addendum listing refinements and clarifications on the RDEIR,
which have been incorporated.
The Final EIR includes the following contents:
• RDEIR (provided under separate cover)
• RDEIR Appendices (provided under separate cover)
• Responses to Written Comments on the RDEIR, Volumes 1 and 2 (Section 3 of this document)
• Errata (Section 4 of this document)
• Mitigation Monitoring and Reporting Program (provided under separate cover)
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SECTION 2: MASTER RESPONSES
Master responses address similar comments made by multiple commenters (public agencies,
businesses, organizations, or individuals) through written comments submitted to the City of
Orange. In some instances, an individual response may both refer to a master response and contain
further information that is responsive to the particular comment. Master responses are provided in
the order set forth below.
2.1 - List of Master Responses
• Master Response 1—Plan Consistency
• Master Response 2—Adequacy of Project Description
• Master Response 3—Analysis of Alternatives
• Master Response 4—Dam Safety and Risk of Failure
• Master Response 5—Wildfire Risk
• Master Response 6—Stewardship of Open Space
• Master Response 7—Applicability of SMARA
• Master Response 8—Site Environmental Conditions
• Master Response 9—Soil Import/Export Numbers
• Master Response 10—General Comments on Project, General Opposition
2.2 - Master Responses
Master Response 1—Plan Consistency
Summary of Relevant Comments
Several commenters raised issues related to the consistency of the project with the City of Orange
General Plan and the Orange Park Acres Plan. Specific issues raised include the following:
• Ability of the City to reconsider land use designations and densities in the existing plans
• Open space and resource area designations
• Proposed density of the project relative to what is identified in the General Plan and the
Orange Park Acres Plan
Response
a. The City General Plan and the Orange Park Acres Plan
The approximately 109.2 acre project site includes both disturbed and undisturbed land, with
approximately 40 acres containing remnants of a prior mining operation and a currently operating
sand and gravel processing facility. There are other improvements on the rest of the site, including a
flood control storm drain, a trunk water distribution line, and historic groundwater and methane
monitoring wells. (Recirculated Draft Environmental Impact Report [RDEIR] Section 2, Project
Description, page 2-1). The analysis of environmental and planning issues in the RDEIR takes account
of these existing conditions in evaluating the impacts of the project.
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The City of Orange General Plan designates the project site as Low Density Residential (LDR) (15.4
acres), Resource Area (RA) (77.3 acres), and Open Space (OS) (16.5 acres). The proposed project
would change the RA designation to a combination of “Low Density Residential” and “Open Space,”
and the LDR designation to “Open Space.” The part of the project site that is currently designated
“Open Space” in the General Plan will remain designated as “Open Space.” The proposed project
also includes a General Plan Amendment that would amend both the East Orange General Plan and
Orange Park Acres plan to incorporate the Trails at Santiago Creek Specific Plan. The Trails at
Santiago Creek Specific Plan would create vertical consistency with the General Plan.
The project site is located within the boundaries of the East Orange General Plan and the Orange
Park Acres (OPA) Plan. It is important to note the legal status of these documents. The East Orange
General Plan is part of the land use element of the City ’s General Plan.
The OPA Plan is often referred to as “specific plan” but it is not a specific plan adopted pursuant to
the specific plan statute. The Plan was adopted by City Resolution No. 3915 (included in Section 4,
Errata, as Appendix R) in December 1973, prior to the 1974 enactment of the specific plan statute.
That resolution adopted the Plan as a land use element of the General Plan. In addition, the OPA
Plan does not meet the requirements for specific plans in Government Code Section 65450 et seq.
The Plan identifies goals, policies and recommended land use concepts for Orange Park Acres, but
does not contain a program of implementation measures, infrastructure plans or development
criteria, as required by the statute. The Plan is described in the current General Plan 2010 as a
“development plan” that is one of the plans that has influenced growth and change within the City
of Orange (General Plan 2010, page I-23).
Therefore, the OPA Plan is a relevant land use document, and the consistency of the project with this
Plan is evaluated in the RDEIR, but the OPA Plan does not control land use policy in the City in the same
manner as the policies in the City’s General Plan 2010. Notably, the Supreme Court in Orange Citizens
for Parks & Recreation v. Superior Court (2016) 2 Cal.5th 141, 157-158, held that the designations and
policies in the General Plan 2010 control over any inconsistent provisions of the OPA Plan.
b. Standards for Determining Consistency with a General Plan
A general plan is the “constitution” for development in a jurisdiction and lies at the top of a city’s
land use regulation hierarchy (Neighborhood Action Group for the Fifth Dist. v. County of Calaveras
(1984) 156 Cal.App.3d 1176, 1183; Lesher Communications, Inc. v. City of Walnut Creek (1990) 52
Cal.3d 531, 540). All zoning and land use approvals must be consistent with the general plan (DeVita
v. County of Napa (1995) 9 Cal.4th 763, 772).
The legal test for determining whether a land use enactment is consistent with a general plan has
been set forth in numerous court decisions. Generally, it is recognized that a general plan or a
community plan consists of policies reflecting a wide range of sometimes competing interests.
Accordingly, a project can be found to be consistent with a general plan and its various competing
policies if the project furthers some policies and objectives of the general plan and does not inhibit
or obstruct the attainment of other policies (67 Ops Cal Atty Gen 75 (1984); Office of Planning and
Research [OPR], State of California General Plan Guidelines (2017)). Under this standard, a project
need not be perfectly consistent with each and every policy (See, e.g., Friends of Lagoon Valley v.
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City of Vacaville (2007) 154 Cal.App.4th 807, 815 [upholding overall consistency finding even though
the project deviated from some plan provisions because plan allowed for balancing of competing
policies]). Instead, the standard for a finding of consistency is that the project is in “harmony” with
the general plan’s goals and objectives (Sequoyah Hills Homeowners Ass’n v. City of Oakland (1993)
23 Cal.App.4th 704, 719). Here, the RDEIR has properly and thoroughly identified and discussed
relevant plan policies and goals for the City’s consistency determination. The RDEIR analyzed all of
the applicable objectives, goals and policies, and provided sufficient detail and analyses to support
the consistency findings for the proposed project.
Under these standards, when a comment expresses an opinion or a question arises regarding
consistency with a specific goal or policy in a City’s general plan or specific plan, it is recognized that
the lead agency has discretion to weigh whether the project would be consistent with the use, scale,
and character of existing development and the surrounding natural environment. Courts generally
defer to an agency’s decision on consistency with its own plan unless, on the basis of evidence
before the decision-making body, a reasonable person could not have found the project to be
consistent (The Highway 68 Coalition v. County of Monterey (2017) 14 Cal.App.5th 883, 896).
Agencies have particularly broad discretion in determining whether a project is consistent with goals,
policies, objectives, and measures of the agency’s own general plan (Napa Citizens for Honest Gov’t
v. Napa County Bd. of Supervisors (2001) 91 Cal.App.4th 342, 378).
c. General Plan Consistency Issues
i. Consistency with General Goals and Policies
One commentator expressed the view that the project is not consistent with General Plan Goal 1.0
and Policies 1.2, 1.4, 1.6 and 6.1 setting forth general provisions governing new development, and
further stated that there is no evidentiary support for the Environmental Impact Report (EIR)
conclusion that the project is consistent with this goal and these policies. As set forth below, a
number of facts demonstrate the consistency of the project with this goal and these policies. The
ultimate determination of General Plan consistency will be made by the City Council, but these facts
demonstrate that there is a sound factual basis for a finding that the project is consistent with the
identified policies.
• Goal 1.0: Meet the present and future needs of all residential and business sectors with a
diverse and balanced mix of land uses.
- Facts supporting consistency: The project would redevelop a site previously used for surface
mining activities to support up to 128 dwelling units and open space and recreation uses.
The project would meet the present and future needs of residents by providing additional
homes in the City and would provide a balanced mix of land uses by incorporating open
space and recreational uses, including equestrian opportunities and trails.
• Policy 1.2: Balance economic gains from new development while preserving the character and
densities of residential neighborhoods.
- Facts supporting consistency: The project would be compatible with surrounding residential
development by clustering the new dwelling units on 40.7 acres of the site adjacent to East
Santiago Canyon Road and preserving the remaining acreage for open space and recreation
use. The proposed density and type of housing product is similar to the residential uses to
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the north, east, and south. Contrary to one commenter’s assertion, the project’s density
would not far exceed surrounding densities. In fact, the density of the project would be on
the low end of the General Plan’s “low-density” land use density range. The project is
consistent with the policy of balancing economic benefits with the preservation of
neighborhood character.
• Policy 1.4: Ensure that new development reflects existing design standards, qualities, and
features that are in context with nearby development.
- Facts supporting consistency: The project would promote land use compatibility with
surrounding residential development by clustering the new dwelling units on 40.7 acres of
the site adjacent to East Santiago Canyon Road and preserving the remaining acreage for
open space and recreation use. The proposed density and type of housing product is similar
to the residential uses to the north, east, and south. The density of the project would be on
the low end of the General Plan’s “low-density” land use density range. The project would
meet the City’s design standards and would be high-quality design. Therefore, it would be
compatible with Policy 1.4.
• Policy 1.6: Minimize effects of new development on the privacy and character of surrounding
neighborhoods.
- Facts supporting consistency: The project would promote land use compatibility with
surrounding residential development by clustering the new dwelling units on 40.7 acres of
the site adjacent to East Santiago Canyon Road and preserving the remaining acreage for
open space and recreation use. The proposed density and type of housing product is similar
to the residential uses to the north, east, and south. The homes on the project site would be
separated from existing residential communities by open space grasslands, an open space
greenway, and trails, which would minimize the massing of the project from other
communities and protect the privacy of existing residents.
• Policy 6.1: Ensure that new development is compatible with the style and design of
established structures and the surrounding environment.
- Facts supporting consistency: The project promotes compatibility with surrounding
residential development by clustering the new dwelling units on 40.7 acres of the site
adjacent to East Santiago Canyon Road and preserving the remaining acreage for open space
and recreation use. Additionally, the density and types of housing products are similar to
residential uses north, east, and south of the project site. The project would contain high-
quality design elements that would be compatible with the style and design of existing
residential neighborhoods near the project site.
ii. Comparison of Project Density with Surrounding Densities
One comment expressed the view that the project is not consistent with the density in the
surrounding area, and thus would permanently change the character of the area. The comment cited
the density of one nearby development, Orange Park Acres. As shown in the EIR, however, the
project is consistent with, and is less dense than, much of the area surrounding the project site.
The project proposes development of 128 dwelling units on approximately 40.7 acres of the
approximately 109.2 acre site, with varying lot sizes, including 82 lots of approximately 8,000 square
feet, 17 lots of approximately 9,200 square feet, and 29 lots of approximately 10,000 square feet.
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Thus, the overall density of development on the site would be less than 1.2 dwelling units per acre.
Considering only the residential portion of the project site, the density would be 3.1 dwelling units
per acre. When considering the acreage of the residential area only, the density of the project (3.1
dwelling units per acre) would be on the low end of the General Plan’s allowable density for the
“low-density residential” designation, which is 2.1 to 6.0 units per acre. Although the General Plan
provides a density range of 2.1-6.0 dwelling units per acre, it notes that the “expected” density for
the low-density residential designation is 5.0 dwelling units per acre, which is substantially higher
density than the proposed project’s density.
The project proposes a zoning designation of single-family residential 8,000 square feet (referring to
minimum lot area). The single-family neighborhood to the north of the site is similarly zoned low-
density residential 8,000 square feet. The single-family neighborhood that forms the eastern boundary
of the site (“The Reserve”) is zoned estate low-density residential 40,000 square feet and has typical lot
sizes of 20,000–44,000 square feet. Surrounding residential uses to the east have typical lot sizes less
than 10,000 square feet. The neighborhoods south of the project site are zoned estate low density
residential 40,000 square feet and estate low density residential 20,000 square feet. South of the
project site, the Jamestown neighborhood has a typical lot size of 8,000–11,000 square feet, the
Orange Park Acres neighborhood has a typical lot size of 50,000 square feet to 1 acre plus, the Eichler
Homes neighborhood has a typical lot size of 7,600–12,000 square feet, and The Colony-South
neighborhood has a typical lot size of 7,000–10,000 square feet. Refer to RDEIR Section 2, Project
Description, Figures 2-5a through 2-5g for the existing lot sizes in surrounding neighborhoods.
The estate low-density residential designations have a density range of 0 to 2.0 dwelling units per acre.
While the estate low-density residential neighborhoods have slightly lower densities than the project
site, the project’s density of 3.1 dwelling units per acre would be substantially similar to the density
range of the estate low-density neighborhoods near the project site. In addition, the project would
contain a substantial amount of open space, which would counterbalance the density of the residential
component of the project. As noted above, while the density of the residential clustered component
would be 3.1 dwelling units per acre, the overall density of the project would be less than 1.2 dwelling
units per acre when considering the entire site (128 dwelling units on a 109.2-acre site).
iii. Consistency with Resource Area Designation
The project site is currently designated “Resource Area,” “Low Density Residential,” and “Open Space”
by the City of Orange General Plan. In accordance with the proposed project, the portion of the site
north of Santiago Creek, currently designated as “Low Density Residential,” is proposed to be re-
designated as “Open Space” and the portion of the site currently designated as “Resource Area” is
proposed to be re-designated to “Low Density Residential,” and “Open Space.” The “Resource Area”
land use designation reflects the surface mining activities that occurred on the south side of Santiago
Creek. General Plan Land Use Element, page LU-23, notes that the “Resource Area designation
provides for the continued use of areas for mining and agriculture.” The description for the Resource
Area designation (General Plan Land Use Element, page LU-16) states that the designation “[a]llows for
agricultural uses and continued use of stream and river channels for aggregate mining. Passive and
active recreational uses are also permitted. May serve as a holding zone for future uses compatible
with established and planned land uses in surrounding areas.”
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Given that the RA designation is characterized as a “holding zone” for current mining and agriculture
uses, one commenter’s assertion that residents have long relied on the RA designation for rural
open space is a mischaracterization of the General Plan’s policies and vision for the RA areas. The
statement in the General Plan that the commenter references (that the RA designation may serve as
a holding zone for uses compatible with established and planned land uses in surrounding areas)
supports the exact project that is proposed. The project would involve low-density residential, open
space, and recreational uses, which would be compatible with existing low-density residential
neighborhoods. Moreover, as noted above, while the project would redesignate an RA area to low
density residential, it would also redesignate low-density residential uses to open space uses,
thereby alleviating the commenter’s concern that the project would not contain rural open space.
iv. Consistency with Public Safety Policies
One commenter states an opinion that the project would be inconsistent with Public Safety Policy
4.3, which calls for the City to ensure that hazardous materials dumpsites are cleaned prior to the
establishment of new land uses. Contrary to the commenter’s assertion, Mitigation Measures HAZ-
2a through HAZ-2c would ensure that hazardous conditions would be remediated prior to
establishment of residential land uses. Please see Master Response 8—Site Environmental
Conditions for further detail.
Specifically, Mitigation Measure HAZ-2a requires proposed enclosed structures to be situated
strategically to allow for future remediation of any potential landfill gas migration. Prior to issuance
of building permits where vapor intrusion has the potential to occur, the applicant will be required to
submit plans to the City identifying vapor intrusion abatement measures for trichloroethylene (TCE)
and methane. Mitigation Measure HAZ-2a includes sample abatement measures and requires
abatement measures to be incorporated into building plans. Mitigation measure HAZ-2a also
requires a supplemental Phase II Environmental Site Assessment (ESA) to be conducted, in
accordance with applicable guidance documents, to determine the vertical and lateral extent of
previously identified contamination. It also requires a soil risk management plan to be prepared and
submitted to the California Department of Toxic Substances Control (DTSC) to address any discovery
of previously unknown contamination. All occupied structures within a 1,000 foot radius of the
landfill will be required to include the following structural controls to limit the potential for landfill
gas accumulation (unless such controls are determined not to be necessary by the City in
consultation with the Local Enforcement Agency): (1) a geomembrane between the slab and the
subgrade; (2) a permeable layer with venting pipe between the geomembrane; and (3) automatic
methane gas sensors with audible alarms in the permeable layer and inside the structures.
Mitigation Measure HAZ-2b requires the project applicant to conduct additional groundwater
sampling under the guidance of DTSC, focused on the area within 1,000 feet of the Villa Park landfill,
to assess whether total petroleum hydrocarbons (TPH), methane, and/or volatile organic compounds
(VOCs) have impacted groundwater. If groundwater is affected, the applicant must conduct a multi-
media risk assessment under the guidance of DTSC, which would be required to be conducted in
accordance with applicable guidance documents. The applicant would be required to retain a
qualified hazardous materials contractor to remove all soil containing TPH to the standards of DTSC
or other applicable regulatory agency prior to issuance of grading permits. Following cleanup of the
soil, the applicant will be required to submit documentation to the City confirming that the
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mitigation measure was successful. Mitigation Measure HAZ-2c requires that the project applicant
contact the City Engineer to consult with and obtain approval from the Orange County Integrated
Waste Management Department for the relocation of any monitoring wells or probes that would be
impacted by development on the site prior to commencement of any construction that would
impact existing landfill or related gas monitoring equipment.
With implementation of the measures above, which provide ample evidentiary support for the
conclusions in the REIR, the project would comply with Public Safety Policy 4.3 and would ensure
that hazardous materials are cleaned prior to establishment of new residential uses.
v. Consistency with Roadway Network Policies
One commenter alleges that the project would be inconsistent with General Plan provisions relating
to operations of the City’s roadway network by identifying a significant and unavoidable impact at
the intersection of Orange Park Boulevard and East Santiago Canyon Road (exceeds the level of
service [LOS] standards in the PM peak-hour in 2022). The commenter argues that because the
impact at the intersection of Orange Park Boulevard and East Santiago Canyon Road is significant and
unavoidable, the project is inconsistent with the following General Plan goals and policies:
• Growth Management Goal 1.0: Reduce traffic congestion within the City.
- The proposed project’s impacts on traffic are evaluated in Section 3.16, Transportation and
Traffic. As discussed in Section 3.16, local intersections were evaluated against the City’s
adopted performance standards and mitigation measures were proposed to improve
deficient operations to acceptable levels. As such, the project is consistent with the goal of
reducing traffic congestion.
• Growth Management Policy 1.2: Ensure completion of transportation improvements as
agreed upon by the City and developer prior to completion of a development project.
- All vehicular access points (including the improved intersection of East Santiago Canyon
Road/North Nicky Way) would be required to be completed in accordance with City
standards prior to issuance of the first certificate of occupancy. The project would comply
with Policy 1.2.
• Growth Management Policy 1.5: Require new development projects to link issuance of
building permits for the appropriate portion of the development plan to roadway
improvements required to achieve the appropriate LOS.
- The proposed project’s impacts on traffic are evaluated in RDEIR Section 3.16,
Transportation and Traffic. Local intersections were evaluated against the City’s adopted
performance standards and mitigation measures were proposed to improve deficient
operations to acceptable levels. As such, the project is consistent with the policy of linking a
building permit for a project to achieving appropriate LOS at intersections that would
potentially be affected by the project.
Mitigation Measure TRANS-2, which would require fair share contributions from the project for two
key intersection improvements, would mitigate the project’s impact at Orange Park Boulevard/East
Santiago Canyon Road. However, despite the fair share contributions, impacts would be significant
and unavoidable because the intersection is not listed in the City of Orange Master Plan of Arterial
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Highways (MPAH) or any similar plan. Therefore, contrary to the commenter’s assertion, the
significant and unavoidable impact at Orange Park Boulevard/East Santiago Canyon Road does not
make the project inconsistent with the General Plan provisions relating to the operations of the
City’s roadway network. The mitigation measures required for the project mitigate all impacts of the
project to the roadway. The impact remains significant and unavoidable simply because the
intersection is not listed in the City of Orange MPAH or a similar plan.
The project would be consistent with the General Plan provisions relating to operations of the City’s
roadway network, as discussed in RDEIR Section 3.10, Land Use, on page 3.10-15. Local intersections
were evaluated against the City’s adopted performance standards and mitigation measures were
recommended to maintain operations at acceptable levels.
d. Consistency with Orange Park Acres Plan and East Orange Plans
As the RDEIR correctly concluded, the project is consistent with the OPA Plan and East Orange Plan.
This consistency is discussed in RDEIR Section 3.10, Land Use, Table 3.10-3, showing the project
would be consistent with the East Orange General Plan, and RDEIR Table 3.10-4, showing the project
would be consistent with the OPA Plan.
i. Consistency with the East Orange Plan
The East Orange General Plan encompasses approximately 1,900 acres. Approximately 37 acres of the
project site are located within the boundaries of the East Orange General Plan. While the East Orange
General Plan does not outline goals and policies similar to contemporary general plans, the project is
consistent with concepts identified in the East Orange General Plan. For example, the East Orange
General Plan contains a concept that where possible, new development should be compatible with
existing residential densities and should maintain continuity with architectural style, house size, and
price range. The project’s residential area would have a density that is similar to or less dense than
most nearby residential areas, including the Jamestown neighborhood, which is within the East Orange
General Plan area. The East Orange General Plan envisions an “assortment of open space categories.”
Approximately 37 acres of the project site are located within the boundaries of the East Orange
General Plan and are designated “Regional Park.” While the project would amend the 37 acres that are
within the East Orange General Plan, the 37 acres are approximately 2 percent of the East Orange
General Plan area. Additionally, the proposed project includes 68.5 acres of open park space, split into
40.2 acres of Greenway Open Space/Santiago Creek Riparian Corridor and 28.3 acres of Grasslands
Open Space. Therefore, the proposed project would include 68.5 acres of open space/park uses
adjacent to, and partially within, the East Orange General Plan; creating more open space in the vicinity
than the 37 acres of the project site that are within the East Orange General Plan.
The East Orange General Plan references design of the Santiago Creek Greenbelt in the project site
area. The project would be consistent with the reference to the Greenbelt because it includes a 40.2-
acre Greenway Open Space/Santiago Creek Riparian Corridor. The East Orange General Plan
emphasizes pedestrian and equestrian movements between neighborhoods. The project would
include a multitude of trails to connect the proposed project and existing community to existing and
future trails and bike lanes. The project would also provide a sidewalk for pedestrians along the
frontage of East Santiago Canyon Road where one does not currently exist. Lastly, the East Orange
General Plan envisions a trail system to include equestrian/hiking trails and bike trails. As mentioned
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above, the project would include a multitude of trails to connect the project and existing community
to existing and future trails and bicycle lanes for recreation and commuting purposes.
ii. Consistency with the Orange Park Acres Plan
The OPA Plan encompasses approximately 1,794 acres, of which 39 acres are located on the project
site. The project is consistent with the OPA Plan objectives and policies. For example, the OPA Plan
contains an objective to provide a wholesome rural atmosphere emphasizing a quiet seclusion close
to nature. The project would retain a wholesome rural atmosphere by separating the residential
component of the project from adjacent residential developments by open space, emphasizing a
quiet seclusion and closeness to nature and open space. The rural character of the site would also be
maintained by inclusion of an equestrian trail system.
An objective of the OPA Plan is to foster compatible residential development within the area both
visually and functionally. The project would comply because its residential area has a similar density
to nearby residential neighborhoods, including the following neighborhoods located in the OPA Plan
area: Broadmoor Homes, Leadership Housing Specific Plan, Pacesetter Homes, and a small portion of
the Jamestown neighborhood. The OPA Plan envisions various areas to be linked through a system of
trails and streetscape landscaping. Additionally, the project includes a sidewalk for pedestrians along
the frontage on East Santiago Canyon Road where a sidewalk does not currently exist.
The OPA Plan promotes a “lifestyle” that allows for diversity of activities. The project would include
residential uses, a multitude of trails, bicycle lanes, sidewalks, and equestrian trails. The project
would serve a diversity of activities, from walking to horseback riding. The OPA Plan seeks to
preserve positive features of major drainage courses and bodies of water to utilize them for
recreational purposes. The project proposes a 40.2 acre Greenway Open Space/Santiago Creek
Riparian Corridor, and preserves the Handy Creek drainage area as greenspace. Approximately 39
acres of the project site are located within the boundaries of the OPA Plan and are designated as
“Open Space.” While the project would amend the approximately 39 acres that are within the OPA
Plan, the 39 acres are approximately 3 percent of the OPA Plan total area, and are on the fringe of
the OPA Plan area. Additionally, the project would include 68.5 acres of open park space, split into
40.2 acres of Greenway Open Space/Santiago Creek Riparian Corridor and 28.3 acres of Grasslands
Open Space. Therefore, the project would include 68.5 acres of open space/park uses adjacent to,
and partially within, the OPA Plan, thus creating more open space in the vicinity than the 39 acres of
the project site that are within the OPA Plan area.
A policy of the OPA Plan is to provide for continuous trail linkages to connect trails to major land use
elements and natural features. Another OPA Plan policy is to preserve Santiago Creek as a balanced
ecological system and allow for light recreational use. The project would include a multitude of trails
that would connect the proposed residential uses with existing and future trails and bicycle lanes.
The project would promote light recreational use. In addition, the project would involve a 40.2-acre
greenway along Santiago Creek and preservation of the Handy Creek drainage areas as greenspace.
One of the OPA Plan policies is to phase out gravel pit operations to restore natural amenities. The
project proposes residential and open space/recreational uses in place of the former mining
operations.
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A prominent policy of the OPA Plan in its residential designations is the concept of “clustering.” The
OPA Plan envisions “single-family attached and detached clusters referred to as “rural clusters”
within a greenbelt or open space context” for medium-low density residential areas. The proposed
project area encompasses approximately 109.2 acres, 68.5 acres of which would be dedicated to
open space, and approximately 40.7 acres of which would contain a residential “cluster” of homes.
The proposed site design would align with the OPA Plan concept of “clustering” and retaining open
space areas near residential “clusters.” Although the residential units are “clustered” on
approximately 40 acres, each lot is being subdivided to meet the City’s R-1-8 standards.
Lastly, one OPA Plan policy is to provide for landscaping, greenbelt, or open space buffers between
housing types. The project would encompass approximately 109.2 acres, 68.5 acres of which would be
dedicated open space. The project’s residential area would be clustered as envisioned by the OPA Plan,
and the density of the residential component would be similar to the density of nearby residential
neighborhoods, including Jamestown, Mabury Ranch, Broadmoor Homes, Leadership Housing Specific
Plan, and Pacesetter Homes. The separation of the project’s residential area from existing residential
development adjacent to the project site, achieved the by the proposed open space, would provide a
quiet seclusion and closeness to nature, as envisioned by the OPA Plan. The rural aspect envisioned by
the OPA Plan would be maintained, in part, by inclusion of an equestrian trail system. A list of the OPA
Plan’s goals, objectives, and policies, which the project is consistent with, is included in RDEIR Section
3.10, Land Use, as Table 3.10-4 (page 3.10-26 through page 3.10-28).
In fact, the Orange Park Acres Association previously supported a more intensive development on
the project site in a letter dated May 28, 2003 and found it to be compatible with the OPA Plan.
Orange Park Acres Association specifically found the more intensely developed project to be
consistent with the clustering concept envisioned by the OPA Plan. Orange Park Acres Association
has consistently supported a clustered residential concept. This earlier project included the
development of a gated residential community with a maximum of 189 single-family homes on lots
ranging from 8,000 to 22,000 square feet. The residential development was spread across most of
the project site, including both the north and south sides of Santiago Creek encompassing
approximately 83 acres. The remaining portion of the site consisted of approximately 26 acres of
open space (approximately 31 percent of the site), which did not include a greenway aspect, unlike
the proposed Trails of Santiago project. The current project includes less development and sets aside
a larger area for open space.
e. Response to General Comments on Plans
A number of commenters expressed the view that certain promises were set forth in the City’s plans,
particularly the East Orange Plan and the OPA Plan, and that City should keep those promises. As
stated in the above responses, the proposed project is consistent with the provisions and policies set
forth in the governing plans. The City Council will make the ultimate determination of plan
consistency, but there is a sound basis for the City to determine that the project is consistent with all
applicable plans should the City Council exercise its discretion to do so.
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Master Response 2—Adequacy of the Project Description, Level of Detail
Summary of Relevant Comments
Several commenters raised the issue of the amount of detail provided in RDEIR Section 2, Project
Description, including claims that more information and detail is needed in order to allow for
sufficient evaluation of the potential environmental effects of the project.
Response
While project descriptions must not omit integral components of the project, project descriptions
should not provide extensive detail beyond that needed for evaluating environmental impacts
(Santiago County Water Dist. v. County of Orange (1981) 118 Cal.App.3d 818, 829; California
Environmental Quality Act [CEQA] Guidelines § 15124). For example, a project description for a sand
and gravel mine cannot omit information regarding the water pipelines proposed to serve the
project. As the court stated in San Joaquin Raptor/Wildlife Rescue Ctr. v. County of Stanislaus (1994)
27 Cal.App.4th 713, 730, “an accurate project description is necessary for an intelligent evaluation of
the potential environmental effects of a proposed activity.” Courts have also stated that an accurate
and stable project description is necessary so that the lead agency and the public have enough
information to “ascertain the project’s environmentally significant effects, assess ways of mitigating
them, and consider project alternatives” (Sierra Club v. City of Orange (2008) 163 Cal.App.4th 523,
533; Save Round Valley Alliance v. County of Inyo (2007) 157 Cal.App.4th 1437, 1448).
The RDEIR contains each of the required elements of an EIR project description; as such
requirements are set forth in CEQA Guidelines Section 15124. RDEIR Section 2, Project Description,
contains the following information:
• The precise location and boundaries of the proposed project, including detailed maps are
included in RDEIR Section 2, Project Description, in Exhibits 2-2, 2-3, 2-5, and 2-7. The RDEIR
includes a regional map in Exhibit 2-1. (CEQA Guidelines § 15124(a))
• A statement of objectives sought by the proposed project is found in RDEIR Section 2, Project
Description, on page 2-64. (CEQA Guidelines § 15124(b))
• A general description of the project’s technical, economic, and environmental characteristics,
considering the principal engineering proposals if any and supporting public service facilities is
located in RDEIR Section 2, Project Description, subsection 2.3, Project Characteristics. (CEQA
Guidelines § 15124(c))
• A statement of the intended uses of the RDEIR is found in RDEIR, Section 2, Project
Description, subsection 2.5, Intended Uses of this Draft EIR, starting at page 2-65. (CEQA
Guidelines § 15124(d))
• A list of known discretionary and ministerial actions is included in RDEIR Section 2, Project
Description, subsection 2.5.1., Discretionary and Ministerial Actions. (CEQA Guidelines §
15124(d))
The project description provides a complete description of the proposed project’s components, an
accurate description of the project’s location, and comprehensive project objectives. The project’s
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technical, economic, and environmental characteristics are also described in the project description.
It contains fundamental information about the project’s implementation and discloses all pertinent
facts necessary to determine the environmental impacts of the project. Contrary to the assertion in
one comment letter, the project description is not required to identify a reclamation plan to be
prepared for mining operations because the Surface Mining and Reclamation Act (SMARA) does not
apply to the project. Please refer to Master Response 7—Applicability of SMARA. The project
description provides all required information necessary for the public and decision-makers to
analyze the impacts of the project and is therefore complete and legally sufficient.
A number of comments claimed that more detail is needed. Notably, the CEQA Guidelines provide
that the level of detail in an EIR project description should be “general.” This means in general that
all EIRs must include information about the main features of a project, but EIRs are not required to
provide information beyond what is needed to assess the impacts of the project. The leading court
decision on the level of detail in EIR project descriptions stated that a “general description” is all that
is required (Dry Creek Citizens Coalition v. County of Tulare (1999) 70 Cal.App.4th 20, 28). The court
also stated that an EIR “should not” provide additional detail beyond what is needed for
environmental evaluation. (Id. at 26.)
In addition, the level of detail or specificity required in an EIR also depends on the degree of
specificity involved in the proposed activity reviewed in the EIR. CEQA Guidelines Section 15146
contrasts a construction-level of detail with a zoning ordinance level of detail. For example, an EIR on
a construction project must be more specific and detailed than an EIR on the adoption of a general
plan or some other general policy or plan (CEQA Guidelines § 15146(a)). In contrast, an EIR on a
policy or plan should focus on the secondary effects expected to follow from adoption of the plan or
policy and need not be as detailed as an EIR on the specific construction projects that will follow
(CEQA Guidelines § 15146(b)). Cases confirm that the level of specificity required is determined on
the basis of the nature of the project (North Coast Rivers Alliance v. Kawamura (2015) 243
Cal.App.4th 647, 679; San Diego Citizenry Group v. County of San Diego (2013) 219 Cal.App.4th 1, 21;
Kings County Farm Bureau v. City of Hanford (1990) 221 Cal.App.3d 692, 733). In this case, the RDEIR
provides a project-specific level of analysis, but it is being prepared for a project with planning-level
entitlements (general plan amendments, zone change, development agreement, and adoption of a
specific plan, see RDEIR Section 2, Project Description, page 2-65).
The RDEIR contains all the detail that is required. The Project Description in the RDEIR is 66 pages in
length, and includes level appropriate descriptions, diagrams, and maps. These diagrams include a
land use plan (RDEIR Section 2, Project Description, Exhibit 2-9), a proposed site plan (RDEIR Section
2, Project Description, Exhibit 2-10), a preliminary greenway, open space and trails plan (RDEIR
Section 2, Project Description, Exhibit 2-11), and diagrams showing existing traffic circulation and
proposed traffic circulation (RDEIR Section 2, Project Description, Exhibits 2-12a, 12b).
Master Response 3—Analysis of Alternatives
Summary of Relevant Comments
Several commenters raised issues related to the analysis of alternatives. The key issues raised by
commenters include the following concepts:
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1. Legal adequacy of the analysis of the two No Project alternatives
a. reasonably foreseeable on-site operations
b. increased impact if sand and gravel operations were to be re-instituted
2. Acreage assumption for Alternative 1—Development within the Existing Land Use
Designations
3. Reflecting land use designations from the OPA and/or East Orange Plans
4. Improper Rejecting of Alternative 3—Collaborative Group
a. alternative should not be rejected as infeasible or as not meeting project objectives
b. proper name should be “Liaison Committee Alternative”
Responses
Several comments suggest the RDEIR’s analysis of alternatives is legally inadequate because it fails to
study specific alternatives proposed by commenters. The CEQA Guidelines, however, explain that an
EIR need discuss only a range of reasonable alternatives (CEQA Guidelines § 15126.6.). An EIR that
discusses a reasonable range of alternatives is not deficient simply because it excludes other
potential alternatives from its analysis (City of Maywood v. Los Angeles Unified Sch. Dist. (2012) 208
Cal.App.4th 362; Cherry Valley Pass Acres & Neighbors v. City of Beaumont (2010) 190 Cal.App.4th 316).
The RDEIR adequately analyzed a reasonable range of project alternatives that could result if the
project was not approved or that could avoid or substantially lessen environmental impacts resulting
from the proposed Project. The Collaborative Group Alternative and the 122 Unit Alternative were
both crafted in response to community input. The Collaborative Group Alternative is based, in part, on
the Pre-Development Agreement Alternative Land Use Plans identified during community outreach. It
was developed in response to meetings with representatives from neighborhoods near the project site:
Orange Park Acres, Mabury Ranch, and The Reserve. It analyzes a reduced density alternative
consisting of 47 lots, with a minimum lot size of 8,000 square feet, and 47 dwelling units of varying
sizes, on approximately 40 acres. The residential lots would be located on the southern portion of the
site. This alternative provides decision makers with information about how project objectives could be
satisfied in a smaller development. As explained in the analysis, this reduced density project would not
meet the majority of project objectives. The lead agency may make reasonable inferences regarding
whether an even smaller project would be able to meet project objectives. There is no requirement
under CEQA to analyze the incremental environmental impacts of several successively smaller
alternative developments, nor is there a CEQA requirement to study specific alternatives suggested by
members of the public if the EIR disclosed a reasonable range of alternatives (Center for Biological
Diversity v. Department of Fish & Wildlife (2015) 234 Cal.App.4th 214, 256; City of Maywood v. Los
Angeles Unified Sch. Dist. (2012) 208 Cal.App.4th 362, 420). The smaller alternative developments
proposed by the Orange Park Acres Board request a mix of densities ranging from 8,000 square feet, to
10,000 square feet, to 15,000 square feet, to 1 acre lots. In proposing an alternative with lots less than
1 acre, these commenters acknowledge that lots with a density range of 8,000 square feet to 1 acre are
compatible with the density of surrounding neighborhoods and a larger open space component that
permits these smaller lots in a cluster format.
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1. Legal Adequacy of the Analysis of the Two No Project Alternatives.
It is appropriate to identify and analyze two potential No Project alternatives. The CEQA Guidelines
recognize that there are two variations on the “no project” alternative (CEQA Guidelines §
15126.6(e)(3)(A-B)). Where the project involves the revision of an existing plan, policy, or ongoing
operation, the no-project alternative should reflect continuation of the existing plan, policy, or
operation (CEQA Guidelines § 15126.6(e)(3)(A)). The EIR should also analyze the impacts of the no-
project alternative by projecting what would reasonably be expected to occur in the foreseeable
future if the project were not approved, based on current plans and consistent with available
infrastructure and community services (CEQA Guidelines § 15126.6(e)(2)).
For the proposed project, Alternative 1 consists of development and land use activities that would
occur pursuant to the existing City of Orange General Plan land use designations of low-density
residential, resource, and open space for the project site. This is a reasonable foreseeable future for
the project site and appropriately analyzed in an alternative.
RDEIR Section 2, Project Description, subsection 2.1.2, Existing Land Use Activities, describes the
current use of the site as a “historically grandfathered land use sand and gravel operation in
accordance with the site’s existing Sand and Gravel zoning” (Orange Municipal Code Chapter 17.32).
Therefore, the continued operation of a sand and gravel land use is an appropriate “no project”
alternative and is analyzed in Alternative 2.
Because both of these alternatives are reasonably foreseeable, they are appropriately considered as
potential outcomes if the project is not approved and are correctly included as “no project” alternatives.
2. Acreage Assumption for Alternative 1—Development within the Existing Land Use Designation
Several comments question the acreage assumption in Alternative 1, stating that only 12.6 acres are
currently designated for residential use. (See Shute, Mihaly & Weinberger LLP, [SMW] comment 18
regarding acreage, and comment 57 regarding use of that acreage in Alternative 1).
RDEIR Section 2, Project Description, Exhibit 2-6, confirms that the Orange General Plan designates
15.4 acres of the project site for residential development. As such, the Alternative correctly identifies
the acreage designated for development in Alternative 1.
3. Reflecting Land Use Designations from Orange Park Acres and/or East Orange Plans
It is important to note that while the OPA Plan is labeled as a “specific plan,” the City has previously
determined that it does not contain the level of detail required of a specific plan under Government
Code Section 65450. The OPA Plan identifies goals, policies, and recommended land use concepts for
Orange Park Acres, but does not contain a program of implementation measures, infrastructure
plans, or development criteria. Refer to RDEIR Section 3.10, Land Use, for a detailed discussion of
project consistency with the City of Orange General Plan, City of Orange zoning, East Orange General
Plan, and Orange Park Acres Plan.
4. Improper Rejecting of Alternative 3—Collaborative Group
The City, as lead agency, will review all project alternatives when considering the project. As
discussed in Section 5.5, the Collaborative Group Alternative, would not advance the objectives that
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concern guiding the transition of an infill site with a Specific Plan; developing a logical internal
circulation system for pedestrians, bicyclists, equestrians, and motorists; and would not include the
Development Agreement benefits to the community.
The City Council designated two members of the Council to serve on a City Council Ad Hoc
Committee to engage with the Sully Miller landowner and members of the community in the area.
That Ad Hoc Committee conducted a series of meetings with representatives of Mabury, The Reserve
and Orange Park Acres to discuss opportunities and constraints related to possible development on
the site. Each Homeowner’s Association (HOA) designated their specific representative(s). The last
meeting of that group was March 2018. Separate from the Ad Hoc Committee meetings, the
representative of the property owner has been meeting with stakeholders from the various
neighborhood groups in the area. The property owner has referred to these stakeholders
cumulatively as a “liaison committee.” In some cases, the property owner has met with the “liaison
committee” as a group and sometimes he has met with them individually. Nevertheless, this activity
has been solely at the property owner’s discretion in an effort to reach a consensus with the
community regarding a development proposal. Again, this activity has been independent from the
City Council Ad Hoc Committee meetings.
Master Response 4—Dam Failure and Liability
Summary of Relevant Comments
Several commenters identified the proximity of Villa Park Dam and Santiago Dam, and the resulting
potential for hazardous conditions in the event of dam failure.
Response
Santiago Creek Dam was last inspected on May 3, 2018, according to the United States Army Corps
of Engineers (USACE) National Inventory of Dams. Its condition assessment rating is “satisfactory”
and its hazard potential rating is “extremely high.” Likewise, Villa Park Dam’s condition assessment
rating is “satisfactory” and its hazard potential rating is “extremely high.” It was last inspected on
February 21, 2018, according to the USACE website. According to the California Division of Safety of
Dams (DSOD) website, a “satisfactory” condition assessment indicates that no existing or potential
dam safety deficiencies are recognized. Acceptable performance is expected under all loading
conditions (static, hydrologic, and seismic) in accordance with applicable regulatory criteria or
tolerable risk guidelines. Hazard classifications are based on the size of the reservoir and the number
of people who live downstream of a dam, not the actual conditions of the dam or its critical
structures. Therefore, the condition assessment is a better indicator of potential dam deficiencies
with the potential to cause downstream flooding.
Pursuant to the California Water Code, dam inspections at Santiago Creek Dam and Villa Park Dam
are conducted by the DSOD at least once per year pursuant to laws, regulations, and practices of
DSOD to ensure the dam is safe, performing as intended, and is not developing problems. DSOD also
reviews the stability of dams and their major appurtenances in light of improved design approaches
and requirements, as well as new findings regarding earthquake hazards and hydrologic estimates in
California.
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The DSOD evaluation program is an ongoing screening process of spillways and other appurtenances
at dams throughout the State. Subsequent to the assessment, DSOD works with dam owners to
expedite development of required assessments and restore known areas of deficiency. Roughly, a
third of DSOD inspections result in in-depth instrumentation reviews. In 2017, the Santiago Creek
Dam required an extra spillway assessment in addition to its standard yearly inspection. The
evaluation required by DSOD includes assessment of:
• The spillway’s design and construction and geologic attributes while concurrently reviewing
the dam owner’s maintenance and inspection program;
• The spillway’s historical performance;
• Any previous spillway repairs.
To conduct the spillway assessment required by DSOD, the owners of Santiago Dam, the Irvine Ranch
Water District (IRWD) and Serrano Water District, submitted a workplan to DSOD in 2017. The
assessment is in-progress.
In addition to the DSOD inspections, IRWD and Serrano Water District inspect the Santiago Creek Dam
and spillway quarterly with a dam safety consultant and bi-annually with the DSOD. In addition, IRWD
staff visually inspects the dam daily and has caretakers that live on-site and observe the dam daily.
Measurements of drain flows, monitoring wells, and piezometers are taken monthly. Piezometers are
used to measure groundwater and other fluid pressure levels. Dam crest survey markers give IRWD the
ability to measure horizontal or vertical movement of the dam, which are measured by a licensed
surveyor annually to evaluate any adverse trends. With the above safety precautions in place and given
the condition rating of both dams as “satisfactory,” dam failure is not anticipated.
In terms of City policy, the General Plan identifies areas downstream of the Santiago Creek and Villa
Park dams for potential flooding in the event of a catastrophic dam failure (General Plan, page PS-4).
The General Plan characterizes such an event as “unlikely” (page PS-4) and does not prohibit or limit
development in these areas.
Maps compiled for potential dam failures are created, in part, in order to implement emergency
procedures required under Section 8589.5 of the California Government Code. The Orange County
Operational Area Emergency Action Plan Dams/Reservoir Failure Annex indicates that it would take a
dam failure flood wave 105 minutes to reach the project site from Villa Park Dam and 255 minutes
from Santiago Dam. Emergency procedures that the County and the City have established to protect
lives and property in the event of a dam failure would allow persons to be evacuated in the event of
a failure of Santiago Creek Dam or Villa Park Dam. Emergency response times for the City of Orange
Police Department vary on average from 4 to 7 minutes and emergency response times for the City
of Orange Fire Department are, on average, 3 minutes, 45 seconds; therefore flood flows would
move at rates which would allow emergency procedures to be implemented and persons to be
evacuated. Staff members at both dams are trained in operation of the facilities and would be able
to identify and respond to indications of adverse conditions; therefore, initial alerting of a dam
failure would occur quickly. Furthermore, the Orange County Sheriff’s Department oversees the
County’s Emergency Operations Center and has modeled dam failure scenarios for both Villa Park
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Dam and Santiago Dam based on Federal Emergency Management Agency (FEMA) Flood Maps
(RDEIR Section 3.9, Hydrology and Water Quality, Exhibit 3.9-4). The Sheriff’s Department has
developed plans to provide timely notification to affected parties and implement an orderly
evacuation in the event dam failure indications are observed, such as the AlertOC mass notification
system that provides time-sensitive messages to residents from the City or County in which they live
or work. Every method known to warn the public of an impending dam failure, including the
following systems, would be utilized by the City and County in the event of a dam failure at Villa Park
Dam or Santiago Dam:
• Emergency Alerting System (EAS) on the AM/FM radio
• AlertOC (Service is available to residents and non-residents to receive time-sensitive information
in the event of a natural disaster or emergency. Residents should register for this service)
• Police and Fire sirens
• Police helicopter loudspeakers
• Door-to-door canvassing1
Moreover, the General Plan requires that appropriate flood control measures be implemented along
Santiago Creek and throughout the planning area to reduce the risks from localized flooding and the
General Plan EIR implements the following two mitigation measures specific to flooding that would
reduce potential impacts throughout the City:
General Plan EIR Section 5.8, Hydrology and Water Quality, Mitigation Measure 5.8-1
Support efforts by the OCFCD to regularly maintain flood control channels and
structures owned by the OCFCD, and to complete necessary repairs in a timely
manner. Work with the OCFCD and USACE to identify new flood control
improvements and establish installation programs for improvements as needed.
Work with the OCFCD to identify opportunities to enhance the natural qualities of
Santiago Creek to protect habitat and reintroduce native plants, animals, and fish.
(Implementation Program V-11; Responsible Party—Community Development
Department, Community Services Department, Public Works Development;
Timeframe—Ongoing) (General Plan EIR, page 5.8-25–5.8-26).
General Plan EIR Section 5.8, Hydrology and Water Quality, Mitigation Measure 5.8-2
Continue to inspect storm drains, remove debris from catch basins as needed, and
evaluate and monitor water storage facilities to determine if they pose a water
inundation hazard. (Implementation Program I-32; Responsible Party—Public Works
Development; Timeframe—Ongoing) (General Plan EIR, page 5.8-25.)
As discussed in the City’s General Plan EIR, Citywide flood prevention methods, such as provision of
detention basins and on-site stormwater drainage, reduce runoff into the City’s drainage facilities
and provide adequate drainage for new developments. The City minimizes flood-related risks and
1 Enjoy Orange County, Dams in Orange County. Website: https://enjoyorangecounty.com/dams-in-orange-countySite accessed
March 6, 2019.
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hazards in the event of dam or reservoir failure by encouraging the County’s Flood Control District to
continue proper inspection of storm drains, ensuring maintenance of the flood control facilities, and
preventing earthquake damage. In addition, the City monitors water storage facilities to determine
potential inundation hazards to surrounding properties (General Plan, page PS-19.).
In addition to the emergency procedures, General Plan policies, and mitigation measures listed
above, RDEIR Section 3.9, Hydrology and Water Quality, Mitigation Measure HYD-5, requires the
applicant to prepare and implement an Emergency Evacuation Plan, which would identify specific
procedures for the safe and orderly evacuation of the project. The plan would specifically require the
streets to be identified with clear and visible signage and, if necessary, wayfinding signage to identify
exit points.
The project is consistent with the provisions of the General Plan related to flooding, and would
implement and support the General Plan’s policies and the General Plan EIR’s mitigation measures.
There is no inconsistency between the proposed project and the provisions of any applicable
general, specific, or regional plan related to flood prevention (CEQA Guideline § 15125(d)).
Given the fact that the (1) Villa Park Dam and the Santiago Creek Dam are listed as having
“satisfactory” conditions, (2) the project is consistent with applicable General Plan policies related to
flood prevention, (3) time durations associated with potential dam failures would provide sufficient
response times and resources to evacuate the project site in the event of a dam failure, and (4)
Mitigation Measure HYD-5 would be required to reduce impacts related to flooding, impacts
associated with dam failure are properly considered less than significant.
Master Response 5—Wildfire Risk
Summary of Relevant Comments
Several commenters raised the issue of wildfire and the project’s location in the wildland urban
interface.
Response
The eastern portion of the project site abuts Santiago Oak Regional Park and contains the wooded
Santiago Creek Corridor. The project site is located at the wildlife/urban interface. As discussed in
RDEIR Section 3.8, Hazards and Hazardous Materials, page 3.8-16, the project proposes to
strategically place approximately 68.5 acres of open space/grasslands and greenway with managed
vegetation within the western, northern, and eastern portions of the project site in order to provide
sufficient protection from wildland fires and alleviate related impacts. The project’s open space
areas will constitute a buffer against the spread of fire. Planning Area B, the Grassland area south of
Santiago Creek, includes a managed vegetation/fuel modification zone north of and east of Planning
Area C that would act as a vegetative buffer between the open space and residential neighborhood.
The buffer zone would be 130 feet wide and would include plantings responsive to fuel management
policies. In addition, the project proposes a 20-foot wet zone within the rear yard of the residential
lots to support fuel management policies. The managed vegetation/fuel modification zones comply
with fuel modification requirements in Section 320 of the Orange County Fire Code (as required by
City of Orange Municipal Code Section 15.32.020). Upon dedication of the open space in Planning
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Areas A and B to the City of Orange, County of Orange, or another entity, the applicant/developer
will retain an easement for fuel modification zone maintenance.
Orange General Plan, Public Safety Element, page PS-4, notes that “keeping neighborhoods buffered
from both urban and wildland fire hazards reduces incidents requiring response, and minimizes
damage to property when fires to occur.” Orange General Plan, Public Safety Element, page PS-19,
states that development within or adjacent to an identified wildland fire area “. . . must prepare and
implement a comprehensive fuel modification program in accordance with City regulations. The City
will review new developments and fire services to ensure adequate emergency services and facilities
to residents and businesses.”
Orange General Plan, Public Safety Element, Goal 3.0 on page PS-4, is to “[p]rotect lives and property
of Orange residents and businesses from urban and wildland fire hazards.”
Orange General Plan, Public Safety Element, Policy 3.3 states:
Require planting and maintenance of fire-resistant slope cover to reduce the risk of
brush fires within the wildland-urban interface areas located in the northern and
eastern portions of the City and in areas adjacent to canyons, and develop and
implement stringent site design and maintenance standards for all areas with high
wild land fire potential. To the extent possible, native, non-invasive plant materials
are encouraged.
The General Plan Public Safety Element goal and policy above would be advanced by incorporating
open space and a vegetative buffer as part of the project. The vegetative buffer would include
plantings responsive to fuel management policies and all City fuel management standards would be
met.
The proposed project would include a robust fire protection system as required by the California
Building Code. Fire sprinkler systems and ignition resistant structures have a very high success rate
for confining fires or extinguishing them. Additionally, there are two fire stations within 2 miles of
the project site: Orange Fire Department Station No. 8, which is 1.75 miles from the project site, and
Orange County Fire Authority Station No. 23, which is 0.64 mile from the project site. Emergency
response times from the City of Orange Fire Department would be approximately 3 minutes and 45
seconds. Fire stations near the project site would increase the likelihood of successful initial attacks
to limit the spread of wildfires. The fire protection system on-site would provide protection from on-
site fires spreading to off-site vegetation through the required fuel modification zone. Accidental
fires within the landscape or structures in the project area would have limited ability to spread.
Landscaping throughout the project site and on its perimeter would be highly maintained, and much
of it would be irrigated, which would further reduce its ignition potential.
In addition, RDEIR Section 3.8, Hazards and Hazardous Materials, Mitigation Measure HAZ-6 will be
implemented to require the applicant to prepare a Fuel Modification Plan for submission to the City
of Orange for review and approval prior to the issuance of building permits, consistent with the Fire
Department’s recommendation that the project meet the City’s fuel modification requirements.
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As identified in the RDEIR, with implementation of project features, incorporation of open space
areas and vegetative buffers as part of the project, compliance with City requirements for fuel
modification, and Mitigation Measure HAZ-6, impacts would be less than significant.
Master Response 6—Stewardship of Open Space
Summary of Relevant Comments
Several commenters question who will be responsible for the maintenance and costs of the open
space component of the project.
Response
The project will include approximately 68.5 acres of dedicated greenway and open space comprised
of natural hillsides, re-established grasslands, a restored Santiago Creek riparian corridor, and a
managed vegetation/fuel modification zone. As noted in an April 1, 2019 Memorandum from the
City of Orange Community Development Director to the Director of OC Parks (included in Section 4:
Errata, as Appendix S, as a component of the Specific Plan and Development Agreement, the project
applicant is proposing to fund $4,100,000 in landscaping, trails, and other improvements for the
Santiago Creek Greenway and open spaces. The amenities planned for these areas include the
following:
• Multi-use trails providing public access to open space and the Santiago Creek environs;
• Tail paseos for hiking and bicycling access;
• Expansion of and connection to the 1,269-acre Santiago Oaks Regional Park;
• Trailside rest-stops;
• Trailhead, informational signage, shade shelters and kiosks and related amenities;
• Stormwater and flood control improvements;
• Managed vegetation and fuel modification; and
• Passive outdoor uses.
In addition, the applicant is funding an additional $3,000,000 for trails, equestrian, and recreational
amenities in the East Orange Area. Among other things, the applicant is proposing to dedicate the
51-acre former Ridgeline Golf Course site to the City for future open space and recreational uses.
Please refer to Errata Appendix S, the City’s April 1, 2019 Memorandum, for further details on the
wide range of open space and greenway amenities the proposed project would provide to future
residents of the proposed project and the community.
Pursuant to the provisions in the Specific Plan, page 8-3, all public trails and open space (except the
easement for fuel modification zone maintenance) shall be offered to Orange County, the City of
Orange, or another suitable public entity as a publically available trail system. All conveyances will be
subject to specific guidelines established in conformance with City standards and project approvals.
Unless and until the applicant’s offer of conveyance is accepted, the public trails will be privately
owned and maintained by the Master HOA or a similar entity.
As stated in RDEIR Section 2, Project Description, page 2-50, the Santiago Creek Greenway Alliance
recommends that the applicant convey the open space grasslands and trails to OC Parks for
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maintenance and stewardship. In the event the applicant conveys the open space grasslands and
trails to OC Parks, the applicant will enter into a Memorandum of Understanding (MOU) with OC
Parks prior to approval of the Tentative Map for the Project. However, in the event that OC Parks will
not provide management and maintenance for the open space grasslands and trails, management
and maintenance would remain the responsibility of the HOA, another public agency, or a non-profit
organization, including long-term management, as part of the proposed project. The project
proponent will provide funding for improvements within the Santiago Creek Greenway. The project
applicant will enter into an agreement with the HOA, non-profit, public agency, or similar entity,
prior to approval of the Tentative Map for the project, to ensure that responsibility for construction
of improvements and maintenance is adequately addressed. The agreement will include a funding
mechanism to ensure adequate funding of open space improvements and subsequent maintenance.
Additionally, pursuant to the terms of the Specific Plan, upon dedication of the Specific Plan’s open
space in Planning Areas A and B to the City of Orange, County of Orange or other entity the
applicant/developer will retain an easement for fuel modification zone maintenance at the time of
final mapping. This ensures that responsibility for this important maintenance area is clearly
established. Responsibility for open space grasslands and trails management and maintenance will
be discussed with OC Parks as part of the ongoing development process.
A financing mechanism will be established for the stewardship of open space within the project,
prior to the dedication to a public agency or non-profit organization.
Master Response 7—Applicability of SMARA
Summary of Relevant Comments
Several commenters made comments relating to the Surface Mining and Reclamation Act (SMARA)
of 1975 (Public Resources Code [PRC], §§ 2710-2796). Commenters questioned whether SMARA
applies to the site or the project and whether a reclamation plan is required.
Response
As discussed in RDEIR Section 3.11, Mineral Resources, page 3.11-3, surface mining operations
ceased on the project site prior to January 1, 1976. Under SMARA, a mining reclamation plan is
required only for post-1975 mining operations. As such, a mining reclamation plan under SMARA is
not required for the project site. This issue was fully evaluated in 2003 by the State Office of Mine
Reclamation (OMR) and by the City. It was at the time that the OMR and the City determined then
that SMARA did not apply to the site. This analysis is fully set forth in Appendix M of the RDEIR.
Further, SMARA applies to surface mining, and does not apply to grading projects that are moving
earth from one place to another. Therefore, grading activities for the project pursuant to the Sand
and Gravel Extraction District (SG) zone or a valid grading permit would not be subject to SMARA.
Master Response 8—Site Environmental Conditions
Summary of Relevant Comments
Several commenters raised issues regarding environmental conditions on the project site, including
questions about soil contamination, cleanup, and handling of mine waste. These included comments
that additional soils investigation should be performed, comments about the proximity of home sites
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to the County’s closed Villa Park landfill and the possibility of methane migration affecting the
homes, and comments that the RDEIR should be recirculated again for preparation of revised
environmental site assessments.
Response
The RDEIR recognizes and discusses the potential for hazardous soils and identifies Mitigation
Measure HAZ-2b as required mitigation. The mitigation would require that any existing potentially
hazardous conditions be abated in accordance with DTSC standards as part of the development of
new residential uses. Further, the mitigation requires that all contaminated soils “be excavated and
disposed of off-site in accordance with the rules and regulations of the United States Department of
Transportation (DOT), United States Environmental Protection Agency (EPA), California
Environmental Protection Agency (Cal/EPA), California Occupational Health and Safety
Administration (Cal/OSHA), and any local regulatory agencies.” The applicant is required to submit
documentation to the City of Orange in the form of confirmatory soil sampling results verifying that
this mitigation measure was successfully implemented as part of the grading permit application for
this property. Refer to RDEIR Section 3.8, Hazards and Hazardous Materials, for further discussion. To
clarify and clearly articulate established abatement procedures identified in RDEIR Section 3.8,
Hazards and Hazardous Materials, the text below is added to Mitigation Measure HAZ-2a to ensure
that further investigation and implementation occurs. The clarifying text is shown below, and is also
included in Section 4, Errata, of this Final EIR.
These regulations, procedures and documentation requirements provide sufficient performance
standards to satisfy CEQA. The mitigation measures below require compliance with applicable DTSC
regulations and require any necessary remediation to meet DTSC standards. “[A] condition requiring
compliance with regulations is a common and reasonable mitigation measure and may be proper
where it is reasonable to expect compliance” (Oakland Heritage Alliance v. City of Oakland (2011)
195 Cal.App.4th 884, 906). Here the project is predicated on compliance with numerous State and
federal standards that are enforceable and it is reasonable to expect compliance (Citizens Opposing a
Dangerous Env’t v. County of Kern (2014) 228 Cal.App.4th 360, 383 [compliance with Federal Aviation
Administration procedures held to be appropriate mitigation for aviation safety impacts]).
MM HAZ-2a A supplemental Phase II Environmental Site Assessment shall be conducted to
further delineate the vertical and lateral extent of the contamination. The proposed
enclosed structures shall be situated strategically, using supplemental Phase II
Environmental Site Assessment data and DTSC’s review thereof, so that structures
will not interfere with future remediation of any potential landfill gas migration; this
shall be demonstrated in connection with approval of any tentative maps for the
project to allow for future remediation of any potential landfill gas migration. Prior
to issuance of building permits for dwelling units in areas of the project site where
vapor intrusion has the potential to occur, the applicant shall prepare and submit
plans to the City of Orange, DTSC, or the Local Enforcement Agency (which is the
County of Orange Environmental Health Division) identifying vapor intrusion
abatement measures for trichloroethylene (TCE) and methane. Areas where vapor
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intrusion has the potential to occur are those identified in the Phase II
Environmental Site Assessment.
The Phase II Environmental Site Assessment shall be conducted in substantial
compliance with applicable guidance documents, including but not limited to the DTSC
Advisory—Active Soil Gas Investigation and Final Guidance for Evaluation and
Mitigation of Subsurface Vapor Intrusion to Indoor Air. The Phase II Environmental Site
Assessment shall use current DTSC HHRA Note 3 and Regional Screening Levels
established by the U.S. Environmental Protection Agency. Following preparation of the
Phase II Environmental Site Assessment, a soil risk management plan shall be prepared
to address any discovery of previously unknown contamination and shall be submitted
to DTSC. These reports shall be conducted pursuant to applicable DTSC advisories, and
abatement shall be implemented as directed by DTSC. Such abatement measures may
include but are not limited to vapor barriers or passive/active venting systems, as
determined by the appropriate regulatory agency, unless determined not to be
necessary by the City in consultation with the Local Enforcement Agency. All occupied
structures within a 1,000 foot radius of the landfill shall include the following
structural controls to limit the potential for landfill gas accumulation (unless such
controls are determined not to be necessary by the City in consultation with the Local
Enforcement Agency): (1) a geomembrane between the slab and the subgrade; (2) a
permeable layer with venting pipe between the geomembrane; and (3) automatic
methane gas sensors with audible alarms in the permeable layer and inside the
structures. The soil risk management plan shall include, among other provisions,
worker safety practices and procedures for discoveries of hazardous materials,
including those already identified at the site. If DTSC concludes that additional
mitigation is needed, the applicant shall work with DTSC and the City to jointly develop
additional mitigation measures that meet residential standards.
The approved abatement measures shall be incorporated into project building plans.
Design plans for: 1) any occupied structures within 1,000 feet of the landfill
boundary; and/or 2) structural systems to prevent gas-related hazards are required
to be reviewed and approved by the Local Enforcement Agency (which is the County
of Orange Environmental Health Division).
MM HAZ-2b Prior to issuance of grading permit for construction of the residential portion of the
project, the project applicant shall retain a qualified hazardous materials contractor
to remove all soil containing Total Petroleum Hydrocarbons in excess of residential
development standards set forth by the California Department of Toxic Substances
Control (DTSC) or other applicable regulatory agency. Soil removal and disposal shall
occur in accordance with DTSC (or other applicable agency) guidelines. Additional
groundwater sampling shall be conducted under the guidance of DTSC, focused on
the area within 1,000 feet of the Villa Park landfill, to assess whether TPH, methane,
and/or VOCs have impacted groundwater at levels that generate either significant
human health or ecological risk, which was encountered at depths of 20 to 50 feet
bgs. If the groundwater is affected, a multi-media risk assessment shall be
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conducted under the guidance of DTSC, and abatement measures as required by
DTSC shall be implemented, subject to final confirmation by the City.
The applicant shall submit documentation to the City of Orange in the form of
confirmatory soil and groundwater sampling results verifying that this mitigation
measure was successfully implemented as part of the grading permit application for
this property. All environmental investigations, sampling and/or remediation for the
project site shall be conducted under a workplan approved and overseen by a
regulatory agency with jurisdiction to oversee hazardous substance cleanup, such as
DTSC and/or the Regional Water Quality Control Board (RWQCB). As part of proper
construction operations and maintenance, any construction areas that are found to
contain contaminated soils shall be excluded using a security fence. All contaminated
soils shall then be excavated and disposed of off-site in accordance with the rules and
regulations of: US Department of Transportation (USDOT), USEPA, CalEPA, CalOSHA,
and any local regulatory agencies. All retention and detention features used during
construction would be lined to prevent infiltration through contaminated soils. Post-
construction retention features shall be lined to prevent infiltration of groundwater.
In response to the comment that the RDEIR should be recirculated for further review of
environmental site issues, responses to the comments, and revised mitigation measures in response
to the comments have been provided. Recirculation is required in situations such as when there is a
new or substantially more severe significant environmental impact, and is not required when the
information in a Final EIR includes responses to comments that clarify or amplify the information in a
draft EIR. In this case, the responses clarify and amplify the information from the RDEIR, and not
trigger CEQA’s requirements for recirculation.
Master Response 9—Soil Import/Export Numbers
Summary of Relevant Comments
Several commenters raised issues regarding the amount of clean soils that would have to be
imported to the project site, and the amount of additional mine waste that would need to be
exported from the site to develop the proposed project.
Response
As noted in RDEIR Section 2, Project Description, page 2-2, the previously mined portions of the site
were “backfilled,” in which unsuitable materials are excavated and replaced with fill, pursuant to a
grading permit issued by the City of Orange in 2011. It was anticipated that approximately 223,000
cubic yards of material would be imported to the site during the process, including concrete, asphalt,
and rock that would be crushed on-site. Approximately 2,000 cubic yards of material was anticipated
to be excavated from the site for reuse and would be blended with the crushed import material for a
total of 225,000 cubic yards of backfill. RDEIR Section 3.11, Mineral Resources, further evaluates
mineral resource extraction activities.
During grading, the project would import approximately 877,000 cubic yards of new material, and
remove 500,000 cubic yards of silt. As a conservative estimate, it was assumed that each haul truck
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would have a capacity of 10 cubic yards per load (plus the return of one empty truck). Based on this
conservative assumption, it was estimated that the project would require up to 275,400 haul trips
during the 1.5-year grading period. Thus, using this estimate, the technical analyses and discussions
in the RDEIR assumes the “worst case” scenario for the project. This allows the reader and decision
makers to fully understand potential environmental impacts.
Regarding the accuracy of the required import and export of soils, and the relationship between the
Project Description and the Geotechnical Investigation contained in Appendix I, the Project
Description provides accurate numbers for the amount of import and export required by the project.
The information provided in Appendix I relates to the larger Rio Santiago Specific Plan analysis, as
one commenter points out. The purpose of including the information in Appendix I, which includes
information from the Rio Santiago Specific Plan project, is to provide additional support for the
characterization of subsurface soils and the likely methods of construction required.
Master Response 10—General Comments on the Project, General Opposition
Summary of Relevant Comments
Numerous commenters expressed general opposition to the project, without making specific
comments on environmental issues related to the project or on the sufficiency of the RDEIR’s
analysis of environmental impacts. Some commenters expressed general support for the project.
Response
The comments containing personal opinions expressing general support for, or opposition to, the
project are noted and will be part of the administrative record that will be before City decision makers
and that will be considered in deciding whether to approve the project or not, and subject to what
conditions any approval would be issued. Similarly, opinions about the general desirability or merits of
the project, or comments about economic or political considerations of the project, will be part of the
record before the decision makers and will be considered in evaluating the proposed project.
CEQA requires that the Final Environmental Impact Report (Final EIR) address comments on the
adequacy of the RDEIR and on environmental issues related to the project (PRC § 21091(d)(2)(B);
CEQA Guidelines § 15088(c)). CEQA considerations are limited to environmental issues and the
potential impacts of the project on the environment. The environmental issues raised in the various
comment letters have been addressed by this Final EIR in the Master Responses and in the individual
responses to comment letters, and no further response is required to general comments opposing
the project or expressing opinions.
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SECTION 3: RESPONSES TO WRITTEN COMMENTS
3.1 - List of Authors
A list of public agencies, organizations, and individuals that provided comments on the Recirculated
Draft Environmental Impact Report (RDEIR) is presented below. Each comment has been assigned a
code. Individual comments within each communication have been numbered so comments can be
crossed-referenced with responses. Following this list, the text of the communication is reprinted
and followed by the corresponding response.
Additionally, the City of Orange received 324 letters that commented on the project but did not
provide comments on any aspect of the RDEIR’s analysis. In accordance with California
Environmental Quality Act (CEQA) Guidelines Section 15003(g), which provides, “The purpose of
CEQA is not to generate paper, but to compel government at all levels to make decisions with
environmental consequences in mind,” copies of these letters are provided at the end of this
section; however, because these letters express general opposition to the project and do not
contain comments specific to the analysis contained within the RDEIR or any environmental issue,
they are addressed collectively via a master response provided in Section 2, Master Responses.
