Update CEQA StatuteAGENDA ITEM
PLANNING COMMISSION
MAY 18, 2020
TO:
THRU:
FROM:
CHAIR AND MEMBERS OF PLANNING COMMISSION
Anna Pehoushek, Assistant Community Development Directorvl.-ri P.
Ashley Brodkin, Associate Planne�
1. SUBJECT
Public Hearing:
2. SUMMARY
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4. AUTHORIZATION GUIDELINES
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7. ANALYSIS AND STATEMENT OF THE ISSUES
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8. PUBLIC NOTICE
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9. ENVIRONMENTAL REVIEW
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11. ATTACHMENTS
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2. P R N 132 0 x :
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a. Draft City Council Ordinance (redline)
b. Draft City Council Ordinance (clean)
3. Planning Commission Resolution No. 14-20 including exhibits:
a. Updated Local CEQA Guidelines including Appendices
4. North Orange County Cities (NOCC) SB 7 43 Implementation Study
5. Draft Traffic Impact Analysis Guidelines
N:\CDD\PLNG\Environmental Review (CEQA Compliance)\Local CEQA Guidelines\2020 Local CEQA Guidelines Update\PC
PC ITEM 7 05/18/2020
RESOLUTION NO. PC 12-20
A RESOLUTION OF THE PLANNING COMMISSION OF
THE CITY OF ORANGE RECOMMENDING THAT THE
CITY COUNCIL OF THE CITY OF ORANGE APPROVE
GENERAL PLAN AMENDMENT NO. 2020-0001
AMENDING THE CITY OF ORANGE GENERAL PLAN
CIRCULATION AND MOBILITY ELEMENT AND
IMPLEMENTATION PLAN TO ESTABLISH
CONSISTENCY WITH THE CALIFORNIA
ENVIRONMENTAL QUALITY ACT STATUTE AND CITY
PRACTICE
APPLICANT: CITY OF ORANGE
Moved by Commissioner ______________ and seconded by Commissioner
________________ that the following resolution be adopted:
WHEREAS, the California Legislature has amended the California Environmental
Quality Act (CEQA) (Public Resources Code Section 21000 et seq.), the California Natural
Resources Agency has amended the State CEQA Guidelines (California Code of Regulations,
Title 14, Section 15000 et seq.), including changing the metric for measuring development-
related transportation impacts to “vehicle miles traveled;” and California courts have provided
additional interpretations of specific provisions of CEQA; and
WHEREAS, the State CEQA Guidelines require local agencies to adopt “objectives,
criteria and procedures” to implement the requirements of the State CEQA Statute and the State
CEQA Guidelines (CEQA Guidelines Section 15022); and
WHEREAS, the current City of Orange General Plan and associated Implementation
Plan identify the metric to measure development-related transportation impacts as Level of
Service (LOS); and
WHEREAS, an amendment to the City of Orange General Plan was deemed necessary to
keep the City’s General Plan consistent with the State CEQA Statute and local practice,
including implementation of Senate Bill 743 with the adoption of a methodology and thresholds
to analyze transportation impacts; and
WHEREAS, the Planning Commission has authority per Orange Municipal Code
Section 17.08.020 to hold a public hearing to make a finding by resolution stating its
recommendation to the City Council on amendments to the General Plan and to make findings
with respect to amendments to the Local CEQA Guidelines.
NOW, THEREFORE, BE IT RESOLVED that the Planning Commission recommends
the City Council adopt the General Plan Amendment contained in Attachment A, attached
hereto, based on the following findings:
SECTION 1- FINDINGS
1. The General Plan Amendment implements the goals of the General Plan Land Use,
Circulation and Mobility, Growth Management and Natural Resources elements to promote
compact “infill” future development, focusing on introducing urban-scale mixed-use
projects located at locations near transportation corridors and transit, and creating additional
retail and employment opportunities within the City that increase the range of goods and
services available to residents and improve the community’s job-housing balance.
2. The General Plan Amendment implements Senate Bill 743 by adopting an updated
methodology and thresholds to analyze transportation impacts under CEQA and to be
consistent with State law.
SECTION 2-ENVIRONMENTAL REVIEW
The General Plan Amendment is categorically exempt from the provisions of the California
Environmental Quality Act per CEQA Guidelines Section 15308 (Class 8 – Class 8, Actions by
Regulatory Agencies for Protection of the Environment) because it involves an amendment to
the City of Orange General Plan to make it consistent with the current provisions and
interpretations of CEQA and the State CEQA Guidelines. It does not involve a specific site,
development project, or focused geographic area, does not change permitted land use or density
and does not otherwise result in a physical change that could cause an impact to the environment.
I hereby certify that the Planning Commission of the City of Orange adopted the foregoing
resolution on May 18th, 2020 by the following vote:
AYES:
NOES:
ABSTAIN:
ABSENT:
David Simpson, Planning Commission Chair
Date
CIRCULATION
& MOBILITY
ORANGE GENERAL PLAN
CM-1
REV. GPA 2014-0001 (12/8/15)
Rev. GPA 2010-0001 (8/10/10)
INTRODUCTION AND VISION FOR THE FUTURE
Orange’s circulation system has been influenced by a variety of historical factors, including
the presence of the Santa Fe Railroad, the vision of Alfred B. Chapman and William T. Glassell,
the agricultural history of the area, and alternative transportation modes including a historic
streetcar system.
In 1887, the Santa Fe Railroad came to Orange and built a station four blocks west of the
Plaza. The coming of the railroad set off a real estate boom that brought hundreds of settlers
to the area. The railroad also influenced the City’s early economic success by providing a
means to transport goods, especially citrus, to the entire country. Today, the railroad tracks
continue to serve freight trains and provide a critical link to the region via the Metrolink
heavy rail transit system.
In the 1870s, Alfred B. Chapman and William T. Glassell subdivided their land into residential
and small farm lots centered on a roundabout known today as Plaza Park. Plaza Park was
dedicated in 1886 and established the City’s two main streets – Chapman Avenue and Glassell
Street – as well as the compact street grid of Old Towne Orange. The street grid and railroad
system were supported historically by a streetcar system that connected the small towns and
settlements that make up the City today.
Over time, the small farms on the outer edges of Orange’s core district began to disappear.
Two factors influenced this change: the demand for housing after World War II and the
appearance of “Quick Decline” disease that destroyed the local citrus industry. As each farm
was developed independently, the grid system expanded outward and commercial corridors
were established. Orange’s roadways began to take on a more suburban pattern of
collectors, connectors, and arterials. As development reached the eastern portion of the City,
the grid gave way to curvilinear street patterns.
The historic roadways and railways that form the basis for the current circulation network
have been complemented over the years by the development of a streetcar system, a transit
service, an emerging and continually expanding bicycle trail and route network, and routes
for equestrian use in the eastern portion of the City. The City will continue to be served by
these multiple modes of transportation and other emerging mobility technologies.
CIRCULATION AND MOBILITY
ORANGE GENERAL PLAN
CM-2
Orange’s Vision for the Future, described in the General Plan Introduction, recognizes that
the circulation system is a key component of the quality of life in the City. Accordingly, the
vision includes the following objectives:
Residential areas will be connected to commercial, recreational, and open space areas, as
well as educational and cultural facilities via a balanced, multi-modal circulation network
that accommodates vehicles, pedestrians, cyclists, hikers, and equestrians. This network
will create additional opportunities for walking and biking, enhancing safety and well-
being for neighborhoods and businesses.
The City will work to define neighborhoods through the use of open space areas and a
trail system that provides a source of aesthetic beauty and recreational opportunities.
These open space areas support a healthy and active community.
We will develop a connected multi-modal network for traveling from one end of town to
the other that provides the option for residents from different neighborhoods to access
parks, open spaces, and scenic areas by vehicle, transit, foot, bicycle or, where
appropriate, horse.
Purpose of the Circulation & Mobility Element
California’s General Plan Guidelines mandate that the Circulation & Mobility Element fulfill
the following objectives:
Show a direct relationship to the Land Use Element to ensure that any changes to land
use as stated by the Land Use Element and growth occur with adequate circulation and
transportation facilities in mind.
