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12-03-18 MND No 1860-18 - Billboard Ordinance UpdateBillboard Ordinance Update Project MITIGATED NEGATIVE DECLARATION NO. 1860-18 Lead Agency: City of Orange Community Development Department  Planning Division 300 East Chapman Avenue Orange, CA 92866-1591 (714) 744 7220 (714) 744 7222 (Fax) www.cityoforange.org Prepared by: FirstCarbon Solutions 1350 Treat Boulevard, Suite 380 Walnut Creek, CA 94597 (925) 357 2562 Date: November 7, 2018 THIS PAGE INTENTIONALLY LEFT BLANK iii Table of Contents Sections Page # MITIGATED NEGATIVE DECLARATION NO. 1860-18 .................................................................... v INTRODUCTION ........................................................................................................................... v EXISTING SETTING .................................................................................................................... vi PROJECT DESCRIPTION .......................................................................................................... xxii BILLBOARD-SPECIFIC REGULATORY CONTEXT ............................................................. xxx REQUIRED APPROVALS ....................................................................................................... xxxiii INTENDED USES OF THIS DOCUMENT ............................................................................ xxxiii Figures Figure 1: Regional Location Map ............................................................................................................... vii Figure 2: Local Vicinity Map ....................................................................................................................... ix Figure 3a: Retained Billboard Location 1—West of SR 55, 100 feet south of East Katella Avenue ........... xi Figure 3b: Retained Billboard Location 2—West of SR 55, 1,900 feet north of Meats Avenue ............... xiii Figure 3c: Retained Billboard Location 3—West of SR 57, 250 feet south of West Chapman Avenue ..... xv Figure 3d: Retained Billboard Location 4—East of SR 57, 100 feet south of the Santa Ana River ......... xvii Figure 3e: Retained Billboard Location 5—East of SR 57, 220 feet east of the SR 57 North onramp ..... xix Figure 4a: Typical Daytime View at a Potential Removal Site ................................................................. xxv Figure 4b: Typical Daytime View at a Potential Removal Site ............................................................... xxvii Figure 5: Retained Billboard 1—1936 East Katella Avenue Site Plan .................................................... xxxi Tables Table 1: Retained Billboard Locations ......................................................................................................... vi Table 2: Billboard Dimensions ................................................................................................................ xxiv Table 3: Regional Construction Emissions by Construction Activity ......................................................... 16 Table 4: Orange County Landfill Summary ................................................................................................ 65 Appendices Appendix A: Draft Billboard Ordinance Appendix B: Photometric Analysis Appendix C: Air Quality and Greenhouse Gas Emissions Supporting Information Appendix D: City of Orange Pending Land Use Applications THIS PAGE INTENTIONALLY LEFT BLANK v MITIGATED NEGATIVE DECLARATION NO. 1860-18 Project Title: Billboard Ordinance Update Project Reference Application Numbers: ZC No. 1292-18 and MND No. 1860-18 Lead Agency and Address: City of Orange 300 E. Chapman Avenue Orange, CA 92866 Contact Person and Telephone No.: Ashley Brodkin, Associate Planner (714) 744-7238 Project Proponent and Address: City of Orange 300 E. Chapman Avenue Orange, CA 92866 Contact Person and Telephone No.: Ashley Brodkin, Associate Planner (714) 744-7238 Project Location: Various sites throughout the City of Orange Existing General Plan Designation: Various sites throughout the City of Orange Existing Zoning Classification: Various sites throughout the City of Orange INTRODUCTION The City of Orange’s Municipal Code (Billboard Ordinance, Municipal Code Title 5—Chapter 5.62, Signs and Billboards) does not currently allow for the construction and operation of digital display billboards within the City’s jurisdictional boundaries. The City is proposing to repeal and delete Chapter 5.62, Signs and Billboards, in its entirety, and to amend Title 17, Chapter 17.36 Sign Regulations to add a new Section 17.36.180 that would provide guidance for the “relocation” of existing billboards within the City. As defined in the proposed Billboard Ordinance, “relocation” includes the conversion of an existing static billboard display to a digital display, subject to the removal of other existing billboard faces, as defined in California Business and Professions Code Section 5412. The purpose of this Initial Study/Mitigated Negative Declaration (IS/MND) is to identify potential environmental impacts from implementation of the proposed City of Orange Billboard Ordinance Update Project (referred to herein as the proposed project) within the City of Orange. Pursuant to California Environmental Quality Act (CEQA) Guidelines Section 15367, the City of Orange is the Lead Agency in the preparation of this IS/MND and additional environmental review documentation required for the proposed project. The City has discretionary authority over the proposed project. The intended use of this IS/MND is to determine the level of environmental impacts resulting from the project; where a potentially significant impact is found, to identify mitigation measures that reduce such impacts to a less than significant level; and to provide the basis for input from public agencies, organizations, and interested members of the public. The remainder of this section provides a brief description of the project location and the characteristics of the project. Section 2 includes an environmental checklist giving an overview of the potential impacts that may result from project implementation. Each individual subsection vi elaborates on the information contained in the environmental checklist, along with justification for the responses provided in the environmental checklist. EXISTING SETTING Regional Setting: City of Orange is located in Orange County, California. It is surrounded by the City of Anaheim to the north and west, the City of Tustin to the south, and unincorporated Orange County to the east. The City of Orange surrounds the City of Villa Park, and also includes unincorporated County lands and County islands. Figure 1: Regional Location Map, and Figure 2: Local Vicinity Map depict surrounding jurisdictions and unincorporated areas and islands. Project Location: There are currently 11 traditional billboards in an array of sizes, ranging from 12 feet by 25 feet (300 square feet) to 20 feet by 60 feet (1,200 square feet) in the City.1 Additionally, there are three billboards located on unincorporated (County) lands that could affect viewsheds within the City.2 Existing Site Conditions and Surrounding Land Uses: Retained Billboard Locations Existing billboards that are identified for retention and are subject to implementation of the proposed project/ordinance are all located along sides of freeways in the City’s Freeway Corridor. The Freeway Corridor is defined as the area within the City comprised of the land within 300 feet of either edge of the right-of-way of the following freeways: California Interstate 5 (I-5); California State Route 22 (SR-22); California State Route 55 (SR-55); and California State Route 57 (SR-57). The billboard sites in the Freeway Corridor are generally surrounded by commercial, residential, and light industrial uses, as well as various roadways. Table 1 lists the retained billboard locations, and Figure 2: Local Vicinity Map provides an aerial map that depicts surrounding land uses. Figures 3a through 3e show the daytime views of the retained billboard locations. Table 1: Retained Billboard Locations Billboard Location APN 1 West side of SR-55, 100 feet south of East Katella Avenue 375-532-07 2 West side of SR-55, 1,900 feet north of Meats Avenue 372-642-33 3 West side of SR-57, 250 feet south of West Chapman Avenue 232-032-01 4 East side of SR-57, 100 feet south of the Santa Ana River 386-381-04; 386-381-05 5 East side of SR-57, 220 feet east of the SR-57 North on ramp 386-401-14 1 Four of the eleven billboards were built after 1995 as part of a 1995 Settlement Agreement with National Advertising. The other seven were built in the 1970s and were already in place when the City annexed the land upon which they were built. 2 The Ordinance as proposed would allow for removal of billboards that affect City viewsheds as part of Relocation Agreements associated with the City’s Billboard Ordinance Update. OrangeCounty SanBernardinoCounty Orange County Los Angeles County 91 83 91 91 55 57 241 261 241 5 O ra n g e C o u nty Riversid e C o u nty 60 5 605 10 210 5 405 5 22 133 15 1 1 210 Prado FloodControl Basin SantiagoReservoir P a c i f i c O c e a n Angeles National Forest ClevelandNationalForest Glendora RanchoCucamongaSan Dimas CovinaAlhambraEl Monte Pomona Ontario Walnut ChinoCommerce Whittier NorcoNorwalk Yorba LindaFullerton Anaheim Orange Garden Grove Seal Beach Santa Ana FountainValleyHuntingtonBeach Costa Mesa Irvine Lake Forest Newport Beach Laguna Hills Laguna Niguel Corona Chino Hills Upland Claremont Montclair LagunaWoods Figure 1Regiona l Loca tion Ma p 5 0 52.5 Miles Text Project Site Source: Census 2000 Da ta , The Ca SIL CITY OF ORANGE COMMUNITY DEVELOPMENTBILLBOARD ORDINANCE UPDATE PROJECTINITIAL STUDY/MITIGATED NEGATIVE DECLARATION 04040014 • 08/2018 | 1_regiona l.mxd Legend Retained Billboard Locations THIS PAGE INTENTIONALLY LEFT BLANK 57 Taft AveBatavia StKatella Ave Orangewood Ave Walnut Ave Chapman Ave Prospect StTustin StChapman Ave Main StLa Veta Ave Shaffer StCollins Ave Batavia StSa n t i a g o B l v d Meats AveOrange Olive RdLincoln Ave Glassell StMain StSunkist St55 9191 22Santa Ana River5 Santa Ana City of Orange Anaheim Anaheim Villa Park 2 5 4 3 1 04040014 • 08/2018 | 2_lo cal_vicinity.m xd Figure 2Lo cal V icinity Map So urce: ESRI Aerial Im agery. Inset Maps Scale: 1inch = 350ft CITY OF ORANGE COMMUNITY DEV ELOPMENTBILLBOARD ORDINANCE UPDATE PROJECTINITIAL STUDY/MITIGATED NEGATIV E DECLARATION 3,000 0 3,0001,500 Feet 55 2 55 Katella Ave 1 Orangewood Ave 57 Santa Ana River4 5 Chapman Ave Anita Dr57 Santa Ana River3 Legend Retained Billboard Locations City Boundaries Orange County THIS PAGE INTENTIONALLY LEFT BLANK Retained Billboard Location 1 – West of SR 55, 100 feet south of East Katella Avenue facing North Retained Billboard Location 1 – West of SR 55, 100 feet south of East Katella Avenue facing South 04040014 • 09/2018 | 3a_site_photos.cdr CITY OF ORANGE COMMUNITY DEVELOPMENT BILLBOARD ORDINANCE UPDATE PROJECT INITIAL STUDY/MITIGATED NEGATIVE DECLARATION Figure 3a Retained Billboard Location 1 – West of SR 55, 100 feet south of East Katella Avenue THIS PAGE INTENTIONALLY LEFT BLANK Retained Billboard Location 2 – West of SR 55, 1,900 feet north of Meats Avenue facing North Retained Billboard Location 2 – West of SR 55, 1,900 feet north of Meats Avenue facing South 04040014 • 09/2018 | 3b_site_photos.cdr CITY OF ORANGE COMMUNITY DEVELOPMENT BILLBOARD ORDINANCE UPDATE PROJECT INITIAL STUDY/MITIGATED NEGATIVE DECLARATION Figure 3b Retained Billboard Location 2 – West of SR 55, 1,900 feet north of Meats Avenue THIS PAGE INTENTIONALLY LEFT BLANK Retained Billboard Location 3 – West of SR 57, 250 feet south of West Chapman Avenue facing North Retained Billboard Location 3 – West of SR 57, 250 feet south of West Chapman Avenue facing South 04040014 • 09/2018 | 3c_site_photos.cdr CITY OF ORANGE COMMUNITY DEVELOPMENT BILLBOARD ORDINANCE UPDATE PROJECT INITIAL STUDY/MITIGATED NEGATIVE DECLARATION Figure 3c Retained Billboard Location 3 – West of SR 57, 250 feet south of West Chapman Avenue THIS PAGE INTENTIONALLY LEFT BLANK Retained Billboard Location 4 – East of SR 57, 100 feet south of the Santa Ana River facing North Retained Billboard Location 4 – East of SR 57, 100 feet south of the Santa Ana River facing South 04040014 • 09/2018 | 3d_site_photos.cdr CITY OF ORANGE COMMUNITY DEVELOPMENT BILLBOARD ORDINANCE UPDATE PROJECT INITIAL STUDY/MITIGATED NEGATIVE DECLARATION Figure 3d Retained Billboard Location 4 – East of SR 57, 100 feet south of the Santa Ana River THIS PAGE INTENTIONALLY LEFT BLANK Retained Billboard Location 5 – East of SR 57, 220 feet east of the SR 57 North onramp facing North Retained Billboard Location 5 – East of SR 57, 220 feet east of the SR 57 North onramp facing South 04040014 • 09/2018 | 3e_site_photos.cdr CITY OF ORANGE COMMUNITY DEVELOPMENT BILLBOARD ORDINANCE UPDATE PROJECT INITIAL STUDY/MITIGATED NEGATIVE DECLARATION Figure 3e Retained Billboard Location 5 – East of SR 57, 220 feet east of the SR 57 North onramp THIS PAGE INTENTIONALLY LEFT BLANK xxi Detailed below is information regarding existing billboard/project site characteristics and surrounding land uses: • Billboard 1: An existing double-sided billboard is located on the west side of SR-55, 100 feet south of East Katella Avenue (at 1936 East Katella Avenue; Assessor’s Parcel Number [APN] 372-532-07). This billboard is located on property developed with a restaurant (Shiki). This site is surrounded by commercial uses to the north, a hotel to the west, light industrial to the south, and SR-55 to the east. • Billboard 2: An existing double-sided billboard is located on the west side of SR-55, 1,900 feet north of Meats Avenue (APN 372-642-33). The billboard is located on an otherwise vacant, triangularly-shaped property immediately east of property developed with a single-story Best Buy Electronics store. This site, located along a freeway, is surrounded by commercial uses to the west, multi-family housing to the north, SR-55 to the east, and a mobile home park to the south. . • Billboard 3: An existing double-sided billboard is located on the west side of SR-57, 250 feet south of West Chapman Avenue (APN 232-032-01). This billboard is located on a property developed with a single-story fast food restaurant (Burger King). This site is surrounded by commercial uses to the north, offices to the south, SR-57 to the east, and South Anita Drive to the west. • Billboard 4: An existing double-sided billboard is located on the east side of SR-57, 100 feet south of the Santa Ana River (APNs 386-381-04 and 386-381-05). This billboard is located on a property developed with a single-story building currently being used as a pickup location for a furniture showroom and shipping company. This site is surrounded by the Santa Ana River to the west, SR-57 further to the west, office buildings to the north and south, and light industrial uses to the east. • Billboard 5: An existing double-sided billboard is located on the east side of West Orangewood Avenue, 220 feet east of the SR-57 North onramp (APN 386-401-14). This billboard is located on a property developed with single-story office buildings. This site is surrounded by offices buildings to the north, south, and east, and SR-57 to the west. Billboard Sites Identified for Removal The Billboard Ordinance Update, as proposed, requires the permanent removal of a minimum of five static billboard faces for every two billboard facings proposed for conversion to an electronic format. The location of billboards proposed for removal will be determined in conjunction with each application for a proposed billboard relocation/conversion. In general, existing billboards are surrounded by major arterial roadways, commercial, residential, light industrial, and rail lines. Figures 4a and 4b show the typical daytime views of existing static billboards that could be removed. xxii PROJECT DESCRIPTION Project Background Outfront Media, owner of several billboards throughout the City of Orange, proposed the conversion of an existing traditional billboard located at 1936 East Katella Avenue to a digital light-emitting diode (LED) billboard and the removal of a total of five billboard faces. Two faces for removal are located at 140 North Prospect Street; one face is located at North Orange Olive Road, 250 feet south of Lincoln Avenue; and two faces are located at 2875 North Orange Olive Road. The billboard at 2875 North Orange Olive Road is located on unincorporated (County) lands that could affect viewsheds within the City. The City of Orange Billboard Ordinance, Municipal Code Title 5—Chapter 5.62, Signs and Billboards, does not address new billboard construction or the conversion of existing billboards to a digital format for those billboards seeking to advertise a message not directly related to the property the billboard is located on. Furthermore, the Orange Municipal Code does not have provisions elsewhere that specifically addresses billboards. Thus, the City has decided to update its Billboard Ordinance, as described in more detail in the following section. Billboard Ordinance Update The City is proposing an update to the Billboard Ordinance with the proposed text included as Appendix A. The updated Billboard Ordinance would completely repeal and delete Chapter 5.62 (Signs and Billboards). Specifically, the update would amend Title 17, Chapter 17.36 (Sign Regulations) of the Municipal Code, which would still prohibit the construction of new billboards, but would allow retention of existing billboards and the conversion of the five billboards located within the Freeway Corridor where conversion would “…include the removal of a display and construction of a new display to substitute for the display removed, as defined in California Business and Professional Code Section 5412.”3 The updated Billboard Ordinance would include a provision for a Relocation Agreement that would allow a billboard company to convert an existing traditional billboard to digital in exchange for removing another. As such, conversion of any of the five billboards specified in Table 1 would be contingent on the removal of existing billboard faces. The conversion would be subject to the discretionary approval of a Minor Site Plan Review. Additionally, Section 17.36.180(D)(2) would stipulate that electronic billboards may only be located within the Freeway Corridor (as described above in Retained Billboard Locations) and away from any residentially zoned property. The electronic billboards would be subject to additional stipulations including height, size of sign face, images displayed, and maximum intensity of light as defined in Section 17.36.180, Billboards, as described in more detail below: • An electronic billboard may only be located within the Freeway Corridor; 3 City of Orange. 