Author Author Code
State Agencies
Office of Planning and Research ........................................................................................................ OPR
California Department of Transportation ................................................................................. CALTR ANS
California Department of Fish and Wildlife .................................................................................... CDFW
Department of Toxic Substances Control ......................................................................................... DTSC
Local Agencies
City of Irvine .................................................................................................................................. IRVINE
City of Villa Park ...................................................................................................................... VILLA PARK
Irvine Water District ........................................................................................................................ IRWD
Metropolitan Water District ............................................................................................................ MWD
Orange County Public Works .......................................................................................................... OCPW
Orange County Transportation Authority ........................................................................................ OCTA
Orange County Waste and Recycling .............................................................................................. OCWR
South Coast Air Quality Management District .......................................................................... SCAQMD
Organizations
California Cultural Resource Preservation Alliance ........................................................................ CCR PA
Friends of Harbor Beach Parks ......................................................................................................... FHBP
Respect Orange .......................................................................................................................... RESPECT
Santiago Creek Greenway Alliance .................................................................................................. SCGA
Shute, Mihaly, & Weinberger LLP .................................................................................................... SMW
Wittwer Parkin LLP ..................................................................................................... WITTWE R_PARKIN
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Individuals
Addison Adams ............................................................................................................................ ADAMS
Kaitlin Agee ...................................................................................................................................... AGEE
Wendy Alexander .................................................................................................................. ALEXANDER
Carolyn Aliotta ............................................................................................................................. ALIOTTA
Angel Anderson ...................................................................................................................... ANDERSON
Janet Andrews ....................................................................................................................... ANDREWS 1
Paul Andrews ........................................................................................................................ ANDREWS 2
Khalil Arshaid.............................................................................................................................. ARSHAID
Kathy Ashford and Laura Thomas ............................................................................................. AS HFORD
Alicia Bausley ............................................................................................................................. BAUSLEY
Gary and Diane Benson ............................................................................................................... BENSON
Michael Bonnaud .................................................................................................................... BONNAUD
Donald E. Bradley .................................................................................................................... BRADLEY 1
Toni Bradley ............................................................................................................................. BRADLEY 2
Cathy Brodsky......................................................................................................................... BRODSKY 1
Jackie Brodsky ........................................................................................................................ BRODSKY 2
Michele Brown ............................................................................................................................. BROWN
Ercell Bryant .............................................................................................................................. BRYANT 1
Sharon Bryant ............................................................................................................................ BRYANT 2
Lucy Busby ................................................................................................................................... BUSBY 1
Todd Busby .................................................................................................................................. BUSBY 2
Sharon Butterfield ............................................................................................................... BUTTERFIELD
Mark Capurso ............................................................................................................................ CAPURSO
Mary Carlson ............................................................................................................................. CARLSON
Holly Caswell .............................................................................................................................. CASWELL
James Cathcart ......................................................................................................................... CATHCART
Scott Chaplin .............................................................................................................................. CHAPLIN
Patricia Closson ......................................................................................................................... CLOSSON
Edward Cook ................................................................................................................................... COOK
Victoria Coonradt ................................................................................................................... COONRADT
Daniel Correa .............................................................................................................................. CORREA
Cindy Couisine ........................................................................................................................... COUISINE
Patrick Courchaine ........................................................................................................... COURCHAINE 1
Tanya Courchaine ............................................................................................................. COURCHAINE 2
Donna Crandall ........................................................................................................................ CRANDALL
Tom Davidson .......................................................................................................................... DAVIDSON
Larry Day ............................................................................................................................................ DAY
Gregg DeNicola ........................................................................................................................ DENICOLA
Diana Des Champs ........................................................................................................... DE S CHAMPS 1
Diana Des Champs ........................................................................................................... DE S CHAMPS 2
Linda Dickinson ...................................................................................................................... DICKINSON
Rich Dobson ............................................................................................................................... DOBSON
Steve Ducolon .......................................................................................................................... DUCOLON
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Michelle Duman .......................................................................................................................... DUMAN
Steve Eimers ................................................................................................................................. EIMERS
Jane Elam ......................................................................................................................................... ELAM
Susan J. Elgin .................................................................................................................................... ELGIN
Maria Fahie ...................................................................................................................................... FAHIE
Jessica Farnham .......................................................................................................................... FARNAM
Annette Feliciani ........................................................................................................................ FELICIANI
Pam and Bruce Ferguson ........................................................................................................ FERGUSON
Toni and John Finn ............................................................................................................................ FINN
Hollis W. Fitz .......................................................................................................................................FITZ
Chris Flathers ............................................................................................................................ FLATHERS
David Fong ....................................................................................................................................... FONG
James and Shirley Fraser .............................................................................................................. FRASER
Lynn Marie and Richard Frediani ............................................................................................... FREDIANI
Andy and Maryann Gaither ........................................................................................................ GAITHER
Alex and Carrie Garufis ............................................................................................................... GARUFIS
Maggie Garza .............................................................................................................................. GARZA 1
Robert Garza ............................................................................................................................... GARZA 2
Marian Gaudette ..................................................................................................................... GAUDETTE
Mike and Kathy Gerakos ............................................................................................................ GERAKOS
Robert Gerger .............................................................................................................................. GERGER
Adrienne J. Gladson, AICP ........................................................................................................ GLADSON
Keith Gladstien ....................................................................................................................... GLADSTIEN
Dan Graupensperger ............................................................................................... GRAUPENSPERG ER 1
Dan Graupensperger ............................................................................................... GRAUPENSPERG ER 2
Tom and Bobbie Grayson ...........................................................................................................GRAYSON
Anthony Gressak ......................................................................................................................... GRESSAK
Martha Guerrero-Phlaum ....................................................................................................... GUERRERO
Kim Haman .................................................................................................................................. HAMAN
Nancy Hamilton ....................................................................................................................... HAMILTON
Jaime Hatzfeld ....................................................................................................................... HATZFELD 1
Kirat Hatzfeld ......................................................................................................................... HATZFELD 2
Sarah Hemmeter ................................................................................................................ HEMMETER 1
Scott Hemmeter ................................................................................................................. HEMMETER 2
Kelly Herbeck .......................................................................................................................... HERBECK 1
Kelly Herbeck .......................................................................................................................... HERBECK 2
Kelly Herbeck .......................................................................................................................... HERBECK 3
Karen Hersom ............................................................................................................................. HERSOM
Marcos and Melissa Higareda ................................................................................................. H IGAREDA
Arlene Hillman ........................................................................................................................ HILLMAN 1
Charles Hillman ....................................................................................................................... HILLMAN 2
Barbara Hillman ...................................................................................................................... HILLMAN 3
David Hillman ......................................................................................................................... HILLMAN 4
Doug Hillman .......................................................................................................................... HILLMAN 5
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Vickie Homer ................................................................................................................................ HOMER
Jay and Donna Hooker ................................................................................................................ HOOKER
Mark A. Huff .................................................................................................................................. HUFF 1
Sarah. Huff .................................................................................................................................... HUFF 2
Tim and Nancy Hume ..................................................................................................................... HUME
Peter Jacklin .............................................................................................................................. JACKLIN 1
Peter Jacklin .............................................................................................................................. JACKLIN 2
Thea Johnson ............................................................................................................................ JOHNSON
Teresa Johnston ....................................................................................................................... JOHNSTON
Mary Ann Jones ............................................................................................................................JONES 1
Susan Jones ..................................................................................................................................JONES 2
Gayle Keyes ..................................................................................................................................... KEYES
Bob Kirkeby .............................................................................................................................. KIRKEBY 1
Bob Kirkeby .............................................................................................................................. KIRKEBY 2
Katrina Kirkeby ......................................................................................................................... KIRKEBY 3
Nora Kirkeby ............................................................................................................................. KIRKEBY 4
Pat Klinker ................................................................................................................................... KLINKER
Vernon Kowitz .............................................................................................................................. KOWITZ
Ken Kribel ....................................................................................................................................... KRIBEL
Nannette Kuhl .................................................................................................................................. KUHL
Nick Lall ............................................................................................................................................. LALL
Jim and Diane Larson ...................................................................................................................LARSON
Charles Leffler .............................................................................................................................. LEFFLER
Frank Lesinski ........................................................................................................................... LESINSKI 1
Stephanie Lesinski .................................................................................................................... LESINSKI 2
Stephanie Lesinski .................................................................................................................... LESINSKI 3
Kimiya Leuteritz ........................................................................................................................ LEUTERITZ
Kathie and Herb Levy ........................................................................................................................ LEVY
Chris Lovell .................................................................................................................................... LOVELL
Barbara Luther ............................................................................................................................. LUTHER
Marilyn Maldonado ........................................................................................................... M ALDONADO
John Marzt .................................................................................................................................... MARZT
Mark Massie ................................................................................................................................. MASSIE
Errol Mathieu ............................................................................................................................ MATHIEU
Packy McFarland .................................................................................................................. MCFARLAND
Marilyn McNulty ....................................................................................................................... MCNULTY
Alexander Mitchell ................................................................................................................. MITCHELL 1
Elisabeth Mitchell ................................................................................................................... MITCHELL 2
Jaclyn Mitten ................................................................................................................................ MITTEN
Deborah Mongan ................................................................................................................... MONGAN 1
Ryan Mongan ......................................................................................................................... MONGAN 2
Kathryn Monteleone ......................................................................................................... MO NTELEONE
Debbie Moore ........................................................................................................................... MOORE 1
Judy Moore ............................................................................................................................... MOORE 2
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Mark Moore .............................................................................................................................. MOORE 3
Michael Moore ......................................................................................................................... MOORE 4
Sharon Mule .................................................................................................................................... MULE
Shirley Mullen ............................................................................................................................. MULLEN
Jennifer Naughton ................................................................................................................. NAUGHTON
Cynthia Nelson ............................................................................................................................. NELSON
Rosemary Nguyen ....................................................................................................................... NGUYEN
George Nicholas ....................................................................................................................... NICHOLAS
Tanya Orth ....................................................................................................................................... ORTH
Sherry Panttaja ...................................................................................................................... PANTTAJA 1
Tim Panttaja ........................................................................................................................... PANTTAJA 2
James and Tracey Parkhurst .................................................................................................. PARKHURST
Fran Pendray ........................................................................................................................... PENDRAY 1
Leroy Pendray ......................................................................................................................... PENDRAY 2
Leroy J. Pendray ...................................................................................................................... PENDRAY 3
Heather Perkins ........................................................................................................................ PERKINS 1
Susan Perkins ............................................................................................................................ PERKINS 2
Susan Philipp ................................................................................................................................ PHILIPP
Jason Phlaum .............................................................................................................................. PHLAUM
Kim Plehn .....................................................................................................................................PLEHN 1
Kim Plehn .....................................................................................................................................PLEHN 2
Kirk Plehn .....................................................................................................................................PLEHN 3
Joanne Pritts ............................................................................................................................... PRITTS 1
Joe Pritts ..................................................................................................................................... PRITTS 2
Barbara Quant ........................................................................................................................... QUANT 1
Leonard Quant ........................................................................................................................... QUANT 2
David Randall ............................................................................................................................. RANDALL
Deborah Redfern ....................................................................................................................... REDFERN
Michael and Sandra Reed ................................................................................................................. REED
Cindy L. Reina .............................................................................................................................. REINA 1
Cynthia Reina ............................................................................................................................... REINA 2
J. Vincent Reina ............................................................................................................................ REINA 3
John Reina ................................................................................................................................... REINA 4
John Reina ................................................................................................................................... REINA 5
Theodore Reina ........................................................................................................................... REINA 6
Kay Ressler ................................................................................................................................... RESSLER
Kim Riechmann ..................................................................................................................... RIECHMANN
Bonnie Robinson ................................................................................................................... ROBINSON 1
Joel Robinson ........................................................................................................................ ROBINSON 2
Howard Rothfeder ................................................................................................................. ROTHFEDER
Ron Rothschild ......................................................................................................................ROTHSCHILD
Greg Rush ........................................................................................................................................ RUSH
Jody Sadeghipour ............................................................................................................. SADEGHIPOUR
Laura and David Sandoval ....................................................................................................... SANDOVAL
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Amee and Scott Scigliano ........................................................................................................ SCIGLIANO
Theresa Sears ............................................................................................................................... SEARS 1
Theresa Sears ............................................................................................................................... SEARS 2
John Seelert .............................................................................................................................. SEELERT 1
Sharon Seelert .......................................................................................................................... SEELERT 2
Julia and Mark Serres .................................................................................................................... SERRES
Lori Shackelford ................................................................................................................. SHACKELFORD
Sheila Sherman ........................................................................................................................ SHERMAN
Eliza Smith ...................................................................................................................................... SMITH
Lynday Sewart ............................................................................................................................. SEWART
Kenneth and Julie Ann Stichter ................................................................................................. STICHTER
Robert and Emiko Stumpf ........................................................................................................... STUMPF
Synde Sutherland ................................................................................................................ SUTHERLAND
Dan Swoish .................................................................................................................................. SWOISH
Laura Thomas .......................................................................................................................... THOMAS 1
Laura Thomas .......................................................................................................................... THOMAS 2
Ronald Thompson ................................................................................................................. THOMPSON
Debra Tous ....................................................................................................................................... TOUS
Steve Tyreman .......................................................................................................................... TYREMAN
Marius Van Derr Watt ...................................................................................................... VAN DER WATT
Viviane Virga .................................................................................................................................. VIRGA
Mike Walker ................................................................................................................................ WALKER
Chrisann V. Walton ...................................................................................................................... WALTON
Deborah Ward ................................................................................................................................ WARD
Ann Webb ....................................................................................................................................... WEBB
Peter Wetzel ................................................................................................................................. WETZEL
Kelley White ................................................................................................................................... WHITE
Dru Whitefeather ............................................................................................................ W HITEFEATHER
Kari Wildermuth ................................................................................................................ WILDERMUTH
Sandra Wingerd ........................................................................................................................ WINGERD
Laurel Wykes ................................................................................................................................. WYKES
Robert Zweig .................................................................................................................................. ZWEIG
3.2 - Responses to Comments
3.2.1 - Introduction
In accordance with the CEQA Guidelines Section 15088, the City of Orange, as the lead agency,
evaluated the comments received on the RDEIR (State Clearinghouse No. 2017031020) for the Trails
at Santiago Creek Specific Plan, and has prepared the following responses to the comments received.
This Response to Comments document becomes part of the Final EIR for the project in accordance
with CEQA Guidelines Section 15132.
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3.2.2 - Comment Letters and Responses
The comment letters reproduced in the following pages follow the same organization as used in the
List of Authors.
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State Agencies
Office of Planning and Research (OPR)
Response to OPR-1
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment.
Response to OPR-2
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment.
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California Department of Transportation (CALTRANS)
Response to CALTRANS-1
Comment noted. The comment consists of introductory remarks that do not raise any questions
about the environmental analysis.
Response to CALTRANS-2
Based on the Existing AM and PM peak-hour Level of Service (LOS) at the three requested study
locations shown in Attachment B and the Highway Capacity Manual (HCM)/LOS calculation
worksheets, attached, and the criteria contained within the Caltrans Guide for the Preparation of
Traffic Impact Studies (December 2002), no further traffic analyses are required for the proposed
project. The proposed project is forecast to generate less than 49 AM or PM peak-hour trips at the
study locations and the three intersections currently operate at LOS C or better. Therefore, no
further analyses are required consistent with the thresholds defined in Section II.A, Trip Generation
Thresholds of the Traffic Impact Analysis (TIA) Guide.
Response to CALTRANS-3
Comment noted. This comment recommends the City coordinate with the County of Orange to
install sidewalks along Villa Park Landfill frontage, including East Santiago Canyon Road and Cannon
Street. This comment does not raise any potentially significant environmental issues.
Response to CALTRANS-4
Comment noted. This comment recommends the City consider constructing a sidewalk along the
eastbound stretch of East Santiago Canyon Road between Nicky Way and Orange Park Boulevard.
This comment does not raise any potentially significant environmental issues.
Response to CALTRANS-5
Comment noted. This comment recommends that the City add Class II bike lane transition striping
through the free right turn lane on westbound East Santiago Canyon Road and northbound Cannon
Street. The comment continues to recommend adding Class II bike lane transition striping through
the right turn only lane on southbound Cannon Street. This comment does not raise any potentially
significant environmental issues.
Response to CALTRANS-6
Comment noted. This comment recommends the City consider using green paint to highlight the
bike lane transition zone and increasing signage for bicyclists at these locations. This comment does
not raise any potentially significant environmental issues.
Response to CALTRANS-7
Comment noted. The comment provides a summary of Caltrans staff contact information. No further
response is required.
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California Department of Fish and Wildlife (CDFW)
Response to CDFW-1
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment.
Response to CDFW-2
Comment noted and the City appreciates the recommendations provided by CDFW. No further
response is necessary, as the comment does not address any aspect of the current environmental
assessment.
Response to CDFW-3
As stated in RDEIR Section 2, Project Description, page 2-50, in the event that OC Parks will not
provide management and maintenance for the open space grasslands and trails, management and
maintenance would be the responsibility of the Homeowner’s Association, another public agency, or
a non-profit organization as part of the proposed project. The project proponent will provide funding
for improvements within the Santiago Creek Greenway. Responsibility for open space grasslands and
trails management and maintenance will be discussed with OC Parks as part of the ongoing process.
Where the City and OC Parks agree to consult with CDFW, the CDFW recommendations regarding
habitat management and maintenance will be appreciated. A condition of approval will be included
regarding the CDFW’s review of the habitat mitigation monitoring plan.
Response to CDFW-4
Mitigation Measure BIO-2b does not reference an off-site agency-approved mitigation bank or an in-
lieu fee program nor does the mitigation measure mention creation credits. However, Mitigation
Measures BIO-3 and BIO-4 have been revised and included in Section 4, Errata, of this Final EIR to
clarify the following:
MM BIO-3 Prior to the issuance of any grading permit in the areas designated as sensitive
riparian communities (e.g., southern cottonwood-willow riparian forest or black
willow scrub/ruderal), the project applicant shall demonstrate to the satisfaction of
the City that either of the following have been or will be accomplished:
• On- or off-site restoration or enhancement of sensitive riparian communities (e.g.,
southern cottonwood-willow riparian forest) at a ratio no less than 1:1 for
permanent impacts. Temporary impacts will be restored to pre-project conditions
(i.e., pre-project contours and revegetate with native species, where appropriate).
If any off-site restoration or enhancement is required, it will be provided at a ratio
no less than 1:1 may include the purchase of mitigation credits at an agency-
approved off-site mitigation bank or in-lieu fee program (e.g., Santa Ana
Watershed Association [SAWA] Soquel Canyon Mitigation Bank1).
• If mitigation is to occur on-site and/or off-site (i.e., not an in-lieu fee program), a
mitigation and monitoring plan shall be prepared. The plan shall focus on the
1 Soquel Canyon Mitigation Bank is the only certified, CDFW-approved mitigation bank whose service area extends to the project site.
Currently, this bank does not have the creation credits necessary to accommodate the CDFW’s policy of “no net loss” of either
wetland habitat values or acreage, nor does it sell species-specific credits (i.e., least Bell’s vireo credits).
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creation of equivalent habitats within disturbed habitat areas of the project site
and/or off-site. In addition, the plan shall provide details as to the implementation
of the plan, maintenance, and future monitoring. Mitigation for impacts to
sensitive riparian communities shall be accomplished by on- or off-site restoration
and/or enhancement (e.g., transplantation, seeding, and/or planting/staking of
sensitive riparian species; salvage/dispersal of duff and seed bank; removal of
large stands of giant reed within riparian areas).
MM BIO-4 Prior to the issuance of any grading permit for permanent impacts in the areas
designated as jurisdictional features, the project applicant shall obtain a CWA
Section 404 permit from the USACE, a CWA Section 401 permit from the Regional
Water Quality Control Board (RWQCB), and Streambed Alteration Agreement permit
under Section 1602 of the California Fish and Game Code from the CDFW. The
following would be incorporated into the permitting, subject to approval by the
regulatory agencies:
1. On- or off-site restoration or replacement of USACE/RWQCB jurisdictional waters
of the United States/waters of the State at a ratio no less than 2:1 for permanent
impacts, and for temporary impacts, restore impact area to pre-project
conditions (i.e., pre-project contours and revegetate with native species, where
appropriate). If any off-site restoration or enhancement is required, it will be
provided at a ratio no less than 2:1 may include the purchase of mitigation
credits at an agency-approved off-site mitigation bank or in-lieu fee program
(e.g., SAWASoquel Canyon Mitigation Bank).
2. On- or off-site restoration or enhancement of CDFW jurisdictional streambed and
associated riparian habitat at a ratio no less than 2:1 for permanent impacts, and
for temporary impacts, restore impact area to pre-project conditions (i.e., pre-
project contours and revegetate with native species, where appropriate). Off-site
If any off-site restoration or enhancement is required, it will be provided at a
ratio no less than 2:1 and may include the purchase of mitigation credits at an
agency-approved off-site mitigation bank or in-lieu fee program (e.g., Soquel
Canyon Mitigation Bank).
Response to CDFW-5
The presence, or absence, of Invasive shot hole borers (ISHBs) within the project site is not known.
However, if ISHB occurrences are documented within Santiago Oaks Regional Park east of the project
site, then there is a high likelihood that ISHBs will spread to trees on the project site if they are not
already present. Regardless, the potential spread of ISHBs within the project site may occur whether
or not the proposed project is implemented. The spread of these destructive beetles is an existing
problem and not an impact attributable to the proposed project.
The proposed project construction and operational activities could contribute to the potential
spread of ISHBs to other areas if on-site trees are removed from the site and are infested with ISHB.
However, the potential spread of ISHB is potentially speculative and would not be a potentially
significant impact under CEQA at a project/specific plan level nor at a cumulative level. As such, the
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following Best Management Practices (BMPs) are recommended as conditions of approval to
minimize the potential spread of ISHB, as these are likely to be standard practices by most arborists
working in infected areas:
a) education of on-site workers regarding ISHB and its spread;
b) reporting sign of ISHB infestation to the City and UC Davis’s Eskalen Lab;
c) equipment disinfection after use in known infected areas;
d) pruning infected limbs in infested areas where project activities may occur;
e) avoidance and minimization of transport of potential host tree materials;
f) chipping potential host materials to less than 1 inch and solarization, prior to either on-site
composting or delivery to a landfill;
g) solarization of cut logs; and/or
h) burning of potential host tree materials.
Response to CDFW-6
Comment noted and the CDFW assistance in mitigation of biological resource impacts is welcomed.
Responses to these comments are included in the Final EIR for the project, as requested. No further
response is necessary, as the comment does not address any aspect of the current environmental
assessment.
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Department of Toxic Substances Control (DTSC)
Response to DTSC-1
The comment provides background on the project and makes introductory remarks that do not raise
comments or questions about the environmental analysis in the RDEIR. Comment noted.
Response to DTSC-2
The comment states an opinion that there is potential for vapor intrusion of volatile organic
compounds (VOCs) and methane and total petroleum hydrocarbons (TPH) in soil. The commenter
recommends vapor intrusion abatement measures and mitigation of TPH contaminated soil. Please
see Master Response 8—Site Environmental Conditions.
Response to DTSC-3
The commenter recommends further investigation to determine the vertical and lateral extent of the
on-site contamination, including soil gas investigations. Please see Master Response 8—Site
Environmental Conditions. As indicated in that response, Mitigation Measure HAZ-2a requires a
supplemental Phase II Environmental Site Assessment (ESA) to be prepared to further delineate the
vertical and lateral extent of contamination and, for a soil risk management plan to be prepared to
address discovery of previously unknown contamination. The Phase II ESA required by Mitigation
Measure HAZ-2a would be conducted in substantial compliance with applicable guidance
documents, including but not limited to the DTSC Advisory—Active Soil Gas Investigation and Final
Guidance for Evaluation and Mitigation of Subsurface Vapor Intrusion to Indoor Air. Please refer to
Master Response 8—Site Environmental Cleanup for clarifying revisions to Mitigation Measure HAZ-
2a made in response to this comment.
Response to DTSC-4
The commenter recommends further investigation to determine whether groundwater is impacted
by TPH, methane, and VOCs, and a multi-media risk assessment to be prepared if groundwater is
impacted. Please see Master Response 8—Site Environmental Conditions. Mitigation Measure HAZ-
2b requires additional groundwater sampling under the guidance of DTSC, and abatement measures
to be implemented as required by DTSC. If further investigation necessitates a risk assessment to be
conducted, the risk assessment would be prepared in substantial compliance with applicable
guidance documents, including but not limited to the DTSC Preliminary Endangerment Assessment
Guidance Manual, Section 2.5 and Human Health Risk Assessment (HHRA) Note 4. Please refer to
Master Response 8—Site Environmental Cleanup for clarifying revisions to Mitigation Measure HAZ-
2b made in response to this comment.
Response to DTSC-5
The commenter notes that California Human Health Screening Levels (CHHSLs) are no longer used by
the DTSC.
CHHSLs were used in the Phase I ESA and the Phase II ESA prepared in 2009 and 2011, respectively.
Since that time, DTSC stopped using CHHSLs as benchmarks for screening health risks. However, as
discussed in Master Response 8—Site Environmental Conditions, a Phase II ESA will be required to
be prepared for the project site by Mitigation Measures HAZ-2a and HAZ-2b. The Phase II ESA will
use then-current DTSC recommended screening levels suggested by the commenter (DTSC HHRA
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Note 3 or Regional Screening Levels established by the United States Environmental Protection
Agency [EPA]), and will not use CHHSLs. Please refer to Master Response 8—Site Environmental
Cleanup for clarifying revisions to Mitigation Measure HAZ-2a made in response to this comment.
Response to DTSC-6
The commenter states that further investigation, risk assessment, and remediation should be
overseen by a regulatory agency with jurisdiction to oversee hazardous substance cleanup. Please
see Master Response 8—Site Environmental Conditions. As requested by the commenter, oversight
by DTSC, the City, and the Local Enforcement Agency (which is the County of Orange Environmental
Health Division) is required by Mitigation Measures HAZ-2a and HAZ-2b.
Response to DTSC-7
The commenter states an opinion that a land use covenant and long-term indoor air and/or soil gas
monitoring are required if the project cannot be remediated to achieve cleanup goals for
unrestricted land use.
The vapor barriers recommended by the commenter are already provided for in Mitigation
Measures HAZ-2a and HAZ-2b. In addition, structural controls are required by Mitigation Measure
HAZ-2a for all occupied structures within a 1,000-foot radius of the landfill to limit gas accumulation
(unless such controls are determined not to be necessary by the City in consultation with the Local
Enforcement Agency). Pursuant to Mitigation Measure HAZ-2a, if the DTSC concludes that additional
mitigation is needed after the structural controls are implemented, the applicant must work with the
DTSC and the City to jointly develop additional mitigation measures that meet residential standards.
Mitigation Measure HAZ-2a would require the project to be remediated to achieve residential
standards and therefore the project does not require a land use covenant or long-term monitoring
by DTSC.
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Local Agencies
City of Irvine (IRVINE)
Response to IRVINE-1
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment.
Response to IRVINE-2
Comment noted. The traffic volumes reflected in Figure 5-6A is correct and they appropriately and
accurately combine Figure 3-2 and Figure 5-2A.
Response to IRVINE-3
Comment noted. The clarification that the third northbound through lane on Cannon Street begins
after East Santiago Canyon Road and does not extend through Serrano Avenue will be included in
Section 4, Errata, of this Final EIR.
Response to IRVINE-4
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment.
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City of Villa Park (VILLA PARK)
Response to VILLA PARK-1
Comment noted. This correction is included in Section 4, Errata, of this Final EIR.
Response to VILLA PARK-2
Consistent with CEQA Guidelines Section 15088.5(f)(1), as noted in RDEIR Section 1, Introduction,
page 1-6, Table 1-2, RDEIR Revision Summary Table Public Agencies, provides a representative list of
sections revised stemming from specific comments received, compiled to not be repetitive in the
types of comments, and do not include minor text revisions throughout the document.
Response to VILLA PARK-3
Please refer to Master Response 9—Soil Import/Export Numbers.
Response to VILLA PARK-4
Comment noted. This clarification text will be included in Section 4, Errata, of this Final EIR.
Response to VILLA PARK-5
Please refer to Master Response 9—Soil Import/Export Numbers.
Response to VILLA PARK-6
The potential project construction schedule/period is consistently referred to as 1.5 years to 4.5
years in the RDEIR; however, out of an abundance of caution and for purposes of providing the most
conservative analysis, a shortened time frame is used in certain instances.
As stated in RDEIR Section 3.12, Noise, the following reference is made on page 3.12-20 as to the
construction schedule of the project: “Implementation of the proposed project will be primarily
dictated by economic conditions and may occur on a phased basis over a period of years. However, for
the purposes of providing a conservative, reasonable worst-case analysis in this EIR, it will be assumed
that the entire project would be developed in a single phase that takes 12 months to complete.” This
explicitly states that the project could be phased over a period of years, which is consistent with other
statements in the RDEIR that refer to a potential construction schedule of 1.5 years to 4.5 years. As the
statement indicates, a 12-month schedule was analyzed to provide a conservative, reasonable worst-
case analysis, as this shortened time frame would require the highest number of pieces of construction
equipment operating simultaneously on the project site. This scenario would provide the reasonable
worst-case loudest construction noise period. The noise analysis does not make any indication that this
is the anticipated construction schedule for the project.
As stated in RDEIR Section 2, Project Description, the “implementation of the proposed project will
be primarily dictated by economic conditions and may occur on a phased basis over a period of
years.” This explicitly states that the project could be phased over a period of years, which is
consistent with other statements in the RDEIR that refer to a potential construction schedule of 1
year to 4.5 years. The varying schedules represent scenarios for construction equipment that could
reasonably represent the worst-case scenarios for the various technical areas. For the noise analysis,
a 12-month schedule was analyzed to provide a conservative, reasonable worst-case analysis, as this
shortened time frame would require the highest number of pieces of construction equipment
operating simultaneously on the project site. The air quality analysis found significant impacts for
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both regional construction emissions and health risks during construction activities, resulting in
mitigation of fugitive dust emissions and on-site construction equipment. Minor variations in the
construction schedule during implementation of the project would not result in changes to the
findings in the RDEIR.
Response to VILLA PARK-7
In RDEIR Section 3.3, Air Quality; subsection 3.3.2, Regulatory Framework, the regulatory setting for
the federal, State, and local entities is discussed. The regulatory setting for South Coast Air Quality
Management District (SCAQMD) describes air quality regulations that are applicable to the region.
Since the City of Orange is the lead agency for the proposed project, additional regulatory
information is included at the local level. Additional details for surrounding jurisdictions are not
required, as those specific policies and zoning regulations would not be applicable to the project site.
Section 3.3, Air Quality, describes the regional analysis related to Air Quality (AQ) and greenhouse
gas (GHG) impacts that account for emissions to the City of Orange, nearby jurisdictions, and
throughout the air basin. Section 3.3 also includes a localized analysis for air quality impacts to the
nearby sensitive receptors located within 1,000 feet. This represents the zone of greatest impact
from project emissions.
In addition, Section 3.3, Air Quality, analyzed the impacts from carbon monoxide (CO) hot spots at
the intersection between Villa Park Road, East Santiago Canyon Road, and Cannon Street. The peak-
hour traffic volume at this intersection is less than 10,000, provided by the traffic study, and would
result in less than significant impacts. Therefore, the most conservative analysis is represented by
the localized air quality emissions, CO hot spot, and health risk assessment within the City of Orange.
Response to VILLA PARK-8
The commenter does not provide a complete summary of the analysis presented in the RDEIR. The
analysis in Impact AIR-4 includes an evaluation of localized emissions, CO hotspots, and health risks.
The localized significance threshold (LST) analysis uses a 4-acre disturbed area on-site during
construction based on the SCAQMD’s “Fact Sheet for Applying CalEEMod to Localized Significance
Thresholds.” The fact sheet determines the maximum number of acres disturbed per day based on
the estimated equipment usage. Therefore, although the entire project site is greater than 50 acres,
the maximum daily disturbed area is 4 acres.
As discussed in Response to Comment VILLA PARK-7, the DEIR analyzed the impacts from CO hot
spots at the intersection between Villa Park Road, East Santiago Canyon Road, and Cannon Street.
The peak-hour traffic volume at this intersection is less than 10,000, provided by the traffic study,
and would result in less than significant impacts.
The health risk assessment (HRA) discussed in Impact AIR-4 provides an evaluation of emission
concentrations and associated risks for sensitive receptors located within 1,000 feet of the project
site. The modeling used in the HRA includes emissions from both on-site construction equipment
and off-site, on-road vehicles. Receptors located in the City of Villa Park are more than 1,000 feet
away from the site and were not included in the analysis. Based on the combined emissions from
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both the on-site and off-site sources, the analysis in the DEIR represented a conservative evaluation
of impacts.
The commenter also references Health and Safety Code Section 42301.6(a) regarding notice of
hazardous air emissions. Again, receptors within 1,000 feet of the project site were evaluated for
health risks. Health and Safety Code Section 42301.6(a) notification requirements apply to permits
requested from the SCAQMD, and the SCAQMD would provide that notification for the proposed
project if necessary. As stated in Health and Safety Code Section 42301.6(a), “Prior to approving an
application for a permit to construct or modify a source which emits hazardous air emissions, which
source is located within 1,000 feet from the outer boundary of a school site, the air pollution control
officer shall prepare a public notice in which the proposed project or modification for which the
application for a permit is made is fully described.”
Response to VILLA PARK-9
As discussed in RDEIR Section 3.8, Hazards and Hazardous Materials, page 3.8-11, “Removal and
disposal of hazardous materials from the project site would be conducted by a permitted and
licensed contractor. Any handling, transporting, use, or disposal would comply with applicable laws,
policies, and programs set forth by various federal, state, and local agencies and regulations,
including the EPA, RCRA, Caltrans, and the local Hazardous Materials Program. Required compliance
with applicable hazardous material laws and regulations would ensure that construction-related
hazardous material use would not result in significant impacts.”
Response to VILLA PARK-10
Villa Park Elementary School is located approximately 1.29 miles west of the project site. As noted in
RDEIR Section 3.8, Hazards and Hazardous Materials, page 3.8-11, “Any handling, transporting, use, or
disposal would comply with applicable laws, policies, and programs set forth by various federal, state,
and local agencies and regulations, including the EPA, RCRA, Caltrans, and the local Hazardous
Materials Program. Required compliance with applicable hazardous material laws and regulations
would ensure that construction-related hazardous material use would not result in significant impacts.”
Response to VILLA PARK-11
Please see Master Response 8—Site Environmental Conditions.
Response to VILLA PARK-12
Please see Master Response 5—Wildfire Risk
Response to VILLA PARK-13
Comment noted. This is a typographical error. Exhibit 3.9-4, 100-Year Flood Hazard Areas, in RDEIR
Section 3.9, Hydrology and Water Quality, incorrectly identifies “Zone AE” as being 0.1 percent. It
should be either a percentage value of 1 percent or a ratio value of 0.01. This correction will be
included in Section 4, Errata, of this Final EIR.
RDEIR Section 3.9, Hydrology and Water Quality, page 3.9-24, Table 3.9-6, Existing and Proposed
Discharge Rates—Proposed Storm Drainage System, illustrates the differences between the existing
runoff rates and the proposed runoff rates for both the 2-year event and the 100-year event. The 2-
year event is used for low flow water quality evaluation, impact assessment, and mitigation. The
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100-year event is used for peak flow drainage protection evaluation, impact assessment, and
mitigation. This comment applies to the 100-year peak flow event. For the 100-year event, 180.05
cubic feet per second (cfs) is the runoff rate for the existing condition and 82.72 cfs is the runoff rate
for the proposed condition. As the table indicates, this is a reduction of 97.33 cfs from the existing
condition to the proposed condition, and reflects a reduction of 54.1 percent from the existing
condition to the proposed condition. This reduction from the existing condition to the proposed
condition mitigates flood risk to properties located adjacent to Santiago Creek downstream in Villa
Park. It does not exacerbate the flood risk to properties located adjacent to Santiago Creek
downstream in Villa Park as stated by the City.
Response to VILLA PARK-14
Please refer to Master Response 1—Plan Consistency.
Response to VILLA PARK-15
Please see Master Response 7—Applicability of SMARA.
Response to VILLA PARK-16
The closest fire station to the project site is Orange Fire Station No. 8, located approximately 1.75
miles north of the project site at 5725 Carver Lane; there is also an Orange County Fire Authority Fire
Station No. 23, approximately 0.64 mile east of the project site at 5020 Santiago Canyon Road, Villa
Park, CA 92869. This clarification will be included in Section 4, Errata, of this Final EIR.
Response to VILLA PARK-17
Comment noted. Based on the City of Orange TIA Guidelines (50 peak-hour trips) and County of
Orange Congestion Management Plan (CMP) criteria (3 percent average daily traffic [ADT] increase),
Villa Park Road was not required to be analyzed. In fact, while not required, the intersection of Villa
Park Road at Hewes Street and the roadway segment of Villa Park Road west of Hewes Street were
analyzed to be conservative and no significant impacts were identified.
Response to VILLA PARK-18
Comment noted. Based on the City of Orange TIA Guidelines (50 peak-hour trips) and County of
Orange CMP criteria (3 percent ADT increase), Villa Park Road was not required to be analyzed.
While not required, the intersection of Villa Park Road at Hewes Street and the roadway segment of
Villa Park Road west of Hewes Street were analyzed to be conservative and no significant impacts
were identified.
Response to VILLA PARK-19
Comment noted. Because no facilities were required or justified to be analyzed within the City of
Villa Park, the LOS criteria for Villa Park does not need to be included in the TIA.
Response to VILLA PARK-20
a) Comment noted. We acknowledge that the traffic volumes in Exhibit 3.16-7A are accurate,
but the term “substantial” does not imply significant.
b) Comment noted. The LOS F indication for “with Project” is an error. The correct value is LOS
C (0.724) as reflected in Table 9-2B of the Approved TIA (Linscott, Law & Greenspan [LLG]
September 13, 2018)
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c) Comment noted. We acknowledge the LOS values but the increase in LOS is less than the 1
percent (0.010) increase impact criteria and therefore not significant.
d) Comment noted. We acknowledge the LOS values but the increase in LOS is less than the 1
percent (0.010) increase impact criteria and therefore not significant.
e) Comment noted. Based on the City of Orange TIA Guidelines (50 peak-hour trips) and
County of Orange CMP criteria (3 percent ADT increase), Villa Park Road was not required to
be analyzed. However, while not required, the intersection of Villa Park Road at Hewes
Street and the roadway segment of Villa Park Road west of Hewes Street were analyzed to
be conservative and no significant impacts were identified.
Response to VILLA PARK-21
East Santiago Canyon Road is not identified as part of the 2017 Orange County Congestion
Management Program. This correction will be included in Section 4, Errata, of this Final EIR.
Response to VILLA PARK-22
Please refer to Master Response 9—Soil Import/Export Numbers.
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Irvine Water District (IRWD)
Response to IRWD-1
Comment noted. As requested, the developer shall coordinate with IRWD’s Planning and Technical
Services Division to develop a technical memorandum or Sub-Area Master Plan Addendum for this
project. This will be included as a Condition of Approval.
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Metropolitan Water District (MWD)
Response to MWD-1
Comment noted. The comment consists of introductory remarks that do not raise any questions
about the environmental analysis.
Response to MWD-2
Comment noted. The Allen McCulloch Pipeline was evaluated in Appendix K, Hydrology and Water
Quality Reports, of the RDEIR (see the Preliminary Water Quality Management Plan dated March 6,
2017; and the Preliminary Hydrology and Hydraulic Report dated March 7, 2017). The RDEIR also
discusses the Metropolitan Water District (MWD) facilities (RDEIR Section 2, Project Description,
page 2-2; and RDEIR Section 3.10, Land Use and Planning, page 3.10-2). The project would not
impact MWD’s ability to access, operate, and/or maintain existing facilities.
In order to avoid potential conflicts with MWD’s rights-of-way, the Applicant will follow established
requirements, including the submittal of design plans for any activity in the area of MWD’s pipelines
or facilities for review and approval. This will be included as a condition of approval.
The Applicant shall submit design plans for any activity in the area of MWD’s pipelines or facilities for
review and written approval. This will be included as a condition of approval. In 2013, Fuscoe
Engineering, Inc. had made such a submittal for the former Rio Santiago Project. This application had
been processed and approved by MWD in 2014. The MWD Substructure Department job number is
4057-98-007d. A copy of the MWD approval letter is attached herein and labeled 4057-98-007d.pdf.
Fuscoe Engineering, Inc. is prepared to make, submit, and process a replacement application to the
MWD for the new Trails at Santiago Creek Project.
Response to MWD-3
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental analysis.
Response to MWD-4
The attachments do not raise any environmental comments that require a response, therefore, they
are not reproduced in this Responses to Written Comments section, but they are included in the
record of proceedings and administrative record.
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Orange County Public Works (OCPW)
Response to OCPW-1
Comment noted. The comment consists of introductory remarks that do not raise any questions
about the environmental analysis.
Response to OCPW-2
Comment noted. The City shall coordinate with the County in the review and approval process of the
mitigation design for the intersection of Orange Park Boulevard at East Santiago Canyon Road. This
will be included as a condition of approval.
Response to OCPW-3
This comment recommends that prior to project entitlements, the developer execute a pre-
development Memorandum of Understanding (MOU) with the County or other intended owner of
open space, grasslands, trails, creeks, and/or other recreational amenities that addresses design
requirement and standards, long-term maintenance, habitat protection, and establishment of an
endowment or other funding mechanism for the management of such facilities in perpetuity.
This comment is noted. Please see Master Response Master Response 6—Stewardship of Open
Space. Furthermore, in response to the County’s request for an MOU, the City will include the
execution of a pre-development MOU with the County as a condition of approval, prior to the
approval of a tentative tract map, if the open space is truly dedicated to the County.
Response to OCPW-4
Along the north side of East Santiago Canyon Road, in addition to the existing Class II bike lane, an
off-street recreational trail will extend along the entire length of the project site. The project
Applicant proposes on-site trails with points of connection at the project boundary with the intent
that off-site extensions and connectivity to other trail systems will be by other entities or agencies.
On-site trails will be designed per the City of Orange Recreational Trails Master Plan (RTMP) (April
27, 1993). The implementation of the Specific Plan and associated project will also fund a maximum
of $4,100,000.00 in landscape, trails, and other improvements for the Santiago Creek Greenway and
Open Space. Please refer to page 4-26 of the Specific Plan (Appendix Q, Trails at Santiago Specific
Plan), particularly the last paragraph that describes the final trail alignment process and entities to
be involved.
Response to OCPW-5
Comment noted. At the project’s eastern boundary, Trail C continues off-site to the Santiago Oaks
Regional Park via the Santiago Creek open space corridor. The project Applicant proposes on-site
trails with points of connection at the project boundary with the intent that off-site extensions and
connectivity to other trail systems will be by other entities or agencies. On-site trails will be designed
per the City of Orange RTMP (April 27, 1993). The implementation of the Specific Plan and
associated project will also fund a maximum of $4,100,000.00 in landscape, trails, and other
improvements for the Santiago Creek Greenway and Open Space. Please refer to page 4-26 of the
Specific Plan (Appendix Q, Trails at Santiago Specific Plan), particularly the last paragraph that
describes the final trail alignment process and entities to be involved.
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Response to OCPW-6
Comment noted. In RDEIR Section 3.9, Hydrology and Water Quality, the RDEIR discusses the
potential effects of the project on storm drainage in RDEIR Section 3.9, Hydrology and Water Quality.
Specifically, Impact HYD-3, on page 3.9-23, evaluates the downstream effects of the project.
Table 3.9-6 summarizes existing and proposed discharge rates into Santiago Creek from the main
drainage area for the 2-year and 100-year storm events. As shown in the table, the project would
achieve a net reduction of stormwater discharge during storm events.
Table 3.9-6: Existing and Proposed Discharge Rates—Proposed Storm Drainage System
Storm Event Drainage Area
Cubic Feet/Second
Change Existing Proposed Difference
2-Year
72.58 acres
44.46 28.72 -15.74 -35.4%
100-Year 180.05 82.72 -97.33 -54.1%
Source: Fuscoe Engineering 2016.
Table 3.9-7 summarizes existing and proposed discharge rates into the Handy Creek storm drain for
the 2-year and 100-year storm events. As shown in the table, the project would achieve no net
increase discharge of stormwater into the Handy Creek storm drain during storm events. Peak flows
to Handy Creek channel through will not be altered through implementation of the project and will
not pose any additional hazards or risks to downstream residents. This drainage area is not proposed
to receive any increases in impervious area as it is designated as open space. Refer to the Hydrology
Report in RDEIR Appendix K, Hydrology and Water Quality Reports, for full calculations compiled via
AES Hydrology Software and HydroCAD Detention Modeling Software.
Table 3.9-7: Existing and Proposed Discharge Rates—Handy Creek Storm Drainage
Storm Event Drainage Area
Cubic Feet/Second
Change Existing Proposed Difference
2-Year
1.46 acres
1.41 1.41 — —
100-Year 4.43 4.43 — —
Source: Fuscoe Engineering 2016.
This serves to illustrate that the proposed storm drainage system would slow, reduce, and meter the
volume of runoff leaving the project site and ensure that downstream storm drainage facilities are
not inundated with project-related stormwater. Impacts would be less than significant. Refer to
Appendices 2, 3, and 5 within the Hydrology Report in RDEIR Appendix K, Hydrology and Water
Quality Reports, for calculations compiled via AES Hydrology Software and HydroCAD Detention
Modeling Software.
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Finally, the proposed project would not alter the two unnamed storm drains located in the
northwestern portion of the project site. Flow patterns in the project site’s post-development
conditions will continue to be conveyed in a similar manner to existing conditions. Refer to the
existing and proposed hydrology maps in Appendix 7 of the Hydrology Report in RDEIR Appendix K,
Hydrology and Water Quality Reports, for further information on existing and proposed runoff
patterns.
As part of the review of final grading and building plans, the Applicant and City will coordinate with
OC Public Works and OC Flood and will provide additional information, if needed, to confirm the
adequacy of existing facilities to accept stormwater and urban runoff flows. This will be included as a
condition of approval.
Response to OCPW-7
As summarized in RDEIR Section 3.4, Biological Resources; subsection 3.4.6, Project Impacts and
Mitigation Measures, on page 3.4-50, four sensitive communities that are considered high priority
for conservation by the CDFW List of California Terrestrial Natural Communities, include southern
cottonwood-willow riparian forest (12.79 acres), blue elderberry scrub (0.13 acre), California
brittlebush scrub (0.26 acre), and yerba santa scrub (0.31 acre). There will be no impacts to blue
elderberry scrub, California brittlebush scrub, and yerba santa scrub, which will be avoided by the
project. The proposed project will impact southern cottonwood-willow riparian forest, including 0.10
acre on-site permanent impacts within the limits of grading, and 0.04 acre permanent, and 0.05 acre
temporary impacts due to installation of an on-site storm drain outlet.
In addition, the proposed project would result in impacts to approximately 170 linear feet (50 linear
feet permanent, ; 120 linear feet temporary) and 0.01 acre (0.01 acre permanent, and less than 0.01
acre temporary) of United States Army Corp of Engineers (USACE)/RWQCB “waters of the United
States”/”waters of the State,” of which less than 0.01 acre is wetland (permanent), as well as 0.07
acre (0.03 acre permanent, and; 0.04 acre temporary) of CDFW jurisdictional streambed and
associated riparian habitat, as discussed in RDEIR Section 3.4, Biological Resources, page 3.4-51.
Response to OCPW-8
Please refer to Master Response Master Response 6—Stewardship of Open Space. Furthermore,
refer to pages 4-12 to 4-13 of the October 30, 2018 Specific Plan (RDEIR Appendix Q, Trails at
Santiago Specific Plan) for a description of open space environs and intended restoration. Refer to
pages 6-13 to through 6-15 for a description of the open space enhancement. Refer to Table 6.1:
Plant Material Palette for plant species.
Response to OCPW-9
Trail E is located in Planning Area B south of and above Santiago Creek and north of Planning Area C.
To the west it terminates at the project boundary with the intent that it connects off-site to the trail
along Cannon Street and to the Santiago Creek Trail west of Cannon Street by others. Coordination
efforts will be needed to allow for access from the project site to Cannon Street across the northerly
portion of the vacant county-owned property to the west. To the east, Trail E connects with on-site
Trail B, which provides connectivity to Trail C and Mabury Avenue to the north, and Trail A and East
Santiago Canyon Road to the south. Please refer to page 4-29 of the October 30, 2018 Specific Plan
City of Orange—Trails at Santiago Creek Specific Plan
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(RDEIR Appendix Q, Trails at Santiago Specific Plan), as well as RDEIR Section 2, Project Description,
Exhibit 2-11, Preliminary Greenway, Open Space and Trails Plan.
Response to OCPW-10
Please refer to RDEIR Section 2, Project Description, Exhibit 2-11, Preliminary Greenway, Open Space
and Trails Plan.
Response to OCPW-11
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment.
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Orange County Transportation Authority (OCTA)
Response to OCTA-1
Comment noted. In reference to RDEIR Section 2, Project Description, page 2-51, clarification that
Trail E will be paved is added to Section 4, Errata, of this Final EIR.
Response to OCTA-2
Trail A will connect to the existing multi-purpose recreation trail to the east that is located south of
The Reserve residential neighborhood. Trail A will extend westerly along the northside of Santiago
Canyon Road to project boundary with the intent that the trail will continue off-site west by others.
Please refer to RDEIR Section 2, Project Description, Exhibit 2-11, Preliminary Greenway, Open Space
and Trails Plan.
Response to OCTA-3
Comment noted. In reference to Section 2, Project Description, page 2-56, clarification that
sidewalks are not provided on Cannon Street south of the bridge over Santiago Creek is added to
Section 4, Errata, of this Final EIR.
Response to OCTA-4
Comment noted. In reference to RDEIR Section 2, Project Description, Exhibit 2-12b, Proposed
Circulation, clarification that Trail E will be paved is added to Section 4, Errata, of this Final EIR.
Response to OCTA-5
Comment noted. In reference to RDEIR Section 2, Project Description, page 2-61, clarification that
the Santiago Creek Bike Trail will be unpaved and does not serve all-weather conditions is added to
Section 4, Errata, of this Final EIR.
Response to OCTA-6
Comment noted. In reference to RDEIR Section 3.16, Transportation, page 3.16-16, clarification to
identify the existing trailhead at the northerly terminus of the Santiago Creek Trail where Santiago
Creek crosses under Cannon Street is added to Section 4, Errata, of this Final EIR.
Response to OCTA-7
Comment noted. In reference to RDEIR Section 3.16, Transportation, page 3.16-122, clarification that
the paved Class I facility will be consistent with local and regional planning policy documents is
added to Section 4, Errata, of this Final EIR.
Response to OCTA-8
The comment appears to support the existing Class II bikeways being maintained with the proposed
widening improvements along East Santiago Canyon Road and Cannon Street in the project vicinity.
All bikeways will comply with local and regional master planning policy documents. The comment is
noted and no further response is required.
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Orange County Waste and Recycling (OCWR)
Response to OCWR-1
The commenter notes that OC Waste & Recycling is responsible for ongoing maintenance and
monitoring of the Villa Park Landfill. The commenter describes the components of the landfill and
the agencies that monitor the Landfill.
Comment noted. The comment does not raise any comments or questions about the environmental
analysis.
Response to OCWR-2
The commenter states an opinion that the project proposes residences east of the former Landfill,
which has the potential for public health and safety impacts. The commenter recommends that all
occupied structures located within 1,000 feet of the Landfill include structural controls to limit gas
accumulation.
Please refer to Master Response 8—Site Environmental Conditions. Mitigation Measure HAZ-2a
requires a Phase II Environmental Site Assessment (ESA) to be conducted and for abatement
measures to limit gas accumulation to be incorporated into the project building plans. Structural
systems to prevent gas-related hazards will be required to be reviewed by the City of Orange, DTSC,
or the Local Enforcement Agency (which is the County of Orange Environmental Health Division). As
requested by the commenter, structural controls have been added to Mitigation Measure HAZ-2a to
clarify the requirements of Mitigation Measure HAZ-2a. Please refer to Master Response 8—Site
Environmental Conditions for clarifying revisions to Mitigation Measure HAZ-2a made in response to
this comment.
Response to OCWR-3
The commenter states that the 2009 and 2011 ESAs were prepared for the Rio Santiago Specific Plan
project on the same site. The commenter requests that the project prepare a new Environmental
Site Assessment based on the proximity of the Landfill’s boundary to the proposed residences.
Please refer to Master Response 8—Site Environmental Conditions. Mitigation Measure HAZ-2a
requires a supplemental Phase II ESA to be prepared in substantial compliance with applicable
guidance documents, including but not limited to the DTSC Advisory—Active Soil Gas Investigation
and Final Guidance for Evaluation and Mitigation of Subsurface Vapor Intrusion to Indoor Air. The
Phase II ESA will use current DTSC HHRA Note 3 and Regional Screening Levels established by the
EPA. In addition, all occupied structures within a 1,000-foot radius of the Landfill will include
structural controls to limit the potential for landfill gas accumulation. Following implementation of
structural controls, if DTSC concludes that additional mitigation is needed, the applicant will work
with DTSC and the City to jointly develop additional mitigation measures that meet residential
standards.
Responding to the comment that the existing ESAs are not adequate and cannot be used for this
project, the current ESAs are adequate to provide information on the project site and environmental
issues present on the site. That type of analysis is not dependent on changes in the proposed
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project, as the purpose of the ESA is to characterize the underlying site. Also, further analysis will be
required pursuant to Mitigation Measures HAZ-2a and HAZ-2b, and the further site assessments
required by those measures will include the criteria requested by the commenter.
Under CEQA case law, it is appropriate for an initial level of site characterization and analysis to be
done as part of an EIR process, with follow-up work included as part of a mitigation measure. For
example, in City of Maywood v. Los Angeles Unified School District (2012) 208 Cal.App.4th 262, the
Court upheld an EIR for a new school site against claims that the EIR did not adequately evaluate
environmental hazards. The EIR relied on some preliminary environmental studies, including a
Preliminary Endangerment Assessment (as required for school sites by statute). The EIR also
committed to the later preparation of a supplemental site investigation, a remedial action work plan,
and cleanup according to that work plan. Commenters on the EIR claimed that further analysis was
required prior to certification of the EIR, and that the school district could not defer a more specific
study until after the new school project was approved. As here, the EIR included a mitigation
measure calling for further study and cleanup. The court held that the EIR analysis was adequate. A
similar result was reached in the decision in Citizens for a Sustainable Treasure Island v. City &
County of San Francisco (2014) 227 Cal.App.4th 1036, where the Court upheld a general analysis of
environmental hazards with follow-up mitigation.
Response to OCWR-4
The commenter states an opinion that the less than significant conclusion in Section 3.8, Hazards
and Hazardous Materials, cannot be substantiated because there is an identified possibility of
methane infiltrating future site buildings.
Please refer to Response OCWR-3 and Master Response 8—Site Environmental Conditions.
Mitigation Measure HAZ-2a requires a supplemental Phase II ESA to be prepared and for vapor
intrusion abatement measures for methane to be reviewed by the City, Local Enforcement Agency
(which is the County of Orange Environmental Health Division), or DTSC prior to issuance of building
permits for dwelling units where vapor intrusion has the potential to occur. The Phase II ESA will use
current DTSC HHRA Note 3 and Regional Screening Levels established by the EPA. Mitigation
Measure HAZ-2a requires that all occupied structures within a 1,000-foot radius of the landfill will
include the following structural controls to limit the potential for landfill gas accumulation: (1) a
geomembrane between the slab and the subgrade; (2) a permeable layer with venting pipe between
the geomembrane; and (3) automatic methane gas sensors with audible alarms in the permeable
layer and inside the structures. This measure is an appropriate basis for the conclusion that impacts
will be mitigated to a less than significant level.
Response to OCWR-5
The commenter states an opinion that the term “situated strategically” in Mitigation Measure HAZ-
2a is unclear. The commenter requests that the applicant provide an exhibit and narrative indicating
placement of proposed occupied structures bordering landfill; identification of the homes that will
include health and safety features; specific structural controls that will be implemented; and which
homes will receive structural controls.
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Please refer to Master Response 8—Site Environmental Conditions. The term “situated strategically”
has been clarified to include “using supplemental Phase II ESA data and DTSC’s review thereof, so
that structures will not interfere with future remediation of any potential landfill gas migration; this
shall be demonstrated in connection with approval of any tentative maps for the project.”
The Villa Park Landfill location is shown in RDEIR Section 2, Project Description, Exhibit 2-2, and the
proposed area of Low Density Residential homes is shown on Exhibit 2-6. As required by Mitigation
Measure HAZ-2a, a supplemental Phase II ESA would be completed and all occupied structures
within a 1,000-foot radius of the Landfill will include structural controls to limit the potential for
landfill gas accumulation and to ensure that homes would not be affected by hazardous conditions
resulting from the Villa Park Landfill. If DTSC concludes that additional mitigation is needed, the
applicant will work with the DTSC and the City to jointly develop additional mitigation measures that
meet residential standards. It is appropriate under CEQA for mitigation measures to specify future
performance standards that must be met to mitigate an impact where, as here, future studies are
required to determine specific measures that will be implemented to reduce the effects of an
impact. (See, e.g., POET, LLC v. State Air Resources Bd. (2013) 218 Cal.App.4th 681, 735.) The specific
measures to be implemented will include identification of specific health and safety features for
specific homes based on the supplemental Phase II ESA.
Response to OCWR-6
The commenter recommends all occupied structures within 1,000 feet of the Landfill to be equipped
with structural controls to prevent landfill gas accumulation. The commenter suggests a mitigation
measure that includes structural controls for all new structures within 1,000 feet of the Landfill.
Please refer to Master Response 8—Site Environmental Conditions. Mitigation Measure HAZ-2a
requires a Phase II ESA to be conducted and for abatement measures to limit gas accumulation to be
incorporated into the project building plans. Structural systems to prevent gas-related hazards will
be required to be reviewed and approved by the City, a Local Enforcement Agency (which is the
County of Orange Environmental Health Division) or the DTSC. All occupied structures within a 1,000
foot radius of the Landfill will include the following structural controls to limit the potential for
landfill gas accumulation: (1) a geomembrane between the slab and the subgrade; (2) a permeable
layer with venting pipe between the geomembrane; and (3) automatic methane gas sensors with
audible alarms in the permeable layer and inside the structures.
Response to OCWR-7
The commenter notes that the RDEIR does not contain a surface water drainage exhibit and
recommends preparing one to indicate how surface water runoff will be controlled and conveyed so
as not to drain onto the Landfill.
The RDEIR contains a surface water drainage exhibit in RDEIR Section 3.9, Hydrology and Water
Quality, page 3.9-11, Exhibit 3.9-6, Existing Drainage Patterns. In the exhibit, the drainage boundary
is shown by a dashed red line. Flow lines are shown in blue with directional arrows. The arrows
indicate flow direction. Surface flow follows the direction of the flowlines and drains to Santiago
Creek. As shown in Exhibit 3.9-6, surface water runoff does not flow from the project site onto the
Landfill site.
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RDEIR Appendix K.1 is the Preliminary Hydrologic and Hydraulic Report by Fuscoe Engineering, Inc.,
dated March 7, 2017. Within that report, Appendix 6 is the Existing Condition Hydrology Map (In
Pocket). The map in Appendix 6 is the source document that was adapted for use as RDEIR Exhibit
3.9-6. Appendix 6 demonstrates that the surface water on the project site is controlled and conveyed
so that there are no impacts to the landfill final cover.
The RDEIR contains an exhibit for the proposed surface drainage pattern in Appendix 7 of the FEI
Preliminary Hydrologic and Hydraulic Report dated March 7, 2017. This is a map of the proposed
surface water drainage pattern for the Trails Site. In the map, numerous proposed drainage sub areas
are identified on the south side of Santiago Creek, within the proposed drainage boundary, which
roughly corresponding to the drainage boundary in Exhibit 3.9-3. Green flowlines with directional
arrows indicate the flow direction for each sub area. All surface flow will drain to Santiago Creek. The
proposed water runoff condition would not allow water to drain from the proposed site onto the
Landfill site. Appendix 7 demonstrates the project will not result in drainage from the project site
onto the Landfill property. It also demonstrates that the Trails surface water is controlled and
conveyed so that there are no impacts to the Landfill final cover.
Response to OCWR-8
The commenter requests a conceptual grading plan exhibit in order to analyze impacts to refuse
mass or impacts to the Landfill gas collection system, groundwater monitoring wells, and/or surface
water collection system.
RDEIR Section 2, Project Description, contains a site plan on page 2-53, Exhibit 2-11. Exhibit 2-11
shows the areas proposed for residential density, which would include grading. The site would be
graded to accommodate the drainage pattern identified in the “Proposed Condition Hydrology Map”
prepared by Fuscoe Engineering, Inc., which is Appendix 7 of RDEIR Appendix K.1. As shown in The
Proposed Condition Hydrology Map, the boundary that requires grading would not include the
landfill property. The ground surface on the landfill property will not be disturbed by the proposed
grading. As discussed in the Master Response 8—Site Environmental Conditions, impacts related to
the Landfill were analyzed and determined to be less than significant with mitigation. An active
landfill gas collection system at the Landfill collects and flares landfill gases. In accordance with
CRWQCB-SA Order No. R8-2013-0010, SCAQMD rule 1150.1, and the site-specific monitoring plan, a
groundwater monitoring well system and a vadose zone perimeter gas probe monitoring system is
located on the Landfill property. Vapor monitoring at the Landfill property is completed at 18 multi-
depth gas perimeter monitoring probes. The location of the monitoring points are shown in Exhibit
3.8-1, which will be included in Section 4, Errata. The perimeter vapor probes along the eastern and
northern boundaries of the Landfill, which are located adjacent to the project site, are spaced at
intervals of 300 to 650 feet. Based on the location of the County’s monitoring equipment, as shown
in Exhibit 3.8-1, it is not anticipated that the project will involve grading that will impact the landfill
gas collection system or any monitoring wells. To ensure that no monitoring wells or monitoring
probes will be affected by the project, Mitigation Measure HAZ-2c requires that the project applicant
contact the City Engineer to consult with and obtain approval from the Orange County Integrated
Waste Management Department for the relocation of any monitoring wells or probes that would be
impacted by development on the site prior to commencement of any construction that would
impact existing landfill or related gas monitoring equipment.
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Response to OCWR-9
The commenter notes that OCWR has three landfill gas monitoring probes and one groundwater
monitoring well on the project site. The commenter requests an undeveloped buffer between
houses and the Landfill and leaving existing probes and the well undisturbed.
Mitigation Measure HAZ-2c requires that prior to the start of any construction activities on the
project site that would impact existing landfill or related gas monitoring equipment, the project
applicant must contact the City Engineer to consult with and obtain approval from the Orange
County Integrated Waste Management Department if any monitoring wells or probes require
relocation. Mitigation Measure HAZ-2c would alleviate the commenter’s concern regarding existing
probes and the existing well. Exhibit 3.8-1 which is included in Section 4, Errata, shows the location
of the Villa Park Landfill’s groundwater monitoring wells and perimeter monitoring probes.
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South Coast Air Quality Management District (SCAQMD)
Response to SCAQMD-1
Comment noted. The comment provides a summary of the project description. No further response
is required.
Response to SCAQMD-2
Comment noted. The comment provides a summary of the air quality and analysis and the findings.
No further response is required.
Response to SCAQMD-3
Comment noted. The comment provides a summary of the 2016 Air Quality Management Plan
(AQMP). No further response is required.
Response to SCAQMD-4
The comment provides a summary of more detailed comments provided by SCAQMD. Detailed
responses are provided in SCAQMD-7 through SCAQMD-9.
Response to SCAQMD-5
Comment noted. Pursuant to California Resources Code Section 21092.5(a) and CEQA Guidelines
Section 15088(b), written responses to all comments have been provided and included in this Final
EIR. Furthermore, issues raised in comments have been addressed in detail giving reasons why
specific comments and suggestions are not accepted.
Response to SCAQMD-6
The comment provides a summary of SCAQMD staff contact information. Comment noted. No
further response is required.
Response to SCAQMD-7
The “commercially available” language included in the mitigation measure is consistent with
language regularly used by other lead agencies (e.g., San Francisco) and is only intended to be used
for unique or specialty equipment. Most standard equipment (e.g., tractors) used during the
construction process will be commercially available with Tier 4 Final engines. The mitigation measure
should be implementable and feasible, and, in the event that specialty equipment is required and
not available with Tier 4 Final engines, the language allows a contractor to continue with
construction activities with documentation that Tier 4 Final equipment is not available by contacting
multiple rental companies. In addition, with regard to the emission estimates in the RDEIR, the
mitigated NOX emissions shown in RDEIR Section 3.3, Air Quality, Table 3.3-17 would continue to
exceed the threshold of significance even with implementation of Mitigation Measure AQ-1g.
Therefore, a change in the modeling assumptions to include other engines (e.g., Tier 3 as suggested
in the comment) would not change the findings in the EIR.
Response to SCAQMD-8
As indicated by the commenter, feasibility means, “being capable of being accomplished within a
reasonable period of time.” The amount of soil hauling that would be required for the grading
portion of construction activities would result in substantial numbers of trucks traveling to and from
the site on a daily basis. In addition, the construction activities would likely involve different sets of
construction contractors and haul companies to complete the project. If such a measure is required,
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a list of approved trucks that meet 2010 model year standards would have to be developed prior to
those trucks coming on-site, and the contractor would have to implement multiple checkpoints to
ensure that the trucks matched that list and no other trucks came on-site. Given that the project
requires approximately 275,000 haul trips, (over 700 trips per day based on the estimated schedule)
and specific make and model of haul trucks can vary by contractor and within each contractor fleet,
such a requirement could result in substantial delays in the construction schedule. In addition, as
trucks would queue and wait to enter the site, additional idling emissions would be generated,
potentially offsetting the benefits of such a measure. As noted by the commenter, California Air
Resources Board regulations would ensure that by January 2023 that nearly all trucks will have 2010
or newer engines. In addition, interim steps in the regulation (e.g., vehicles older than 1999 will be
replaced with newer engines by 2020) and fleet turnover also ensure that vehicle emission rates will
be improved by the start of construction activities.
Response to SCAQMD-9
The proposed project is not planned to result in impacts on the landfill or monitoring equipment.
However, the Lead Agency will contact SCAQMD if a permit or other coordination is required for
project construction.
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Organizations
California Cultural Resource Preservation Alliance (CCRPA)
Response to CCRPA-1
Comment noted. Section 3.5, Cultural Resources, and Section 3.17, Tribal Cultural Resources, of the
RDEIR analyzed the potential impacts to Cultural and Tribal Cultural Resources, respectively.
Section 3.5, Cultural Resources, page 3.5-19, and Section 3.17, Tribal Cultural Resources, page 3.17-
7, of the RDEIR notes that letters were sent to three tribes in March 2017 inviting consultation with
the City in regards to this project. The City did not receive a response from any of the tribes.
Section 3.5, Cultural Resources, page 3.5-11, of the RDEIR discusses that CA-ORA-369 was
thoroughly studied in 1979 and found to yield insufficient depth, midden deposits, or other
interpretive data to warrant further investigation. Subsequently, two archaeological surveys in 1994
and 2000 failed to locate any remains of the site. The 2008 investigation also failed to locate the site;
however, given the dense vegetation, it was concluded that the site could be obscured, buried, or
otherwise concealed from view and monitoring was recommended.
Section 3.5, Cultural Resources, page 3.5-11, of the RDEIR continues to discuss that CA-ORA-1172 is
recorded immediately adjacent to the southeast corner of the property, presumably outside the
property boundary.
Response to CCRPA-2
Comment noted. Please see Response to CCRPA-1.
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Friends of Harbors, Beaches, and Parks (FHBP)
Response to FHBP-1
Comment noted. The comment consists of introductory remarks that do not raise any questions
about the environmental analysis.
Response to FHBP-2
Comment noted. Both letters will be included in the official record of proceedings for the project. As
noted in RDEIR Section 1, Introduction, page 1-1, comments submitted on the previous Draft EIR will
be part of the overall administrative record for the project; however, because the RDEIR replaces the
previous Draft EIR in its entirety, written responses will only be provided to new comments
submitted on the RDEIR during the RDEIR public comment period.
Response to FHBP-3
Please see Master Response 7—Applicability of SMARA. RDEIR Section 2, Project Description,
subsection 2.2, Project History, describes the project site’s history, including the site’s former mining
activities of Sully Miller. Mitigation measures pertaining to hazards and hazardous materials are
found in RDEIR Section 3.8, Hazards and Hazardous Materials. Mitigation Measure HAZ-2a requires
the enclosed structures to be situated strategically to allow for future remediation of any potential
landfill gas migration. As explained in RDEIR Section 3.11, Mineral Resources, subsection 3.11.6,
Project Impacts and Mitigation Measures, under Surface Mining and Reclamation Act (SMARA),
operators of surface mining operations are required to file a mining reclamation plan for post-1975
mining operations. As such, because mining operations ceased on the project site prior to 1976 (see
RDEIR Appendix M, City of Orange SMARA Memo), a mining reclamation plan under SMARA is not
required for the project site. Mitigation Measure HAZ-2b requires the Applicant to retain a qualified
hazardous materials contractor to remove all soil containing Total Petroleum Hydrocarbons in excess
of residential development standards set forth by the California Department of Toxic Substances
Control (DTSC) or other applicable regulatory agency. Furthermore, Phase I and Phase II
Environmental Site Assessments (ESAs) were prepared for the project site and included as RDEIR
Appendix J, Phase I and Phase II Environmental Site Assessments, of the RDEIR.