Address relevant issues including the adequacy of “major thoroughfares, transportation
routes, terminals, other local public utilities and facilities.” The goal of the Circulation &
Mobility Element is to identify circulation problems related to these facilities in the early
stages and resolve them in local goals and policies without costly delays.
Other relevant issues discussed in the Circulation & Mobility Element include those that
address streets, highways, public transit routes, railroads, bicycle and pedestrian routes,
recreational trails, paratransit, parking, transportation system management, and air
pollution. The hierarchy of streets within the residential areas helps to frame the urban form.
Connections between neighborhoods can be achieved by a comprehensive network of
sidewalks and trails. Also, the commercial corridors can be enhanced with adequate street
capacity, public transit, and pedestrian-friendly environments.
The state also recommends that the Circulation & Mobility Element address coordination
efforts among the local, regional, and state transportation plans to better resolve circulation
issues. Since many transportation concerns are regional, addressing them requires
intergovernmental and regional transportation management plans and policy
implementation. These partnerships ensure the most efficient use of funding, infrastructure,
and other resources. The state also recommends the “preservation of transportation
corridors for future system improvements.”
CIRCULATION AND MOBILITY
ORANGE GENERAL PLAN
CM-3
The Circulation & Mobility Element prioritizes the issues and opportunities that exist within
Orange’s transit network. It is directly responsive to proposed changes in land use and
anticipates the impacts of those changes. This Element also seeks to reassure residents and
businesses that the City recognizes the link between transportation and land uses, and
provides a means to mitigate the impacts of growth.
Another goal of the Circulation & Mobility Element is to increase transportation options and
provide increased access to the circulation system for all residents of Orange. This goal
includes improved rail and bus transit connections and frequency, implementation of a
Bikeway Master Plan, and completion of a trails system. Transforming many of Orange’s
historically auto-oriented commercial corridors, such as Katella Avenue, Main Street, and
portions of La Veta Avenue, Chapman Avenue, and Glassell Street into more pedestrian-
friendly mixed-use environments is an overarching goal. Where possible, the development of
equestrian trails is also encouraged.
One of the main functions of the Circulation & Mobility Element is to guide and direct
enhancement of the current circulation system for existing and future developments. Thus,
circulation provisions correlate with the Land Use Element to avoid unchecked growth and
unnecessary congestion.
Another key objective of the Element is to work toward a future circulation network that
provides meaningful alternatives for getting around the community by less auto-dependent
means. The City’s topography, street and sidewalk system, transit and trail framework, and
land use relationships provide an excellent foundation for pursuit of this objective.
The Circulation & Mobility Element does not simply determine automobile routes. It also
guides the movement of people and goods, directly affecting Orange’s physical, social, and
economic environment. Since circulation permits accessibility to places and social amenities,
it can either improve or cause deterioration in quality of life. Circulation efficiency also plays a
major role in progress and development of the City’s economy.
Scope and Content of the Circulation & Mobility Element
The Circulation & Mobility Element comprises three sections:
(1) Introduction;
(2) Issues, Goals, and Policies; and
(3) The Circulation & Mobility Plan.
The first section introduces the contents of the Circulation & Mobility Element. The second
section presents issues, goals, and policies for improving circulation. The third section
includes the Circulation & Mobility Plan, which designates locations and standards for
roadways and non-motorized circulation facilities, and states the community’s desired level
of transportation service.
Implementation measures designed to promote achievement of the goals and policies are
provided in an Appendix to the General Plan.
CIRCULATION AND MOBILITY
ORANGE GENERAL PLAN
CM-4
Relationship to other General Plan Elements
California planning law requires that the Circulation & Mobility Element correlate and
maintain consistency with the other General Plan elements. The Circulation & Mobility
Element relates most closely to the Land Use, Natural Resources, Noise, Economic
Development, Housing, and Urban Design Elements.
The Circulation & Mobility Element is linked to the Land Use Element because the General
Plan land use designations identified in the Land Use Element serve as a basis for the
allocation of vehicle trips and establishment of capacity levels for circulation planning. The
Land Use Element also provides land use designations that accommodate mixed commercial
and residential development, which encourage shorter trips and improve the efficiency of
the transportation network. The Circulation & Mobility Plan is established to define and
provide for adequate levels of service and facilities to support future land uses. This Element
recommends roadway and intersection improvements that may require land acquisition.
Location of public transportation facilities will also influence pedestrian activity and transit -
oriented development, and the physical size of streets will affect urban land uses and the
physical appearance of the City.
The Natural Resources Element identifies regional air quality objectives and provides
appropriate mitigation efforts that affect the Circulation & Mobility Element. Improving
access, encouraging alternative modes of travel, and maintaining air quality and conservation
standards are common objectives of the Natural Resources and the Circulation & Mobility
Elements.
The Noise Element addresses future noise levels associated with roadways, rail, and other
transportation facilities. Future volumes of traffic on the circulation system are directly
related to future noise levels and mitigation strategies.
The Economic Development Element identifies desirable economic conditions and land uses
that enhance and promote business activity, employment growth, and economic stability.
The goals and policies of the Circulation & Mobility Element will determine road capacity in
Orange, which will impact the type and location of uses, and parking and access
considerations associated with future uses. Both elements share a common objective of
planning for future transportation infrastructure needs. Maintaining roadways, bikeways and
bus and rail transit facilities is critical to the success of both current and future businesses in
Orange.
The Urban Design Element is a framework for shaping the future form and character of
Orange. The quality of Orange’s physical environment contributes to its identity, attracts
new residents, and sets the stage for economic activity. The Urban Design Element builds on
the foundation of Orange’s already strong sense of place to preserve and strengthen the
streetscape environment of commercial corridors and landmarks within the city. The Urban
Design Element and Circulation & Mobility Element share a common objective to reinvent
City streets as more functional and walkable public places.
CIRCULATION AND MOBILITY
ORANGE GENERAL PLAN
CM-5
ISSUES, GOALS, AND POLICIES
The goals, policies, and implementation programs of the Circulation & Mobility Element seek
to achieve a better balance between vehicular, pedestrian, and bicycle travel, and to provide
a wide range of viable transportation options to Orange residents. The following six issues
are addressed: (1) enhancing the local circulation system; (2) maintaining the regional
circulation system; (3) maintaining a viable public transportation network; (4) creating a
comprehensive system of sidewalks, trails, and bikeways; (5) providing adequate parking
facilities; and (6) improving circulation system aesthetics and safety.
Local Circulation System
The local roadway system serves the community’s primary needs for mobility and access, and
consists of a hierarchy of City streets to meet those needs. The City’s original street system
was established as a grid pattern long before a Master Plan of Arterial Highways (MPAH) was
adopted. The Old Towne area and many postwar neighborhoods were designed in a classic
grid configuration, while in newer parts of the City, physical features such as the Santa Ana
River, Santiago Creek, hilly terrain, freeways and the presence of the City of Villa Park have
resulted in a system without a definitive pattern. Some major roads do not connect the
eastern and western portions of the City and consequently do not provide effective through
circulation. A well-designed roadway system will provide convenient access to activities in
Orange.
GOAL 1.0: Provide a safe, efficient, and comprehensive circulation system that serves
local needs, meets forecasted demands, and sustains quality of life in
neighborhoods.
Policy 1.1: Plan, build, and maintain an integrated, hierarchical, and multi-modal system
of roadways, pedestrian walkways, and bicycle paths throughout the City.
Policy 1.2: Identify key intersections and streets with historical or projected traffic
congestion problems and apply creative traffic management measures to
improve overall circulation.
Policy 1.3: Consider various methods to increase safety on City arterials and
neighborhood streets, including landscaping, provision of bike/transit lanes,
and consideration of traffic calming on neighborhood streets in accordance
with the City’s Neighborhood Residential Traffic Management Program.
Policy 1.4: Prohibit on-street parking where possible to reduce bicycle/automobile
conflicts in appropriate target areas as recommended by the Bikeways Master
Plan.
Policy 1.5: Address possible safety and noise effects of increased rail activity on grade
crossings throughout the City.
Policy 1.6: Maintain and repair roadways and sidewalks as necessary to improve
circulation and safety.
Policy 1.7: Consolidate driveways along roadways that provide access to commercial
uses to minimize side street interruption and promote smooth traffic flows.