2018. Ordinance No. 01-18. [Note at the time of writing of this IS/MND, the text within this ordinance has not yet been adopted.] xxiii • Each sign face of an electronic billboard shall be oriented primarily for viewing from the Freeway Corridor and away from any residentially zoned property; • No electronic billboard shall be located on or within 300 feet of any single family residentially zoned property, as measured from the base of the structural support column of the electronic billboard to the nearest property line; • No electronic billboard shall be located within 500 feet of any other billboard located on the same side of the freeway, or within 1,000 feet of any other electronic billboard or on- premises electronic sign located on the same side of the freeway; • The permitted height of an electronic billboard shall be determined through the Minor Site Plan Review process and shall be limited to the maximum height necessary to ensure adequate visibility of the display from the Freeway Corridor; however, in no event shall an electronic billboard exceed 60 feet in height, as measured from finished grade to the top of the billboard structure, or in the case of the conversion of an existing billboard, the height of the existing billboard, whichever is greater; • The area of each electronic billboard sign face, including framing and trim, shall not exceed 680 square feet; • Electronic billboard displays shall contain still or static messages or images only, and no part of the sign structure or image being displayed may move or present the appearance or optical illusion of movement, or include flashing, blinking, or traveling lighting, the varying of light intensity, or any other means of not providing constant illumination. Each static message or image shall be displayed for a minimum of 8 consecutive seconds before changing, and the transition or blank screen time between one display message and the next shall not exceed 1 second; • The maximum intensity of light output produced by an electronic billboard display shall not exceed 0.3 foot-candles above the ambient light level at any time, as measured using a foot- candle meter at a distance of 250 feet, and shall otherwise comply with Section 5403(g) of the Outdoor Advertising Act, and Section 21466.5 of the California Vehicle Code; • Electronic billboard owners and/or operators shall make space available for the display of emergency messaging in accordance with local, regional, and/or State protocols. Relocation Agreement of Billboard Location 1—1936 Katella Avenue Site In November 2017, the City and Outfront Media entered into a tentative Relocation Agreement for the relocation and consolidation of signs that would result in the removal of five sign faces and the upgrade of the existing billboard at 1936 Katella Avenue to LED. This Relocation Agreement did not commit the City to approving the project or to any course of action, and was wholly contingent on the City’s later adoption of the Billboard Ordinance Update. If the ordinance amendments are adopted, this Relocation Agreement would become effective and Outfront would be entitled to apply for remaining approvals to remove various signs and xxiv construct a new sign at the Katella Avenue site, including any necessary building permits, electrical permits, demolition permits, and Minor Site Plan Review. Potential Upgrades to LED Potential upgrades to LED would occur as part of implementation of the Billboard Ordinance Update. All of the five billboard locations identified in Table 1, above, could be upgraded to an electronic billboard with two LED display faces. The billboards could be two sided or V-shaped with north- and south-facing LED displays that are anticipated to continue to be visible to vehicles traveling in both directions on adjacent freeways. The displays on the billboard would be in the same orientation as they are now, which is a flag design structure mounted on a support column. The pole heights of the existing billboards would not change as part of a conversion to LED displays; however, the smaller “face” of an LED display would result in a slightly reduced billboard height overall. As stated in the proposed text “except as otherwise provided in subsection F, the height of the top of the sign face shall not exceed 60 feet, as measured from finished grade,” where subsection F provides that, in the case of conversion, the height of the billboard must be 60 feet or the height of the existing billboard, whichever is greater. The billboard frames would be smaller than they are currently, and the advertising surface area of each billboard face would also be reduced. Table 2 shows the existing static billboard dimensions and the allowed LED billboard dimensions. The billboards would continue to be equipped with upper and lower catwalks that would continue to be accessed via an existing access ladder that is attached to the catwalk deck. Table 2: Billboard Dimensions Billboard Billboard Location Billboard Structure Height (feet) Billboard Frame (feet) Number of Faces Advertising Surface Area Per Face (square feet) 1 West side of SR-55, 100 feet south of East Katella Avenue Static 95 20 x 60 2 1,200 LED 90 14 x 48 2 672 2 West side of SR-55, 1,900 feet north of Meats Avenue Static 70 20 x 60 2 1,200 LED 65 14 x 48 2 672 3 West side of SR-57, 250 feet south of West Chapman Avenue Static 55 20 x 60 2 1,200 LED 50 14 x 48 2 672 4 East side of SR-57, 100 feet south of the Santa Ana River Static 55 20 x 60 2 1,200 LED 50 14 x 48 2 672 5 East side of SR-57, 220 feet east of the SR-57 North onramp Static 70 20 x 60 2 1,200 LED 65 14 x 48 2 672 140 North Prospect Street facing North 140 North Prospect Street facing South 04040014 • 09/2018 | 4a_site_photos.cdr CITY OF ORANGE COMMUNITY DEVELOPMENT BILLBOARD ORDINANCE UPDATE PROJECT INITIAL STUDY/MITIGATED NEGATIVE DECLARATION Figure 4a Typical Daytime View at a Potential Removal Site THIS PAGE INTENTIONALLY LEFT BLANK North Orange-Olive road, 250 South of Lincoln Avenue facing North 04040014 • 09/2018 | 4b_site_photos.cdr CITY OF ORANGE COMMUNITY DEVELOPMENT BILLBOARD ORDINANCE UPDATE PROJECT INITIAL STUDY/MITIGATED NEGATIVE DECLARATION Figure 4b Typical Daytime View at a Potential Removal Site THIS PAGE INTENTIONALLY LEFT BLANK xxix When upgrading a billboard, construction at each location would take approximately five days in total. Construction activities would include removing the existing copy, removing the existing billboard sections4, and removing the metal pieces that attach the sign to the top of the billboard structure, which would take approximately two to three days. After the static billboard is removed, a stinger package5 would be installed, which would take approximately one day. This would be followed by the installation of the LED faces and illumination of the sign, which would take approximately two days of construction. The proposed digital billboards would operate 24 hours per day, 7 days per week. The illuminated double-sided billboard would cycle through a rotation of images on its display and is proposed to operate under specific criteria to limit the potential for driver distraction. These criteria include, (1) images from the billboard would rotate no more than once every 8 seconds, and; (2) light levels emitted from the billboard would adjust to respond to darker and lighter conditions to provide contrast. The maximum ambient light output level of the digital billboard sign faces would be 0.3 foot-candle or less at a distance of 250 feet. Furthermore, the billboards would not show video or motion, nor would they emit noise or audio. The timing of these upgrades has not yet been determined. However, as discussed above in Project Background, Outfront Media has proposed the conversion of an existing traditional billboard located at 1936 East Katella Avenue (Billboard 1; see Figure 5: Retained Billboard 1— 1936 East Katella Avenue Site Plan) to a digital LED billboard and the removal of a total of five billboard faces. It is reasonably foreseeable that the upgrade of Billboard 1 and removal of five billboard faces would move forward soon after the implementation of the updated Billboard Ordinance. Removal Sites As mentioned above, as part of implementation of the Billboard Ordinance Update, billboards throughout the City of Orange could be removed in the future. Though the City does not have jurisdiction over billboards located in adjacent unincorporated (County) lands, billboards located in the County that affect viewsheds within the City could be removed as part of Relocation Agreements associated with the City’s Billboard Ordinance Update. As discussed in Project Background, three specific locations with static billboard faces were identified by Outfront Media for potential removal as part of the proposed upgrade of Billboard 1: 140 North Prospect Street; North Orange Olive Road, 250 feet south of Lincoln Avenue, and 2875 North Orange Olive Road. The billboard at 2875 North Orange Olive Road is located on unincorporated (County) lands that could affect viewsheds within the City. Hand tools and small crane rigs would be used to remove the billboards. The top of the billboards would first be disassembled and removed, and then the poles would be removed to ground level. Only the above-grade portion of the billboard structures would require removal. 4 These sections are comprised of eight metal pieces that would be removed individually. 5 Stringers are steel braces attached to the back of a billboard panel that function to support the display face. xxx Below-surface foundations could remain in place. Materials from the removed billboard could be reused or transported to a recycling facility, or be disposed of at a landfill. It would take approximately one to two working days to remove each of the existing billboard structures. BILLBOARD-SPECIFIC REGULATORY CONTEXT Relevant Lighting Regulations and Standards The California Department of Transportation (Caltrans) Outdoor Advertising Act and Regulations 2014 Edition (Outdoor Advertising Act) addresses illumination generated by advertising displays by stating that displays may not “interfere with the effectiveness of, or obscure any official traffic sign, device, or signal . . . nor shall any advertising display cause beams or rays of light to be directed at the traveled ways if the light is of an intensity or brilliance as to cause glare or to impair the vision of any driver, or to interfere with any driver’s operation of a motor vehicle.” Caltrans regulations prohibit images on signs from changing more than once every four seconds.6 With respect to the brightness of signs, Business and Professions Code Section 5403(g) defines the brightness standard for changeable electronic variable message billboards in relation to Vehicle Code Section 21466.5, which provides: No person shall place or maintain or display, upon or in view of any highway, any light of any color of such brilliance as to impair the vision of drivers upon the highway. A light source shall be considered vision impairing when its brilliance exceeds the values listed below. The brightness reading of an objectionable light source shall be measured with a 1½-degree photoelectric brightness meter placed at the driver’s point of view. The maximum measured brightness of the light source within 10 degrees from the driver’s normal line of sight shall not be more than 1,000 times the minimum measured brightness in the driver’s field of view, except that when the minimum measured brightness in the field of view is 10 foot-lamberts or less, the measured brightness of the light source in foot-lambert shall not exceed 500 plus 100 times the angle, in degrees, between the driver’s line of sight and the light source. Under the Business and Professions Code, the most conservative brightness limit with which the LED billboards would have to comply is 500 foot-lamberts, which is equivalent to 1,713 nits.7,8 6 California Department of Transportation. 2014. Outdoor Advertising Act and Regulations 2014 Edition. California Business Professional Code § 5200–§5486. 7 This calculation assumes a minimum measured brightness in the field of view of less than 10 foot-lamberts, and a view angle of zero degree (i.e., directly in front of the driver). 8 In lighting, the nit is a unit of visible-light intensity, commonly used to specify the brightness of a cathode ray tube or liquid crystal display computer display. One nit is equivalent to one candela per square meter. The candela, is approximately the amount of light emitted by a common tallow candle. I 04040014 • 10/2018 | 5_east_katella_ave_site_plan.cdr Figure 5 Retained Billboard 1 - 1936 East Katella Avenue Site Plan CITY OF ORANGE COMMUNITY DEVELOPMENT BILLBOARD ORDINANCE UPDATE PROJECT INITIAL STUDY/MITIGATED NEGATIVE DECLARATION Source: Leedco Engineers, Inc., September 2018. THIS PAGE INTENTIONALLY LEFT BLANK xxxiii The Outdoor Advertising Association of America (OAAA) recommends more conservative lighting intensity standards for billboards of the proposed size of a maximum ambient light output level of 0.3 foot-candle at a distance of 250 feet from the billboard faces.9,10 These operational parameters (i.e., 0.3 foot-candle at 250 feet) translate into a brightness of about 300 nits, meaning that the signs would always operate at approximately one-sixth of the maximum brightness level for LED billboards, as set forth by the Outdoor Advertising Act, which is a California State Law. The light levels emitted from the billboards would be set to adjust based upon ambient light conditions at any given time (i.e., nighttime versus daytime). The proposed ordinance is equivalent to or more restrictive than Caltrans Outdoor Advertising Act, Business and Professions Code Section 5403(g), and OAAA requirements and recommendations. REQUIRED APPROVALS The following discretionary approvals are required by the City of Orange for approval of the proposed project: • The adoption of the IS/MND; • Adoption of a Zoning Code Text Amendment (ZC No. 1292-18) for the Billboard Ordinance to amend Title 17 of the Orange Municipal Code Subsequent activities would be examined in light of the adopted IS/MND to determine whether additional CEQA documentation would be required pursuant to Section 15162 of the CEQA Guidelines for subsequent approvals by the City of Orange and Caltrans, including, but not limited to the following: • Minor Site Plan Review by City of Orange per the City’s Billboard Ordinance (City Municipal Code Section 17.36.180); • Encroachment Permits (If public right-of-way is used); • Outdoor Advertising Permit/Relocation Agreement approval by Caltrans; and • Ministerial approvals, including, but not limited to, building permits. INTENDED USES OF THIS DOCUMENT This IS/MND has been prepared to determine the level of environmental impacts associated with a Billboard Ordinance that could result in 1) the potential removal of existing billboard faces within the City of Orange and, 2) potential upgrade of up to five existing static billboard signs to LED signs within the City of Orange; and, where a potentially significant impact might occur, to identify appropriate mitigation that would reduce impacts to less than significant levels. This 9 For a frame of reference, 0.3 foot-candle is comparable in brightness to the light emanating from a computer monitor, and the light levels emitted from the LED displays would be set to adjust based upon ambient light conditions at any given time (i.e., nighttime versus daytime). 10 Setting a standard in foot-candles is a more appropriate metric by which to judge impacts on sensitive receptors, as a foot-candle measures light intensity experienced at the receptor, whereas measurement in candela/square meters or nits reveals only the intensity of light at its source. xxxiv document will also serve as a basis for soliciting comments and input from members of the public and public agencies regarding the proposed project. The IS/MND will be circulated for a minimum of 20 days, during which period comments concerning the analysis contained in the IS/MND should be sent to: Ashley Brodkin, Associate Planner City of Orange Community Development Department 300 East Chapman Avenue Orange, CA 92866 Phone: (714) 744-7238 Email: abrodkin@cityoforange.org Scheduled Public Meetings or Hearings The City will hold a Planning Commission Hearing at 7:00 p.m. on December 3, 2018 in the Orange Council Chambers at City Hall, located at 300 East Chapman Avenue, Orange, CA 92866. A notice of a City Council hearing for the proposed project will be distributed in the same manner as this notice once a date is established. The public and interested agencies are invited to attend any of the meetings. THIS PAGE INTENTIONALLY LEFT BLANK 3 EVALUATION OF ENVIRONMENTAL IMPACTS: 1. A brief explanation is required for all answers except “No Impact” answers that are adequately supported by the information sources a lead agency cites in the parentheses following each question. A “No Impact” answer is adequately supported if the referenced information sources show that the impact simply does not apply to projects like the one involved (e.g., the project falls outside a fault rupture zone). A “No Impact” answer should be explained where it is based on project-specific factors as well as general standards (e.g., the project will not expose sensitive receptors to pollutants, based on a project-specific screening analysis). 2. All answers must take account of the whole action involved, including off-site as well as on-site, cumulative as well as project-level, indirect as well as direct, and construction as well as operational impacts. 3. Once the lead agency has determined that a particular physical impact may occur, then the checklist answers must indicate whether the impact is potentially significant, less than significant with mitigation, or less than significant. “Potentially Significant Impact” is appropriate if there is substantial evidence that an effect may be significant. If there are one or more “Potentially Significant Impact” entries when the determination is made, an EIR is required. 4. “Negative Declaration: Less Than Significant With Mitigation Incorporated” applies where the incorporation of mitigation measures has reduced an effect from “Potentially Significant Impact” to a “Less Than Significant Impact.” The lead agency must describe the mitigation measures, and briefly explain how they reduce the effect to a less than significant level (mitigation measures from earlier analyses may be cross-referenced, as discussed below). 5. Earlier analyses may be used where, pursuant to the tiering, program EIR, or other CEQA process, an effect has been adequately analyzed in an earlier EIR or negative declaration. Section 15063 (c)(3)(D). In this case, a brief discussion should identity the following: a. Earlier Analysis Used. Identify and state where they are available for review. b. Impacts Adequately Addressed. Identify which effects from the above checklist were within the scope of and adequately analyzed in an earlier document pursuant to applicable legal standards, and state whether such effects were addressed by mitigation measures based on the earlier analysis. c. Mitigation Measures. For effects that are “Less than Significant with Mitigation Measures Incorporated,” describe the mitigation measures which were incorporated or refined from the earlier document and the extent to which they address site-specific conditions for the project. 6. Lead agencies are encouraged to incorporate into the checklist references to information sources for potential impacts (e.g., general plans and zoning ordinances). Reference to a previously prepared or outside document should, where appropriate, include a reference to the page or pages where the statement is substantiated. 7. Supporting Information Sources: A source list should be attached, and other sources used or individuals contacted should be cited in the discussion. 8. This is only a suggested form, and lead agencies are free to use different formats; however, lead agencies should normally address the questions from this checklist that are relevant to a project’s environmental effects in whatever format is selected. 9. The explanation of each issue should identify: a. the significance criteria or threshold, if any, used to evaluate each question; and b. the mitigation measure identified, if any, to reduce the impact to less than significance. THIS PAGE INTENTIONALLY LEFT BLANK 5 CHECKLIST OF ENVIRONMENTAL IMPACT ISSUES: 1. AESTHETICS. Would the project: Potentially Significant Impact Less than Significant With Mitigation Incorporated Less Than Significant Impact No Impact (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 buildings within a state scenic highway? (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? Environmental Setting The Natural Resources Element of the General Plan (page NR-8) states that portions of the City of Orange are characterized by scenic vistas that include hillsides, ridgelines, or open space areas that provide a unifying visual backdrop to the urban environment. These “viewsheds” contribute to the City’s identity and quality of life. The Natural Resources Element states that the City will preserve open space areas and view corridors where possible and will encourage landscaping in urban areas to improve boulevards, neighborhoods, commercial, and industrial districts. The State of California designates certain segments of State highways as scenic routes. In Orange County, State Route 1 (SR-1), SR-57, SR-74, and SR-91 are eligible State Scenic Highways. However, the only officially designated State Scenic Highway is a segment of SR-91 from SR-55 to east of Anaheim city limits.11 This segment is approximately is 1.13 miles northeast of the nearest billboard location. The analysis in this section is based, in part, on the Photometric Analysis prepared for the City of Hayward in Alameda County for the construction of a LED billboard on Arbor Avenue. That billboard is similar in dimension (80 feet in height with frames measuring 14 feet by 48) to the billboards that could be upgraded as part of the Billboard Ordinance Update, so the analysis in that study is used to evaluate the potential light impacts of this project as described in Impact(c). The Photometric Analysis is provided as Appendix B. Impact Analysis a) Have a substantial adverse effect on a scenic vista? Billboard Locations 1 and 2 are adjacent to SR-55, while Billboard Locations 3, 4, and 5 are adjacent to SR-57. Northbound lanes in the vicinity of these locations provide views towards distant ridgelines to the northeast of the project sites. 11 California Department of Transportation. California Scenic Highway Mapping System. Website: http://www.dot.ca.gov/hq/LandArch/16_ livability/scenic_highways/index.htm. Accessed August 2018. 