Response to FHBP-4
As noted in RDEIR Section 2, Project Description, page 2-2, the previously mined portions of the site
were “backfilled,” in which unsuitable materials are excavated and replaced with fill, pursuant to a
grading permit issued by the City of Orange in 2011. It was anticipated that approximately 223,000
cubic yards of material would be imported to the site during the process, including concrete, asphalt,
and rock that would be crushed on-site. Approximately 2,000 cubic yards of material was anticipated
to be excavated from the site for reuse and would be blended with the crushed import material for a
total of 225,000 cubic yards of backfill. RDEIR Section 3.11, Mineral Resources, further evaluates
mineral resource extraction activities. The technical analysis assumes the “worst case” scenario for
the project as a conservative measure in their analysis. RDEIR Section 3.8, Hazards and Hazardous
Materials, evaluates the existing hazards and hazardous materials setting and potential effects from
project implementation on the site and its surrounding area. Furthermore, please refer Master
Response 9—Soil Import/Export Numbers.
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Response to FHBP-5
Please see Master Response 4—Dam Safety and Risk of Failure.
Response to FHBP-6
Please see Master Response 5—Wildfire Risk.
Response to FHBP-7
As stated in RDEIR Section 3.10, Land Use and Planning, page 3.10-29, the precedence for allowing
residential developments in the Orange Park Acres Plan with less than 1-acre minimum lots under
clustered zoning has been established by the Orange Park Association’s previous support for
Broadmoor Homes, Leadership Housing Specific Plan (Pheasant Run), and Pacesetter Homes (The
Wilderness) projects (RDEIR Appendix D, Orange Park Acres Association Fieldstone Letter). More
specifically, in May 2003, the Orange Park Acres Board of Directors Supported the Fieldstone/Sully
Miller Project consisting of 189 8,000-square-foot lot minimum homes. Orange Park Acres Board of
Directors felt this was a good project that had gotten better with time.
Appendix L, Land Use Background, of the RDEIR provides the City Council Approval and Staff Report
for the Broadmoor Homes, Leadership Housing Specific Plan (Pheasant Run), and Pacesetter Homes
(The Wilderness).
Response to FHBP-8
Please see Master Response 1—Plan Consistency.
Response to FHBP-9
Please see Response to FHBP-7 and Master Response 1—Plan Consistency.
Response to FHBP-10
As stated in RDEIR Section 2, Project Description, page 2-50, the Santiago Creek Greenway Alliance
recommends that OC Parks maintain the open space grasslands and trails. However, in the event that
OC Parks will not provide management and maintenance for the open space grasslands and trails,
management and maintenance would be the responsibility of the Homeowner’s Association,
another public agency, or a non-profit organization, including long-term management, as part of the
proposed project. The project proponent will provide funding for improvements within the Santiago
Creek Greenway. Responsibility for open space grasslands and trails management and maintenance
will be discussed with OC Parks as part of the ongoing process.
A financing mechanism will be established for the stewardship of open space within the project,
prior to the dedication to a public agency or non-profit organization.
There is no reason for recirculating the RDEIR again for the ongoing discussions regarding the
management of the project open space areas. CEQA Guidelines (California Code of Regulations [CCR}
§ 15088.5) regarding the Recirculation of an EIR Prior to Certification states:
a) A lead agency is required to recirculate an EIR when significant new information is added to
the EIR after public notice is given of the availability of the draft EIR for public review under
Section 15087 but before certification. As used in this section, the term “information” can
include changes in the project or environmental setting as well as additional data or other
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information. New information added to an EIR is not “significant” unless the EIR is changed
in a way that deprives the public of a meaningful opportunity to comment upon a
substantial adverse environmental effect of the project or a feasible way to mitigate or
avoid such an effect (including a feasible project alternative) that the project’s proponents
have declined to implement. “Significant new information” requiring recirculation include,
for example, a disclosure showing that:
1. A new significant environmental impact would result from the project or from a new
mitigation measure proposed to be implemented.
2. A substantial increase in the severity of an environmental impact would result unless
mitigation measures are adopted that reduce the impact to a level of insignificance.
3. A feasible project alternative or mitigation measure considerably different from others
previously analyzed would clearly lessen the environmental impacts of the project, but
the project’s proponents decline to adopt it.
4. The draft EIR was so fundamentally and basically inadequate and conclusory in nature
that meaningful public review and comment were precluded. (Mountain Lion Coalition v.
Fish and Game Com. (1989) 214 Cal.App.3d 1043).
Response to FHBP-11
As stated in RDEIR Section 3.4, Biological Resources, page 3.4-15, “focused surveys for this species
were conducted by Michael Brandman Associates (MBA) in 2008, and PCR in 2010. No arroyo toads
were found on-site. Because of the negative results of focused surveys, and lack of suitable habitat
for this species on-site, this species is not expected to occur within the project site. Therefore,
surveys were not repeated after 2010.” Surveys were not repeated beyond 2010 due to lack of
suitable habitat for this species on-site as determined by a qualified biologist experienced in habitat
assessments and focused surveys for this species, and the qualified biologist determined that this
species is not expected to occur within the project site not only from the prior negative results of
focused surveys, but also the lack of suitable habitat for this species on-site. The species has not
been observed in Santiago Canyon since 1974. Based on available evidence, the conclusion of less
than significant impacts to arroyo toad is supported.
Response to FHBP-12
The landscaping and fuel modification setback area is not the proposed mitigation for potential
impacts to special-status wildlife species (e.g., least Bell’s vireo and willow flycatcher) but is a feature of
the project design to provide an interface between the wildlands and the urban development. For least
Bell’s vireo, as stated in Section 3.4, Biological Resources, subsection 3.4.6, pages 3.4-40 through 3.4-
43, of the RDEIR, “any potential impacts to the least Bell’s vireo would be considered potentially
significant. Mitigation Measures BIO-2a through BIO-2c are proposed to reduce impacts to a less than
significant level.” Extensive mitigation measures to offset impacts and protect least Bell’s vireo are
detailed in Mitigation Measures BIO-2a through BIO-2c on pages 3.4-45 through 3.4-47.
For willow flycatcher, as stated in Section 3.4, Biological Resources, subsection 3.4.6, page 3.4-44, of
the RDEIR, “although the black willow scrub/ruderal habitat will be permanently removed, this
isolated stand of willows provides only a small, limited amount of foraging habitat for this species.
The riparian habitat within Santiago Creek that will be avoided by the proposed project will still be
available to provide a greater area of contiguous habitat for foraging opportunities.” There is no
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record of willow flycatcher nesting in this riparian habitat. Therefore, “impacts to potential willow
flycatcher foraging habitat are not expected to threaten regional populations of this species and
would be considered less than significant, and no mitigation measures would be required.”
Response to FHBP-13
Comment noted. Please refer to Master Response 3—Analysis of Alternatives.
Response to FHBP-14
Comment noted. Please refer to Master Response 3—Analysis of Alternatives.
Response to FHBP-15
Comment noted. The comment consists of conclusory remarks.
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Respect Orange (RESPECT)
Response to RESPECT-1
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. Commenter does not elaborate further on why the RDEIR
fails to meet the requirements of CEQA with regard to project description, environmental impacts,
and land use conflict; therefore, a more detailed response is not possible nor warranted under CEQA
Guidelines.
Response to RESPECT-2
The RDEIR complies with CEQA in every respect, including its analysis of environmental impacts.
Commenter does not elaborate further on why the RDEIR fails to meet the requirements of CEQA;
therefore, a more detailed response is not possible nor warranted under CEQA Guidelines.
Response to RESPECT-3
The RDEIR analyzes the project’s consistency with applicable land use plans adopted for the purpose
of avoiding or mitigating environmental effects pursuant to CEQA Appendix G threshold, under
Impact LUP-1 and Impact LUP-2 in RDEIR Section 3.10, Land Use and Planning, pages 3.10-11 to
3.10-30. Table 3.10-2, General Plan Consistency Analysis, in particular, analyzes the project’s
consistency with General Plan Land Use policies. Table 3.10-4, OPA Plan Consistency Analysis,
analyzes the project’s consistency with Orange Park Acres Plan objectives and policies. In all cases,
the RDEIR substantiates that the project is consistent with General Plan policies and other applicable
land use plans that have been adopted for the purpose of avoiding or mitigating an environmental
effect. The commenter does not elaborate further on why the RDEIR conflicts with the fundamental
policies of the Orange General Plan and Orange Park Acres Plan; therefore, a more detailed response
is not possible nor warranted under CEQA Guidelines.
Response to RESPECT-4
As stated in RDEIR Section 3.8, Hazards and Hazardous Materials, the project is not anticipated to
create a significant hazard to the public or environment through the routine transport, use, or
disposal of hazardous materials. Although a limited amount of cleaning supplies and other
potentially hazardous fluids may be stored on-site during construction and operation, they are not
anticipated to be of sufficient quantity to pose a significant hazard to the public or environment.
Additionally, the project would comply with all applicable laws regarding the use, storage, and
disposal of hazardous materials, including provision of spill prevention kits in accordance with
California Occupational Health and Safety Administration (Cal/OSHA) standards.
Response to RESPECT-5
Please refer to Master Response 9—Soil Import/Export Numbers.
Response to RESPECT-6
A City Attorney memo is included in RDEIR Appendix M, City of Orange SMARA Memo, with regard
to SMARA.
Response to RESPECT-7
Commenter does not elaborate on why the RDEIR does not effectively evaluate impacts related to
public health and safety, traffic, air quality, noise, hydrology, hazards or climate change. Impacts
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related to air quality are discussed in RDEIR Section 3.3, Air Quality. Impacts related to Hazards are
discussed in RDEIR Section 3.8, Hazards and Hazardous Materials. Impacts related to Hydrology are
discussed in RDEIR Section 3.9, Hydrology and Water Quality. Impacts related to Noise are discussed
in RDEIR Section 3.12, Noise. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Climate change, by nature, is a cumulative impact. Potential impacts of
climate change within California are discussed in RDEIR Section 3.3, Air Quality, pages 3.3-1 to 3.3-3.
Response to RESPECT-8
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment.
Response to RESPECT-9
Comment noted. Impacts related to zoning are discussed in RDEIR Section 3.10, Land Use and
Planning. Commenter does not elaborate further on why the project would violate State planning
and zoning laws if it were approved; therefore, a more detailed response is not possible nor
warranted under CEQA Guidelines.
Response to RESPECT-10
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment.
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Santiago Creek Greenway Alliance (SCGA)
Response to SCGA-1
Comment noted.
Response to SCGA-2
The comment appears to support the project’s trail system and open space allocation. The comment
is noted and no further response is required.
Response to SCGA-3
Comment noted. Any trails west of the project site and west of Cannon Street will be implemented
by others. Trail E, whose alignment is comparable to the trail depicted in the 2018 Santiago Creek
Vision Plan, page 33, Figure 44, would be the trail that would connect to the Santiago Creek Trail
West of the site and of Cannon Street. Furthermore, please refer to Master Response 6—
Stewardship of Open Space.
Response to SCGA-4
A Preliminary Greenway, Open Space, and Trails Plan is shown in RDEIR Section 2, Project
Description, Exhibit 2-11. A detailed landscape cost plan is included in RDEIR Appendix Q, Trails at
Santiago Specific Plan. The Applicant is creating a funding source to restore and improve the open
space and greenway within the project site. On-site trails will be designed per the City of Orange
RTMP dated April 27, 1993. The implementation of the Specific Plan and associated project will also
fund a maximum of $4,100,000.00 in landscape, trails, and other improvements for the Santiago
Creek Greenway and Open Space. Furthermore, please refer to Master Response 6—Stewardship of
Open Space.
Response to SCGA-5
Comment noted. Please refer to Master Response 6—Stewardship of Open Space.
Response to SCGA-6
Comment noted. OC Parks, another public agency, or a non-profit organization will be the
permanent steward of the open space within the project. A financing district mechanism will be
established for the funding.
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396 HAYES STREET, SAN FRANCISCO, CA 94102
T: (415) 552-7272 F: (415) 552-5816
www.smwlaw.com
December 28, 2018
Via E-Mail and U.S. Mail
Robert Garcia, Senior Planner
City of Orange Community Development Department
300 East Chapman Avenue
Orange, CA 92866
rgarcia@cityoforange.org
Re: Recirculated Draft Environmental Impact Report for the Trails at
Santiago Creek Project
Dear Mr. Garcia:
On behalf of the Orange Park Association (OPA), we have reviewed the
Recirculated Draft Environmental Impact Report (RDEIR) for the Trails at Santiago
Creek Project (Project). We submit this letter to state our position that the RDEIR fails to
meet the requirements of the California Environmental Quality Act (CEQA), Public
Resources Code § 21000 et seq., and the CEQA Guidelines, California Code of
Regulations, title 14, § 15000 et seq. (Guidelines). Like all concerned members of the
public, OPA relies on the environmental document required by CEQA for an honest and
thorough assessment of the environmental impacts of a project such as this. The RDEIR’s
failure to provide that assessment undermines CEQA’s core purpose.
The EIR is “the heart of CEQA.” Laurel Heights Improvement Assn. v. Regents of
University of California (1988) 47 Cal.3d 376, 392. It “is an environmental ‘alarm bell’
whose purpose it is to alert the public and its responsible officials to environmental
changes before they have reached ecological points of no return. The EIR is also intended
‘to demonstrate to an apprehensive citizenry that the agency has, in fact, analyzed and
considered the ecological implications of its action.’ Because the EIR must be certified or
rejected by public officials, it is a document of accountability.” Id. (citations omitted).
After carefully reviewing the RDEIR for the proposed Project, we have concluded
that it fails in numerous respects to comply with the requirements of CEQA. As described
below, the RDEIR violates this statute because it fails to: (1) provide a legally adequate
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description of the Project; (2) analyze the significant environmental impacts of the
Project or propose adequate mitigation measures to address those impacts; or (3)
undertake a legally sufficient study of alternatives to the Project.
To comply with CEQA and to ensure that the public as well as the City’s
decisionmakers have adequate information to consider the effects of the proposed Project,
the City must again prepare and recirculate a revised draft EIR that properly describes the
Project, analyzes its impacts, and considers meaningful alternatives and mitigation
measures that would help ameliorate those impacts.
The proposed Project also demonstrates a disturbing disregard for the City of
Orange General Plan (General Plan) and the Orange Park Acres Specific Plan (OPA
Plan). For decades, both the General Plan and the OPA Plan have called for open space
and recreational uses on the Project site—and the City has long recognized that
development proposals on the Project site are governed by the OPA Plan. If approved at
the intensity and density anticipated by the Project, the City would be reneging on its
promise to provide for balanced growth that preserves the integrity of the Santiago Creek
corridor and the unique rural character of this area.
In addition, the Project conflicts with fundamental policies of the General Plan and
the OPA Plan, thereby violating the California Planning and Zoning Law, Gov. Code §
65000 et seq. And because these conflicts result in significant environmental impacts, the
City’s failure to identify them in the EIR violates CEQA as well. Therefore, the City may
not legally approve the Project or certify the EIR.
I. THE RDEIR VIOLATES THE CALIFORNIA ENVIRONMENTAL
QUALITY ACT.
A. The RDEIR’s Flawed Project Description Does Not Permit Meaningful
Public Review of the Project.
For an environmental document to adequately evaluate the environmental impacts
of a project, it must first provide a comprehensive description of the project itself. This
description must be accurate and sufficiently detailed to permit informed decisionmaking.
See Guidelines § 15124. Indeed, “[a]n accurate, stable and finite project description is the
sine qua non of an informative and legally sufficient EIR.” San Joaquin Raptor/Wildlife
Rescue Center v. County of Stanislaus (1994) 27 Cal.App.4th 713, 730, quoting County
of Inyo v. City of Los Angeles (1977) 71 Cal.App.3d 185, 193. As a result, courts have
found that, even if an EIR is adequate in all other respects, the use of a “truncated project
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concept” violates CEQA and requires the conclusion that the lead agency did not proceed
in a manner required by law. San Joaquin Raptor, 27 Cal.App.4th at 730. “An accurate
project description is necessary for an intelligent evaluation of the potential
environmental effects of a proposed activity.” Id.
Here, the RDEIR’s Project Description fails to meet CEQA’s clear mandate
because it lacks fundamental information about the Project’s implementation. Perhaps
most concerning, because the City never required that a reclamation plan be prepared for
the site’s aggregate mining operations, it is not possible to identify the scope of
remediation that would be necessary to develop the Project site. Indeed, the document
raises more questions than it answers. For example, the RDEIR Project Description
implies that backfilling (the excavation of unsuitable material associated with the
previously mined portions of the site and replacement with fill) already occurred pursuant
to a prior grading permit. RDEIR at 2-2. Yet, according to the RDEIR’s technical
appendix, grading permits will be requested from the City to complete the backfilling of
the previously mined portions of the project site.” RDEIR Appendix I (Geotechnical) at
pdf page 9. The revised EIR must disclose the precise status of the backfilling that has
already occurred on the Project site pursuant to Grading Permit No. 2047 and the scope
of the additional backfilling needed.
The RDEIR also provides inconsistent information about the amount of clean soils
that would have to be imported, and the amount of additional mine waste that would need
to be exported in order to develop the proposed Project. The RDEIR Project Description
states that the Project will require the import of 877,000 cy of clean materials and the
export of about 500,000 cy of silty soils. RDEIR at 2-62; 3.3-34. The appendix included
in the RDEIR, however, identifies import/export figures that are substantially greater than
that disclosed in the main text of the RDEIR. Appendix I (Geotechnical Investigation)
identifies a total to 3,348,200 cy to be over excavated (2,248,200 cy will be exported and
1,100,000 cy will be imported). Appendix I, pdf page 9. The revised EIR must reconcile
the import/export figures presented in the RDEIR with those identified in Appendix I. It
is particularly troubling that the RDEIR relies on grading details prepared for an entirely
different project. Specifically, Appendix I was prepared in connection with the Rio
Santiago Specific Plan, not the Santiago Trails Project. See Appendix I at 4. The failure
to provide accurate details relating to the site’s remediation creates all sorts of analytical
problems, including making it impossible to verify the accuracy of the RDEIR’s analysis
of environmental impacts including traffic, air quality, health risk, water quality,
greenhouse gas emissions, and noise.
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Moreover, because the Project Description provides such scant information, it is
entirely unclear what actions must occur to ensure that the site can be made safe for
human occupation. For example, the document mentions, almost in passing, that the
mined portions of the site were used for residue silt deposition (otherwise known as silt
ponds). RDEIR at 3.8-5. According to the Environmental Site Assessments (RDEIR
Appendix J), “there is a high probability that [the site] contains a recognized
environmental condition(s) relative to hazardous materials.” RDEIR Appendix J – Phases
1 and 2 Site Assessments (Site Assessments) at pdf page 15. Moreover, certain of the silt
ponds may contain hazardous compounds, including, “asbestos-containing material” (Site
Assessments at pdf page 1011,) yet the Project Description does not even mention these
alarming facts.
Nor does the Project Description disclose that past mining operations and the
neighboring landfill have resulted in the potential for (1) vapor intrusion of
trichloroethylene (TCE) and methane into future dwelling units and (2) elevated levels of
Total Petroleum Hydrocarbons in soil, or that these hazardous materials could pose a
significant human health risk, exceed explosive limits, and threaten the environment.
RDEIR at ES-30; 3.8-3; 3.8-12. Rather, one must review the EIR’s technical appendices
to learn about these potentially devastating health and safety consequences. See RDEIR
Appendix J at 17. Despite these serious potential threats, the RDEIR simply asserts that
the details about grading and earthwork will be worked out later and that the Project’s
houses will be situated strategically to avoid harming future residents. See, RDEIR at
ES-30 and 2-62; see also RDEIR at 3.6-8, stating that a “design-level Geotechnical
Investigation” will be prepared prior to the issuance of building permits, and RDEIR at
3.8-13, explaining that (unspecified) vapor intrusion abatement measures and a plan for
removing hazardous soils will be developed after the Project is approved.
Relatedly, the RDEIR mentions almost in passing that groundwater and methane
monitoring wells exist on the western portion of the Project site, but the RDEIR fails to
describe whether these wells pose any constraints on development of the site. RDEIR at
2-2. Unless and until the applicant prepares a detailed site development plan, the RDEIR
will remain unable to address and analyze the Project’s potential to create a significant
hazard to the public and the environment.
The RDEIR’s failure to provide fundamental information about remediation of the
Project site and site development details is a serious violation of the law. CEQA requires
this information be disclosed now in order to evaluate the Project’s potential to create a
significant public hazard. Guidelines §15124 (a).
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The Project Description omits other critical details relating to public safety. The
Project site is within the dam-failure inundation area of two dams. RDEIR at 4-7. The
Villa Park Dam (constructed in 1963) is located just 1.5 miles upstream of the Project site
while the Santiago Dam (completed in 1931) is located about 5.0 miles upstream. RDEIR
at 3.9-2; 3.9-10; 3.9-26. The Orange County Operational Area Emergency Action Plan
Dams/Reservoir Failure Annex indicates that it would take a dam-failure flood wave 105
minutes to reach the Project site from Villa Park Dam and 255 minutes from Santiago
Dam. Id. at 3.9-26. Despite these potential threats, the RDEIR does not bother to identify
procedures or protocols to protect residents from a flood caused by a dam failure. In light
of the dramatic failure of the Oroville dam last year, we can no longer be over confident
and complacent about antiquated dams.1 The Oroville Dam had suffered from years of
neglect and its “weak as-constructed conditions and lack of repair durability was not
recognized during numerous inspections.” Id. Here, the RDEIR does not even recognize
the potential threats; instead the RDEIR simply calls for the preparation and
implementation of a non-descript “emergency evacuation plan” after the Project is
approved. RDEIR at 3.9-27.
The Project site is also highly prone to wildfire as it is located in the wildland
urban interface, adjacent to the Santiago Oaks Regional Park, Weir Canyon, Fremont
Canyon, the Santa Ana Mountains, and the wooded Santiago Creek Corridor. RDEIR at
3.18-16. Yet, here too, the RDEIR’s Project Description does not even mention this fact.
Nor does it provide a plan that would help protect residents in the event that a wildfire
approaches the area. Rather, the RDEIR suggests that the eventual preparation of an ill-
defined “fuel modification plan” would protect the public from the threat of a wildfire. Id.
Deferring the preparation of wildfire related plans –especially when the Project is in a
severe fire hazard zone – defies common sense as well as the law.
The Project also includes the restoration of Santiago Creek yet the RDEIR
inappropriately defers until after Project approval the preparation of studies and plans for
the creek corridor’s restoration. RDEIR at 2-49; 2-50. Given the importance of Santiago
1 See Oroville Dam: Designer of failed spillway had almost no experience, The
Mercury News, January 5, 2018; available at:
https://www.mercurynews.com/2018/01/05/oroville-dam-new-report-details-what-
caused-the-near-disaster-last-year/; accessed December 17, 2018; see also Independent
Forensic Team Report Oroville Dam Spillway Incident, January 5, 2018, available at:
http://issuu.com/asdso/docs/independent_forensic_team_report_fi?e=16355058/5708761
5; accessed December 17, 2018.
8
cont.
9
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Robert Garcia, Senior Planner
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Creek, the RDEIR must address factors such as the creek’s ultimate alignment, width,
depth, bottom configuration, and creek edge treatment, including its riparian and wetland
habitats. Until these factors are taken into account, it is not possible to evaluate impacts
relating to flood control, water quality, wildlife preservation and protection, trail design,
community character, and aesthetics. Nor is it possible to identify the actual costs
associated with the creek corridor’s restoration.
In another critical omission, the RDEIR fails to provide any viable plan for the
management and maintenance of the Project’s open space lands and trails, including the
Santiago Creek corridor. Instead, it simply asserts that open space grasslands and trails
should be cared for and maintained by Orange County Parks (OC Parks) while openly
acknowledging that OC Parks has made no commitment for long-term stewardship of the
Project’s open space grasslands and trails. RDEIR at 2-50. More importantly, it is not
known whether OC Parks even agrees with the design, phasing, or the costs of the
necessary improvements not to mention the costs to reclaim the area or the standard OC
Parks would require if it were to become the landowner. No mention has been made of an
endowment that may be required for ongoing land management. The RDEIR simply
asserts that in the event that OC Parks will not provide management and maintenance for
the open space grasslands and trails, the Homeowners Association will be responsible. Id.
However, the RDEIR provides no information about this Homeowners Association let
alone any detail about how the Association would be structured to ensure that the
Project’s open space lands and trails would be maintained in perpetuity.
Nor does the DEIR contain necessary information relating to the design, phasing,
timing, and financing of Project infrastructure. In a development of this size and duration,
public and private improvements must be developed in a logical and viable sequence;
infrastructure needs to be in place prior to demand for new development. Yet the RDEIR
lacks any documentation demonstrating that these critical Project components would be
efficiently and effectively implemented. For example, the RDEIR states that the Project
will install a network of storm drainage facilities consisting of inlets, underground piping,
and basins, but it includes no description or design of these facilities. Instead, it simply
asserts that the “system will adequately serve the residential and open space
development.” RDEIR at 2-62.
These are just a few of the myriad issues that define sound land use planning and
proper environmental review. The RDEIR’s failure to address these issues is particularly
frustrating because the Project applicant, which has been planning this Project since at
least 2015, is clearly capable of providing these details. RDEIR at ES-3. Unless and until
10
cont.
11
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Robert Garcia, Senior Planner
December 28, 2018
Page 7
the applicant confronts these basic planning and design considerations, the RDEIR will
remain unable to analyze the Project’s environmental impacts.
At this point, the RDEIR’s failure to describe these critical features sends an
ominous message about the process for this large and highly controversial Project. It is
simply inconceivable that accountable decisionmakers could make a decision to approve
the Project with such incomplete information about fundamental Project components. Yet
that is effectively what this RDEIR asks the City to do. Under state law, the RDEIR
needs to be revised to include a detailed description of the Project. See County of Inyo, 71
Cal.App.3d at 193. This description must then provide the basis for new, extensive
analyses of the Project’s environmental impacts.
Finally, it is important to understand that, in addition to the obvious CEQA
implications, the Project appears not to have been planned. Even the casual observer
would wonder how the City could be this far along in the administrative process for the
development yet still lack the critical substantive land use planning details. Only when
the planning is complete will the City will be in a position to actually evaluate the
Project’s environmental effects. And only then can it make the intelligent, informed
decisions that CEQA requires.
B. The RDEIR’s Analysis of and Mitigation for the Impacts of the
Proposed Project Are Inadequate.
In every section of the RDEIR’s analysis of impacts, it is apparent that the authors
were faced with an impossible task: They must evaluate the environmental consequences
of a Project that almost does not exist. As described above, the RDEIR provides a cursory
description of the Project’s essential components. This void becomes even more clear in
the chapters purporting to examine the Project’s impacts. Time and again the RDEIR
defers analysis and mitigation because there is no way to determine how the Project will
affect the environment.
1. The RDEIR Fails to Analyze or Mitigate the Project’s Land Use
Impacts.
CEQA requires that EIRs analyze the consistency of a project with applicable
local plans, including general plans. See Napa Citizens for Honest Gov. v. Napa County
Bd. of Supervisors (2001) 91 Cal.App.4th 342, 386-87; Guidelines Appendix G, § IX (b).
Inconsistencies with a general plan or other local plan’s goals and policies that were
enacted to protect the environment are significant impacts in themselves and can also be
12
cont.
13
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Robert Garcia, Senior Planner
December 28, 2018
Page 8
evidence of other significant impacts. See id.; Pocket Protectors v. City of Sacramento
(2004) 124 Cal.App.4th 903, 929. In addition, a recently issued California Court of
Appeal opinion validates a jurisdiction’s ability to deny a project because it does not
comply with its general plan. See Kutzke v. City of San Diego (2017) 11 Cal.App.5th
1034, 1040-42. As discussed below, the DEIR’s failure to adequately analyze the
Project’s inconsistency with the Orange General Plan, the OPA Plan and the East Orange
Plan is a fatal flaw.
(a) The RDEIR Fails to Adequately Analyze the Project’s
Inconsistency with the City of Orange General Plan.
Like all general plans, the City of Orange’s General Plan represents a legally
enforceable “constitution” that governs land development. Orange Citizens for Parks and
Recreation v. City of Orange (2016) 2 Cal.5th 141, 152. It also represents the region’s
vision for its future. A cornerstone objective of the General Plan is to provide policy
guidance for Orange’s future based on innovative land use planning techniques, unifying
the developed portion of the City with East Orange, and expressing community values.
General Plan at LU-1.
The General Plan states: “The quality of the physical environment, built or natural,
plays a large part in defining Orange’s quality of life. Land use conflicts often occur
when newer developments are insensitive to the use, scale or character of existing
development and/or the surrounding natural environment.” General Plan at LU-7. To this
end, the General Plan identifies a goal and a series of policies requiring that future
development preserve the character of existing neighboring communities.
The RDEIR fails to disclose that the proposed Project would be directly at odds
with the following goal and policies:
x Goal 1.0: Meet the present and future needs of all residential and business
sectors with a diverse and balanced mix of land uses.
x Policy 1.2: Balance economic gains from new development while
preserving the character and densities of residential neighborhoods.
x Policy 1.4: Ensure that new development reflects existing design
standards, qualities, and features that are in context with nearby
development.
14
cont.
15
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Robert Garcia, Senior Planner
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Page 9
x Policy 1.6: Minimize effects of new development on the privacy and
character of surrounding neighborhoods.
x Policy 6.1: Ensure that new development is compatible with the style and
design of established structures and the surrounding environment.
Instead, the RDEIR concludes, without any evidentiary support, that the Project would be
consistent with these policies because it would be “compatible” with surrounding uses.
RDEIR at 3.10-12; 3.10-13. Specifically, the document asserts that the Project “promotes
land use compatibility with surrounding residential development by clustering the new
dwelling units on 40 acres of the site.” RDEIR at 3.10-13. This statement is incorrect and
deeply misleading. It is this very clustering—and specifically allowing more than 3
dwelling units per acre—that makes the Project incompatible with surrounding
neighborhoods.
This area of Orange is characterized by a unique rural environment with low
density development. The properties in Orange Park Acres are designated Estate Low
Density Residential, which allows only 0-2 dwelling units per acre with the majority of
OPA zoned R-1-40. General Plan at LU-25. The proposed Project’s density would far
exceed surrounding densities and thereby permanently change the character of the area.
Because the RDEIR lacks any basis to conclude the Project would be compatible with
surrounding areas, it must be revised to correct the error—and to acknowledge that the
Project’s inconsistency with the General Plan constitutes a significant environmental
impact. See Pocket Protectors, 124 Cal.App.4th at 929.
It is also important to emphasize that the General Plan currently designates more
than one-half the Project site as Resource Area. According to the General Plan, the
Resource Area designation provides that the site “[m]ay serve as a holding zone for
future uses compatible with established and planned land uses in surrounding areas.”
General Plan at LU-16. For decades, residents have relied on the City’s land use
constitution, including this statement and the designation of Sully Miller as “open space”,
when supporting development in the surrounding neighborhoods. If the City amends the
General Plan to remove this long-held designation, it would renege on its promise to
provide for balanced growth that preserves the unique rural character of this area.
The Project would also be blatantly inconsistent with Public Safety Policy 4.3
which calls for the City to ensure that hazardous materials dumpsites are cleaned prior to
the establishment of new land uses. RDEIR at 3.10-20. Hazardous conditions exist on the
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15
cont.
16
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Robert Garcia, Senior Planner
December 28, 2018
Page 10
Project site and the RDEIR lacks the required evidentiary support that these conditions
will be remedied prior to the Project’s development.
The Project would also be inconsistent with General Plan provisions relating to the
operations of the City’s roadway network. The Project would cause the intersection of
Orange Park Boulevard and Santiago Canyon Road to exceed level of service standards
in the p.m. peak hour in 2022. RDEIR at 3.16-104. The RDEIR identifies this impact as
significant and unavoidable. Id. If approved in its current form, the Project would be
inconsistent with the following City of Orange General Plan goals and policies:
x Goal 1.0 Reduce traffic congestion within the City.
x Growth Management Element Policy 1.2: “Ensure completion of
transportation improvements as agreed upon by the City and developer
prior to completion of a development project.”
x Growth Management Policy 1.5 “Require new development projects to link
issuance of building permits for the appropriate portion of the development
plan to roadway improvements required to achieve the appropriate LOS.”
The RDEIR concludes that the Project is consistent with this goal and these
policies by relying on the incorrect assumption that mitigation measures would be
adopted to bring this intersection to an acceptable level of operation. RDEIR at 3.10-15.
Because this impact was determined to be significant and unavoidable, the RDEIR must
be revised once again to disclose the Project’s clear inconsistency with this goal and these
policies.
It is also imperative that the revised EIR correctly identify the acreages of the
General Plan land use designations for the proposed Project site. The RDEIR incorrectly
identifies them as: OS-16.5 acres; RA-77.3 acres; LDR-15.4 acres. RDEIR at 2-34. The
correct acreages are: OS-26.40; RA-70.00; LDR-12.6. See City of Orange Planning
Commission Staff Report, May 5, 2003 at 3, attached as Exhibit A.
(b) The RDEIR Fails to Adequately Analyze the Project’s
Consistency with the OPA and East Orange Plans.
The City has long recognized that development proposals on the Project site must
conform to the OPA Plan and the East Orange Plan. According to the City of Orange
General Plan, the purpose of the OPA and East Orange Specific Plans is to provide
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17
cont.
18
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Robert Garcia, Senior Planner
December 28, 2018
Page 11
greater specificity than the General Plan as to the types of uses allowed in the area, the
applicable development standards (setbacks, heights, landscape, architecture, etc.), and
the required circulation and infrastructure improvements. Id. As the General Plan
explains, the OPA and East Orange Plans “are often used to ensure that multiple property
owners and developers adhere to a single common development plan.” Id. (emphasis
added).
The OPA Plan designates the Project site as “Santiago Greenbelt Plan,” while the
East Orange Plan designates the Project site as “Regional Park.” RDEIR at 3.10-4. The
RDEIR incorrectly identifies the acreages of the Project site within the OPA and East
Orange Plans. The document states that 39 and 37 acres of the Project site are within the
OPA and East Orange Plans, respectively. RDEIR at 3.10-4. However, the City has long
recognized that 56.60 acres of the Project site are within the OPA Plan boundaries while
42.50 acres of the Project site are within the East Orange Plan boundaries. In addition, the
RDEIR incorrectly identifies the amount of land that is designated as Open Space within
the Santiago Creek Channel. The RDEIR identifies 16.5 acres. RDEIR at 2-13. The
correct acreage is 26.40. These mistakes in the RDEIR’s text and mapping must be
corrected.
Rather than adhere to the land use designations set forth within the OPA and East
Orange Plans—as the City’s General Plan clearly envisions—the proposed Project would
amend both specific plans. The RDEIR alleges that amending the plans would create
vertically consistent documents that cover and include the proposed Project. RDEIR at
3.10-23. The RDEIR does not, however, disclose or analyze that, by amending the plans,
the Project would create internal inconsistencies within the OPA and East Orange Plans.
Amending these subordinate plans would allow intensive development on lands that have
long been planned for open space and park uses. In particular, both the OPA and the East
Orange Plans call for phasing out the sand and gravel extraction operations on the Project
site and creating a natural riparian area along Santiago Creek, together with proposed
greenbelts, trails, recreation and open space areas. See OPA Plan Policy 11 and East
Orange Environmental Policy 10.
As the OPA Plan explains, the “Land Use Element offers a balance in types of
residential, public-quasi-public, open space and recreational land use. This balance
provides for the retaining of the rural environment, offers economic viability and offers a
visually compatible climate for the preservation of the Orange Park Acres lifestyle. Thus,
it is believed that the goals of the community have been met.” OPA Plan at 120. In other
words, the OPA Plan provides for preservation of important open space to retain the rural
lifestyle of Orange Park Acres, while allowing for a reasonable amount of development.
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Robert Garcia, Senior Planner
December 28, 2018
Page 12
Because it would allow development on lands intended for preservation, the Project
would undermine this policy. Moreover, the intensity of the proposed development –
more than three units per acre – is entirely inconsistent with the existing rural lifestyle.
The OPA Plan sets forth myriad protective policies (see OPA Specific Plan policies
attached as Exhibit B). If approved in its current form, the Project would be inconsistent
with many of these policies.
For its part, the East Orange Plan strikes a similar balance between development
and open space. It states: “[the] central theme of the proposed General Plan is the
provision of needed residential development in the Area while simultaneously providing
for the protection of the environmental assets of the Area.” East Orange Plan at 107. The
Plan describes the “extensive open space-greenbelt network” as one of the “key features
of the Plan.” Id. Rather than protect this extensive open space network, however, the
Project would place a large subdivision in the midst of this greenbelt network, frustrating
both the Plan’s key feature and its central theme.
In sum, the proposed Project would take the heart out of an area intended for
preservation and make a mockery of the state-mandated goal of providing for orderly
development consistent with the City’s long-range planning documents: the General Plan
and the subordinate plans that help implement the General Plan. Instead of amending
these land use planning documents, which were developed and approved with community
support, the City should abide by the promises made in the plans. At the same time, the
RDEIR must be revised to disclose and analyze these land use plan inconsistencies.
2. The RDEIR Fails to Adequately Analyze or Mitigate the
Project's Impacts on Hydrology and Water Quality.
The RDEIR's evaluation of the Project’s hydrological and water quality impacts is
flawed because the document fails to support its conclusions with the necessary facts and
analysis.
(a) Water Quality Impacts.
The Project site is a part of the Santiago Creek Watershed, which is a major
tributary to the Santa Ana River. RDEIR at 5.9-2. Santiago Creek is listed on the 303(d)
List for Impaired Waterbodies for salinity/total dissolved solids/and chlorides, while the
Santa Ana River is impaired for indicator bacteria. Id. at 3.9-3. Currently, runoff from the
site either sheet-flows into Santiago Creek or flows into inlets along roadways where it
enters the Creek via a storm drain system. Id at 3.9-20. Given the Project’s potential to
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20
21
22
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Robert Garcia, Senior Planner
December 28, 2018
Page 13
substantially degrade water quality during construction and operation, one would expect
the RDEIR to provide a comprehensive analysis of these potential impacts.
Unfortunately, the impact analysis is vague, cursory and incomplete.
(i) Construction-related Water Quality Impacts
The RDEIR’s analysis of construction-related impacts raises more questions than
it answers. It acknowledges the potential for increased on-site erosion and sedimentation
impacts. RDEIR at 3.9-19. It also discloses that the Project would create the potential for
discharge of pollutants including Total Petroleum Hydrocarbons (TPH) into downstream
waterways. RDEIR at 3.8-2; 3.8-3; 3.9-20; 3.10-19. The document fails, however, to
actually evaluate the effect that this contaminated discharge could have on water quality
in these waterways. The end result is a document which is so crippled by its approach
that decisionmakers and the public are left with no real idea as to the severity and extent
of the Project’s potential to degrade water quality. See, e.g., Berkeley Keep Jets Over the
Bay Com. v. Bd. of Port Comrs. (2001) 91 Cal.App.4th 1344, 1370-71; Galante
Vineyards v. Monterey Peninsula Water Management Dist. (1997) 60 Cal.App.4th 1109,
1123; Santiago County Water Dist. v. County of Orange (1981) 118 Cal.App.3d 818, 831
(lead agency may not jump to conclusion that impacts would be significant without
disclosing how adverse the impacts would be).
In lieu of actually analyzing the Project’s effect on water quality, the RDEIR
includes a mitigation measure calling for the eventual preparation of a stormwater
pollution prevention plan (SWPPP). RDEIR at 3.9-21. The SWPPP would apparently
include best management practices (BMPs) that would purportedly prevent stormwater
from entering waterways. Id. While it may be sufficient to rely on post-approval BMPs in
certain circumstances, here the site is known to be contaminated with TPH-laden soils and
runoff from the site is known to discharge to Santiago Creek and the Santa Ana River.
Worse yet, the Hydrology and Water Quality Reports included as Appendix K to the
RDEIR fail to explain how the BMPs would protect water quality. In fact, this appendix
does not even acknowledge that contaminated soils occur on site, much less identify
performance standards that would ensure that contaminated runoff does not harm
downstream water bodies. Because the RDEIR provides no evidence that its mitigation
measures would protect adjacent water bodies from contaminated runoff, it cannot
support the conclusion that the Project’s water quality impacts would be less than
significant.
The appropriate first step to development of the Project site, of course, would be
the preparation of a reclamation plan. To date, the City has taken the position that no
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23
cont.
24
25
Robert Garcia, Senior Planner
December 28, 2018
Page 14
reclamation plan need be prepared because the Project site is not subject to Surface
Mining and Reclamation Act of 1975 (SMARA). Yet, SMARA was enacted to avoid this
exact situation. Pub. Res. Code § 2710-2796. The Project site is known to contain
hazardous and other contaminated materials and the applicant has been unwilling to
describe the specific remediation measures necessary to protect public health, property
and the environment. See RDEIR at ES-31; 3.8-2; 3.8-13. In addition to protecting the
environment and public health, a reclamation plan prepared now, prior to Project
approval, could protect the City itself because the scope of the reclamation effort will be
clearly established, and its cost fully recovered before any development occurs.
(ii) Operational Water Quality Impacts
The RDEIR fares no better in its analysis of, and mitigation for, water quality
impacts that could occur during the Project’s operational stage. The RDEIR
acknowledges that the Project would increase the amount of impervious surface coverage
on the Project site, thereby creating the potential for discharge of urban pollutants into
downstream waterways. Such pollutants would include sediment and turbidity, nutrients,
organic compounds, oxygen demanding substances, trash and debris, bacteria and
viruses, oil and grease, pesticides, and metals. RDEIR at 3.9-20. Here too, the RDEIR
looks to a mitigation measure (MM HYD-1b) that calls for BMPs to be implemented as
part of a future Water Quality Management Plan. RDEIR at 3.9-21, 3.9-22. Similar to
MM HYD-1a, though, the RDEIR fails to provide any substantive explanation as to what
these BMPs would entail or how they would be implemented. For example, MM HYD-
1b refers to technical terms such as “first flush,” a design concept that would purportedly
remove pollutants from the system before entering storm drains (ES-33, 3.9-21), but the
RDEIR provides no details about how such a system would operate or its effectiveness.
The measure also calls for the applicant to prepare and submit to the City an operations
and maintenance agreement identifying procedures to ensure that stormwater quality
control measures work properly. RDEIR at 3.9-22. Because the RDEIR does not describe
the first flush concept or the operations and maintenance agreement, the reader is forced
to read through a 300-plus page technical appendix (Appendix K: Hydrology and Water
Quality Reports) to attempt to understand whether water quality would in fact be
protected.
As an initial matter, the DEIR’s approach is a wholly unacceptable way of
presenting decisionmakers and the public with essential information, and it renders the
EIR legally inadequate. Whatever is required to be in the EIR must be in the EIR text, not
buried in an appendix. See Santa Clarita Organization for Planning the Environment v.
County of Los Angeles (2003) 106 Cal.App.4th 715, 722-23; San Joaquin Raptor, 27
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cont.
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Robert Garcia, Senior Planner
December 28, 2018
Page 15
Cal.App.4th at 727. Moreover, Appendix K itself is vague and incomplete and therefore
lacks the necessary detail about the Project’s potential impacts or the ability of the BMPs
to protect water quality. Compounding the problem, Appendix K reveals that a yet-to-be-
formed Homeowners Association (HOA) rather than the applicant will be responsible for
the inspection and maintenance of the BMPs. See Appendix K at pdf page 229. Because
the RDEIR provides no information on this HOA, including its ability to ensure that
stormwater control measures will be effectively implemented over the life of the Project,
the RDEIR lacks evidentiary support that the Project’s impacts relating to water quality
would be reduced to less than significant levels.
(b) Storm Drainage and Flooding Impacts.
The Project site is located in an area with serious hydrologic constraints, as it
contains 100-year and 500-year flood hazard areas. RDEIR at 3.9-25. The 100-year flood
hazard areas within the Project site overlap the Santiago Creek channel. Id. The 500-year
flood hazard areas overlap areas south of the creek, including areas that were previously
mined. Id. The Handy Creek storm drain, which currently accepts runoff from the Project
site, has been identified by Orange County as a deficient flood control facility that is not
capable of conveying runoff from a 100-year storm event. RDEIR at 3.9-9.
The extensive grading required for the Project will increase impervious surface
coverage thereby causing increased runoff. This runoff has the potential to create
flooding conditions for downstream neighborhoods. In light of the site’s existing
hydrologic constraints, one would expect the RDEIR to thoroughly analyze the Project’s
impact on downstream properties. RDEIR at 3.6-9. It does not. Instead, it generally
asserts that storm drain facilities will be constructed that would achieve a net reduction of
stormwater during storm events. Other than a casual mention of inlets, underground
piping, and basins, the RDEIR provides no detailed regarding these facilities, or any
documentation that they would be sufficient to protect adjacent properties.
Although the RDEIR includes a table (Table 3.9-6) showing a reduction in
discharge rates as a result of the Project (at 3.9-24), it does not provide any explanation as
to how these discharge rates were calculated. Without a description of the assumptions
and analytical methodology used to calculate discharge rates, the public and
decisionmakers cannot determine whether the RDEIR’s information is accurate. CEQA
prohibits such a cursory approach to environmental analysis. Rather, the statute requires
that an EIR be detailed and complete, reflecting a good faith effort at full disclosure.
Guidelines § 15151. As one court put it, the information regarding the project’s impacts
must be “painstakingly ferreted out.” Environmental Planning and Information Council
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cont.
27
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Robert Garcia, Senior Planner
December 28, 2018
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of Western El Dorado County v. County of El Dorado, (1982) 131 Cal.App.3d 350, 357
(finding EIR for general plan amendment inadequate that did not fully disclose the
project’s effect on the physical environment). The RDEIR here does not come close to
meeting these requirements.
As regards the Project’s storm drainage, the RDEIR touts the fact that the Project
would achieve a no net increase in discharge of stormwater into the Handy Creek storm
drain during storm events. RDEIR at 3.9-23. Yet, because the Handy Creek storm drain is
currently incapable of conveying runoff from a 100-year storm event, achieving a no net
increase in discharge is not sufficient to ensure that downstream properties will not be
impacted by the Project.
Finally, the RDEIR fails to provide information as to how the Project would
comply with National Pollutant Discharge Elimination System (NPDES) permitting
requirements. The prior DEIR referenced the need to comply with the NPDES Program
permitted under the Phase II Small Municipal Separate Storm Sewer System (MS4)
Permit (Order No. 2013- 0001 DWQ, effective July 1, 2013).2 DEIR at 3.9-16. We
commented that the DEIR did not explain how the Project would comply with these
requirements. The RDEIR now suggests that the Project would need to satisfy
requirements for a large municipal sewer system. RDEIR at 3.9-16. Yet, the RDEIR
provides no explanation for this change, leaving the reader in the dark as why the Project
needs to meet the requirements for a large, rather than a small, municipal sewer system.
Furthermore, the RDEIR, like the DEIR, fails to explain how the Project would be
expected to comply with the MS4 regulations. Given that the Project site is located within
a 100-year flood zone and the site drains to Santiago Creek, the Project will almost
certainly need to incorporate additional BMPs to satisfy MS4 requirements. The
RDEIR’s failure to provide this information renders the document inadequate on two
levels. First, it leaves the project description unacceptably incomplete because we do not
know the stormwater infrastructure needed for the Project. Second, it makes effective
analysis of impacts relating to stormwater management and associated environmental
impacts impossible. Without detailed stormwater plans—including the specific
2 Municipal Separate Storm Sewer System (MS4) permits typically describe,
among other things, water quality goals and recommend additional BMPs to protect
water quality. U.S. EPA Final MS4 General Permit Remand Rule, November 17, 2016
available at: https://www.epa.gov/sites/production/files/2016-
11/documents/final_rule_fact_sheet_508.pdf; accessed March 13, 2018.
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cont.
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documentation required by the MS4 permit—the RDEIR lacks any evidentiary support
that it will be possible to fully mitigate the Project’s stormwater impacts.
3. The RDEIR Lacks a Legally Adequate Analysis of and
Mitigation for Environmental and Public Health and Safety
Impacts Relating to Exposure to Hazardous Materials.
As discussed above, given the Project site’s historic mining operations and the
site’s proximity to a closed landfill, construction has the potential to result in significant
environmental and public safety impacts due to exposure to trichloroethylene-impacted
soil vapor, methane, and TPH-contaminated soils. RDEIR at ES-30; 3.8-3. The RDEIR
concedes that a workplan has yet to be conducted for the necessary environmental
investigations, sampling and hazardous substance remediation at the Project site. RDEIR
at ES-31; 3.8-2; 3.8-13. Because this workplan will be prepared to support hazardous
substance clean up (see RDEIR at 3.8-2), it is critical that this information be identified
now, during the EIR process, rather than after project approval.
A recent decision by the California Supreme Court confirms that information
relating to regulatory compliance must be included in the EIR, so that the document can
meet the needs of other government agencies overseeing clean-up of the site, such as the
Regional Water Quality Control Board, the California Environmental Protection Agency,
the California Division of Occupational Safety and Health, and any local regulatory
agencies. See RDEIR at 3.8-13. Banning Ranch Conservancy v. City of Newport Beach
(2017) 2 Cal. 5th 918, 936; Pub. Res. Code § 21003(a). As the CEQA Guidelines explain,
lead agencies must “[c]onsult[] with state and local responsible agencies before and
during preparation of an environmental impact report so that the document will meet the
needs of all the agencies which will use it.” Guidelines § 15006(g). The CEQA
Guidelines similarly specify that “[t]o the extent possible, the EIR process should be
combined with the existing planning, review, and project approval process used by each
public agency.” Id. § 15080. We can find no logical reason why the RDEIR does not
provide this workplan now so that the RDEIR will meet the needs of regulatory agencies.
Finally, as discussed above, it is imperative that a reclamation plan be undertaken
now, prior to Project approval.
4. The RDEIR Fails to Adequately Analyze or Mitigate the
Project’s Impacts on Biological Resources.
(a) Impacts to Wildlife Species.
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Robert Garcia, Senior Planner
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An EIR’s description of a project’s environmental setting plays a critical part in all
of the subsequent parts of the EIR because it provides “the baseline physical conditions
by which a lead agency determines whether an impact is significant.” Guidelines §
15125(a). “Knowledge of the regional setting is critical to the assessment of
environmental impacts.” Guidelines § 15125(c). Although numerous sensitive wildlife
species have been observed—or have the potential to occur—on the Project site, the
RDEIR fails to conduct the necessary focused surveys for all species potentially impacted
by the Project.
The RDEIR’s failure to conduct a survey for the arroyo toad, a Federal
Endangered Species and a Species of Special Concern, is especially concerning. The
RDEIR admits that suitable habitat for the toad exists on the Project site (RDEIR at 3.4-
15; Appendix G [Biological Resources Supporting Information] at pdf page 73) and that
no survey has been conducted since 2010. Appendix G at 36. Because the 2010 survey
was negative for the toad, the RDEIR preparers simply did not bother to survey the site
again, claiming that this species is not “expected” to occur within the Project site.
Appendix G at 63 (pdf page 73).
The RDEIR’s approach is unacceptable. The failure to locate a species during a
single survey does not suggest that the species is absent from the Project site. Tellingly,
the RDEIR does not provide any information about the nature of the 2010 survey, so
readers cannot ascertain whether appropriate protocols were followed. It is entirely
possible that adverse conditions prevented the investigators from determining the toad’s
presence. Disease, drought, or predation may preclude the presence or identification of a
species in any given year. For these reasons, the United States Fish & Wildlife Service
(USFWS) advises that “to be reasonably confident that arroyo toads are not present at a
site, at least six (6) surveys must be conducted during the breeding season.” See USFWS
Survey Protocol for the Arroyo toad, May 1999, attached as Exhibit C. Given that the
arroyo toad is an endangered species and that the Project site includes suitable habitat for
this species (see DEIR at 3.4-15), current protocol-level surveys must be conducted.
Without these surveys, the RDEIR lacks the evidentiary support that impacts to the toad
would be less than significant.
The RDEIR analytical error is not limited to the arroyo toad. Although the yellow-
breasted chat was observed on-site, we could find no indication that the RDEIR analyzed
potential impacts to this sensitive species. See RDEIR at 3.4-12, 3.4-38. Accordingly, the
revised EIR must include focused surveys and a comprehensive analysis of potential
impacts to the chat. If impacts are determined to be significant, the RDEIR must then
identify mitigation measures to eliminate or reduce these impacts.
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In addition, the RDEIR fails to provide legally enforceable mitigation for the
Project’s impacts to southern cottonwood riparian forest, a sensitive community that is
considered high priority for conservation by California Department of Fish and Wildlife
(CDFW). RDEIR at 3.4-50. The RDEIR calls for temporary impacts to be restored to pre-
project conditions, but it does not require the planting of any native species, let alone
southern cottonwood riparian forest. See RDEIR at 3.4-53 (calling for temporary impacts
to be restored using native species “where appropriate”). Moreover, CEQA does not
distinguish between temporary and permanent environmental impacts. Any impacts
should mitigated at 1:1 ratio (on-or off-site restoration or enhancement of southern
cottonwood riparian forest community).
The RDEIR makes this same error in its mitigation for the Project’s “temporary”
impacts to CDFW jurisdictional streambed and associated riparian habitats. Here too, it
would allow these sensitive habitats to be replaced with non-native species. RDEIR at
3.4-52. But to maintain the habitat’s value for wildlife, native species must be planted.
This is because exotic plants not only sever the food web, but often become invasive
pests, outcompeting native species and degrading habitats in remaining natural areas.3
Unless and until the EIR commits to replacing this lost habitat with other designated
sensitive riparian habitat, i.e., locally appropriate native species, the RDEIR has no basis
to conclude that these impacts would be less than significant.
Finally, the Project site’s southern cottonwood-willow riparian forest provides
habitat for the least Bell’s vireo and is suitable nesting habitat for the willow flycatcher, a
State Endangered species. RDEIR at 3.4-1, 3.4-40, 3.4-43. The Project proposes a 150-
foot landscaping and fuel modification setback area adjacent to the southern cottonwood
forest, but this measure is flawed: landscaping of this setback area would not be restricted
to native plants. Id. For the reasons discussed above, all replacement vegetation must be
native.
(b) Impacts to Federally Protected Wetlands, Streambeds and
Riparian Habitat.
The RDEIR acknowledges permanent and “temporary” impacts to federally
protected wetlands, a jurisdictional streambed, and associated riparian habitat. RDEIR at
3.4-51. The proposed mitigation, Mitigation Measure BIO-4, is defective. While MM
3 Why Native Plants Matter, Audubon; available at:
http://www.audubon.org/content/why-native-plants-matter; accessed March 14, 2018.
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BIO-4 requires mitigating permanent impacts at a 2:1 ratio, it calls for restoring wetlands
that are temporarily impacted only to “pre-project conditions.” Id. Again, CEQA does not
distinguish between temporary and permanent environmental impacts. Consequently, all
Project impacts to these resources should be mitigated at a 2:1 ratio. Moreover, the
RDEIR never describes the referenced pre-project conditions, so there is no assurance
that satisfactory restoration would even occur. RDEIR at 3.4-52. Finally, MM BIO-4
calls for restoration and revegetation with native species, but only “where appropriate.”
Id. For the reasons discussed above, all natural communities should be restored with
native species.
(c) Cumulative Biological Resources Impacts.
The RDEIR fails to provide any analysis of cumulative impacts to biological
resources. The purpose of a cumulative impacts analysis is to determine whether the
proposed Project’s contribution is “cumulatively considerable” when viewed together
with environmental changes anticipated from past, present, and probable future projects.
Guidelines §§ 15064(h)(1), 15355(b). In determining the significance of the Project's
incremental contribution, the question is not the relative amount of the Project's
contribution to the existing cumulative problem (i.e., does this Project contribute the
same, less, or more than other projects), but whether the addition of the Project's impact
is significant in light of the serious existing problem (i.e., is the Project's contribution to
the existing environmental problem cumulatively considerable). Thus, the greater the
existing environmental problem is, the lower the threshold of significance is for
considering a project's contribution to the cumulative impact. Communities for a Better
Environment v. Cal. Resources Agency (2002) 103 Cal.App.4th 98, 120.
Here, the Project site provides habitat for numerous sensitive species, some of
which are endangered. Accordingly, any threats to these species—such as from loss of
habitat and habitat fragmentation—must be considered a serious existing problem. Thus,
the RDEIR’s failure to provide any analysis of cumulative impacts to biological resources
is a fatal flaw.
(d) Impacts Related to Tree Removal.
The primary purpose of the City’s Tree Preservation Ordinance is to regulate the
removal and destruction of trees on undeveloped and public interest property and to
prevent further destruction of the City’s once vast number of majestic trees. See
Municipal Code §12.32.010(A). The Municipal Code explains that the regulation of tree
removal is necessary because “large scale tree removal” is “more likely to have an
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Page 21
adverse affect [sic] upon the existing environment.” Id. at §12.32.010(b). The Code also
states that the “past destruction of trees on such property has not only interfered with the
natural scenic beauty and tourism of the city, but also greatly diminished the ecological
value of such natural vegetation.” Id.
The applicant’s proposal to remove 204 trees must certainly be considered “large
scale tree removal.” The RDEIR concludes that removed trees would be replanted at a
1:1 ratio. The document then states that this replanting would reduce impacts to a less
than significant level, thereby implying that merely replanting trees would eliminate any
conflict with the Tree Ordinance. RDEIR at 3.4-61. But this facile reasoning is untenable.
The whole purpose of the Tree Ordinance is to prevent destruction of the City’s once
majestic trees. To this end, the Ordinance explicitly acknowledges that trees of historical
value may be considered “public interest property.” Municipal Code § 12.32.050. It
further defines “historical trees” as those that by virtue of their origin, size, uniqueness
and/or national or regional rarity are now likely to be of historical value. Id. at 12.32.060.
Tellingly, the RDEIR makes no effort to determine the historical value of the trees
that would be removed by the applicant. This omission is particularly egregious in light
of the fact that the Biological Resources Appendix calls for an updated tree survey to be
conducted. RDEIR Appendix G, pdf page 65. Until this analysis occurs, there is no way
of determining whether the trees should be considered “public interest property” under
the Tree Ordinance. Given the Ordinance’s strong predilection toward tree preservation,
the RDEIR might well recommend a revised site development plan that allows for the
preservation of the site’s healthy mature trees.
In sum, the EIR should be revised again both to determine the historical value of
the site’s trees and to disclose the Project’s grading and development schedule. It must
also analyze any potential inconsistency with the Municipal Code. If the Project’s plan
for tree removal is determined to be inconsistent with the Code, the EIR must identify the
impact as significant and propose feasible mitigation.
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cont.
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Robert Garcia, Senior Planner
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5. The RDEIR Fails to Adequately Analyze or Mitigate the
Project’s Traffic Impacts.
(a)Insufficient Information about “Entitled” Uses and
Discrepancies Relating to the Amount of Earthwork
Required to Prepare the Site for Development Make it
Impossible to Verify the Accuracy of the Transportation
Impact Analysis.
As discussed above, the RDEIR provides insufficient information about the status
of existing recycling and backfill operations on the site. In addition, there are numerous
discrepancies and inconsistencies relating to the amount of earthwork required to
implement the proposed Project. The consequences of these errors and omissions cannot
be overstated. To begin with, it is not possible to verify the accuracy of the transportation
impact analysis. Moreover, based on the information that is provided, it would appear
that the RDEIR may have substantially underestimated the number of truck trips required
to prepare the site for development. The RDEIR also appears to have substantially
underestimated the Project’s trip generation. If this is the case, the Project’s traffic
impacts would be far more severe than the RDEIR discloses.
(i)The RDEIR’s Failure to Include Accurate Earthwork
Data Undermines the Analysis of Traffic (and Other
Environmental) Impacts.
The RDEIR’s technical appendices identify an amount of import and export that
greatly exceeds the amount identified in the RDEIR’s Project Description. The RDEIR
Project Description states that the Project will require the import of 877,000 cubic yards
(cy) of clean materials and the export of about 500,000 cy of silty soils. The RDEIR’s
appendix, however, identifies a total of 3,348,200 cy to be over excavated (2,248,200 cy
will be exported and 1,100,000 cy will be imported). This inconsistency is neither
identified nor explained. Apparently relying on the 877,000 cy of material figure, the
RDEIR determines that the Project’s construction activities will require up to 275,400
total haul trips during the grading period. RDEIR at 3.3-34. Yet, the number of truck trips
would be substantially higher had the RDEIR relied, instead, on the import/export figures
identified in the technical appendix. In order to accurately identify the number of haul
trips, the revised EIR must clearly identify the import/export figures.
In addition, the amount of on-site construction equipment will vary depending on
the amount of earthwork required. Once the revised EIR identifies accurate import/export
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Robert Garcia, Senior Planner
December 28, 2018
Page 23
figures, it must identify the amount of equipment (e.g., excavators, graders, loaders, etc.)
needed to prepare the site for development. All of this information is required not only to
evaluate construction-related traffic impacts but also to evaluate the Project’s
construction-related air quality, greenhouse gas, noise, hydrological, and hazards impacts.
(ii) The RDEIR Relies on a Questionable Vehicular Trip
Credit and Appears to Underestimate the Project’s
Trip Generation.
The RDEIR’s transportation impact analysis relies on a “Materials Recycling and
Backfilling Operation Trip Credit” for permitted (“entitled”) sand and gravel operations
for purposes of identifying the Project’s trip generation. RDEIR at 3.16-20. The
document explains that this trip credit was calculated based on traffic counts conducted
during normal sand and gravel mining operations in October/November 2010. RDEIR at
3.16-20. The trip credit was determined to be 686 daily trips. RDEIR at 3.16-21. There
are numerous problems with the RDEIR’s approach.
First, because the RDEIR omits any information about sand and gravel operations
in 2010, it is impossible to verify whether 686 daily trips is even accurate. The revised
EIR must describe the nature of operations in 2010. In particular, it must identify the
amount of materials imported and the amount of materials exported on a daily basis and
the number of daily truck trips used for these operations during 2010.
Second, the City granted Grading Permit No. 2047 (to allow previously mined
portions of the Project site to be backfilled) in March 2011. RDEIR at 2-2; RDEIR
Appendix P at 5. The RDEIR does not describe how operations changed between 2010
(the year used to conduct traffic counts for purposes of determining the “trip credit”
(RDEIR at 3.16-20) and 2011 (the year that, according to the RDEIR, the “site operation
was at its peak”). See RDEIR at 3.16-21. Why did the RDEIR preparers rely on the year
2010 for determining the trip credit rather than 2011?
Third, the RDEIR is giving trip credits to activities that appear to have already
been completed. According to RDEIR Appendix P (Traffic Impact Analysis), about 29
percent of the traffic for these “entitled” sand and gravel operations is related to materials
recycling activities, while 71 percent is related to the backfill operations on the Project
site. RDEIR Appendix P at 5. This includes both truck and passenger-car (employees)
trips generated from the Project site. Under this recycling/backfill ratio, the backfill
activities would be expected to generate about 487 daily trips (71 percent of 686).
Assuming some of these trips are made by workers in their vehicles, backfill-related
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activities would still generate in excess of 400 trips per day. If 50 percent of these trips
represent loaded trucks going to the site and 50 percent represent empty trucks leaving
the site, and if each truck carries 10 cy of materials per load, then backfilling operations
would average about 2,000 cy per day. These statistics suggest that the total amount of
material associated with backfilling operations approved under the 2011 grading permit
could be accomplished within about 111 days. In numerous instances, the RDEIR
discusses the backfilling activities in the past tense, suggesting that the backfill portion of
“Existing Materials and Backfilling Operations” has already been completed. If this is the
case, the RDEIR cannot rely on this “trip credit” for purposes of calculating the Project’s
trip generation or for purposes of analyzing the Project’s traffic impacts.
(iii) Other Inaccuracies in the RDEIR’s Approach to Trip
Generation Undermine the Integrity of the
Transportation Analysis.
According to RDEIR Appendix P, materials recycling will continue on the Project
site through the construction of the proposed Project, until Planning Area D is developed.
RDEIR Appendix P at 4. However, the RDEIR’s trip generation estimates do not appear
to take into account trips associated with these materials recycling operations. The
revised EIR must revise the trip generation figures to include trips from materials
recycling associated with Planning Area D, (until that area is developed).
(b) The RDEIR Fails to Adequately Analyze the Project’s
Roadway Safety Impacts.
The RDEIR discusses the Project’s roadway safety impacts, yet this analysis
focuses exclusively on the Project’s operations. The RDEIR ignores altogether the safety
hazards caused by the Project’s construction phase. By the RDEIR’s own estimates, the
Project would result in 275,400 total haul trips during the grading period. RDEIR at 3.3-
34. While we question the accuracy of the RDEIR’s truck trip estimate, we can find no
logical explanation as to why the document fails to evaluate how a massive increase in
haul trucks will impact roadway safety.
The revised EIR must begin its analysis by accurately identifying the number of
haul trucks that will be needed for site remediation and preparation. It must then identify
the haul route for these construction-related trucks and evaluate how traffic flow would
be managed on area roadways and intersections. As part of this analysis, the revised EIR
must include a crash prediction model that estimates the frequency of crashes expected
on area roadways based on their geometric design and traffic characteristics. The crash
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cont.
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Robert Garcia, Senior Planner
December 28, 2018
Page 25
prediction algorithm will need to consider the effect of a number of roadway variables:
number of lands, lane width, shoulder width and type, horizontal curve length (if any),
any changes in elevation, and grade. If roadway safety impacts are determined to be
significant, the EIR must identify mitigation measures capable of addressing these
impacts.
6. The RDEIR Fails to Adequately Analyze the Project’s
Construction-Related Air Quality Impacts.
The RDEIR fails to accurately evaluate the Project’s potential to expose nearby
sensitive receptors to substantial pollutant concentrations because it appears not to have
included mobile source criteria air pollutants and toxic air contaminant emissions from
the haul trucks transporting soils to and from the site. The DEIR ignored haul trucks
altogether. While the RDEIR now acknowledges that the Project will require the use of
haul trucks, we can find no evidence that the RDEIR’s air quality analysis was revised to
include the criteria and toxic air contaminant emissions that would be generated by these
haul trucks. (See RDEIR Table 3.3-7: Construction Equipment Assumptions and Table
3.3-8: Construction Maximum Daily Regional Emissions – Unmitigated, which do not
identify haul trucks or their expected emissions). Nor has Appendix B - AQ and GHG
Supporting Information been updated since the release of the DEIR.
Because the RDEIR fails to include emissions from haul trucks, it also
underestimates the Project’s potential to expose sensitive receptors to diesel particulates,
a known toxic air contaminant. The DEIR’s analysis determined that without mitigation,
the Project would exceed the South Coast Air Quality Management District’s Localized
Significance Threshold for PM10 and PM2.5. Even with mitigation, the DEIR
determined that the Project would come very close to exceeding these same standards.
We explained in our comments on the DEIR that had emissions from haul trucks been
included, PM10 and PM2.5 would very likely exceed the Localized Significance
Thresholds, thereby causing a significant impact. Inexplicably, the PM10 and PM2.5
emissions included in the RDEIR are now far lower than those disclosed in the DEIR.
See DEIR at 3.3-41, identifying unmitigated PM10 emissions as 11.95 per day and
unmitigated PM2.5 emissions as 4.70 pounds per day; and RDEIR at 3.3-42, showing
unmitigated PM10 emissions as 4.97 pounds per day and unmitigated PM 2.5 emissions
as 3.35 pounds per day.
The revised EIR must reconcile the varying emission estimates included in the
DEIR and the RDEIR. Moreover, once the revised EIR accurately identifies the amount
of earthwork necessary to prepare the site for development, it must disclose the number
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Page 26
of haul trucks and amount of construction-related equipment associated with the
earthwork. The EIR must then clearly show that emissions from these trucks and
equipment have been included in the air analysis. Once the Project’s construction-related
emissions have been identified, the EIR’s Localized Significance Analysis must be
revised. If particulate emissions exceed the thresholds, the Project may expose nearby
sensitive receptors to an elevated health risk, which would likely require the preparation
of a health risk assessment.
7. The RDEIR Fails to Adequately Mitigate the Project’s Energy-
Related Impacts.