CIRCULATION AND MOBILITY
ORANGE GENERAL PLAN
CM-6
On-street parking is prohibited on commercial access streets to provide
adequate curb-to-curb width for travel lanes.
Regional Circulation System
Mobility in Orange is directly related to the regional transportation network, as the City lies
at the confluence of several regional freeways: the Santa Ana Freeway (Interstate 5), Orange
Freeway (State Route [SR] 57), Garden Grove Freeway (SR-22), Costa Mesa Freeway (SR-55),
Riverside Freeway (SR-91) and Eastern Transportation Corridor (SR-241). In addition to the
freeways, other connections to the region include the commuter rail system known as
Metrolink, a freight and goods rail transport system, and a regional bikeways system with
connections to the Santa Ana River and other locations. Orange is also connected to the
region via the Orange County Transportation Authority (OCTA) bus system. City
infrastructure must accommodate regional through traffic originating in other communities
in addition to providing local residents access to the regional network.
GOAL 2.0: Provide an effective regional transportation network.
Policy 2.1: Ensure consistency with the County MPAH in order to qualify for funding
programs.
Policy 2.2: Coordinate with adjacent cities to plan and develop major east/west and
north/south arterials and rapid transit to connect the City with the cities of
Anaheim, Tustin, Santa Ana, Garden Grove, and Villa Park, as well as
developing areas within the City’s sphere of influence.
Policy 2.3: Cooperate with and support local and regional agencies’ efforts to improve
regional arterials and transit in order to address increasing traffic congestion.
Policy 2.4: Coordinate land use planning with anticipated future development of
roadways and other transportation facility improvements as well as the
expansion of commuter rail and bus service.
Policy 2.5: Ensure that transportation facilities and improvements do not degrade the
quality of Orange’s commercial and residential areas.
Policy 2.6: Encourage the use of regional rail, transit, bicycling, carpools , and vanpools
for work trips to relieve traffic congestion.
Policy 2.7: Continue to support the use of rail corridors within the City for the movement
of freight and goods, and work with rail operators to minimize associated
traffic delays.
Public Transportation
Public transportation is a crucial component of a comprehensive circulation system. In
addition to reducing air pollution and traffic congestion, a successful public transit system
provides an alternative mode of travel for those with limited mobility, residents who may not
have access to a car, and persons who choose not to drive.
GOAL 3.0: Connect centers within the City to each other and to the region through
efficient and accessible public transportation.
CIRCULATION AND MOBILITY
ORANGE GENERAL PLAN
CM-7
Policy 3.1: Work with OCTA and other agencies to assess City public transportation
needs and to ensure delivery of services when and where they are needed.
Policy 3.2: Enhance and encourage provision of convenient and attractive transit
amenities and streetscapes to encourage use of public transportation (e.g.,
benches, trash cans, shelters, and lighting).
Policy 3.3: Require incorporation of transit-oriented design features within major
commercial and employment areas as well as in medium density residential
and mixed-use development areas.
Sidewalks, Trails, and Bikeways
In addition to offering recreational and public health benefits, non-vehicular modes of
transportation offer commuting options. Also, the mixed-use environments advocated by
Land Use Element policies will encourage increased pedestrian activity on City sidewalks for
both business and pleasure. An effective pedestrian, bicycle, and equestrian network must
be safe and accessible, and must connect key activity centers within the City with each other
and with the regional trail system. A comprehensive network of on-street bicycle lanes, off-
street bicycle paths, sidewalks, and trails should be developed and maintained to increase
the safety and utility of the system, with a particular focus on the City’s sidewalk deficient
industrial areas
GOAL 4.0: Provide efficient and accessible modes of pedestrian, bicycle, and
equestrian transportation and improved facilities and amenities.
Policy 4.1: Create a comprehensive bicycle network that is integrated with other
transportation systems by establishing complementary on-street and off-
street facilities as identified in the City of Orange Bikeways Master Plan and
OCTA Commuter Bikeways Strategic Plan, including Santiago Creek, the Santa
Ana River, and the Tustin Branch Trail.
Policy 4.2: Install racks and safe storage facilities at parking areas for City facilities, as
appropriate, and encourage incorporation of such facilities within privately-
developed projects.
Policy 4.3: Improve citywide awareness of automobile and bicycle safety.
Policy 4.4: Encourage use of the bikeway system by providing adequate signage, trail
markings, and other amenities.
Policy 4.5: Ensure that pedestrian sidewalks, trails, and bikeways are safe environments
through the use of crime prevention-oriented trail design features, lighting
where appropriate, pedestrian and bicycle safety improvements at at-grade
rail crossings, access for emergency vehicles, and links to the roadway signal
system.
Policy 4.6: Explore opportunities to convert abandoned rail corridors into segments of
the City’s bikeway and pedestrian trail system.
Policy 4.7: Provide ADA accessible sidewalks and pedestrian amenities throughout the
City.
CIRCULATION AND MOBILITY
ORANGE GENERAL PLAN
CM-8
Policy 4.8: Expand and maintain an equestrian trail network and provide for appropriate
staging areas and infrastructure.
Parking Facilities
A shortage of parking can cause circulation problems and could lead to a reduction or loss of
business activity. Old Towne Orange has been identified as an area of particular concern. As
the City develops, providing adequate parking adjacent to other activity centers is
increasingly important.
GOAL 5.0: Provide adequate parking to meet the needs of activity centers throughout
the City.
Policy 5.1: Provide adequate parking to protect and support the economic vitality and
diversity of Old Towne.
Policy 5.2: Plan for and design parking facilities throughout the City that are adequate to
meet demand, but also consider land use-parking efficiencies, and the
surrounding natural and built environment.
Policy 5.3: Encourage adjacent businesses to consolidate parking facilities and access
points.
Policy 5.4: Encourage well-designed structured parking in commercial areas where such
features would be economically feasible, safe, and visually integrated with
existing development.
Circulation System Aesthetics
Streets that have been made or modified to include visual and pedestrian amenities can
improve the overall look and feel of City streets, as well as enhancing functionality for all
users. As major commercial corridors are beautified and changed to include a pleasant
pedestrian environment, this will have positive effects on the feelings of safety and security
for pedestrians, bicyclists, and motorists.
GOAL 6.0: Provide roadway corridors that are aesthetically pleasing and contribute to
a feeling of safety, security, and comfort for motorists, bicyclists, and
pedestrians.
Policy 6.1: Supply adequate, clear, and correctly placed signage to direct both motorists
and non-motorists toward destinations and away from hazards.
Policy 6.2: Provide clear indicators in the right-of-way for where pedestrians and
bicyclists are encouraged to walk, bike, or cross safely. These may include
special paving, line stripes, and crosswalks.
Policy 6.3: Provide lighting, landscaping, street trees, and other appropriately scaled
streetscape features that accommodate all users on commercial corridors.
Where appropriate, lighting should be scaled for autos as well as pedestrians.
CIRCULATION AND MOBILITY
ORANGE GENERAL PLAN
CM-9
CIRCULATION & MOBILITY PLAN
The objective of the Circulation & Mobility Plan is to document existing transportation
facilities in the planning area used for the movement of people and goods. The Element
addresses the desired future condition of these facilities, and their relationship to future land
uses identified in the Land Use Element. The Plan describes the circulation system, including
the arterial network and intersections, the public transit system, bicycle paths, recreation
facilities, parking, and railroad operations. The City’s circulation network includes an
extensive system of roadways, bus transit service, commuter rail, and freight rail.
Local Circulation System
A well-designed local arterial roadway system that connects to a well-developed regional
circulation system provides safe and convenient access to employment, housing, recreation,
and commercial areas in Orange. City arterial roadways located on the western side of SR-55
generally follow north-south and east-west orientations. On the eastern side of the freeway,
arterials are characterized by curvilinear streets due to undulating geographical
surroundings. Key north-south arterials include Tustin Street, Glassell Street, Main Street, and
The City Drive. Key east-west arterials include Chapman Avenue, Katella Avenue, Taft
Avenue, and parts of La Veta Avenue. These arterial roadways are in turn supported by a
network of collector and local streets that provide access to homes and businesses
throughout the City.