6 The Ordinance Update would allow for conversion of existing billboards to electronic billboards with two LED displays. The LED displays would maintain the same orientation as the existing static display. The existing heights of the billboard structures range from 55 to 95 feet. In converting the structures to LED display, the pole heights would not change; however, the smaller “face” of the LED display would result in a reduced overall billboard height. The existing billboard frames are 20 feet by 60 feet (height by width), and would be reduced in size to 14 feet by 48 feet (height by width), which represents a 6-foot reduction in height of the facing and a 12-foot reduction in its width. The conversion to LED would result in a reduction in height and width for the converted billboard facings, as well as the associated removal of additional billboards as required by the Ordinance and Relocation Agreement. The overall effect would be an improvement to intermittent views of distant ridgelines provided to travelers along SR-55 or SR-57. Therefore, the impact on scenic vistas would be less than significant. Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: Less Than Significant Impact b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic building within a state scenic highway? SR-55 and SR-57 are in the immediate vicinity of the project sites, but are not designated State Scenic Highways, nor are they eligible to become designated State Scenic Highways. The nearest officially designated State Scenic Highway is a segment of SR-91 from SR-55 to east of Anaheim city limits, located approximately 1.13 miles northeast of Billboard Location 2, the closest upgrade location. As discussed in the Project Description, the LED faces would not exceed an output level of 0.3 foot-candle at a distance of 250 feet from the billboard faces. Because SR-91 is over 1.13 miles from the nearest billboard location (Billboard 2), the nighttime lighting would not be visible from SR-91 and would not degrade nighttime views. Furthermore, Billboard Location 2 is located in an urban setting near several other sources of nighttime lighting including car headlights, parking lot lighting, streetlights, security lighting on buildings, and internal lights in buildings. Therefore, the proposed upgrade would have no impact to scenic resources within a designated State Scenic Highway. Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact 7 c) Substantially degrade the existing visual character or quality of the site and its surroundings? The project sites are located along the SR-55 and SR-57 corridors, with adjacent development consisting of commercial and residential buildings, local roadways, minimal landscaping, roadway signage, and above-ground infrastructure including power lines. The Billboard Ordinance Update would allow conversion of any of the five billboards specified in the Project Description (Table 1) to LED faces. This conversion would be contingent on the removal of existing billboard faces for each conversion of one billboard to LED display. The overall effect would be to reduce the number of billboards in the City of Orange and within the City’s viewshed. Implementation of the Billboard Ordinance Update would change the visual character of the surrounding areas. The existing visual setting of the billboard sites consists of developed areas adjacent to a heavily traveled highway. The upgrade locations are generally surrounded by commercial, residential, light industrial, various roadways, and rail lines. In addition, existing billboards (Billboard Locations 1 and 2) are visible from the elevated neighborhoods on the hillsides to the east. The upgrade from a traditional billboard to an LED digital billboard would not increase obstruction of existing views, as the proposed LED faces would be smaller than the existing static billboards. The nearest sensitive receptors are mobile homes located to the south of Billboard Location 2, approximately 175 feet away. Conversion to an LED face from a static face would not change the visual character of the surrounding area, and would remain consistent with the mixed-use and urban environments surrounding these residences. In addition, the LED face would be in the same orientation as the existing static face, which is oriented toward highway motorists. With respect to brightness, it is not possible to directly compare the light output of existing static billboards to the light output of a LED billboard. It is difficult to quantify the light output of a static billboard (light reflected off vinyl) because there are too many surrounding light sources and the reading would quantify all the light in the vicinity. In comparison, it is possible to adjust the light output for LED lights on digital billboards. Unlike static billboards that reflect surrounding light sources, LED billboards can be programmed to ensure brightness levels are well below applicable standards. The standard that is incorporated into the proposed City ordinance is that signs cannot have a light output that exceeds 0.3 foot candles at 250 feet, which is approximately one-sixth of the maximum brightness level for LED billboards set forth by the Outdoor Advertising Act. The existing billboards (Billboard Locations 1 and 2) that are visible from the elevated neighborhoods on the hillsides to the east would not be significantly more visible after conversion to LED due to the proposed brightness standard in the Billboard Ordinance Update. The messages on the LED billboards would change, but, as described in Impact 1(d) 8 and required by the proposed Ordinance Update, each static message or image would be displayed for a minimum of 8 consecutive seconds before changing, which is more stringent than the recommendations and standards as set forth by California State Law,12 OAAA, and Federal Highway Administration (FHWA). Therefore, the proposed enhancement to LED billboards would not substantially change or degrade the visual character, as the sites would remain surrounded by existing urban development, including other pole mounted highway signs that provide information to travelers and the LED faces would exceed the standards of the Outdoor Advertising Act. The signs designated for removal are located along existing roadways in developed urban environments, with commercial, light industrial, and residential uses located nearby, as discussed in the Project Description. Removing existing billboards would not have an impact to the visual character of the surrounding areas. Therefore, the impact would be less than significant. Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: Less Than Significant Impact d) Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area? The nearest sensitive receptors are mobile homes located to the south of Billboard Location 2, approximately 175 feet away. Like the other upgrade locations, the nighttime light source in this residential area are local street lighting, parking lot lighting, headlights from automobile traffic, streetlights, highway lighting, security lighting on buildings, and internal building lights. As described in the Project Description, the proposed Billboard Ordinance Update stipulates that the maximum intensity of light output produced by an electronic billboard display would not exceed 0.3 foot-candle above the ambient light level at any time, as measured using a foot-candle meter at a distance of 250 feet. Because Billboard Location 2 represents the most conservative scenario as the billboard replacement location with the closes sensitive receptors and greatest potential impacts, the following analysis focuses on this site. To evaluate the effect of night-time lighting on the mobile homes 175 feet to the south of Billboard Location 2 and sensitive receptors at all other upgrade locations, this IS/MND incorporates analysis contained in a lighting study that was conducted for the construction of a billboard with two LED faces in Alameda County, CA13 (Appendix B) because of its similarity to the project. The billboard evaluated in the Alameda County study was 80 feet in height with frames measuring 14 feet by 48 feet (height by width), which is the same as the 12 Business and Professions Code Section 5405(d)(1), 13 The billboard evaluated in the study was proposed at the southwestern end of Arbor Avenue (22083 Arbor Avenue), just north of West A Street, in Alameda County. 9 dimensions stipulated in the proposed Billboard Ordinance update. Specifically, Billboard 2 would be 65 feet in height, with frames measuring 14 feet by 48 feet (height by width). Furthermore, the billboard evaluated in the Alameda County study is the same type of sign with the same brightness level and brightness threshold of significance (0.3 foot-candle above the ambient light level at any time, as measured using a foot-candle meter at a distance of 250 feet) as the proposed billboard upgrades. The billboard evaluated in the Alameda County study and Billboard Location 2 are in similar environments; they are next to a highway with nearby residential uses. The billboard evaluated in the Alameda County study was located within 100 feet from sensitive receptors, whereas Billboard Location 2 is approximately 175 feet from the nearest sensitive receptors. The modeling conducted for the Alameda County billboard demonstrated that the light intensity produced by these billboards, due to their design, height, and configuration, would not exceed 0.3 foot-candle at a distance of 68 feet near the ground and at second-story residential locations. On this basis, the brightness levels of proposed upgrade billboards at nighttime are not anticipated to exceed the threshold established by the Billboard Ordinance Update. Furthermore, as discussed in Impact 1(c), the LED faces would not be significantly brighter than the existing static faces and would not significantly increase ambient nighttime lighting when compared to existing conditions at any of the billboard locations. Therefore, the project would not result in significant light or glare at the nearest residential use. To ensure that the specific upgrade billboard locations in the City of Orange do not have a significant impact on nearby sensitive uses, Mitigation Measure (MM) AES-1 would be imposed to require a site-specific lighting study to confirm that the maximum intensity of light output produced by billboards authorized pursuant to the Billboard Ordinance Update would not exceed 0.3 foot-candle at a distance of 250 feet. In addition, the project would implement MM AES-2, which would ensure that the LED billboard would include an operating mechanism that turns off the display or turns it all black in the event of a malfunction. MM AES-3 requires that the LED signs’ operational parameters be provided to the City for review and approval prior to initial operation. The removal component of the project would reduce the amount of nighttime lighting in the removal locations because the existing lighting used to illuminate the billboards would be removed along with the sign faces, and would have a beneficial impact with respect to light and glare. Analysis of Driver Distraction Driver distraction could occur due to the changing of electronic messages on the proposed LED billboards. Several federal and State regulations apply to the operation of electronic billboards, as discussed below. • California law allows LED billboards to operate at a minimum dwell time of no less than 4 seconds before the display may transition to the next image. This requirement is set forth in Business and Professions Code second 5405(d)(1), which provides, in pertinent part,”. . . 10 no message center display may include any illumination or message change that is in motion or appears to be in motion or that changes in intensity or exposes its message for less than four seconds.” • The Outdoor Advertising Association of America (OAAA) likewise recommends that billboards display a message for no less than 4 seconds.14 • The FHWA, meanwhile, has approved of a similar dwell time standard. According to a FHWA memorandum, the acceptable range for the “[d]uration of each display is generally between 4 and 10 seconds—8 seconds is recommended.”15 The Updated Billboard Ordinance requires that “each static message or image shall be displayed for a minimum of eight (8) consecutive seconds before changing, and the transition or blank screen time between one display message and the next shall not exceed one second.” The Updated Billboard Ordinance would therefore ensure that any billboard converted to LED pursuant to the Ordinance would exceed the relevant State and federal requirements, and would therefore avoid any significant distraction drivers. Significance Determination: Less Than Significant Impact With Mitigation Incorporated Mitigation Measures: MM AES-1 To ensure the lighting of signs does not exceed 0.3 foot-candle at 250 feet, prior to conversion or relocation of any billboard, the City shall require a site-specific lighting study to be submitted as part of the Minor Site Plan Review. Should the results of the study indicate the maximum intensity of light output produced by this billboard would exceed 0.3 foot-candle at a distance of 250 feet, design modifications shall be incorporated into the billboard design to comply with this regulation. MM AES-2 The plans for the LED billboard to be approved by the City as part of the Minor Site Plan Review shall include an operating mechanism (hardware or software controlled) that turns off the display or turns it to all black in the event of a malfunction or failure in any system or subsystem that results in the display wholly or partly appearing to flash. MM AES-3 The signs’ operational lighting parameters shall be provided to the City of Orange Community Development Department for review and approval prior to regular operation of the LED billboard as part of the Minor Site Plan Review, and shall be implemented by the project proponent to ensure no residents or drivers will be adversely affected or impacted by trespass glare lighting. Significance Determination After Mitigation: Less Than Significant Impact 14 California Department of Transportation. 2012. Caltrans Division of Research and Innovation, Effects of Outdoor Advertising Displays on Driver Safety, p.9. October 11. 15 U.S. Dept. of Transportation. 2007. Fed. Highway Admin., Guidance On Off-Premise Changeable Message Signs, p.2. September 25. 11 2. AGRICULTURAL RESOURCES. (In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Department of Conservation as an optional model to use in assessing impacts on agriculture and farmland.) Would the project Potentially Significant Impact Less than Significant With Mitigation Incorporated Less Than Significant Impact No Impact (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 zoning for agricultural use, or 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 Government Code section 51104(g))? (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 conversion of Farmland, to non-agricultural use? Environmental Setting The Farmland Mapping and Monitoring Program (FMMP) produces maps that display farmland in the County. There are no agricultural land or forested areas within or in the vicinity of the project sites. The Department of Conservation Farmland Inventory Map confirms that all project sites are classified as Urban Land.16 Impact Analysis 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? None of the project sites support commercial-scale cultivated agricultural activities. The California Department of Conservation Farmland Mapping and Monitoring Program mapping for Orange County designates the project sites as “Urban and Built-Up Land” on the Orange County Important Farmland 2014 map. Therefore, development of the project would not convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to non- agricultural use. No impact would occur. Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact 16 Department of Conservation. 2014. Orange County Important Farmland. August 10. Website: ftp://ftp.consrv.ca.gov/pub/dlrp/FMMP/pdf/2014/ora14.pdf. 12 b) Conflict with existing zoning for agricultural use, or a Williamson Act contract? The billboards are located throughout the City of Orange and none of them are in agricultural zoning districts. According to the California Department of Conservation’s Agricultural Preserves 2004 map, none of the project sites are not encumbered by a Williamson Act contract.17 Therefore, the project would not conflict with existing agricultural zoning or with a Williamson Act contract. No impact would occur. Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact 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 Government Code section 51104(g))? The billboards are located in non-forest land zoning districts. This condition precludes the possibility of a conflict with a forest zoning designation. No impact would occur. Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact d) Result in the loss of forest land or conversion of forest land to non-forest use? The project sites do not contain nor are adjacent to any forested land. Therefore, there would be no loss of forest land or conversion of forest land to non-forest use as a result of the project. No impacts would occur. Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact e) Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use? The project sites are not adjacent to or in the immediate vicinity of any existing agricultural operations. There is no Prime Farmland, Unique Farmland, Farmland of Statewide Importance, or Forest Land on any of billboard sites. This condition precludes the possibility of conversion of farmland to non-agricultural use, or forest land to non-forest use. Therefore, no impacts would occur. 17 Department of Conservation. 2004. Agricultural Preserves 2004. Website: ftp://ftp.consrv.ca.gov/pub/dlrp/wa/Orange_WA_03_04.pdf. Accessed August 2018. 13 Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact 14 3. AIR QUALITY. (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: Potentially Significant Impact Less than Significant With Mitigation Incorporated Less Than Significant Impact No Impact (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? The project is located in the City of Orange and is within the South Coast Air Basin (SCAB). The San Gabriel, San Bernardino, and San Jacinto Mountains bound the SCAB on the north and east while the Pacific Ocean lies to the west of the SCAB. The southern limit of the SCAB is the San Diego County line. The SCAB 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. The air pollutants for which national and State standards have been promulgated and that are most relevant to air quality planning and regulation include ozone, nitrogen oxides (NOX), carbon monoxide (CO), respirable particulate matter (PM10), and fine particulate matter (PM2.5). Ozone is not directly emitted into the atmosphere but is the result of atmospheric reactions of NOX and volatile organic compounds (VOC) emissions in the presence of sunlight. The analysis in this section is based, in part, on the California Emissions Estimator Model (CalEEMod) analysis completed by FirstCarbon Solutions (FCS). The modeling data is provided in its entirety in Appendix C. Impact Analysis a) Conflict with or obstruct implementation of the applicable air quality plan? The South Coast Air Quality Management District (SCAQMD) 2016 Air Quality Management Plan (AQMP) is designed to accommodate growth, to reduce the high levels of pollutants within the areas under the jurisdiction of SCAQMD, to achieve the federal 8-hour ozone standard by 2024, and to minimize the impact on the economy. Projects that are considered to be consistent with the AQMP do not interfere with attainment and do not contribute to the exceedance of an existing air quality violation because this growth is included in the projections utilized in the formulation of the AQMP. Therefore, projects, 15 uses, and activities that are consistent with the applicable assumptions used in the development of the AQMP would not jeopardize attainment of the air quality levels identified in the AQMP, even if they exceed the SCAQMD recommended thresholds. The project would not construct habitable structures. In addition, it would not generate significant employment, as no additional employees would be required to maintain the signs over the maintenance workers required for the existing signs. Therefore, the project would not change or increase population figures over those that have been planned for the area and would be consistent with the AQMP forecasts for this area. Therefore, the project would be consistent with air quality-related regional plans, and would not jeopardize attainment of state and federal ambient air quality standards in the region. Therefore, impacts would be less than significant. Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: Less Than Significant Impact b) Violate any air quality standard or contribute substantially to an existing or projected air quality violation? The project would generate regional criteria air pollutant and ozone precursor emissions resulting from short-term construction and long-term operational activities. SCAQMD has developed regional thresholds of significance for both construction and operational emissions. These thresholds are considered the allowable emissions limit for each project in order for the region to attain and maintain ambient air quality standards. Therefore, a project that would not generate daily regional emissions that exceed SCAQMD thresholds would also not violate or contribute substantially to an existing or projected air quality violation. Construction of the project would result in the temporary generation of criteria pollutant emissions. Construction emissions were estimated for the activities associated with removal of the existing billboards and the installation of billboards. Hand tools and small crane rigs would be used to remove the billboards. It would take approximately one to two working days to remove each of the existing billboard structures. Air pollutant emissions associated with project construction were estimated using the SCAQMD-approved CalEEMod (Version 2016.3.2) land use emission model. Where project-specific information was not available or unknown, default assumptions were used to complete emissions modeling. Table 3 presents the project’s maximum daily construction emissions for each billboard removal and construction. 16 Table 3: Regional Construction Emissions by Construction Activity Construction Activity Regional Pollutant Emissions (pounds per day) VOC NOX CO SOX PM10 PM2.5 Billboard Removal 0.91 8.17 6.56 0.01 0.60 0.50 Billboard Face Upgrades to LED1 0.46 4.85 2.55 0.005 0.35 0.25 Maximum Daily Emissions 0.91 8.17 6.56 0.01 0.60 0.50 SCAQMD Significance Threshold 75 100 550 150 150 55 Significant Impact? No No No No No No Notes: 1 The billboard face upgrades to LED are assuming 1 crane used for four hours and one haul truck used for six hours. VOC = volatile organic compounds; NOX = oxides of nitrogen; CO = carbon monoxide; SOX =sulfur oxides; PM10 = particulate matter with aerodynamic diameter less than 10 microns; PM2.5 = particulate matter with aerodynamic diameter less than 2.5 microns Source of emissions: CalEEMod Output (Appendix C) Source of thresholds: South Coast Air Quality Management District 2015 As shown in Table 3, billboard upgrade and removal activities would not exceed any of SCAQMD thresholds of significance. Even with overlapping billboard upgrades and removals occurring at different locations at the same time, regional emissions from the project would not exceed the recommended thresholds of significance. Following upgrade and removal activities, long-term operational emissions would be generated, resulting from the day-to-day operations. Billboards require occasional upkeep and maintenance activities, which generate vehicle trips. The long-term operation of the upgraded billboards would include vehicle trips with minimal and irregular maintenance activities, occurring only as needed (less than once per month and likely only one vehicle). Because these upgraded billboards would not require manual change of images like the static billboards require, it is anticipated these trips would be lesser in frequency and duration than the trips necessary to service the existing billboards that would be removed in order to facilitate the relocation (i.e., the five faces removed for every two new digital faces placed). Accordingly, billboard upgrade and removal activities and operational criteria pollutant emissions would not be anticipated to exceed the recommended thresholds of significance. Therefore, the project would not result in any significant increase in criteria pollutants or contribute to an existing air quality violation or exceed SCAQMD threshold. Additionally, the project will be required to comply with all applicable rules to reduce construction impacts. Therefore, impacts would be less than significant. Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: Less Than Significant Impact 17 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? The SCAQMD thresholds of significance represent the allowable amount of emissions each project can generate without generating a cumulatively considerable contribution to regional air quality impacts. Therefore, a project that would not exceed the SCAQMD thresholds of significance on a project level also would not be considered to result in a cumulatively considerable contribution to these regional air quality impacts. As described above, the project is not expected to result in a cumulatively considerable net increase of any criteria pollutant. Therefore, impacts would be less than significant. Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: Less Than Significant Impact d) Expose sensitive receptors to substantial pollutant concentrations? Sensitive receptors are defined as schools, hospitals, resident care facilities, daycare centers, or other facilities that may house individuals with health conditions that would be adversely impacted by changes in air quality. The nearest sensitive receptors are mobile homes located to the south of Billboard Location 2, approximately 175 feet away. Because of the limited amount of construction equipment associated with the upgrades (which would entail replacement of billboard facings) and removals and short duration of associated activities, health risks during upgrade and removal activities would be less than significant. In addition, the project would be required to comply with all applicable SCAQMD rules to reduce impacts associated with upgrade and removal activities. Operation of the project would only require minimal maintenance activities that would not expose sensitive receptors to substantial pollutant concentrations. As such, impacts would be less than significant. Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: Less Than Significant Impact e) Create objectionable odors affecting a substantial number of people? Diesel exhaust and VOCs from these diesel engines would be emitted during upgrade and removal activities, which are objectionable odors to some; however, the duration of these activities is expected to be short (one to two days at each billboard location), emissions would disperse rapidly from the project sites, and diesel exhaust odors would be consistent with existing vehicle odors in the area. The project would not be a source of odor during operations. Considering this information, upgrade and removal activities and operation of 18 the project would not create objectionable odors affecting a substantial number of people; impacts would be less than significant. Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: Less Than Significant Impact 19 4. BIOLOGICAL RESOURCES. Would the project: Potentially Significant Impact Less than Significant With Mitigation Incorporated Less Than Significant Impact No Impact (a) 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? (b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Game or U.S. Fish and Wildlife Service? (c) 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? (d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites? (e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance? (f) Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan? Environmental Setting The project sites are generally located in highly urbanized settings adjacent to State highways or major thoroughfares and within commercially developed properties with impervious surfaces. No natural habitats are present at the project locations other than urban landscaping. The project sites and their surroundings are characterized by parking lots, commercial buildings, multifamily residential buildings, and the adjacent highway. Impact Analysis a) 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? The upgrade locations and the billboard sites identified for removal are located on commercial developments and have no natural or sensitive habitats, including wetlands or riparian habitats. Migrating birds, such as songbirds, can be affected by human-built structures because of their propensity to migrate at night, their low flight altitudes, and their tendency to be disoriented by artificial light, which makes them vulnerable to collision with obstructions that could 20 eventually lead to their injury or mortality. In addition, birds migrating at night can be strongly attracted to sources of artificial light, particularly during periods of inclement weather. According to the Federal Aviation Administration (FAA), static red lights attract birds and can cause them to circle lights repeatedly resulting is exhaustion and death.18 Transparent and reflective glass can reflect or make the nearby environment (such as trees, vegetation, or food source) visible through structures, which could also lead to migrating bird collision. The billboard upgrades to digital LED lights would not create a substantial change in billboard illumination as described above in Impact 1(c). Colors on the billboard would change every 8 seconds and therefore any red lights produced by the LED billboards would not be static and would not likely attract birds. The billboard would not have transparent or reflective surfaces, such as glass or windows that would lead to bird collision. For these reasons, operation of the LED billboards would have a less than significant impact on the movement of migrating birds. Nesting raptors and other migratory birds are protected under the Migratory Bird Treaty Act (MBTA) and California Department of Fish and Wildlife (CDFW) Code Sections 3503, 3503.5, and 2800. As stated above, raptors (such as falcons, hawks, eagles, and owls) and other migratory birds may utilize the existing billboards for foraging or nesting. Construction disturbance near raptor nests can result in the incidental loss of fertile eggs or nestlings, or otherwise lead to nest abandonment and/or loss of reproductive effort, which is considered a taking by the CDFW. MM BIO-1 requires the completion of nesting bird surveys and associated protective measures, when construction is necessary during the nesting season. Implementation of MM BIO-1 would ensure that potential impacts to nesting birds would be minimized to a level that would be less than significant. Significance Determination: Less Than Significant Impact With Mitigation Incorporated Mitigation Measures: MM BIO-1 In the event that billboard removal should occur between September 1 and January 31, the Project Applicant shall retain a qualified biologist to conduct pre- construction surveys for nesting birds to ensure that no nests will be disturbed during project implementation. This survey shall be completed no more than three (3) days prior to the initiation of demolition activities during nesting season. During this survey, the biologist will inspect all billboards and other possible nesting habitats immediately adjacent to the demolition areas for nests. If an active nest is found sufficiently close to work areas to be disturbed by demolition, the biologist, in consultation with the California Department of Fish and Wildlife (CDFW), will determine the extent of a demolition-free buffer zone to be established around the nest, typically 250 feet, to ensure that raptor or migratory bird nests will not be disturbed during project demolition. Prior to the 18 Oliver Milman, environmental reporter for The Guardian. 2016. FAA aims to save millions of birds by changing static red airport lights. March. Website: https://www.theguardian.com/environment/2016/mar/24/airport-lights-birds-faa. Accessed October 4, 2018. 21 commencement of construction activities and the issuance of any permits, the City of Orange Community Development Department shall verify that all project construction plans include specific notes regarding the requirements of the MBTA, that preconstruction surveys have been completed and the results reviewed by staff, and that the appropriate buffers (if needed) are noted on the plans. Significance Determination After Mitigation: Less Than Significant Impact b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Game or U.S. Fish and Wildlife Service? The upgrade locations and the billboard sites identified for removal are located in urban environments and have no natural or sensitive habitats, including wetland riparian habitats. Therefore, no impacts would occur. Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact c) 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? The upgrade locations and the billboard sites identified for removal are located in urban environments and have no natural or sensitive habitats, including wetland or riparian habitat. Therefore, no impacts would occur. Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites? There are no wildlife nurseries on the project sites, nor are there any wildlife movement corridors located on or near the project sites. The location of project activities are in urban environments with no habitat on-site or nearby; therefore, no impacts to migratory wildlife corridors would occur because of project implementation. Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact 22 e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance? Since project activities would not involve the removal of trees, the project would not conflict with any local policies or ordinances protecting biological resources; as such, no impacts would occur. Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact f) Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan? There are a number of Habitat Conservation Plans (HCPs) and two Natural Community Conservation Plans (NCCPs) in Orange County.19,20 However, the project sites are not located in a HCPs or NCCPs. Furthermore, the project sites are within an established urban community. Therefore, the project would not conflict with the provisions of an adopted HCP, NCCP, or another approved local, regional, or state habitat conservation plan. Furthermore, according to the Orange County General Plan, the project sites are not within a designated Open Space/Conservation area.21 As such, there is no impact. Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact 19 2015. Conservation Plans By Species. Website: https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=108719&inline. 20 2017. Summary of Natural Community Conservation Plans (NCCPs). Website: https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=15329&inline. 21 Orange County General Plan. 2005. Resources Element. Website: https://www.ocgov.com/civicax/filebank/blobdload.aspx?blobid=40235. Accessed August 2018. 23 5. CULTURAL RESOURCES. Would the project: Potentially Significant Impact Less than Significant With Mitigation Incorporated Less Than Significant Impact No Impact (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? (d) Disturb any human remains, including those interred outside of dedicated cemeteries? Environmental Setting As discussed in the Project Description, the billboards are all located in urban environments, and no subsurface disturbance would be required for the upgrades or removals. Impact Analysis a) Cause a substantial adverse change in the significance of a historical resource as defined in §15064.5? The Billboard Ordinance Update would allow the faces of existing static billboards located in the City’s Freeway Corridor to be upgraded with LED faces, which would not require any ground disturbance. For the removal sites, only the above-grade portion of the billboard structures would be removed; the removal would not require ground disturbance. The Code of Federal Regulations (CFR), Title 36, sets forth policies related to Parks, Forests, and Public Property. Under 36 CFR 60, a property is recommended for possible inclusion on the National Register if it is at least 50 years old. Because the earliest billboards were built in the 1970s, they are not more than 50 years old and therefore do not constitute historic structures. As such, the project would not introduce new impacts on any existing historic resources. Therefore, no impact would occur. Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to §15064.5? The Billboard Ordinance Update would allow the faces of existing static billboards to be upgraded with LED faces. This conversion would not require ground disturbance. For the removal sites, only the above-grade portion of the billboard structures would be removed; the removal would not require ground disturbance. Because the conversion to LED faces and billboard removal do not involve any ground disturbance, the project would not cause adverse change in the significance of an archaeological resource as defined in Section 15064.5 of the State CEQA Guidelines. Therefore, no impact would occur. 24 Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact c) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature? As discussed in Impacts 5(a) and 5(b), the project does not involve any ground disturbance, and thus would not destroy a unique paleontological resource. Therefore, no impact would occur. Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact d) Disturb any human remains, including those interred outside of dedicated cemeteries? As discussed in Impacts 5(a) and 5(b), the project does not involve any ground disturbance, and thus would not disturb any potential human remains. Therefore, no impact would occur. Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact 25 6. GEOLOGY AND SOILS. Would the project: Potentially Significant Impact Less than Significant With Mitigation Incorporated Less Than Significant Impact No Impact (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 waste water disposal systems where sewers are not available for the disposal of waste water? Environmental Setting The City of Orange is located in the center of Orange County, and according to the 1998 California Geological Survey, it is not located in any earthquake fault zone nor does it border any fault lines.22 According to the more recent City of Orange General Plan Update EIR, the City of Orange is in a seismically active zone surrounded by four large active faults: the Whittier- Elsinore fault, the Newport-Inglewood fault, the San Andreas fault, and the San Jacinto fault.23 Seismic-related ground failure most commonly occurs in areas underlain by loose, unconsolidated soils (e.g., sandy soils) and high groundwater levels. According to the California Department of Conservation, the upgrade locations along the SR-57 are located within a State- designated Liquefaction Hazard Zone.24 These zones are areas where historical occurrence of liquefaction, or local geological, geotechnical, and groundwater conditions indicate a potential for permanent ground displacements such that mitigation as defined in the Public Resources Code Section 2693(c) would be required. As presented in Section 2693, the provisions governing development within a Seismic Hazard Zone are primarily concerned with the structural integrity of existing and future buildings for human occupancy. 22 California Geological Survey. 1998. Earthquake Zones of Required Investigation Orange Quadrangle. Website: http://gmw.conservation.ca.gov/SHP/EZRIM/Maps/ORANGE_EZRIM.pdf. 23 Orange General Plan. 2010. Program Environmental Impact Report. Website: https://www.cityoforange.org/DocumentCenter/View/584/General-Plan-Environmental-Impact-Report-EIR-PDF. 24 California Geographical Survey. 1998. Earthquake Zones of Required Investigation Orange Quadrangle. Website: http://gmw.conservation.ca.gov/SHP/EZRIM/Maps/ORANGE_EZRIM.pdf. Accessed August 2018. 26 Impact Analysis 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. The project sites are not located within the vicinity of any Alquist-Priolo Earthquake Fault Zone. To ensure the project upgrades and removal are conducted safely, construction and design would be undertaken using standard engineering and seismic safety design techniques in accordance with the 2016 California Building Code. As such, the impacts related to potential rupture of a known earthquake fault would be less than significant. ii. Strong seismic ground shaking? The project sites are located within a seismically active region and strong shaking would be expected during the lifetime of the project, which could damage future improvements on the site and expose people to injury. To avoid or minimize potential damage from seismic shaking and liquefaction, the LED upgrades shall be implemented using standard engineering and seismic safety design techniques in accordance with the 2016 California Building Code. The impact would be less than significant. iii. Seismic-related ground failure, including liquefaction? As mentioned above, some the billboard locations are located within State designated liquefaction zones. However, the project would not construct structures intended for human occupancy. Therefore, impacts would be less than significant. iv. Landslides The project sites are relatively flat and already developed with residential and commercial buildings and the probability of landslides occurring during a seismic event is low. Furthermore, the project would not construct structures intended for human occupancy. Therefore, a landslide-related impact would be less than significant. Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: Less Than Significant Impact 27 b) Result in substantial soil erosion or the loss of topsoil? Upgrades from traditional billboard to LED digital billboards and removal of the existing billboards that would occur through implementation of the Billboard Ordinance Update would not consist of any earth-disturbing activities and would not result in soil erosion or loss of topsoil. Therefore, no impact would occur. Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact 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 landsliding, lateral spreading, subsidence, liquefaction, or collapse? As previously addressed, the LED upgrades would be implemented using standard engineering and seismic safety design techniques in accordance with the 2016 California Building Code. As such, the project would be compliant with all applicable State and local requirements. Therefore, the impact associated with unstable geologic unit would be less than significant. Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: Less Than Significant Impact 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? The project would not construct structures intended for human occupancy, which precludes substantial risks to life or property as a result of expansive soils. As such, the project would be compliant with all applicable State and local requirements. Therefore, the impact associated with expansive soils would be less than significant. Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: Less Than Significant Impact e) Have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water? The project does not propose to use septic tanks or alternative wastewater disposal systems. Therefore, no impact would occur. Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact 28 7. GREENHOUSE GAS EMISSIONS. Would the project: Potentially Significant Impact Less than Significant With Mitigation Incorporated Less Than Significant Impact No Impact (a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment? (b) Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases? Impact Analysis a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment? Projects generate greenhouse gas (GHG) emissions during construction and operation (e.g., mobile emissions, emissions from generation of electricity for operations, emissions from the transport of materials). This analysis is restricted to GHGs identified by Assembly Bill (AB) 32, which include carbon dioxide (CO2), methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride. The SCAQMD GHG Working Group recommended interim GHG significance thresholds to review project impacts. 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 also widely accepted by lead agencies in the region and by SCAQMD. According to the City of Orange Local Interim Guidance Memo for Greenhouse Gas Analysis, dated April 26, 2010, the recommended GHG thresholds for residential, commercial, or mixed use development would be 3,000 metric tons (MT) carbon dioxide equivalents (CO2e) per year. During upgrade and removal activities, GHG emissions would be generated by construction activities such as the operation of construction vehicles, material hauling, and construction worker vehicle trips. These emissions would be considered short-term in duration. Construction emissions related to upgrade and removal activities were estimated using CalEEMod (version 2016.3.2). As shown in Appendix C, the analysis shows that GHG emissions were estimated to be 5 MT CO2e for each billboard removal and 1 MT CO2e generated for each billboard upgrade. The exact timing of the upgrades and removals are not known at this time, however, as discussed above in Project Background, Outfront Media has proposed the conversion of an existing traditional billboard located at 1936 East Katella Avenue (Billboard 1) to a digital LED billboard and the removal of a total of five billboard faces. It is reasonably foreseeable that the upgrade of Billboard 1 and removal of five billboard faces would occur soon after the implementation of the updated Billboard Ordinance in 2019. However, the GHG emissions related to upgrade and removal activities is negligible when compared to the 3,000 MT CO2e per year threshold. 29 Operational or long-term GHG emissions occur over the life of the project. Motor vehicle, water, and waste sources of GHG emissions would be negligible during operation. LED digital billboards (programmable electronic signs) are subject to energy efficiency requirements under Title 24 of the California Code of Regulations. The billboard is required to be dimmable, which would reduce energy use and GHG emissions associated with the generation of electricity. The proposed LED digital billboard would be illuminated 24 hours per day, 365 days per year. The light levels emitted from the billboard would be set to adjust based upon ambient light conditions at any given time (i.e., nighttime versus daytime). Each billboard upgraded to LED would be used for a total of 8,760 hours per year, which would require the use of approximately 66 megawatt-hours of electricity annually. Southern California Edison would supply the electrical energy needed to illuminate each billboard. Based on an estimated 66 megawatt-hours of electricity use annually for each billboard, each of the project’s electronic billboards would be expected to generate 21 MT CO2e per year for a total of 105 MT CO2e per year. The project’s expected upgrade and removal activities and operational GHG emissions would not exceed the recommended threshold of 3,000 MT CO2e per year, and, therefore, GHG impacts related to the operation of the project would be less than significant. Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: Less Than Significant Impact b) Conflict with any applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases? The project is subject to State of California, regional, and local plans, policies, and regulations adopted for the purpose of reducing GHG emissions. Projects that are inconsistent or that conflict with the applicable plans would result in a significant project and cumulative impact unless mitigation was available to eliminate the inconsistency or conflict. The California Air Resources Board (CARB) Scoping Plan contains measures designed to reduce the State’s emissions to 1990 levels by the year 2020 to comply with Assembly Bill (AB) 32. The Scoping Plan states, “The 2020 goal was established to be an aggressive, but achievable, mid-term target, and the 2050 GHG emissions reduction goal represents the level scientists believe is necessary to reach levels that would stabilize climate.”25 The Governor signed Senate Bill (SB) 32 in September 2016, giving CARB the statutory responsibility to reduce the GHG emissions to at least 40 percent below the Statewide GHG emissions limit no later than December 31, 2030. The 2017 Climate Change Scoping Plan Update addressing the SB 32 targets was adopted on December 14, 2017. 25 ARB 2008. Initial AB32 Climate Change Scoping Plan Document. Website: https://www.arb.ca.gov/cc/scopingplan/document /scopingplandocument.htm. 30 The City of Orange has not adopted a GHG reduction plan applicable to new development projects. Since no other applicable local or regional Climate Action Plan is in place, the project is assessed for its consistency with the CARB adopted Scoping Plan. The CARB 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. There are several implementation action items related to energy, most of which relate to energy use in commercial or residential buildings. None of the implementation action items would be directly applicable to the upgrade of billboards from traditional faces to LED faces and operation of those LED billboards. As such, the project would not significantly hinder or delay the State’s ability to meet the reduction targets contained in AB 32 and SB 32, or conflict with implementation of the Scoping Plan. As discussed in Impact 7(a), the project would not generate substantial GHG emissions during either construction or operations. For the reasons discussed above, the project would not conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the GHG emissions. As such, impacts would be less than significant. Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: Less Than Significant Impact 31 8. HAZARDS AND HAZARDOUS MATERIALS. Would the project: Potentially Significant Impact Less than Significant With Mitigation Incorporated Less Than Significant Impact No Impact (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 reasonable foreseeable upset and accident conditions involving the 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? (d) Be located on a site which is included on a list of hazardous materials sites complied pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment? (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 in the project area? (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? (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? Environmental Setting The area surrounding the project sites contain residential and commercial land uses as well as transportation corridors. Some of the billboards that could be upgraded or removed as a result of the Billboard Ordinance Update may have been constructed in the 1970s or earlier, and could contain asbestos-containing materials and/or lead-based paint. It is possible that the surrounding land uses utilize some hazardous materials such as cleaning products, and trucks could also transport hazardous materials along SR-55 and SR-57. No known Cortese List (Section 65962.5(a)), sites are located on the project sites. The nearest potential hazardous site to a project site is a gas station adjacent to the Billboard 1 location. The two closest airports to the project site are John Wayne International Airport and Fullerton Municipal Airport. John Wayne International Airport is over 7.5 miles south, and the Fullerton Municipal Airport is over 7.5 miles northwest of the nearest upgrade location (Billboard Location 4). The project sites are not located within the vicinity of a private airport. Finally, the project sites are in urban environments and are not located near wildlands. 32 Impact Analysis a) Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? Upgrades to LED faces and billboard removal may involve the use, transport, and disposal of hazardous materials such as gasoline, diesel fuel, lubricating oil, hydraulic oil, lubricating grease, automatic transmission fluid, paints, solvents, glues, and other substances used during construction. Any handling of hazardous materials would be limited in both quantity and concentrations. Furthermore, all upgrade and removal activities would be required to conform to Title 49 of the Code of Federal Regulations, US Department of Transportation (DOT), State of California, and local laws, ordinances, and procedures. Finally, operation of the project would require sporadic maintenance by a negligible number of workers and trucks, and would not involve the use of any hazardous materials with the potential to significantly impact the public. Therefore, with adherence to applicable State, local, and federal requirements, impacts would be less than significant. Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: Less Than Significant Impact b) Create a significant hazard to the public or the environment through reasonable foreseeable upset and accident conditions involving the release of hazardous materials into the environment? For the billboards that would be removed as part of the project, only the above-grade portion would be removed; the below surface foundations would remain. Disposal of the billboard structures would comply with local and State regulations. Some of the existing billboard structures were constructed in the 1970s and, therefore, could contain asbestos-containing materials and/or lead-based paint. However, the impacts related to asbestos-containing materials and lead-based paint would be less than significant through compliance with local and State regulations and with the implementation of MM HAZ-1, which includes measures to reduce potential impacts to construction workers associated with lead-based paint or other hazardous building materials (e.g., Universal Waste). Significance Determination: Less Than Significant Impact with Mitigation Incorporated Mitigation Measures: MM HAZ-1 The following measures shall be implemented during billboard removal activities: • In conformance with State and local laws, including California Health and Safety Code section 19827.5, a visual inspection and possible sampling shall be completed prior to the removal of the billboard structures to determine the presence of asbestos, lead-based paint, or other hazardous building materials. 33 • If this assessment finds presence of such materials, the project applicant shall create and implement a health and safety plan to ensure workers are not exposed to contaminants in excess of OSHA and other applicable State and federal standards and associated risks associated with hazardous materials during demolition, renovation of affected structures, transport, and disposal. • During billboard removal activities, all materials containing lead-based paint shall be removed in accordance with Cal OSHA Lead in Construction Standard, Title 8, CCR 1532.1, including employee training, employee air monitoring and dust control. • During billboard removal activities, all materials containing asbestos and/or lead- based paint shall be handled and removed by qualified professionals in accordance with applicable regulations, including SCAQMD Regulation XIV, Rule 1403; Title 22, California Code of Regulations, Section 66261.24; Title 8, California Code of Regulations, Section 1532.1. • Any debris or soil containing asbestos lead-based paint or coatings shall be disposed of at landfills that meet acceptance criteria for the waste being disposed. Significance Determination After Mitigation: Less Than Significant Impact c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? The nearest school within a mile of each billboard location is as follows: • California Elementary School is approximately 0.55 mile northeast of Billboard Location 1. • Sycamore Elementary School and Portola Middle School are approximately 0.69 mile southeast and 0.59 mile southeast of Billboard Locations 4 and 5, respectively. • West Orange Elementary is approximately 0.85 mile east of Billboard Location 3. • There are no schools within 1 mile of Billboard Location 2. Therefore, the implementation of the proposed project would not emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within 0.25 mile of an existing or proposed school, and no impact would occur. Demolition activities to remove billboard signs could occur within 0.25 mile of a school. As mentioned in Impact 8(b), existing billboards could contain asbestos-containing materials and/or lead-based paint. Adherence to MM HAZ-1 and all applicable federal, State, and local regulations would mitigate potential impacts to a less than significant level. Significance Determination: Less Than Significant With Mitigation Incorporated Mitigation Measures: Implement MM HAZ-1 Significance Determination After Mitigation: Less Than Significant Impact 34 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? As previously stated, a gas station on the adjacent property north of the Billboard 1 location is an open Leaking Underground Storage Tank (LUST) Cleanup Site. There were four Cleanup Action Reports submitted from 2006 to 2014 that collectively extracted 5,076 pounds of soil vapor from the site. A Path-to-Closure Plan (PTCP) was reviewed on May 8, 2018, and reported that the case should remain open in spite of meeting policy criteria. A previous PTCP revealed Soil Vapor Extraction (SVE) remediation completion in 2017; a subsequent PTCP is projected for September 30, 2018.26 However, the billboard upgrade from the traditional face to digital LED would use the existing billboard structure and would not require ground disturbing activities, which precludes significant hazard to the public or the environment. Removal sites could also be located adjacent to hazardous materials sites. However, only the above-grade portion of the billboard structures would be removed; below- surface foundations would remain in place. Removing billboards would not require ground disturbing activities, which precludes significant hazard to the public or the environment. Therefore, the impact would be less than significant. Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: Less Than Significant Impact 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 in the project area? The two closest airports to the project site are John Wayne International Airport and Fullerton Municipal Airport. John Wayne International Airport is over 7.5 miles south and the Fullerton Municipal Airport is over 7.5 miles northwest of the nearest upgrade location, Billboard Location 4. This condition precludes the possibility of the project resulting in a safety hazard. There would be no impact. Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact 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? There are no private airstrips in the vicinity of the project sites. This precludes the possibility of the project resulting in a safety hazard. Therefore, no impact would occur. 26 State Water Resources Control Board. 2015. GeoTracker. Website: https://geotracker.waterboards.ca.gov/profile_report.asp?global_id=T0605910783. Accessed August 16, 2018. 35 Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact g) Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan? The project does not involve the construction of any new signs. The existing signs do not interfere with traffic access or evacuation during an emergency. Therefore, no impact would occur. Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact 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? The project would not expose people or structures to a significant risk of loss, injury, or death involving wildland fires, because there are no wildlands on or surrounding the project sites. The project sites have extensive history of development. No impact would occur. Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact 36 9. HYDROLOGY AND WATER QUALITY. Would the project: Potentially Significant Impact Less than Significant With Mitigation Incorporated Less Than Significant Impact No Impact (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 the site or area, including through the alteration of the course of a stream or river, in a manner which would result in a substantial erosion or siltation on- or 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? (e) Create or contribute runoff water which would exceed the capacity of existing or planned storm water 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? (k) Potentially impact stormwater runoff from construction activities? (l) Potentially impact stormwater runoff from post-construction activities? (m) Result in a potential for discharge of stormwater pollutants from areas of material storage, vehicle or equipment fueling, vehicle or equipment maintenance (including washing), waste handling, hazardous materials handling or storage, delivery areas, loading docks or other outdoor work areas? (n) Result in the potential for discharge of stormwater to affect the beneficial uses of the receiving waters? (o) Create the potential for significant changes in the flow velocity or volume of stormwater runoff to cause environmental harm? (p) Create significant increases in erosion of the project site or surrounding areas? 37 Environmental Setting Project Area The project area is urban and is covered with impervious surfaces in the form of buildings and paved roadways. The average annual precipitation in Orange County is 12.85 inches per year.27 The only surface body of water that exists in the surrounding project area is the Santa Ana River, which is approximately 100 feet from Billboard Location 4. No surface bodies of water traverse the project sites. Impact Analysis a) Violate any water quality standards or waste discharge requirements? For upgrading the billboards, construction activities would include removing the existing copy, removing the existing billboard sections28, and removing the metal pieces that attach the sign to the top of the billboard. After removing the static billboard faces, a stinger package29 would be installed followed by the installation of the LED faces. For the removal of existing billboards, hand tools and small crane rigs would be used. The top of the billboards would first be disassembled and removed, and then the poles would be removed to ground level. Only the above-grade portion of the billboard structures would require removal. Below-surface foundations could remain in place. No ground disturbance would be required for upgrades of removals. Construction activities could allow surface water to carry small quantities of pollutants (e.g., oil or fuel used in construction equipment) off-site, thereby potentially affecting local waterways by degrading water quality. The National Pollutant Discharge Elimination System (NPDES) requires implementation of Best Management Practices (BMPs). BMPs may include installing sediment barriers such as silt fence and fiber rolls, maintain equipment and vehicles used for construction, tracking controls such as stabilizing entrances to the construction site, and developing and implementing a spill prevention and cleanup plan. The California Stormwater Quality Association’s (CASQA) California Stormwater Best Management Practice Handbook (2003),30 contains standard, effective BMPs. Implementation of BMPs would ensure impacts would be less than significant. The project would include limited construction activities for short durations (i.e. one to two days at each location) at urban sites, and would not substantially affect water quality standards. The impact would be less than significant. Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: Less Than Significant Impact 27 MWDOC. 2014. Annual Rainfall in Orange County, CA. Website: https://www.mwdoc.com/wp-content/uploads/2017/07/Rainfall-1970- 2014.pdf. Accessed August 16, 2018 28 These sections are comprised of eight metal pieces that would be removed individually. 29 Stringers are steel braces attached to the back of a billboard panel that function to support the display face. 30 California Stormwater Quality Association. 2013. Stormwater Best Management Practice Handbook. January. Website: https://www.casqa.org/sites/default/files/BMPHandbooks/BMP_NewDevRedev_Complete.pdf. Accessed October 3, 2018. 38 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? The project would not utilize groundwater sources, and there would be no need to drill wells to supply water for the project. The proposed upgrades and removals would not add to existing impervious surface conditions. Therefore, no impact would occur regarding the depletion of groundwater. Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, in a manner which would result in substantial erosion or siltation on- or off-site? The proposed upgrades would occur using pole structures that already exist and would not require ground disturbance. As such, the proposed upgrades would not alter existing drainage patterns of the site or area, including through the alteration of the course of a stream or river, in a manner which would result in substantial erosion or siltation on- or off-site. Therefore, the impact would be less than significant. The removal sites are located in urbanized areas generally over impervious surfaces. No earth would be disturbed as a result of removal activities and no runoff would occur. In addition, removal of the signs would not require any ground disturbance, and would not affect the amount of impervious surface or the rate of runoff from any of the sites. Therefore, the impact would be less than significant. Significance Determination: Less Than Significant Impact Mitigation Measures: N/A Significance Determination After Mitigation: Less Than Significant Impact 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? The proposed upgrades would occur using pole structures that already exist and would not require ground disturbance. As such the proposed upgrades would not alter existing drainage patterns of the project sites including 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. Therefore, the impact would be less than significant. 39 The removal sites are located in urbanized areas generally over impervious surfaces. In addition, removal of the signs would not require any ground disturbance and would not affect the amount of impervious surface or the rate of runoff from any of the sites. Therefore, the impact would be less than significant. Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: Less Than Significant Impact e) Create or contribute runoff water which would exceed the capacity of existing or planned storm water drainage systems or provide substantial additional sources of polluted runoff? The project would upgrade traditional faces to LED digital faces on existing billboard structures. The upgrades would utilize pole structures that already exist and would not increase the amount of impervious surfaces on the project sites. Therefore, the upgrades would not substantially impact the amount of runoff from the sites. Therefore, the impact would be less than significant. The removal sites are located in urbanized areas, generally over impervious surfaces. No earth would be disturbed as a result of removal activities and no runoff would occur. In addition, removal of the signs would not affect the amount of impervious surface on any of the removal sites and thus would not impact runoff amounts. Therefore, the impact would be less than significant. Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: Less Than Significant Impact f) Otherwise substantially degrade water quality? The project would not change the amount of impervious surfaces compared with current conditions at any of the project locations. Therefore, the project would not substantially degrade water quality, and impacts would be less than significant. Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: Less Than Significant Impact 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? The proposed upgrades and removals do not include the construction or demolition of any housing. This precludes the possibility of housing being placed within a 100-year flood hazard area. Therefore, no impact would occur. 40 Significance Determination: No Impact. Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact h) Place within a 100-year flood hazard area structures which would impede or redirect flood flows? Construction of housing or habitable structures would not occur as part of the project. This precludes the possibility of structures being placed within a 100-year flood hazard area. Therefore, no impact would occur. Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact 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? Construction of housing or habitable structures would not occur as part of the project. This precludes the possibility of exposing 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. Therefore, no impact would occur. Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact j) Inundation by seiche, tsunami, or mudflow? A seiche is a seismically or wind-induced wave on an enclosed body of water such as a lake or reservoir. There are no lakes or reservoirs in the vicinity, so there would be no seiche hazard. Tsunami inundation would not occur because the project sites are over 11 miles from the Pacific Ocean. The project sites are located in a relatively flat area, so mudflows are unlikely to occur. Therefore, no impact would occur. Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact k) Potentially impact stormwater runoff from construction activities? As addressed in Impact 9(a), the NPDES program regulates industrial pollutant discharges, including construction activities. Implementation of the project would require compliance with all the NPDES requirements including the submittal and certification of plans and 41 details showing BMPs that would be implemented as part of project construction. As such, stormwater impacts from construction would be less than significant. Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: Less Than Significant Impact l) Potentially impact stormwater runoff from post-construction activities? The project would not increase the amount of impervious surfaces from current conditions at any of the project locations and would not substantially impact stormwater runoff post- construction. Therefore, the impact would be less than significant. Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: Less Than Significant Impact m) Result in a potential for discharge of stormwater pollutants from areas of material storage, vehicle or equipment fueling, vehicle or equipment maintenance (including washing), waste handling, hazardous materials handling or storage, delivery areas, loading docks or other outdoor work areas? The Billboard Ordinance Update would allow the upgrade of existing traditional billboards to LED billboards and include the removal of existing billboards. The upgrades and removals would not require ground disturbance and would therefore not affect the discharge of stormwater pollutants. As described in Impact 9(a) construction activities could allow surface water to carry small quantities of pollutants (e.g., oil or fuel used in construction equipment) off-site, thereby potentially affecting local waterways by discharging stormwater pollutants. The NPDES requires implementation of BMPs as described in further detail in Impact 9(a). Implementation of BMPs would ensure impacts would be less than significant. Therefore impacts would be less than significant Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: Less Than Significant Impact n) Result in the potential for discharge of stormwater to affect the beneficial uses of the receiving waters? As described in Impact 9(e), the project would not increase the amount of impervious surfaces from current conditions at any of the project locations. As such, the project would not substantially change current conditions of receiving waters. Therefore, the impact would be less than significant. Significance Determination: Less Than Significant Impact 42 Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: Less Than Significant Impact o) Create the potential for significant changes in the flow velocity or volume of stormwater runoff to cause environmental harm? As described in Impact 9(e), the project would not increase the amount of impervious surfaces from current conditions at any of the project locations. As such, the project would not create the potential for significant changes in the flow velocity or volume of stormwater runoff. Therefore, the impact would be less than significant. Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: Less Than Significant Impact p) Create significant increases in erosion of the project site or surrounding areas? As described in Impact 9(e), the project would not require ground disturbance at any of the retained billboard locations or removal sites. Because the project would not increase the amount of impervious surfaces and would not require ground disturbance, it would not create would not increase potential erosion from the project sites. Therefore, the impacts would be less than significant. Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: Less Than Significant Impact 43 10. LAND USE/PLANNING. Would the project: Potentially Significant Impact Less than Significant With Mitigation Incorporated Less Than Significant Impact No Impact (a) Physically divide an established community? (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 community conservation plan? Environmental Setting The project sites are within established urban community that has an extensive history of development. There are a number of HCP and two NCCPs in Orange County.31,32 No HCPs or NCCPs cover any of the project sites. Impact Analysis a) Physically divide an established community? The physical division of an established community typically refers to the construction of a physical feature, such as an interstate highway or railroad tracks, or removal of a means of access, such as a local road or bridge that would impair mobility within an existing community or between a community and outlying area. Conversion of static billboard faces to LED faces and the removal of billboards would not result in the disruption of division of an established community. As such, no impact would occur. Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact 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? The City of Orange Municipal Code (Billboard Ordinance, Municipal Code Title 5—Chapter 5.62, Signs and Billboards) does not currently allow the construction and operation of digital billboards within the City’s jurisdictional boundaries. The City of Orange is currently updating its Municipal Code to allow for digital billboards within City limits and within the designated Freeway Corridor only. If adopted, the updated Billboard Ordinance would 31 2015. Conservation Plans By Species. Website: https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=108719&inline. 32 2017. Summary of Natural Community Conservation Plans (NCCPs). Website: https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=15329&inline. 44 include a provision for Relocation Agreements that would allow a billboard company to convert an existing traditional billboard to digital in exchange for removing other billboards containing at least five billboard faces. Furthermore, the electronic billboards would be subject to additional stipulations including height, size of sign face, images displayed, setbacks for any property zoned single-family residential, and maximum intensity of light as defined in Section 17.36.180, Billboards, as described in the Project Description. In addition, the project would be subject to the Caltrans Outdoor Advertising Act and Section 21466.5 of the California Vehicle Code. The project’s compatibility with these standards is discussed extensively in the Project Description and in Impact 1(d) of this IS/MND where it was determined that the project would be consistent with these policies and regulations. Therefore, impacts would be less than significant. Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: Less Than Significant Impact c) Conflict with any applicable habitat conservation plan or natural community conservation plan? The project sites are not located in a HCPs or NCCPs, which precludes the potential for conflict with the provisions of an adopted HCP or NCCP. Project activities would all take place in an urbanized environment that has largely been built out with other uses. As such, there is no impact. Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact 45 11. MINERAL RESOURCES. Would the project: Potentially Significant Impact Less than Significant With Mitigation Incorporated Less Than Significant Impact No Impact (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 land use plan? Environmental Setting According to the City of Orange General Plan, no known mineral deposits exist at any of the project sites. Impact Analysis 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? The project would not involve subsurface construction or mineral extraction. Therefore, implementation of the proposed upgrades or removals would not result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the State. No impacts would occur. Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact 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 land use plan? The project would not involve subsurface construction or mineral extraction. Therefore, implementation of the proposed upgrades or removals would not result in the loss of availability of locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan. No impacts would occur. Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact 46 12. NOISE. Would the project result in: Potentially Significant Impact Less than Significant With Mitigation Incorporated Less Than Significant Impact No Impact (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? Impact Analysis 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? Construction Noise Impacts Removal of existing billboard structures could involve the use of hand tools, a haul truck, and a crane. Upgrading the traditional billboard to a digital LED billboard would involve similar tools. The removal and upgrade locations are all located in urban areas along busy roadway corridors with associated traffic noise. Noise generated by the proposed construction activities would temporarily elevate noise levels at nearby noise sensitive receptors for a short duration. The loudest piece of heavy equipment that would operate at each site would be a large crane. Typical maximum noise levels generated by a large crane are documented to range up to approximately 85 A-weighted decibel (dBA) Lmax at 50 feet.33 Section 8.24.050 of the City’s Municipal Code states that noise sources associated with construction, repair, remodeling, or grading of any real property are exempt from the provisions of Chapter 8.24, Noise Control chapter of the Municipal Code, provided said activities take place between the hours of 7:00 a.m. and 8:00 p.m. on any day except for 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. Although there could be a relatively high single event noise exposure potential causing an intermittent noise nuisance, the effect on longer-term (hourly or daily) ambient noise levels 33 FHWA 2006. Highway Construction Noise Handbook, August. 47 would be small but could result in excessive noise levels leading to levels of annoyance or sleep disturbances at nearby sensitive receptors. However, compliance with the permissible construction hours established by the City’s Municipal Code would reduce the effects of noise produced by construction activities on longer-term (hourly or daily) ambient noise levels, and would also reduce potential impacts that could result in annoyance or sleep disturbances at nearby sensitive receptors. Implementation of MM NOI-1, which requires implementation of best management noise reduction techniques and practices would ensure that construction noise levels would not expose persons to noise levels in excess of established standards. Therefore, with implementation of MM NOI-1, the potential short-term construction noise impacts on sensitive receptors in the project vicinity would be reduced to a less than significant level. Operational Noise Impacts The proposed LED digital billboards would be located along a freeway corridor, where traffic is the predominate source of noise. The proposed LED digital billboards are not designed to emit any sound, and the project would not generate regular vehicle trips. Therefore, implementation of the project would not expose people to excessive noise levels associated with the introduction of new stationary noise sources or an increase in the number of vehicle trips. No traffic-related noise impacts or stationary operational noise impacts would occur. Significance Determination: Less Than Significant With Mitigation Incorporated Mitigation Measures: MM NOI-1 To reduce potential construction noise impacts, the following multi-part mitigation measure shall be implemented for the project: • The construction contractor shall ensure that all internal combustion engine- driven equipment is equipped with mufflers that 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 prohibit unnecessary idling of internal combustion engines. • The construction contractor shall, to the maximum extent practical, locate on- site equipment staging areas so as to maximize the distance between construction-related noise sources and noise-sensitive receptors nearest the project site during all project construction. Significance Determination After Mitigation: Less Than Significant Impact 48 b) Exposure of persons to or generation of excessive groundborne vibration or groundborne noise levels? The City of Orange has not established a standard for excessive groundborne vibration levels resulting from construction activities. However, the Federal Transit Administration (FTA) has established industry accepted standards for vibration impact criteria and impact assessment in its Transit Noise and Vibration Impact Assessment document (FTA 2006). The FTA guidelines include thresholds for construction vibration impacts for various structural categories. In extreme cases, excessive groundborne vibration has the potential to cause structural damage to buildings. Common sources of groundborne vibration include construction activities such as blasting, pile driving and operating heavy earthmoving equipment. 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. Short-term Construction Vibration Impacts Of the variety of equipment that would be used to upgrade the traditional billboard to a digital LED billboard, cranes would produce the greatest groundborne vibration levels. Cranes produce groundborne vibration levels ranging up to 0.051 inch per second (in/sec) peak particle velocity (PPV) at 25 feet from the operating equipment.34 Impact equipment such as pile drivers would not be used during construction or removal of any of these sites. The closest off-site structures to each of the upgrade billboard locations are located more than 25 feet from proposed construction areas where heavy equipment such as cranes, would operate. At this distance, groundborne vibration levels would range up to 0.051 PPV from the operation of a crane. This is well below the FTA damage threshold criteria of 0.12 in/sec PPV for the most sensitive type of structures: buildings extremely susceptible to vibration damage. Therefore, impacts resulting from construction-related groundborne vibration levels would be less than significant. Operational Vibration Impacts Upon completion of construction, the project would not include any permanent sources of groundborne vibrations. As such, implementation of the project would not expose persons within the project vicinity to excessive groundborne vibration levels. Therefore, project related groundborne vibration impacts would be considered less than significant. Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact 34 FHWA 2006. Highway Construction Noise Handbook, August. 49 c) A substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project? The proposed LED digital billboards are not designed to emit any sound, and the project would not generate regular vehicle trips. Therefore, the project would not result in a substantial permanent increase in ambient noise levels compared with noise levels that would exist without the project. No impact would occur. Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact d) A substantial temporary or periodic increase in ambient noise levels in the project vicinity above levels existing without the project? As discussed in Impact 12(a), the removal and upgrade locations are all located in urban areas along busy roadway corridors with associated traffic noise. Noise generated by proposed construction activities would temporarily elevate noise levels at nearby noise sensitive receptors for a short duration. This noise would result from the temporary use of heavy construction equipment. 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. However, restricting the permissible hours of construction and implementing best management noise reduction techniques and practices, would reduce the effects of noise produced by construction activities on longer-term (hourly or daily) ambient noise levels, and would reduce potential impacts that could result in annoyance or sleep disturbances at nearby sensitive receptors. Therefore, compliance with Chapter 8.24 of the City’s Municipal Code and implementation of MM NOI-1 would reduce impacts from temporary increases in ambient noise levels due to construction activity to less than significant. Significance Determination: Less Than Significant With Mitigation Incorporated Mitigation Measures: Implement MM NOI-1 Significance Determination After Mitigation: Less Than Significant Impact 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? The two closest airports to the project site are John Wayne International Airport and Fullerton Municipal Airport. John Wayne International Airport is over 7.5 miles south, and the Fullerton Municipal Airport is over 7.5 miles northwest of the nearest retained billboard location, Billboard Location 4. In addition, none of the project sites are located within the boundaries of an airport land use plan. Therefore, implementation of the project would not 50 expose people residing or working in the project area to excessive noise levels associated with public airport noise, and no impacts associated with airport noise would occur. Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact 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? None of the project sites are located within 2 miles of a private airport. Therefore, no impacts associated with private airstrip noise would occur. Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact 51 13. POPULATION AND HOUSING Would the project: Potentially Significant Impact Less than Significant With Mitigation Incorporated Less Than Significant Impact No Impact (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? (c) Displace substantial numbers of people, necessitating the construction of replacement housing elsewhere? Environmental Setting According to the California Department of Finance, the City of Orange’s estimated population for 2018 is approximately 141,952 and is expected to grow to 151,400 by 2035.35, 36 Impact Analysis 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)? The project would update the City’s Billboard Ordinance to include a provision for a Relocation Agreement that would allow a billboard company to convert an existing traditional billboard located within the City’s Freeway Corridor to digital in exchange for removing another billboard face. The proposed project does not involve the construction of homes or the extension of infrastructure. Therefore, the project would not induce population growth directly or indirectly. There would be no impact. Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact b) Displace substantial numbers of existing housing, necessitating the construction of replacement housing elsewhere? The proposed project, which would allow for billboard upgrades and removals in the City of Orange, would not displace any existing housing. Therefore, the proposed upgrades and removals would not necessitate the construction of replacement housing. No impact would occur. Significance Determination: No Impact 35 2018. E-1 Cities, Counties, and the State Population Estimates with Annual Percent Change—January 1, 2017 and 2018. August 10. Website: http://www.dof.ca.gov/Forecasting/Demographics/Estimates/E-1/. 36 2018. 2016-2040 RTP/SCS Final Growth Forecast by Jurisdiction. Website: http://www.scag.ca.gov/Documents/2016_2040RTPSCS_FinalGrowthForecastbyJurisdiction.pdf. Accessed August 10. 52 Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact c) Displace substantial numbers of people, necessitating the construction of replacement housing elsewhere? The proposed project, which would allow for billboard upgrades and removals in the City of Orange, would not displace any people. Therefore, the proposed upgrades and removals would not necessitate the construction of replacement housing. No impact would occur. Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact 53 14. PUBLIC SERVICES. Would the project: Potentially Significant Impact Less than Significant With Mitigation Incorporated Less Than Significant Impact No Impact (a) Would the project result in substantial adverse physical impacts associated with the provision of or 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: i) Fire Protection? ii) Police Protection? iii) Schools? iv) Parks? v) Other public facilities? Environmental Setting Fire service for the City is provided by the Orange Fire Department (OFD). Law enforcement services for the City are provided by the Orange Police Department (OPD).37 Impact Analysis: (a) Would the project result in substantial adverse physical impacts associated with the provision of or 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: i) Fire Protection LED billboards present a potential fire hazard due to the thermal energy generated by LED illumination.38 LED lights maintain a relatively low temperature and produce much less heat than traditional bulbs (i.e. compact fluorescent lamp or incandescent bulbs). Furthermore, the upgraded billboard faces would be constructed in conformance with current codes (i.e. California Building Code, California Electrical Code, and the California Fire Code) that would prevent potential fires. The proposed project, which would allow for billboard upgrades and removals in the City of Orange, does not involve the construction of homes or the extension of infrastructure. As such, the project would not increase the population and thus would not result in the need for new or expanded fire protection facilities. No impact would occur. Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: Less Than Significant Impact 37 City of Orange General Plan. 2010. Public Safety. Website: https://www.cityoforange.org/DocumentCenter/View/573/Public-Safety-PDF. August 15, 2018. 38 Underwriters Laboratories. 2009. LED Signs and Luminaries. Website: https://www.ul.com/wp- content/uploads/2014/04/ul_LEDSignsLuminaires1.pdf. Accessed October 3, 2018. 54 ii) Police Protection? The proposed project, which would allow for billboard upgrades and removals in the City of Orange, would not increase the population and thus would not result in an increased demand for police protection. No impact would occur. Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact iii) Schools? The proposed project, which would allow for billboard upgrades and removals in the City of Orange, would not increase the population and thus would not result in an increased demand for school facilities. No impact would occur. Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact iv) Parks? The proposed project, which would allow for billboard upgrades and removals in the City of Orange, would not result in an increase in population or an increase in demand for existing parks and recreational facilities. Therefore, this project would not necessitate the construction of new parks and recreational facilities. No impact would occur. Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact v) Other Public Facilities? The proposed project, which would allow for billboard upgrades and removals in the City of Orange, would not result in an increase in population or an increase in demand for other public facilities. Therefore, this project would not necessitate the construction of new public facilities. No impact would occur. Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact 55 15. RECREATION. Would the project: Potentially Significant Impact Less than Significant With Mitigation Incorporated Less Than Significant Impact No Impact (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? Environmental Setting The billboards are located in urbanized environments that include neighborhood and local parks. Impact Analysis 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? The project, which would allow for billboard upgrades and removals in the City of Orange, would not generate new residents that could increase the demand and use of nearby parks or recreational facilities. Therefore, the project would not result in any physical deterioration of recreational facilities. No impact would occur. Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact 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? The project, which would allow for billboard upgrades and removals in the City of Orange, would not generate new residents that could increase the demand and use of nearby parks or recreational facilities. Therefore, construction or expansion of recreational facilities would not be required. No impact would occur. Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact 56 16. TRANSPORTATION/TRAFFIC. Would the project: Potentially Significant Impact Less than Significant With Mitigation Incorporated Less Than Significant Impact No Impact (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 supporting alternative transportation (e.g., bus turnouts, bicycle racks)? Environmental Setting The project sites are within urban areas that are traversed by several roadways and major highways, including SR-91, SR-55, SR-57, SR-22, and I-5. Impact Analysis 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? Construction-related traffic, including truck and construction worker trips, would be minimal and would not substantially affect traffic conditions during the short duration of project construction required for the upgrades and removal of the existing billboards. The crane used for the upgrades and removals of billboards would be staged on the properties the billboards are situated on and would not occur within the public right-of-way (ROW). Construction related to the upgrades and removals of the billboards would not disrupt traffic because of street closures. Because these upgraded billboards would not require manual change of images like the static billboards require, it is anticipated these maintenance trips would be lesser in frequency and duration than the trips necessary to service the existing billboards. These trips would occur only as needed (less than once per month and likely only one 57 vehicle). Therefore, in aggregate, maintenance trips would likely be less. Therefore, the project would not increase traffic congestion on the surrounding roadways or freeways, or affect level of service standards at nearby intersections. No impact would occur. Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact 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? As described in the Project Description, construction at each upgrade location would involve minimal activities and would last approximately five days in total. Construction activities would include removing the existing copy of the existing billboard, removing the existing billboard sections, and removing the metal pieces that attach the sign to the top of the billboard structure, which would take approximately two to three days. Once the existing static faces of the billboard is removed, a stinger package would be installed which would take approximately one day followed by the installation of the LED faces and illumination of the sign that would take approximately two days. For removal, hand tools and small crane rigs would be used, and it would take approximately one to two working days to remove each of the existing billboard structures. Therefore, construction (associated with the sign face upgrades) and demolition activities (associated with billboard removal) would involve negligible traffic, generated largely during off-peak hours, and is not expected to affect traffic congestion on an individual or cumulative basis. Because the upgraded billboards would not require manual change of images like the static billboards require, it is anticipated these maintenance trips would be lesser in frequency and duration than the trips necessary to service the existing billboards. These trips would occur only as needed (less than once per month and likely only one vehicle). Therefore, in aggregate, maintenance trips would likely be less. These trips occur only as needed (less than once per month and likely only one vehicle). As such, impacts on traffic congestion and other City standards would be less than significant. Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: Less Than Significant Impact 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? The two closest airports to the project site are John Wayne International Airport and Fullerton Municipal Airport. John Wayne International Airport is over 7.5 miles south, and the 58 Fullerton Municipal Airport is over 7.5 miles northwest of the nearest retained billboard location (Billboard Location 4). This condition precludes potential safety hazards to pilots and air traffic controllers. There would be no impact. Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact d) Substantially increase hazards due to a design feature (e. g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? The project does not involve the construction of any new signs; only the replacement of existing signs on existing pole-mounted structures. Therefore, the upgraded billboards would not change roadway design and would not increase hazards due to sharp curves or dangerous intersections. Impact 1(d) addresses the potential for LED upgrades to distract drivers. As discussed in Impact 1(d), California law, OAAA recommendations, and FHWA standards require billboards to have a minimum dwell time of no less than four seconds. The Updated Billboard Ordinance requires a minimum of eight seconds of dwell time. Therefore, implementation of the Billboard Ordinance Update would ensure that any billboard converted to LED pursuant to the Ordinance would exceed the relevant State and federal requirements of minimum dwell time, and would therefore avoid any hazards related to driver distraction. In addition, the implementation of MM AES-2 would turn off the display or turn it black in the event of malfunction or failure. MM AES-3 would require the City of Orange to review and approve the signs operational lighting parameters to ensure compliance with State codes. With compliance with the requirements in the proposed Ordinance and the implementation of MM AES-2 and MM-AES-3, impacts would be less than significant. Significance Determination: Less Than Significant Impact With Mitigation Incorporated Mitigation Measures: MM AES-2 and MM AES-3 Significance Determination After Mitigation: Less Than Significant Impact e) Result in inadequate emergency access? The project does not involve the construction of any new signs; only the replacement of existing signs on existing pole-mounted structures. The existing signs do not interfere with traffic access or evacuation during an emergency, and the replacement signs would not materially change the existing condition in regards to emergency access. The crane used for the upgrades and removals of billboards would be staged on the properties the billboards are situated on and would not occur within public ROW and not disrupt traffic because of street closures. Therefore, impacts are less than significant. Significance Determination: Less Than Significant Impact 59 Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: Less Than Significant Impact 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 supporting alternative transportation (e.g., bus turnouts, bicycle racks)? The project does not involve the construction of any new billboard signs; only the upgrade of existing static billboard signs with LED signs on existing pole-mounted structures. The existing billboards do not interfere with public transit, bicycle, or pedestrian facilities, and the updated billboard faces would not materially change the existing condition in regards to access and use of these facilities. The crane used for the upgrades and removals of billboards would be staged on the properties the billboards are situated on and would not occur within public ROW and would not disrupt access to or use of these facilities. Therefore, the project would not conflict with public transit, bicycle, or pedestrian policies. No impact would occur. Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact 60 17. TRIBAL CULTURAL RESOURCES. 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: Potentially Significant Impact Less than Significant With Mitigation Incorporated Less Than Significant Impact No Impact (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). (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 Resources Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American Tribe. Impact Analysis 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: 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)? The Billboard Ordinance Update would allow the faces of pre-existing static billboards to be replaced with LED faces. This conversion would not require ground disturbance. In addition, for the removal sites, only the above-grade portion of the billboard structures would be removed and billboard removal would not require ground disturbance. As such, the project would not introduce new impacts on any existing tribal cultural resources. Therefore, no impact would occur. Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact 61 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 Resources Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American Tribe. Assembly Bill 52 (AB 52) established a formal consultation process for California Native American tribes to identify potential significant impacts to Tribal Cultural Resources, as defined in Public Resources Code Section 21074, as part of CEQA. As specified in AB 52, lead agencies must provide notice to tribes that are traditionally and culturally affiliated with the geographic area of a project if the tribe has submitted a written request to be notified. The City received a written request for such notification from three tribes who might have knowledge of the religious and/or cultural significance of resources that may be in and near the project sites. On October 9, 2018, the City mailed notices to the Sam Gabriel Band of Mission Indians, the Torrez Martinez Desert Cahuilla Indians, and the Gabrieleño Band of Mission Indians—Kizh Nation, providing a 30-day period in which any of the three tribes could request consultation with the City concerning tribal cultural resouces that may be impacted by the project. One tribe, the Gabrieleño Band of Mission Indians—Kizh Nation, initially requested consultation, but after being informed the project would not involve ground disturbance, rescinded the request for consultation. As of the time of the writing of this document, no other tribes have requested consultation.39 Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact 39 Ashely Brodkin, Associate Planner, City of Orange. Personal communication: email. October 17, 2018. 