The RDEIR quantifies the Project’s increase in construction- and operational-
energy impacts. RDEIR at 3.18-14. Although the Project would increase electricity,
natural gas, and petroleum-based fuel consumption, the RDEIR concludes that impacts
related to this energy consumption would be less than significant because the Project
would not involve inefficient, wasteful and unnecessary use of energy. DEIR at 3.18-15.
Yet the RDEIR lacks the evidentiary basis for this questionable conclusion.
The Project would consume 805,632 kWh of electricity and 4.5 million cubic-feet
of natural gas each year. RDEIR at 3.18-14. At build-out, the transportation component
of the Project would consume 276,430 gallons of gasoline or diesel. DEIR at 6-6. To
conclude that the Project would not be inefficient and wasteful, the RDEIR must
demonstrate that the Project includes reasonably available measures to decrease energy
consumption.
We can find no indication that the Project includes any features that would reduce
its consumption of electricity, natural gas, gasoline or diesel fuel. One way for a
residential project to decrease energy consumption is to build to LEED (Leadership in
Energy & Environmental Design) standards, which require the incorporation of energy-
saving features. For example, according to A Citizen’s Guide to LEED for Neighborhood
Development, “green buildings” should incorporate strategies like the use of (1) solar
energy, (2) water efficiency measures, (3) sustainably sourced (or recycled) materials,
and (4) efficient irrigation equipment, in addition to capturing rainwater and recycling
wastewater. See A Congress For New Urbanism, Citizen’s Guide to LEED for
Neighborhood Development at 13-16, excerpts attached as Exhibit D.
The applicant appears to have ignored all such LEED strategies. Because these
strategies have been determined to be feasible by a national advisory committee of
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December 28, 2018
Page 27
experts in smart growth, the revised EIR should include these measures to mitigate for
the Project’s dramatic increase in energy consumption.
8. The RDEIR Fails to Adequately Analyze or Mitigate the
Project’s Consistency with Plans, Policies or Regulations
Adopted for the Purpose of Reducing GHG Emissions.
The RDEIR provides no evidence that the Project, which would generate more
than 1,900 metric tons of CO2e emissions every year, is doing its fair share to meet GHG
reduction goals. DEIR at 3.7-21. Worse still, because the RDEIR concludes that the
Project would have no significant climate-related impacts, it fails to adopt any mitigation
for the Project’s substantial increase in emissions. The RDEIR provides only a cursory
discussion of the Project’s consistency with the City’s General Plan climate change
policies and provides no analysis at all of the Project’s consistency with state plans to
reduce GHG emissions.
(a) The RDEIR Lacks Any Evidentiary Support that the
Project Would Not Conflict with the City’s General Plan
Climate Change Policies.
Acknowledging that the City has not yet adopted a GHG reduction plan, the
RDEIR identifies a few General Plan policies related to climate change. RDEIR at 3.7-
22; 3.7-25. One of these policies calls for the City to develop a strategy to reduce GHG
emissions within Orange by at least 15 percent from current levels by 2020. RDEIR at
3.7-25. Yet, rather than evaluate whether the Project incorporates features that would
help the City achieve a 15 percent reduction in GHG emissions by 2020, the document
skips this step altogether. Instead, it merely asserts that because the Project preserves
some open space on the Project site, it would avoid additional GHG emissions. Id. The
RDEIR never identifies the amount of GHG emissions that would purportedly be avoided
by preserving open space. Id. Nor does the RDEIR ever explain how a Project that
increases GHG emissions by more than 1,900 metric tons every year could, at the same
time, avoid emissions.
The Project is clearly inconsistent with the City’s climate-related General Plan
policies. These inconsistencies constitute a significant impact of the Project. The EIR
must be revised to rectify this deficiency.
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(b) The RDEIR Fails to Analyze the Project’s Consistency
With State Plans to Reduce GHG Emissions.
Executive Order (EO) S-3-05 sets forth state policy related to GHG reduction,
including reducing GHG emissions to 80% below 1990 levels by 2050. EO B-30-15,
signed by the Governor in 2015, establishes a new interim target to reduce GHG
emissions by 40 percent below 1990 levels by 2030. The RDEIR acknowledges EO S-3-
05 and EO B-30-15, but it never analyzes the Project’s consistency with these directives.
Tellingly, the RDEIR provides no justification for its failure to undertake this
analysis. Other agencies have easily performed this analysis. For example, the San Diego
Association of Governments (SANDAG) utilized the following threshold of significance
in the EIR for its most recent Regional Transportation Plan/Sustainable Communities
Strategy: “GHG-4: Be inconsistent with the State’s ability to achieve the Executive Order
B-30-15 and S-3-05 goals of reducing California’s GHG emissions to 40 percent below
1990 levels by 2030 and 80 percent below 1990 levels by 2050.” See SANDAG’s
RTP/SCS DEIR, GHG Chapter, attached as Exhibit E at 4.8-33.
The SANDAG RTP/SCS EIR evaluated the project’s impacts by calculating a 40
percent and 80 percent reduction from the region’s 1990 emissions and utilizing that as a
target reference point for the RTP. It then compared the region’s expected GHG
emissions in the years 2035 and 2050 to the emissions that would be necessary to meet
the EO trajectories. It included charts showing that the Plan would not meet the EO goals,
concluding: “Because the total emissions in the San Diego region of 25.5 MMT CO2e in
2035 would exceed the regional 2035 GHG reduction reference point of 14.5 MMT
CO2e (which is based on EO-B-30-15 and EO-S-3-05), the proposed Plan’s 2035 GHG
emissions would be inconsistent with state’s ability to achieve the Executive Orders’
GHG reduction goals. Therefore, this impact (GHG-4) in the year 2035 is significant.”
Exhibit E at 4.8-35. It reached a similar conclusion for the year 2050 goal. This analysis
is easily adaptable to the proposed Project’s GHG emissions.
The RDEIR’s failure to compare the Project’s emissions—which will continue for
decades if not in perpetuity—against long-term GHG emission reduction policies such as
those in EO S-3-05 and EO B-30-15 is unlawful. The public should understand just how
far the Project will set the area off course from state-wide reduction goals.
Finally, because the RDEIR fails to undertake a proper analysis of the Project’s
climate impacts, it fails to analyze measures to reduce its GHG emissions. At a minimum,
the applicant could incorporate strategies such as those discussed above and outlined in
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Page 29
the LEED Handbook. Certain measures to reduce energy consumption for residential
projects could also be effective in reducing GHG emissions.
9. The RDEIR Fails to Identify the Project’s Construction-Related
Noise Impacts on Salem-Lutheran Church and School as a
Significant Impact.
The RDEIR fails to recognize that construction of the proposed Project would
result in a substantial increase in noise levels at the Salem-Lutheran Church and School.
The Salem-Lutheran Church and School, a private elementary school and church, is
located approximately 600 feet southeast of the area proposed to be graded. RDEIR at
Exhibit 2-2; Exhibit 3.2-1; page 3.3-1. The RDEIR noise chapter fails to even mention
this school and church, let alone analyze how construction-related noise might interfere
with school/church activities. The revised EIR must provide this analysis. If the Project’s
noise impacts are determined to be significant, the document must identify mitigation
capable of reducing these impacts.
10. The RDEIR Fails to Adequately Address the Project’s Growth-
Inducing Impacts.
The RDEIR fails to evaluate, or even acknowledge, the potential for the Project to
encourage growth caused by the applicant’s proposal to amend the OPA and East Orange
Plans. By amending these plans to allow comparatively higher density (e.g., less than a 1-
acre minimum lot size), the Project has the potential to encourage large-lot property
owners to subdivide their lots. Consequently, the RDEIR’s conclusion that the Project
will not induce growth cannot be sustained. RDEIR at 6-3. The revised EIR must
acknowledge the potential for such growth and analyze the associated environmental
impacts.
C. The RDEIR’s Analysis of Project Alternatives Is Legally Inadequate.
CEQA provides that “public agencies should not approve projects as proposed if
there are feasible alternatives . . . which would substantially lessen the significant
environmental effects of such projects.” Pub. Resources Code § 21002. Critically, an EIR
must consider a “reasonable range” of alternatives “that will foster informed
decisionmaking and public participation.” Guidelines § 15126.6(a); Laurel Heights
Improvement Assn., 47 Cal.3d at 404 (“An EIR's discussion of alternatives must contain
analysis sufficient to allow informed decision making.”)
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1. The RDEIR Fails to Adequately Identify or Analyze a “No-
Project” Alternative.
The RDEIR identifies two no-project alternatives, both of which call for the
continuation of sand and gravel operations on the Project site. RDEIR at 5-2. While
CEQA does allow the no-project alternative to take into account “predictable actions” if a
proposed project is denied, the EIR must nonetheless conduct an appropriate analysis of
the no-project’s environmental impacts. Guidelines § 15126.6(e)(3)(B). In particular,
CEQA requires that the no-project alternatives analysis discuss what would be reasonably
expected to occur in the foreseeable future if the project were not approved, based on
current plans and consistent with available infrastructure and community services.
Guidelines § 15126.6(e)(2). Here, the RDEIR fails to provide an accurate analysis
because it is unrealistic to assume that sand and gravel mining could continue on an on-
going basis. Almost 25 years ago, the City determined that the extraction life of the
aggregate mine was mostly depleted (See Exhibit F at 1 (City of Orange Resolution No.
8182)). Accordingly, it is simply nonsensical that two of the RDEIR’s alternatives call
for a continuation of mining operations.
In addition, the RDEIR fails to provide an accurate analysis of the environmental
impacts that would occur under these no-project alternatives. In several instances, the
RDEIR incorrectly concludes that the no-project alternatives would result in fewer
environmental impacts than the proposed Project when, in fact, the opposite is true. For
example, the RDEIR finds that the no-project alternatives would result in fewer air
quality and noise impacts than the proposed Project. See RDEIR at Table-5-9. Clearly, if
sand and gravel operations were to resume at full capacity as the no-project alternatives
call for, the quarry’s operations would likely be far more environmentally impactful than
a 128-unit subdivision. Indeed, the City has long known that the sand and gravel
operations on the Project site cause extensive environmental harm. See Exhibit F at 5
(City of Orange Resolution No. 8182, stating: “the site’s aggregate mining opportunities,
if any, are limited by the residential development of the adjacent property to the north
because noise and dust impacts associated with mining would have deterred such
opportunities.”).
2. The RDEIR Relies on Incorrect Land Use Designation Acreages
in its Evaluation of Alternative 1.
In its description of Alternative 1 (Development within the Existing Land Use
Designations), the RDEIR states that a target of 77 homes would be developed on 15.4
acres north of Santiago Creek. RDEIR at 5-11. As discussed above, however, only 12.60
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acres of the Project site are currently designated for residential uses, not 15.4 acres.
Consequently, it is erroneous to assume that 77 homes could be developed under the
existing land use designation. The EIR must be revised to calculate the number of units
that could be built on 12.60 acres. This calculation must also take into account the site’s
existing zoning and site constraints including creek setbacks and the Metropolitan Water
District line that runs through and adjacent to the creek.
3. The RDEIR Fails to Evaluate a No-Project Alternative that Is
Based on Current Plans.
As discussed above, CEQA requires that the no-project alternatives analysis
discuss what would be reasonably expected to occur on a project site in the foreseeable
future if the project were not approved, based on current plans and consistent with
available infrastructure and community services. Guidelines § 15126.6( e)(2) (emphasis
added). In addition, when a project consists of “the revision of an existing land use or
regulatory plan . . . the ‘no project’ alternative will be the continuation of the existing
plan . . . into the future.” Guidelines § 15126.6(e)(3)(A).
Neither of the RDEIR’s “no-project” alternatives take into account existing plans,
i.e., the OPA Plan or the East Orange Plan’s land use designations for the site. To
properly analyze these alternatives, the RDEIR should have forecasted “what would be
reasonably expected to occur in the foreseeable future if the project were not approved,
based on current plans.” Guidelines § 15126.6(e)(2). As discussed above, the City clearly
anticipated that development proposals on the Project site were to be governed by the
OPA Plan and the East Orange Plan. See Exhibit F at 4 (City of Orange Resolution No.
8182). Consequently, a continuation of the existing land use plans means the Project site
would continue to be designated as “Santiago Greenbelt Plan” under the OPA Plan and
“Regional Park” under the East Orange Plan. In other words, the current Resource Area
uses could continue, but any future development would comply with the City’s
determination of compatible uses as shown in the OPA Plan and East Orange Plan—that
is, open space/park uses. The RDEIR incorrectly assumes that under “No Project:
Alternative 1:Development within the Existing Land Use Designations,” Resource Area
and Low Density Residential uses would occur on the Project site. RDEIR Page 5-2. This
mistake must be corrected.
The RDEIR must be revised to reflect a legally correct no-project alternative. This
alternative will inform decisionmakers and the public that under current land use plans,
future uses on the Project site would be open space/park. Without a proper no-project
alternative, the DEIR “fail[s] to meet the most important purpose of CEQA, to fully
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inform the decision makers and the public of the environmental impacts of the choices
before them.” Planning & Conservation League v. Department of Water Resources
(2000) 83 Cal.App.4th 892, 920 (invalidating EIR because the no-project alternative
improperly analyzed what would reasonably be expected to occur in the absence of the
project).
4. The RDEIR Must Consider Other Feasible Alternatives Capable
of Avoiding or Substantially Reducing the Project's Significant
Environmental Impacts.
The DEIR identifies the “Collaborative Group” alternative,4 which consists of 47
lots and 47 dwelling units on approximately 40 acres, as the environmentally superior
alternative because it achieves impact reductions in eight topic areas. RDEIR at 5-34. As
an initial matter, the RDEIR does not provide an accurate representation of the
“Collaborative Group” alternative. See RDEIR Exhibit 5-2. The correct version of this
alternative is attached as Exhibit G. The RDEIR errs further when it rejects the
“Collaborative Group” alternative, asserting summarily that it would not achieve project
objectives and would not be financially feasible. RDEIR at 5-35. However, because the
RDEIR provides no evidentiary support for these claims, its rejection of this alternative
does not withstand scrutiny.
First, the RDEIR asserts that the “Collaborative Group” alternative would not
advance the Project’s objectives. This claim is disingenuous, however, because the
RDEIR does not actually evaluate the alternative against the Project’s objectives. Rather,
the document invents a few new objectives and then asserts the Project would not be
consistent with these new objectives. RDEIR at 5-35.
• New objective No.1: Transition of an infill site with a Specific Plan. As an
initial matter, the meaning of this objective is unclear. Moreover, the RDEIR offers no
explanation as to why the Collaborative Group alternative would be inconsistent with an
objective calling for use of a Specific Plan to support development on the site. Certainly,
4 We can find no logical explanation as to why the RDEIR refers to this alternative
as the Collaborative Group Alternative. There is no “Collaborative Group.” Rather, the
name of the group that met with the City over the years in connection with this Project is
the “City of Orange Sully Miller Liaison Committee” (Liaison Committee). To avoid
confusion, the revised EIR must consistently refer to this group as the “Liaison
Committee” and the alternative should be renamed to “Liaison Committee Alternative.”
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a specific plan could be prepared to support the level of development contemplated by the
“Collaborative Group” alternative.
• New objective No. 2: Develop a logical internal circulation system for
pedestrians, bicyclists, equestrians, and motorists. This new objective is similar to the
RDEIR’s Objective 6, but, unlike the original objective, it calls for an internal circulation
system for motorists. RDEIR at 5-7. The RDEIR provides no reason why the
Collaborative Group alternative could not be developed to have an internal transportation
system. Moreover, the original Project objective calls for providing a circulation system
that will minimize adverse effects on local residential neighborhoods and encourage
pedestrian and bicycle circulation. Because the “Collaborative Group” alternative calls
for considerably less development than the proposed Project, it would be more effective
at reducing traffic impacts on local neighborhoods than the proposed Project.
Consequently, the “Collaborative Group” alternative would be more consistent with the
Project’s actual objectives than would the Project itself.
• New Objective No. 3: Would not permit the “Development Agreement
Benefits” to the Community. RDEIR at 5-28. This objective is also not included in the
RDEIR. However, certain of the Project objectives do call for improvements that are
apparently included in the proposed Project, including the establishment of a greenway
along the Santiago Creek corridor, developing a trail network, and improving circulation
by widening Santiago Canyon Road and restriping Cannon Road. RDEIR at 5-7. The
RDEIR explains that the “Collaborative Group” alternative would not permit any of these
items (at 5-22), but it does not explain why. And it makes no sense that the
“Collaborative Group” alternative would eliminate these improvements. Including a trail
network and making improvements to the Santiago Creek corridor would increase the
marketability of the Project and likely command higher home prices.
Finally, the RDEIR asserts that the “Collaborative Group” alternative is not
financially feasible. Here too, the RDEIR provides no evidentiary support for this
assertion. Moreover, if this alternative is already known to be infeasible, it is unclear why
it was included in the EIR. Under CEQA, the City must identify feasible alternatives
capable of attaining the Project’s objectives while avoiding or substantially lessening the
Project’s significant impacts. Pub. Res. Code § 21100(b)(4); Guidelines § 15126(d) (EIR
must describe a range of alternatives to a proposed project, and to its location, that would
feasibly attain the project’s basic objectives while avoiding or substantially lessening the
project’s significant impacts).
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The RDEIR’s alternative analysis is further flawed because its remaining
alternative—the 122-Unit alternative—results in impacts that are equivalent to the
Project’s in virtually every impact area. Thus, rather than imparting serious information
about potentially viable alternatives, the “Collaborative Group” alternative and the 122-
Unit alternative serve only as “straw men” to provide justification for the Project. Such
an approach violates CEQA, as it leaves the public and decisionmakers with no
reasonable, less damaging option for development on the Project site.
To comply with CEQA, the EIR must identify feasible alternatives that actually
reduce impacts caused by the proposed Project. One such alternative is the Liaison
Committee Map alternative, the result of the City’s public outreach. A graphic depiction
of this alternative is shown in the November 2, 2016 PDA (Exhibit H). The Liaison
Committee Map alternative allows for less development than the proposed Project and
would therefore be more effective than the proposed Project in achieving the Project’s
objectives (e.g., locate homes in the most suitable areas of the site; preserve open space
and greenway; preserve and protect Santiago Creek; and be compatible with neighboring
residential uses). It would also be environmentally superior to the proposed Project since
less development and more open space would result in reduced environmental impacts.
Under CEQA, an agency may not approve a proposed project if a feasible
alternative exists that would meet a project’s objectives and would diminish or avoid its
significant environmental impacts. Pub. Res. Code § 21002; Kings County Farm Bureau
v. City of Hanford (1990) 221 Cal.App.3d 692, 731; see also Guidelines §§ 15002(a)(3),
15021(a)(2), 15126(d); Citizens for Quality Growth v. City of Mount Shasta (1988) 198
Cal.App.3d 433, 443-45. An alternative need not meet every Project objective or be the
least costly in order to be feasible. See Guidelines § 15126.6(b). The “Collaborative
Group” and Liaison Committee Map alternatives are feasible and would substantially
reduce the Project’s environmental impacts. Consequently, approval of the Project, or any
alternative project with greater impacts than these alternatives would violate CEQA.
D. The RDEIR Must Be Recirculated.
Under California law, the present EIR cannot properly form the basis of a final
EIR. CEQA and the Guidelines describe the circumstances that require recirculation of a
draft EIR. Such circumstances include: (1) the addition of significant new information to
the EIR after public notice is given of the availability of the RDEIR but before
certification, or (2) the draft EIR is so “fundamentally and basically inadequate and
conclusory in nature that meaningful public review and comment were precluded.”
Guidelines § 15088.5.
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Here, both circumstances apply. Decisionmakers and the public cannot possibly
assess the Project’s impacts or even its feasibility through the present RDEIR, which is
riddled with errors. As we have explained, the RDEIR omits certain information and
provides inconsistent information about prior remediation efforts on the Project site and
the nature of earthwork that would be needed to prepare the site for development.
Without additional information, it is not possible to evaluate the Project’s impacts
relating to: hydrology, hazards, public health and safety, transportation, air quality, noise,
and climate change. Nor is it possible to evaluate the feasibility of the Project’s
alternatives. The revised EIR must provide the following information and then be
recirculated for public review and comment:
1. In March 2011, the City granted Grading Permit No. 2047 to allow
previously mined portions of the Project site to be backfilled. RDEIR at 2-2; RDEIR
Appendix P at 5. The RDEIR fails to disclose the amount of backfilling that has already
occurred pursuant to this Permit. What is the precise amount of import and export that
has taken place on the Project site since 2011, the year that Permit No. 2047 was issued?
Clearly, this information is available as RDEIR Appendix P states that “the Project site
was backfilled in sequentially defined phases.” RDEIR Appendix P at 4.
2. The RDEIR states that since 2015, backfilling operations have been limited
to 15 consecutive business days in any 6-month period. RDEIR at ES-8. Precisely, how
many cubic yards of soils have been removed since this limitation began in 2015?
3. The RDEIR states that “During grading, the project is expected to require
the import of approximately 877,000 cubic yards of new material and the removal of
approximately 500,000 cubic yards of silt.” RDEIR at 3.3-34. The RDEIR’s Appendix I,
however, states that “Approximately 2,248,200 cubic yards of material will be over
excavated. This includes all materials required to restore the project site. Once removed,
the material will be spread and dried on the project site. The material will then be mixed
with imported materials. A total of 1,100,000 cubic yards of material will be imported to
the site. The imported materials include concrete, asphalt, rock, and soil. The imported
materials will be crushed on-site. A total of 3,348,200 cubic yards of material, both over
excavated and imported to the project site, will be blended during the backfilling
operation.” RDEIR Appendix I at (pdf page 9) The RDEIR must reconcile the
import/export figures presented in the RDEIR with those identified in RDEIR Appendix
I.
4. RDEIR Appendix I (at pdf page 9) states that the “project site is presently
being backfilled in accordance with the specific backfill description provided by the EIR
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Robert Garcia, Senior Planner
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consultant.” Is the backfill operation identified in Appendix I a component of the
proposed Project or is it separate and distinct from the Project?
5. As reflected in the Rio Santiago EIR, under the 2011 plan, grading and
backfilling activities would have lasted 52 months (1,129 days). The RDEIR indicates
that grading and backfilling activities will last only 18 months (391 days). Since the
grading equipment identified in connection with the two plans is essentially the same, this
suggests that the silt pond excavation, spreading, and mixing activity that formed the core
of the 2011 plan has been eliminated. Has the silt pond excavation, spreading, and mixing
activity that formed the core of the 2011 plan been eliminated from the current project?
If so, why?
6. Why does the RDEIR rely on grading and earthwork technical appendices
prepared in connection with the Rio Santiago Project? The Rio Santiago Project,
contemplated in 2013, proposed entirely different land uses than the current Trails at
Santiago Creek Project.
7. The RDEIR’s transportation impact analysis relies on a “trip credit” for
permitted sand and gravel operations for purposes of identifying the Project’s trip
generation. RDEIR at 3.16-20. The document explains that this trip credit was calculated
based on traffic counts conducted during normal operations in October/November 2010.
RDEIR at 3.16-20. The trip credit was determined to be: 686 daily trips, with 63 trips (34
inbound, 29 outbound) produced in the AM peak-hour and 32 trips (15 inbound, 17
outbound) produced in the PM peak-hour. RDEIR at 3.16-21. The RDEIR states that the
peak of the site’s backfilling operations occurred in 2011. RDEIR at 3.16-21. Why did
the RDEIR rely on trip counts from 2010 to arrive at the “trip credit” amount if the site’s
peak traffic occurred in 2011? What was the daily, AM, and PM peak hour truck and
employee vehicle counts in 2010? What was the daily, AM, and PM peak hour truck and
employee vehicle counts in 2011?
8. According to RDEIR Appendix P, materials recycling will continue on the
Project site through the construction of the proposed Project until Planning Area D is
developed. RDEIR Appendix P at 4. The RDEIR’s trip generation estimates do not
appear to take into account trips associated with these materials recycling operations.
How many truck and employee trips are associated with materials recycling within
Planning Area D?
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9. According to the RDEIR Table of Contents, Appendix L: Land Use
Background should have been included in the RDEIR. This appendix is missing. The
revised EIR must include the Land Use Background appendix.
II. APPROVAL OF THE PROJECT WOULD VIOLATE THE CALIFORNIA
PLANNING AND ZONING LAW.
The State Planning and Zoning Law require that development decisions be
consistent with the jurisdiction’s general plan. As reiterated by the courts, “[u]nder state
law, the propriety of virtually any local decision affecting land use and development
depends upon consistency with the applicable general plan and its elements.” Resource
Defense Fund v. County of Santa Cruz (1982) 133 Cal.App.3d 800, 806. Accordingly,
“[t]he consistency doctrine [is] the linchpin of California’s land use and development
laws; it is the principle which infuses the concept of planned growth with the force of
law.” Families Unafraid to Uphold Rural El Dorado County v. Bd. of Supervisors (1998)
62 Cal.App.4th 1332, 1336 (citations and internal quotations omitted).
General plans establish long-term goals and policies to guide future land use
decisions, thus acting as a “constitution” for future development. Lesher
Communications, Inc. v. City of Walnut Creek (1990) 52 Cal.3d 531, 540. The policies in
the General Plan must be internally consistent. Gov. Code § 65300.5. To promote
coordinated land use policies and practices, state law requires local governments not only
to formulate land use plans, but also to conform their development and land use projects
and approvals with those duly certified plans. Citizens of Goleta Valley v. Bd. of
Supervisors (1990) 52 Cal.3d 553, 570; see also Gov. Code § 65860 (requiring
consistency of zoning to general plan); id. §§ 65359 & 65454 (requiring consistency of
specific plan and other development plan and amendments thereto to general plan); id.
§ 65867.5(b) (requiring consistency of development agreement to general plan).
It is an abuse of discretion to approve a project that “frustrate[s] the General
Plan’s goals and policies.” Napa Citizens for Honest Government v. Napa County Board
of Supervisors (2001), 91 Cal.App.4th at 357. The project need not present an “outright
conflict” with a general plan provision to be considered inconsistent; the determining
question is instead whether the project “is compatible with and will not frustrate the
General Plan’s goals and policies.” Id. at 379.
Here, for the reasons described above, the proposed Project is inconsistent with the
City’s General Plan. Because of these inconsistencies, approval of this Project would
violate the State Planning and Zoning Law.
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III. CONCLUSION.
As set forth above, the Trails at Santiago Creek RDEIR suffers from numerous
deficiencies, many of which would independently render it inadequate under CEQA.
Taken as a whole, the deficiencies of the RDEIR necessitate extensive revision of the
document and recirculation for public comment. Moreover, as currently designed, the
Project conflicts with the City of Orange General Plan, the OPA and East Orange Plans,
and the City’s Tree Preservation Ordinance. OPA respectfully requests that the City
reevaluate the Project in light of its inconsistencies with these plans and ordinances and
make changes to the Project to reduce its serious environmental impacts.
Very truly yours,
SHUTE, MIHALY & WEINBERGER LLP
Laurel L. Impett, AICP,
Urban Planner
cc: Donald Bradley, Orange Park Acres
List of Exhibits:
Exhibit A: City of Orange Planning Commission Staff Report, May 5, 2003.
Exhibit B: OPA Specific Plan policies.
Exhibit C: USFWS Survey Protocol for the Arroyo toad, May 1999.
Exhibit D: A Congress For New Urbanism, Citizen’s Guide to LEED for
Neighborhood Development.
Exhibit E: SANDAG’s RTP/SCS DEIR, GHG Chapter.
Exhibit F: City of Orange Resolution No. 8182, May 18, 1993.
Exhibit G: “Collaborative Group” alternative, Corrected.
Exhibit H: Preliminary Development Agreement, November 2, 2016.
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Shute, Mihaly & Weinberger LLP (SMW)
Response to SMW-1
The comment provides introductory remarks generally reciting CEQA requirements, and stating
generally that the EIR fails to comply with CEQA’s core purpose. The City in its independent judgment
has reviewed the information in the EIR and concludes that the analysis is thorough and meets CEQA
requirements.
Response to SMW-2
The comment asserts generally that the project description is inadequate and that the EIR does not
analyze significant impacts or provide adequate mitigation. Specifically, the commenter argues that the
EIR fails to provide a legally adequate project description, analyze significant environmental impacts of
the project, and undertake a legally sufficient study of alternatives. Please refer to Master Response 2
for a response regarding the adequacy of the project description and Master Response 3 regarding the
adequacy of the range and analysis of project alternatives. The Trails at Santiago Creek Specific Plan
was made available for review during the time the RDEIR was circulated and the RDEIR included a
complete and legally adequate description of the Specific Plan. All details on the project have been
provided to the public as part of the RDEIR. In response to the commenter’s general assertion that the
EIR fails to properly analyze significant environmental impacts of the project, please see responses to
this letter below, which discuss specific environmental issue areas raised by this letter.
Response to SMW-3
The comment asserts that the project is inconsistent with the City’s General Plan and Orange Park
Acres Plan. The City disagrees with this comment, for the reasons stated in Master Response 5—Plan
Consistency. The proposed project is consistent with the City’s General Plan and the Orange Park
Acres Plan, and furthers the goals of those plans.
Response to SMW-4
The comment asserts that the project description is inadequate and contains insufficient detail.
Please refer to Master Response 6—Adequacy of the Project Description. The Trails at Santiago
Creek Specific Plan was made available to the public during the time the RDEIR was circulated. The
RDEIR provided all necessary details on the project to the public.
Response to SMW-5
Please refer to Master Response 2—Applicability of SMARA.
The commenter argues that the project description lacks fundamental information about the project
because it does not require a reclamation plan to be prepared for the site’s aggregate mining
operations. As discussed in RDEIR Section 3.11, Mineral Resources, page 3.11-3, operators of surface
mining operations are required to obtain a permit for operations post-1976 under SMARA, and are
required to file a mining reclamation plan for post-1975 mining operations. The project does not
involve aggregate mining operations. In fact, the mined areas of the site have been backfilled, which
effectively precludes the resumption of surface mining operations. The Geotechnical Investigation
prepared for the project concluded that aggregate mining operations on the project site would not
be economically feasible and the resource is effectively depleted. As such, there is no basis for the
project to prepare a reclamation plan. Contrary to the commenter’s assertion, backfilling on-site has
been suspended since September 15, 2015. Addressing the scope of backfilling is therefore not
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necessary because it is not part of the project. The status of previous backfilling that already
occurred on the site is not necessary because the baseline for CEQA analysis is existing conditions.
(See, e.g., Communities for a Better Env’t v South Coast Air Quality Mgmt. Dist. (2010) 48 C4th 310.)
Response to SMW-6
Please refer to Master Response 2—Applicability of SMARA and Master Response 9—Soils
Import/Export Numbers. Regarding the accuracy of the required import and export of soils, and the
relationship between the Project Description and the Geotechnical Investigation contained in
Appendix I, the Project Description provides accurate numbers for the amount of import and export
required by the project. The information provided in Appendix I relates to the larger Rio Santiago
Specific Plan analysis, as the commenter points out. The purpose of including this information from
the Rio Santiago Specific Plan project is not to identify contradictory cut and fill numbers, but to
provide additional support for the characterization of subsurface soils and the likely methods of
construction required. Contrary to the assertions of the commenter, the RDEIR did not rely on
grading details prepared for an entirely different project.
Response to SMW-7
The comment asserts that it is unclear in the project description what actions must occur to ensure
that the site can be made safe for human occupation. The comment states concern that potential
impacts from vapor intrusion of TCE, methane, and elevated levels of TPH in soil were not identified
in the project description. Please refer to Master Response 8—Site Environmental Conditions for a
discussion of potential impacts from vapor intrusion of TCE, methane, and elevated levels of TPH.
As an initial matter, project descriptions must include integral components of the project, but should
not provide extensive detail beyond that needed for evaluating environmental impacts (Santiago
County Water Dist. V County of Orange (1981) 118 CA3d 818, 829; CEQA Guidelines Section 15124).
The commenter’s suggestion that hazardous materials impacts should be addressed in the project
description is misplaced. Hazardous materials impacts, analyses, and mitigation measures are
addressed in RDEIR Section 3.8, Hazards and Hazardous Materials, based on the fundamental
components of the project identified in the Project Description, which is adequate under CEQA.
RDEIR Section 3.8, Hazards and Hazardous Materials, discloses the presence of contaminants and the
need for remediation and/or off-haul to ensure that the site is appropriate for residential re-use.
As discussed in Section 3.8, Hazards and Hazardous Materials, three Phase I or Phase II ESAs were
prepared for the project site in 2000, 2009, and 2011. As noted in the comment letter, the Phase II
ESA conducted in 2011 concluded that there were two potential hazards to future occupants and
users of the site: (1) potential vapor intrusion of TCE and methane into future dwelling units and (2)
elevated petroleum hydrocarbon concentrations in soil. The Phase II ESA determined that the
hazards identified in the 2000 and 2009 Phase I ESAs, including asbestos, no longer exist. The project
incorporates several mitigation measures to ensure that hazardous materials do not affect human
health or the environment. As the commenter mentions, the proposed enclosed structures will be
situated strategically to allow for future remediation, which will be implemented through design
plans and structural systems to prevent gas-related hazards. Structural systems will be approved by
the County of Orange Health Care Agency/Local Enforcement Agency. The mitigation measures
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identified are technically adequate under CEQA, which allows mitigation measures to specify
performance standards that will be met following project approval when it is impractical to devise
specific measures during the planning process so long as further action (i.e., a building permit) is
contingent on meeting those performance standards. (Sacramento Old City Ass’n v City Council
(1991) 229 CA3d 1011.) Pursuant to this standard, the mitigation measures identified in the
hazardous materials section are adequate under CEQA because they contain performance standards
that will be verified by the City and/or an agency.
The commenter argues that groundwater and methane monitoring wells exist on the project site,
but the RDEIR fails to describe whether the wells pose constraints on the project development.
Contrary to the commenters’ assertion, Mitigation Measure HAZ-2c requires that prior to
commencement of any construction activities, the Applicant must obtain approval from Orange
County Integrated Waste Management Department for the relocation of any monitoring wells or
probes that would be affected by the project development.
Contrary to the commenter’s assertion, the disclosure of potential hazardous materials impacts and
mitigation measures are not buried in the technical appendices but are presented plainly in Section
3.8, Hazards and Hazardous Materials, of the RDEIR.
The DTSC, in their comment letter dated December 27, 2018, provided suggested refinements to
Mitigation Measures HAZ-2a and HAZ-2b that clarify and confirm the actions required to meet
specific DTSC regulatory performance measures. The inclusion of more specificity in the
performance measures for the remediation of hazardous conditions will ensure that the site is
remediated to levels appropriate for residential use. The refinements recommended by DTSC are
shown in Section 4, Errata. Please also see the response to DTSC-4. The refinements to required
performance standards are intended to clarify and amplify Mitigation Measures HAZ-2a and HAZ-2b
and do not constitute significant new information or new or considerably different mitigation
measures pursuant to CEQA Guidelines Section 15088.5.
Response to SMW-8
Please refer to Master Response 4—Dam Failure and Liability.
Response to SMW-9
Please refer to Master Response 5—Wildfire Risk.
Response to SMW-10
The comment states an opinion that the RDEIR inappropriately defers studies and plans for Santiago
Creek’s restoration until after project approval.
As noted in the Project Description, studies of Santiago Creek will be conducted and plans will be
prepared and submitted to the City and/or other jurisdictional agencies for review and approval for the
enhancement, restoration, and re-establishment of the plant community habitats on the land on the
north side of Santiago Creek, within the Santiago Creek corridor and within the grassland areas in the
southeast portion of the Specific Plan area. As part of the project, a conservancy, OC Parks, the HOA, a
non-profit, or another similar entity will be responsible for caring for and maintaining open space
grasslands and trails. Please refer to Master Response 6—Stewardship of Open Space for more detail.
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Contrary to the commenter’s arguments, an analysis of responsibility for maintenance of the open
space grasslands and trails is not improperly deferred. As part of the project, either a conservancy,
OC Parks, the HOA, a non-profit, or another similar entity will be responsible for maintaining the
open space grasslands and trails. The project Applicant will enter into an agreement with a
conservancy, the HOA, non-profit, public agency, or similar entity, prior to approval of the Tentative
Map for the project, to ensure that responsibility for construction of improvements and
maintenance is adequately addressed. The agreement will include a funding mechanism to ensure
adequate funding of open space improvements and subsequent maintenance. There are no studies
or future mitigation measures required to analyze environmental impacts associated with
maintenance of the open space or trail area. The RDEIR did not identify any impacts associated with
maintenance nor did the RDEIR identify mitigation measures that are required to address potential
impacts associated with maintenance. Moreover, it is unnecessary to conduct any additional analysis
of Santiago Creek’s ultimate alignment, width, depth, etc., as suggested by the commenter, because
after a thorough analysis of potential creek impacts, the project was found not to result in any
impacts to Santiago Creek with implementation of mitigation. Likewise, it is unnecessary to conduct
a cost analysis of restoration of Santiago Creek.
Response to SMW-11
The comment states an opinion that the RDEIR fails to provide a viable plan for the management and
maintenance of the project’s open space lands and trails, including the Santiago Creek corridor. The
commenter opines that it is not known whether OC Parks agrees with the design, phasing, or costs
of the necessary improvements.
As part of the project, either a conservancy, OC Parks, the HOA, a non-profit, or another similar entity
will be responsible for maintaining the open space grasslands and trails. The project Applicant will
enter into an agreement with a conservancy, the HOA, a non-profit, public agency, or similar entity,
prior to approval of the Tentative Map for the project, to ensure that responsibility for construction of
improvements and maintenance is adequately addressed. The agreement will include a funding
mechanism to ensure adequate funding of open space improvements and subsequent maintenance.
The agency or entity responsible for maintenance will ensure that habitat will be properly managed for
the public benefit. Please refer to Master Response 6—Stewardship of Open Space for more detail.
Based on the project’s design features, including maintenance by a conservancy, OC Parks, the HOA, or
another entity, the RDEIR did not identify any potential impacts related to maintenance of the project’s
open space lands and trails. As such, mitigation is not required.
The commenter argues that the DEIR did not include necessary information related to the design,
phasing, timing, and financing of project infrastructure in the project description. The Project
Description describes the utilities required for the project beginning in RDEIR Section 2, Project
Description, page 2-62, including storm drainage, potable water, wastewater, electricity, and natural
gas. See Master Response 2—Adequacy of the Project Description, Level of Detail. As discussed in
Master Response 2—Adequacy of Project Description, project descriptions should not provide
extensive detail beyond that needed for evaluating environmental impacts (Santiago County Water
District v County of Orange (1981) 118 CA3d 818, 829; CEQA Guidelines Section 15124). The CEQA
Guidelines provide that the level of detail in an EIR project description should be “general.” The
leading court decision on the level of detail in EIR project descriptions stated that a “general
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description” is all that is required. Dry Creek Citizens Coalition v. County of Tulare (1999) 70
Cal.App.4th 20, 28. The level of detail in the project description related to project infrastructure is
sufficient to analyze the environmental impacts of the project. A detailed engineering design-level
drawing of storm drainage facilities is not required to analyze stormwater or flooding impacts, for
example. RDEIR Section 3.18, Utilities, addresses Utilities and Service Systems in detail to reach the
conclusion that impacts are less than significant. The level of detail presented in Section 3.18 is not
required to be included in the project description by the CEQA Guidelines or case law.
Response to SMW-12
Please refer to Master Response 2—Adequacy of the Project Description.
Response to SMW-13
The commenter opines generally that the Project Description is cursory and that analysis of impacts
and mitigation measures accordingly is deferred. Based on the City’s independent review, the City
concludes that the RDEIR Project Description provides a detailed and sufficient basis for the
environmental analysis in the RDEIR. The Trails at Santiago Creek Specific Plan was made available
for review as RDEIR Appendix Q, all details on the project have been provided to the public.
Please refer to Master Response 2—Adequacy of the Project Description.
Please also refer to responses SMW-1 through SMW-12 for more specific responses to the specific
issues raised in those comments and generally referenced in SMW-13.
Response to SMW-14
Please refer to Master Response 1—Plan Consistency.
Response to SMW-15
Please refer to Master Response 1—Plan Consistency.
Response to SMW-16
Please refer to Master Response 1—Plan Consistency.
Response to SMW-17
Please refer to Master Response 1—Plan Consistency.
Response to SMW-18
The comment alleges that the RDEIR incorrectly identifies General Plan land use designation
acreages for the project site.
The RDEIR correctly discloses that approximately 37 acres of the project site are designated
“Regional Park” in the East Orange General Plan. Similarly, the RDEIR correctly identifies
that approximately 39 acres of the project site are listed as “Open Space” in the Orange Park Acres
Plan; however, it is acknowledged that Orange Park Acres Association considers the Orange Park
Acres area to be 56.74 acres.
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Response to SMW-19
The comment alleges that the project is inconsistent with the Orange Park Acres and the East Orange
Plans. It also alleges that acreages are incorrectly identified in the RDEIR.
Please refer to Master Response 1—Plan Consistency. See also response to SMW-18.
Response to SMW-20
Please refer to Master Response 1—Plan Consistency.
Response to SMW-21
Please refer to Master Response 1—Plan Consistency.
Response to SMW-22
The comment states a general opinion that the RDEIR’s evaluation of hydrology and water quality
impacts is flawed. As explained in responses SMW-23 through SMW-26, this comment is incorrect.
Response to SMW-23
The comment notes that the project site is located in the Santiago Creek Watershed, which is listed
as an impaired water body on the Regional Board’s 303(d) List, and generally states that the RDEIR
should provide a comprehensive analysis of potential impacts to water quality.
RDEIR Section 3.9, Hydrology and Water Quality, discusses surface water quality. As discussed, the
project would result in an increase in the amount of impervious surfaces on the project site and
would create potential for discharge of urban pollutants into downstream waterways. However,
Mitigation Measure HYD-1b would be required, which would mandate a Water Quality Management
Plan (WQMP) to be prepared and submitted to the City of Orange for review and approval. The
WQMP is included as Appendix K to the RDEIR, which is referenced in RDEIR Section 3.9, Hydrology
and Water Quality, page 3.9-20. As part of the WQMP, the project would be required to comply with
pollution prevention measures and practices that comply with the most recently adopted provision
of the Orange County Municipal Separate Storm Sewer Program (MS4). In addition, the WQMP
proposes proprietary biotreatment BMPs that have high removal rates of typical pollutants found in
stormwater. With implementation of mitigation, operational water quality impacts would be less
than significant and the project would not substantially degrade water quality.
Related to construction impacts, Mitigation Measure HYD-1a would be required, which would
mandate a Stormwater Pollution Prevention Plan (SWPPP) to be prepared to prevent construction
related impacts to water quality. The SWPPP will be written and approved by both the City and
RWQCB prior to issuance of grading permits. BMPs will be implemented in accordance with the
SWPPP to retain sediment and pollutants on-site. Contaminated sediment identified would be
retained on-site will be treated as hazardous and handled/disposed of appropriately. With
implementation of mitigation, temporary stormwater impacts would be less than significant and the
project would not substantially degrade water quality during construction.
Response to SMW-24
The commenter states an opinion that the RDEIR fails to evaluate the effect that contaminated
discharge could have on water quality during construction. The comment also states an opinion that
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the Hydrology and Water Quality Reports in RDEIR Appendix K fail to explain how BMPs would
protect water quality given that contaminated soils occur on-site.
Mitigation Measure HYD-1a, which is required in the RDEIR, requires a SWPPP to be prepared for
project construction activities. The SWPPP must identify BMPs to reduce any potential impacts to
water quality. Mitigation Measure HYD-1a specifically requires sediment to be retained on-site by a
system of sediment basins, traps, or other BMPs. In addition, the mitigation measure requires the
construction contractor to prepare Standard Operating Procedures for handling hazardous materials
on the construction site to eliminate potential discharge of hazardous materials to the storm drain
system. Mitigation Measure HYD-1a would ensure that any contaminated soil is contained on-site
and does not discharge to storm drains. Contrary to the commenter’s assertion, the RDEIR
adequately addresses the presence of contaminated soil and includes mitigation to ensure that
contaminated soil is not discharged from the site during construction.
Response to SMW-25
Please refer to Master Response 2—Applicability of SMARA.
Response to SMW-26
The commenter states an opinion that operation of the project would create the potential for
discharge of urban pollutants into downstream waterways. The commenter argues that the RDEIR
does not properly describe the “first flush concept” because it is described in the appendices. The
commenter states opposition to Mitigation Measure HYD-1b, which requires BMPs to be
implemented by a WQMP.
Contrary to the commenter’s assertions, the WQMP for the project requires BMPs necessary to
control stormwater pollution from operational activities and facilities. The WQMP would be required
to be reviewed and approved by the City prior to issuance of building permits. As noted in the
WQMP for the project, Section 7.11-2.4.3 states, “Priority Projects must infiltrate, harvest and use,
evapotranspire, or biotreat/biofilter, the 85th percentile, 24-hour storm event (Design Capture
Volume),” which may be commonly referred to as the “first flush.” Appendix K details how BMPs are
designed to treat this amount of flow/volume generated from the project area; however, the body of
the RDEIR references the “first flush” and Mitigation Measure HYD-1b requires the WQMP to include
design concepts and BMPs intended to address the “first flush,” which will be reviewed and
approved by the City prior to issuance of building permits to ensure compliance.
In addition, an Operations and Maintenance Agreement described in Section V of the WQMP in
Appendix K of the RDEIR, has been submitted to the City. Section V of the WQMP designates the
owner of the project as the responsible party for maintaining the listed BMPs in the Operation and
Maintenance Agreement. In the event that ownership is to be transferred to an HOA, a formal notice
of transfer shall be submitted to the City in a WQMP amendment, which is consistent with
Mitigation Measure HYD-1b identified in RDEIR Section 3.9, Hydrology and Water Quality, page 3.9-
21, requiring BMPs in the WQMP to be reviewed and approved by the City prior to issuance of
building permits. Contrary to the commenter’s assertions, Appendix K is not vague or incomplete.
Moreover, the details of the BMPs required in the WQMP will be refined and reviewed and approved
by the City at the building permit stage.
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Until the HOA is formed, the Applicant, Milan Capital Management, will be responsible for the
inspection and maintenance of BMPs. As stated in Appendix K, “A Home Owners Association (HOA) will
be formed upon project completion. The HOA will be responsible for inspecting and maintaining all
BMPs prescribed for the Trails at Santiago Creek. Until an HOA is formally established, Milan Capital
Management shall assume all BMP maintenance and inspection responsibilities for the proposed
project. Inspection and maintenance responsibilities are outlined in Section V of this report.”
Response to SMW-27
The commenter states an opinion that runoff from the project site during operation has the
potential to create flooding conditions.
The project contains within its boundaries both FEMA “Zone AE” and FEMA “Zone X” areas. The
FEMA definition of Zone AE is a “Special Flood Hazard Area Subject to Inundation by the 1% Annual
Chance Flood.” This 1 percent Annual Chance Storm is known as the 100-year storm. The FEMA
definition of Zone X is “Other Flood Areas” which include “areas of 0.2% annual chance flood; areas
of 1% annual chance flood with average depths of less than 1 foot or with drainage areas less than 1
square mile; and areas protected by levees from the 1% annual chance flood.” The 0.2 percent
annual chance storm is known as the 500-year storm.
The 100-year flood hazard areas on the project site overlap with the Santiago Creek channel.
However, the project would establish a greenway along the creek corridor and would not alter the
existing 100-year flood hazard area. The areas mapped as 500-year flood hazard areas primarily
coincide with areas proposed for open space and recreation. Approximately 15 acres of the
residential portion of the project is on areas mapped as 500-year flood hazard areas; however,
applicable federal regulations permit residential uses in the 500-year flood elevation. The residential
uses would be raised above the flood elevation of Zone X.
The project would reduce the size of the ground surface area that is a tributary to Handy Creek, as
shown in the Preliminary Hydrology Report in Appendix K. The 100-year flood flow is contained
within the bed and banks of the existing creek.
The Proposed Condition Hydrology Map shows the sub areas east of Handy Creek are rearranged to
bypass Handy Creek and drain further to the west to sub area B6. The location of the proposed
condition in sub area labeled C8 lies over Handy Creek and measures 1.46 acres. Sub area C8 is a
tributary to Node 131, which is an inlet to Handy Creek. This rearrangement of sub areas reduces the
size of the ground surface area that is tributary to Handy Creek from 61.9 acres to 1.46 acres. This
calculation demonstrates that the conveyance capacity constraint of Handy Creek under the
proposed project condition, which would be reduced to less than significant level based on the
Preliminary Hydrology Report. Table 3.9-7 shows the existing and proposed discharge rates at Handy
Creek. As shown in the table, the existing 100-year runoff is 180.05 cfs and the proposed runoff is
82.72 cfs, for a reduction of 54.1 percent. As indicated in the table, the project will actually decrease
runoff due to the proposed detention basin, contrary to the statement of the commenter.
The commenter states an opinion that the existing hydrologic constraints are responsible for the
project’s potential to impact the downstream properties. However, contrary to the commenter’s
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opinion, the existing site hydrologic situation is well known and well documented. The project has
been designed to adapt to site constraints in such a way as not to exceed them. As concluded in the
Preliminary Hydrology Report for the project, and as reported in RDEIR Section 3.9, Hydrology and
Water Quality, the project would not result in downstream flooding.
Response to SMW-28
The commenter claims the RDEIR does not provide explanation as to how discharge rates were
calculated.
The Preliminary Hydrology and Hydraulics Report in Appendix K, and referenced throughout RDEIR
Section 3.9, Hydrology and Water Quality, includes detailed methodology of the analysis of
stormwater discharges during the 2-year event and 100-year event that were analyzed to assess
impacts for hydromodification (2-year) and flood control (100-year). As described in Appendix K, the
“study was prepared in conformance with the Orange County Hydrology Manual. The project site
100-year event Inflow Hydrographs were calculated for the pre and post development conditions
using the small area hydrograph method. These hydrographs were routed through the detention
basin for design of the detention facilities. A.E.S. Computer Software was utilized to compile the
hydrologic data and to determine the peak discharges and hydrographs.” This methodology is
summarized in the RDEIR under Impact HYD-3.
The proposed discharge rates compared to existing discharge rates are described in RDEIR Section
3.9, Hydrology and Water Quality, Table 3.9-6, Existing and Proposed Discharge Rates—Proposed
Storm Drainage System. The values presented in this table were extracted verbatim from Appendix
K.1, Preliminary Hydrology and Hydraulic Report, pages 6 and 7, which contain the source values.
Further, the Report presents a complete description of how all the values were calculated, including
assumptions and analytical methodology. The combination of the summary presented in Table 3.9-6
and the detailed report in Appendix K.1 is technically adequate for use by the public and decision
makers to ascertain the potential impacts related to flooding.
Response to SMW-29
The commenter states an opinion that achieving no net increase in discharge is not sufficient to
ensure downstream properties will not be affected by flooding.
As determined in the Preliminary Hydrology and Hydraulic Report in Appendix K of the RDEIR, the
project will not cause any changes in runoff as compared to existing conditions and the project will
not cause any impacts on downstream properties. See Response to SMW-27 above. As the project
would implement features that would mimic existing conditions runoff, the proposed project will not
alter or exacerbate downstream flooding impacts and project impacts would be less than significant.
Response to SMW-30
The comment suggests that the project comply with large municipal sewer system requirements.
The project is a part of the City of Orange MS4, which is considered a large MS4. Therefore, the
updated RDEIR correctly references the City of Orange MS4 jurisdiction. As the project is considered
a Priority Project as defined in the Model WQMP, and has prepared a WQMP highlighting proposed
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BMPs associated with the project, the project is in compliance with the NPDES permitting
requirements for the City’s MS4 regulations.
Response to SMW-31
The comment states an opinion that the RDEIR fails to explain how the project would comply with
MS4 regulations.
All BMPs to satisfy MS4 requirements, including detention and water quality BMPs, are included in
the project’s WQMP in Appendix K and the process to comply with the MS4 Permit is also
summarized under Impact HYD-1 of the RDEIR. Mitigation Measure HYD-1b requires the project to
comply with the Regional MS4 Permit and City of Orange WQMP requirements, including the use of
low impact development features to infiltrate, filter, store, evaporate, or retain runoff. For areas
where infiltration is not recommended or accepted, biofiltration features would be incorporated to
treat runoff and control effluent flows. Contrary to the commenter’s opinion, the project would be
required to comply with MS4 regulations.
Response to SMW-32
Please refer to Master Response 8—Site Environmental Conditions and Master Response 7—
Applicability of SMARA (based on last paragraph of Comment SMW-32).
Response to SMW-33
The commenter alleges generally that numerous sensitive wildlife species have been observed or
have the potential to occur on the site but the RDEIR fails to conduct focused surveys for such
species.
The general comment that the RDEIR does not address “numerous wildlife species,” is not specific
regarding the species of which the commenter is concerned. The RDEIR addressed potential impacts
to all species that were identified to have the potential to occur on-site and concluded that with
mitigation, impacts are less than significant. Because of the general nature of the comment, no
additional specific substantiation of analyses or impacts identified in the RDEIR can be provided.
Response to SMW-34
As stated in RDEIR Section 3.4, Biological Resources, subsection 3.4.2, page 3.4-15, focused protocol
surveys for the arroyo toad were conducted by Michael Brandman Associates (MBA) in 2008 and PCR
in 2010, during which no arroyo toads were found on-site. The 2010 protocol survey methodology,
data, and results are included in RDEIR Appendix G. Focused surveys were not repeated beyond 2010
due to the lack of suitable habitat for this species on-site, a determination that was based on the
expert opinion of a qualified biologist experienced in habitat assessments and in conducting focused
surveys for this species. Due to the lack of suitable habitat and due to the negative results of focused
surveys that were conducted in 2008 and 2010, this species is not expected to occur within the project
site. Additionally, there have been no new records of this species within Orange County subsequent to
the 2010 report, indicating that no new information has been available to suggest that updated studies
are needed, and it does not change the analysis of the proposed project on this species.
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Response to SMW-35
The commenter states an opinion that the RDEIR incorrectly failed to conduct focused surveys for
the yellow-breasted chat and failed to provide enforceable mitigation for the southern cottonwood
riparian forest.
Yellow-breasted chat is a California Species of Special Concern, and there is no survey protocol for
this species published by either the United States Fish and Wildlife Service (USFWS) or CDFW. This
species was identified as a species observed on-site during the numerous surveys conducted over
multiple years on the project site, as mentioned in RDEIR Section 3.4, Biological Resources,
subsection 3.4.2, page 3.4-15. Effects of the proposed project on special-status species such as
yellow-breasted chat are included in RDEIR Section 3.4, Biological Resources, subsection 3.4.6, page
3.4-38, which states: “The majority of the suitable habitat (e.g., southern cottonwood willow
riparian forest, coastal sage scrub, and other native habitats) within Santiago Creek and northern
portion of the project site which has potential to support special-status species will be avoided, and
the availability of contiguous habitat within the project site will continue to provide resources and
foraging habitat for these species, if present. Thus, the loss of individuals as a result of the proposed
project would not be expected to reduce regional population numbers. Therefore, impacts to these
sensitive wildlife species are considered adverse but less than significant and no mitigation measures
would be required.” Mitigation Measure BIO-3 would mitigate any potential impacts to the southern
cottonwood riparian forest by requiring the Applicant to demonstrate restoration or enhancement of
sensitive riparian communities at a ratio of 1:1 for permanent impacts. Consistent with the
commenter’s suggestion that the project mitigate permanent and temporary impacts, Mitigation
Measure BIO-3 requires temporary impacts to be restored to pre-project conditions.
Response to SMW-36
The commenter states an opinion that the temporary impacts to CDFW jurisdictional streambed and
riparian habitats are not properly identified as less than significant.
All temporary impacts to riparian habitat are required by RDEIR Mitigation Measure BIO-3 to be
restored to pre-project conditions following construction. As those pre-project conditions consist of
native species, naturally native species must be used for the restoration. The RDEIR characterizes
impacts as temporary and permanent to identify the nature of the impact, analyze it accordingly,
and determine appropriate mitigation to offset the impact. Temporary impacts will be restored to
pre-project conditions, which are the conditions that exist prior to implementation of the project,
including pre-project contours and vegetation. As suggested by the commenter, Mitigation Measure
BIO-3 requires replacement with native vegetation. Additionally, the regulatory agencies, CDFW and
USACE, require their permits to include both temporary and permanent impacts with corresponding
appropriate mitigation that mandate the planting of native species.
Response to SMW-37
The commenter requests that all vegetation in the setback area be native.
The proposed “setback area” involves planting a landscaping and fuel modification area where there
is currently little to no vegetation due to the previous backfill and stockpiling operations (which are
not a part of the proposed project) that had been ongoing for years and caused the currently
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disturbed, denuded conditions on-site. The planting of native and non-native vegetation would
ostensibly improve the existing conditions of the project site by creating more habitat for native
plants and wildlife. Native plants will be incorporated into the plant palette, and although
appropriate non-native landscaping species may also occur within this area, the proposed project
will not use plants identified as invasive exotic species by California Invasive Plant Council (Cal-IPC)
Invasive Plant Inventory within the landscape plan.
The setback area is intended to provide a vegetative buffer from the southern cottonwood-willow
riparian forest within Santiago Creek, which provides habitat for the least Bell’s vireo. It is not
intended to provide habitat for the least Bell’s vireo itself. Therefore, contrary to the commenter’s
assertion, it is not required to contain native vegetation exclusively.
Response to SMW-38
The commenter requests temporary impacts to wetland and riparian habitat to be mitigated at a 2:1
ratio and for only native species to be planted.
Impacts are characterized as temporary and permanent in the RDEIR to identify the nature of
specific impacts, analyze them accordingly, and determine appropriate mitigation to offset impacts.
Temporary and permanent impacts were both fully evaluated. As discussed in RDEIR Section 3.4,
Biological Resources, pages 3.4-51 and 3.4-52, temporary impacts will be restored to pre-project
conditions immediately after the necessary work is completed and these areas will remain in the
same location with the same conditions that occurred prior to the project. Permanent impacts will
permanently remove the resource; thus, mitigation must take place at another on-site and/or off-
site location and more planning is required to determine the appropriate conditions that must be
available for the mitigation to take place and to be successful over time (e.g., soil conditions,
hydrology, surrounding vegetation types, etc.). Thus, a higher mitigation ratio of 2:1 is proposed to
account for the loss of the resource from the time when impacts occur to the time when the
resource will be fully mitigated and replaced.
As stated above in Response to SMW-36, temporary impacts will be restored to pre-project
conditions, which are the conditions that exist prior to project implementation, including pre-project
contours and vegetation assemblages.
In response to the commenter’s concern that Mitigation Measure BIO-4 calls for revegetation with
native species “where appropriate,” the map of jurisdictional features was created at a broad scale,
and there may be portions of the jurisdictional feature that are unvegetated or contained non-native
vegetation. Prior to any work in the area, the biological monitor can photograph and record the
vegetation composition of proposed areas to be impacted in finer detail to document the pre-project
conditions. Mitigation Measure BIO-4 is written to allow for this fine-tuning, which is why the language
“where appropriate” was included (in case impacts occur in unvegetated areas). The intent of the
mitigation measure is to commit the project to restore temporary impacts to pre-project conditions or
better, and to replace native vegetation with native vegetation, as requested by the commenter.
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Response to SMW-39
The commenter states an opinion that the RDEIR fails to provide analysis of cumulative biological
impacts.
As stated in RDEIR Section 3.4, Biological Resources, on page 3.4-4, the proposed project has the
potential to have a significant impact on the least Bell’s vireo and nesting birds. Mitigation Measures
BIO-2a through BIO-2d would require pre-construction surveys for these species and
implementation of protection measures if they are found to be present. Some of the other projects
listed in RDEIR Section 4, Cumulative Effects, Table 4-1, Cumulative Projects, are located on sites with
similar biological attributes and, therefore, would be required to mitigate for impacts on
special-status wildlife species in a manner similar to the proposed project. The required mitigation
would reduce the project’s contribution to any significant cumulative impact on special-status
wildlife species and the project’s contribute would not be cumulatively considerable, as none of
these species are expected to drop below a sustainable level.
In addition, Mitigation Measure BIO-2b would require that for permanent grading impacts to least
Bell’s vireo habitat, on-site or off-site restoration or enhancement of least Bell’s vireo habitat would
occur at a ratio no less than 3:1. Thus, with implementation of this mitigation measure, there will be
a net increase in habitat to support the least Bell’s vireo, and cumulative impacts to this species
would not be cumulatively considerable and therefore would be less than significant.
The proposed project has the potential to have a significant impact on sensitive riparian
communities and wetlands. Mitigation Measures BIO-3 and BIO-4 are proposed requiring restoration
or replacement of disturbed features. Some of the other projects listed in RDEIR Section 4,
Cumulative Effects, Table 4-1, Cumulative Projects, are located on sites with similar biological
attributes and would be required to mitigate for impacts on sensitive riparian communities and
wetlands. The required mitigation would reduce the project’s contribution to any significant
cumulative impact on sensitive riparian communities and wetlands to less than cumulatively
considerable. All other project-related biological resource impacts (e.g., wildlife movement,
conservation plans) were found to be less than significant and did not require mitigation.
Contrary to the commenter’s assertion, the project would not result in cumulatively considerable
impacts with respect to biological resources impacts. The RDEIR fully analyzed all potential biological
resources impacts and provided mitigation where necessary. The full biological discussion relative to
cumulative impacts can be found in RDEIR Section 3.4, Biological Resources, pages 3.4-3 and 3.4-4.
Response to SMW-40
The comment describes the City’s regulations with respect to tree removal. The comment is noted
but does not warrant a response.
Response to SMW-41
The commenter states an opinion that the tree removal is a “large scale tree removal” and disagrees
that replanting trees would result in a less than significant project impact.
Only those trees within the project footprint or within the immediate vicinity of the project footprint
were surveyed, and these trees comprise only a small fraction of the total number of trees within
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the project site boundary, most of which will be completely avoided by the project. As such, the
impacts associated with project construction and implementation are not considered “large scale
tree removal” when the total number of trees on the project site are taken into account. With the
exception of those trees within Santiago Creek that will be impacted by the installation of the storm
drain outlet, the majority of the on-site trees that will be impacted are scattered and therefore
provide a lower ecological value as habitat. These scattered trees also include a large number of
non-native tree species (e.g., bottlebrush (Callistemon citrinus) and gum tree (Eucalyptus globulus).
The City requires a 1:1 mitigation replacement ratio for all trees that would be removed by the
proposed project, and compliance with the existing regulations outlined in the City of Orange
Municipal Code, Chapter 12.32—Tree Preservation would reduce impacts to regulated trees to a
less-than-significant level (see also RDEIR Section 3.4, Biological Resources, pages 3.4-58 through
3.4-61).
Response to SMW-42
Please see Response to SMW-41.
Response to SMW-43
Comment acknowledged. It is not clear specifically what is being referred to as the number of truck
trips to prepare the site for development. The project trip generation is based on the most current
version of the ITE Trip Generation Manual (10th Edition2017), which is the appropriate reference
manual to determine the Project trip generation forecast and is consistent with the City of Orange
Traffic Impact Analysis Guideline requirements. See Master Response 9—Soil Import/Export
Numbers for a discussion of the amount of earthwork required to implement the project.
Response to SMW-44
See Master Response 9—Soil Import/Export Numbers
Response to SMW-45
The commenter questions the RDEIR’s trip generation based on a “Materials Recycling and
Backfilling Operation Trip Credit.” The commenter asks why the RDEIR relies on the year 2010 to
determine trip credit rather than year 2011.
The “Materials Recycling and Backfilling Operation” was based on traffic counts conducted during
normal operation in October/November 2010 and adjusted to account for 7:00 a.m. to 7:00 p.m.
operation. The materials recycling and backfilling operation was one of two trip generation scenarios
analyzed in the TIA. It excluded credit for the existing sand and gravel operation and is used to
illustrate the typical entitled traffic condition.
Given that the Sand and Gravel operation was suspended prior to preparation of the TIA, traffic
counts could not be retaken and the 2010 data, which is reliable and reflects entitled conditions, was
used in the TIA. Given that the Sand and Gravel operation was at its peak in 2011, the 2010 data
underestimates the potential trip credit for the entitled sand and gravel operation scenario and
therefore would be a conservative analysis.
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Response to SMW-46
The commenter states that materials recycling does not appear to be considered in trip generation
estimates. The TIA analyzes the project completion condition, which includes Planning Area D and
consists of the greatest trip generation condition. Because it represents conservative estimates of
impacts, materials recycling is not required to be included in the trip generation estimate.
Response to SMW-47
The commenter states concern for safety hazards caused by the project’s traffic. Construction of the
project will not significantly change roadway conditions, such that roadway safety would be
impacted beyond the current condition.
As stated in RDEIR Section 2, Project Description, page 2-55, current traffic volumes resulting from
the existing on-site rock crushing operation generates approximately 686 daily trips, of which over
500 of those trips is truck traffic. Further, the RDEIR indicates that “the project would require up to
275,400 haul trips during the 1.5-year grading period,” resulting in approximately 700 trips per day.
The potential project construction schedule/period is consistently referred to as 1.5 years to 4.5
years in the RDEIR; however, out of an abundance of caution and for purposes of providing the most
conservative analysis, a short time frame is used in certain instances. Thus, a conservative estimation
would result in a net increase of approximately 200 truck trips per day.
In compliance with City of Orange Municipal Code Section 12.36.050, a transportation permit will be
required to allow for the monitoring of truck traffic throughout the City, and to minimize the
potential of damage to City infrastructure by oversize and overweight vehicles. Pursuant to City of
Orange Municipal Code Chapter 10.67.030, transportation permits are also required in conjunction
with moving earth materials (dirt, sand and gravel). Per the City of Orange Grading Manual, permits
are issued when moving more than 500 cubic yards of material, or if moving on public roadways that
are not designated as approved City truck routes. Hauls in excess of 30,000 cubic yards requiring the
use of City streets require City Council approval and the possible provision of the following
additional measures:
• Periodic safety inspection of all haul trucks.
• A hold harmless agreement between the City of Orange and the grading contractor will be
required for vehicles hauling earth material to and from the project site.
• Flagmen and/or automatic traffic lights may be necessary as required by the City Traffic
Engineer.
• A cash deposit may be required to ensure against loss of pavement life along primary haul
routes.
• Furthermore, the City Traffic Engineer will be responsible for identifying and approving haul
routes for the project. Additionally, Chapter 10.66 of the City of Orange Municipal Code
identifies the following streets as fixed truck routes.
Anaheim Boulevard Chapman Avenue to North City Limits
Batavia Street Chapman Avenue to Lincoln Avenue
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Chapman Avenue West City Limits to East City Limits, except as otherwise limited
in City of Orange Municipal Code Section 10.66.030B
Collins Avenue Eckhoff Street to Glassell Street
City Drive, The South City Limits to North City Limits
Garden Grove
Boulevard
West City Limits to East City Limits
Glassell Street Collins Avenue to North City Limits
Katella Avenue West City Limits to East City Limits
La Veta Avenue Main Street to the eastbound ramp connections of the Garden
Grove Freeway (SR-22).
Lincoln Avenue West City Limits to East Santiago Canyon Boulevard
Main Street South City Limits to Chapman Avenue
Main Street Collins Avenue to Taft Avenue
Meats Avenue Glassell Street to Orange-Olive Road
Orange-Olive Road Glassell Street to Lincoln Avenue
Orangewood Avenue West City Limits to Eckhoff Street
East Santiago Canyon
Boulevard
Northbound off-ramp (East Santiago Canyon Boulevard/Nohl
Ranch Road) of the Costa Mesa Freeway (SR-55) to the
northbound on-ramp of the SR-55
East Santiago Canyon
Boulevard
West City Limits to Chapman Avenue
State College Boulevard Chapman Avenue to North City Limits
Taft Avenue West City Limits to Glassell Street
Town & Country Road Main Street to the eastbound on-ramp of SR-22
Tustin Street South City Limits to North City Limits
As noted in the table above, East Santiago Canyon Road is designated as a fixed truck route from the
west City limits to Chapman Avenue, which includes the portion of East Santiago Canyon Road
adjacent to the project site. East Santiago Canyon Road would be the anticipated truck route for
construction of the project, precluding any safety concerns identified by the City’s Traffic Engineer.
Response to SMW-48
The commenter states an opinion that the RDEIR fails to adequately analyze construction related air
quality impacts.
The RDEIR includes haul truck emissions in the impact analyses. Impacts AIR-2 and AIR-4 include
those emissions as shown in RDEIR Section 3.3, Air Quality, Table 3.3-8, Table 3.3-9, Table 3.3-17 and
Table 3.3-18. The appendix to this Final EIR includes emission estimates consistent with the
information in the referenced tables.