Roadway Classification System
The City’s roadway network is distinguished by a hierarchical classification system that
differentiates roads by size, function, and approximate daily capacity based upon Level of
Service D (LOS D). LOS is a qualitative measure that characterizes traffic congestion on a
scale of A to F with LOS A representing a free-flow condition and LOS F representing extreme
congestion. LOS standards can apply to either intersections or links (a section of street
between two intersections). Generally speaking, LOS represents the ability of a roadway or
an intersection to accommodate traffic.
In the City, intersections are used as actual control points. City roadways consist of both
divided and undivided roadways. Divided roadways generally contain a physical barrier or
buffer, such as a raised median or a continuous two-way left turn lane, between each
direction of travel. Divided roadways remove vehicles making a left turn from the travel lanes
so as not to impede through traffic and constrict roadway capacity. Undivided roadways do
not contain a buffer between each direction of travel, and therefore left-turning traffic can
impede through traffic. Undivided roadways may provide turn movement pockets at
intersections. The six categories of roadways in Orange are summarized in Table CM-1.
Proposed cross-sections for each type of roadway are shown in Figure CM-1.
The City’s policy is to use a link capacity standard of LOS D. The following paragraphs
represent link capacities of each roadway type at LOS D.
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Smart Streets are typically four- to eight-lane roadways with enhanced capacity and
smoother traffic flow than standard arterial streets. These streets have enhanced features
such as traffic signal synchronization, bus bays, intersection improvements, and the addition
of travel lanes by removing on-street parking and consolidating driveways. The traffic
carrying capacities of Smart Streets can range from 60,000 to 79,000 vehicles per day,
depending on the number of lanes, degree of access control, peak period loading, and the
configurations of major intersections.
Principal Arterials are typically eight-lane divided roadways with medians or continuous two-
way left turn lanes. They can accommodate up to 67,500 vehicles on an average weekday at
LOS D conditions, depending on the degree of access control, peak period traffic loadings,
and lane configurations at major intersections. Principal arterials prohibit on-street, curbside
parking, and connect directly to freeways.
Major Arterials are six-lane divided roadways with medians or continuous two-way left turn
lanes. They can accommodate up to 50,700 vehicles on an average weekday at LOS D
conditions, depending on the degree of access control, peak period traffic loadings, and lane
configurations at major intersections. Major arterials facilitate traffic circulation within
Orange, and also prohibit on-street, curbside parking.
Primary Arterials are four-lane divided roadways with medians or continuous two-way left turn
lanes. They can accommodate up to 33,750 vehicles on an average weekday at LOS D
conditions, depending on the degree of access control and peak period loadings. Primary
Arterials provide for easy circulation in the City, and allow for limited on-street, curbside
parking.
Secondary Arterials are four-lane undivided roadways without medians. They can
accommodate up to 21,600 vehicles on an average weekday at LOS D conditions, depending
on the degree of access control and peak period loadings. Secondary arterials allow for on-
street, curbside parking.
Table CM-1
Roadway Classifications
Classification Facility Type Characteristics
Smart Street Smart Street 4-8 lane divided, with possible signal coordination, intersection capacity
improvements and/or grade separations
Principal Arterial 8 Lane Divided Primarily serves through traffic with limited local access
Major Arterial 6 Lane Divided Serves mostly through traffic with some local access allowed
Primary Arterial 4 Lane Divided Serves through and local traffic
Secondary Arterial 4 Lane Undivided Serves through and local traffic
Collector Street 2 Lane Serves mostly local traffic
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Figure CM-1
Roadway Cross Sections
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Collector Streets are typically two-lane roadways without medians that gather and distribute
traffic to higher-capacity arterials. They can accommodate up to 10,800 vehicles per average
weekday at LOS D conditions, depending on the degree of access control and peak period
traffic loadings. Centerline striping is typically not provided on collector streets, and on-street
parking is allowed. There are several types of two-lane streets in the City, including divided,
undivided, residential, and collector streets. Each type serves a slightly different purpose and
may have different capacity thresholds based on various factors.
Performance Criteria
Evaluating the ability of the circulation system to serve residents and businesses in Orange
requires establishing performance criteria. Performance criteria have a policy component
that establishes a desired LOS, and a technical component that specifies how traffic forecast
data can be used to measure criteria achievement.
The LOS definition for intersections is based on a volume-to-capacity (V/C) ratio and provides
a more quantitative description of traffic conditions. Table CM-2 presents LOS based on
traffic volumes and the design capacity of intersections.
Table CM-2
Level of Service Definitions for Intersections
Level of
Service
Volume-to-Capacity
Ratio Description
A 0.00-0.60 Free Flow/Insignificant Delays: No approach phase is fully utilized by traffic and
no vehicle waits longer than one red indication.
B 0.61-0.70 Stable Operation/Minimal Delays: An occasional approach phase is fully
utilized. Many drivers feel somewhat restricted within platoons of vehicles.
C 0.71-0.80 Stable Operation/Acceptable Delays: Major approach phases fully utilized.
Most drivers feel somewhat restricted.
D 0.81-0.90 Approaching Unstable/Tolerable Delays: Drivers may have to wait through
more than one red signal indication. Queues may develop but dissipate rapidly,
without excessive delays.
E 0.91-1.00 Unstable Operation/Significant Delays: Volumes at or near capacity. Vehicles
may wait through several signal cycles. Long queues form upstream from
intersection.
F N/A Forced Flow/Excessive Delays: Represents jammed conditions. Intersection
operates below capacity with low volumes. Queues may block upstream
intersections.
Source: Highway Capacity Manual, Transportation Research Board, Special Report No. 209, Washington DC, 2000.
Although roadway capacity is generally a function of peak hour intersection performance
and the corresponding peak hour volumes, daily arterial segment capacities (link capacities)
also provide a measure of the overall LOS of the arterial system. Generally, traffic impact
mitigation focuses on peak hour intersection performance, since system performance is
typically a function of intersection performance. The City’s policy is to use a link capacity
standard of LOS D. Table CM-3 presents arterial daily capacities at LOS D and LOS E.
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CM-13
Table CM-3
Arterial Daily Capacity Threshold Assumptions
Street Type
Daily Capacity
LOS D LOS E
Smart Street – 6- to 8-lane divided 71,100 79,000
Principal – 8-lane divided 67,500 75,000
Major – 6-lane divided 50,700 56,300
Primary – 4-lane divided 33,750 37,500
Secondary – 4- lane undivided 21,600 24,000
Collector – 2-lane undivided 10,800 12,000
Source: City of Orange General Plan Update Traffic Report, 2008.
Various LOS policy standards have been established to evaluate observed traffic conditions,
future development plans, and circulation system modifications. At the local level, the City of
Orange has established LOS D as the lowest acceptable level of service for both roadway
segments and peak-hour signalized intersection movements. At the regional planning level,
Orange County’s Congestion Management Plan (CMP) specifies LOS E as the operating
standard for roadways and intersections on the CMP highway system. The CMP Highway
System consists of the Orange County smart street network plus the state highway system.
Thus, the SR-55 northbound and southbound ramps at Katella Avenue are CMP intersections
within the City’s jurisdiction. The City does not have an adopted LOS standard for
unsignalized intersections. Performance of unsignalized intersections is evaluated on a case-
by-case basis.
The City has also established additional thresholds for project impacts that go beyond
acceptable operational LOS to address direct project impacts to roadway capacity. In
addition to the LOS standards for roadways and intersections, In accordance with the
California Environmental Quality Act (CEQA) Guidelines (Section 15064.3), require “vehicle
miles traveled” (VMT), is the most appropriate to measure of transportation impacts on the
community. VMT refers to the amount and distance of automobile travel attributable to a
project.
For purposes of compliance with CEQA, a significant impact would occur if the baseline
and/or cumulative project-generated VMT per service population (population plus
employment) exceeds the anticipated City of Orange General Plan Buildout VMT per service
population. One vehicle traveling one mile would generate one VMT. Additionally, the
project’s effect on VMT would be considered significant if it resulted in the baseline and/or
cumulative link-level boundary citywide VMT per service population increases under the plus
project condition compared to the no project condition. Link-level boundary VMT is
calculated by summing all weekday VMT on a roadway network within the City boundary and
includes all trips including trips that pass through the City’s roadway network but do not
start and end with in City.