62 18. UTILITIES/SERVICE SYSTEMS Would the project: Potentially Significant Impact Less than Significant With Mitigation Incorporated Less Than Significant Impact No Impact (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 or collection facilities or expansion of existing facilities, the construction of which could cause significant environmental effects? (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 insufficient permitted capacity to accommodate the project’s solid waste disposal needs? (g) Comply with federal, state, and local statutes and regulations related to solid wastes? (h) Have significant effects on energy resources as described in Appendix F of the State CEQA Guidelines? Environmental Setting The City of Orange provides wastewater services and the City utilizes the Orange County Sanitation District (OCSD) for regional collection and treatment of sewage. The City of Orange provides water service to most of the City and the water used to serve the City’s residents is made up of imported water purchased from the Metropolitan Water District of Orange County (MWDOC) and groundwater. The three landfills in Orange County—Olinda Alpha in Brea, the Frank R. Bowerman Landfill in Irvine, and the Prima Deshecha Landfill in San Juan Capistrano—serve the project area. Orange County Waste and Recycling owns and operates these landfills.40 The project sites may contain water or wastewater infrastructure to support uses on each of the sites. None of the existing billboards generate demand for water supply, wastewater collection, or solid disposal. Impact Analysis a) Exceed wastewater treatment requirements of the applicable Regional Water Quality Control Board? The City of Orange provides wastewater services and the City utilizes the OCSD for regional collection and treatment of sewage within the project area. The project would not construct 40 City of Orange General Plan. 2010. Infrastructure. Website: https://www.cityoforange.org/DocumentCenter/View/568/Infrastructure- PDF. Accessed August 15, 2018. 63 habitable structures. In addition, it would not generate significant employment, as no additional employees would be required to maintain the signs over the maintenance workers required for the existing signs. Therefore, the project would not generate demand for wastewater services, and, no impact would occur. Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact b) Require or result in the construction of new water or wastewater treatment or collection facilities or expansion of existing facilities, the construction of which could cause significant environmental effects? The project would not construct habitable structures. In addition, it would not generate significant employment, as no additional employees would be required to maintain the signs over the maintenance workers required for the existing signs. Therefore, the project would not generate demand for wastewater services, and, no impact would occur. Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact 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? As described in Impact 9(e), the project would not increase the amount of impervious surfaces. Therefore, the project would not increase stormwater runoff from the site and the existing stormwater system would not be impacted. No impact would occur. Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact d) Have sufficient water supplies available to serve the project from existing entitlements and resources, or are new or expanded entitlements needed? The project would not construct habitable structures. In addition, it would not generate significant employment, as no additional employees would be required to maintain the signs over the maintenance workers required for the existing signs. Therefore, the project would not generate demand for water and there would be no impact on water supplies and existing entitlements and resources. Significance Determination: No Impact 64 Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact 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? The project would not construct habitable structures. In addition, it would not generate significant employment, as no additional employees would be required to maintain the signs over the maintenance workers required for the existing signs. Therefore, the project would not generate demand for wastewater services and it would not require the construction of wastewater treatment facilities or new expansion of existing facilities. No impact would occur. Significance Determination: No Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: No Impact f) Be served by a landfill with insufficient permitted capacity to accommodate the project’s solid waste disposal needs? The removal of traditional billboard faces and structures and upgrade of traditional faces would generate some waste materials that would be disposed of at landfills that accept demolition waste from contractors. Assembly Bill (AB) 939, the Integrated Waste Management Act, requires a 50 percent of diversion of solid waste from landfills. Orange County Waste and Recycling requires 65 percent diversion for construction and demolition projects. As stated on Orange County Waste and Recycling website, “applicants can achieve diversion through reuse, recycling, and/or composting of construction and demolition materials at County-approved facilities or use of a County franchised Waste Hauler.”41 This policy is more stringent than AB 939, and, therefore, through compliance with Orange County Waste and Recycling requirements, the project would comply with AB 939. There are three landfills in Orange County that could accept solid waste from the project: Olinda Alpha in Brea, the Frank R. Bowerman Landfill in Irvine, and the Prima Deshecha Landfill in San Juan Capistrano. The landfill capacities are provided in Table 4. 41 Orange County Waste and Recycling. 2018. Construction & Demolition (C&D) Program. Website: http://media.ocgov.com/gov/waste/recycling/cnd_program.asp. Accessed October 5, 2018. 65 Table 4: Orange County Landfill Summary Facility Location Maximum Daily Throughput Cubic Yards Permitted Capacity Remaining Capacity Olinda Alpha Brea 8,000 tons/day 148.8 million cubic yards 34.2 million cubic yards Frank R. Bowerman Irvine 11,500 tons/day 266 million cubic yards 205 million cubic yards Prima Deshecha San Juan Capistrano 4,000 tons/day 172.9 million cubic yards 87.4 million cubic yards Source: Cal Recycle, 2018. The three landfills have a total remaining capacity of approximately 326.6 million cubic yards. Using a conservative estimate, the largest billboard face is 20 feet by 60 feet (height by width) with a depth of 6 feet, and removal of each billboard face would generate approximately 267 cubic yards of solid waste.42 Therefore, each removal and upgrade would generate significantly less than one percent43 of existing landfill capacity. Therefore, impacts would be less than significant. Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: Less Than Significant Impact g) Comply with federal, state, and local statutes and regulations related to solid wastes? Solid waste disposal would follow the requirements of the franchised waste hauler, which must adhere to federal, State, and local statutes and regulations related to the collection of solid waste. The project would comply with all State and local waste diversion requirements. The project would be consistent with policies and actions stated in the City of Orange General Plan Infrastructure Element. As such, impacts would be less than significant. Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: Less Than Significant Impact h) Have significant effects on energy resources as described in Appendix F of the State CEQA Guidelines? Existing energy uses for the static billboards includes lighting used to illuminate the billboards at night. 42 Volume in cubic yards = feet3/27 43 0.000046 percent 66 The project would result in a commitment of additional resources and energy during construction and operation. The upgrade from traditional billboards to LED digital billboards would require the use of nonrenewable construction material, such as concrete, metals, and plastics. Nonrenewable resources and energy would also be consumed during the manufacturing and transportation, and construction of the signs. The scope of construction activities, however, is minimal with removal activities occurring within one to two working days at each existing billboard structure. Large amounts of energy would not be expended, and all construction vehicles would comply with federal and State standards for on- and off- road vehicles (e.g., emission standards set by the California Air Resources Board), meaning wasteful usage of energy would not occur. Construction-related impacts would therefore be less than significant. Energy usage for the existing billboards includes the nighttime lighting used to illuminate the billboards faces at night. Digital billboards are comprised of LEDs, power supplies, cooling systems, lighting controls, and a computer, with LEDs being the largest portion of the energy consumption, particularly during peak demand times when ambient lighting from sunlight is the brightest.44 The annual energy use of a digital billboard can range from 50 to 320 MWh.45 Digital billboards produced in recent years require significantly less energy (between 50 to 70 percent less, in some cases) than those produced several years ago.46 In addition, energy savings can come from the use of high quality LEDs and tighter brightness control settings, resulting in up to 85 percent reduction in power usage. The operational parameters of the project (i.e., 0.3 foot-candle at 250 feet) would mean that the signs would always operate at one-sixth of the maximum brightness level for LED billboards, as set forth by California State Law,47 resulting in efficient energy consumption. Moreover, the LED lighting used in the proposed LED billboards would meet Title 24 requirements for energy efficiency. Electricity would be provided by Southern California Edison, which obtains its energy supplies from power plants and natural gas fields in Southern California, as well as from energy purchased outside its service area and delivered through high voltage transmission lines and pipelines. Power is generated from various sources, including fossil fuel, hydroelectric, nuclear, wind, and geothermal plants; and is fed into the electrical grid system serving Southern California. Southern California Edison is subject to California’s Renewables Portfolio Standard, which was established in 2002 under Senate Bill 1078, accelerated in 2006 under Senate Bill 107, and expanded in 2011 under Senate Bill 2. This program requires investor-owned utilities, electric service providers, and community choice aggregators to increase procurement from eligible renewable energy resources to 33 percent of total procurement by 2020. According to the CPUC, Southern California Edison provided 44 Energy Solutions. 2014. Digital Billboard Energy Use in California. Website: https://www.etcc-ca.com/sites/default/files/reports/et1 4sdg8011_digitalbillboardreport_2014-7.pdf. Accessed July 20, 2018. 45 Young. 2010. Illuminating the Issues Digital Signage and Philadelphia’s Green Future. Website: http://www.scenic.org/storage/ documents/Digital_Signage_Final_Dec_14_2010.pdf. Accessed July 20, 2018. 46 Energy Solutions. 2014. Digital Billboard Energy Use in California. Website: https://www.etcc-ca.com/sites/default/files/reports/et 14sdg8011_digitalbillboardreport_2014-7.pdf. Accessed July 20, 2018. 47 Business and Professions Code Section 5403(g), Vehicle Code Section 21466.5 67 28 percent of its retail electricity from renewable energy resources in 2016.48 As such, the project’s electricity source is expected to be produced and utilized in an efficient manner. Energy, in the form of fossil fuels, would also be used to fuel vehicles traveling to and from the site to repair or maintain the signs. However, as described in Section 16, Transportation/Traffic, vehicle maintenance trips would be irregular (less than one per month), and the operation of the signs would not generate daily trips. Moreover, because billboards would be removed as part of the Billboard Ordinance Update, maintenance trips would be expected to be less frequent than those associated with maintenance of the existing billboards. With respect to lifecycle emissions, although there is no regulatory definition for “lifecycle emissions,” the term is generally used to refer to all emissions associated with the creation and existence of a project, including emissions from the manufacture and transportation of component materials, and even emissions from the manufacture of the machines required to produce those materials. However, since it is impossible to accurately estimate the entire chain of emissions associated with any given project, lifecycle analyses are limited in effectiveness and meaning (relative to assessing or reducing Project-specific emissions for the CEQA analysis). The California Natural Resources Agency has stated that lifecycle analyses are not required under CEQA. The project would not encourage activities that result in the use of large amounts of energy, or use of energy in a wasteful manner. Therefore, operational impacts with regard to use of energy would have a less than significant impact. Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required Significance Determination After Mitigation: Less Than Significant Impact 48 CPUC. 2018. Current Renewable Procurement Status. Website: http://www.cpuc.ca.gov/RPS_Homepage/. Accessed July 20, 2018. 68 19. MANDATORY FINDINGS OF SIGNIFICANCE. Potentially Significant Impact Less than Significant With Mitigation Incorporated Less Than Significant Impact No Impact (a) Does the project have the potential to degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self- sustaining levels, threaten to eliminate a plant or animal community, reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory? (b) Does the project have impacts that are individually limited, but cumulatively considerable? (“Cumulatively considerable” means that the incremental effects of a 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?) (c) Does the project have environmental effects which will cause substantial adverse effects on human beings, either directly or indirectly? Impact Analysis a) Does the project have the potential to degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory? As described in Section 4, Biological Resources, the project would not result in significant environmental impacts to wildlife or plant species. There are no known special-status species on the upgrade or removal sites, though this analysis provides for mitigation in the event that construction activities take place during bird nesting season. As described in Section 5, Cultural Resources, the project does not include ground disturbance, which precludes impacts to cultural resources. Therefore, with implementation of MM BIO-1, the project would not degrade the quality of the environment at a project- or cumulative-level in terms of biological or cultural resources. Significance Determination: Less Than Significant Impact With Mitigation Incorporated Mitigation Measures: MM BIO-1 Significance Determination After Mitigation: Less Than Significant Impact 69 b) Does the project have impacts that are individually limited, but cumulatively considerable? (“Cumulatively considerable” means that the incremental effects of a 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?) Operation of the project would involve the display of messages on electronic billboards near SR-55 and SR-57 corridors. Operation entails no new noise production, minimal maintenance traffic, and negligible GHG emissions. Appendix D contains a list of the City of Orange’s pending land use applicants as of September 27, 2018. Some of the projects listed in the table are within the vicinity of the upgrade locations. The project’s lighting would have the potential to have cumulative impacts in conjunction with the other reasonably foreseeable projects listed in Appendix D within the vicinity of the upgrade locations. The SR-55 and SR-77 corridors are within urban settings with other existing nighttime lighting including car headlights, parking lot lighting, streetlights, security lighting on buildings, and internal lights in buildings. In addition, the existing billboards are illuminated at night, which produces nighttime lighting. The LED faces would operate at a maximum of 0.3 foot-candle at 250 feet in compliance with the Billboard Ordinance Update. Therefore, the LED faces would have one-sixth of the maximum brightness level for LED billboards, as set forth by the Outdoor Advertising Act, which is a California State Law and would result in a nominal increase in the existing lighting footprint. Moreover, the brightness of the LED sign faces would be dimmable to reflect ambient light conditions. Therefore, the nighttime lighting produced by the LED faces in combination with the lighting for other reasonably foreseeably projects would not result in a cumulatively significant impact. With respect to electricity usage, the LED lighting used in the LED faces would meet Title 24 requirements for energy efficiency. While the signs electricity usage is associated with off- site emissions where power is generated, the IS/MND analysis of GHGs demonstrates the project falls well below applicable SCAQMD thresholds, which account for cumulative impacts of climate change. Therefore, because of the project’s size and utilization of energy efficient lighting, it would not make a cumulatively considerable contribution to cumulative GHG emissions or result in an overall impact to local and regional levels of GHG emissions. With respect to construction, the construction activities necessary to upgrade the traditional billboards to digital LED billboards and remove existing billboards requires very little equipment and would occur within one to two days at each billboard location. However, as detailed in this IS/MND, there are potential impacts related to aesthetics, biological resources, hazardous materials, noise, and transportation/traffic. The project would incorporate MM AES-1, MM AES-2, MM AES-3 (implemented for both aesthetics impacts and impacts related to transportation and traffic), MM BIO-1, MM HAZ-1, and MM NOI-1. These mitigation measures ensure not only that the project, individually, would not have a significant impact, but that it would not make a considerable contribution to any cumulative impact. 70 Significance Determination: Less Than Significant Impact With Mitigation Incorporated Mitigation Measures: MM AES-1, MM AES-2, MM AES-3, MM BIO-1, MM HAZ-1, and MM NOI-1 Significance Determination After Mitigation: Less Than Significant Impact c) Does the project have environmental effects which will cause substantial adverse effects on human beings, either directly or indirectly? The City of Orange Municipal Code (Billboard Ordinance, Municipal Code Title 5—Chapter 5.62, Signs and Billboards) does not currently allow the construction and operation of digital billboards within the City’s jurisdictional boundaries. The City of Orange is currently updating the Municipal Code to allow for digital billboards within City limits. If adopted, the updated Code would allow similar upgrades of other billboards from traditional format to digital format. The removal of billboard structures would improve aesthetics/visual quality. The project would include MM AES-1, MM AES-2 and MM AES-3 to minimize light and glare and traffic hazards for vehicle drivers along SR-55 and SR-57. The project also would not make sizable contributions to traffic or substantially change land uses. In addition, the project would not affect public services, utilities, recreation, or population/housing balance. With implementation of MM HAZ-1 as discussed in Section 8, Hazards and Hazardous Materials, the project would also not expose human beings to significant risks related to hazards/hazardous materials. With implementation of MM NOI-1, the project would not contribute to a significant impact with respect to noise. Therefore, with implementation of MM AES-1, MM AES-2, MM AES-3, MM HAZ-1, and MM NOI-1, the project would not cause direct or indirect substantial adverse effects on human beings in terms of aesthetics/light-glare, air quality, geology/soils, traffic/traffic safety, noise, land use, public services, utilities, recreation, population/housing, hydrology, water quality, or hazards/hazardous materials. As such, impacts would be less than significant with mitigation incorporated. Significance Determination: Less Than Significant Impact With Mitigation Incorporated Mitigation Measures: MM AES-1, MM AES-2, MM AES-3, MM HAZ-1, and MM NOI-1 Significance Determination After Mitigation: Less Than Significant Impact 71 20. References 2016–2040 RTP/SCS Final Growth Forecast by Jurisdiction. 2018. Website: http://www.scag.ca.gov/Documents/2016_2040RTPSCS_FinalGrowthForecastbyJurisdict ion.pdf. Accessed August 10. ARB 2008. Initial AB32 Climate Change Scoping Plan Document. Website: https://www.arb.ca.gov/cc/scopingplan/document/scopingplandocument.htm. California Department of Transportation. 2012. Caltrans Division of Research and Innovation, Effects of Outdoor Advertising Displays on Driver Safety, p.9. October 11. California Department of Transportation. 2014. Outdoor Advertising Act and Regulations 2014 Edition. California Business Professional Code § 5200–§5486. California Department of Transportation. California Scenic Highway Mapping System. 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