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As discussed in the RDEIR, the localized analysis is based on concentrated emissions around the
project site. The health risk assessment includes all sources of emissions, including construction
equipment and haul trucks, within 1,000 feet of the project site. Therefore, contrary to the
commenter’s assertions, the RDEIR addressed emissions from these sources.
The amount of earthwork used in the analysis of air quality emissions is consistent with the project
description and the Specific Plan. As discussed in Impact AIR-2, the project would import
approximately 877,000 cubic yards of new material, and remove 500,000 cubic yards of silt. As a
conservative estimate, it was assumed that each haul truck would have a capacity of 10 cubic yards per
load (plus the return of one empty truck). Based on this information, it was estimated that the project
would require up to 275,400 haul trips during the 1.5-year grading period. Haul truck emissions were
included in the analysis of regional emissions. The comment indicates, “the Project may expose nearby
sensitive receptors to an elevated health risk, which would likely require the preparation of a health
risk assessment.” However, as discussed in the Impact AIR-4, the RDEIR already includes a health risk
assessment that evaluates both on-road and off-road emissions sources.
The previous version of the modeling had the “Site Preparation” and “Grading” construction phases
as separate and overlapping phases. The revised modeling assumptions had a combined “Site
Preparation/Grading” phase with an increase in the total number of days for those phases to
account for the haul trips. The longer construction schedule resulted in a slight decrease in the daily
on-site emissions (the majority of haul truck emissions are off-site). With both the original modeling
in the DEIR and revised modeling in the RDEIR, the localized emissions would not exceed the
recommended thresholds of significance.
Response to SMW-49
The commenter states an opinion that the RDEIR fails to adequately mitigate energy related impacts.
CEQA requires an evaluation of whether energy consumption would be wasteful, inefficient, and
unnecessary. Both the discussion in RDEIR Section 3.18, Utilities, and Section 6, Other CEQA
Considerations, subsection 6.4, Energy Conservation, provide evidence of how the project, while
increasing energy consumption, would not be wasteful and inefficient by complying with federal,
State, and local requirements.
The RDEIR found that impacts related to energy consumption would be less than significant.
Therefore, mitigation measures are not required.
Response to SMW-50
The commenter argues that the RDEIR fails to adequately analyze and mitigate GHG emissions.
As described in RDEIR Section 3.7, Greenhouse Gas Emissions, page 3.7-21, of the RDEIR, the
project’s combined long-term operational emissions and amortized construction emissions would
generate approximately 1,921 metric tons (MT) carbon dioxide equivalent (CO2e) per year and would
not exceed the applicable South Coast Air Quality Management District (SCQMD) threshold of 3,500
MT CO2e per year. As such, the project’s generation of GHG emissions would not result in a
significant impact. Because the project’s generation of GHG emissions would not result in a
significant impact, no mitigation is necessary to the project’s generation of GHG emissions.
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The commenter states that the RDEIR provides “no analysis at all of the Project’s consistency with
state plans to reduce GHG emissions.” However, as described in the discussion under Impact GHG-2,
the project would not conflict with the California Air Resources Board (ARB) adopted Assembly Bill
32 (AB 32) 2008 Scoping Plan.
Response to SMW-51
Please refer to Master Response 1—Plan Consistency.
As described in RDEIR Section 3.7, Greenhouse Gas Emissions, page 3.7-25, the project would not
conflict with the City of Orange General Plan. Natural Resources Policy 3.2 is a policy for the City of
Orange to develop and adopt a comprehensive strategy to reduce GHG emissions within Orange by
at least 15 percent from current levels by 2020. This specific policy is for the City to develop and
adopt a GHG reduction plan. As stated in RDEIR Section 3.7, Greenhouse Gas Emissions, page 3.7-22,
the City of Orange had not adopted a GHG reduction plan at the time of the analysis, and this policy
cannot be implemented by an individual development project. CEQA does not require a project
analysis to quantify all possibilities in which GHG emissions could be “avoided.” Rather, the RDEIR
provides a discussion of the overall project characteristics that support consistency with the General
Plan. Since the project would not conflict with the ARB Scoping Plan or the City of Orange General
Plan and would not exceed the applicable SCAQMD’s threshold of significance, the project would not
impede regional or State GHG reduction goals. This information is included in the summary
subsection of RDEIR Section 3.7, Greenhouse Gas Emissions, on page 3.7-25.
In addition, RDEIR Section 3.7, Greenhouse Gas Emissions, page 3.7-19, indicates that the
residential-specific draft SCAQMD thresholds of 3,500 MT CO2e per year for annual operational
emissions and amortized construction emissions would be used to evaluate whether the project’s
generation of GHG emissions would result in a significant impact on the environment. As described
in RDEIR Section 3.7, Greenhouse Gas Emissions, page 3.7-21, the combined long-term operational
emissions and amortized construction emissions from the project would generate approximately
1,921 MT CO2e per year and would not exceed the applicable SCQMD threshold of 3,500 MT CO2e
per year. This explanation was provided to support the conclusion that the project’s generation of
GHG emissions would not result in a significant impact.
The commenter provides a general statement with no supporting evidence that the project is
“clearly inconsistent” with the General Plan. As described in RDEIR Section 3.7, Greenhouse Gas
Emissions, page 3.7-25, the project would not conflict with the City of Orange General Plan and
would be consistent with the goals and policies adopted for the purposes of reducing the emissions
of GHGs contained within the City’s General Plan.
Response to SMW-52
The commenter argues that the RDEIR fails to analyze project consistency with State plans to reduce
GHG emissions.
The project was assessed for its consistency with the ARB adopted AB 32 Scoping Plan under Impact
GHG-2. In addition, because the project’s combined long-term operational and amortized
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construction emissions would not exceed the applicable threshold of significance recommended by
the lead agency, the project would not impede regional and state GHG reduction goals.
The commenter provides examples from the San Diego Association of Governments (SANDAG)
Regional Transportation Plan (RTP) EIR as a methodology for estimating emissions based on a
threshold, but fails to provide how a regional plan (from another county) would translate into a
project-level analysis. As stated in RDEIR Section 3.7, Greenhouse Gas Emissions, page 3.7-25, the
thresholds of significance are considered an allowable amount of emissions under which a project
would not impede regional or State GHG reduction goals. The project’s combined long-term
operational and amortized construction emissions would not exceed the applicable SCAQMD
threshold of significance.
The analyses contained within Impacts GHG-1 and GHG-2 adequately addressed the project’s GHG
and climate change impacts. Both impacts were found to be less than significant; therefore, no
mitigation is required.
Response to SMW-53
The commenter states an opinion that the RDEIR fails to identify construction related noise impacts.
The construction noise impact analysis contained in RDEIR Section 3.12, Noise, pages 3.12-20 and -
21 analyzed the “reasonable worst-case” noise impacts from construction activity on the project site
to sensitive receptors in the project vicinity. The analysis identified that the closest sensitive receptor
to the project construction footprint would be the residential land uses located directly east of the
project site. The analysis identified that these homes would be located as near as 100 feet from the
center of the nearest construction footprint where multiple pieces of heavy equipment could be
operating simultaneously. The analysis further identified that, at this distance, the loudest
construction activities could be expected to result in noise levels ranging up to approximately 84 A-
weighted decibel (dBA) maximum noise/sound level (Lmax) intermittently when multiple pieces of
heavy construction equipment operate simultaneously at the nearest center of construction activity.
The analysis concluded that “compliance with the City’s permissible hours of construction, as well as
compliance with best management practices, construction noise reduction measures outlined in
Mitigation Measure (MM) NOI-1a, would ensure that construction noise would not result in sleep
disturbance of sensitive receptors or exposure of persons to noise levels in excess of established
standards.” Since the analysis determined that construction noise impacts would be less than
significant for the closest sensitive receptors located only 100 feet from the construction footprint, it
can reasonably be concluded that impacts to receptors further from the project site (such as the
Salem-Lutheran Church and School located over 600 feet from the nearest construction footprint)
would be similarly reduced to less than significant with implementation of Mitigation Measure NOI-
1a. Therefore, the conclusion that all project-related construction noise impacts would be reduced
to less than significant with implementation of Mitigation Measure NOI-1a remains valid.
Response to SMW-54
The commenter alleges that the RDEIR fails to adequate address the project’s growth-inducing
impacts.
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The RDEIR acknowledges that the surrounding area is already developed with infrastructure and
housing. RDEIR Section 2, Project Description, Exhibit 2-5, Surrounding Properties with Lot Sizes
under 10,000 square feet, depicts the location of lots less than 10,000 square feet in size, which
surround the project site to the north west and southwest. The Reserve Community to the east is, as
the commenter points out, comprised of larger lots (20,000-44,000 square feet). It should be noted
that the Reserve Community is currently bordered by smaller lots to the south, which has not
resulted in requests for subdivision. Any such application would have to undergo environmental
review and processing by the City of Orange.
The proposed project would develop 128 dwelling units, which would add 393 persons to the City of
Orange’s population, which represents an increase of 0.3 percent relative to the City’s population of
141,420. A portion of the project site is currently designated for residential use by the City of Orange
General Plan and Orange Zoning Ordinance and, thus, is contemplated to support population
growth. Growth inducement impacts were found to be less than significant. Please refer to Master
Response 1—Plan Consistency.
Response to SMW-55
Please see Master Response 8—Analysis of Alternatives.
Response to SMW-56
Please see Master Response 3—Analysis of Alternatives.
Response to SMW-57
Please see Master Response 1—Plan Consistency
Response to SMW-58
Please see Master Response 3—Analysis of Alternatives.
Response to SMW-59
Please see Master Response 3—Analysis of Alternatives.
Response to SMW-60
Please see Master Response 3—Analysis of Alternatives.
Response to SMW-61
Please see Master Response 3—Analysis of Alternatives.
Response to SMW-62
The commenter argues that the RDEIR should be recirculated because significant new information is
presented and the EIR is inadequate. Contrary to the commenter’s assertion, significant new
information is not presented; instead, the information contained in these responses is amplifying
and clarifying information, and the information presented in the RDEIR is adequate. Therefore,
recirculation is unnecessary.
Response to SMW-63
Please see Master Response 9—Soil Import/Export Numbers.
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Response to SMW-64
Please see Master Response 9—Soil Import/Export Numbers.
Response to SMW-65
Please see Master Response 9—Soil Import/Export Numbers.
Response to SMW-66
The commenter asks whether the backfill operation identified in Appendix I is a component of the
proposed project or separate from the project.
These comments refer to Appendix I, Geotechnical Investigation from 2011, which reflects that
previously mined portions of the site were “backfilled,” in which unsuitable materials were
excavated and replaced with fill. Backfilling is not proposed as part of the project. The information
provided in Appendix I relates to the larger Rio Santiago Specific Plan analysis. The purpose of
including this information from the Rio Santiago Specific Plan project is not to identify contradictory
cut and fill numbers, but to provide additional support for the characterization of subsurface soils
and the likely methods of construction required.
Response to SMW-67
The comment asks whether the silt pond excavation, spreading, and mixing activity that occurred in
2011 was eliminated from the project and why backfilling would occur for 391 days, compared to the
Rio Santiago EIR, which estimated backfilling would be 1,129 days. These comments refer to
Appendix I, Geotechnical Investigation from 2011. The information provided in Appendix I relates to
the larger Rio Santiago Specific Plan analysis. The purpose of including this information from the Rio
Santiago Specific Plan project is not to identify contradictory cut and fill numbers, but to provide
additional support for the characterization of subsurface soils and the likely methods of construction
required.
In 2011 when the Rio Santiago Project was analyzed, previously mined portions of the site were used
for residue silt deposition, otherwise known as silt ponds. As stated in RDEIR Section 2, Project
Description, page 2-2, the previously mined portions of the site were “backfilled,” in which
unsuitable materials were excavated and replaced with fill, pursuant to a Grading Permit No. 2047
issued by the City of Orange in 2011. It was anticipated that approximately 223,000 cubic yards of
material was imported to the site during the process, including concrete, asphalt and rock that was
crushed on-site. Approximately 2,000 cubic yards of material was excavated from the site for reuse
and blended with the crushed import material for a total of 225,000 cubic yards of backfill. In 2015,
in a “good faith” gesture, the property owner voluntarily temporarily suspended operations on the
site, and limited rock crushing operations to a total of 15 consecutive business days in any 6-month
period. As a result of backfilling between 2011 and 2018, the backfilling activities that would be
required to implement the project would be estimated to occur for 391 days. The duration is shorter
than what was required for the Rio Santiago Project because backfilling has continued since 2011.
While backfilling is a permitted use, it is not proposed as part of the project.
Response to SMW-68
The commenter asks why the RDEIR relies on technical appendices from the Rio Santiago Project.
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The information provided in Appendix I relates to the larger Rio Santiago Specific Plan analysis, as
the commenter points out. The purpose of including this information from the Rio Santiago Specific
Plan project is not to identify contradictory cut and fill numbers, but to provide additional support
for the characterization of subsurface soils and the likely methods of construction required. Contrary
to the assertions of the commenter, the RDEIR did not rely on grading details prepared for an
entirely different project.
Response to SMW-69
Please see Response to SMW-45 and SMW-46.
Response to SMW-70
Please see Response to SMW-45 and SMW-46.
Response to SMW-71
Please see Response to SMW-45 and SMW-46.
Response to SMW-72
See Master Response 1—Plan Consistency. As discussed in Master Response 1, the project is
consistent with the General Plan and therefore, does not violate State Planning and Zoning Law,
contrary to the commenter’s assertion.
Response to SMW-73
The comment is a concluding statement summarizing the other comments set forth in the letter.
Responses have been prepared to all of the referenced comments.
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Wittwer Parkin LLP (Wittwer_Parkin)
Response to Wittwer Parkin-1
Comment noted. The comment consists of a description of the project and introductory remarks
that do not raise any comments or questions about the environmental analysis. The responses set
forth below respond to all of the particular comments submitted in this letter.
Response to Wittwer Parkin-2
Please refer to Master Response 2—Adequacy of the Project Description, and Master Response 6—
Stewardship of Open Space. OC Parks, the HOA, a conservancy, a non-profit, or another entity will be
responsible for maintenance and management of the Specific Plan’s open space. The project
Applicant will enter into an agreement with the HOA, non-profit, public agency, conservancy, or
similar entity, prior to approval of the Tentative Map for the project, to ensure that responsibility for
construction of improvements and maintenance is adequately addressed. In the event the applicant
conveys the open space grasslands and trails to OC Parks, the applicant will enter into an MOU with
OC Parks prior to approval of the Tentative Map for the Project. The agreement will include a funding
mechanism to ensure adequate funding of open space improvements and subsequent maintenance.
Response to Wittwer Parkin-3
As explained in the RDEIR, the project Applicant requests the approval of the draft Specific Plan.
Once approved, the City of Orange shall monitor compliance with the adopted Specific Plan and
mitigation measures during the Major Site Plan Review and Design Review processes. (The Trails at
Santiago Creak Specific Plan, page 8-4.) Specifically, following the review and approval by the City of
Orange of the Trails at Santiago Creek Specific Plan, a Tentative Tract Map will be submitted for
Major Site Plan Review by the City in compliance with Section 17.10.060, Site Plan Review, of the
City of Orange Municipal Code. Detailed plans for future implementing projects in the Trails at
Santiago Creek Specific Plan area will be submitted to the City for Design Review approval, in
accordance with the policies and procedures of the Orange Municipal Code Section 17.10.070,
Design Review.
Response to Wittwer Parkin-4
Please refer to Master Response 8—Site Environmental Conditions, and Master Response 9—Soil
Import/Export Numbers. Backfilling on the site was considered in the pre-development agreement
and is properly included in the project description and accompanying analysis. The RDEIR fully
analyzes potential impacts from backfilling.
The Proposed Site Plan includes an exhibit of the proposed residential land development
configuration for the Trails Site. (RDEIR Section 2, Project Description, page 2-47, Exhibit 2-11.) The
proposed grading will conform to this configuration. In the exhibit, note that a gap (tan color) is
proposed along the property line between and the existing landfill site and the proposed residential
lots. On the Trails side of the property line, this gap is to be graded to match the existing grades
along the property line and to accommodate the proposed drainage pattern as described in the
Proposed Condition Hydrology Map, Appendix 7. On the Landfill side of the property line, the ground
surface will not be disturbed by Trails Site surface grading or by Trails Site subsurface grading. The
project will require a grading permit.
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Response to Wittwer Parkin-5
As stated in the RDEIR, it is the intent of The Trails at Santiago Creek to provide a recreational trail
system for the benefit of the community of Orange and the general public, as well as the project’s
residential neighborhood. The intent of the trail system is to be an integral part of the City’s and
County’s trail master plans via connectivity opportunities. (RDEIR Section 2, Project Description, page
2-61.)
To this end, the REIR states that the “project includes a variety of public multi-use recreation trails
that will traverse the project site, providing shared use of hiking, biking, and horseback riding on
decomposed granite trail surfaces.” (RDEIR Section 2, Project Description, page 2-61.) The RDEIR also
provides a visual depiction of the conceptual location, extent, and number of trails included in the
project in Exhibit 2-11: Preliminary Greenway, Open Space and Trails Plan. Additionally, the trails are
described in detail in Section 2, Project Description, pages 2-50, 2-52, and 2-61. The Santiago Creek
Trail is included in the discussion as Trail C. The conceptual plan and description of each trail
provides sufficient detail for a complete discussion of the trail system.
The RDEIR explains that throughout the open space in Planning Areas A and B, a network of 10-foot-
wide multi-use recreation trails will provide public access to the restored open space and the
Santiago Creek environs. (RDEIR Section 2, Project Description, page 2-61.) The project’s trail system
will connect to the existing Santiago Creek Trail along the northern boundary and on the west side at
Cannon Street Trail access to the residential neighborhoods in PA-C will be via a number of trail
paseos allowing for hiking and bicycling access, and via the Handy Creek Linear Park in PA-B. With
the exception of Trail A (in Planning Area B paralleling East Santiago Canyon Road) and Trail F (in
Planning Area B north of Planning Area C and with multiple uses as recreation trail, fuel modification
maintenance and emergency vehicle access) final trail design, alignment and points of connectivity
with existing and future adjacent trails will be accomplished through a collaborative effort involving
the City of Orange, the Orange Park Acres Trail Committee, the Santiago Creek Greenway Alliance,
Orange County Parks, and representatives of the Applicant. However, contrary to the commenter’s
assertion, the RDEIR adequately describes and characterizes proposed trails. For a discussion of the
detail required in an EIR, refer to Master Response 2—Adequacy of Project Description.
Response to Wittwer Parkin-6
Project impacts to biological resources are analyzed in detail in RDEIR Section 3.4, Biological
Resources, subsection 3.4.6. A summary of total impacts to natural communities is shown in RDEIR
Section 3.4, Biological Resources, Table 3.4-3 on page 3.4-48. The proposed project will impact the
sensitive southern cottonwood-willow riparian forest, including 0.10 acre of on-site permanent
impacts within the limits of grading, as well as 0.04 acre of permanent impacts, and 0.05 acre of
temporary impacts due to installation of an on-site storm drain outlet. Impacts to special-status
species (and their habitat) are analyzed in RDEIR Section 3.4, Biological Resources, subsection 3.4.6,
pages 3.4-38 through 3.4-48. The proposed project will permanently impact less than 0.01 acre of
federal wetland. Impacts to wetlands are adequately analyzed in RDEIR Section 3.4, Biological
Resources, subsection 3.4.6, pages 3.4-51 to 3.4-52. As discussed, impacts would be less than
significant with mitigation. Please refer to Response to SMW-38 and SMW-39 for further detail.
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Response to Wittwer Parkin-7
The enhancements agreed to in the Development Agreement and identified on ES-5 and ES-6 are
design features of the project and are analyzed as such throughout the RDEIR. Contrary to the
commenter’s assertion, the project’s design features are not mitigation measures, nor are they
required to be identified as mitigation measures. A feature built into the design or operation of a
project that will reduce or avoid an environmental impact that might otherwise occur is not treated
as a mitigation measure. (See, e.g., Wollmer v. City of Berkeley (2011) 193 Cal.App.4th 1329, 1352.)
The project’s design features are appropriately analyzed as part of the project, since alternatives to
the project would not be subject to the same development agreement terms.
Response to Wittwer Parkin-8
The commenter requests all required State approvals be listed in the EIR. All known and anticipated
project approvals are listed in the RDEIR and the Specific Plan. RDEIR Section 2, Project Description,
subsection 2.5.2, identifies those State and federal agencies that may be required to grant approvals
or coordinate with other agencies. The RDEIR discusses the potential approvals that may be required
of each of these agencies in the relevant impact discussions.
Response to Wittwer Parkin-9
The Rio Santiago Project, contemplated in 2013, proposed more intensive land uses than the current
project, including a 395 residential units and a YMCA-type facility with outdoor swimming pools, an
Autism Center, sports courts, and playfields. The RDEIR is not required to analyze or disclose the
City’s previous decision not to approve the Rio Santiago Project. All environmental impacts of the
project are analyzed in the RDEIR. A comparison to analysis and impacts of the Rio Santiago Project
is not required or warranted.
Response to Wittwer Parkin-10
The baseline condition includes 30 days of rock crushing trips per year because the rock crushing
operation would reoccur approximately 30 days throughout the year. Therefore, it is unnecessary to
evaluate rock crushing 365 days per year as the baseline condition, as suggested by the commenter.
However, as discussed in the RDEIR, the site’s current grading permit allows backfilling operations to
occur year-round. Should entitlement of the project not succeed, the property owner reserves the
right to resume all rock crushing operations consistent with the Sand and Gravel zoning and
grandfathered uses of the property, which would not require environmental review.
Response to Wittwer Parkin-11
Project impacts related to aesthetics are analyzed in detail in RDEIR Section 3.1, Aesthetics, Light and
Glare. As stated on page 3.1-8 of the RDEIR, the only portion of the project site that could be
considered a scenic vista is the Santiago Creek Trail along the north bank of Santiago Creek. (The trail
passes through several heavily vegetated areas, which limits viewpoint opportunities.) The balance
of the project site is closed to public access and secured with a fence. A greenway would be
established along the creek corridor and the undeveloped land along the north bank of the creek
would be permanently protected as open space. Thus, scenic views from the Santiago Creek Trail
would not be affected by the project. As requested by the commenter and in order to clarify the
impact analysis contained in the RDEIR, an exhibit showing views of the project site from the trail is
provided in Section 4, Errata, of this Final EIR.
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Response to Wittwer Parkin-12
The RDEIR evaluates whether the loss of trees may result in a significant aesthetic impact. The
discussion regarding Impact AES-2 explains that there are 323 trees located on the project site, and
that while development of the project would change the character of approximately 40.7 acres of
the project site to residential uses, these changes would not result in a significant impact because of
the extensive remaining open space and preserved greenway (RDEIR Section 3.1, Aesthetics, Light,
and Glare, page 3.1-9). Further, the RDEIR explains that the project would be consistent with City
policies related to aesthetics and that the proposed project would follow the City of Orange Tree
Preservation Ordinance by replacing any removed trees in a no-less-than 1:1 ratio. (RDEIR Section
3.1, Aesthetics, Light, and Glare, page 3.1-2.) As discussed in the RDEIR, compliance with the City’s
Tree Preservation Ordinance would result in less than significant impacts. Further discussion of on-
site trees is also found in Section 3.4, Biological Resources.
Response to Wittwer Parkin-13
The statement in the RDEIR that “[o]ther areas of the Code related to aesthetics are not applicable
to the proposed project . . .” illustrates that there are no other areas of the Municipal Code that are
relevant to this project. As explained in the RDEIR, the Residential Infill Guideline does not apply to
the proposed project because the proposed project is a subdivision consisting of more than four lots.
Additionally, the proposed project includes a Specific Plan, which provides for the systematic
development of the project consistent with the existing community and in accordance with the
Planning Community Zoning. Contrary to the commenter’s assertion, the aesthetics discussion is not
based upon a hypothetical approved project scenario as the baseline. The baseline is existing
conditions. The analysis simply states that the Specific Plan will create design standards that meet
the Planning Community Zoning standards.
Response to Wittwer Parkin-14
Change in the visual character alone does not demonstrate a potentially significant impact. The
discussion in impact AES-2 relating to visual character and quality is based on several factors. The
aesthetics analysis discusses how the project would change the existing visual character of the site
from a rock and concrete materials recycling and backfilling operation into an environmentally
enhanced, ecologically friendly open space environment with well-planned and attractive single-
family detached residential neighborhood. The analysis recognizes that the approximately 109-acre
site contains already disturbed, undeveloped land that previously supported mining activities. Under
the project, 69.2 acres, the majority of the site, would be enhanced and maintained as open space.
The RDEIR also notes that residential uses are adjacent to the project site and that the project’s own
residential development would be consistent with the existing residences, demonstrating that
introducing similar residential uses will not substantially degrade the existing environment.
Moreover, the discussion notes that the residential uses would only occupy 40.7 acres in the
southern and western portion of the site, coinciding with the former mining area and an oval-shaped
raised pad. After discussing these elements of the project, the analysis concludes that the project
would not substantially degrade the existing visual character of the site or its surroundings. The
commenter does not provide any evidence to substantiate the opinion that the project would impact
views from Santiago Creek and East Santiago Canyon Road, while the RDEIR provides ample analysis
to support the conclusion that the project would not substantially degrade the existing visual
character of the site or its surroundings.
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Response to Wittwer Parkin-15
Contrary to the commenter’s assertion, and according to the SCAQMD Air Quality Analysis
Handbook, the only case where the significance thresholds for project specific and cumulative
impacts differ is the Hazard Index (HI) significance threshold for toxic air contaminant (TAC)
emissions. Projects that exceed the project-specific significance thresholds are considered by the
SCAQMD to be cumulatively considerable. This is the reason project-specific and cumulative
significance thresholds are the same, absent the HI significance threshold. Conversely, projects that
do not exceed the project-specific thresholds are generally not considered to be cumulatively
significant. No revisions to the analysis are necessary.
Response to Wittwer Parkin-16
See Response to Comment Wittwer Parkin-15. The commenter cites provisions of the CEQA
Guidelines but does not provide specific suggestions or direction on how the commenter believes
the analysis should be revised. The analysis of project specific and cumulative air quality impacts is
technically adequate and does not require revisions.
Response to Wittwer Parkin-17
The potentially significant impacts in the DEIR are based on regional oxides of nitrogen (NOX)
emissions during construction activities and diesel PM exhaust that could result in a potential health
risk during construction activities. Mitigation Measure AIR-1g would require the use of Tier 4 engines
for on-site equipment, which would reduce both NOX and PM exhaust emissions. The determination
in the RDEIR that project impacts are significant and unavoidable regarding NOX is due to the use of
Tier 4 Final engines, which would reduce NOX emissions but would not reduce NOX emissions below
the threshold. Therefore, impacts remain significant and unavoidable for NOX. This conclusion that
the project’s impact is unavoidable applies only to NOX.
Response to Wittwer Parkin-18
See Response to Comment SCAQMD-7. Since NOX emissions are significant and unavoidable with the
use of Tier 4 Final engines, the use of lower tier engines, even in limited use, would not change the
findings in the EIR.
Response to Wittwer Parkin-19
Please see Master Response 9—Soil Import/Export Numbers. As the commenter notes, the project
would generate 275,400 haul trips. Further, the RDEIR indicates that “the project would require up to
275,400 haul trips during the 1.5-year grading period,” resulting in approximately 700 trips per day. For
a response to the commenter’s question about the baseline for rock crushing, please refer to
Response Wittwer Parkin-10 above.
Response to Wittwer Parkin-20
RDEIR Section 3.3, Air Quality, Tables 3.3-8 and 3.3-9 both included estimates of VOC and NOX
emissions, the components of ozone, and compare those emissions to the recommended thresholds.
Since ozone is a regional pollutant that is based on a mixture of pollutants and sunlight, it is not
possible to estimate ozone impacts at a project level and no such thresholds exist for the purposes of a
CEQA analysis. Appendix F to the RDEIR includes emission estimates consistent with the information in
the referenced tables. The data for Table 3.3-1 is typically delayed and not available until the middle of
the following year. Therefore, the data for 2017 is now available, but the data for 2018 will not be
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available until sometime later in 2019. As a clarification to the information presented in the RDEIR, the
table will be revised in the Final EIR (FEIR) to include data for the year 2017.
Response to Wittwer Parkin-21
As discussed in Impact AIR-2, the project would import approximately 877,000 cubic yards of new
material, and remove 500,000 cubic yards of silt. As a conservative estimate, it was assumed that
each haul truck would have a capacity of 10 cubic yards per load (plus the return of one empty
truck). Based on this information, it was estimated that the project would require up to 275,400 haul
trips during the 1.5-year grading period. Haul truck emissions were included in the analysis of
regional emissions. Therefore, contrary to the commenter’s assertion, hauling trips were accounted
for in the Air Quality Analysis conducted for the project and construction impacts were not
underestimated. As discussed in the Impact AIR-4, the RDEIR already includes a health risk
assessment that evaluates both on-road and off-road emissions sources.
Response to Wittwer Parkin-22
The LST analysis only considers localized emissions, and it would not be appropriate to include the
entire length of vehicle trips and all mobile source emissions in the localized analysis. As shown in
RDEIR Section 3.3, Air Quality, Table 3.3-12, the maximum daily disturbed acreage is 4 acres.
Therefore, LSTs for a 2-acre site and a 5-acre site were obtained and interpolated to determine an
appropriate threshold to measure localized construction impacts.
Response to Wittwer Parkin-23
RDEIR Appendix G (Biological Resources Assessment) contains thorough tables of special-status plant
and wildlife species that include site-specific information and whether the species was observed, has
the potential to occur, or is not expected to occur on-site. Habitat assessments and observations of
special-status species were based on multiple years of extensive focused protocol surveys conducted
from 2010 through 2017, as summarized in RDEIR Appendix G (Biological Resources Assessment)
(refer to pages 26 through 28).
Impacts to special-status species (and their habitat) are analyzed in RDEIR Section 3.4, Biological
Resources, subsection 3.4.6, pages 3.4-38 through 3.4-48. This section of the RDEIR discusses at
length whether suitable habitat occurs on-site to support special-status species, whether these
species were observed on-site during extensive surveys, and whether project impacts were found to
be significant for species that were present or have the potential to occur on-site. The RDEIR
biological surveys and discussion of project impacts to those biological resources is sufficient to
identify the presence of special-status species at the level of accuracy and clarity required under
CEQA. The commenter’s opinion that there is not sufficient detail to determine impacts and that
there have been “numerous sightings” of species on the project site is unsupported by evidence or
details and therefore cannot be addressed.
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Response to Wittwer Parkin-24
Please see response to Wittwer Parkin-23. A list of all potential species is provided in the EIR.
Response to Wittwer Parkin-25
As stated in RDEIR Section 3.4, Biological Resources, pages 3.4-45 through 3.4-48, if project
construction is scheduled to occur within the nesting season, Mitigation Measure BIO-2d requires
that a survey for nesting birds be conducted prior to construction activities. If nesting birds are
found, a buffer of at least 300 feet (500 feet for raptors) will be delineated, flagged, and avoided
until the nesting cycle is complete, or as determined appropriate by the biological monitor.
Residential lighting will be shielded away from Santiago Creek, and light and glare impacts to birds
will be reduced to less than significant levels with implementation of the proposed project design
features listed on page 3.4-43 of the RDEIR, and Mitigation Measure MM Bio-2a (including the
provisions of BMP 7 relating to lighting).
As stated in Mitigation Measure BIO-2a (RDEIR Section 3.4, Biological Resources, page 3.4-45):
Prior to the issuance of any grading permit for areas supporting least Bell’s vireo
habitat (such as southern cottonwood-willow riparian forest), the project applicant
shall obtain federal and State take authorizations via regulatory permits (such as a
CWA Section 404 permit issued by the USACE), which will require that the USFWS be
consulted as provided for by Section 7 of the FESA (for the federally listed least Bell’s
vireo). The federal regulatory permits (such as CWA Section 404 permit issued by the
USACE) provide a “federal nexus” by which Section 7 consultation can occur. This
statute imposes the obligation on federal agencies to ensure that their actions (such as
issuing federal CWA permits for this project) are not likely to jeopardize the continued
existence of a listed species or destroy or adversely modify its designated critical
habitat. This obligation is enforced through the procedural requirement that agencies
such as the USACE initiate consultation with the USFWS on any actions that may affect
a threatened or endangered species. During the FESA Section 7 consultation
anticipated for this project, the USFWS will gather all relevant information concerning
the proposed project and the potential project-related impacts on the least Bell’s vireo
(i.e., the project applicant will submit a species-specific Biological Assessment),
prepare its opinion with respect to whether the project is likely to jeopardize the
continued existence of the species (i.e., the USFWS will issue a Biological Opinion), and
recommend mitigation/conservation measures where appropriate. Additionally, the
need for State regulatory permits (i.e., Fish and Game Code Section 1602 Streambed
Alteration Agreement issued by the CDFW) will require a Consistency Determination
from the CDFW for the State-listed least Bell’s vireo under CESA.
No unauthorized take will occur. The remainder of Mitigation Measure BIO-2a includes BMPs that will
ensure that indirect impacts will not occur to least Bell’s vireo within 300 feet of occupied habitat.
Mitigation Measure BIO-2b requires habitat mitigation (on- or off-site restoration or enhancement of
least Bell’s vireo habitat at a ratio no less than 3:1 for permanent grading impacts) and Mitigation
Measure BIO-2c requires construction, grading, and fuel modification activities to take place outside of
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the least Bell’s vireo nesting season to the greatest extent feasible. If this is not possible, measures are
included to ensure that impacts to least Bell’s vireo remain less than significant.
Contrary to the commenter’s assertion, there is sufficient evidence in the RDEIR to support a finding
that mitigation will reduce impacts to species to a less than significant level.
Response to Wittwer Parkin-26
As stated in RDEIR Section 3.4, Biological Resources, subsection 3.4.6, page 3.4-39, no coastal California
gnatcatcher were observed on-site during focused surveys conducted by MBA in 2008; PCR in 2010,
2012, 2013, 2015; and ESA in 2017. The preferred habitat of the coastal California gnatcatcher is
coastal sage scrub, and the proposed project will not impact any coastal sage scrub habitats.
As the RDEIR notes, however, individual incidental sightings of coastal California gnatcatcher
occurred in 2010, 2014 and 2017. Contrary to the comments, the basis for the determination that
these sightings were incidental is fully explained in RDEIR Section 3.4, Biological Resources, page 3.4-
39. Although the incidental sightings of coastal California gnatcatcher were in disturbed/non-native
herbaceous cover or within disturbed areas perched on mule fat, and not coastal sage scrub, if these
areas were used for foraging and/or dispersal, the areas of Santiago Creek and native habitats that
will be avoided by the proposed project north of the drainage will continue to provide higher quality
habitat (including coastal sage scrub dominated by California sagebrush), which provide resources
for foraging and connectivity to other open space areas for dispersal (e.g., to Santiago Oaks Regional
Park to the east). As such, no significant impacts will occur to the coastal California gnatcatcher. The
comment that the significance of habitat or impacts is downplayed is unsubstantiated.
Response to Wittwer Parkin-27
RDEIR Section 3.4, Biological Resources, page 3.4-44, stated that willow flycatcher is listed by the
State as Endangered. To clarify, as stated in RDEIR Section 3.4, Biological Resources, subsection 3.4.6,
page 3.4-44, the willow flycatchers that were observed during the 2012 survey were found in two
locations. Two willow flycatchers were observed within the black willow scrub/ruderal community
that borders the fallow field in the eastern portion of the project site. The habitat within which these
willow flycatchers were observed is considered unsuitable as potential nesting habitat; therefore, it
is assumed that both birds were migrants passing through the area, and are not the southwestern
willow flycatcher subspecies. One willow flycatcher was observed within southern cottonwood-
willow riparian forest within the north-central portion of the project site. The habitat within which
this willow flycatcher was observed is considered suitable for nesting; however, no breeding willow
flycatchers were observed during the focused surveys for the species.
The proposed project would impact habitat suitable to support the willow flycatcher. Although the black
willow scrub/ruderal will be permanently removed, this isolated stand of willows provides only a small,
limited amount of foraging habitat for this species. The riparian habitat within Santiago Creek that will
be avoided by the proposed project will still be available to provide a greater area of contiguous habitat
for foraging opportunities, and impacts to potential willow flycatcher foraging habitat are not expected
to threaten regional populations of this species and are therefore less than significant.
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For the limited amount of southern cottonwood-willow riparian forest that could be used for nesting
habitat, which will be impacted by the installation of an on-site storm drain outlet, temporary
impacts will be restored to pre-project conditions; therefore, impacts are less than significant.
Contrary to the commenter’s opinion, there is adequate analysis of impacts to the willow flycatcher.
Impacts are less than significant.
Response to Wittwer Parkin-28
Edge effects associated with the proposed project are discussed in Appendix G (Biological Resources
Assessment, pages 93 to 94). A 150-foot limited use setback area is proposed as a project design
feature that will provide a buffer between the development and the wildlife movement corridor to
minimize edge effects. In addition, the USFWS will be required to be consulted to ensure that actions
are not likely to jeopardize the continued existence of a listed species or destroy or adversely modify
its designated critical habitat. Moreover, the project requires Mitigation Measure BIO-2c, which
would require all construction activities to occur outside of the least Bell’s vireo breeding season to
the extent feasible. If any activities are required to occur during the breeding season, activities
would be required to maintain a separation distance of 300 feet from least Bell’s vireo habitat, as
monitored by an on-site biological specialist. With implementation of mitigation, the project would
not impact least Bell’s vireo habitat. Contrary to the commenter’s statement, the RDEIR fully
evaluates impacts to this species.
Least Bell’s vireo is thoroughly analyzed and project design features and mitigation measures are
proposed to minimize direct and indirect permanent and temporary impacts to this species, as
discussed in RDEIR Section 3.4, Biological Resources, subsection 3.4.6, pages 3.4-40 through 3.4-48.
Response to Wittwer Parkin-29
Contrary to the commenter’s statement, the RDEIR did not include that impacts to 100 southern
tarplant individuals would result in a per se less than significant impact. As discussed in the RDEIR,
impacts to less than 100 southern tarplants are not expected to threaten regional populations of this
species, which consist of tens of thousands of plants within the Orange County region. As described in
RDEIR Section 3.4, Biological Resources, page 3.4-11, the project Applicant salvaged the southern
tarplant seed in 2010, 2013, and 2015. The southern tarplant seed was processed and stored at
Rancho Santa Ana Botanic Garden (RSABG). A portion of the seed was donated to RSABG’s permanent
conservation collection and a portion of the remaining seed was donated to Newport Banning Land
Trust for restoration purposes. This Conservation Measure was already applied and implemented in
order to prevent loss of this local population due to current on-site activities related to existing
backfilling and material recycling operations, which are not related to the proposed project. The
remainder of the salvaged southern tarplant seed will be relocated and sown on- and/or off-site within
the open space areas to be avoided and preserved. As such, impacts to southern tarplant associated
with the implementation of the proposed project are considered less than significant since impacts are
not expected to threaten regional populations. Contrary to the commenter’s assertion, the loss of 100
individual southern tarplants would not result in a significant impact.
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Response to Wittwer Parkin-30
Domestic pets are owned by the current area residents, and the special-status species found on-site
still persist. While the proposed project may introduce domestic pets closer to open space areas,
Orange County Ordinance Section 4-1-45 states that no person owning or having charge, care,
custody, or control of any dog shall cause or permit, either willfully or through failure to exercise due
care or control, any such dog to be upon any public property unless such dog be restrained by a
substantial chain, or leash not exceeding 6 feet in length, and is under the charge of a person
competent to exercise care, custody, and control over such dog. Therefore, domestic dogs would not
be anticipated to impact California coastal gnatcatcher and least Bell’s vireo. In addition, the
proposed residential portion of the project would be located in the southern portion of the site,
which is removed from the coastal gnatcatcher and least Bell’s vireo habitat. As discussed in the
RDEIR, habitat for California coastal gnatcatcher and least Bell’s vireo would be protected by the
project through design features and mitigation measures and impacts would be less than significant.
Response to Wittwer Parkin-31
To clarify, direct impacts to the prairie falcon are considered less than significant because no active
nests were observed and no suitable nesting habitat for the species is present on-site (or within a
0.5-mile radius of the project site), as discussed in RDEIR Section 3.4, Biological Resources, page 3.4-
40. Contrary to the commenter’s assertion, both direct and indirect impacts to suitable foraging
habitat were analyzed in the RDEIR are considered less than significant due to the limited amount of
impacts that would occur to native habitat that is suitable for foraging, and the abundance and
relative availability of foraging habitats in the project vicinity, including the native habitats that will
be preserved as open space upon project completion.
Response to Wittwer Parkin-32
The three measures listed in RDEIR Section 3.4, Biological Resources, on page 3.4-37 and the nine
measures listed on page 3.4-43 are proactively incorporated into the project as project design
features, and will be required project components. Contrary to the commenter’s statement, these
design features are a part of the project and are not mitigation measures. A feature built into the
design or operation of a project that will reduce or avoid an environmental impact that might
otherwise occur is not treated as a mitigation measure. (See, e.g., Wollmer v. City of Berkeley, supra,
193 Cal.App.4th 1329, 1352.)
Response to Wittwer Parkin-33
“Occupied habitat” means the habitat where least Bell’s vireo has been observed or is known to
reside, as well as the contiguous riparian habitat on-site. The mitigation measure referenced by the
commenter (Mitigation Measure BIO-2a) does not specify the duration of monitoring (e.g., full-time,
part-time, spot checks); rather, it requires monitoring to ensure indirect impacts will not occur to the
least Bell’s vireo, which will be based on the recommendations of the qualified biological monitor
and will therefore be more effective than a measure specifying duration of monitoring prior to
completion of pre-construction surveys. As requested by the commenter, there will be a qualified
biological monitor on-site if any construction, grading, and fuel modification activities are required
during the breeding season within 300 feet of potential least Bell’s vireo habitat (Mitigation
Measure BIO-2c).
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Response to Wittwer Parkin-34
The comment that daytime construction would worsen construction impacts is speculative and
unsupported by evidence. As discussed in the RDEIR, construction impacts would be less than
significant with incorporation of mitigation, so there is no need to analyze possible impacts of
conducting construction during the nighttime. The limiting of construction to daylight hours is intended
to minimize noise impacts on both wildlife and nearby residents. Daytime noise is greater than
nighttime noise and consequently construction noise during the day is relatively less noticeable.
Additionally, nighttime construction activities would contribute to unnecessary lighting impacts.
Response to Wittwer Parkin-35
Noise-related mitigation measures are intended to protect a variety of sensitive receptors (e.g.,
human, avian), and the project will have to comply with all mitigation measures pertaining to
minimizing noise impacts. Contrary to the commenter’s assertion, Mitigation Measure BIO-2a does
not conflict with other mitigation measures. Directing noise away from biological and human
sensitive receptors can be accomplished simultaneously, particularly on a large site such as the
project site. The commenter does not provide any evidence for the proposition that mitigation to
direct construction equipment away from biological sensitive receptors would contradict mitigation
to direct construction equipment away from human sensitive receptors.
Response to Wittwer Parkin-36
As requested by the commenter, the RDEIR provides sufficient discussion regarding tree impacts and
discloses conditions that will be required for the project. The City’s Tree Preservation Ordinance
requires a 1:1 replacement ratio for trees that will be removed, in which the project will comply. No
additional mitigation is required, since compliance with this existing regulation required by the City
will offset impacts to trees. This is discussed in RDEIR Section 3.4, Biological Resources, pages 3.4-58
to 3.4-61.
Response to Wittwer Parkin-37
Contrary to the commenter’s assertion, the RDEIR does not simply conclude that the cumulative
biological resources impacts are less than significant because the project’s biological resources
impacts are less than significant, but conducts an analysis of the potential cumulative impacts of the
project combined with other projects to determine that cumulative biological resource impacts are
less than significant. As stated in RDEIR Section 4, Cumulative Effects, page 4-4, “The proposed
project has the potential to have a significant impact on the least Bell’s vireo and nesting birds.
Mitigation Measures BIO-2a through BIO-2d are proposed, requiring pre-construction surveys for
these species and implementation of protection measures if they are found to be present. Some of
the other projects listed in Table 4-1 are located on sites with similar biological attributes and,
therefore, would be required to mitigate for impacts on special-status wildlife species in a manner
similar to the proposed project.” Implementation of the required mitigation would reduce the
project’s contribution to any significant cumulative impact on special-status wildlife species and the
project contribution would not be cumulatively considerable, as none of these species are expected
to drop below a sustainable level.
In addition, Mitigation Measure BIO-2b would require that for permanent grading impacts to least
Bell’s vireo habitat, on-site or off-site restoration or enhancement of least Bell’s vireo habitat would
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occur at a ratio no less than 3:1. Thus, with implementation of Mitigation Measure BIO-2b, there will
be a net increase in habitat to support the least Bell’s vireo, and cumulative impacts to this species
would not be cumulatively considerable and therefore are considered less than significant.
Response to Wittwer Parkin-38
The commenter notes a typographical error in Mitigation Measure CUL-2. Mitigation Measure CUL-2
has been revised as follows:
If the find is determined to have archaeological or paleontological significance, the
procedures in Mitigation Measure CUL-1 or Mitigation Measure CUL-3 shall be
implemented. Monitoring may cease once all of the areas depicted in Exhibit 3.5-1
have been thoroughly disturbed.
This correction will be included in Section 4, Errata, of this Final EIR.
Response to Wittwer Parkin-39
The commenter states an opinion that Mitigation Measure CUL-3 is deficient because it is triggered if
subsurface excavations exceed depths of 15 feet below the surface. It is unclear why the commenter
believes this Mitigation Measure is deficient. The commenter portrays this provision as a deficiency
in the RDEIR Project Description, claiming that the EIR must state whether project excavation will
reach this depth. Excavation may reach 15 feet, and for that reason, the mitigation measure is set
forth. Disclosing that excavation may reach this depth is consistent with CEQA’s requirements that an
EIR project description include a “general description” of the project’s characteristics. An EIR is not
required to disclose design-level details such as the precise depth of excavation.
Response to Wittwer Parkin-40
Under CEQA, it is proper to require, as mitigation, that a site-specific study will be conducted in the
future and performance measures will subsequently be incorporated based on the site-specific
study, when, as here, it would be premature to conduct a design-level report because the specific
design, location, and footprint of the proposed residential structures has not been finalized. (See,
e.g., POET, LLC v. State Air Resources Bd. (2013) 218 Cal.App.4th 681, 735.) Therefore, it is practical
and appropriate to prepare this report when this specific information is available to ensure the most
effective performance measures are incorporated into the development. Accordingly, Mitigation
Measure GEO-1 requires the Applicant to submit a design-level geotechnical report to the City of
Orange for review and approval prior to proceeding with development consistent with the
performance criteria identified in the Specific Plan. The investigation must be prepared by a qualified
engineer and identify grading and building practices necessary to achieve compliance with the latest
adopted edition of the California Building Standards Code’s geologic, soils, and seismic requirements.
The measures identified in the approved report must also be incorporated into the project plans.
Response to Wittwer Parkin-41
See Response to Wittwer Parkin-40. Geology and Soils are discussed extensively in RDEIR Section
3.6, Geology and Soils.
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Response to Wittwer Parkin-42
RDEIR Appendix F erroneously included air quality modeling results that were inconsistent with
tables in the Air Quality Section of the RDEIR. Section 4, Errata, of this Final EIR provides updated
modeling results that are consistent with the modeling results presented in the RDEIR Air Quality
Section. All detailed modeling and assumptions, which support the analysis and conclusions in the
RDEIR Air Quality Section,are included in the appendix.
Response to Wittwer Parkin-43
See Response to Comments SMW-50. The RDEIR did not rely on a baseline of rock-crushing traffic
year-round. As discussed in RDEIR Section 3.7, Greenhouse Gas Emissions, the SCAQMD
recommends several options for GHG emissions, including 3,500 MT CO2e per year for residential
and 3,000 MT CO2e per year for mixed use. Because the development portion of the project is
residential, SCAQMD’s residential threshold is appropriate for the project. However, even the lower
threshold of 3,000 MT CO2e per year suggested in the comment would not be exceeded by the
project. The specific information requested by the commenter, such as operational mobile
greenhouse gas emissions values, are included in RDEIR Section 3.7, Greenhouse Gas Emissions.
Response to Wittwer Parkin-44
Contrary to the commenter’s assertion, the discussion of impacts under Impact GHG-2 is not
inadequate. The City has not yet adopted a GHG reduction plan against which the project can be
evaluated. In addition, the City has not completed the GHG inventory, benchmarking, and goal-
setting process required to identify a reduction target and to take advantage of the streamlining
provisions contained in the CEQA Guidelines amendments adopted for SB 97. Since no other local or
regional climate action plan is in place, the project is assessed in the RDEIR for its consistency with
the ARB’s adopted AB 32 2008 Scoping Plan.
Although the City of Orange General Plan does not meet the CEQA Guidelines 15064.4(b)(3)
requirements for an applicable plan to reduce GHG emissions, it contains policies intended to reduce
vehicle travel and energy use that would provide GHG reductions. Therefore, the project’s
consistency with the General Plan policies is also assessed in the RDEIR.
Contrary to the commenter’s statement, the analytical approach in the RDEIR was not invalidated in
Center for Biological Diversity v. California Department of Fish and Wildlife (2015) 62 Cal.4th 204. In
fact, the Court in Center for Biological Diversity noted that a discussion of project consistency with
the State’s long-term climate stabilization objective is appropriate under CEQA when the analysis is
tailored specifically to a particular project, which was accomplished in the RDEIR. Moreover, the
project discussed consistency with the ARB’s Scoping Plan as well as the City’s policies intended to
reduce vehicle travel and energy use that would provide GHG reductions. The project’s GHG analysis
and conclusions are legally and technically adequate.
Response to Wittwer Parkin-45
Please see Master Response 8—Site Environmental Conditions. As discussed in Master Response 8,
the project will be required to conduct a supplemental Phase II ESA for the property, which will be
reviewed by the DTSC, to update the previous environmental site assessments as necessary.
Response to Wittwer Parkin-46
Contrary to the commenter’s assertion, the RDEIR does not conclude that impacts regarding
hazardous materials within 0.25-mile of a school are less than significant because proposed uses
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would not involve handling hazardous substances routinely. Rather, the discussion indicates that the
proposed project would develop residential, open space, and recreational uses on the project site,
and these uses are not associated with activities that involve handling hazardous substances. No
hazardous materials are expected to be handled for the proposed uses. As noted in RDEIR Section
3.8, Hazards and Hazardous Materials, page 3.8-11, impacts are less than significant.
Response to Wittwer Parkin-47
The RDEIR states that the proposed project would not modify any surrounding roadways in a manner
that could impair emergency response or evacuation. It specifically states that there would be no
road closures or lane narrowing. (RDEIR Section 3.8, Hazards and Hazardous Materials, page 3.8-15.)
Response to Wittwer Parkin-48
Please see Master Response 5—Wildfire Risk.
Response to Wittwer Parkin-49
Please see Master Response 4—Dam Safety and Risk of Failure.
Response to Wittwer Parkin-50
The comment is conflating two separate and distinct elements of Impact HYD-3.
a) Element No. 1, Handy Creek Storm Drain: The sentence “The project would achieve no net
increase discharge [sic] of stormwater into the Handy Creek Storm Drain during storm
events.” appears in the paragraph in the middle of page 3.9-24, following Table 3.9-6, but
preceding Table 3.9-7. This paragraph pertains only to the existing Handy Creek storm drain,
which is an existing feature that lies in the center of the project site. Additionally, Table 3.9-7
pertains only to the existing Handy Creek storm drain.
b) Element No. 2, Detention Basin Outlet: The phrase “riprap and an energy dissipator” appears
in the paragraph at the top of the page 3.9-24, preceding Table 3.9-6. This sentence pertains
only to the outlet of the proposed detention basin that is described in the last paragraph on
page 3.9-23. The storm drain outlet from the detention basin is a proposed feature that will
be placed at the westerly end of the site. The riprap is to be placed at the downstream end of
the detention basin storm drain outlet to Santiago Creek. Riprap placement is a universally
accepted method of flow regulation.
The RDEIR discussion is adequate and refers to Appendices 2, 3, and 5 within the Hydrology Report
in Appendix K of the RDEIR for calculations compiled via AES Hydrology Software and HydroCAD
Detention Modeling Software.
Response to Wittwer Parkin-51
See Master Response 1—Plan Consistency. Contrary to the commenter’s assertion, a project that
requires a General Plan amendment does not impermissibly evaluate project consistency with the
General Plan by concluding that with implementation of the General Plan Amendment, the project
will be consistent with the General Plan.
Response to Wittwer Parkin-52
Please see Master Response 1—Plan Consistency.
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Response to Wittwer Parkin-53
The RDEIR does not fail to disclose any relevant information regarding the designation of the project
site. There is no General Plan prohibition on redesignating land identified as Resource Area, nor is
there any requirement to quantify the percentage of land identified by any category. The RDEIR
clearly states that a portion of the project site is designated Resource Area (RA) (77.3 acres). (RDEIR
Section 2, Project Description, page 2-12, Exhibit 2-6, and RDEIR Section 3.3, Air Quality, page 3.3-
28). The proposed project involves the development of up to 128 dwelling units on approximately
40.7 acres within the area designated “Resource Area” and the preservation of the remaining 68.5
acres (which overlap with the “Resource Area” and “Low Density Residential” designations) as open
space and recreation uses. Accordingly, the Applicant is proposing to change the “Resource Area”
designation to a combination of “Low Density Residential,” and “Open Space,” and the “Low Density
Residential” designation to “Open Space.” This serves to preserve the majority of the site as “Open
Space.” It is within the City’s discretion to determine the most beneficial designation for the project
site via the requested General Plan amendment.
Response to Wittwer Parkin-54
See Response to Wittwer Parkin-51 and 53 above. It is within the City’s discretion to find that an
approved zone change would bring the project into compliance with the Zoning Code and reduce
impacts to below a level of significance. The fact that a project requires a zone change does not
prohibit a finding of less than significant with land use regulations.
Response to Wittwer Parkin-55
The project’s consistency with the Orange County Central and Coastal Subregion Natural Community
Conservation Plan (NCCP)/Habitat Conservation Plan (HCP) (RDEIR Section 3.4, Biological Resources,
Exhibit 3.4-6) is discussed in detail in RDEIR Section 3.4, Biological Resources, starting at page 3.4-28
and in both Impact BIO-7 and RDEIR Section 3.10, Land Use, Impact LUP-3.
Response to Wittwer Parkin-56
The commenter indicates that the construction noise analysis contained in the RDEIR did not
quantify construction noise impacts. However, RDEIR Section 3.12, Noise, page 3.12-21 identifies the
closest sensitive receptors and quantifies the reasonable worst-case maximum noise levels that
could occur during the loudest phase of construction, the site preparation phase, when the heaviest
types of construction equipment would operate.
The commenter further indicates that the construction noise analysis did not disclose whether
construction noise would exceed hourly or daily noise thresholds set by the City. However, as
discussed in the RDEIR, the City does not have hourly of daily noise thresholds for construction.
Rather, in accordance with Section 8.24-070 of the Municipal Code, as shown in RDEIR Section 3.12,
Noise, page 3.12-16, construction noise is exempt from the noise performance standards of the
Municipal Code provided these activities do not take place between 8:00 p.m. and 7:00 a.m. on
weekdays, including Saturdays, or at any time on Sundays or a federal holiday. Mitigation Measure
NOI-1a includes these restrictions on permissible hours of construction, along with best
management noise reduction measures. Therefore, the analysis does provide a quantitative analysis
of reasonable worst-case construction noise levels and ensures that the construction noise complies
with the applicable noise standards of the City’s Municipal Code.
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The commenter indicates that the construction noise analysis segments construction haul trip noise
impacts from other construction activity noise impacts. However, the construction noise analysis
quantifies the reasonable worst-case construction noise levels of the project construction. Noise
levels from construction haul trips would be more than 10 dBA below the reasonable worst-case
construction noise levels identified for the site preparation phase of construction. A characteristic of
noise is that combining noise levels that are 10 dBA or greater in difference does not result in any
increase. Therefore, as stated in the analysis, the construction noise impact analysis quantified the
reasonable worst-case construction noise levels and provided mitigation to reduce any potential
impacts to a level that is less than significant.
Response to Wittwer Parkin-57
The commenter indicates that project-related traffic noise impacts to off-site receptors are not
identified, and that project-related traffic noise levels that result in an exceedance of 65 dBA
community noise equivalent level (CNEL) as measured at any off-site receptor would automatically
be a significant impact. However, as indicated in RDEIR Section 3.12, Noise, page 3.12-43, in
accordance with the City’s standards, project-related traffic noise impacts to off-site receptors would
occur under the following conditions:
In order for off-site roadway noise impacts created by the proposed project’s
operations to be considered significant, the proposed project would need to
increase the noise levels on a residential or school land use above 65 dBA CNEL
where the without project noise level is below 65 dBA CNEL, or by (1) 5 dBA CNEL
where the without project noise level is less than 65 dBA CNEL, or (2) 3 dBA CNEL
where the without project noise level is greater than 65 dBA CNEL. A significant
impact would also occur if the proposed project provides any increase to a
residential or school use that already exceeds 75 dBA CNEL.
As shown in Tables 3.12-12 through 3.12-14 in RDEIR Section 3.12, Noise, project-related traffic
noise increases at modeled receptors in the project vicinity would range from 0.0 to 0.1 dBA CNEL,
which is below the 5 dBA increase threshold for roadways that have without-project traffic noise
levels below 65 dBA CNEL. It is also below the 3 dBA increase threshold for roadways that have
without-project traffic noise levels that exceed 65 dBA CNEL. In every modeled traffic scenario, no
additional roadway segments would exceed the City’s residential or school noise standard of 65 dBA
CNEL when compared to traffic noise conditions that would exist without the project. In addition, no
modeled receptor location would experience traffic noise levels that exceed the 75 dBA CNEL
maximum noise exposure level. Therefore, the analysis clearly shows that implementation of the
project would not result in a substantial permanent increase in traffic noise levels compared to levels
that would exist without the project, and project-related traffic noise levels would not exceed the
City’s thresholds. Therefore, as concluded in the RDEIR, project-related traffic noise impacts to off-
site sensitive receptors would be less than significant and no mitigation would be required.
Response to Wittwer Parkin-58
The commenter indicates that the noise analysis does not mention the need for a soundwall to
shield off-site receptors from “Project-created sounds.” As stated in the noise analysis assumptions,
and as shown in the SoundPlan modeling data files included in the appendix, on-site operational
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noise impact analysis only included reductions for existing soundwalls in the project vicinity. The
analysis further demonstrates that all on-site operational noise levels would not exceed the City’s
noise performance standards and further would not result in an exceedance of the existing
background average-hourly or -daily ambient noise levels. Therefore, implementation of a soundwall
to reduce on-site operational noise levels is not necessary, as no significant impact would occur. In
addition, it should be noted that Mitigation Measure NOI-1b requires the installation of a minimum
6-foot high sound barrier and a 4-foot high berm along the project’s property line adjacent to East
Santiago Canyon Road in order to reduce traffic noise impacts to the project. The presence of this
sound barrier and berm would provide further noise reduction for on-site noise sources, reducing
the on-site operational noise levels as measured at off-site receptors to be even lower than what is
stated in the stationary source noise impact analysis shown in Section 3.12, Noise, pages 3.12-37 and
-38. Therefore, the noise impact analysis fully discloses the assumptions made in the modeling.
Furthermore, it provides a conservative analysis of operational noise impacts by evaluating predicted
noise levels as measured at the nearest sensitive receptors without accounting for noise reductions
that would be achieved from implementation of the project’s sound barrier and berm that are
required under Mitigation Measure NOI-1b. Finally, the analysis clearly demonstrates that the
project would not result in an exceedance of the City’s noise performance standards. Thus, the
conclusion that Project on-site stationary source noise impacts on off-site receptors would be less
than significant remains valid.
Response to Wittwer Parkin-59
The commenter indicates that the cumulative noise impact analysis is flawed in that the cumulative
noise impact analysis should not separate construction and operational noise impacts in the
cumulative impact analysis. The commenter correctly states that it is the “volume [of noise], not the
type, of noise” that matters to sensitive receptors in a cumulative noise impact analysis. The
cumulative noise impact analysis correctly addresses and evaluates the project-related combined
reasonable worst-case noise levels as measured at nearby sensitive receptors. As such, as discussed,
the loudest phase of construction activities (the site preparation phase) would not occur
simultaneously with any project operational noise impacts. Therefore, the cumulative noise impact
analysis must consider these noise sources separately, as they would occur on different timelines. As
construction noise and project operational-related noise would not overlap in time, they would not
contribute to the same cumulative ambient noise impact. By identifying the noise impacts from
construction activities and from operational activities separately, the analysis, therefore, has
correctly analyzed the project’s contribution to a cumulative impact.
The commenter further claims that, “Project construction will contribute to cumulatively significant
noise impacts when considered in conjunction with all other contemporaneous noise impacts.” The
commenters also states that “several locations will exceed the 65 decibels CNEL during the lifetime
of the Project,” apparently implying that this indicates an automatic significant cumulative impact.
However, the significance threshold for a cumulative impact would be ambient noise levels that
exceed the City’s “conditionally acceptable” threshold for a receiving land use. The ambient noise
environment in the project vicinity, as documented through the ambient noise monitoring and traffic
and airport noise modeling, does not (and would not in the future year 2040 conditions) have noise
levels that are in excess of the City’s “conditionally acceptable” noise levels for any receiving land use
in the project vicinity. Therefore, there is no significant cumulative impact to which the project is
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contributing. Furthermore, the analysis shows that project-relate construction noise levels would be
reduced to less than significant with implementation of Mitigation Measure NOI-1a (which includes
restrictions on permissible hours of construction in compliance with the City’s noise ordinance
requirements for construction noise sources). The analysis also shows that project-related
operational noise levels would not cause ambient noise levels in the project vicinity to exceed
“conditionally acceptable” noise levels for any land use in the project vicinity from any project-
related noise source. Therefore, there is no significant cumulative impact to which the project is
contributing or creating. As such, the conclusion that the project would not contribute to a
significant cumulative impact to the ambient noise environment in the project vicinity is valid, and
no mitigation would be required.
Response to Wittwer Parkin-60
Please refer to Response to Wittwer Parkin-59.
Response to Wittwer Parkin-61
The Southern California Association of Governments (SCAG) is the regional body charged with
allocating regional housing requirements and projecting regional growth down to the local level. As
shown in RDEIR Section 3.13, Population and Housing, Table 3.13-3, the proposed project would
increase the City’s population by 393 persons. The population of the City of Orange is forecast to
increase from 141,420 (the City’s 2016 population estimate) to 151,400 people in 2035 (DOF 2015;
SCAG 2013), a net increase of 9,980 people. The proposed project’s 393 residents would represent
approximately 3.9 percent of the City’s projected population increase, which does not represent a
significant increase. To answer the commenter’s question, the project would not cause the City
population to exceed its estimated growth rate.
Furthermore, the project would help carry out the goals, objectives, and policies of the City’s
General Plan Housing Element by developing a new for-sale residential development that offers
additional housing opportunities in the City. Specifically, the housing element indicates the
need/objective for construction of 5,079 new dwelling units in the City (2014-2021 Housing Element,
Appendix C-1, Table C-1, Progress in Achieving Quantified Objectives: 2006-2014 Planning Period, of
the housing element) in order to accommodate the City’s forecast growth in the number of
households, to replace expected demolitions and conversion of housing units to non-housing uses,
and to achieve a future vacancy rate that allows for healthy functioning of the housing market.
Project development would help accomplish a portion of this need/objective by providing 128
residential units in the City.
Response to Wittwer Parkin-62
Contrary to the commenter’s assertion, the RDEIR considers and evaluates potential impacts to
schools in Impact PS-3. That discussion identifies that the Orange Unified School District would
provide K-12 education to the proposed project. The discussion further explains that the proposed
project would develop up to 128 dwelling units, which would add 393 new residents to the City’s
population. Then, using a standard student generation rate of 0.5 student/dwelling unit, the RDEIR
discloses that the proposed project would add 64 new students to the School District’s enrollment.
Only after this discussion does the RDEIR conclude that the payment of impact fees pursuant to
Government Code Section 65995 would reduce impacts to less than significant. The fees set forth in
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California Government Code Section 65996 constitute the exclusive means of both “considering” and
“mitigating” school facilities impacts of projects. (GOV § 65996(a); see also Chawanakee Unified
School Dist. v. County of Madera (2011) 196 Cal.App.4th 1016, 1020.)
Response to Wittwer Parkin-63
The City’s public libraries operate according to the Public Library Facilities Master Plan (2002-2020).
This Master Plan outlines current and projected future demand based on City’s General Plan
buildout. The document is intended to ensure that the California State Library’s recommended
standard of 4 volumes and 0.7 square foot per capita is maintained, and that the City’s library
services needs are met as future development occurs. The project would add 393 residents. The
population increase would result in an increase in the demand for books, periodicals, and similar
materials. Using the California State Library standard of 4 volumes and 0.7 square foot per capita,
the proposed project would generate an estimated demand for approximately 1,572 volumes and
275 square feet of library space. However, the increase in population associated with the proposed
project would have a nominal effect on the library.
Moreover, during the City’s development review process, the project would be required to comply
with the requirements of the Orange Municipal Code, including payment of the required library
facilities fee, as outlined in Chapter 3.50 (Library Facilities Fees) of the Orange Municipal Code.
Pursuant to Section 3.50.080 (Use of Library Facilities Fees), the funds collected under the program
would be used for the purpose of (1) paying the actual or estimated costs of acquiring, building,
improving, expanding, maintaining, and operating public libraries located within the City of Orange
or (2) reimbursing the City of Orange for the development’s share of those library facilities already
constructed by the City of Orange or for costs advanced with respect to a specific library facility
project. Impacts would be less than significant.
Contrary to the commenter’s assertion, the RDEIR’s discussion of impacts related to library services
is not inadequate. The commenter fails to describe or request additional information, but rather
makes a general statement that “further explanation is needed.” The RDEIR provides adequate
information and additional explanation is not required.
Response to Wittwer Parkin-64
The commenter incorrectly suggests that the cumulative impacts analysis should discuss potential
impacts associated with the maximum future response area of the police department. However, in
addition to being speculative, this eventual maximum service area is not the appropriate measure
for a cumulative impact analysis. A cumulative impact is created by the combination of the project
reviewed in the RDEIR together with other projects causing related impacts (CEQA Guidelines §
15130(a)(1)). The cumulative impact from several projects is the change in the environment that
results from the incremental effect of the project when added to other past, present, and probable
future projects (CEQA Guidelines §§ 15065(a)(3), 15130(b)(1)(A), and 15355(b)). Consistent with the
requirements of CEQA, the RDEIR appropriately considered the cumulative impacts of the proposed
project in conjunction with other proposed and approved projects in the City of Orange. RDEIR
Section 4, Cumulative Effects, Table 4-1, provides a list of the other projects considered in the
cumulative analysis. Cumulative impacts regarding public services are discussed in detail in RDEIR
Section 4, Cumulative Effective, subsection 4.2.14, pages 4-10—4-11). Contrary to the commenter’s
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assertion, the RDEIR adequately explains how the City would meet service needs in light of the
project’s impacts combined with other past, present, and reasonably foreseeable future projects.
Response to Wittwer Parkin-65
An EIR’s discussion of cumulative impacts need not provide the same level of detail as is provided for
project-specific effects (CEQA Guidelines § 15130(b)). The level of detail provided should correspond
to the severity of the impact and the likelihood that it will occur (CEQA Guidelines § 15130(b).) Here,
the Fire Department indicated that the project’s impacts on fire services would be less than
significant and that the Department could handle the call load associated with the project (Appendix
O.) Moreover, an increase in response times or in demand on public facilities, services, and utilities
that will result from a project is not, standing alone, an environmental impact under CEQA. (City of
Hayward v. Trustees of California State University (2015) 242 Cal.App.4th 833.) Contrary to the
commenter’s statement, the conclusion in the RDEIR is based on evidence in the record. The project
will not make a contribution to a cumulative environmental effect.
Response to Wittwer Parkin-66
The proposed project design feature is a voluntary transportation improvement to be implemented
by the Applicant and is not a mitigation measure. The LOS values shown for Cannon Street at Taft
Avenue in Table 3.16-11 are not consistent with the LOS values contained in the TIA (Appendix P)
and were shown in error. The AM peak hour “Existing with Project Traffic Conditions” LOS should be
0.985 (LOS E) and the PM should be 0.655 (LOS B), which is consistent with Table 3.16-12. This
typographical error will be corrected in Section4, Errata, the FEIR.