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CM-14
These thresholds are designed to reduce the number of miles traveled by automobiles, and
are implemented within the City of Orange Traffic Impact Analysis Guidelines.
For purposes of compliance with the California Environmental Quality Act (CEQA), projects
that increase V/C by .01 or more on affected roadway segments at intersections already
experiencing or projected to experience LOS E or F conditions, are considered to create
significant impacts, and mitigation is required. This requirement is designed to reduce the
occurrence of both roadway congestion and underfunded improvements, and is
implemented within the City of Orange Traffic Impact Analysis Guidelines.
In order to maximize the efficiency of its circulation system, the City will look at where
physical improvements to the circulation infrastructure can be made to expand capacity and
increase traffic flow. To maximize efficiency of the road system, the City will support traffic
signal coordination and spacing, and will also discourage on-street parking along arterials. In
addition, the City will explore ways to reduce the demand for vehicular transportation,
specifically through the provision and maintenance of bike lanes, bikeways, and trails, and
will also encourage additional regional transit services and support facilities. The City’s
Transportation Demand Management (TDM) ordinance (Chapter 10.83 of the Municipal
Code) further specifies a variety of techniques available to employers with 100 or more
employees to advance the goals of efficiently utilizing the existing and planned
transportation system and reducing vehicle emissions.
City Master Plan of Streets and Highways
Land Use Element policy will allow land use changes and intensification to occur in specific
focus areas within the City. The City’s Master Plan of Streets and Highways displayed in
Figure CM-2 has been developed in close coordination with land use policy to ensure that
traffic generated by new development will not compromise the City’s goal to ensure that
intersections and roadway segments operate efficiently. The map identifies components of
the City’s roadway circulation system. The map also indicates where augmented roads are
needed, and pinpoints locations for enhanced intersections, including the future Meats
Avenue interchange at SR-55. Although most of Orange is already built out, most remaining
developable land is located in the eastern part of the City. New development in east Orange
will require construction of new roads to provide circulation and traffic flow to residents and
businesses. Land Use Element policies enabling reuse and redevelopment within established
portions of the City, particularly within the focus areas, may also necessitate roadway
widening and intersection enhancements. The City will continue to collect funds for
necessary circulation system capital improvements through a program that sets up a fee
structure for all new development and redevelopment projects. This program will require
developers to pay their fair share for transportation system improvements required by new
projects. The City will use the annual seven-year Capital Improvement Program (CIP) process
to prioritize, fund, and complete improvements required to achieve build-out of the
proposed roadway system identified in Figure CM-2.
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CM-15
Roadway Widening
Roadway widening in specific locations will be necessary to obtain new travel lanes.
Additional travel lanes may be acquired
either by obtaining additional rights-of-
way as necessary or by constructing
new lanes within existing rights-of-way.
Parking restrictions may be applied to
allow additional lanes to be provided
within existing rights-of-way.
Old Towne Street Network
The Old Towne street network is a clear
example of Orange’s grid street pattern.
Parallel roadways have been established
in both the north-south and east-west
direction to distribute traffic evenly. The
Plaza area at Glassell Street and Chapman Avenue is a unique feature that creates
discontinuous traffic flows along these two primary roadways. However, no plans have been
made to modify the National Register-listed Historic Plaza to increase its traffic carrying
capacity.
CM-15
Figure CM-2 City Master Plan of Streets and Highways
GPA 2014-0001 (12/8/15)
GPA 2010-0001 (8/10/10)
CM-16
(This Page Left Intentionally Blank)
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CM-17
In light of these conditions, parallel roadways such as Almond Avenue, Palmyra Avenue,
Lemon Street, Olive Street, Shaffer Street, Grand Street, Palm Avenue, and Maple Street will
continue to serve as local collectors around The Plaza.
Metropolitan Drive Extension
Extending Metropolitan Drive behind the University of California, Irvine (UCI) Medical Center
will help facilitate the movement of north-south traffic near The Block at Orange shopping
area, improve access to Interstate 5 (I-5), and relieve congestion on The City Drive.
Metropolitan Drive will be extended from The City Drive/State College Boulevard to the
Metropolitan Drive/Rampart Street connection.
Critical Intersection Program
Intersections serve as traffic control points for the circulation system, regulating the flow of
vehicles along City streets and sometimes limiting the capacity of the system. In the long
term, system capacity and efficiency can both be increased if intersections are designed to
handle future anticipated traffic volumes. Typically, the design of the roadways forming an
intersection dictates the intersection configuration. Department of Public Works standards
indicate that a left-turn pocket may or may not be provided, depending on traffic volumes
through the intersection. However, one pocket may not be adequate to handle vehicles
during peak hours. Traffic may back up into a through travel lane, resulting in congestion at
the intersection and at other locations along the roadway.
One way of providing additional intersection capacity at critical locations is through the use
of special intersection configurations known as “critical intersections.” Critical intersections
deviate from typical City design standards by increasing the number of lanes at an
intersection beyond what typically would be required. By increasing capacity at the
intersection, the circulation link increases overall system capacity.
The Master Plan of Streets and Highways (Figure CM-2) identifies the locations of critical
intersections within Orange. A list of these intersections and diagrams depicting their
geometries are on file in the Public Works Department.
Regional Roadway System
The City’s local circulation network is connected to an efficient regional circulation system.
Figure CM-2 shows the freeways that traverse the Orange planning area. The Santa Ana
Freeway (I-5) provides interstate and regional access to the City. In addition, SR-57, SR-55,
and SR-22 all provide connections to the City from northern Orange County and neighboring
Los Angeles County, San Diego County, Riverside County, and San Bernardino County. SR-91
and SR-241 provide additional, more limited freeway access. SR-241 is a toll facility controlled
by the Transportation Corridor Agency (TCA).
I-5 is a northwest-southeast freeway that passes through the southwest corner of the City,
and provides direct access to Los Angeles County to the north and San Diego County to the
south. I-5 has two interchanges within Orange—one located at its junction with SR-57 and
SR-22 (commonly known as the Orange Crush) and the other at State College Boulevard/The
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ORANGE GENERAL PLAN
CM-18
City Drive. The junction at the Orange Crush currently has the most severe congestion, which
directly affects the roadway system in the City. With projected future growth in Orange and
in the region, traffic flow at this junction is expected to worsen. The City will continue to
work with and support the efforts of local and regional agencies to mitigate the increased
traffic congestion in this area.
SR-91 is an east-west freeway that provides access to key arterial facilities in Orange,
including interchanges at Tustin Street and Glassell Street. SR-91 also provides regional
access through interchanges with SR-55 and SR-57 and SR-241.
SR-22 is an east-west freeway that crosses through the southern portion of the City. Five SR-
22 interchanges are located in the City, at Tustin Street, Glassell Street, Main Street/La Veta
Avenue, Bristol Street, and The City Drive.
SR-55 is a north-south freeway that passes through the center of Orange, and provides
access to the coastal communities of Orange County. SR-55 has four interchanges in Orange,
located at Lincoln Avenue, Katella Avenue, Chapman Avenue, and SR-22. An additional future
interchange at Meats Avenue is contemplated within this General Plan.
SR-57 is a north-south freeway that originates at the junction of I-5 and SR-22 and extends to
San Dimas in Los Angeles County. It provides access for the eastern parts of Los Angeles
County, and central and northern parts of Orange County. SR-57 has three interchanges in
Orange, at Chapman Avenue, Orangewood Avenue, and the junctions of I-5 and SR-22.
The Eastern Transportation Corridor (SR-241) is a north-south toll facility located in the
eastern portion of the planning area. This facility provides direct access to east Orange. SR-
241 has three toll lanes in each direction and provides regional access through an interchange
at Santiago Canyon Road.
Consistency with County Master Plan of Arterial Highways
Maintaining consistency with the County’s Master Plan of Arterial Highways (MPAH) is
required in order to ensure that the City’s circulation system develops in a manner that
promotes regional mobility. At a practical level, consistency is also required in order for the
City to receive transportation funding under Measure M. Orange’s Master Plan of Streets and
Highways (Figure CM-2) is generally consistent with the MPAH.