Response to Wittwer Parkin-67
Because of the proposed Project Design Features, it is accurate that the level of service may
decrease under “Existing with Project” traffic conditions even though the Project will add traffic to
the transportation system. Contrary to the commenter’s assertion, the analysis is not a “shifting
baseline.” It is proper under CEQA to implement design features as part of a project. Contrary to the
commenter’s statement, project design features are binding components of the project.
Response to Wittwer Parkin-68
The City of Orange Traffic Impact Analysis Guidelines (dated August 15, 2007) indicates that a
transportation impact on an intersection shall be deemed “significant” and require mitigation under
CEQA in accordance with following table:
Table 3-1: Significant Transportation Impact
Level of Service Final V/C Ratio Project-Related Increase in V/C
E, F >0.900 equal to or greater than 0.010
As concluded in the RDEIR, the project would add less than 0.010 to the V/C ratio. Based on the City
thresholds identified above, the project would not result in a significant impact at any intersection.
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Response to Wittwer Parkin-69
The Planned Improvements referenced by the commenter are consistent with the General Plan
Circulation Element and will be implemented over time by the City and/or development community.
One of the Planned Improvements is to widen and/or restripe East Santiago Canyon Road at Orange
Park Boulevard to provide a third eastbound through lane and a third westbound through lane.
Mitigation Measure TRANS-2 would require the project Applicant to contribute fair share fees to
restripe the northbound approach of Orange Park Boulevard at East Santiago Canyon Road to
provide one exclusive left-turn lane and one shared left-turn/right-turn lane. The Applicant’s fair
share responsibility for these improvements is 18.2 percent.
Response to Wittwer Parkin-70
Table 3.16-13 reflects the Roadway Segment LOS Summary, whereas the other tables that reflect
Taft/Cannon as LOS E are Intersection LOS Summary tables. Therefore, the RDEIR correctly identifies
the LOS at this location and does not pose a discrepancy.
Response to Wittwer Parkin-71
The RDEIR correctly identifies that the Project will only cumulatively impact one location based on
the City of Orange impact criteria. Adding Project traffic to a study location operating at LOS E or
worse does not automatically constitute a significant impact in itself.
Response to Wittwer Parkin-72
As referenced in Section 3.17, Tribal Cultural Resources, page 3.17-9, of the RDEIR, no tribal cultural
resources were observed on-site during the field survey. A “tribal cultural resource” is defined as (1)
“sites, features, places, cultural landscapes, sacred places and objects with cultural value to a
California Native American tribe” that are included in the State or local register of historical
resources or that are determined to be eligible for inclusion in the State register; and (2) resources
determined by the lead agency, in its discretion, to be significant on the basis of criteria for listing in
the State register of historical resources. (PRC § 21074(a).) As detailed throughout Section 3.17, the
RDEIR conducted extensive research to determine if there were any tribal cultural resources on site
eligible for inclusion in the state register. In TCR-1 it is explained that the project site is not listed on
any national, State, or local registers of historic places (including those for tribal cultural resources).
Because the project site contains undeveloped land, it does not possess any attributes that would
make it eligible for such a listing. Therefore, the RDEIR properly concluded that there were no
resources meeting the definition of a tribal cultural resource on the site.
To further explore whether any cultural resources with value to a California Native American tribe
were present on site, FCS contacted 12 identified tribal contacts. FCS also sent a letter to the Native
American Heritage Commission (NAHC) in an effort to determine whether any sacred sites are listed
in its Sacred Lands File for this portion of the City of Orange. The City did not receive any responses
requesting consultation.
Based on the lack of identified resources during extensive research and field surveys and the fact
that the City did not receive any responses indicating that the project would cause a substantial
adverse change in the significance of a tribal cultural resource, the City is within its discretion to
determine that there are no known tribal cultural resources on site. Contrary to the commenter’s
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statement, the RDEIR did not conclude that impacts were less than significant simply because no
response from tribal representatives was received. Additionally, in an abundance of caution, the
RDEIR sets forth mitigation measures for the inadvertent discovery of such resources during
construction. Refer to Section 3.4, Cultural Resources, for further discussion.
Response to Wittwer Parkin-73
An analysis of impacts to wastewater facilities due to the project is in RDEIR impact analysis USS-2.
As discussed, the project would generate approximately 0.060 million gallons of wastewater per day.
Wastewater would be treated at either Orange County Sanitation District (OCSD) Plant No. 1, which
has a primary treatment capacity of 198 mgd, or Plant No. 2, which has a primary treatment capacity
of 168 mgd. The proposed project’s daily effluent generation of 0.060 mgd represents less than 0.01
percent of the primary treatment capacity at either plant. Additionally, according to the OCSD,
average daily influent has steadily decreased since approximately year 2000 (from approximately 250
mgd in 2000 to less than 200 in 2016) due to conservation efforts. (OCSD 2016-2017 Annual Report,
Figure ES-1.) Therefore, OCSD wastewater treatment plants have additional capacity to
accommodate the project’s flows compared to previous years.
Response to Wittwer Parkin-74
The project properly relies on design features that will be implemented with the proposed project. A
feature built into the design or operation of a project that will reduce or avoid an environmental
impact that might otherwise occur is not treated as a mitigation measure. (See, e.g., Wollmer v. City
of Berkeley, supra, 193 Cal.App.4th 1329, 1352.)
Response to Wittwer Parkin-75
Contrary to the commenter’s assertion, the RDEIR did not wrongfully dismiss the environmentally
superior alternative. As discussed in Section 5.5, after thorough analysis was conducted, the
Collaborative Group Alternative was determined not to advance the objectives that concern guiding
the transition of an infill site with a Specific Plan; would not develop a logical internal circulation
system for pedestrians, bicyclists, equestrians, and motorists; and would not include the
Development Agreement benefits to the community. Development consistent with a Specific Plan
does not unreasonably narrow the analysis as suggested by the comment. Although the
Collaborative Group Alternative was determined not to meet project objectives, it is adequately
analyzed in the RDEIR and the decision-making body could consider approving this alternative;
therefore, it is not improperly dismissed.
Response to Wittwer Parkin-76
To fully analyze potential traffic, air quality and other potential impacts, it was conservatively
estimated that the project would require up to 275,400 haul trips during the 1.5-year grading period.
This estimate is based on the reasonable assumption that each haul truck would have a capacity of
10 cubic yards per load. This allows the reader and decision makers to fully understand potential
environmental impacts. There is no evidence that this conservative estimate, or the underlying
assumption, is wasteful, inefficient, or involves the unnecessary consumption of energy. Therefore,
the energy section does not need to be revised to reduce the number of these trips or the trip
length. Impacts were fully analyzed and determined to be less than significant.
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Response to Wittwer Parkin-77
As the comment notes, the OCTA does not have plans to extend bus service to the project area;
however, the project does not include any design elements that would preclude buses in the future.
OCTA identifies transit priorities in its Long Range Transportation Plan. The assumption that the
project’s VMT would be higher than those in an urban center is speculative. Moreover, the project
would not result in any significant adverse environmental impacts. Therefore, mitigation is not
required. The commenter’s opinion that the project fails to meet a numeric distance to commercial
and job centers is unsupported by a CEQA or City threshold. Finally, the project is designed to
encourage pedestrian and equestrian uses.
Response to Wittwer Parkin-78
The RDEIR states that the project would comply with Title 24, which requires new non-residential
buildings to be “solar ready” and requires solar photovoltaic systems for new homes. The RDEIR
further states that this requirement is consistent with the Million Solar Roofs program because it
does not impede implementation of this strategy. (RDEIR, page 3.7-23.) However, this consistency
finding is not intended as a mitigation measure. Contrary to the commenter’s suggestion, rooftop
solar panels are not required as a mitigation measure of the project because no significant impacts
were identified. To maximize energy efficiency in the project, the Specific Plan states that the
builder(s) at The Trails of Santiago Creek are required to go “above and beyond the standards set
forth in Title 24 by incorporating additional elements of energy efficient design.” (Specific Plan, page
6-45.) A minimum 5 percent energy efficiency baseline will be required for all builders, which is more
than is required by Title 24. (Specific Plan, page 6-45.) This requirement ensures that the project is
energy efficient and reduces waste.
Response to Wittwer Parkin-79
This comment does not raise any environmental issues. The request for notice is noted.
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NORTH AMERICA | EUROPE | AFRICA | AUSTRALIA | ASIA
WWW.FIRSTCARBONSOLUTIONS.COM
VOLUME II
FINAL
Environmental Impact Report
Trails at Santiago Creek Specific Plan
City of Orange, Orange County, California
State Clearinghouse No: 2017031020
Prepared for:
City of Orange
Community Development Department, Planning Division
300 East Chapman Avenue, Orange, CA 92866
714.744.7231
Contact: Robert Garcia, Senior Planner
Prepared by:
FirstCarbon Solutions
250 Commerce, Suite 250
Irvine, CA 92602
714.508.4100
Contact: Jason Brandman, Project Director
Cecilia So, Project Manager
Date: September 16, 2019
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Individuals
Addison Adams (ADAMS)
Response to ADAMS-1
Comment noted. This comment supports the Collaborative Group Alternative and the development
of 128 dwelling units. The commenter states that with acreage credit, the project would be
consistent with the Orange Park Acres Plan. No further response is necessary.
Response to ADAMS-2
Comment noted. This comment supports the project’s proposed clustering. No further response is
necessary.
Response to ADAMS-3
Comment noted. The commenter suggests that the proposed development allows for “the keeping
of animals in a collective manner,” consistent with the Orange Park Acres Plan, be included as a
condition of approval. This comment will be provided to the City decision makers for their review
and consideration in determining whether to approve the project.
Response to ADAMS-4
Comment noted. This comment supports the proposed residential zoning change for the project. No
further response is necessary.
Response to ADAMS-5
Comment noted. This comment suggests that the developer should be given credit for all 109 acres
of the subject site, and the donation of Ridgeline site, as part of calculating gross density, consistent
with pages 112 and 115 of the Orange Park Acres Plan. No further response is necessary.
Response to ADAMS-6
Comment noted. This comment supports the termination of gravel pit operations, restoration of
natural amenities to Santiago Creek, and creating equestrian and hiking trails along the creek, all
consistent with the Orange Park Acres Plan.
Response to ADAMS-7
Comment noted. Please refer to the October 30, 2018, The Trails at Santiago Creek Specific Plan,
found on the City’s website (https://www.cityoforange.org/DocumentCenter/Index/635) for specifics
on the design of the project. The commenter suggests design issues can be remedied as a condition
of approval. This comment will be provided to the City decision makers for their review and
consideration in determining whether to approve the project, and what conditions of approval to
consider in connection with that decision.
Response to ADAMS-8
The commenter requests the immediate permanent termination of all sand, gravel, rock crushing,
and rock storage activities at the site be included as a condition of approval. This comment will be
provided to the City decision makers for their review and consideration in determining whether to
approve the project, and what conditions of approval to consider in connection with that decision.
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Response to ADAMS-9
Comment noted. As discussed in RDEIR Section 3.4, Biological Resources, page 3.4-50,
implementation of Mitigation Measure BIO-3 would be required to reduce the project impacts to
sensitive natural communities.
MM BIO-3 Prior to the issuance of any grading permit in the areas designated as sensitive
riparian communities (e.g., southern cottonwood-willow riparian forest or black
willow scrub/ruderal), the project applicant shall demonstrate to the satisfaction of
the City that either of the following have been or will be accomplished:
On- or off-site restoration or enhancement of sensitive riparian communities (e.g.,
southern cottonwood-willow riparian forest) at a ratio no less than 1:1 for
permanent impacts. Temporary impacts will be restored to pre-project conditions
(i.e., pre-project contours and revegetate with native species, where appropriate).
Off-site restoration or enhancement at a ratio no less than 1:1 may include the
purchase of mitigation credits at an agency-approved off-site mitigation bank (e.g.,
Soquel Canyon Mitigation Bank).
If mitigation is to occur on-site and/or off-site (i.e., not an in-lieu fee program), a
mitigation and monitoring plan shall be prepared. The plan shall focus on the
creation of equivalent habitats within disturbed habitat areas of the project site
and/or off-site. In addition, the plan shall provide details as to the implementation
of the plan, maintenance, and future monitoring. Mitigation for impacts to sensitive
riparian communities shall be accomplished by on- or off-site restoration and/or
enhancement (e.g., transplantation, seeding, and/or planting/staking of sensitive
riparian species; salvage/dispersal of duff and seed bank; removal of large stands of
giant reed within riparian areas).
Response to ADAMS-10
Please refer to Master Response 6—Stewardship of Open Space.
Response to ADAMS-11
Comment noted. The project will be responsible for constructing trails and bikeways within the
project boundaries. A variety of recreational trails for combined uses of hiking, bicycling, and
horseback riding will traverse the project site. For example, along the north side of East Santiago
Canyon Road, an off-street recreational trail will extend along the entire length of the project site.
This trail will provide continuity from the existing recreational trail that parallels the roadway east of
the project site. In addition, recreational trails will extend northward from the East Santiago Canyon
Road trail and will cross the Santiago Creek riparian corridor via a bridge that will span the creek
environs. The bridge will be located toward the easterly end of the creek corridor. There will also be
trails adjacent to the proposed Greenway Open Space area on the northeast portion of the project
site. At the project’s eastern boundary, the trail system will continue off-site to the Santiago Oaks
Regional Park. Trail crossings will be provided for safe crossing of residential streets.
The creek crossing mentioned by the commenter is outside the project’s boundaries. As noted in
RDEIR Appendix Q, the construction of a trail underpass under Cannon Street is envisioned as
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Project 7.1 in the Santiago Creek Vision Plan. This land is currently County owned land east of
Cannon Street and north of East Santiago Canyon Road. Project 7.1 is currently identified as a future
project in the Santiago Creek Vision Plan.
Response to ADAMS-12
Comment noted. The project will be required to comply with the City of Orange Zoning Code with
regards to building height restrictions.
Response to ADAMS-13
This comment requests that the gravel yard operations should be terminated effective immediately
upon approval; that the stockpiles be reduced immediately; the Ridgeline donation to the City
should be immediate; and the open space should be donated immediately to the County and
managed by OC Parks immediately upon approval. The commenter would like the benefits be
provided to the community immediately and not tied with the certificate of occupancy. This
comment is noted and will be provided to the City decision makers for their review and
consideration in determining whether to approve the project, and what conditions of approval to
consider in connection with that decision.
Response to ADAMS-14
This comment opines that the gravel yard operations should have been terminated 20 years ago and
it would be best to terminate those operations now and leave the entire valley open space for use by
the public after remediation. The comment continues to support the housing development with
open space and trails with connecting linkage. This comment is noted and no further response is
necessary.
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Kaitlin Agee (AGEE)
Response to AGEE-1
Comment noted. This comment will be provided to the City decision makers for their review and
consideration in determining whether to approve the project.
Comment noted, for the comment related to Traffic, please refer to Response SMW-17.
Response to AGEE-2
Comment noted. Impacts related to hydrology and water quality, including floodplain, are discussed
in RDEIR Section 3.9, Hydrology and Water Quality.
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ALEXANDER
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Wendy Alexander (ALEXANDER)
Response to ALEXANDER-1
Comment noted. Please refer to Master Response 1—Plan Consistency. Please see Master Response
6—Stewardship of Open Space.
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Carolyn Aliotta (ALIOTTA)
Response to ALIOTTA-1
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17. Impacts related to
wildfire, please refer to Master Response 5—Wildfire Risk. As discussed in RDEIR Section 3.8,
Hazards and Hazardous Materials, page 3.8-15, Mitigation Measure HAZ-5 would require the
Applicant to prepare and submit plans to the City of Orange for review and approval demonstrating
compliance with all applicable emergency access provisions of the Fire Code, prior to issuance of the
first building permit. The approved plan shall be incorporated into the proposed project.
Response to ALIOTTA-2
Please refer to Master Response 1—Plan Consistency. Impacts related to transportation are
discussed in RDEIR 3.16.
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ANDERSON
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Angel Anderson (ANDERSON)
Response to ANDERSON-1
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17.
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ANDREWS 1
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Janet Andrews (ANDREWS 1)
Response to ANDREWS 1-1
Comment noted. Please refer to Master Response 1—Plan Consistency.
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Paul Andrews (ANDREWS 2)
Response to ANDREWS 2-1
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only require analysis of potential physical impacts on
the environment.
Response to ANDREWS 2-2
Comment noted. Impacts related to hydrology and water quality, including floodplain, are discussed
in RDEIR Section 3.9, Hydrology and Water Quality. Impacts related to fault line and liquefaction are
discussed in RDEIR Section 3.6, Geology and Soils. Please refer to Master Response 4—Dam Safety
and Risk of Failure.
Response to ANDREWS 2-3
As discussed in RDEIR Section 3.8, Hazards and Hazardous Materials, page 3.8-12, Tait Environmental
Services conducted a Phase II ESA of the project site that evaluated potential exposure to hazardous
materials from the past land use activities and the neighboring landfill. Tait Environmental Services
found that there was the potential for (1) vapor intrusion of TCE and methane into future dwelling
units and (2) elevated levels of TPH in soil. However, the proposed occupied structures will be
situated strategically to allow for future remediation of any potential landfill gas migration,
consistent with the DTSC or other applicable regulatory agency. Accordingly, Mitigation Measures
HAZ-2a to HAZ-2c are proposed to abate these conditions to a level of less than significant.
Response to ANDREWS 2-4
Comment noted. This comment will be provided to the City decision makers for their review and
consideration in determining whether to approve the project.
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Khalil Arshaid (ARSHAID)
Response to ARSHAID-1
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17 and Master Response
5—Wildfire Risk. As discussed in RDEIR Section 3.8, Hazards and Hazardous Materials, page 3.8-15,
Mitigation Measure HAZ-5 would require the Applicant to prepare and submit plans to the City of
Orange for review and approval demonstrating compliance with all applicable emergency access
provisions of the Fire Code, prior to issuance of the first building permit. The approved plan shall be
incorporated into the proposed project. Impacts related to air quality are discussed in RDEIR Section
3.3, Air Quality.
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Kathy Ashford (ASHFORD)
Response to ASHFORD-1
Comment noted. This comment will be provided to the City decision makers for their review and
consideration in determining whether to approve the project.
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ASHFORD & THOMAS
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Kathy Ashford and Laura Thomas (ASHFORD & THOMAS)
Response to ASHFORD & THOMAS-1
The commenter refers to a letter dated May 28, 2003, which the commenter requests should be
disregarded. This comment is noted and no further response is required. The 2003 letter will be
disregarded.
Response to ASHFORD & THOMAS-2
Comment noted. Please refer to Master Response 1—Plan Consistency.
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BAUSLEY
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Alicia Bausley (BAUSLEY)
Response to BAUSLEY-1
Comment noted. Please refer to Master Response 1—Plan Consistency. Impacts related to land use
and planning are discussed in RDEIR Section 3.10, Land Use and Planning.
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Gary and Diane Benson (BENSON)
Response to BENSON-1
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17.
Response to BENSON-2
Comment noted. Please refer to Master Response 1—Plan Consistency.
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Michael Bonnaud (BONNAUD)
Response to BONNAUD-1
Comment noted. Impacts related to hazards are discussed in RDEIR Section 3.8, Hazards and
Hazardous Materials.
Response to BONNAUD-2
Comment noted. For impacts related to truck trips, please see Master Response 9–Soil
Import/Export Numbers. Impacts related to zoning are discussed in RDEIR Section 3.10, Land Use
and Planning.
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Donald E. Bradley (BRADLEY 1)
Response to BRADLEY 1-1
Please refer to Response to SMW-15.
Response to BRADLEY 1-2
Please refer to Response to Stichter-7, Master Response 7—Applicability of SMARA, and Master
Response 8—Site Environmental Conditions. As discussed in RDEIR Section 3.8, Hazards and
Hazardous Materials, the 2011 Tait Phase II ESA determined that asbestos, which was previously
located on the project site as indicated by the 2000 and 2009 Phase I ESAs, no longer exists.
Mitigation Measure HAZ-2a requires a Phase II Environmental Site Assessment to be conducted for
the project. Any hazardous soil conditions identified by the Phase II ESA will be abated in compliance
with clean up goals for unrestricted land use, or the Applicant will be required to implement a land
use covenant and long-term operations and maintenance plan approved by DTSC. These
requirements would ensure that runoff from the project site would not be contaminated and would
not affect drinking water supplies.
Response to BRADLEY 1-3
Please refer to Response to SMW-17.
Response to BRADLEY 1-4
Please refer to Master Response 9—Soil Import/Export Numbers.
Response to BRADLEY 1-5
Please see Response to Villa Park-7.
Response to BRADLEY 1-6
Please see Master Response 1—Plan Consistency.
Response to BRADLEY 1-7
Please refer to Master Response 6—Stewardship of Open Space.
Response to BRADLEY 1-8
Comment noted. The comment consists of conclusory remarks. Commenter does not elaborate
further on why the RDEIR fails to meet the requirements of CEQA; therefore, a more detailed
response is not possible nor warranted under CEQA Guidelines.
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Toni Bradley (BRADLEY 2)
Response to BRADLEY 2-1
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition.
Response to BRADLEY 2-2
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17.
Response to BRADLEY 2-3
Comment noted. Please refer to Master Response 1—Plan Consistency.
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Cathy Brodsky (BRODSKY 1)
Response to BRODSKY 1-1
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition. For impacts related to fire hazards, please refer to Master Response 5—Wildfire Risk. As
discussed in RDEIR Section 3.8, Hazards and Hazardous Materials, page 3.8-15, Mitigation Measure
HAZ-5 would require the Applicant to prepare and submit plans to the City of Orange for review and
approval demonstrating compliance with all applicable emergency access provisions of the Fire
Code, prior to issuance of the first building permit. The approved plan shall be incorporated into the
proposed project. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17.
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Jackie Brodsky (BRODSKY 2)
Response to BRODSKY 2-1
Comment noted. This comment supports the development of the project. No further response is
necessary.
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Michele Brown (BROWN)
Response to BROWN-1
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17.
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Ercell Bryant (BRYANT 1)
Response to BRYANT 1-1
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17.
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Sharon L. Bryant (BRYANT 2)
Response to BRYANT 2-1
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17.
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Lucy Busby (BUSBY 1)
Response to BUSBY 1-1
Comment noted. This comment states that 128 houses is “too much.” This comment is noted and
will be provided to the City decision makers for their review and consideration in determining
whether to approve the project, and what conditions of approval to consider in connection with that
decision.
Response to BUSBY 1-2
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
Response to BUSBY 1-3
Please refer to Response to SMW-15.
Response to BUSBY 1-4
This comment suggests that a mixture of 8,000- to 9,000-square-feet; more than 10,000-square-feet;
more than 20,000-square-feet; and more than 40,000-square-foot lot sizes would be a better mix
and reflect the surrounding neighborhoods accurately. This comment is noted and no further
response is necessary, as the comment does not address any aspect of the current environmental
assessment. CEQA only requires analysis of potential physical impacts on the environment.
Response to BUSBY 1-5
Comment noted. As discussed in RDEIR Section 2, Project Description, page 2-33, East Santiago
Canyon Road, a four-lane, divided roadway, forms the southern boundary of the project site.
Detached single-family dwelling units associated with the Jamestown neighborhood (typical lot size
8,000–11,000 square feet), Orange Park Acres (typical lot size 50,000 square feet to 1 acre plus
additional square footage), the Fairhills Eichler Homes (typical lot size 7,600–12,000 square feet),
and The Colony-South (typical lot size 7,000–10,000 square feet) are located south of the roadway.
The Mara Brandman Arena is located at the intersection of East Santiago Canyon Road and North
Nicky Way.
Response to BUSBY 1-6
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
Response to BUSBY 1-7
Please refer to Master Response 6—Stewardship of Open Space.
Response to BUSBY 1-8
Please refer to Master Response 6—Stewardship of Open Space.
Response to BUSBY 1-9
This comment suggests that any approval of the Trails at Santiago Specific Plan should include at a
minimum the existing four openings to the Mabury Trail (Trail C) from both directs of Mabury
Avenue and the Greenway Open Space, Area A. The project Applicant proposes on-site trails with
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points of connection at the project boundary with the intent that off-site extensions and
connectivity to other trail systems will be by other entities or agencies. This comment is noted and
will be provided to the City decision makers for their review and consideration in determining
whether to approve the project.
Response to BUSBY 1-10
Comment noted. Please refer to Response to SMW-15. Pursuant to CEQA Guidelines Section 15163,
a supplemental/subsequent EIR is necessary if there is a change in the project or circumstances, or
new information that was not known previously indicates the project will have a significant effect on
the environment that was not covered in the previous EIR. The Lead or Responsible Agency may
choose to prepare a supplement to an EIR rather than a subsequent EIR to make minor additions or
changes necessary to make the previous EIR adequately apply to the project in the changed
situation.
Response to BUSBY 1-11
Pursuant to Public Resource Code Section 21081.6(a); Guidelines Section 15091(d) and 15097, a
Mitigation Monitoring and Reporting Plan (MMRP) will be adopted by the City of Orange, upon
project approval. The reporting or monitoring program must ensure compliance with mitigation
measures during project implementation.
Response to BUSBY 1-12
Comment noted. Please refer to Response to SWM-17 and RDEIR Section 3.16, Transportation and
Traffic.
Response to BUSBY 1-13
The commenter does not elaborate on the concerns they have over the air quality during this
process. Impacts related to air quality are discussed in RDEIR Section 3.3, Air Quality. Please see
Response to BUSBY 1-11 regarding implementation of mitigation measures.
Response to BUSBY 1-14
As discussed in Appendix A, as a component of the Pre-development Agreement, the Developer is
committing to lower the material stockpiles on the site. This significant public benefit is being
provided by the Developer in advance of obtaining any land use approvals. Per the agreement, the
Developer will have 90 days to prepare and submit to the City a stockpile reduction plan (“Interim
Remediation Plan”). The agreement allows the Developer to discontinue the Interim Remediation
Plan should they withdraw their land use entitlement application.
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Todd Busby (BUSBY 2)
Response to BUSBY 2-1
Comment noted. Please refer to Response to SMW-15.
Response to BUSBY 2-2
Comment noted. Please refer to Response to BUSBY 1-5.
Response to BUSBY 2-3
Comment noted. Please refer to RDEIR Exhibit 2-5, Surrounding Properties with Lot Sizes Under
10,000 sq. ft., for surrounding areas to the south of the project site.
Response to BUSBY 2-4
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment.
Response to BUSBY 2-5
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment.
Response to BUSBY 2-6
Comment noted. The project will be required to comply with the City of Orange Zoning Code
concerning building height restrictions. No further response is necessary, as the comment does not
address any aspect of the current environmental assessment.
Response to BUSBY 2-7
As discussed in RDEIR Section 3.8, Hazards and Hazardous Materials, page 3.8-13, Mitigation
Measure HAZ-2b requires that the project Applicant, prior to issuance of grading permits, “. . . shall
retain a qualified hazardous materials contractor to remove all soil containing TPH in excess of
residential development standards set forth by the DTSC or other applicable regulatory agency. Soil
removal and disposal shall occur in accordance with DTSC (or other applicable agency) guidelines.
The Applicant shall submit documentation to the City of Orange in the form of confirmatory soil
sampling results verifying that this mitigation measure was successfully implemented as part of the
grading permit application for this property. All environmental investigations, sampling and/or
remediation for the project site shall be conducted under a workplan approved and overseen by a
regulatory agency with jurisdiction to oversee hazardous substance cleanup, such as the RWQCB. As
part of proper construction operations and maintenance, any construction areas that are found to
contain contaminated soils shall be excluded using a security fence. All contaminated soils shall then
be excavated and disposed of off-site in accordance with the rules and regulations of: US
Department of Transportation (USDOT), USEPA, CalEPA, CalOSHA, and any local regulatory agencies.
All retention and detention features used during construction would be lined to prevent infiltration
through contaminated soils. Post-construction retention features shall be lined to prevent infiltration
of groundwater.”
Response to BUSBY 2-8
Please refer to Master Response 6—Stewardship of Open Space.
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Response to BUSBY 2-9
As discussed in Appendix Q, Trails at Santiago Specific Plan, the majority of the project site (62.7
percent) is intended for the enhancement and preservation of the natural greenway/open space and
Santiago Creek environs (Planning Area A) in the northern portions of the project, as well as re-
establishing open grasslands in the easterly portions of the site (Planning Area B) in areas that have
been denuded by the project site’s history of commercial operations. Recreational trails will traverse
both Planning Areas and will provide public access to the site.
Response to BUSBY 2-10
Impacts related to transportation are discussed in RDEIR Section 3.16, Transportation and Traffic.
Furthermore, please refer to Response to SMW-17.
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Sharon Butterfield (BUTTERFIELD)
Response to BUTTERFIELD-1
Comment noted. Please refer to Master Response 1—Plan Consistency. Impacts related to
transportation are discussed in RDEIR Section 3.16, Transportation and Traffic. Furthermore, please
refer to Response to SMW-17.
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Mark Capurso (CAPURSO)
Response to CAPURSO-1
Comment noted. This comment will be provided to the City decision makers for their review and
consideration in determining whether to approve the project. Impacts related to transportation are
discussed in RDEIR Section 3.16, Transportation and Traffic. Furthermore, please refer to Response to
SMW-17.
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Mary E. Carlson (CARLSON)
Response to CARLSON-1
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17. Impacts related to
emergency evacuation are discussed in RDEIR Section 3.8. Hazards and Hazardous Materials, page
3.8-15, Mitigation Measure HAZ-5 would require the Applicant to prepare and submit plans to the
City of Orange for review and approval demonstrating compliance with all applicable emergency
access provisions of the Fire Code, prior to issuance of the first building permit. The approved plan
shall be incorporated into the proposed project. Furthermore, as discussed in RDEIR Section 3.9,
Hydrology and Water Quality, page 3.9-27, Mitigation Measure HYD-5 requires the Applicant to
retain a qualified consultant to prepare and implement an Emergency Evacuation Plan. The plan shall
identify the various types of emergency that could affect the proposed project (e.g., dam failure,
earthquake, flooding, etc.) and identify procedures for the safe and orderly evacuation of the
project. The plan shall require that streets be identified with clear and visible signage and, if
necessary, wayfinding signage be provided to identify exit points.
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Holly Caswell (CASWELL)
Response to CASWELL-1
Comment noted. This comment will be provided to the City decision makers for their review and
consideration in determining whether to approve the project.
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James A. Cathcart (CATHCART)
Response to CATHCART-1
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to CATHCART-2
The commenter asks how an average lot size of 10,300 square feet, as noted in RDEIR Section 2,
Project Description, page 2-39, is possible when the proposed homes range in size from 8,000—
9,000 square feet; 9,200—10,000 square feet, and 10,000 square feet and greater.
The project proposes development of 128 dwelling units on approximately 40.7 acres, including 82
lots of approximately 8,000 square feet, 17 lots of approximately 9,200 square feet, and 29 lots of
approximately 10,000 square feet. The average lot size of 10,300 square feet, which is cited on page
2-39 of the RDEIR, was determined by taking the total square footage of the residential development
area (40.7 acres) and subtracting the square footage of street right-of-ways, pocket parks, and other
non-residential areas, and then dividing the square footage by 128 units. This calculation method
provides a conservative estimate of impacts because it overestimates the average lot size. As noted
in the RDEIR, considering only the residential portion of the project site, the density of the project
would be 3.1 dwelling units per acre (128 homes on 40.7 acres). A density of 3.1 dwelling units per
acre is on the low end of the General Plan’s allowable density for the “low-density residential”
designation.
Response to CATHCART-3
Please refer to Master Response 1—Plan Consistency.
Response to CATHCART-4
Please refer to Master Response 9—Soil Import/Export Numbers.
Response to CATHCART-5
Please refer to Response to VILLA PARK-6.
Response to CATHCART-6
Please refer to Response to SMW-67.
Response to CATHCART-7
Please refer to Master Response 9—Soil Import/Export Numbers.
Response to CATHCART-8
Please refer to Response to SMW-33.
Response to CATHCART-9
Please refer to Master Response 6—Stewardship of Open Space.
Response to CATHCART-10
Comment noted. This comment suggests a stable and turnout area be considered in the project site.
This comment will be provided to the City decision makers for their review and consideration in
determining whether to approve the project. No further response is necessary, as the comment does
not address any aspect of the current environmental assessment.
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Response to CATHCART-11
Comment noted. The comment consists of conclusory remarks. Please refer to Master Response 1—
Plan Consistency.
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Scott Chaplin (CHAPLIN)
Response to CHAPLIN-1
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17. Impacts related to
plan consistency, please refer to Master Response 1—Plan Consistency.
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Patricia Closson (CLOSSON)
Response to CLOSSON-1
Comment noted. For impacts regarding plan consistency, please refer to Master Response 1—Plan
Consistency.
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Edward Cook (COOK)
Response to COOK-1
Comment noted. Impacts related to hydrology and water quality, including floodplain, are discussed
in RDEIR Section 3.9, Hydrology and Water Quality.
Response to COOK-2
Comment noted. CEQA only requires analysis of potential physical impacts on the environment. This
comment is related to social or economic concerns and do not identify any environmental issue
within the purview of CEQA or the EIR; thus, no further response is necessary.
Response to COOK-3
Comment noted. CEQA only requires analysis of potential physical impacts on the environment. This
comment is related to social or economic concerns and do not identify any environmental issue
within the purview of CEQA or the EIR; thus, no further response is necessary.
Response to COOK-4
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17.
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Victoria Coonradt (COONRADT)
Response to COONRADT-1
Comment noted. Please refer to Master Response 2—Adequacy of Project Description.
Response to COONRADT-2
Comment noted. Please refer to Master Response 3—Analysis of Alternatives.
Response to COONRADT-3
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to COONRADT-4
Comment noted. CEQA only requires analysis of potential physical impacts on the environment. The
remainder of this comment is related to social or economic concerns and do not identify any
environmental issue within the purview of CEQA or the EIR; thus, no further response is necessary.
Response to COONRADT-5
The commenter states an opinion that impacts to wildlife, wetlands, streambeds, and riparian
habitats are significant without providing any supporting facts. Impacts related to wildlife and
wildlife habitat, wetlands, streambeds and riparian habitats are discussed in RDEIR Section 3.4,
Biological Resources. As discussed in RDEIR Section 3.4, all impacts would be reduced to a less than
significant level with mitigation incorporated. Without additional details or facts to support the
commenter’s opinion, a more detailed response is not possible or warranted under the CEQA
Guidelines.
Response to COONRADT-6
The commenter states an opinion that East Santiago Canyon Road is overburdened with traffic and
the project would add more traffic, potentially causing safety risks and hazards. Comment noted.
Impacts related to traffic are discussed in RDEIR Section 3.16, Transportation and Traffic. As
discussed in Section 3.16, Impact TRANS-2, impacts would remain significant and unavoidable after
implementation of mitigation and would require a statement of overriding considerations to be
adopted by the City prior to approval of the project. Potential hazards are discussed in Impact
TRANS-5. As discussed, the project’s impacts related to safety hazards would be less than significant
with implementation of Mitigation Measure TRANS-5, which would ensure adequate ingress and
egress to the site.
Response to COONRADT-7
The commenter states an opinion that the project is a bad idea and that the EIR does not address
problems the project would bring to the community. The commenter does not provide any
supporting facts to support the comment, nor does the commenter note any specific environmental
concerns or questions. Therefore, a more detailed response is not possible or warranted under
CEQA Guidelines.
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Daniel Correa (CORREA)
Response to CORREA-1
Comment noted. The comment consists of introductory remarks that do not raise any questions
about the environmental analysis.
Response to CORREA-2
Please refer to Master Response 4—Dam Safety and Risk of Failure.
Response to CORREA-3
As discussed in RDEIR Section 3.9, Hydrology and Water Quality, page 3.9-10, the Santiago Dam is
located 5 miles upstream of the project site.
Response to CORREA-4
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment.
Response to CORREA-5
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment.
Response to CORREA-6
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment.
Response to CORREA-7
No indication of this information would alter the findings of the analysis. No further response is
necessary, as the comment does not address any aspect of the current environmental assessment.
Response to CORREA-8
No indication of this information would alter the findings of the analysis. No further response is
necessary, as the comment does not address any aspect of the current environmental assessment.
Response to CORREA-9
Comment noted. Seismic Hazards are discussed in RDEIR Section 3.6, Geology and Soils.
Response to CORREA-10
Please see Master Response 7—Applicability of SMARA.
Response to CORREA-11
Comment noted. Please see Section 3.1, List of Authors, of this Final EIR for a list of agencies and
interested parties who provided comments on the RDEIR.
Response to CORREA-12
Please see Master Response 7—Applicability of SMARA.
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Response to CORREA-13
Please refer to Response to SMW-36. Furthermore, RDEIR Section 2, Project Description, subsection
2.5.2, Responsible and Trustee Agencies, page 2-65, includes a list of Responsible and Trustee
Agencies, which have been notified of the project.
Response to CORREA-14
This comment cannot be understood. No further response necessary.
COUISINE
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Cindy Couisine (COUISINE)
Response to COUISINE-1
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17.
Response to COUISINE-2
Comment noted. Impacts related to hydrology and water quality, including floodplain, are discussed
in RDEIR Section 3.9, Hydrology and Water Quality.
Response to COUSINE-3
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
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COURCHAINE 1
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Patrick Courchaine (COURCHAINE 1)
Response to COURCHAINE 1-1
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition. Impacts related to transportation are discussed in RDEIR Section 3.16, Transportation
and Traffic. Furthermore, please refer to Response to SMW-17.
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Tanya Courchaine (COURCHAINE 2)
Response to COURCHAINE 2-1
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition. Impacts related to transportation are discussed in RDEIR Section 3.16, Transportation
and Traffic. Furthermore, please refer to Response to SMW-17. Impacts related to air quality are
discussed in RDEIR Section 3.3, Air Quality. Impacts related to hazards and hazardous materials are
discussed in RDEIR Section 3.8, Hazards and Hazardous Materials.
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CRANDALL
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Donna Crandall (CRANDALL)
Response to CRANDALL-1
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
Response to CRANDALL-2
As discussed in RDEIR Section 3.8, Hazards and Hazardous Materials, page 3.8-12, Tait Environmental
Services conducted a Phase II ESA of the project site that evaluated potential exposure to hazardous
materials from the past land use activities and the neighboring landfill. Tait Environmental Services
found that there was the potential for (1) vapor intrusion of TCE and methane into future dwelling
units and (2) elevated levels of TPH in soil. However, the proposed occupied structures will be
situated strategically to allow for future remediation of any potential landfill gas migration,
consistent with the DTSC or other applicable regulatory agency. Accordingly, Mitigation Measures
HAZ-2a to HAZ-2c are proposed to abate these conditions to a level of less than significant.
Response to CRANDALL-3
Comment noted. Impact related to truck trips, please see Master Response 9–Soil Import/Export
Numbers.
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Tom Davidson (DAVIDSON)
Response to DAVIDSON-1
Comment noted. Impacts related to air quality are discussed in RDEIR Section 3.3, Air Quality.
Impacts related to transportation are discussed in RDEIR Section 3.16, Transportation and Traffic.
Grading and Earthwork is discussed in RDEIR Section 2, Project Description, page 2-62. Impacts
related to recreation are discussed in RDEIR Section 3.15, Recreation. Impacts related to land use
and planning are discussed in RDEIR Section 3.10, Land Use and Planning. Impacts related to mineral
resources are discussed in RDEIR Section 3.11, Mineral Resources.
Response to DAVIDSON-2
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic and RDEIR Appendix P, Traffic Impact Analysis.
Response to DAVIDSON-3
Comment noted. Impacts related to recreation are discussed in RDEIR Section 3.15, Recreation.
Response to DAVIDSON-4
The comment appears to support the project’s proposed clustering. The comment is noted and no
further response is required.
Response to DAVIDSON-5
Comment noted. Impacts related to mineral resources are discussed in RDEIR Section 3.11, Mineral
Resources. Specifically, SMARA is discussed in detail in Appendix M, City of Orange SMARA Memo.
Please refer to Master Response 7—Applicability of SMARA.
Response to DAVIDSON-6
The comment appears to support a reduced density version of the project. The comment is noted
and will be provided to the decision-makers for their consideration of the project as a whole.
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DAY
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Larry Day (DAY)
Response to DAY-1
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition. No further response is necessary, as the comment does not address any aspect of the
current environmental assessment. CEQA only requires analysis of potential physical impacts on the
environment.
Response to DAY-2
Comment noted. Commenter does not elaborate further on how the RDEIR continues to be “weak”
in regards to dust pollution, traffic concerns, trucking trips, SMARA, open space, etc.; therefore, a
more detailed response is not possible nor warranted under CEQA Guidelines.
Response to DAY-3
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to DAY-4
No further response is necessary, as the comment does not address any aspect of the current
environmental assessment. CEQA only requires analysis of potential physical impacts on the
environment.
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DENICOLA
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Gregg DeNicola (DENICOLA)
Response to DENICOLA-1
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition. Impacts related to transportation are discussed in RDEIR Section3.16, Transportation
and Traffic. Furthermore, please refer to Response to SMW-17.
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DES CHAMPS 1
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Diana Des Champs (DES CHAMPS 1)
Response to DES CHAMPS 1-1
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition. Impacts related to transportation are discussed in RDEIR Section 3.16, Transportation
and Traffic. Furthermore, please refer to Response to SMW-17.
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Diana Des Champs (DES CHAMPS 2)
Response to DES CHAMPS 2-1
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
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Linda Dickinson (DICKINSON)
Response to DICKINSON-1
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition. Impacts related to transportation are discussed in RDEIR Section 3.16, Transportation
and Traffic. Furthermore, please refer to Response to SMW-17.
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Richard L. Dobson (DOBSON)
Response to DOBSON-1
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition. Impacts related to transportation are discussed in RDEIR Section 3.16, Transportation
and Traffic. Furthermore, please refer to Response to SMW-17. Commenter does not elaborate
further on how the RDEIR is flawed; therefore, a more detailed response is not possible nor
warranted under CEQA Guidelines.
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DUCOLON
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Steve Ducolon (DUCOLON)
Response to DUCOLON-1
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
Response to DUCOLON-2
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17.
Response to DUCOLON-3
Comment noted. Impacts related to air quality are discussed in RDEIR Section 3.3, Air Quality.
Impacts related to biological resources, including arroyo toad habitat, are discussed in RDEIR Section
3.4, Biological Resources. Impacts related to hydrology and water quality, including floodplain, are
discussed in RDEIR Section 3.9, Hydrology and Water Quality. Furthermore, as discussed in RDEIR
Section 3.8, Hazards and Hazardous Materials, page 3.8-12, Tait Environmental Services conducted a
Phase II ESA of the project site that evaluated potential exposure to hazardous materials from the
past land use activities and the neighboring landfill. Tait Environmental Services found that there
was the potential for (1) vapor intrusion of TCE and methane into future dwelling units and (2)
elevated levels of TPH in soil. However, the proposed occupied structures will be situated
strategically to allow for future remediation of any potential landfill gas migration, consistent with
the DTSC or other applicable regulatory agency. Accordingly, Mitigation Measures HAZ-2a to HAZ-2c
are proposed to abate these conditions to a level of less than significant.
Response to DUCOLON-4
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
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DUMAN
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Michelle Duman (DUMAN)
Response to DUMAN-1
Comment noted. Impacts related to dam failure, please refer to Master Response 4—Dam Safety
and Risk of Failure.
Response to DUMAN-2
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17.
Response to DUMAN-3
Comment noted. Impacts related to air quality are discussed in RDEIR Section 3.3, Air Quality.
Response to DUMAN-4
Comment noted. As discussed in RDEIR Section 3.8, Hazards and Hazardous Materials, page 3.8-15,
Mitigation Measure HAZ-5 would require the Applicant to prepare and submit plans to the City of
Orange for review and approval demonstrating compliance with all applicable emergency access
provisions of the Fire Code, prior to issuance of the first building permit. The approved plan shall be
incorporated into the proposed project.
Response to DUMAN-5
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
Response to DUMAN-6
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
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EIMERS
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Steve Eimers (EIMERS)
Response to EIMERS-1
Comment noted. Impacts related to transportation are discussed in RDEIR Section3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17.
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ELAM
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Jane Elam (ELAM)
Response to ELAM-1
Comment noted. This comment will be provided to the City decision makers for their review and
consideration in determining whether to approve the project. Please refer to Master Response 10—
General Comments on Project, General Opposition.
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ELGIN
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Susan Elgin (ELGIN)
Response to ELGIN-1
Comments noted. Impacts related to the Orange Park Acres Plan, please refer to Master Response
1—Plan Consistency. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17. Impacts related to
emergency evacuation, as discussed in RDEIR Section 3.8, Hazards and Hazardous Materials, page
3.8-15, Mitigation Measure HAZ-5 would require the Applicant to prepare and submit plans to the
City of Orange for review and approval demonstrating compliance with all applicable emergency
access provisions of the Fire Code, prior to issuance of the first building permit. The approved Plan
shall be incorporated into the proposed project. Furthermore, as discussed in RDEIR Section 3.9,
Hydrology and Water Quality, page 3.9-27, Mitigation Measure HYD-5 requires the Applicant to
retain a qualified consultant to prepare and implement an Emergency Evacuation Plan. The Plan shall
identify the various types of emergency that could affect the proposed project (e.g., dam failure,
earthquake, flooding, etc.) and identify procedures for the safe and orderly evacuation of the project
area. The Plan shall require that streets be identified with clear and visible signage and, if necessary,
wayfinding signage be provided to identify exit points.
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Maria A. Fahie (FAHIE)
Response to FAHIE-1
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
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FARNHAM
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Jessica Farnham (FARNHAM)
Response to FARNHAM-1
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17.
Response to FARNHAM-2
Comment noted. Comment noted. This comment will be provided to the City decision makers for
their review and consideration in determining whether to approve the project.
Response to FARNHAM-3
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
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FELICIANI
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Annette Feliciani (FELICIANI)
Response to FELICIANI-1
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17.
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FERGUSON
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Pam and Bruce Ferguson (FERGUSON)
Response to FERGUSON-1
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17.
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FINN
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John and Toni Finn (FINN)
Response to FINN-1
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17.
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FITZ
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Hollis W. Fitz (FITZ)
Response to FITZ-1
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17.
Response to FITZ-2
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition.
Response to FITZ-3
Comment noted. Please refer to Master Response 1—Plan Consistency.
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FLATHERS
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Chris Flathers (FLATHERS)
Response to FLATHERS-1
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
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FONG
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David Fong (FONG)
Response to FONG-1
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17. Impacts related to
noise are discussed in RDEIR Section 3.12.
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James and Shirley Fraser (FRASER)
Response to FRASER-1
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17.
Response to FRASER-2
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
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Lynn-Marie and Richard Frediani (FREDIANI)
Response to FREDIANI-1
Comment noted. Commenter provides opening remarks expressing opposition for the project.
Please refer to Master Response 1—Plan Consistency. This comment will be provided to the City
decision makers for their review and consideration in determining whether to approve the project.
Response to FREDIANI-2
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17.
Response to FREDIANI-3
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to FREDIANI-4
Comment noted. Please see Master Response 6—Stewardship of Open Space.
Response to FREDIANI-5
Comment noted. Please see Master Response 6—Stewardship of Open Space.
Response to FREDIANI-6
Comment noted. Impacts related to access, circulation, and transportation are discussed in RDEIR
Section 3.16, Transportation and Traffic.
Response to FREDIANI-7
Comment noted. Commenter restates opposition to the project. No further response is necessary.
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Andy and Maryann Gaither (GAITHER)
Response to GAITHER-1
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
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GARUFIS
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Alex and Carrie Garufis (GARUFIS)
Response to GARUFIS-1
Please refer to Master Response 1—Plan Consistency. Furthermore, as discussed in RDEIR Section
3.8, Hazards and Hazardous Materials, page 3.8-12, Tait Environmental Services conducted a Phase II
ESA of the project site that evaluated potential exposure to hazardous materials from the past land
use activities and the neighboring landfill. Tait Environmental Services found that there was the
potential for (1) vapor intrusion of TCE and methane into future dwelling units and (2) elevated
levels of TPH in soil. However, the proposed occupied structures will be situated strategically to allow
for future remediation of any potential landfill gas migration, consistent with the DTSC or other
applicable regulatory agency. Accordingly, Mitigation Measures HAZ-2a to HAZ-2c are proposed to
abate these conditions to a level of less than significant.
Response to GARUFIS-2
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17.
Response to GARUFIS-3
Comment noted. Impacts related to open space are discussed in RDEIR Section 3.15, Recreation.
Response to GARUFIS-4
Comment noted. The comment consists of concluding remarks that do not raise any questions about
the environmental analysis.
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GARZA 1
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Maggie Garza (GARZA 1)
Response to GARZA 1-1
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17.
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GARZA 2
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Robert Garza (GARZA 2)
Response to GARZA 2-1
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17.
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GAUDETTE
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Marian Gaudette (GAUDETTE)
Response to GAUDETTE-1
Comment noted. Impacts related to Geology and Soils are discussed in RDEIR Section 3.6, Geology.
Please refer to Master Response 7—Applicability of SMARA.
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GERAKOS
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Mike and Kathy Gerakos (GERAKOS)
Response to GERAKOS-1
Comment noted. This comment will be provided to the City decision makers for their review and
consideration in determining whether to approve the project.
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GERGER
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Robert Gerger (GERGER)
Response to GERGER-1
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17.
Response to GERGER-2
Comment noted. Comment noted. No further response is necessary, as the comment does not
address any aspect of the current environmental assessment. CEQA only requires analysis of
potential physical impacts on the environment.
Response to GERGER-3
Comment noted. Impacts related to hydrology and water quality, including floodplain, are discussed
in RDEIR Section 3.9, Hydrology and Water Quality.
Response to GERGER-4
Comment noted. Comment noted. No further response is necessary, as the comment does not
address any aspect of the current environmental assessment. CEQA only requires analysis of
potential physical impacts on the environment.
Response to GERGER-5
Comment noted. Comment noted. No further response is necessary, as the comment does not
address any aspect of the current environmental assessment. CEQA only requires analysis of
potential physical impacts on the environment.
Response to GERGER-6
Comment noted. Comment noted. No further response is necessary, as the comment does not
address any aspect of the current environmental assessment. CEQA only requires analysis of
potential physical impacts on the environment.
Response to GERGER-7
Comment noted. Comment noted. No further response is necessary, as the comment does not
address any aspect of the current environmental assessment. CEQA only requires analysis of
potential physical impacts on the environment.
Response to GERGER-8
Comment noted. Please refer to Master Response 1—Plan Consistency.
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GLADSON
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Adrienne J. Gladson (GLADSON)
Response to GLADSON-1
This comment incorrectly assumes that 13 acres are currently residential and the remaining 96.2
acres are Open Space. However, this is not accurate. As explained in the RDEIR, 15.4 acres of Low-
Density as Residential (confirmed by the City of Orange Community Development Department) are
allowed in the north-central portion of the site, north of Santiago Creek and abutting Mabury Ranch
Road. Consistent with the General Plan’s density range of 2.1 to 6.0 units per acre, a target of 40 to
55 residential homes on this 15.4-acre residential land use parcel. The existing R-1-8 Zoning for the
residential area would yield approximately 40 to 50 single-family dwelling units. Access to this
residential parcel would be from Mabury Avenue. A section of approximately 16.5 acres of Open
Space (OS) bisects the site in an east-west trend, generally following the Santiago Creek corridor, and
avails itself to creekside trails to allow for connectivity to regional trails to the west, and eventually
connecting to Santiago Oaks Regional Park to the east. The majority of the site, approximately 77.3
acres, is designated Resource Area (RA) which permits ongoing rock crushing and sand and gravel
operations. Rather than remove 27 acres from open space as the commenter suggests, the project
instead proposes the transformation of a rock and concrete materials recycling and backfilling
operation to an environmentally enhanced, ecologically friendly open space environment embracing
a well-planned and attractive single-family detached residential neighborhood. The environmental
impacts associated with this conversion are detailed throughout the RDEIR.
Response to GLADSON-2
The proposed project is consistent with the City’s goals regarding open space. Regarding the East
Orange General Plan, approximately 37 acres of the project site are located within the boundaries of
the East Orange General Plan and are designated “Regional Park.” That represents approximately 2
percent of the East Orange General Plan total area. The proposed project includes 68.5 acres of open
park space, split into 40.2 acres of Greenway Open Space/Santiago Creek Riparian Corridor and 28.3
acres of Grasslands Open Space. Therefore, the proposed project would include 68.5 acres of open
space/park uses adjacent to, and partially within, the East Orange General Plan; creating more open
space in the vicinity than the 37 acres of the project site that are within the East Orange General
Plan.
Response to GLADSON-3
Please refer to Master Response 1—Plan Consistency. The comment speculates regarding the intent
of the Orange Park Acres and East Orange General Plan. The proposed project’s consistency with
both plans is discussed in Section 3.10, Land Use and Planning, of the RDEIR. Table 3.10-3, East
Orange General Plan Consistency Analysis, further evaluates project consistency with the applicable
concepts of the East Orange General Plan. While the Orange Park Acres Plan does not outline goals
and policies similar to contemporary General Plans, or contain the specificity required of a Specific
Plan, the Orange Park Acres Plan does outline goals, objectives, and policies. Table 3.10-4, OPA Plan
Consistency Analysis, evaluates project consistency with the applicable objectives and policies of the
Orange Park Acres Plan. No revisions to the consistency analysis are required based on this
comment.
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Response to GLADSON-4
The Applicant is creating a funding source to restore and improve the open space and greenway
within the project site. On-site trails will be designed per the City of Orange RTMP dated April 27,
1993. The implementation of the Specific Plan and associated project will also fund a maximum of
$4,100,000.00 in landscape, trails and other improvements for the Santiago Creek Greenway and
Open Space. Furthermore, please refer to Master Response 9—Stewardship of Open Space.
GLADSTIEN
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Keith Gladstien (GLADSTIEN)
Response to GLADSTIEN-1
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
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GRAUPENSPERGER 1
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Dan Graupensperger (GRAUPENSPERGER 1)
Response to GRAUPENSPERGER 1-1
Comment noted. Please refer to Master Response 7—Applicability of SMARA.
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GRAUPENSPERGER 2
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Dan Graupensperger (GRAUPENSPERGER 2)
Response to GRAUPENSPERGER 2-1
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to GRAUPENSPERGER 2-2
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17.
Response to GRAUPENSPERGER 2-3
Comment noted. Please see Master Response 6—Stewardship of Open Space.
Response to GRAUPENSPERGER 2-4
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
Response to GRAUPENSPERGER 2-5
Comment noted. Impacts related to hydrology and water quality, including floodplain, are discussed
in RDEIR Section 3.9, Hydrology and Water Quality.
Response to GRAUPENSPERGER 2-6
Comment noted. Please refer to Master Response 7—Applicability of SMARA.
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GRAYSON
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Tom and Bobbie Grayson (GRAYSON)
Response to GRAYSON-1
Comment noted. Impacts related to hydrology and water quality, including floodplain, are discussed
in RDEIR Section 3.9, Hydrology and Water Quality.
Response to GRAYSON-2
As discussed in RDEIR Section 3.8, Hazards and Hazardous Materials, page 3.8-12, Tait Environmental
Services conducted a Phase II ESA of the project site that evaluated potential exposure to hazardous
materials from the past land use activities and the neighboring landfill. Tait Environmental Services
found that there was the potential for (1) vapor intrusion of TCE and methane into future dwelling
units and (2) elevated levels of TPH in soil. However, the proposed occupied structures will be
situated strategically to allow for future remediation of any potential landfill gas migration,
consistent with the DTSC or other applicable regulatory agency. Accordingly, Mitigation Measures
HAZ-2a to HAZ-2c are proposed to abate these conditions to a level of less than significant.
Response to GRAYSON-3
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17. Impacts related to
noise are discussed in RDEIR Section 3.12, Noise.
Response to GRAYSON-4
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
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GRESSAK
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Anthony Gressak (GRESSAK)
Response to GRESSAK-1
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
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GUERRERO-PHLAUM
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Martha Guerrero-Phlaum (GUERRERO-PHLAUM)
Response to GUERRERO-1
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17.
Response to GUERRERO-2
Comment noted. Impacts related to hydrology and water quality, including floodplain, are discussed
in RDEIR Section 3.9, Hydrology and Water Quality. Please refer to Master Response 5—Wildfire Risk.
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HAMAN
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Kim Haman (HAMAN)
Response to HAMAN-1
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
Response to HAMAN-2
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17.
Response to HAMAN-3
Comment noted. Impacts related to schools are discussed in RDEIR Section 3.14, Public Services.
Response to HAMAN-4
Comment noted. Impacts related to hazards are discussed in RDEIR Section 3.8, Hazards and
Hazardous Materials. Impacts related to hydrology and water quality, including floodplain, are
discussed in RDEIR Section 3.9, Hydrology and Water Quality. Please refer to Master Response 7—
Applicability of SMARA.
Response to HAMAN-5
Impacts related to biological resources, including arroyo toad habitat, are discussed in RDEIR Section
3.4, Biological Resources.
Response to HAMAN-6
Comment noted. See RDEIR.
Response to HAMAN-7
Comment noted. Please refer to Master Response 5—Wildfire Risk.
Response to HAMAN-8
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
Response to HAMAN-9
Comment noted. Impacts related to open space are discussed in RDEIR Section 3.15, Recreation.
Response to HAMAN-10
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
Response to HAMAN-11
Comment noted. The comment consists of concluding remarks that do not raise any questions about
the environmental analysis.
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HAMILTON
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Nancy Hamilton (HAMILTON)
Response to HAMILTON-1
Comment noted. Impacts related to transportation are discussed in RDEIR 3.16, Transportation and
Traffic. Furthermore, please refer to Response to SMW-17.
Response to HAMILTON-2
Comment noted. As discussed in RDEIR Section 3.8, Hazards and Hazardous Materials, page 3.8-15,
Mitigation Measure HAZ-5 would require the Applicant to prepare and submit plans to the City of
Orange for review and approval demonstrating compliance with all applicable emergency access
provisions of the Fire Code, prior to issuance of the first building permit. The approved plan shall be
incorporated into the proposed project.
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Jaime Hatzfeld (HATZFELD 1)
Response to HATZFELD 1-1
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition.
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Kirat Hatzfeld (HATZFELD 2)
Response to HATZFELD 2-1
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
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HEMMETER 1
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Sarah Hemmeter (HEMMETER 1)
Response to HEMMETER 1-1
Comment noted. Please refer to Master Response 1—Plan Consistency.
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Scott Hemmeter (HEMMETER 2)
Response to HEMMETER 2-1
Comment noted. Please refer to Master Response 1—Plan Consistency.
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HERBECK 1
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Kelly Herbeck (HERBECK 1)
Response to HERBECK 1-1
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17. Impacts related to air
quality are discussed in RDEIR Section 3.3, Air Quality. Impacts related to noise are discussed in
RDEIR Section 3.12, Noise.
Response to HERBECK 1-2
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
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Kelly Herbeck (HERBECK 2)
Response to HERBECK 2-1
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition.
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Kelly Herbeck (HERBECK 3)
Response to HERBECK 3-1
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition.
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Karen Hersom (HERSOM)
Response to HERSOM-1
Comment noted. This comment will be provided to the City decision makers for their review and
consideration in determining whether to approve the project.
Response to HERSOM-2
Comment noted. Impacts related to active faults are discussed in RDEIR Section 3.6, Geology and
Soils. Impacts related to hydrology and water quality, including flood plains, are discussed in RDEIR
Section 3.9, Hydrology and Water Quality. Please refer to Master Response 5—Wildfire Risk. Impacts
related to transportation are discussed in RDEIR Section 3.16, Transportation and Traffic.
Furthermore, please refer to Response to SMW-17.
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Marcos and Melissa Higareda (HIGAREDA)
Response to HIGAREDA-1
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition.
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Arlene Hillman (HILLMAN 1)
Response to HILLMAN 1-1
Comment noted. Impacts related to hydrology and water quality, including floodplain, are discussed
in RDEIR Section 3.9, Hydrology and Water Quality.
Response to HILLMAN 1-2
Comment noted. Please refer to Master Response 5—Wildfire Risk.
Response to HILLMAN 1-3
As discussed in RDEIR Section 3.8, Hazards and Hazardous Materials, page 3.8-12, Tait Environmental
Services conducted a Phase II ESA of the project site that evaluated potential exposure to hazardous
materials from the past land use activities and the neighboring landfill. Tait Environmental Services
found that there was the potential for (1) vapor intrusion of TCE and methane into future dwelling
units and (2) elevated levels of TPH in soil. However, the proposed occupied structures will be
situated strategically to allow for future remediation of any potential landfill gas migration,
consistent with the DTSC or other applicable regulatory agency. Accordingly, Mitigation Measures
HAZ-2a to HAZ-2c are proposed to abate these conditions to a level of less than significant.
Response to HILLMAN 1-4
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
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Charles Hillman (HILLMAN 2)
Response to HILLMAN 2-1
Please refer to Master Response 10—General Comments on Project, General Opposition.
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HILLMAN 3
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Barbara Hillman (HILLMAN 3)
Response to HILLMAN 3-1
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition.
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David Hillman (HILLMAN 4)
Response to HILLMAN 4-1
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition.
Response to HILLMAN 4-2
Comment noted. Please refer to Master Response 5—Wildfire Risk.
Response to HILLMAN 4-3
Comment noted. Impacts related to hydrology and water quality, including floodplain, are discussed
in RDEIR Section 3.9, Hydrology and Water Quality. Impacts related to liquefaction are discussed in
RDEIR Section 3.6, Geology and Soils.
Response to HILLMAN 4-4
Comment noted. Please refer to Master Response 2—Adequacy of Project Description.
Response to HILLMAN 4-5
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
Response to HILLMAN 4-6
Comment noted. Please see Master Response 6—Stewardship of Open Space
Response to HILLMAN 4-7
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
Response to HILLMAN 4-8
Comment noted. Please refer to Master Response 4—Dam Safety and Risk of Failure.
Response to HILLMAN 4-9
Comment noted. Please refer to Master Response 7—Applicability of SMARA.
Response to HILLMAN 4-10
Please refer to Master Response 10—General Comments on Project, General Opposition.
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HILLMAN 5
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Doug Hillman (HILLMAN 5)
Response to HILLMAN 5-1
Comment noted. Please refer to Master Response 7—Applicability of SMARA.
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HOMER
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Vickie Homer (HOMER)
Response to HOMER-1
Comment noted. Impacts related to soil are discussed in RDEIR Section 3.6, Geology and Soils.
Impacts related to hydrology and water quality, including floodplain, are discussed in RDEIR Section
3.9, Hydrology and Water Quality. Impacts related to air quality are discussed in RDEIR Section 3.3,
Air Quality. As discussed in RDEIR Section 3.8, Hazards and Hazardous Materials, page 3.8-15,
Mitigation Measure HAZ-5 would require the applicant to prepare and submit plans to the City of
Orange for review and approval demonstrating compliance with all applicable emergency access
provisions of the Fire Code, prior to issuance of the first building permit. The approved plan shall be
incorporated into the proposed project. For impacts related to plan consistency, please refer to
Master Response 1—Plan Consistency.
Response to HOMER-2
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17.
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HOOKER
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Jay and Donna (Chris) Hooker (HOOKER)
Response to HOMER-1
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition.
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HUFF 1
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Mark A. Huff (HUFF 1)
Response to HUFF 1-1
Comment noted. Impacts related to hydrology and water quality, including floodplain, are discussed
in RDEIR Section 3.9, Hydrology and Water Quality. Please refer to Master Response 5—Wildfire Risk.
As discussed in RDEIR Section 3.8, Hazards and Hazardous Materials, page 3.8-15, Mitigation
Measure HAZ-5 would require the Applicant to prepare and submit plans to the City of Orange for
review and approval demonstrating compliance with all applicable emergency access provisions of
the Fire Code, prior to issuance of the first building permit. The approved plan shall be incorporated
into the proposed project.
Response to HUFF 1-2
Comment noted. Impacts related to air quality are discussed in RDEIR Section 3.3, Air Quality. Please
refer to Master Response 7—Applicability of SMARA.
Response to HUFF 1-3
Comment noted. Impacts related to truck trips, please see Master Response 9–Soil Import/Export
Numbers.
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HUFF 2
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Sarah A. Huff (HUFF 2)
Response to HUFF 2-1
Comment noted. Please refer to Master Response 1—Plan Consistency.
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HUME
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Nancy and Tim Hume (HUME)
Response to HUME-1
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17. Impacts related to
noise are discussed in RDEIR Section 3.12, Noise.
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JACKLIN 1
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Peter Jacklin (JACKLIN 1)
Response to JACKLIN 1-1
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
Response to JACKLIN 1-2
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17.
Response to JACKLIN 1-3
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17.
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Peter Jacklin (JACKLIN 2)
Response to JACKLIN 2-1
Comment noted. Please refer to Master Response 7—Applicability of SMARA.
Response to JACKLIN 2-2
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17.
Response to JACKLIN 2-3
Comment noted. Impacts related to hydrology and water quality are discussed in RDEIR Section 3.9,
Hydrology and Water Quality. Impacts related to hazards are discussed in RDEIR Section 3.8, Hazards
and Hazardous Materials. Impacts related to air quality are discussed in RDEIR Section 3.3, Air
Quality.
Response to JACKLIN 2-4
Comment noted. CEQA only requires analysis of potential physical impacts on the environment. The
remainder of these comments are related to social or economic concerns and do not identify any
environmental issue within the purview of CEQA or the EIR; thus, no further response is necessary.
Response to JACKLIN 2-5
Comment noted. This comment does not raise any questions about the environmental analysis. No
further response is necessary.
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JOHNSON
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Thea Johnson (JOHNSON)
Response to JOHNSON-1
Comment noted. Impacts related to air quality are discussed in RDEIR Section 3.3, Air Quality.
Impacts related to hydrology and water quality are discussed in RDEIR Section 3.9, Hydrology and
Water Quality. Furthermore, the City of Villa Park provided a response to the RDEIR. A response to
that letter is listed in this document under Local Agencies.
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JOHNSTON
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Teresa Johnston (JOHNSTON)
Response to JOHNSTON-1
Comment noted. Please refer to Master Response 1—Plan Consistency.
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JONES 1
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Mary Ann Jones (JONES 1)
Response to JONES 1-1
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17.
Response to JONES 1-2
Comment noted. Please refer to Master Response 5—Wildfire Risk.
Response to JONES 1-3
As discussed in RDEIR Section 3.8, Hazards and Hazardous Materials, page 3.8-12, Tait Environmental
Services conducted a Phase II ESA of the project site that evaluated potential exposure to hazardous
materials from the past land use activities and the neighboring landfill. Tait Environmental Services
found that there was the potential for (1) vapor intrusion of TCE and methane into future dwelling
units and (2) elevated levels of TPH in soil. However, the proposed occupied structures will be
situated strategically to allow for future remediation of any potential landfill gas migration,
consistent with the DTSC or other applicable regulatory agency. Accordingly, Mitigation Measures
HAZ-2a to HAZ-2c are proposed to abate these conditions to a level of less than significant.
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JONES 2
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Susan Jones (JONES 2)
Response to JONES 2-1
Comment noted. Please refer to Master Response 5—Wildfire Risk. As discussed in RDEIR Section
3.8, Hazards and Hazardous Materials, page 3.8-15, Mitigation Measure HAZ-5 would require the
Applicant to prepare and submit plans to the City of Orange for review and approval demonstrating
compliance with all applicable emergency access provisions of the Fire Code, prior to issuance of the
first building permit. The approved plan shall be incorporated into the proposed project.
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KEYES
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Gayle Keyes (KEYES)
Response to JONES-1
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
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KIRKEBY 1
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Bob Kirkeby (KIRKEBY 1)
Response to KIRKEBY 1-1
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
Response to KIRKEBY 1-2
Comment noted. Impacts related to open space are discussed in RDEIR Section 3.15, Recreation.
Please see Master Response 6—Stewardship of Open Space
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Bob Kirkeby (KIRKEBY 2)
Response to KIRKEBY 2-1
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
Response to KIRKEBY 2-2
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17.
Response to KIRKEBY 2-3
As discussed in RDEIR Section 3.8, Hazards and Hazardous Materials, page 3.8-12, Tait Environmental
Services conducted a Phase II ESA of the project site that evaluated potential exposure to hazardous
materials from the past land use activities and the neighboring landfill. Tait Environmental Services
found that there was the potential for (1) vapor intrusion of TCE and methane into future dwelling
units and (2) elevated levels of TPH in soil. However, the proposed occupied structures will be
situated strategically to allow for future remediation of any potential landfill gas migration,
consistent with the DTSC or other applicable regulatory agency. Accordingly, Mitigation Measures
HAZ-2a to HAZ-2c are proposed to abate these conditions to a level of less than significant.
Response to KIRKEBY 2-4
Please see Master Response 6—Stewardship of Open Space
Response to KIRKEBY 2-5
Impacts related to hydrology and water quality, including floodplain, are discussed in RDEIR Section
3.9, Hydrology and Water Quality.
Response to KIRKEBY 2-6
Comment noted. Please refer to Master Response 4—Dam Safety and Risk of Failure.
Response to KIRKEBY 2-7
Comment noted. Impacts related to liquefaction are discussed in RDEIR Section 3.6, Geology and
Soils.
Response to KIRKEBY 2-8
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
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Katrina Kirkeby (KIRKEBY 3)
Response to KIRKEBY 3-1
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to KIRKEBY 2-2
Comment noted. Please refer to Master Response 2—Adequacy of Project Description.
Response to KIRKEBY 3-3
Comment noted. Please refer to Response to FHBP-2.
Response to KIRKEBY 3-4
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17. Please see Master
Response 9–Soil Import/Export Numbers. Please refer to Master Response 4—Dam Safety and Risk
of Failure. Please refer to Master Response 5—Wildfire Risk. As discussed in RDEIR Section 3.8,
Hazards and Hazardous Materials, page 3.8-15, Mitigation Measure HAZ-5 would require the
Applicant to prepare and submit plans to the City of Orange for review and approval demonstrating
compliance with all applicable emergency access provisions of the Fire Code, prior to issuance of the
first building permit. The approved plan shall be incorporated into the proposed project. Impacts
related to biological resources, including arroyo toad habitat, are discussed in RDEIR Section 3.4,
Biological Resources.
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Nora Kirkeby (KIRKEBY 4)
Response to KIRKEBY 4-1
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition.
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KLINKER
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Pat Klinker (KLINKER)
Response to KLINKER-1
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
Response to KLINKER-2
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17.
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KOWITZ
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Vernon Kowitz (KOWITZ)
Response to KOWITZ-1
Please refer to Master Response 10—General Comments on Project, General Opposition.
Response to KOWITZ-2
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to KOWITZ-3
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
Response to KOWITZ-4
Comment noted. Please see Master Response 9–Soil Import/Export Numbers.
Response to KOWITZ-5
Comment noted. Please refer to Master Response 7—Applicability of SMARA.
Response to KOWITZ-6
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17. Impacts related to air
quality are discussed in RDEIR Section 3.3, Air Quality. Impacts related to noise are discussed in
RDEIR Section 3.12, Noise. Impacts related to hydrology and water quality are discussed in RDEIR
Section 3.9, Hydrology and Water Quality. Impacts related to hazards are discussed in RDEIR Section
3.8, Hazards and Hazardous Materials.
Response to KOWITZ-7
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
Response to KOWITZ-8
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to KOWITZ-9
Comment noted. Please refer to Master Response 4—Dam Safety and Risk of Failure. Please refer to
Master Response 5—Wildfire Risk. Impacts related to earthquakes and liquefaction are discussed in
RDEIR Section 3.6, Geology and Soils. Furthermore, as discussed in RDEIR Section 3.8, Hazards and
Hazardous Materials, page 3.8-12, Tait Environmental Services conducted a Phase II ESA of the
project site that evaluated potential exposure to hazardous materials from the past land use
activities and the neighboring landfill. Tait Environmental Services found that there was the potential
for (1) vapor intrusion of TCE and methane into future dwelling units and (2) elevated levels of TPH
in soil. However, the proposed occupied structures will be situated strategically to allow for future
remediation of any potential landfill gas migration, consistent with the DTSC or other applicable
regulatory agency. Accordingly, Mitigation Measures HAZ-2a to HAZ-2c are proposed to abate these
conditions to a level of less than significant.
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Response to KOWITZ-10
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
Response to KOWITZ-11
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
Response to KOWITZ-12
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
Response to KOWITZ-13
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
KRIBEL
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Ken Kribel (KRIBEL)
Response to KRIBEL-1
Comment noted. The comment consists of introductory remarks that do not raise any questions
about the environmental analysis.
Response to KRIBEL-2
Comment noted. Impacts related to air quality are discussed in RDEIR Section 3.3, Air Quality.
Impacts related to open space are discussed in RDEIR Section 3.15, Recreation. Impacts related to
transportation are discussed in RDEIR Section 3.16, Transportation and Traffic. Please refer to Master
Response 9—Soil Import/Export Numbers. The commenter does not elaborate further; therefore, a
more detailed response is not possible nor warranted under CEQA Guidelines.
Response to KRIBEL-3
Comment noted. Please refer to Response to SMW-17.
Response to KRIBEL-4
Comment noted. Please refer to Master Response 1—Plan Consistency and Master Response 6—
Stewardship of Open Space.
Response to KRIBEL-5
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
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Nannette Kuhl (KUHL)
Response to KUHL-1
Comment noted. Please refer to Master Response 4—Dam Safety and Risk of Failure and Master
Response 5—Wildfire Risk.
Response to KUHL-2
Comment noted. Please refer to Response to SMW-17.
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Nick Lall (LALL)
Response to LALL-1
Comment noted. This comment supports the development of the project and no further response is
necessary.
Response to LALL-2
Comment noted. This comment supports the development of the project and no further response is
necessary.
Response to LALL-3
Comment noted. This comment supports the development of the project and discusses the impacts
of the current operations related to truck trips, noise, and dust. No further response is necessary.
Response to LALL-4
Comment noted. This comment supports the development of the project and no further response is
necessary.
Response to LALL-5
Comment noted. This comment supports the development of the project and no further response is
necessary.
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Jim and Diane Larson (LARSON)
Response to LARSON-1
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition and Response to SMW-17.
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LEFFLER
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Charles Leffler (LEFFLER)
Response to LEFFLER-1
Comment noted. Please refer to Master Response 7—Applicability of SMARA. Furthermore, as
discussed in RDEIR Section 3.8, Hazards and Hazardous Materials, page 3.8-12, Tait Environmental
Services conducted a Phase II ESA of the project site that evaluated potential exposure to hazardous
materials from the past land use activities and the neighboring landfill. Tait Environmental Services
found that there was the potential for (1) vapor intrusion of TCE and methane into future dwelling
units and (2) elevated levels of TPH in soil. However, the proposed occupied structures will be
situated strategically to allow for future remediation of any potential landfill gas migration,
consistent with the DTSC or other applicable regulatory agency. Accordingly, Mitigation Measures
HAZ-2a to HAZ-2c are proposed to abate these conditions to a level of less than significant.
Response to LEFFLER-2
Comment noted. Please refer to Master Response 7—Applicability of SMARA, Response to SMW-17,
and Master Response 9–Soil Import/Export Numbers.
Response to LEFFLER-3
Comment noted. Please see Response to Leffler-1.
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LESINSKI
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Frank Lesinski (LESINSKI 1)
Response to LESINSKI 1-1
Comment noted. Please refer to Response to SMW-17.
Response to LESINSKI 1-2
Comment noted. Please refer to Master Response 5—Wildfire Risk. Furthermore, as discussed in
RDEIR Section 3.8, Hazards and Hazardous Materials, page 3.8-15, Mitigation Measure HAZ-5 would
require the Applicant to prepare and submit plans to the City of Orange for review and approval
demonstrating compliance with all applicable emergency access provisions of the Fire Code, prior to
issuance of the first building permit. The approved plan shall be incorporated into the proposed
project.
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Stephanie Lesinski (LESINSKI 2)
Response to LESINKSI 2-1
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
Response to LESINSKI 2-2
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition and Master Response 1—Plan Consistency.
Response to LESINKSI 2-3
Comment noted. Please refer to Master Response 5—Wildfire Risk.
Response to LESINSKI 2-4
Comment noted. Please refer to Response to SMW-17.
Response to LESINKSI 2-5
Comment noted. Please see Master Response 9–Soil Import/Export Numbers.
Response to LESINSKI 2-6
Comment noted. Please refer to Master Response 1—Plan Consistency.
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Stephanie Lesinski (LESINSKI 3)
Response to LESINKSI 3-1
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17.
Response to LESINSKI 3-2
Comment noted. As discussed in RDEIR Section 3.8, Hazards and Hazardous Materials, page 3.8-15,
Mitigation Measure HAZ-5 would require the Applicant to prepare and submit plans to the City of
Orange for review and approval demonstrating compliance with all applicable emergency access
provisions of the Fire Code, prior to issuance of the first building permit. The approved plan shall be
incorporated into the proposed project.
Response to LESINKSI 3-3
Comment noted. Please refer to Master Response 7—Applicability of SMARA. Please see Master
Response 9–Soil Import/Export Numbers. Impacts related to transportation are discussed in RDEIR
Section 3.16, Transportation and Traffic. Furthermore, please refer to Response to SMW-17. Impacts
related to noise are discussed in RDEIR Section 3.12, Noise. Impacts related to air quality are
discussed in RDEIR Section 3.3, Air Quality.
Response to LESINSKI 3-4
Comment noted. Please see Master Response 6—Stewardship of Open Space.
Response to LESINKSI 3-5
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to LESINSKI 3-6
Comment noted. Commenter reiterates opposition for the project. No further response is necessary,
as the comment does not address any aspect of the current environmental assessment. CEQA only
requires analysis of potential physical impacts on the environment.
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LEUTERITZ
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Kimiya Leuteritz (LEUTERITZ)
Response to LEUTERITZ-1
Comment noted. Please refer to Master Response 1—Plan Consistency.
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Kathie and Herb Levy (LEVY)
Response to LEVY-1
Comment noted. Please refer to Master Response 7—Applicability of SMARA.
Response to LEVY-2
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition.
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Chris Lovell (LOVELL)
Response to LOVELL-1
Comment noted. Please refer to Master Response 1—Plan Consistency. Impacts related to
transportation are discussed in RDEIR Section 3.16, Transportation and Traffic. Impacts related to
noise are discussed in RDEIR Section 3.12, Noise. Impacts related to hydrology and water quality are
discussed in RDEIR Section 3.9, Hydrology and Water Quality. Impacts related to air quality are
discussed in RDEIR Section 3.3, Air Quality. Impacts related to open space are discussed in RDEIR
Section 3.15, Recreation.
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Barbara Luther (LUTHER)
Response to LUTHER-1
Comment noted. Please refer to Response to SMW-17.
Response to LUTHER-2
Comment noted. Please refer to Master Response 1—Plan Consistency.
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MALDONADO
3DJHRI
$0/5
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Marilyn Maldonado (MALDONADO)
Response to MALDONADO-1
Comment noted. This comment will be provided to the City decision makers for their review and
consideration in determining whether to approve the project. Please refer to Response to FHBP-10.
Response to MALDONADO-2
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to MALDONADO-3
Comment noted. Please refer to Master Response 7—Applicability of SMARA.
Response to MALDONADO-4
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Impacts related to hydrology and water quality, including floodplain, are
discussed in RDEIR Section 3.9, Hydrology and Water Quality. Impacts related to biological resources,
including arroyo toad habitat, are discussed in RDEIR Section 3.4, Biological Resources.
Response to MALDONADO-5
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition.
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John Marzt (MARZT)
Response to MARZT-1
Comment noted. Please refer to Response to SMW-17. Impacts related to biological resources,
including arroyo toad habitat, are discussed in RDEIR Section 3.4, Biological Resources. Impacts
related to noise are discussed in RDEIR Section 3.12, Noise. Impacts related to air quality are
discussed in RDEIR Section 3.3, Air Quality.
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Mark Massie (MASSIE)
Response to MASSIE-1
Comment noted. Please refer to Master Response 1—Plan Consistency and Response to SMW-17.
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Errol Mathieu (MATHIEU)
Response to MATHIEU-1
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to MATHIEU-2
Comment noted. Please refer to Response to SMW-17.
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MCFARLAND
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Packy McFarland (MCFARLAND)
Response to MCFARLAND-1
Comment noted. Please refer to Response to SMW-17.
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MCNULTY
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Marilyn McNulty (MCNULTY)
Response to MCNULTY-1
Comment noted. This comment will be provided to the City decision makers for their review and
consideration in determining whether to approve the project. Please refer to Master Response 5—
Wildfire Risk.
Response to MCNULTY-2
Comment noted. Please refer to Response to SMW-17.
Response to MCNULTY-3
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, as discussed in RDEIR Section 3.8, Hazards and Hazardous
Materials, page 3.8-15, Mitigation Measure HAZ-5 would require the Applicant to prepare and
submit plans to the City of Orange for review and approval demonstrating compliance with all
applicable emergency access provisions of the Fire Code, prior to issuance of the first building
permit. The approved plan shall be incorporated into the proposed project.
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MITCHELL 1
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Alexander Mitchell (MITCHELL 1)
Response to MITCHELL 1-1
Comment noted. Please refer to Response to SMW-17.
Response to MITCHELL 1-2
Comment noted. Please refer to Response to SMW-17. CEQA only requires analysis of potential
physical impacts on the environment. The remainder of these comments are related to social or
economic concerns and do not identify any environmental issue within the purview of CEQA or the
EIR; thus, no further response is necessary.
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MITCHELL 2
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Elisabeth Mitchell (MITCHELL 2)
Response to MITCHELL 2-1
Comment noted. Please refer to Response to SMW-17.
Response to MITCHELL 2-2
Comment noted. This comment will be provided to the City decision makers for their review and
consideration in determining whether to approve the project. CEQA only requires analysis of
potential physical impacts on the environment. The remainder of these comments are related to
social or economic concerns and do not identify any environmental issue within the purview of CEQA
or the EIR; thus, no further response is necessary.
Response to MITCHELL 2-3
Comment noted. This comment will be provided to the City decision makers for their review and
consideration in determining whether to approve the project. CEQA only requires analysis of
potential physical impacts on the environment. The remainder of these comments are related to
social or economic concerns and do not identify any environmental issue within the purview of CEQA
or the EIR; thus, no further response is necessary.
Response to MITCHELL 2-4
Comment noted. Please refer to Master Response 5—Wildfire Risk. Impacts related to air quality are
discussed in RDEIR Section 3.3, Air Quality. Impacts related to hydrology and water quality are
discussed in RDEIR Section 3.9.
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Jacalyn Mitten (MITTEN)
Response to MITTEN-1
Comment noted. This comment supports the development of the project and no further response is
necessary.
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Deborah Mongan (MONGAN 1)
Response to MONGAN 1-1
Comment noted. Commenter states that her previous comments were not addressed. Please refer to
Response to FHBP-2.
Response to MONGAN 1-2
Comment noted. This comment will be provided to the City decision makers for their review and
consideration in determining whether to approve the project. For a discussion of the project’s
consistency with the East Orange General Plan and the Orange Park Acres Plan, please see Master
Response 1—Plan Consistency. No further response is necessary, as the remaining comments do not
address any aspect of the current environmental assessment. CEQA only requires analysis of
potential physical impacts on the environment.
Response to MONGAN 1-3
Please refer to Master Response 1—Plan Consistency. Please refer to Master Response 3—Analysis
of Alternatives. The remaining comments do not warrant a response, as they are opinions unrelated
to the environmental analysis in the EIR.
Response to MONGAN 1-4
Comment noted. Please refer to Master Response 1—Plan Consistency and Master Response 10—
General Comments on Project, General Opposition. The remaining comments do not warrant a
response, as they are opinions unrelated to the environmental analysis in the EIR.
Response to MONGAN 1-5
Comment noted. . Please refer to Master Response 1—Plan Consistency for a discussion of project
consistency with the East Orange General Plan and the Orange Park Acres Plan.
The commenter states general concern for environmental impacts related to traffic, flooding,
methane, seismic issues, fire, open space, and habitat. These concerns are noted and will be
provided to City decision-makers. Traffic impacts are discussed in RDEIR Section 3.16, Transportation
and Traffic. As noted in Section 3.16, impacts would be significant and unavoidable, requiring a
statement of overriding considerations by the City. Flooding is discussed in RDEIR Section 3.9,
Hydrology and Water Quality. As discussed, there would be no potential for flooding to occur.
Please also refer to Master Response 4—Dam Safety and Risk of Failure. For methane, please refer
to Master Response 8—Site Environmental Conditions. For open space concerns, please see Master
Response 6—Stewardship of Open Space. Fire risks are discussed in RDEIR Section 3.8, Hazards and
Hazardous Materials. As discussed, with mitigation requiring a Fuel Modification Plan, fire risks
would be less than significant. Biological Resources issues are addressed in RDEIR Section 3.4,
Biological Resources. As discussed, all biological impacts would be less than significant with
mitigation.
The commenter requests a reclamation plan to be prepared. Please see Master Response 7—
Applicability of SMARA and Master Response 8—Site Environmental Conditions.
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Ryan Mongan (MONGAN 2)
Response to MONGAN 2-1
Comment noted. Please refer to Master Response 1—Plan Consistency.
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Kathryn Monteleone (MONTELEONE)
Response to MONTELEONE-1
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition.
Response to MONTELEONE-2
Comment noted. Please refer to Response to SMW-17.
Response to MONTELEONE-3
Comment noted. Impacts related to hydrology and water quality are discussed in RDEIR Section 3.9,
Hydrology and Water Quality.
Response to MONTELEONE-4
Comment noted. Please refer to Response to SMW-17 and Master Response 6—Stewardship of
Open Space. Impacts related to hydrology and water quality are discussed in RDEIR Section 3.9,
Hydrology and Water Quality.
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Debbie Moore (MOORE 1)
Response to MOORE 1-1
Comment noted. Please refer to Master Response 1—Plan Consistency.
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Judy Moore (MOORE 2)
Response to MOORE 2-1
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition.
Response to MOORE 2-2
Comment noted. Please refer to Response to SMW-17.
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Mark Moore (MOORE 3)
Response to MOORE 3-1
Comment noted. Impacts related to air quality are discussed in RDEIR Section 3.3, Air Quality.
Response to MOORE 3-2
Comment noted. Impacts related to noise are discussed in RDEIR Section 3.12, Noise.
Response to MOORE 3-3
Comment noted. Impacts related to air quality, including dust, are discussed in RDEIR Section 3.3, Air
Quality.
Response to MOORE 3-4
Comment noted. CEQA only requires analysis of potential physical impacts on the environment. The
remainder of these comments are related to social or economic concerns and do not identify any
environmental issue within the purview of CEQA or the EIR; thus, no further response is necessary.
Response to MOORE 3-5
Comment noted. Impacts related to hydrology and water quality are discussed in RDEIR Section 3.9,
Hydrology and Water Quality.
Response to MOORE 3-6
Comment noted. Please refer to Response to SMW-17. CEQA only requires analysis of potential
physical impacts on the environment. The remainder of these comments are related to social or
economic concerns and do not identify any environmental issue within the purview of CEQA or the
EIR; thus, no further response is necessary.
Response to MOORE 3-7
Comment noted. CEQA only requires analysis of potential physical impacts on the environment. The
remainder of these comments are related to social or economic concerns and do not identify any
environmental issue within the purview of CEQA or the EIR; thus, no further response is necessary.
Response to MOORE 3-8
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
Response to MOORE 3-9
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
Response to MOORE 3-10
This comment supports the development of the project. No further response is necessary.
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Michael Moore (MOORE 4)
Response to MOORE 4-1
Comment noted. This comment supports the development of the project and no further response is
necessary.
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Sharon Mulé (MULÉ 1)
Response to MULÉ 1-1
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition.
Response to MULÉ 1-2
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition and Response to SMW-17.
Response to MULÉ 1-3
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to MULÉ 1-4
Comment noted. Please see Master Response 6—Stewardship of Open Space. CEQA only requires
analysis of potential physical impacts on the environment. The remainder of these comments are
related to social or economic concerns and do not identify any environmental issue within the
purview of CEQA or the EIR; thus, no further response is necessary.
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Sharon Mulé (MULÉ 2)
Response to MULÉ 2-1
Comment noted. Commenter states that previous comments from the attached agency and
individual letters were not addressed. Please refer to Response to FHBP-2.
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Shirley Mullen (MULLEN)
Response to MULLEN-1
Comment noted. This comment will be provided to the City decision makers for their review and
consideration in determining whether to approve the project. Please refer to Response to SMW-17.
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Jennifer Naughton (NAUGHTON)
Response to NAUGHTON-1
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition.
Response to NAUGHTON-2
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to NAUGHTON-3
Comment noted. Impacts related to hazards are addressed in RDEIR Section 3.8, Hazards and
Hazardous Materials.
Response to NAUGHTON-4
Comment noted. Please see Master Response 9–Soil Import/Export Numbers.
Response to NAUGHTON-5
Please refer to Master Response 7—Applicability of SMARA.
Response to NAUGHTON-6
Comment noted. Impacts related to air quality are discussed in RDEIR Section 3.3, Air Quality.
Impacts related to hydrology and water quality are discussed in RDEIR Section 3.9, Hydrology and
Water Quality. Impacts related to noise are discussed in RDEIR Section 3.12, Noise.
Response to NAUGHTON-7
Comment noted. Please refer to Master Response 1—Plan Consistency. Impacts related to land use
planning and zoning are discussed in RDEIR Section 3.10, Land Use and Planning.
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Cynthia Nelson (NELSON)
Response to NELSON-1
Comment noted. Please refer to Response to SMW-17, and Master Response 1—Plan Consistency.
Impacts related to hydrology and water quality are discussed in RDEIR Section 3.9, Hydrology and
Water Quality.
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NGUYEN
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Rosemary Nguyen (NGUYEN)
Response to NGUYEN-1
Comment noted. Please refer to Response to SMW-17.
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NICHOLAS
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George Nicholas (NICHOLAS)
Response to NICHOLAS-1
Comment noted. Please refer to Response to SMW-17 and Master Response 1—Plan Consistency.
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ORTH
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Tanya Orth (ORTH)
Response to ORTH-1
Comment noted. Please refer to Response to SMW-17. Impacts related to air quality are discussed in
RDEIR Section 3.3, Air Quality.
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PANTTAJA 1
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Sherry Panttaja (PANTTAJA 1)
Response to PANTTAJA 1-1
Comment noted. This comment will be provided to the City decision makers for their review and
consideration in determining whether to approve the project. Please refer to Master Response 1—
Plan Consistency.
Response to PANTTAJA 1-2
Please refer to Master Response 7—Applicability of SMARA.
Response to PANTTAJA 1-3
Comment noted. Please refer to Appendix I, Geotechnical Report. Furthermore, see RDEIR Section
3.6, Geology and Soils.
Response to PANTTAJA 1-4
Comment noted. Please refer to Master Response 1—Plan Consistency. Impacts related to hydrology
and water quality are discussed in RDEIR Section 3.9, Hydrology and Water Quality.
Response to PANTTAJA 1-5
Comment noted. Please refer to Response to SMW-17.
Response to PANTTAJA 1-6
Comment noted. Please see Master Response 6—Stewardship of Open Space
Response to PANTTAJA 1-7
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to PANTTAJA 1-8
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition.
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PANTTAJA 2
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Tim Panttaja (PANTTAJA 2)
Response to PANTTAJA 2-1
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition.
Response to PANTTAJA 2-2
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to PANTTAJA 2-3
Comment noted. Please refer to Appendix I, Geotechnical Report. Furthermore, see RDEIR Section
3.6, Geology and Soils.
Response to PANTTAJA 2-4
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
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PARKHURST
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Jim and Tracey Parkhurst (PARKHURST)
Response to PARKHURST-1
Comment noted. Please refer to Response to SMW-17.
Response to PARKHURST-2
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition.
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PENDRAY 1
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Fran Pendray (PENDRAY 1)
Response to PENDRAY 1-1
Comment noted. Please refer to Response to SMW-17.
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CONT
PENDRAY 2
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Leroy Pendray (PENDRAY 2)
Response to PENDRAY 2-1
Comment noted. Please refer to Response to FHBP-10.
Response to PENDRAY 2-2
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to PENDRAY 2-3
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to PENDRAY 2-4
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to PENDRAY 2-5
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to PENDRAY 2-6
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
Response to PENDRAY 2-7
Comment noted. Please refer to Response to SMW-17.
Response to PENDRAY 2-8
Comment noted. Please see Master Response 9–Soil Import/Export Numbers.
Response to PENDRAY 2-9
Comment noted. As discussed in RDEIR Section 3.16, Transportation and Traffic, page 3.16-104,
Mitigation Measure TRANS-2 would require the project Applicant to provide the City of Orange with
fair share fees to restripe the northbound approach of Orange Park Boulevard at East Santiago
Canyon Road to provide one exclusive left-turn lane and one shared left-turn/right-turn lane, prior to
issuance of building permits. The Applicant’s fair share responsibility for these improvements is 18.2
percent.
Response to PENDRAY 2-10
Comment noted. Please refer to Response to SMW-17. No further response is necessary, as the
comment does not address any aspect of the current environmental assessment. CEQA only requires
analysis of potential physical impacts on the environment.
Response to PENDRAY 2-11
Comment noted. CEQA only requires analysis of potential physical impacts on the environment. The
remainder of these comments are related to social or economic concerns and do not identify any
environmental issue within the purview of CEQA or the EIR; thus, no further response is necessary.
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Leroy J. Pendray (PENDRAY 3)
Response to PENDRAY 3-1
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to PENDRAY 3-2
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to PENDRAY 3-3
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to PENDRAY 3-4
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to PENDRAY 3-5
Comment noted. Please refer to Response to PENDRAY 2-6.
Response to PENDRAY 3-6
Comment noted. Please refer to Response to SMW-17.
Response to PENDRAY 3-7
Comment noted. Please see Master Response 9–Soil Import/Export Numbers.
Response to PENDRAY 3-8
Comment noted. Please refer to Master Response 9—Soil Import/Export Numbers.
Response to PENDRAY 3-9
Comment noted. Please refer to Response to PENDRAY 2-9.
Response to PENDRAY 3-10
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
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Heather Perkins (PERKINS 1)
Response to PERKINS 1-1
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition and Response to SMW-17.
Response to PERKINS 1-2
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to PERKINS 1-3
Comment noted. Please refer to Master Response 4—Dam Safety and Risk of Failure. Impacts related
to hydrology and water quality are discussed in RDEIR Section 3.9, Hydrology and Water Quality.
Impacts related to hazards are discussed in RDEIR Section 3.8, Hazards and Hazardous Materials.
Response to PERKINS 1-4
Comment noted. CEQA only requires analysis of potential physical impacts on the environment. The
remainder of these comments are related to social or economic concerns and do not identify any
environmental issue within the purview of CEQA or the EIR; thus, no further response is necessary.
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PERKINS 2
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Susan Perkins (PERKINS 2)
Response to PERKINS 2-1
Comment noted. Please refer to Master Response 7—Applicability of SMARA, and Response to
SMW-17. Impacts related to hydrology and water quality are discussed in RDEIR Section 3.9,
Hydrology and Water Quality.
Response to PERKINS 2-2
Comment noted. Please refer to Master Response 7—Applicability of SMARA, and Response to
SMW-17. Impacts related to hydrology and water quality are discussed in RDEIR Section 3.9,
Hydrology and Water Quality.
Response to PERKINS 2-3
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17.
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PHILIPP
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Susan Philipp (PHILIPP)
Response to PHILIPP-1
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition.
Response to PHILIPP-2
Comment noted. Impacts related to hydrology and water quality are discussed in RDEIR Section 3.9,
Hydrology and Water Quality.
Response to PHILIPP-3
Comment noted. As discussed in RDEIR Section 3.8, Hazards and Hazardous Materials, page 3.8-15,
Mitigation Measure HAZ-5 would require the Applicant to prepare and submit plans to the City of
Orange for review and approval demonstrating compliance with all applicable emergency access
provisions of the Fire Code, prior to issuance of the first building permit. The approved plan shall be
incorporated into the proposed project.
Response to PHILIPP-4
Comment noted. Impacts related to biological resources, including arroyo toad habitat, are discussed
in RDEIR Section 3.4, Biological Resources.
Response to PHILIPP-5
Comment noted. Please refer to Response to SMW-17.
Response to PHILIPP-6
Comment noted. Impacts related to air quality are discussed in RDEIR Section 3.3, Air Quality.
Response to PHILIPP-7
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
Response to PHILIPP-8
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
Response to PHILIPP-9
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition.
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PHLAUM
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Jason Phlaum (PHLAUM)
Response to PLAUM-1
Comment noted. CEQA only requires analysis of potential physical impacts on the environment. The
remainder of these comments are related to social or economic concerns and do not identify any
environmental issue within the purview of CEQA or the EIR; thus, no further response is necessary.
Response to PHLAUM-2
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition.
Response to PHLAUM-3
Comment noted. Please refer to Response to SMW-17, Master Response 3—Analysis of Alternatives,
and Master Response 7—Applicability of SMARA.
Response to PHLAUM-4
Comment noted. CEQA only requires analysis of potential physical impacts on the environment. The
remainder of these comments are related to social or economic concerns and do not identify any
environmental issue within the purview of CEQA or the EIR; thus, no further response is necessary.
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PLEHN 1
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Kim Plehn (PLEHN 1)
Response to PLEHN 1-1
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to PLEHN 1-2
Comment noted. Please refer to Response to SMW-17.
Response to PLEHN 1-3
Comment noted. Please refer to Master Response 1—Plan Consistency.
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Kim Plehn (PLEHN 2)
Response to PLEHN 2-1
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to PLEHN 2-2
Comment noted. Please refer to Response to SMW-17.
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Kirk Plehn (PLEHN 3)
Response to PLEHN 3-1
Comment noted. Please refer to Master Response 1—Plan Consistency and Response to SMW-17.
Response to PLEHN 3-2
Comment noted. Please refer to Response to SMW-17.
Response to PLEHN 3-3
Comment noted. CEQA only requires analysis of potential physical impacts on the environment. The
remainder of these comments are related to social or economic concerns and do not identify any
environmental issue within the purview of CEQA or the EIR; thus, no further response is necessary.
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PRITTS 1
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Joanne Pritts (PRITTS 1)
Response to PRITTS 1-1
Comment noted. Please refer to Master Response 1—Plan Consistency and Response to SMW-17.
Response to PRITTS 1-2
Comment noted. Please refer to Response to SMW-17.
Response to PRITTS 1-3
Comment noted. Comment noted. This comment will be provided to the City decision makers for
their review and consideration in determining whether to approve the project.
Response to PRITTS 1-4
Comment noted. Please refer to Response to SMW-17.
Response to PRITTS 1-5
Comment noted. CEQA only requires analysis of potential physical impacts on the environment. The
remainder of these comments are related to social or economic concerns and do not identify any
environmental issue within the purview of CEQA or the EIR; thus, no further response is necessary.
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PRITTS 2
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Joe Pritts (PRITTS 2)
Response to PRITTS 2-1
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition.
Response to PRITTS 2-2
Comment noted. Please refer to Response to SMW-17.
Response to PRITTS 2-3
Comment noted. CEQA only requires analysis of potential physical impacts on the environment. The
remainder of these comments are related to social or economic concerns and do not identify any
environmental issue within the purview of CEQA or the EIR; thus, no further response is necessary.
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Barbara Quant (QUANT 1)
Response to QUANT 1-1
Comment noted. This comment will be provided to the City decision makers for their review and
consideration in determining whether to approve the project.
Response to QUANT 1-2
Comment noted. Please refer to Response to SMW-17.
Response to QUANT 1-3
Comment noted. This comment will be provided to the City decision makers for their review and
consideration in determining whether to approve the project. Please refer to Response to SMW-17.
CEQA only requires analysis of potential physical impacts on the environment. The remainder of
these comments are related to social or economic concerns and do not identify any environmental
issue within the purview of CEQA or the EIR; thus, no further response is necessary.
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Leonard Quant (QUANT 2)
Response to QUANT 2-1
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition.
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David Randall (RANDALL)
Response to RANDALL-1
Comment noted. Please refer to Master Response 1—Plan Consistency and Response to SMW-17.
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Deborah Redfern (REDFERN)
Response to REDFERN-1
Comment noted. Please refer to Response to SMW-17. Impacts related to noise are discussed in
RDEIR Section 3.12, Noise.
Response to REDFERN-2
Comment noted. Please refer to Response to SMW-17.
Response to REDFERN-3
Comment noted. Please refer to Response to SMW-17. Impacts related to noise are discussed in
RDEIR Section 3.12, Noise.
Response to REDFERN-4
Comment noted. Please see Master Response 9–Soil Import/Export Numbers. Impacts related to air
quality are discussed in RDEIR Section 3.3, Air Quality.
Response to REDFERN-5
Comment noted. Please refer to Response to SMW-17 and Master Response 1—Plan Consistency.
Impacts related to noise are discussed in RDEIR Section 3.12, Noise. Impacts related to air quality are
discussed in RDEIR Section 3.3, Air Quality.
Response to REDFERN-6
Comment noted. Please refer to Master Response 1—Plan Consistency.
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REED
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Michael and Sandra Reed (REED)
Response to REED-1
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition.
Response to REED-2
Comment noted. Please refer to Response to SMW-17.
Response to REED-3
Comment noted. Impacts related to land use and planning are discussed in RDEIR Section 3.10, Land
Use and Planning.
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Cindy Reina (REINA 1)
Response to REINA 1-1
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition.
Response to REINA 1-2
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to REINA 1-3
Comment noted. Impacts related to hydrology and water quality are discussed in RDEIR Section 3.9,
Hydrology and Water Quality. Impacts related to air quality are discussed in RDEIR Section 3.3, Air
Quality.
Response to REINA 1-4
Comment noted. Please refer to Response to SMW-17.
Response to REINA 1-5
Comment noted. CEQA only requires analysis of potential physical impacts on the environment. The
remainder of these comments are related to social or economic concerns and do not identify any
environmental issue within the purview of CEQA or the EIR; thus, no further response is necessary.
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Cynthia Reina (REINA 2)
Response to REINA 2-1
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to REINA 2-2
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
Response to REINA 2-3
Comment noted. Impacts related to hydrology and water quality are discussed in RDEIR Section 3.9,
Hydrology and Water Quality. Please refer to Appendix I, Geotechnical Report. Furthermore, see
RDEIR Section 3.6, Geology and Soils.
Response to REINA 2-4
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition.
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J. Vincent Reina (REINA 3)
Response to REINA 3-1
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition.
Response to REINA 3-2
Comment noted. Please refer to Response to SMW-17. As discussed in RDEIR Section 3.8, Hazards
and Hazardous Materials, page 3.8-15, Mitigation Measure HAZ-5 would require the Applicant to
prepare and submit plans to the City of Orange for review and approval demonstrating compliance
with all applicable emergency access provisions of the Fire Code, prior to issuance of the first
building permit. The approved plan shall be incorporated into the proposed project.
Response to REINA 3-3
Comment noted. Please refer to Response to SMW-17.
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REINA 4
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John Reina (REINA 4)
Response to REINA 4-1
Comment noted. Please refer to Response to SMW-17.
Response to REINA 4-2
Comment noted. Please refer to Master Response 1—Plan Consistency. CEQA only requires analysis
of potential physical impacts on the environment. The remainder of these comments are related to
social or economic concerns and do not identify any environmental issue within the purview of CEQA
or the EIR; thus, no further response is necessary.
Response to REINA 4-3
Comment noted. Please refer to Master Response 4—Dam Safety and Risk of Failure. Please refer to
Appendix I, Geotechnical Report. Furthermore, see RDEIR Section 3.6, Geology and Soils.
Response to REINA 4-4
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition.
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John Reina (REINA 5)
Response to REINA 5-1
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition.
Response to REINA 5-2
Comment noted. Impacts related to hydrology and water quality are discussed in RDEIR Section 3.9,
Hydrology and Water Quality. As discussed in RDEIR Section 3.8, Hazards and Hazardous Materials,
page 3.8-15, Mitigation Measure HAZ-5 would require the Applicant to prepare and submit plans to
the City of Orange for review and approval demonstrating compliance with all applicable emergency
access provisions of the Fire Code, prior to issuance of the first building permit. The approved plan
shall be incorporated into the proposed project. Please refer to Appendix I, Geotechnical Report.
Furthermore, see RDEIR Section 3.6, Geology and Soils.
Response to REINA 5-3
Comment noted. As discussed in RDEIR Section 3.8, Hazards and Hazardous Materials, page 3.8-15,
Mitigation Measure HAZ-5 would require the Applicant to prepare and submit plans to the City of
Orange for review and approval demonstrating compliance with all applicable emergency access
provisions of the Fire Code, prior to issuance of the first building permit. The approved plan shall be
incorporated into the proposed project.
Response to REINA 5-4
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition.
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Theodore J. Reina (REINA 6)
Response to REINA 6-1
Comment noted. Opening remarks. Please refer to Master Response 10—General Comments on
Project, General Opposition.
Response to REINA 6-2
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to REINA 6-3
Comment noted. Impacts related to hydrology and water quality are discussed in RDEIR Section 3.9,
Hydrology and Water Quality. As discussed in RDEIR Section 3.8, Hazards and Hazardous Materials,
page 3.8-15, Mitigation Measure HAZ-5 would require the Applicant to prepare and submit plans to
the City of Orange for review and approval demonstrating compliance with all applicable emergency
access provisions of the Fire Code, prior to issuance of the first building permit. The approved plan
shall be incorporated into the proposed project. Please refer to Appendix I, Geotechnical Report.
Furthermore, see RDEIR Section 3.6, Geology and Soils.
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Kay Ressler (RESSLER)
Response to RESSLER-1
Comment received. Please refer to Response to SMW-17. Impacts related to air quality are discussed
in RDEIR Section 3.3, Air Quality.
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Kim Riechmann (RIECHMANN)
Response to RIECHMANN-1
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition and Response to SMW-17.
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Bonnie Robinson (ROBINSON 1)
Response to ROBINSON 1-1
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to ROBINSON 1-2
Comment noted. Impacts related to hydrology and water quality are discussed in RDEIR Section 3.9,
Hydrology and Water Quality. Impacts related to air quality are discussed in RDEIR Section 3.3, Air
Quality. Impacts related to transportation are discussed in RDEIR Section 3.16, Transportation and
Traffic. Furthermore, please refer to Response to SMW-17. As discussed in RDEIR Section 3.8,
Hazards and Hazardous Materials, page 3.8-15, Mitigation Measure HAZ-5 would require the
Applicant to prepare and submit plans to the City of Orange for review and approval demonstrating
compliance with all applicable emergency access provisions of the Fire Code, prior to issuance of the
first building permit. The approved plan shall be incorporated into the proposed project.
Response to ROBINSON 1-3
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to ROBINSON 1-4
Comment noted. Comment noted. No further response is necessary, as the comment does not
address any aspect of the current environmental assessment. CEQA only requires analysis of
potential physical impacts on the environment.
Response to ROBINSON 1-5
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to ROBINSON 1-6
Comment noted. Comment noted. No further response is necessary, as the comment does not
address any aspect of the current environmental assessment. CEQA only requires analysis of
potential physical impacts on the environment.
Response to ROBINSON 1-7
Comment noted. Please see Master Response 9–Soil Import/Export Numbers. Impacts related to air
quality are discussed in RDEIR Section 3.3, Air Quality. Impacts related to noise are discussed in
RDEIR Section 3.12, Noise.
Response to ROBINSON 1-8
Please refer to Response to SCGA-4.
Response to ROBINSON 1-9
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17.
Response to ROBINSON 1-10
Comment noted. Impacts related to noise are discussed in RDEIR Section 3.12, Noise. Impacts
related to transportation are discussed in RDEIR Section 3.16, Transportation and Traffic.
Furthermore, please refer to Response to SMW-17.
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Response to ROBINSON 1-11
Comment noted. Please refer to Response to FHBP-2.
Response to ROBINSON 1-12
Comment noted. Impacts related to biological resources, including arroyo toad habitat, are discussed
in RDEIR Section 3.4, Biological Resources.
Response to ROBINSON 1-13
Comment noted. Impacts related to land use and planning are discussed in RDEIR Section 3.10, Land
Use and Planning.
Response to ROBINSON 1-14
Comment noted. Please see Master Response 6—Stewardship of Open Space.
Response to ROBINSON 1-15
Comment noted. Commenter refers to the mailing of notices and reiterates opposition for the
project. No further response is necessary, as the comment does not address any aspect of the
current environmental assessment. CEQA only requires analysis of potential physical impacts on the
environment.
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Joel Robinson (ROBINSON 2)
Response to ROBINSON 2-1
Comment noted. Commenter asks that he is notified of the receipt of his comment letter and that
they have been included in public record. No further response is necessary.
Response to ROBINSON 2-2
Comment noted. Commenter states his opposition of the project and indicates the favorability of
Alternative E. No further response is necessary.
Response to ROBINSON 2-3
Comment noted. Commenter states that previous comments have been ignored. No further
response is necessary, as the comment does not address any aspect of the current environmental
assessment. CEQA only requires analysis of potential physical impacts on the environment.
Response to ROBINSON 2-4
Comment noted. Impacts related to air quality are discussed in RDEIR Section 3.3, Air Quality.
Impacts related to transportation are discussed in RDEIR Section 3.16, Transportation and Traffic.
Furthermore, please refer to Response to SMW-17. Impacts related to aesthetics are discussed in
RDEIR Section 3.1, Aesthetics, Light, and Glare. Impacts related to noise are discussed in RDEIR
Section 3.12, Noise.
Response to ROBINSON 2-5
Comment noted. Please refer to Master Response 2—Adequacy of Project Description.
Response to ROBINSON 2-6
Please refer to Response CDFW-4.
Response to ROBINSON 2-7
Comment noted. Please refer to RDEIR Section 3.4. There will be no significant impacts to the
Coastal California gnatcatcher. Furthermore, please refer to Response to SMW-39 related to least
bell’s vireo.
Response to ROBINSON 2-8
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17.
Response to ROBINSON 2-9
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment.
Response to ROBINSON 2-10
Comment noted. Please refer to Response to OCPW-5.
Response to ROBINSON 2-11
Comment noted. Impacts related to biological resources, including arroyo toad habitat, are discussed
in RDEIR Section 3.4, Biological Resources.
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Howard Rothfeder (ROTHFEDER)
Response to ROTHFEDER-1
Comment noted. Please refer to Master Response 1—Plan Consistency. Impacts related to land use
and planning are discussed in RDEIR Section 3.10, Land Use and Planning.
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Ron Rothschild (ROTHSCHILD)
Response to ROTHSCHILD-1
Comment noted. Impacts related to hydrology and water quality are discussed in RDEIR Section 3.9,
Hydrology and Water Quality.
Response to ROTHSCHILD-2
Comment noted. Impacts related to hydrology and water quality are discussed in RDEIR Section 3.9,
Hydrology and Water Quality.
Response to ROTHSCHILD-3
Comment noted. Impacts related to biological resources, including arroyo toad habitat, are discussed
in RDEIR Section 3.4, Biological Resources.
Response to ROTHSCHILD-4
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to ROTHSCHILD-5
Comment noted. Please refer to Appendix J, Phase I Environmental Site Assessment and Phase II
Environmental Site Assessment. Furthermore, impacts related to hazards and hazardous materials
are discussed in RDEIR Section 3.8, Hazards and Hazardous Materials.
Response to ROTHSCHILD-6
Comment noted. Impacts related to air quality are discussed in RDEIR Section 3.3, Air Quality.
Response to ROTHSCHILD-7
Comment noted. Impacts related to aesthetics are discussed in RDEIR Section 3.1, Aesthetics, Light,
and Glare. CEQA only requires analysis of potential physical impacts on the environment. The
remainder of these comments are related to social or economic concerns and do not identify any
environmental issue within the purview of CEQA or the EIR; thus, no further response is necessary.
Response to ROTHSCHILD-8
Comment noted. Please refer to Response to SMW-17.
Response to ROTHSCHILD-9
Comment noted. Please refer to Master Response 1—Plan Consistency and Master Response 7—
Applicability of SMARA.
Response to ROTHSCHILD-10
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition.
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Greg Rush (RUSH)
Response to RUSH-1
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17.
Response to RUSH-2
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17.
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Jody Sadeghipour (SADEGHIPOUR)
Response to SADEGHIPOUR-1
Comment noted. Please refer to Response to SMW-17
Response to SADEGHIPOUR-2
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to SADEGHIPOUR-3
Comment noted. Impacts related to hydrology and water quality are discussed in RDEIR Section 3.9,
Hydrology and Water Quality. Impacts related to hazards and hazardous materials are discussed in
RDEIR Section 3.8, Hazards and Hazardous Materials. Please refer to Master Response 4—Dam
Safety and Risk of Failure.
Response to SADEGHIPOUR-4
Comment noted. CEQA only requires analysis of potential physical impacts on the environment. The
remainder of these comments are related to social or economic concerns and do not identify any
environmental issue within the purview of CEQA or the EIR; thus, no further response is necessary.
Response to SADEGHIPOUR-5
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition.
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Laura and David Sandoval (SANDOVAL)
Response to SANDOVAL-1
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition, Master Response 1—Plan Consistency, and Response to SMW-17. Impacts related to
noise are discussed in RDEIR Section 3.12, Noise.
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Amee and Scott Scigliano (SCIGLIANO)
Response to SCIGLIANO-1
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition and Response to SMW-17.
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Theresa Sears (SEARS 1)
This comment letters references issues raised in the Shute Mihaly & Weinberger (SMW) letter.
Therefore, the responses below point the reader to the relevant responses to the SMW letter.
Response to SEARS 1-1
Please refer to Master Response 2—Adequacy of Project Description, as well as responses to SMW-4
through SMW-12.
Response to SEARS 1-2
Please refer to SMW-13.
Response to SEARS 1-3
Please refer to SMW-14 through SMW-21.
Response to SEARS 1-4
Please refer to SMW-22 through SMW-31.
Response to SEARS 1-5
Please refer to SMW-32.
Response to SEARS 1-6
Please refer to SMW-33 through SMW-42.
Response to SEARS 1-7
Please refer to SMW-43 through SMW-46.
Response to SEARS 1-8
Please refer to SMW-50 through SMW-52.
Response to SEARS 1-9
Please refer to SMW-54 and SMW-55.
Response to SEARS 1-10
Please refer to SMW-56 through SMW-58.
Response to SEARS 1-11
Please refer to SMW-59 through SMW-61.
Response to SEARS 1-12
Please refer to SMW-62 through SMW-71.
Response to SEARS 1-13
Please refer to SMW-72.
Response to SEARS 1-14
Please refer to Master Response 1—Plan Consistency
Response to SEARS 1-15
Please refer to SMW-15 through SMW-18.
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Response to SEARS 1-16
Please refer to SMW-15 through SMW-18.
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Theresa Sears (SEARS 2)
Response to SEARS 2-1
The commenter expresses frustration with the lack of coordination with the Liaison Committee and a
lack of historical information in the RDEIR. RDEIR Section 2, Project Description, subsection 2.3.1,
includes a summary of the project site history and public outreach activities that have occurred.
Response to SEARS 2-2
The commenter refers to inaccuracies in Figure 3.2, Community Character Summary Map, which is
part of the Applicant’s Specific Plan, not the RDEIR.
The line on the General Plan exhibit denotes the area that is unincorporated. The Orange Park Acres
Plan limits covers even more area than shown (it includes the Reserve and the project site for
example).
Response to SEARS 2-3
The commenter refers to inaccuracies in Figure 3.3, Surrounding Neighborhoods with Lots Less than
1-acre, which is part of the Applicant’s Specific Plan, not the RDEIR. RDEIR Section 2, Project
Description, Exhibit 2-5, includes similar information and highlights Lots that are smaller than 10,000
square feet in size. As shown, the northernmost Lots in Orange Park Acres that front East Santiago
Canyon Road, are predominantly less than 10,000 square feet in size. Exhibit 2-5g provides additional
information regarding lot sizes in this area.
Response to SEARS 2-4
The commenter recommends a lower density zoning for the project site (the commenter specifically
requests a density that aligns with the County’s E-4-1 zone; 1-acre minimum) than what is proposed
by the project (R-1-8 and R-1-10; 8,000 to 10,000 square feet).
The impacts associated with implementation of the project, including the proposed General Plan
Amendments and rezoning, are evaluated in the RDEIR. The Planning Commission and City Council
will evaluate the proposed project, including the proposed General Plan Amendments and Rezoning,
and will consider information provided by the public regarding a preference for lower density.
Response to SEARS 2-5
The RDEIR acknowledges that the surrounding area is already developed with infrastructure and
housing. RDEIR Section 2, Project Description, Exhibit 2-5 depicts the location of Lots less than
10,000 square feet in size, which surround the project site to the northwest and southwest. The
Reserve Community to the east is, as the commenter points out, comprised of larger lots (20,000-
44,000 square feet). It should be noted that the Reserve Community is currently bordered by smaller
lots to the south, which has not resulted in requests for subdivision. Any such application would
have to undergo environmental review and processing by the City of Orange. Additionally, please
refer to Response to SMW-54.
Response to SEARS 2-6
Please refer to Master Response 1—Plan Consistency
Response to SEARS 2-7
Please refer to Master Response 1—Plan Consistency
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Response to SEARS 2-8
Please refer to SMW-33 through SMW-42.
Response to SEARS 2-9
Please refer to Master Response 2—Adequacy of Project Description.
Response to SEARS 2-10
Please refer to Master Response 7—Applicability of SMARA.
Regarding Furthermore, Mitigation Measures HAZ-2a and HAZ-2b are refined to clarify the
remediation actions needed to meet the requirements of the DTSC, including methodology and
performance standards for additional sampling. Please refer to Section 4: Errata for the refined
language of these measures.
Response to SEARS 2-11
The commenter provides background information on the sand and gravel operations. RDEIR Section
2, Project Description, provides background related to the prior operations and prior development
proposals for the site.
Response to SEARS 2-12
The evaluation of Alternative 1 is based on developing the existing 15.4 acres north of Santiago
Creek according to the existing zoning (R-1-8, 8,000 minimum lot size). The range of 18-25 units on
25 acres, as suggested by the commenter, appears to suggest a new zoning designation for the site.
Please also see Master Response 3—Analysis of Alternatives.
Response to SEARS 2-13
Please see Master Response 3—Analysis of Alternatives.
Response to SEARS 2-14
The Collaborative Alternative map is included as Exhibit 5-2 in RDEIR Section 5, Alternatives to the
Proposed Project.
Response to SEARS 2-15
Please see Master Response 3—Analysis of Alternatives.
Response to SEARS 2-16
Please see Master Response 3—Analysis of Alternatives.
Response to SEARS 2-17
RDEIR Section 3.10, Land Use, Exhibit 3.10-1, depicts approximately 37 acres of the proposed project
that is within the East Orange General Plan. This land use acreage is provided by the City of Orange
and based upon 1989 General Plan Land Use Map. RDEIR Exhibit 3.10-2 depicts approximately 39
acres of the proposed project that is within the Orange Park Acres Plan. This land use acreage is
provided by the City of Orange and based upon 1989 General Plan Land Use Map. RDEIR Section 2,
Project Description, Exhibit 2-7 shows approximately 11.6 acres zoned R-1-8, as per the City of
Orange (July 15, 2016). As discussed in RDEIR Executive Summary, page ES-8; RDEIR Section 2,
Project Description, page 2-12, and depicted in RDEIR Section 2, Exhibit 2-6, City of Orange General
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Plan Land Use, 77.3 acres is designated Resource Area (RA) and approximately 16.5 acres is
designated as Open Space (OS).
Response to SEARS 2-18
Please refer to Master Response 1—Plan Consistency. Furthermore, refer to RDEIR Appendix Q, Trails
at Santiago Specific Plan, pages 4-12 to 4-13 for a description of open space environs and intended
restoration. Refer to pages 6-13 to 6-15 for a description of the open space enhancement and refer
to Table 6.1, Plant Material Palette, for plant species.
Response to SEARS 2-19
Please refer to Master Response 1—Plan Consistency.
Response to SEARS 2-20
As noted in RDEIR Appendix A, Pre-Development Agreement, the Applicant will submit an
application for land use entitlement approvals that include a General Plan Amendment, Zoning
Change, Major Site Plan Review, Design Review, CEQA compliance, Development Agreement, Park
Planning and Development Committee consideration of project trails, and commitment by the City
to expeditiously process these entitlements while complying with all legal requirements.
Response to SEARS 2-21
Pursuant to CEQA; California Public Resources Code Section 21000 et seq., specifically Public
Resources Code Sections 21081 and 21081.6, as well as the CEQA Guidelines (14 CCR 15000 et seq.)
Sections 15091 and 15093A, a Finding of Fact and Statement of Overriding Considerations document
will be prepared upon project approval.
Response to SEARS 2-22
As discussed in RDEIR Section 3.4, Biological Resources, page 3.4-23, Santiago Creek is channelized
and surrounded by development along portions of its extent, Santiago Creek serves as a corridor for
wildlife movement by providing patches of habitat, as well as a water source, which connect the
Santa Ana Mountains to the Santa Ana River, and eventually flows out to the Pacific Ocean. Thus, the
habitat associated with Santiago Creek within the northern portion of the project site supports live-
in and movement habitat for species on a local scale (i.e., some limited live-in habitat for fish, and
live-in and at least marginal movement habitat for amphibian, reptile, bird, and mammal species),
and likely functions to facilitate wildlife movement or a number of species on a regional scale.
Response to SEARS 2-23
Impacts related to hydrology, including potential runoff impacts, are discussed in RDEIR Section 3.9,
Hydrology and Water Quality, and extensively analyzed in Appendix K, Hydrology and Water Quality
Reports.
Response to SEARS 2-24
Drainage pattern, flow rate and amount are discussed in RDEIR Section 3.9, Hydrology and Water
Quality, page 3.9-19.
Response to SEARS 2-25
Impacts related to hydrology, including water quality, are discussed in RDEIR Section 3.9, Hydrology
and Water Quality, and extensively analyzed in Appendix K, Hydrology and Water Quality Reports.
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Response to SEARS 2-26
As discussed in RDEIR Section 3.8, Hazards and Hazardous Materials, page 3.8-12, Tait Environmental
Services conducted a Phase II ESA of the project site that evaluated potential exposure to hazardous
materials from the past land use activities and the neighboring landfill. Tait Environmental Services
found that there was the potential for (1) vapor intrusion of TCE and methane into future dwelling
units and (2) elevated levels of Total Petroleum Hydrocarbons in soil. However, the proposed
occupied structures will be situated strategically to allow for future remediation of any potential
landfill gas migration, consistent with the DTSC or other applicable regulatory agency. Accordingly,
Mitigation Measures HAZ-2a to HAZ-2c are proposed to abate these conditions to a level of less than
significant.
Response to SEARS 2-27
Please refer to Master Response 4—Dam Safety and Risk of Failure.
Response to SEARS 2-28
Soil erosion s discussed in RDEIR Section 3.6, Geology and Soils, page 3.6-9. Liquefaction and
landslides are also discussed in RDEIR Section 3.6, Geology and Soils, on page 3.6-9.
Response to SEARS 2-29
As discussed in RDEIR Section 3.8, Hazards and Hazardous Materials, page 3.8-5, the project site has
been previously backfilled as a permitted use to restore previously mined portions of the site.
Previously mined portions of the project site were used for residue silt deposition, otherwise known
as silt ponds. The backfilling operation addressed both mined and silt pond areas. Furthermore,
please refer to Master Response 7—Applicability of SMARA.
Response to SEARS 2-30
Please refer to Master Response 7—Applicability of SMARA.
Response to SEARS 2-31
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment.
Response to SEARS 2-32
The NCCP/HCP is discussed in RDEIR Section 3.4, Biological Resources, and specifically in RDEIR
Section 3.10, Land Use, on page 3.10-31.
Response to SEARS 2-33
Impacts related to biological resources, including the wetland, riparian habitat and trees are
discussed extensively in RDEIR Section 3.4, Biological Resources.
Response to SEARS 2-34
Please refer to RDEIR Section 3.4, Biological Resources.
Response to SEARS 2-35
Please refer to Response to OCPW-8 regarding restoration.
Response to SEARS 2-36
Santiago Creek is discussed in RDEIR Section 3.9, Hydrology and Water Quality, page 3.9-2.
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Response to SEARS 2-37
As noted in RDEIR Section 1, Introduction, page 1-17, City of Orange 2015 Urban Water Management
Plan is used in the preparation of the RDEIR.
Response to SEARS 2-38
Impacts related to wastewater are discussed in RDEIR Section 3.18, Utilities, page 3.18-10. Impacts
related to stormwater are discussed in RDEIR Section 3.9, Hydrology and Water Quality, page 3.9-24.
Response to SEARS 2-39
A noise study was prepared for the project and is included as Appendix N of the RDEIR.
Response to SEARS 2-40
Impacts related to air quality, including diesel emissions, are discussed in RDEIR Section 3.2,
Agriculture Resources and Forest Resources.
Response to SEARS 2-41
Impacts related to grading are discussed extensively throughout the RDEIR, such as in Section 3.2,
Agriculture Resources and Forest Resources; Section 3.4, Biological Resources; Section 3.6, Geology
and Soils; Section 3.8, Hazards and Hazardous Materials; Section 3.9, Hydrology and Water Quality,
etc. This comment does not elaborate or specify on which impacts are not provided related to
grading. No further response necessary.
Response to SEARS 2-42
Impacts related to Air Quality are analyzed in RDEIR Section 3.3, Air Quality, and RDEIR Appendix F,
Air Quality and Greenhouse Gas Supporting Information. Energy consumption is analyzed in RDEIR
Section 6, Other CEQA Considerations, subsection 6.4, Energy Conservation.
Response to SEARS 2-43
AB 32 is discussed in RDEIR Section 3.7, Greenhouse Gas Emissions, page 3.7-12. Impacts related to
Air Quality are analyzed in RDEIR Section 3.3, Air Quality, and RDEIR Appendix F, Air Quality and
Greenhouse Gas Supporting Information.
Response to SEARS 2-44
The technical reports submitted for the RDEIR have been reviewed by the City of Orange. RDEIR
Section 2, Project Description, subsection 2.5.2, identifies those State and federal agencies that may
be required to grant approvals or coordinate with other agencies. The RDEIR discusses the potential
approvals that may be required of each of these agencies in the relevant impact discussions.
Response to SEARS 2-45
The traffic study included as RDEIR Appendix P, Traffic Impact Analysis, was prepared on September
13, 2018. Thus, the traffic study is current and up-to-date. The traffic study included the analysis of
cumulative projects in the area and an analysis of the permanent project. Please refer to Master
Response 9—Soil Import/Export Numbers.
Response to SEARS 2-46
Facilities supporting alternative transportation, such as public transit, bicycles, and pedestrians, are
discussed in RDEIR Section 3.16, Transportation and Traffic, specifically on page 3.16-122. As
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discussed in RDEIR Section 1, Introduction, page 1-14, Air Traffic Patterns is an environmental issue
determined not to be significant. RDEIR Section 7, Effects Found Not To Be Significant, page 7-2
states that the project site is 10 miles from the closest airport, Orange County John Wayne Airport.
This distance precludes the possibility of alterations to air traffic patterns. No impacts would occur.
Response to SEARS 2-47
As discussed in RDEIR Section 3.9, Hydrology and Water Quality, page 3.9-27, Mitigation Measure
HYD-5 requires the applicant to retain a qualified consultant to prepare and implement an
Emergency Evacuation Plan. “The plan shall identify the various types of emergency that could affect
the proposed project (e.g., dam failure, earthquake, flooding, etc.) and identify procedures for the
safe and orderly evacuation of the project. The plan shall require that streets be identified with clear
and visible signage and, if necessary, wayfinding signage be provided to identify exit points.”
Response to SEARS 2-48
Please refer to Master Response 6—Stewardship of Open Space.
Response to SEARS 2-49
Cumulative impacts are discussed and analyzed in RDEIR Section 4, Cumulative Effects. A summary
matrix is provided in RDEIR Executive Summary, page ES-12. Alternatives are analyzed in RDEIR
Section 5, Alternatives to the Proposed Project.
Response to SEARS 2-50
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to SEARS 2-51
Comment noted. Appendix L is currently posted on the City’s website and available to the public
through the following link (https://www.cityoforange.org/DocumentCenter/View/8316/App-L---
Land-Use-Background-ASMBLD)
Response to SEARS 2-52
Comment noted. This comment letter is included in the administrative record.
Response to Sears 2-53
As noted in RDEIR Section 1, Introduction, page 1-1, comments submitted on the previous Draft EIR
will be part of the overall administrative record for the project; however, because the RDEIR replaces
the previous Draft EIR in its entirety, written responses will only be provided to new comments
submitted on the RDEIR during the RDEIR public comment period. The remaining exhibits do not
raise any environmental comments that require a response, therefore, they are not reproduced in
this Responses to Written Comments section, but they are included in the record of proceedings and
administrative record.
SEELERT 1
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John Seelert (SEELERT 1)
Response to SEELERT 1-1
Comment noted. Please refer to Master Response 1—Plan Consistency and Master Response 7—
Applicability of SMARA.
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Sharon Seelert (SEELERT 2)
Response to SEELERT 2-1
Comment noted. Please refer to Master Response 1—Plan Consistency and Master Response 10—
General Comments on Project, General Opposition.
Response to SEELERT 2-2
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to SEELERT 2-3
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to SEELERT 2-4
Comment noted. Please refer to Master Response 1—Plan Consistency. Furthermore, as discussed in
RDEIR Section 3.8, Hazards and Hazardous Materials, page 3.8-12, Tait Environmental Services
conducted a Phase II ESA of the project site that evaluated potential exposure to hazardous materials
from the past land use activities and the neighboring landfill. Tait Environmental Services found that
there was the potential for (1) vapor intrusion of TCE and methane into future dwelling units and (2)
elevated levels of TPH in soil. However, the proposed occupied structures will be situated
strategically to allow for future remediation of any potential landfill gas migration, consistent with
the DTSC or other applicable regulatory agency. Accordingly, Mitigation Measures HAZ-2a to HAZ-2c
are proposed to abate these conditions to a level of less than significant.
Response to SEELERT 2-5
Comment noted. Please refer to Master Response 7—Applicability of SMARA. Refer to Appendix I,
Geotechnical Report. Furthermore, see RDEIR Section 3.6, Geology and Soils.
Response to SEELERT 2-6
Comment noted. Please refer to Master Response 4—Dam Safety and Risk of Failure. Impacts related
to hydrology and water quality are discussed in RDEIR Section 3.9, Hydrology and Water Quality.
Response to SEELERT 2-7
Comment noted. Please refer to Master Response 7—Applicability of SMARA.
Response to SEELERT 2-8
Comment noted. Please see Master Response 9–Soil Import/Export Numbers.
Response to SEELERT 2-9
Comment noted. Please see Master Response 9–Soil Import/Export Numbers.
Response to SEELERT 2-10
Comment noted. Please refer to Master Response 2—Adequacy of Project Description.
Response to SEELERT 2-11
Comment noted. Please refer to Master Response 2—Adequacy of Project Description.
Response to SEELERT 2-12
Comment noted. Please refer to Master Response 7—Applicability of SMARA.
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Response to SEELERT 2-13
Comment noted. Impacts related to hydrology and water quality are discussed in RDEIR Section 3.9,
Hydrology and Water Quality.
Response to SEELERT 2-14
Comment noted. Impacts related to hydrology and water quality are discussed in RDEIR Section 3.9,
Hydrology and Water Quality.
Response to SEELERT 2-15
Comment noted. Impacts related to biological resources, including arroyo toad habitat, are discussed
in RDEIR Section 3.4, Biological Resources.
Response to SEELERT 2-16
Comment noted. Please see Master Response 6—Stewardship of Open Space.
Response to SEELERT 2-17
Comment noted. Please refer to Response to SMW-17.
Response to SEELERT 2-18
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to SEELERT 2-19
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to SEELERT 2-20
Comment noted. CEQA only requires analysis of potential physical impacts on the environment. The
remainder of these comments are related to social or economic concerns and do not identify any
environmental issue within the purview of CEQA or the EIR; thus, no further response is necessary.
Furthermore, RDEIR Section 3.4, Biological Resources, discusses impacts related to Biological
Resources. No further response is necessary, as the comment does not address any aspect of the
current environmental assessment. CEQA only requires analysis of potential physical impacts on the
environment.
SERRES
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Julia and Mark Serres (SERRES)
Response to SERRES-1
Comment noted. Please refer to Response to SMW-17. Impacts related to biological resources,
including arroyo toad habitat, are discussed in RDEIR Section 3.4, Biological Resources. No further
response is necessary, as the comment does not address any aspect of the current environmental
assessment. Commenter does not elaborate further on the deficiencies of the RDEIR with regard to
the ecosystem, infrastructure, and traffic safety; therefore, a more detailed response is not possible
nor warranted under CEQA Guidelines.
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Lori Shackelford (SHACKELFORD)
Response to SHACKELFORD-1
Comment noted. Please refer to Response to SMW-17.
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Sheila Sherman (SHERMAN)
Response to SHERMAN-1
Comment noted. Please refer to Response to SMW-17.
Response to SHERMAN-2
Comment noted. Please refer to Master Response 1—Plan Consistency. Impacts related to hydrology
and water quality are discussed in RDEIR Section 3.9, Hydrology and Water Quality.
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Eliza Smith (SMITH)
Response to SMITH-1
Comment noted. Please refer to Response to SMW-17.
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Lynda Stewart (STEWART)
Response to STEWART-1
Comment noted. Please refer to Response to SMW-17.
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Kenneth and Julie Stichter (STICHTER)
Response to STICHTER-1
Comment noted. The comment consists of introductory remarks that do not raise any questions
about the environmental analysis.
Response to STICHTER-2
Comment noted. This comment supports the need to rectify the negative impact of the sand and
gravel operation at the former Sully Miller site. No further response is necessary.
Response to STICHTER-3
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to STICHTER-4
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to STICHTER-5
Comment noted. Please refer to Response to SMW-17.
Response to STICHTER-6
Comment noted. Please refer to Response to SMW-17.
Response to STICHTER-7
As discussed in RDEIR Section 3.8, Hazards and Hazardous Materials, page 3.8-12, Tait Environmental
Services conducted a Phase II ESA of the project site that evaluated potential exposure to hazardous
materials from the past land use activities and the neighboring landfill. Tait Environmental Services
found that there was the potential for (1) vapor intrusion of TCE and methane into future dwelling
units and (2) elevated levels of TPH in soil. However, the proposed occupied structures will be
situated strategically to allow for future remediation of any potential landfill gas migration,
consistent with the DTSC or other applicable regulatory agency. Accordingly, Mitigation Measures
HAZ-2a to HAZ-2c are proposed to abate these conditions to a level of less than significant.
Response to STICHTER-8
Please refer to Response to BUSBY 1-11.
Response to STICHTER-9
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
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Robert and Emiko Stumpf (STUMPF)
Response to STUMPF-1
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition and Master Response 1—Plan Consistency.
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Synde Sutherland (SUTHERLAND)
Response to SUTHERLAND-1
Comment noted. This comment will be provided to the City decision makers for their review and
consideration in determining whether to approve the project. Please refer to Master Response 10—
General Comments on Project, General Opposition and Master Response 1—Plan Consistency.
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Dan Swoish (SWOISH)
Response to SWOISH-1
Comment noted. This comment supports the development of the project and no further response is
necessary.
Response to SWOISH-2
Comment noted. This comment supports the development of the project and no further response is
necessary.
Response to SWOISH-3
Comment noted. This comment supports the development of the project and no further response is
necessary.
Response to SWOISH-4
Comment noted. This comment supports the development of the project and no further response is
necessary.
Response to SWOISH-5
Comment noted. This comment supports the development of the project and no further response is
necessary.
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Laura Thomas (THOMAS 1)
Response to THOMAS 1-1
Comment noted. Please refer to Master Response 1—Plan Consistency.
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Laura Thomas (THOMAS 2)
Response to THOMAS-1
Comment noted. Please refer to Response to FHBP-2.
Response to THOMAS-2
Comment noted. Please refer to Master Response 7—Applicability of SMARA.
Response to THOMAS-3
Comment noted. The comment consists of introductory remarks. No further response is necessary,
as the commenter does not elaborate on what eight issues are that could not be mitigated. CEQA
only requires analysis of potential physical impacts on the environment.
Response to THOMAS-4
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. CEQA only requires analysis of potential physical impacts on
the environment.
Response to THOMAS-5
Comment noted. Please refer to Master Response 7—Applicability of SMARA. Economic or social
considerations such as real estate values are not within the purview of CEQA or the RDEIR, which is
limited to the potential environmental impacts of this particular proposed project. This comment will
be provided to the City decision makers for their review and consideration in determining whether
to approve the project.
Response to THOMAS-6
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to THOMAS-7
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to THOMAS-8
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to THOMAS-9
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17.