While the City’s Master Plan of Streets and Highways has been consistent with the County
MPAH to maintain funding eligibility, both the City of Orange and OCTA have the goal of a
realistic and implementable MPAH. In keeping with this spirit, in 2010 as a follow up to
adoption of this General Plan, the City worked with OCTA on amendments to the MPAH and
Master Plan of Streets and Highways that downgraded the long-standing classification of
Chapman Avenue and Glassell Street from 4-lane Primary Arterials to 2-lane Collector Streets,
and removed the Critical Intersection classification of the Plaza. A remaining desire of the
City is to work with OCTA to downgrade La Veta Avenue between Glassell Street and
Cambridge Street from a Secondary Arterial to a Collector Street to reflect physical
constraints related to historic buildings and features in the Old Towne National Register
Historic District.
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To initiate the MPAH amendment process, a local agency must submit a written request to
OCTA describing the amendment requested and provide documentation to support the basis
for the request. A copy of the request must be submitted concurrently to the City Managers
of adjoining cities. For the facilities under consideration, this would require a letter to be
forwarded to the City of Santa Ana.
Once the initial request is forwarded to OCTA, a conference between the City of Orange,
OCTA, and potential affected jurisdictions is held to determine whether mutual agreement
exists for the MPAH amendment. If mutual agreement exists, then Orange is expected to
proceed with adopting this revision to the Circulation & Mobility Element. Upon adoption,
the City of Orange would submit the Circulation & Mobility Element to OCTA and request
OCTA Board approval of the Orange County MPAH amendment.
Public Transportation
Effective regional transportation strategies are required to successfully implement City and
County plans for accommodating future growth. Such strategies must link the City of Orange
with other regional employment and commercial centers, as well as airports and other
transportation hubs, and should fully integrate alternatives to the automobile. Alternative
modes of transportation, including public transportation, bicycling, and walking, are
important components of a comprehensive circulation system. These modes of
transportation also help reduce air pollution and road congestion.
Public transportation plays a key role in future land use development and mobility. As the
roadway system reaches capacity, alternative modes of transportation provide additional
capacity as well as an enhanced degree of mobility for residents, workers , and visitors.
Existing services are expected to continue while enhancements, many of them currently in
the planning stages, will increase the viability of alternative modes of travel. The integration
into the circulation system of alternative modes of transportation, such as bus, rail, bicycle,
and pedestrian, is essential to maximizing mobility opportunities for residents, workers, and
visitors.
Bus Service
OCTA provides public bus service for the City of Orange. In addition, the Riverside Transit
Agency (RTA) provides long-distance service between The Village at Orange and the
Downtown Terminal in Riverside. Table CM-4 identifies local bus routes that connect various
activity centers in Orange to each other and to the region.
Table CM-5 shows the different community, station link, and inter- or intra-County routes that
serve Orange. Community routes are express bus routes that provide faster connections to
activity centers within and outside Orange County. Station link shuttles provide services
between the Orange Transportation Center (OTC) and Orange. Both community and station
link routes operate only at peak commuter times.
In addition to the fixed-route service, OCTA also offers several types of specialized
community transportation services, such as standard service (curb-to-curb service), door-to-
door service, subscription service, and same-day taxi service. Some of these services cater to
senior citizens and people with disabilities residing in the City.
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OCTA has forecast bus ridership to increase by approximately 75 percent by 2030. Some of
this ridership increase will be the result of enhanced services, including express bus routes
and introduction of bus rapid transit service. Much of the increase will be driven by increased
arterial and freeway congestion levels in conjunction with improved local bus service. OCTA
is planning to introduce bus rapid transit (BRT) services by 2011 on the Bristol Street-State
College Boulevard, Harbor Boulevard, and Westminster Avenue corridors. This service would
include planned BRT stops in Orange on State College Boulevard south of Orangewood
Avenue and on The City Drive south of Chapman Avenue. With the projected success of this
service, which is comparable to the Los Angeles Metro Rapid service, it is likely that BRT will
be implemented on other key corridors. Corridors that have been considered for potential
future application include Katella Avenue.
Convenient, accessible, frequent, and easy-to-use public transit is a cornerstone element of
the proposed land use plan. Planned mixed-use residential and commercial areas and
intensified commercial and professional office corridors must be coupled with increases in
transit service. Orange’s land use plan features mixed-use districts that strategically
concentrate population density near alternative transit facilities, such as the OTC in Old
Towne, transit hubs at The Block at Orange and South Main Street, and the future Anaheim
Regional Transportation Intermodal Center station in Anaheim near the City’s western
boundary at Katella Avenue.
Table CM-4
Local Bus Routes
Route # Route Type Route Service Service Corridors Key Orange Activity Centers Served
24 Local Fullerton–Orange Malvern Ave. / The Village at Orange
Chapman Ave. / Lincoln Park and Ride
Tustin St..
42 Local Orange–Seal Beach Lincoln Ave. / The Village at Orange
Los Alamitos Blvd. / Lincoln Park and Ride
Seal Beach Blvd.
46 Local Los Alamitos–Orange Ball Rd. / The Village at Orange
Taft Ave. Lincoln Park and Ride
47 Local Brea–Newport Beach Brea Blvd. / Theo Lacy Jail
Anaheim Blvd. / Orangewood Children's Home
Fairview St. UCI Medical Center
The Block at Orange
50 Local Long Beach–Orange Katella Ave. The Village at Orange
Lincoln Park and Ride
53 Local Brea–Irvine Main St. Batavia Industrial Parks
Children's Hospital – CHOC
St. Joseph's Hospital
OCTA Offices
54 Local Garden Grove–Orange Chapman Ave. Orange Civic Center
Orange Transportation Center
The Plaza
UCI Medical Center
The Block at Orange
Rancho Santiago Community College
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Table CM-4
Local Bus Routes
Route # Route Type Route Service Service Corridors Key Orange Activity Centers Served
56 Local Garden Grove–Orange Garden Grove Blvd. Orange Transportation Center
OCTA Offices
Children's Hospital–CHOC
St. Joseph's Hospital
57 Local Brea–Newport Beach State College Blvd. / The Block at Orange
Bristol St. UCI Medical Center
Theo Lacy Jail
Orangewood Children's Home
59 Local Brea–Irvine Kraemer Blvd. / Orange Transportation Center
Glassell St. / Chapman University
Grand Ave. / Orange Plaza
Von Karman Ave.
71 Local Yorba Linda–Balboa Tustin St. / The Village at Orange
Red Hill Ave. / Lincoln Park and Ride
Newport Blvd.
Source: Orange County Transportation Authority, 2006
Table CM-5
Community, Station Link, Intra- and Inter-County Bus Routes
Route # Route
Type Route Service Service Corridors Key Orange Activity Centers Served
131 Community Yorba Linda–Orange Lakeview Ave./ The Village at Orange
Riverdale Ave. / Lincoln Park and Ride
Tustin St.
147 Community Brea–Santa Ana Raiit St. / UCI Medical Center
Greenville St. / The Block at Orange
Fairview St. OCTA Offices
St. Joseph's Hospital
Children's Hospital – CHOC
167 Community Anaheim–Irvine Santiago Blvd. / The Village at Orange
Hewes St. / Lincoln Park and Ride
Bryan Ave.
453 Station Link Orange Transportation
Center Chapman Ave. / Orange Transportation Center
–St. Joseph's Hospital Main St. / Children's Hospital–CHOC
La Veta Ave. St. Joseph's Hospital
OCTA Offices
454 Station Link Orange Transportation
Center Chapman Ave. / Orange Transportation Center
–The Block at Orange Metropolitan Dr. UCI Medical Center
The Block at Orange
Bergen Brunswig
Nexus
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Table CM-5
Community, Station Link, Intra- and Inter-County Bus Routes
Route # Route
Type Route Service Service Corridors Key Orange Activity Centers Served
213 Intra County Brea–Irvine Express SR-55 Lincoln Park and Ride
The Village at Orange
757 Inter County Diamond Bar SR-57 UCI Medical Center
–Santa Ana Express The Block at Orange
RTA 149 Inter County Riverside–Orange SR-91 The Village at Orange
(Operated by RTA) Downtown Riverside
Source: Orange County Transportation Authority and Riverside Transit Agency, 2006.