Response to THOMAS-10
Comment noted. As discussed in RDEIR Section 3.8, Hazards and Hazardous Materials, page 3.8-15,
Mitigation Measure HAZ-5 would require the Applicant to prepare and submit plans to the City of
Orange for review and approval demonstrating compliance with all applicable emergency access
provisions of the Fire Code, prior to issuance of the first building permit. The approved plan shall be
incorporated into the proposed project. Impacts related to transportation are discussed in RDEIR
Section 3.16, Transportation and Traffic. Furthermore, please refer to Response to SMW-17.
Response to THOMAS-11
Comment noted. No further response is necessary, as the comment does not address any aspect of
the current environmental assessment. Commenter does not elaborate further on why the RDEIR
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fails to meet the requirements of CEQA; therefore, a more detailed response is not possible nor
warranted under CEQA Guidelines.
Response to THOMAS-12
Comment noted. Impacts related to hydrology and water quality are discussed in RDEIR Section 3.9,
Hydrology and Water Quality.
Response to THOMAS-13
Comment noted. Please refer to Master Response 3—Analysis of Alternatives.
Response to THOMAS-14
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to THOMAS-15
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to THOMAS-16
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition.
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Ronald Thompson (THOMPSON)
Response to THOMPSON-1
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17. Impacts related to
noise are discussed in RDEIR Section 3.12, Noise.
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Debra Tous (TOUS)
Response to TOUS-1
Comment noted. This comment will be provided to the City decision makers for their review and
consideration in determining whether to approve the project.
Response to TOUS-2
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition and Master Response 1—Plan Consistency.
Response to TOUS-3
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition.
Response to TOUS-4
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition.
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TYREMAN
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Steve Tyreman (TYREMAN)
Response to TYREMAN-1
Comment noted. This comment will be provided to the City decision makers for their review and
consideration in determining whether to approve the project.
Response to TYREMAN-2
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17.
Response to TYREMAN-3
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition.
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Marius Van Der Watt (VAN DER WATT)
Response to VAN DER WATT-1
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition and Master Response 1—Plan Consistency. Impacts related to hydrology and water
quality are discussed in RDEIR Section 3.9, Hydrology and Water Quality.
Impacts related to transportation are discussed in RDEIR Section 3.16, Transportation and Traffic.
Furthermore, please refer to Response to SMW-17.
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VIRGA
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Viviane Virga (VIRGA)
Response to VIRGA-1
Comment noted. Please refer to Master Response 1—Plan Consistency. Impacts related to
transportation are discussed in RDEIR Section 3.16, Transportation and Traffic. Furthermore, please
refer to Response to SMW-17.
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WALKER
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Mike Walker (WALKER)
Response to WALKER-1
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17.
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WALTON
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Chrisann Walton (WALTON)
Response to WALTON-1
Comment noted. This comment will be provided to the City decision makers for their review and
consideration in determining whether to approve the project. Please refer to Master Response 10—
General Comments on Project, General Opposition.
Response to WALTON-2
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17. As discussed in RDEIR
Section 3.8, Hazards and Hazardous Materials, page 3.8-15, Mitigation Measure HAZ-5 would require
the Applicant to prepare and submit plans to the City of Orange for review and approval
demonstrating compliance with all applicable emergency access provisions of the Fire Code, prior to
issuance of the first building permit. The approved plan shall be incorporated into the proposed
project. Impacts related to noise are discussed in RDEIR Section 3.12, Noise. Impacts related to air
quality are discussed in RDEIR Section 3.3, Air Quality.
Response to WALTON-3
Comment noted. Impacts related to noise are discussed in RDEIR Section 3.12, Noise. Impacts
related to air quality are discussed in RDEIR Section 3.3, Air Quality.
Response to WALTON-4
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to WALTON-5
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to WALTON-6
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition.
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WARD
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Deborah Ward (WARD)
Response to WARD-1
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17.
Response to WARD-2
Comment noted. As discussed in RDEIR Section 3.8, Hazards and Hazardous Materials, page 3.8-15,
Mitigation Measure HAZ-5 would require the Applicant to prepare and submit plans to the City of
Orange for review and approval demonstrating compliance with all applicable emergency access
provisions of the Fire Code, prior to issuance of the first building permit. The approved plan shall be
incorporated into the proposed project.
Response to WARD-3
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to WARD-4
Comment noted. Please refer to Master Response 1—Plan Consistency. Impacts related to
transportation are discussed in RDEIR Section 3.16, Transportation and Traffic. Furthermore, please
refer to Response to SMW-17.
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3DJHRI
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Ann Webb (WEBB)
Response to WEBB-1
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition. Impacts related to transportation are discussed in RDEIR Section 3.16, Transportation
and Traffic. Furthermore, please refer to Response to SMW-17.
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WETZEL
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Peter Wetzel (WETZEL)
Response to WETZEL-1
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition.
Response to WETZEL-2
Comment noted. This comment supports Alternative 5.2—Development within the Existing Land Use
Designations. No further response necessary.
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WHITE
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Kelley White (WHITE)
Response to WHITE-1
Comment noted. Please refer to Master Response 1—Plan Consistency. Impacts related to
transportation are discussed in RDEIR Section 3.16, Transportation and Traffic. Furthermore, please
refer to Response to SMW-17.
Response to WHITE-2
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition.
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WHITEFEATHER
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Dru Whitefeather (WHITEFEATHER)
Response to WHITEFEATHER-1
Comment noted. Impacts related to biological resources, including arroyo toad habitat, are discussed
in RDEIR Section 3.4, Biological Resources.
Response to WHITEFEATHER-2
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to WHITEFEATHER-3
Comment noted. Impacts related to transportation are discussed in RDEIR Section 3.16,
Transportation and Traffic. Furthermore, please refer to Response to SMW-17.
Response to WHITEFEATHER-4
Comment noted. Impacts related to hazards and hazardous materials is discussed in RDEIR Section
3.8, Hazards and Hazardous Materials.
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WILDERMUTH
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Kari Wildermuth (WILDERMUTH)
Response to WILDERMUTH-1
Comment noted. This comment will be provided to the City decision makers for their review and
consideration in determining whether to approve the project. Impacts related to transportation are
discussed in RDEIR Section 3.16, Transportation and Traffic. Furthermore, please refer to Response to
SMW-17. As discussed in RDEIR Section 3.8, Hazards and Hazardous Materials, page 3.8-15,
Mitigation Measure HAZ-5 would require the Applicant to prepare and submit plans to the City of
Orange for review and approval demonstrating compliance with all applicable emergency access
provisions of the Fire Code, prior to issuance of the first building permit. The approved plan shall be
incorporated into the proposed project.
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WINGERD
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Sarah Wingerd (WINGERD)
Response to WINGERD-1
Comment noted. This comment will be provided to the City decision makers for their review and
consideration in determining whether to approve the project. Impacts related to transportation are
discussed in RDEIR Section 3.16, Transportation and Traffic. Furthermore, please refer to Response to
SMW-17. As discussed in RDEIR Section 3.8, Hazards and Hazardous Materials, page 3.8-15,
Mitigation Measure HAZ-5 would require the Applicant to prepare and submit plans to the City of
Orange for review and approval demonstrating compliance with all applicable emergency access
provisions of the Fire Code, prior to issuance of the first building permit. The approved plan shall be
incorporated into the proposed project.
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WYKES
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Laurel Wykes (WYKES)
Response to WYKES-1
Comment noted. This comment will be provided to the City decision makers for their review and
consideration in determining whether to approve the project. Please refer to Master Response 10—
General Comments on Project, General Opposition.
Response to WYKES-2
Comment noted. Please refer to Master Response 1—Plan Consistency.
Response to WYKES-3
Comment noted. Please refer to Master Response 7—Applicability of SMARA.
Response to WYKES-4
Comment noted. Please see Master Response 9–Soil Import/Export Numbers.
Response to WYKES-5
Comment noted. Impacts related to hydrology and water quality are discussed in RDEIR Section 3.9,
Hydrology and Water Quality.
Response to WYKES-6
Comment noted. Impacts related to hydrology and water quality are discussed in RDEIR Section 3.9,
Hydrology and Water Quality.
Response to WYKES-7
Comment noted. Impacts related to biological resources, including arroyo toad habitat, are discussed
in RDEIR Section 3.4, Biological Resources.
Response to WYKES-8
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition.
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Robert Zweig (ZWEIG)
Response to ZWEIG-1
Comment noted. Please refer to Master Response 10—General Comments on Project, General
Opposition. Impacts related to transportation are discussed in RDEIR Section 3.16, Transportation
and Traffic. Furthermore, please refer to Response to SMW-17.
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Non-Draft RDEIR Comments
Table 3-1 summarizes the individuals that submitted comments that pertained to the proposed
project, but did not specifically address any aspect of the RDEIR’s analysis. The letters are reproduced
following the table. Please refer to Master Response 10—General Comments on Project, General
Opposition for a response to these comments.
Table 3-1: Non-RDEIR Comments
Signatory Signatory Signatory
Carol Adams Michael Adams Bob and Alice Agnew
Kaye and John Amdon Bruce Bauersfeld Karen Beck
Kelli Bennett Janae Blalock Oscar Brandi
Linda Cannon Crystal Chavez Ho Choi
John Clark Kate Clift Julie Clinton
Jim Cora Christina Crandall Tom Davidson
Charlene Davis Marcie Dial Cheryl Dickey
Ron Dominguez Craig Erion Amanda Ferris
Wolfgang Frisch Kevin Gaffney Richard Gallego
Everett Geis Leslie and Dan Getzinger Leslie and Irving Gislason
Sidney Glazer and Janice Lysiak Kalen Hatzfeld Mike and Judy Henry
Jim Herkimer B. Higgins Luann Hillman
Randy Hillman Dana Homer-Bertrand Stephen Kaufman
Cindy Keefer Diane Kelley John Kennedy
Kevin Koo Jackie Kovach Rob Kurowski
Tom Lauderdale David Letourneau Mark Litman
Andy Long Jason Martin Suzanne Martin (2 letters)
Tim McAleele Kathy McNeill Cliff and Doris Melson
Byung Min Emily Moore Megan Moore
Steve Moore Leo Moyneur Sandi Mulliner
Carol Natividad David Natividad Stephen Natividad
Vicky Northup John O’Leary James Philipp
Nicole Photoglou Valentina Rang Thomas and Deborah Rapport
Jayne and Art Reynolds Kim Riechmann Craig Rizzi
Daniel and Karen Rodiles Susan Rutten Alice Schultz
Heather Schultz Oscar Sendowsky Julie Shaw
Robert and Emiko Stumpf Vivien Swanson Gisella Tellez
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Table 3-1 (cont.): Non-RDEIR Comments
Signatory Signatory Signatory
Adam Torres Joanna Tu Van Tu
Amy Vail Rene Valbuena Maria Von Sprecken
Bernice Wakefield Lynda Waldrip Thomas Walsh
Beverly Warren Barbara Weiner Martha Wetzel
Thomas and Cinda Wittman Ali Youssef —
Source: City of Orange 2018.
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SECTION 4: ERRATA
The following are revisions to the Recirculated Draft Environmental Impact Report (RDEIR) for the
Trails at Santiago Creek Specific Plan. These revisions are minor modifications and clarifications to the
document, and do not change the significance of any of the environmental issue conclusions within
the RDEIR. The revisions are listed by page number. All additions to the text are underlined
(underlined) and all deletions from the text are stricken (stricken).
4.1 - Changes in Response to Specific Comments
Executive Summary
Page ES-5, Paragraph 1
The following text has been revised to clarify that 15.4 acres of residential uses are allowed under
the General Plan north of Santiago Creek. The following text has also been revised to note the
correct reference to the Pre-Development Agreement Appendix.
Alternative FG consists of residential uses would be developed 15.4 acres north of Santiago
Creek, with resource land use activities (sand, gravel, and materials recycling) occurring on
77.3 acres on both sides of the waterway. The General Plan allows 15.4 acres of residential
uses north of Santiago Creek. Vehicular access would be taken from two points Mabury
Drive. Resource land use activities would be located on 77.3 acres on both sides of the
waterway. These activities would consist of the continuation of the existing materials
recycling and backfilling operation.
Page ES-7, Paragraph 3
The following text has been revised to clarify the correct number of anticipated haul trips during the
grading period. The RDEIR was very conservative in its estimate of anticipated tonnage per truckload
and number of haul trips during project grading. It assumed 10 cubic yards of material per truckload
and a total of 275,400 haul trips during an 18 month grading period. Since the RDEIR was circulated,
a more accurate estimate of the number of total haul trips has been prepared. Assuming a capacity
of 20 cubic yards per truckload and 1,377,000 cubic yards of combined export and import (500,000
cubic yards of export and 877,000 cubic yards of import), there would be a total of 137,900 haul
trips, including 68,950 inbound trips and 68,950 outbound trips. Daily construction truck trips would
be 350 per day over an 18-month period, assuming 3,500 cubic yards of material would be hauled
per day over an 8-hour workday 5 days a week with a truck payload of 20 cubic yards per truck.
As discussed in Impact AIR-2, the project’s construction activities are estimated to generate
a maximum of 199.47 pounds of NOX per day with implementation of mitigation measures
AIR-1a through AIR-1g. As such, the project’s construction would continue to exceed the
SCAQMD’s recommended regional threshold of significance for NOX even after
implementation of Mitigation Measures AIR-1a through AIR-1g. The project’s construction
activities are only anticipated to exceed any of SCAQMD’s regional thresholds of significance
during the combined site preparation and grading period. A review of the detailed emissions
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estimates, contained in Appendix F, show that 196.17 of the 199.47 pounds of NOX are from
off-site sources. As previously discussed, the project is anticipated to require up to 275,400
137,900 total haul trips during the grading period.
Page ES-8, Paragraph 2
The Recirculated Draft EIR erroneously noted an incorrect total number of dwelling units that would
be developed under Alternative 1. However, the analysis of Alternative 1 was conducted assuming
40-50 single-family residential units would be developed under Alternative 1. The following text has
been revised to clarify that the correct number of units Alternative 1 would develop is 40-50 units
and to clarify that 15.4 acres of residential is allowed under the General Plan.
This alternative consists of allowing residential development north of the Santiago Creek and
the continuation of existing sand and gravel operations in accordance with the current City
of Orange General Plan and Zoning designations.1 As such, 15.4 acres of Low-Density as
Residential (confirmed by the City of Orange Community Development Department) are
allowed by the General Plan in the north-central portion of the site, north of Santiago Creek
and abutting Mabury Ranch Road. Consistent with the General Plan’s density range of 2.1 to
6.0 units per acre and the existing R-1-8 Zoning, Alternative 1 would develop there is an
allowable range of 32 to 92 residential homes, and a target of 77 40 to 50 single-family
residential homes on this 15.4-acre residential land use parcel. The existing R-1-8 Zoning for
the residential area would provide a maximum of 77 single-family dwelling units based on
acre density and would yield approximately 40 to 50 single-family dwelling units (although a
range of 32 to 92 dwelling units could be developed under the existing land use
designations). Access to this residential parcel would be from Mabury Avenue.
Pages ES-20 through ES-31, Table ES-2: Executive Summary Matrix
In response to comment CDFW-4, Table ES-2 has been revised to reflect the correct, certified,
Department-approved Soquel Canyon Mitigation Bank, whose service area extends to the project
site. Additionally, as part of Master Response 8—Site Environmental Conditions, Table ES-2 has been
revised to provide for further investigation and implementation with regard to Mitigation Measure
HAZ-2a and Mitigation Measure HAZ-2b. Additionally, in Table ES-2, clarifying language has been
added to the mitigation measures required for Impact AIR-3 and Mitigation Measure CUL-2.
Mitigation Measure TRANS-5 was inadvertently included in the RDEIR as a mitigation measure;
however, the improvements required by Mitigation Measure TRANS-5 are all design features that
were identified in the traffic study and were already included in the project’s design. Therefore,
Mitigation Measure TRANS-5 has been removed as a mitigation measure in its entirety.
1 The Development within the Existing Land Use Designations Alternative corresponds to Alternative F in the PDA.
City of Orange—Trails at Santiago Creek Specific Plan Final EIR Errata FirstCarbon Solutions 4-3 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\14 - FEIR\27650002 Sec 04-00 Errata.docx Table ES-2: Executive Summary Matrix Impacts Mitigation Measures Level of Significance After Mitigation Section 3.3—Air Quality Impact AIR-3: The project may result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or State ambient air quality standard. Impact AIR-3: Implement Mitigation Measures AIR-1a through AIR-1g. However, Tthe project may result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or State ambient air quality standard. Significant and unavoidable impact. Section 3.4—Biological Resources Impact BIO-3: The project may impact sensitive natural communities. MM BIO-3: Prior to the issuance of any grading permit in the areas designated as sensitive riparian communities (e.g., southern cottonwood-willow riparian forest or black willow scrub/ruderal), the project Applicant shall demonstrate to the satisfaction of the City that either of the following have been or will be accomplished: On- or off-site restoration or enhancement of sensitive riparian communities (e.g., southern cottonwood-willow riparian forest) at a ratio no less than 1:1 for permanent impacts. Temporary impacts will be restored to pre-project conditions (i.e., pre-project contours and revegetate with native species, where appropriate). Off-site restoration or enhancement at a ratio no less than 1:1 may include the purchase of mitigation credits at an agency-approved off-site mitigation bank (e.g., Santa Ana Watershed Association [SAWA] Soquel Canyon Mitigation Bank).2 If mitigation is to occur on-site and/or off-site (i.e., not an in-lieu fee program), a mitigation and monitoring plan shall be prepared. The plan shall focus on the creation of equivalent habitats within disturbed habitat areas of the project site and/or off-site. In addition, the plan shall provide details as to the implementation of the plan, maintenance, and future monitoring. Mitigation for impacts to sensitive riparian communities shall be accomplished by on- or off-site restoration and/or enhancement (e.g., transplantation, seeding, and/or planting/staking of sensitive riparian species; salvage/dispersal of duff and seed bank; removal of large stands of giant reed within riparian areas). Less than significant impact. 2 Soquel Canyon Mitigation Bank is the only certified, California Department of Fish and Wildlife (CDFW)-approved mitigation bank whose service area extends to the project site. Currently, this bank does not have the creation credits necessary to accommodate the CDFW’s policy of “no net loss” of either wetland habitat values or acreage, nor does it sell species-specific credits (i.e., least Bell’s vireo credits).
City of Orange—Trails at Santiago Creek Specific Plan Final EIR Errata FirstCarbon Solutions 4-4 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\14 - FEIR\27650002 Sec 04-00 Errata.docx Table ES-2 (cont.): Executive Summary Matrix Impacts Mitigation Measures Level of Significance After Mitigation Impact BIO-4: The proposed project may impact federally protected wetlands. MM BIO-4: Prior to the issuance of any grading permit for permanent impacts in the areas designated as jurisdictional features, the project Applicant shall obtain a CWA Section 404 permit from the USACE, a CWA Section 401 permit from the RWQCB, and Streambed Alteration Agreement permit under Section 1602 of the California Fish and Game Code from the CDFW. The following would be incorporated into the permitting, subject to approval by the regulatory agencies: 1. On- or off-site restoration or replacement of USACE/RWQCB jurisdictional waters of the United States/waters of the State at a ratio no less than 2:1 for permanent impacts, and for temporary impacts, restore impact area to pre-project conditions (i.e., pre-project contours and revegetate with native species, where appropriate). Off-site restoration or enhancement If any off-site restoration or enhancement is required, it will be provided at a ratio no less than 2:1 and may include the purchase of mitigation credits at an agency-approved off-site mitigation bank or in-lieu fee program (e.g., SAWASoquel Canyon Mitigation Bank). 2. On- or off-site restoration or enhancement of CDFW jurisdictional streambed and associated riparian habitat at a ratio no less than 2:1 for permanent impacts, and for temporary impacts, restore impact area to pre-project conditions (i.e., pre-project contours and revegetate with native species, where appropriate). Off-site restoration or enhancement at a ratio no less than 2:1 may include the purchase of mitigation credits at an agency-approved off-site mitigation bank (e.g., Soquel Canyon Mitigation Bank). Less than significant impact. Section 3.5—Cultural Resources Impact CUL-2: Subsurface construction activities associated with the proposed project may damage or destroy previously undiscovered archaeological resources. Implement Mitigation Measure CUL-1 and: MM CUL-2: During the ground disturbing activities in the areas depicted in Exhibit 3.5 1, a qualified archaeological and paleontological monitor shall be present on-site to observe earthwork activities. In the event of a discovery of an archaeological or paleontological resource, the monitor shall have the discretion to halt all ground disturbing activities within 50 feet of the find until it has been evaluated for significance. If the find is determined to have archaeological or paleontological significance, the procedures in Mitigation Less than significant impact.
City of Orange—Trails at Santiago Creek Specific Plan Final EIR Errata FirstCarbon Solutions 4-5 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\14 - FEIR\27650002 Sec 04-00 Errata.docx Table ES-2 (cont.): Executive Summary Matrix Impacts Mitigation Measures Level of Significance After Mitigation Measure CUL-1 or Mitigation Measure CUL-3 shall be implemented. Monitoring may cease once all of the areas depicted in Exhibit 3.5 1 have been thoroughly disturbed. Section 3.8—Hazards and Hazardous Materials Impact HAZ-2: The project may create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the likely release of hazardous materials into the environment. MM HAZ-2a: A supplemental Phase II Environmental Site Assessment shall be conducted to further delineate the vertical and lateral extent of the contamination. The proposed enclosed structures shall be situated strategically, using supplemental Phase II Environmental Site Assessment data and DTSC’s review thereof, so that structures will not interfere with future remediation of any potential landfill gas migration; this shall be demonstrated in connection with approval of any tentative maps for the project to allow for future remediation of any potential landfill gas migration. Prior to issuance of building permits for dwelling units in areas of the project site where vapor intrusion has the potential to occur, the applicant shall prepare and submit plans to the City of Orange, DTSC, or the Local Enforcement Agency (which is the County of Orange Environmental Health Division) identifying vapor intrusion abatement measures for trichloroethylene (TCE) and methane. Areas where vapor intrusion has the potential to occur are those identified in the Phase II Environmental Site Assessment. The Phase II Environmental Site Assessment shall be conducted in substantial compliance with applicable guidance documents, including but not limited to the DTSC Advisory—Active Soil Gas Investigation and Final Guidance for Evaluation and Mitigation of Subsurface Vapor Intrusion to Indoor Air. The Phase II Environmental Site Assessment shall use current DTSC HHRA Note 3 and Regional Screening Levels established by the U.S. Environmental Protection Agency. Following preparation of the Phase II Environmental Site Assessment, a soil risk management plan shall be prepared to address any discovery of previously unknown contamination and shall be submitted to DTSC. These reports shall be conducted pursuant to applicable DTSC advisories, and abatement shall be implemented as directed by DTSC. Such abatement measures may include but are not limited to vapor barriers or passive/active venting systems, as determined by the appropriate regulatory agency, unless determined not to be necessary by the City in consultation with the Local Less than significant impact.
City of Orange—Trails at Santiago Creek Specific Plan Final EIR Errata FirstCarbon Solutions 4-6 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\14 - FEIR\27650002 Sec 04-00 Errata.docx Table ES-2 (cont.): Executive Summary Matrix Impacts Mitigation Measures Level of Significance After Mitigation Enforcement Agency. All occupied structures within a 1,000 foot radius of the landfill shall include the following structural controls to limit the potential for landfill gas accumulation (unless such controls are determined not to be necessary by the City in consultation with the Local Enforcement Agency): (1) a geomembrane between the slab and the subgrade; (2) a permeable layer with venting pipe between the geomembrane; and (3) automatic methane gas sensors with audible alarms in the permeable layer and inside the structures. The soil risk management plan shall include, among other provisions, worker safety practices and procedures for discoveries of hazardous materials, including those already identified at the site. If DTSC concludes that additional mitigation is needed, the applicant shall work with DTSC and the City to jointly develop additional mitigation measures that meet residential standards. The approved abatement measures shall be incorporated into project building plans. Design plans for: 1) any occupied structures within 1,000 feet of the landfill boundary; and/or 2) structural systems to prevent gas-related hazards are required to be reviewed and approved by the Local Enforcement Agency (which is the County of Orange Environmental Health Division). MM HAZ-2b: Prior to issuance of grading permit for construction of the residential portion of the project, the project applicant shall retain a qualified hazardous materials contractor to remove all soil containing Total Petroleum Hydrocarbons in excess of residential development standards set forth by the California Department of Toxic Substances Control (DTSC) or other applicable regulatory agency. Soil removal and disposal shall occur in accordance with DTSC (or other applicable agency) guidelines. Additional groundwater sampling shall be conducted under the guidance of DTSC, focused on the area within 1,000 feet of the Villa Park landfill, to assess whether TPH, methane, and/or VOCs have impacted groundwater at levels that generate either significant human health or ecological risk, which was encountered at depths of 20 to 50 feet bgs. If the groundwater is affected, a multi-media risk assessment shall be conducted under the guidance of DTSC, and abatement measures as required by DTSC shall be implemented, subject to final confirmation by the City. The applicant shall submit documentation to the City of Orange in the form of confirmatory soil and groundwater sampling results verifying that this
City of Orange—Trails at Santiago Creek Specific Plan Final EIR Errata FirstCarbon Solutions 4-7 Y:\Publications\Client (PN-JN)\2765\27650002\EIR\14 - FEIR\27650002 Sec 04-00 Errata.docx Table ES-2 (cont.): Executive Summary Matrix Impacts Mitigation Measures Level of Significance After Mitigation mitigation measure was successfully implemented as part of the grading permit application for this property. All environmental investigations, sampling and/or remediation for the project site shall be conducted under a workplan approved and overseen by a regulatory agency with jurisdiction to oversee hazardous substance cleanup, such as DTSC and/or the Regional Water Quality Control Board (RWQCB). As part of proper construction operations and maintenance, any construction areas that are found to contain contaminated soils shall be excluded using a security fence. All contaminated soils shall then be excavated and disposed of off-site in accordance with the rules and regulations of: US Department of Transportation (USDOT), USEPA, CalEPA, CalOSHA, and any local regulatory agencies. All retention and detention features used during construction would be lined to prevent infiltration through contaminated soils. Post-construction retention features shall be lined to prevent infiltration of groundwater. Section 3.16—Transportation and Traffic Impact TRANS-5: The project may substantially increase hazards due to a design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment). MM TRANS-5: Prior to issuance of the first certificate of occupancy, the City of Orange shall verify that the Applicant has made improvements to traffic circulation in the area and ensured that adequate ingress and egress to the project site is provided, as follows: • Project Driveway/Nicky Way at East Santiago Canyon Road: - Construct the north leg of the intersection and provide one inbound lane and two outbound lanes (i.e., one dedicated left turn lane and one shared through/right-turn lane). - Widen and/or restripe East Santiago Canyon Road to provide one eastbound left-turn lane, one westbound right-turn lane and a third westbound through-lane. - A five-phase signal has been installed with protected left-turn phasing in the east-west direction and permissive phasing in the north-south direction. • Cannon Street at Taft Avenue: - Widen and/or restripe Cannon Street to provide a third northbound through lane. No mitigation is necessary. Less than significant impact.
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Section 1, Introduction
Page 1.1, Table 1-1: DEIR Comment Letters, Row 3
In response to comment VILLA PARK-1, the following correction has been made to reflect the correct
signatory for the City of Villa Park DEIR letter.
Status Affiliation Signatory Date
Public Agencies City of Irvine Melissa Chao, Senior Planner March 9, 2018
Department of Toxic
Substances Control
Johnson P. Abraham, Program
Manager
March 20, 2018
City of Villa Park Karen Goebel, Assistant Field
Supervisors; Jonathan Snyder
Raynald F. Pascua, Planning Manager
March 24, 2018
Santa Ana Regional Water
Quality Control Board
Keith Person, Regional Salt and
Nutrient Coordinator
March 28, 2018
Section 2, Project Description
Page 2-51, Paragraph 2
In response to comment OCTA-1, the following correction has been made with regard to trail pavement.
A variety of recreational trails for combined uses of hiking, bicycling, and horseback riding
will traverse the project site as described in the following. Trails are proposed to be unpaved
(decomposed granite or similar) in keeping with the natural setting, with the exception of
Trail E, which is proposed to have an all-weather surface, as described below.
Page 2-55, Paragraph 2
In response to comment VILLA PARK-4, the following clarifying text has is added with regard to East
Santiago Canyon Road.
Regional access to the site is provided via the SR-55 Freeway, SR-91 Freeway, and the SR-
241/SR-261 Freeways (Toll Roads). The principal local network of streets serving the proposed
project includes East Santiago Canyon Road and Cannon Street. East Santiago Canyon Road
becomes Villa Park Road, west of Hewes Street, and regional access to the project site from SR-
55 is through the City of Villa Park on Villa Park Road. Properties immediately adjacent to Villa
Park Road are predominately single-family residences. Villa Park Elementary School is
approximately 200-feet from Villa Park Road and approximately 1.5 miles from the project site.
Page 2-56, Paragraph 10
In response to comment OCTA-3, the following clarifying text has been added with regard to
pedestrian circulation.
There is no public sidewalk on the north side of Santiago Canyon Road abutting the project
site or west of the site. Lastly, there are existing public sidewalks onf both the east and west
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sides of Cannon Street south of East Santiago Canyon Road. However, sidewalks are not
provided on the east or west side of Cannon Street between the bridge over Santiago Creek
and East Santiago Canyon Road. The pedestrian circulation on the west side of Cannon
Street is provided via a multi-use path (Class I) that serves both pedestrian and bicycling
activities. There are no existing sidewalks along the Villa Park Landfill frontage on either East
Santiago Canyon Road or Cannon Street.
Page 2-61, Paragraph 3
In response to comment OCTA-5, the following revisions have been included to clarify that the
Santiago Creek Bike Trail is unpaved and does not serve all-weather conditions.
A variety of public multi-use recreation trails will traverse the project site, providing shared
use of hiking, biking and horseback riding on decomposed granite trail surfaces. Along the
north side of East Santiago Canyon Road, in addition to the existing Class II bike lane, an off-
street recreational unpaved trail, which does not serve all-weather conditions, will extend
along the entire length of the project site. This unpaved trail will provide continuity from the
existing trail that parallels the roadway east of the project site, with the intention of
connecting to future planned trails off-site to the west (provided by others). This 10-foot-
wide unpaved trail will be separated from East Santiago Canyon Road by a minimum 6-foot-
wide landscaped parkway measured from the back of curb within a minimum 18-foot-wide
easement, as per the City of Orange Recreational Trail Master Plan (RTMP) Detail #2.
Section 3.1, Aesthetics, Light, and Glare
Exhibit 3.1-2, Open Space Sections
In response to comment Wittwer_Parkin-11, a new exhibit, Exhibit 3.1-2, Open Space Sections, is
added to Section 3.1, Aesthetics, Light, and Glare.
Section 3.3, Air Quality
Page 3.3-34, Paragraph 6
The following text has been revised to reflect the revised number of anticipated haul trips during
construction. The RDEIR conservatively estimated the anticipated tonnage per truckload (10 cubic
yards) and number of haul trips (275,400) during project grading. The correct number of total haul
trips has since been more accurately estimated to be 137,900.
Based on applicant-provided information, it was assumed that construction of the project
would begin in January of 2019 and would last approximately four and one half years. A
conceptual construction schedule is provided in Table 3.3-6. There are no existing buildings
or hardscape on-site, therefore, the demolition phase would not be necessary. During
grading, the project is expected to require the import of approximately 877,000 cubic yards
of new material and the removal of approximately 500,000 cubic yards of silt. As a
conservative estimate, it was assumed that each haul truck would have a capacity of 10 20
cubic yards per load. Based on this information, it was estimated that the project would
require up to 275,400 137,900 haul trips during the 1.5-year grading period.
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Source:
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Exhibit 3.1-2
Open Space Sections
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Page 3.3-37, Paragraph Below Table 3.3-9
As shown in Table 3.3-9, the project’s construction activities are estimated to generate a
maximum 199.47 pounds of NOX per day with implementation of Mitigation Measures AIR-
1a through AIR-1g. As such, the project’s construction would continue to exceed the
SCAQMD’s recommended regional threshold of significance for NOX even after
implementation of Mitigation Measures AIR-1a through AIR-1g. As shown summarized in
Table 3.3-9, the project’s construction activities are only anticipated to exceed any of
SCAQMD’s regional thresholds of significance during the combined site preparation and
grading period. A review of the detailed emissions estimates, contained in Appendix F, shows
that 196.17 pounds of the 199.47 pounds of NOX are from off-site sources. As previously
discussed, the project is anticipated to require up to 275,400 137,900 total haul trips during
the grading period. Because the exceedance is largely a result of the anticipated haul trips,
feasible and enforceable mitigation measures to reduce the impact are limited.
Section 3.4, Biological Resources
Page 3.4-50, Paragraph 6
In response to comment CDFW-4, the following paragraph, which is part of Mitigation Measure BIO-
3, has been revised to reflect the correct, certified, Department-approved Soquel Canyon Mitigation
Bank, whose service area extends to the project site.
On- or off-site restoration or enhancement of sensitive riparian communities (e.g., southern
cottonwood-willow riparian forest) at a ratio no less than 1:1 for permanent impacts.
Temporary impacts will be restored to pre-project conditions (i.e., pre-project contours and
revegetate with native species, where appropriate). Off-site restoration or enhancement at a
ratio no less than 1:1 may include the purchase of mitigation credits at an agency-approved
off-site mitigation bank (e.g., Santa Ana Watershed Association [SAWA] Soquel Canyon
Mitigation Bank).3
Page 3.4-52, Paragraph 3
In response to comment CDFW-4, the following paragraph, which is part of Mitigation Measure BIO-
4, has been revised to reflect the correct, certified, Department-approved Soquel Canyon Mitigation
Bank, whose service area extends to the project site.
1. On- or off-site restoration or replacement of USACE/RWQCB jurisdictional waters of the
United States/waters of the State at a ratio no less than 2:1 for permanent impacts, and
for temporary impacts, restore impact area to pre-project conditions (i.e., pre-project
contours and revegetate with native species, where appropriate). If any off-site
restoration or enhancement is required, it will be provided at a ratio no less than 2:1 and
may include the purchase of mitigation credits at an agency-approved off-site mitigation
bank or in-lieu fee program (e.g., SAWASoquel Canyon Mitigation Bank).
3 Soquel Canyon Mitigation Bank is the only certified, California Department of Fish and Wildlife (CDFW)-approved mitigation bank
whose service area extends to the project site. Currently, this bank does not have the creation credits necessary to accommodate
the CDFW’s policy of “no net loss” of either wetland habitat values or acreage, nor does it sell species-specific credits (i.e., least
Bell’s vireo credits).
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Section 3.5, Cultural Resources
Page 3.5-23, Paragraph 2
In response to comment Wittwer_Parkin-38, the following correction is made to Mitigation Measure
CUL-2.
If the find is determined to have archaeological or paleontological significance, the procedures
in Mitigation Measure CUL-1 or Mitigation Measure CUL-3 shall be implemented. Monitoring
may cease once all of the areas depicted in Exhibit 3.5-1 have been thoroughly disturbed.
Section 3.8, Hazards and Hazardous Materials
Exhibit 3.8-1, Soil Matrix Core and Soil Vapor Boring Locations Map
In response to comment OCWR-8, a new exhibit, Exhibit 3.8-1, Soil Matrix Core and Soil Vapor Boring
Locations Map, is added to Section 3.8, Hazards and Hazardous Materials.
Page 3.8-13, Paragraph 2
In response to comments DTSC-3, DTSC-4, SMW-7, SMW-32, and SEARS 2-10, the following clarifying
text is added to Mitigation Measure HAZ-2a and Mitigation Measure HAZ-2b to ensure that further
investigation and implementation of abatement measures occur under the direction of the City and
DTSC.
MM HAZ-2a A supplemental Phase II Environmental Site Assessment shall be conducted
to further delineate the vertical and lateral extent of the contamination. The
proposed enclosed structures shall be situated strategically, using
supplemental Phase II Environmental Site Assessment data and DTSC’s
review thereof, so that structures will not interfere with future remediation
of any potential landfill gas migration; this shall be demonstrated in
connection with approval of any tentative maps for the project to allow for
future remediation of any potential landfill gas migration. Prior to issuance
of building permits for dwelling units in areas of the project site where vapor
intrusion has the potential to occur, the applicant shall prepare and submit
plans to the City of Orange, DTSC, or the Local Enforcement Agency (which is
the County of Orange Environmental Health Division) identifying vapor
intrusion abatement measures for trichloroethylene (TCE) and methane.
Areas where vapor intrusion has the potential to occur are those identified
in the Phase II Environmental Site Assessment.
The Phase II Environmental Site Assessment shall be conducted in
substantial compliance with applicable guidance documents, including but
not limited to the DTSC Advisory—Active Soil Gas Investigation and Final
Guidance for Evaluation and Mitigation of Subsurface Vapor Intrusion to
Indoor Air. The Phase II Environmental Site Assessment shall use current
DTSC HHRA Note 3 and Regional Screening Levels established by the U.S.
Environmental Protection Agency. Following preparation of the Phase II
Environmental Site Assessment, a soil risk management plan shall be
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prepared to address any discovery of previously unknown contamination
and shall be submitted to DTSC. These reports shall be conducted pursuant
to applicable DTSC advisories, and abatement shall be implemented as
directed by DTSC. Such abatement measures may include but are not limited
to vapor barriers or passive/active venting systems, as determined by the
appropriate regulatory agency, unless determined not to be necessary by
the City in consultation with the Local Enforcement Agency. All occupied
structures within a 1,000 foot radius of the landfill shall include the
following structural controls to limit the potential for landfill gas
accumulation (unless such controls are determined not to be necessary by
the City in consultation with the Local Enforcement Agency): (1) a
geomembrane between the slab and the subgrade; (2) a permeable layer
with venting pipe between the geomembrane; and (3) automatic methane
gas sensors with audible alarms in the permeable layer and inside the
structures. The soil risk management plan shall include, among other
provisions, worker safety practices and procedures for discoveries of
hazardous materials, including those already identified at the site. If DTSC
concludes that additional mitigation is needed, the applicant shall work with
DTSC and the City to jointly develop additional mitigation measures that
meet residential standards.
The approved abatement measures shall be incorporated into project
building plans. Design plans for: 1) any occupied structures within 1,000 feet
of the landfill boundary; and/or 2) structural systems to prevent gas-related
hazards are required to be reviewed and approved by the Local Enforcement
Agency (which is the County of Orange Environmental Health Division).
MM HAZ-2b Prior to issuance of grading permit for construction of the residential
portion of the project, the project applicant shall retain a qualified
hazardous materials contractor to remove all soil containing Total Petroleum
Hydrocarbons in excess of residential development standards set forth by
the California Department of Toxic Substances Control (DTSC) or other
applicable regulatory agency. Soil removal and disposal shall occur in
accordance with DTSC (or other applicable agency) guidelines. Additional
groundwater sampling shall be conducted under the guidance of DTSC,
focused on the area within 1,000 feet of the Villa Park landfill, to assess
whether TPH, methane, and/or VOCs have impacted groundwater at levels
that generate either significant human health or ecological risk, which was
encountered at depths of 20 to 50 feet bgs. If the groundwater is affected, a
multi-media risk assessment shall be conducted under the guidance of
DTSC, and abatement measures as required by DTSC shall be implemented,
subject to final confirmation by the City.
The applicant shall submit documentation to the City of Orange in the form
of confirmatory soil and groundwater sampling results verifying that this
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mitigation measure was successfully implemented as part of the grading
permit application for this property. All environmental investigations,
sampling and/or remediation for the project site shall be conducted under a
workplan approved and overseen by a regulatory agency with jurisdiction to
oversee hazardous substance cleanup, such as DTSC and/or the Regional
Water Quality Control Board (RWQCB). As part of proper construction
operations and maintenance, any construction areas that are found to
contain contaminated soils shall be excluded using a security fence. All
contaminated soils shall then be excavated and disposed of off-site in
accordance with the rules and regulations of: US Department of
Transportation (USDOT), USEPA, CalEPA, CalOSHA, and any local regulatory
agencies. All retention and detention features used during construction
would be lined to prevent infiltration through contaminated soils. Post-
construction retention features shall be lined to prevent infiltration of
groundwater.
Page 3.8-15, Paragraph 2
The RDEIR includes erroneous text that does not apply to the current Trails at Santiago Creek project.
Thus, the following text has been removed.
Finally, the proposed project would locate open space and recreation uses within the portion
of the site that abuts the Villa Park Landfill. These uses would serve as a buffer between the
former landfill and the residential uses that would be located in the eastern portion of the
site. Therefore, development and operation of the proposed project would not expose
persons to residual hazardous materials from past uses of the Villa Park Landfill. Impacts
would be less than significant.
Section 3.9, Hydrology and Water Quality
Exhibit 3.9-4, 100-Year Flood Hazard Areas
In response to comment VILLA PARK-13, Exhibit 3.9-4, 100-Year Flood Hazard Areas, has been
corrected to reflect a 1 percent chance of annual flood, not 0.1 percent, in Zone AE.
Page 3.9-26, Paragraph 1
The distance of the project site to Santiago Dam was correctly noted as 5 miles on Page 3.9-10, but
erroneously noted as 1.3 miles on Page 3.9-26. The following text has been revised to correct this
erroneous notation.
Santiago Dam is located 1.3 approximately 5 miles upstream of the project site.
I
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Exhibit 3.8-1
Soil Matrix Core and Soil Vapor Boring Locations Map
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLAN
RECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
Source: TAIT, May 2011
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Exhibit 3.9-4100-Year Flood Hazard Areas
Source: CA Dept of Conservatoin, 2014
CITY OF ORANGE • TRAILS AT SANTIAGO CREEK SPECIFIC PLANRECIRCULATED DRAFT ENVIRONMENTAL IMPACT REPORT
E S a n t i a g o C a n y o n R d
NCanonSt SerranoAveOrangeParkBlvdM a b u r y AveETaftAve SantiagoCreekVilla ParkLandfill (Closed)
Linda VistaElementarySchool
OakridgePrivateSchool
Salem LutheranChurch and School
1,000 0 1,000500
Feet
Legend
Project Site
Special Flood Hazard Areas
Zone AE - Within 1% chance annual Flood, base flood elevations determined
Zone AE - Within 1% chance annual flood. Within floodway.
Other Flood Hazard Areas
Zone X - Areas of 0.2% chance annual flood
Other Areas
Zone X - Areas outside the 0.2% annual chance floodplain.
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City of Orange—Trails at Santiago Creek Specific Plan
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Section 3.14, Public Services
Page 3.14-7, Paragraph 4
In response to VILLA PARK-16, the following clarifying text has been added with regard to the nearest
fire station to the project.
The nearest fire station to the project site is Orange Fire Station No. 8, located 1.75 miles from
the project site at 5725 Carver Lane. Using an average travel speed of 25 miles per hour, it
would take a fire engine responding from Station No. 8 to the project site 4 minutes, 12
seconds. For comparison purposes, the Fire Departments average response time was 3 minutes,
45 seconds in 2016. There is also Orange County Fire Authority (OCFA) Fire Station No. 23,
approximately 0.64 mile east of the project site at 5020 East Santiago Canyon Road, Villa Park,
CA 92869. However, the project site is located outside of OCFA jurisdiction boundaries.
Section 3.16, Transportation and Traffic
Page 3.16-17, Paragraph 5
In response to comment OCTA-6, the following clarify text has been included with regard to the
Santiago Creek Bike Trail parking entrance.
Additionally, Class I bike paths (off-road bike paths) exist west of Jamboree Road, extending
from Chapman Avenue to the Irvine Park, west of Hewes Street, extending from Bond
Avenue to Villa Park Road, north of Villa Park Road, extending from Hewes Street to Cannon
Street, and west of Cannon Street, extending approximately 1,000 feet north of East
Santiago Canyon Road. At the northerly terminus of Santiago Creek Trail, where Santiago
Creek crosses under Cannon Street, there is a trailhead that provides a gravel parking lot and
is designated as the “Santiago Creek Bike Trail Parking Entrance.”
Page 3.16-84, Table 3.16-11: Existing With Project Peak-Hour Intersection Capacity Analysis
(Without Sand and Gravel Credit)
In response to comment Wittwer_Parkin-66, the following correction has been made with regard to
the intersection of Cannon Street at Taft Avenue.
2 Cannon Street at Taft Avenue
AM
D
0.983 B 0.655
0.985
B1
E
0.000
0.002 No
PM 0.869 D 0.870
0.655
D
B1 0.001 No
Page 3.16-120, Paragraph 5
In response to comment VILLA PARK-21, the following correction has been made with regard to East
Santiago Canyon Road as a facility in the Orange County Congestion Management Program.
East Santiago Canyon Road is a facility that is identified in the Orange County Congestion
Management Program. As discussed in Impacts TRANS-1 through TRANS-3, the proposed
project can mitigate all of its impacts associated with deficient traffic conditions on East
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Santiago Canyon Road. Thus, no conflicts with the Congestion Management Plan would
occur. Impacts would be less than significant.
Page 3.16-122, Paragraph 1
The text below has been removed because the improvements required by Mitigation Measure
TRANS-5 are design features that were identified in the project’s traffic study and were already
incorporated into the project. Mitigation Measure TRANS-5 has therefore been removed from the
RDEIR. Further, revisions to Mitigation Measure TRANS-5 were inadvertently included in the Final
EIR’s Response to Comments. References to Mitigation Measure TRANS-5 have been removed
throughout the Final EIR.
MM TRANS-5: Prior to issuance of the first certificate of occupancy, the City of Orange shall
verify that the Applicant has made improvements to traffic circulation in the area and
ensured that adequate ingress and egress to the project site is provided, as follows:
• Project Driveway/Nicky Way at East Santiago Canyon Road:
- Construct the north leg of the intersection and provide one inbound lane and two
outbound lanes (i.e., one dedicated left turn lane and one shared through/right-
turn lane).
- Widen and/or restripe East Santiago Canyon Road to provide one eastbound left-
turn lane, one westbound right-turn lane and a third westbound through-lane.
- A five-phase signal has been installed with protected left-turn phasing in the east-west
direction and permissive phasing in the north-south direction.
• Cannon Street at Taft Avenue:
- Widen and/or restripe Cannon Street to provide a third northbound through lane.
Page 3.16-123, Paragraph 1
In response to comment OCTA-7, the following clarifying text is included with regard to the paved
Class I facility being consistent with local and regional master planning policy documents.
The Class I Santiago Creek Bike Path follows the Santiago Creek corridor before terminating
at Cannon Street. The proposed project would extend the trail through the project site to
Santiago Oaks Regional Park. This would close a gap in the regional bicycle and pedestrian
network. The paved Class I facility will be consistent with local and regional master planning
policy documents, such as the City of Orange Bicycle Master Plan (2001), County of Orange
Major Riding and Hiking Trails and Off-Road Paved Bikeways Map, and the OCTA Commuter
Bikeways Strategic Plan (2009).
Section 5.1.2, Alternatives to the Proposed Project
The Recirculated Draft EIR Alternatives Section erroneously noted that the total number of dwelling
units that would be developed under Alternative 1 would be 90 units, 77 units, and 40 units. It also
erroneously noted that Alternative 1 would require a General Plan Amendment to remove the
project site from the East Orange General Plan and the Orange Park Acres Plan. Moreover, it noted
that the alternative would require the intersection of East Santiago Canyon Road/Nicky Way to be
improved to provide turn lanes and improved access to the materials recycling and backfilling
operation. However, these facts were erroneously noted in the RDEIR. The analysis of Alternative 1
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was conducted assuming 40-50 single-family residential units would be developed under Alternative
1 and assuming no General Plan Amendment would be required. The Alternative 1 traffic analysis did
not include improvements to East Santiago Road/Nicky Way. Therefore, the erroneous statements in
the RDEIR are hereby revised and/or removed to clarify that Alternative 1 would yield 40-50 single-
family dwelling units, would not require a General Plan Amendment, and would not require
improvements to the intersection of East Santiago Canyon Road/Nicky Way. Specific revisions
include the following:
Page 5-2, Paragraph 6
The following text has been revised to reflect the correct number of units Alternative 1 would develop
and to clarify that the General Plan allows 15.4 acres of residential uses north of Santiago Creek.
This alternative consists of new residential development and the continuation of existing
sand and gravel operations in accordance with the existing City of Orange General Plan
designations. Residential uses would be developed on 15.4 acres north of Santiago Creek
(7740 to 50 dwelling units), with sand and gravel activities occurring on 77.3 acres on both
sides of the waterway. 40-50 dwelling units would be consistent with the General Plan’s
density range of 2.1 to 6.0 units per acre and tThe existing R-1-8 Zoning for the residential
area would provide a maximum of 77 single-family dwelling units based on acre density and
would yield approximately 40 to 50 single-family dwelling units (although a range of 32 to 92
dwelling units could be developed under the existing land use designations). The General
Plan allows 15.4 acres of residential uses north of Santiago Creek. The Santiago Creek
corridor would be designated for open space (16.5 acres). The Development within the
Existing Land use Designations Alternative is depicted in Exhibit 5-1.
Section 5.3, Alternative 1—Development within the Existing Land Use Designations
Page 5-1, Paragraph 5
The following text has been revised to reflect the correct number of anticipated haul trips during
construction of the project.
As discussed in Impact AIR-2, the project’s construction activities are estimated to generate
a maximum of 199.47 pounds of NOX per day with implementation of Mitigation Measures
AIR-1a through AIR-1g. As such, the project’s construction would continue to exceed the
SCAQMD’s recommended regional threshold of significance for NOX even after
implementation of Mitigation Measures AIR-1a through AIR-1g. The project’s construction
activities are only anticipated to exceed any of SCAQMD’s regional thresholds of significance
during the combined site preparation and grading period. A review of the detailed emissions
estimates, contained in Appendix F, show that 196.17 of the 199.47 pounds of NOX are from
off-site sources. As previously discussed, the project is anticipated to require up to 275,400
137,900 total haul trips during the grading period.
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Page 5-11, Paragraph 1
The following text has been revised to reflect the correct number of units Alternative 1 would
develop and to omit reference to 15.4 acres, which is the acreage that is allowed for residential in
the General Plan north of Santiago Creek.
Residential uses would be developed on 15.4 acres north of Santiago Creek, with resource
land use activities (sand, gravel, and materials recycling) occurring on 77.3 acres on both
sides of the waterway.1 Consistent with the City of Orange General Plan’s density range of 2.1
to 6.0 units per acre and the existing R-1-8 Zoning, there is an allowable range of 32 to 92
residential homes, and a target of 40 to 5077 residential homes would be developed on this
15.4-acre residential land use parcel. The existing R-1-8 Zoning for the residential area would
provide a maximum of 77 single-family dwelling units based on acre density and would yield
approximately 40 to 50 single-family dwelling units(although a range of 32 to 92 dwelling
units could be developed under the existing land use designations).
Page 5-11, Paragraph 2
The following text has been revised to remove improvements to the intersection of East Santiago
Canyon Road/Nicky Way, which was erroneously included as a component of Alternative 1.
The intersection of East Santiago Canyon Road/Nicky Way would be improved to provide
turn lanes and improved access to the materials recycling and backfilling operation.
Page 5-11, Paragraph 3
The following text has been revised to remove a sentence regarding the number of units, which was
erroneously included as a component of Alternative 1.
The total number of dwelling units that would be developed under this alternative would be 90.
Page 5-11, Paragraph 6
The following text has been revised to remove a sentence regarding the requirement of a General
Plan Amendment, which was erroneously included as a component of Alternative 1.
This alternative would require a General Plan Amendment to remove the project site from
the East Orange General Plan and Orange Park Acres Plan.
Page 5-11, Table 5-1
The column labeled “Dwelling Units” has been revised to reflect the correct number of units
Alternative 1 would develop. The column labeled “Acres” has been revised to omit reference to 15.4
acres, which is the acreage that is allowed for residential in the General Plan north of Santiago Creek.
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Scenario Land Use Acres Dwelling Units
Development within
the Existing Land Use
Designations
Alternative
Residential (North Bank) 15.4 77 40–50
Materials Recycling and
Backfilling/Sand and Gravel
77.3
Santiago Creek Greenway
Open Space
16.5
Subtotal 109.2 77 40-50
Page 5-11, Footnote 1
The following text has been revised to reflect the correct reference to the Pre-Development
Agreement.
The No Project Alternative/Existing Land Use Designations Alternative corresponds to
Alternative F G in the Pre-Development Agreement (PDA). Refer to Section 2, Project
Description for further discussion of the PDA.
Page 5-12, Paragraph 1
The following text has been revised to reflect the correct number of units Alternative 1 would
develop and to omit reference to 15.4 acres, which is the acreage that is allowed for residential in
the General Plan north of Santiago Creek.
Aesthetics, Light, and Glare
The Development within the Existing Land Use Designations Alternative consists of
developing 7740 to 50 dwelling units on 15.4 acres on the north side of Santiago Creek, and
maintaining the existing resource extraction activities on 77.3 acres of the project site.
Page 5-12, Paragraph 3
The following text has been revised to reflect the correct number of units Alternative 1 would
develop and to omit reference to 15.4 acres, which is the acreage that is allowed for residential in
the General Plan north of Santiago Creek.
Air Quality
The Development within the Existing Land Use Designations Alternative consists of
developing 7740 to 50 dwelling units on 15.4 acres on the north side of Santiago Creek, and
maintaining the existing resource extraction activities on 77.3 acres of the project site.
Page 5-12, Paragraph 4
The following text has been revised to reflect the correct number of units Alternative 1 would
develop and to omit reference to 15.4 acres, which is the acreage that is allowed for residential in
the General Plan north of Santiago Creek.
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Biological Resources
The Development within the Existing Land Use Designations Alternative consists of
developing 7740 to 50 dwelling units on 15.4 acres on the north side of Santiago Creek, and
maintaining the existing resource extraction activities on 77.3 acres of the project site.
Page 5-12, Paragraph 5
The following text has been revised to reflect the correct number of units Alternative 1 would
develop and to omit reference to 15.4 acres, which is the acreage that is allowed for residential in
the General Plan north of Santiago Creek.
Cultural Resources
The Development within the Existing Land Use Designations Alternative consists of
developing 7740 to 50 dwelling units on 15.4 acres on the north side of Santiago Creek, and
maintaining the existing resource extraction activities on 77.3 acres of the project site.
Page 5-13, Paragraph 1
The following text has been revised to reflect the correct number of units Alternative 1 would
develop and to omit reference to 15.4 acres, which is the acreage that is allowed for residential in
the General Plan north of Santiago Creek.
Geology and Soils
The Development within the Existing Land Use Designations Alternative consists of
developing 7740 to 50 dwelling units on 15.4 acres on the north side of Santiago Creek, and
maintaining the existing resource extraction activities on 77.3 acres of the project site.
Page 5-13, Paragraph 2
The following text has been revised to reflect the correct number of units Alternative 1 would
develop and to omit reference to 15.4 acres, which is the acreage that is allowed for residential in
the General Plan north of Santiago Creek.
Greenhouse Gas Emissions
The Development within the Existing Land Use Designations Alternative consists of
developing 7740 to 50 dwelling units on 15.4 acres on the north side of Santiago Creek, and
maintaining the existing resource extraction activities on 77.3 acres of the project site.
Page 5-13, Paragraph 3
The following text has been revised to reflect the correct number of units Alternative 1 would
develop and to omit reference to 15.4 acres, which is the acreage that is allowed for residential in
the General Plan north of Santiago Creek.
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Hazards and Hazardous Materials
The Development within the Existing Land Use Designations Alternative consists of
developing 7740 to 50 dwelling units on 15.4 acres on the north side of Santiago Creek, and
maintaining the existing resource extraction activities on 77.3 acres of the project site.
Page 5-14, Paragraph 1
The following text has been revised to reflect the correct number of units Alternative 1 would
develop and to omit reference to 15.4 acres, which is the acreage that is allowed for residential in
the General Plan north of Santiago Creek.
Hydrology and Water Quality
The Development within the Existing Land Use Designations Alternative consists of
developing 7740 to 50 dwelling units on 15.4 acres on the north side of Santiago Creek, and
maintaining the existing resource extraction activities on 77.3 acres of the project site.
Page 5-14, Paragraph 2
The following text has been revised to reflect the correct number of units Alternative 1 would
develop and to omit reference to 15.4 acres, which is the acreage that is allowed for residential in
the General Plan north of Santiago Creek.
Land Use and Planning
The Development within the Existing Land Use Designations Alternative consists of
developing 7740 to 50 dwelling units on 15.4 acres on the north side of Santiago Creek, and
maintaining the existing resource extraction activities on 77.3 acres of the project site.
Page 5-14, Paragraph 3
The following text has been revised to reflect the correct number of units Alternative 1 would
develop and to omit reference to 15.4 acres, which is the acreage that is allowed for residential in
the General Plan north of Santiago Creek.
Mineral Resources
The Development within the Existing Land Use Designations Alternative consists of
developing 7740 to 50 dwelling units on 15.4 acres on the north side of Santiago Creek, and
maintaining the existing resource extraction activities on 77.3 acres of the project site.
Page 5-14, Paragraph 4
The following text has been revised to reflect the correct number of units Alternative 1 would
develop and to omit reference to 15.4 acres, which is the acreage that is allowed for residential in
the General Plan north of Santiago Creek.
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Noise
The Development within the Existing Land Use Designations Alternative consists of
developing 7740 to 50 dwelling units on 15.4 acres on the north side of Santiago Creek, and
maintaining the existing resource extraction activities on 77.3 acres of the project site.
Page 5-15, Paragraph 1
The following text has been revised to reflect the correct number of units Alternative 1 would develop.
The Development within the Existing Land Use Designations Alternative consists of
developing 7740 to 50 dwelling units within the project site, a net decrease of 66 78-88
dwelling units relative to the proposed project. The reduction in dwelling units would
decrease the population growth attributable to this alternative by 195 123 to 154 persons
relative to the proposed project.
Page 5-15, Paragraph 2
The following text has been revised to reflect the correct number of units Alternative 1 would develop.
Public Services
The Development within the Existing Land Use Designations Alternative consists of
developing 7740 to 50 dwelling units within the project site, a net decrease of 66 78-88
dwelling units relative to the proposed project. The reduction in dwelling units would reduce
the population growth attributable to this alternative by 195 123 to 154 persons relative to
the proposed project.
Page 5-15, Paragraph 3
The following text has been revised to reflect the correct number of units Alternative 1 would develop.
Recreation
The Development within the Existing Land Use Designations Alternative consists of
developing 7740 to 50 dwelling units within the project site, a net decrease of 66 78-88
dwelling units relative to the proposed project. The reduction in dwelling units would reduce
the population growth attributable to this alternative by 195 123 to 154 persons relative to
the proposed project.
Page 5-15, Paragraph 4
The following text has been revised to reflect the correct number of units Alternative 1 would
develop and to omit reference to 15.4 acres, which is the acreage that is allowed for residential in
the General Plan north of Santiago Creek.
The Development within the Existing Land Use Designations Alternative consists of
developing 40 to 50 dwelling units on 15.4 acres on the north side of Santiago Creek, and
maintaining the existing resource extraction activities on 77.3 acres of the project site.
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Page 5-16, Paragraph 1
The following text has been revised to reflect that Alternative 1 would not require improvements to
East Santiago Canyon Road/Nicky Way, which was erroneously included in the RDEIR.
This alternative would also require improvements to the East Santiago Canyon Road/Nicky
Way intersection, which would provide access to the resource extraction operations on the
project site.
Page 5-16, Paragraph 3
The following text has been revised to reflect the correct number of units Alternative 1 would
develop and to omit reference to 15.4 acres, which is the acreage that is allowed for residential in
the General Plan north of Santiago Creek.
Tribal Cultural Resources
The Development within the Existing Land Use Designations Alternative consists of
developing 7740 to 50 dwelling units on 15.4 acres on the north side of Santiago Creek, and
maintaining the existing resource extraction activities on 77.3 acres of the project site.
Page 5-16, Paragraph 4
The following text has been revised to reflect the correct number of units Alternative 1 would develop.
Utilities and Service Systems
The Development within the Existing Land Use Designations Alternative consists of
developing 7740 to 50 dwelling units within the project site, a net decrease of 72 78-88
dwelling units relative to the proposed project. The reduction in dwelling units would reduce
the population growth attributable to this alternative by 195 123 to 154 persons relative to
the proposed project.
Section 6.0, Other CEQA Considerations
Page 6-1, Paragraph 4
The following text has been revised to reflect the revised number of anticipated haul trips during
construction of the project.
As discussed in Impact AIR-2, the project’s construction activities are estimated to generate
a maximum of 199.47 pounds of NOX per day with implementation of Mitigation Measures
AIR-1a through AIR-1g. As such, the project’s construction would continue to exceed the
SCAQMD’s recommended regional threshold of significance for NOX even after the
implementation of Mitigation Measures AIR-1a through AIR-1g. The project’s construction
activities are only anticipated to exceed any of SCAQMD’s regional thresholds of significance
during the combined site preparation and grading period. A review of the detailed emissions
estimates, contained in Appendix F, shows that 196.17 pounds of the 199.47 pounds of NOX
are from off-site sources. As previously discussed, the project is anticipated to require up to
275,400 137,900 total haul trips during the grading period.
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Appendix F, Air Quality and Greenhouse Gas Supporting Information
In response to Wittwer-Parkin-42, the Final EIR includes updates to Appendix F. RDEIR Appendix F
erroneously included air quality modeling results that were inconsistent with tables in the Air Quality
Section of the RDEIR. The Final EIR provides updated modeling results that are consistent with the
modeling results presented in the RDEIR Air Quality Section. All detailed modeling results and
assumptions, which support the analysis and conclusions in the RDEIR Air Quality Section, are
included in Appendix F.
Appendix R, City Resolution No. 3915
As part of Master Response 1—Plan Consistency, RDEIR Appendix G has been included to support
the statement in the Final EIR that the OPA Plan is not a specific plan adopted pursuant to the
specific plan statute. The Plan was adopted by City Resolution No. 3915 in December 1973, prior to
the 1974 enactment of the specific plan statute. Resolution No. 3915 adopted the Plan as a land use
element of the General Plan.
Appendix S, April 1, 2019 Memorandum from the City of Orange Community Development
Director to the Director of OC Parks
As part of Master Response 6—Stewardship of Open Space, RDEIR Appendix H has been included to
emphasize that as a component of the Specific Plan and Development Agreement, the project
applicant is proposing to fund $4,100,000 in landscaping, trails, and other improvements for the
Santiago Creek Greenway and open spaces.
Responses to Written Comments
Page 353, Response to COONRADT-6
The following text has been revised to reflect that the improvements required by Mitigation
Measure TRANS-5 are design features that were identified in the project’s traffic study and are
already incorporated into the project. As such, Mitigation Measure TRANS-5 has been removed.
The commenter states an opinion that East Santiago Canyon Road is overburdened with traffic
and the project would add more traffic, potentially causing safety risks and hazards. Comment
noted. Impacts related to traffic are discussed in RDEIR Section 3.16, Transportation and
Traffic. As discussed in Section 3.16, Impact TRANS-2, impacts would remain significant and
unavoidable after implementation of mitigation and would require a statement of overriding
considerations to be adopted by the City prior to approval of the project. Potential hazards are
discussed in Impact TRANS-5. As discussed, the project’s impacts related to safety hazards
would be less than significant with implementation of Mitigation Measure TRANS-5, which
would ensure adequate and ingress and egress to the site would be adequate.
Page 2-24, Paragraph 7
The following text has been revised to reflect an updated, more accurate estimate of construction
truck trips.
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During grading, the project would import approximately 877,000 cubic yards of new
material, and remove 500,000 cubic yards of silt. As a conservative estimate, iIt was assumed
that each haul truck would have a capacity of 10 20 cubic yards per load (plus the return of
one empty truck). Based on this conservative assumption, it was estimated that the project
would require up to 275,400 137,900 haul trips during the 1.5-year grading period. Thus,
using this estimate, the technical analyses and discussions in the RDEIR assumes an accurate
estimate of the number of haul trips that will be required the “worst case” scenario for the
project. This allows the reader and decision makers to fully understand potential
environmental impacts.
Page 3-88, Response to SCAQMD-8
The following text has been revised to reflect an updated, more accurate estimate of construction
truck trips.
As indicated by the commenter, feasibility means, “being capable of being accomplished
within a reasonable period of time.” The amount of soil hauling that would be required for
the grading portion of construction activities would result in substantial numbers of trucks
traveling to and from the site on a daily basis. In addition, the construction activities would
likely involve different sets of construction contractors and haul companies to complete the
project. If such a measure is required, a list of approved trucks that meet 2010 model year
standards would have to be developed prior to those trucks coming on-site, and the
contractor would have to implement multiple checkpoints to ensure that the trucks matched
that list and no other trucks came on-site. Given that the project requires approximately
137,900 275,000 haul trips, (over 700 trips per day based on the estimated schedule)
(approximately 350 trips per day based on the estimated 18 month schedule) and specific
make and model of haul trucks can vary by contractor and within each contractor fleet, such
a requirement could result in substantial delays in the construction schedule.
Page 3-161, Response to SMW-47, Paragraph 2
As stated in RDEIR Section 2, Project Description, page 2-55, current traffic volumes resulting
from the existing on-site rock crushing operation generates approximately 686 daily trips, of
which over 500 of those trips is truck traffic. Further, the RDEIR indicates that “the project
would require up to 275,400 137,900 haul trips during the 1.5-year grading period,” resulting
in approximately 700 300 trips per day.
Page 3-163, Paragraph 2, Response to SMW-48
The following text has been revised to reflect an updated, more accurate estimate of construction
truck trips.
The amount of earthwork used in the analysis of air quality emissions is consistent with the
project description and the Specific Plan. As discussed in Impact AIR-2, the project would
import approximately 877,000 cubic yards of new material, and remove 500,000 cubic yards
of silt. As a conservative estimate, iIt was assumed that each haul truck would have a
capacity of 10 20 cubic yards per load (plus the return of one empty truck). Based on this
information, it was estimated that the project would require up to 275,400 137,900 haul
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trips during the 1.5-year grading period. Haul truck emissions were included in the analysis
of regional emissions. The comment indicates, “the Project may expose nearby sensitive
receptors to an elevated health risk, which would likely require the preparation of a health
risk assessment.” However, as discussed in the Impact AIR-4, the RDEIR already includes a
health risk assessment that evaluates both on-road and off-road emissions sources.
Page 3-197, Response to Wittwer-Parkin-19
The following text has been revised to reflect an updated, more accurate estimate of construction
truck trips.
Please see Master Response 9—Soil Import/Export Numbers. As the commenter notes, tThe
project would generate 275,400 137,900 haul trips. Further, the RDEIR indicates that “the
project would require up to 275,400 haul trips The 137,900 haul trips during the 1.5-year
grading period,” would resulting in approximately 700 350 trips per day. For a response to
the commenter’s question about the baseline for rock crushing, please refer to Response
Wittwer Parkin-10 above.
Page 3-198, Response to Wittwer-Parkin-21
The following text has been revised to reflect an updated, more accurate estimate of construction
truck trips.
As discussed in Impact AIR-2, the project would import approximately 877,000 cubic yards of
new material, and remove 500,000 cubic yards of silt. As a conservative estimate, iIt was
assumed that each haul truck would have a capacity of 10 20 cubic yards per load (plus the
return of one empty truck). Based on this information, it was estimated that the project
would require up to 275,400 137,900 haul trips during the 1.5-year grading period. Haul
truck emissions were included in the analysis of regional emissions. Therefore, contrary to
the commenter’s assertion, hauling trips were accounted for in the Air Quality Analysis
conducted for the project and construction impacts were not underestimated. As discussed
in the Impact AIR-4, the RDEIR already includes a health risk assessment that evaluates both
on-road and off-road emissions sources.
Page 3-214, Response to Wittwer Parkin-76
The following text has been revised to reflect an updated, more accurate estimate of construction
truck trips.
To fully analyze potential traffic, air quality and other potential impacts, it was conservatively
reasonably estimated that the project would require up to 275,400 137,900 haul trips during
the 1.5-year grading period. This estimate is based on the reasonable assumption that each
haul truck would have a capacity of 10 20 cubic yards per load. This allows the reader and
decision makers to fully understand potential environmental impacts. There is no evidence
that this conservative estimate, or the underlying assumption, is wasteful, inefficient, or
involves the unnecessary consumption of energy. Therefore, the energy section does not
need to be revised to reduce the number of these trips or the trip length. Impacts were fully
analyzed and determined to be less than significant.
Appendices
Appendices to Trails at Santiago Creek Specific Plan Certified Environmental Impact Report No.
1857-18 (SCH No. 2017031020) can be found at the following locations:
https://www.cityoforange.org/292/Project-NoticesRelated-Environmental-Doc