The City recognizes that ridership of both the bus and rail transit systems will increase, and
has designed a land use plan that both enables and accommodates increased transit use. A
large part of the City’s role in accommodating additional transit use includes providing
convenient and attractive transit amenities and streetscape features that improve user
comfort and perception of safety, thus encouraging transit use. Transit-oriented
Development (TOD) design features will be encouraged in major commercial and
employment areas within the City, such as the Town and Country Road corridor, South Main
Street, Katella Avenue, Uptown Orange, and Old Towne. Such TOD features may consist of
streetscape measures such as bus turn-outs, benches, trash receptacles, shelters from wind
and rain, and lighting. TOD features may also be more fundamental to the permitted uses
and design within projects, such as incorporating child care centers, convenience stores, or
personal services within the retail component of mixed-use projects, or near professional
office concentrations. These and other measures help to make the transit system more
accessible to a wide range of people.
The City will continue to work with OCTA to pursue expanded community circulators, such as
the current Station Link service, that will connect people to rail transit, employment centers,
residential areas, and commercial corridors. Additional options, such as jitney services that
function as group taxis, will also be explored.
The City will also continue to support OCTA initiatives and services that promote the mobility
of Orange’s senior, disabled, and youth populations. To accommodate the needs of these
groups, the City will continue to work with OCTA to offer para-transit services, and will seek
ways to improve mobility for Orange youth through transit.
The City of Orange will continue to cooperate with OCTA and other regional providers to
establish new bus routes and stops, and to provide transit amenities. New subdivision plans
will be reviewed by OCTA to assess impacts on bus services, and to examine the need to
provide bus stops or bays. Orange will also work with OCTA to maintain and, if needed,
expand successful transfer stations in Old Towne, the Village at Orange, and The Block at
Orange.
Rail Transit
Many current passenger and commuter fixed-rail transit options in the City will be expanded
in the future, offering significant alternatives to automobile transit for many individuals who
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CM-23
commute to or from the City for housing or employment. Rail transit now has a proven track
record in Orange, and Metrolink seeks to expand rail services in support of land use
transformations near current and future rail stations.
Metrolink
Metrolink operates seven commuter rail lines in Southern California, two of which pass
through Orange. The Orange County Line offers direct connections to Union Station in Los
Angeles to the north and to Oceanside to the south. The Inland Empire–Orange County Line
provides direct connections to Riverside/San Bernardino to the east and San Juan Capistrano
to the south. Roughly 30 Metrolink trains pass through the City on a daily basis. The
Metrolink station in Orange is located three blocks from The Plaza at the OTC, close to a
variety of stores and civic uses in Old Towne. Amtrak and Metrolink operate a cooperative
program called “Rail-2-Rail”, which allows all Metrolink monthly pass holders to use Amtrak
within the limits specified on the pass.
Another much-anticipated rail service improvement is intra-county rail service along the
County’s core transit corridor. This service, which will be provided by Metrolink on behalf of
OCTA, is an attempt to provide intra-county trips with a high degree of reliability. This 30-
minute service is planned to operate between the Irvine Transportation Center (and possibly
Laguna Niguel) and the Fullerton Transportation Center throughout the day to supplement
Metrolink’s peak period commuter service.
The City recognizes that plans to increase daily service on the current Metrolink lines,
improvements to the OTC, and future expansion of Metrolink services to new destinations
would be beneficial to Orange by providing multi-modal transportation options for people
living and working in the community, thus reducing auto dependence for business and leisure
purposes.
Anaheim Regional Transportation Intermodal Center
The Platinum Triangle, which borders Angel
Stadium in the City of Anaheim, proposes a
variety of high-density multiple-family high-rise
housing, office space, and commercial uses.
The Anaheim Regional Transportation
Intermodal Center (ARTIC) is located adjacent
to the proposed development, between Angel
Stadium and the Honda Center. ARTIC will be a
major regional transportation center similar in
scale to Union Station in Los Angeles and
Ontario International Airport in Ontario. The
intermodal center will be a stopping point for
Amtrak, Metrolink, buses, and future high-
speed rail systems that connect to Ontario Airport, Las Vegas, and the Bay Area.
The City of Orange will coordinate with the City of Anaheim, OCTA, and others to ensure that
the City is able to take full advantage of the regional mobility benefits offered by ARTIC.
Potential benefits offered to the City by ARTIC include:
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BRT service along Katella Avenue;
a dynamic mixed-use commercial and residential center at the westernmost end of
Katella Avenue; and
bicycle and pedestrian connections to the Santa Ana River.
California High Speed Rail Corridor
The California High-Speed Rail Authority was established as a state agency in 1996 to direct
the planning, design, construction, and operation of a future high-speed train system
extending from Sacramento, San Francisco, and Oakland in the north to Los Angeles and San
Diego in the south. This high-speed train is proposed to stop at ARTIC. OCTA estimates that
by 2025, the California High Speed Rail Corridor will serve between 150,000 and 230,000
passengers each week.
Magnetic Levitation Train
A magnetic levitation train is being planned that would connect Anaheim to Ontario,
Victorville, Barstow, Primm, and Las Vegas. The California-Nevada Super Speed Train (SST)
will use Magnetic Levitation Systems (Maglev), a type of transportation technology that uses
electric power and non-contact electromagnetic levitation to sustain speeds in excess of 300
mph.
The trip from ARTIC to Las Vegas on the California-Nevada SST will take about 90 minutes,
with an estimated 40.4 million annual riders. A key future benefit offered by the Maglev train
is a high-speed connection to Ontario International Airport, which is planned to grow
substantially and to expand international service in coming decades. The City will support
efforts of the California High-Speed Rail Authority, OCTA, and Southern California Association
of Governments to construct these important rail corridors, and will cooperate with all
parties involved in any future studies conducted to examine the noise and other impacts
associated with the corridors within Orange.
Sidewalks, Trails and Bikeways
Walking and biking contribute to a healthy community, and play increasingly significant roles
as alternatives to the automobile. The City recognizes this by providing and maintaining
sidewalks, trails, and bikeways to support pedestrians and cyclists.
Pedestrian Facilities
In addition to providing basic transportation routes, sidewalks and pathways offer the
opportunity to create appealing public spaces that reflect community pride and invite people
to walk. Proposed mixed-use areas and reinvigorated commercial areas throughout the City
will provide new and reinvented spaces for people to walk and shop. Walkability and access
are essential components of a circulation system that easily and specifically accommodates
pedestrians. Features that contribute to walkability include wide sidewalks, safe street
crossings, design elements that encourage cautious driving, and a pleasant and safe walking
environment. Sidewalks, walkways, well-designed pedestrian crossings, pathways, and
pedestrian short-cuts allow people to get from one destination point to another with ease.
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Dedicated pedestrian paths can provide access between residential and activity areas,
especially if streets do not connect. Access strategies for school children, seniors, and people
with disabilities should also be incorporated into street and sidewalk plans. The City supports
proactive integration of pedestrian improvements and amenities within the circulation
system to improve walkability.
The City will create and implement a pedestrian-oriented streetscape master plan addressing
key commercial corridors, including Tustin Street, Chapman Avenue, Main Street, Lincoln
Avenue, and Katella Avenue. The master plan will address all functional aspects of the
pedestrian environment. It will identify pedestrian links that need improvement and
strengthening, determine new pedestrian links to underserved areas, ensure adequate
sidewalk widths to accommodate lighting and street trees, develop sidewalks in the
industrial area that create links between bus stops, encourage safe routes to schools and
recreation facilities, and minimize barriers to pedestrian and bicycle access.
Recreational Trails and Bikeways
A comprehensive network of recreational trails and bikeways greatly benefits Orange
residents and visitors by providing popular modes of transportation for recreation. In
addition to recreation activities, the City also supports walking and bicycling as viable
commute alternatives to the automobile. The City’s plan for recreational trails and bikeways
is shown in Figure CM-3.
The plan includes trails maintained by the County and private homeowners associations, and
is consistent with the OCTA Commuter Bikeways Strategic Plan. It is also consistent with the
County’s major riding and hiking trails and off-road paved bikeways. As described in the
Vision for the Future, the plan will enable the City to connect parks to activity centers and
residential areas using a combination of recreational trails and bikeways that truly allows
people to travel from place to place within the City without needing an automobile.
Recreational Trails
As shown in Figure CM-3, over 70 miles of existing recreational trails are located within the
City, connecting a large number of neighborhoods and community parks. In addition, 104
miles of proposed future trails are planned throughout Orange on land currently utilized for a
variety of purposes, including flood control, railroad rights-of-way, and roadways.
The City will use the annual seven-year Capital Improvement Program (CIP) process to
prioritize, fund, and build proposed trail segments identified in Figure CM-3. These trails have
been and will continue to be constructed and administered through cooperative efforts of
the City, County, developers, and private homeowner associations.
Desired cross-sections for recreational trails are identified in Figure CM -4. The City may
require construction of portions of proposed trails identified in Figure CM-3 as a condition of
development approval for projects located adjacent to the proposed trail alignments.
Funding for recreational trails and associated restoration projects comes from a variety of
federal, state, and regional sources. Priority for funding of trail improvements will be given to
projects that complete loops within the system, provide missing links for regional and local
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CM-26
trail systems, or serve as destination links to schools, parks, retail businesses, or regional
trails.
Priorities for the recreational trail system include:
trail connections to the Santiago Oaks Regional Park extension west of Cannon Street,
consisting of a connection between Calle Grande and Cannon Street, and the Jamestown
trail from the Orange Park Acres equestrian arena to Cannon Street;
trail connection from Serrano Avenue near Fred Barrera Park to Santiago Oaks Regional
Park;
Mabury Ranch Trail connection from the proposed Cerro Villa Park to the Santiago Oaks
Regional Park;
Serrano Avenue connection near Cannon Street; and
Additional trail connection into Santiago Oaks Regional Park from Orange Park Acres.
To increase the number of people using non-vehicular means of transportation, the City will
encourage putting in place a safe network of crosswalks, grade separations, and walkways to
ensure the safety of pedestrians, bicyclists, and equestrians. Where appropriate, traffic
calming devices and methods such as median landscaping and provision of bike or transit
lanes should be used to slow traffic, improve roadway capacity, and address potential safety
issues. The City will continue to work towards improving the overall condition, appearance,
and safety of both medians and sidewalks in Orange.
Bikeways
Orange’s relatively mild climate
permits bicycle riding year-round, and
the growing popularity of bicycling has
drawn enthusiasts onto the streets
and bike trails throughout the City. The
plan for recreational trails and
bikeways (Figure CM-3) shows the
planned system of bikeways within the
City. The Orange Bikeway Master Plan
has established three classes of bicycle
routes that adhere to California
Department of Transportation
(Caltrans) standards:
Class I Off-road bike paths are located on vacated rail lines, water corridors, or areas
otherwise separated from streets.
Class II On-road bike lanes are located along arterial roadways that are delineated by
painted stripes and other features.
Class III On-road bike routes share use with motor vehicle traffic. They provide a route
that is signed but not striped.
CM-27
Figure CM-3 Plan for Recreational Trails and Bikeways
CM-28
(This Page Left Intentionally Blank)
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CM-29
Figure CM-4
Trail Standards
Cross-sections for each type of route are shown in Figure CM-5.
As shown in Figure CM-3, several future bike routes are planned within Orange, including the
following high-priority projects:
Completing Class I bike routes along Santiago Creek and the Tustin Branch Trail
Establishing Class II bike lanes, including:
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Figure CM-5
Bikeway Standards
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o An east/west corridor on Walnut Avenue from the western City limits to
Santiago Boulevard
o North/south corridors on Main Street from Taft Street to Palm Street, on
Batavia Street from Chapman Avenue to La Veta Avenue, and on Parker
Street from La Veta Avenue to the City limits
Establishing Class III routes along Almond Street, Feldner Street, and Bedford Street
The City has recently completed a paved bike trail along Santiago Creek from Tustin Street to
the western City limit that continues on to Main Place Mall and the Discovery Science Center
as well as two additional segments to the bike trail, which will extend the Santiago Creek
Trail from Tustin Street to Grijalva Park, and also connect Grijalva Park at Santiago Creek to
Collins Avenue along the City-owned portion of the Tustin Branch Trail right-of-way between
Walnut and Collins Avenues. The Santiago Creek trail is planned to extend through and
beyond the City, connecting the regional Santa Ana River Trail to Santiago Oaks Regional
Park and wilderness areas east of Orange. The City will continue to work towards designing a
comprehensive bike trail system that is highly accessible and safe for those who wish to use
it.
The City has proposed Class II and III routes along many north-south and east-west arterials,
all of which connect to pedestrian trails and Class I routes. The City responds to the need to
provide safe and efficient bike travel by making every effort to provide bikeways separate
from the roadway. When bicyclists must share the road with automobiles, the City will work
to improve overall safety.
Currently, only one bicycle parking facility is located in Orange, at the OTC (Metrolink
station). The City will work to provide greater bike amenities including delineated bike lanes
and clear signage along bike trails. The City will also install bicycle racks and safe storage
facilities at parking areas for City facilities, as appropriate, and will require privately
developed projects to incorporate on-site bicycle facilities in accordance with the City’s
Zoning Code (Title 17 of the Orange Municipal Code).
Parking Facilities
Although parking is often considered a separate issue from vehicle circulation, it is important
to address on-street parking because it has a direct effect on roadway capacity. In order to
facilitate improved traffic flow along Orange’s major arterials, the City generally plans to
permit on-street parking only on streets
classified as Primary or Secondary
Arterials or Collector Streets.
Off-street parking deficiencies can
reduce business activity, and can cause
vehicles to re-circulate on public streets,
which increases traffic volumes and
congestion by reducing capacity for
through traffic. The City’s Zoning Code
includes parking requirements to ensure
that an adequate number of spaces are
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CM-32
provided on-site for most uses. The Code also establishes minimum stall dimensions
consistent with current standards for other jurisdictions. These regulations apply to all new
developments, and may be applied to current uses that are modified or expanded.
Particular concern has been expressed within the community regarding current and
expected future parking shortages in Old Towne. Figure CM-6 identifies the location of
existing public parking lots in Old Towne. Most Old Towne parking lots have a maximum time
limit of three hours, with or without a permit. However, some parking lots, such as the OTC
parking located off Chapman Avenue, have no time limit.
Orange will continue to provide sufficient parking to meet community demands. In Old
Towne, the City will study the benefits of creating a parking district and the feasibility of
developing underutilized parking lots surrounding The Plaza as public parking facilities. The
City may encourage the use of shared parking, consolidated parking facilities, and
underground parking or parking structures to provide additional off-street parking to meet
future demands in areas throughout the City with higher concentrations of commercial uses.
Circulation System Aesthetics
The City has determined that it is necessary and desirable to improve certain roadways and
their rights-of-way to enhance the experience for all users of these corridors. Major
commercial corridors have been designated within the Urban Design Element to be improved
with pedestrian-scale enhancements. Enhancements could include street trees, sidewalk
improvements, lighting, bus shelters, and crosswalks. These improvements not only offer a
more aesthetically-pleasing experience for all users in these corridors, they also may offer
increased safety and security.
Streetscape improvements offer safety and security to both motorists and non-motorists
through increased visual cues, better visibility, and increased activity. Many streetscape
enhancements provide not only a comfortable environment for the pedestrian and bicyclist,
but also offer drivers visual cues that a non-motorist could be expected in an area.
Improvements such as striping, bus shelters, and pedestrian-scaled signage guide the non-
motorist towards areas that are most appropriate for their use. These same cues help the
motorist to see where the presence of pedestrians and bicyclists is most likely to occur. For
example, a well-marked crosswalk guides the pedestrian towards the location in the right-of-
way most appropriate for crossing, while also alerting the motorist to slow down and look
out for pedestrian traffic.
Visibility offered by pedestrian-scaled lighting benefits non-motorists and motorists alike.
Pedestrians and bicyclists are better able to see their way, which increases their feelings of
security. Improvements that create a sense of security for pedestrians encourage increased
use and activity. This increased activity, in turn, leads to a greater feeling of safety. The City
has acknowledged the importance of improving the experience of users on many of its major
commercial corridors.
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CM-33
*Note: Possession of City issued parking permit enables holder to exceed specified time limit
GPA 2010-0001 (8/10/10)
Figure CM-6
Public Parking Lots in Old Towne Ora nge
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CM-34
CIRCULATION & MOBILITY IMPLEMENTATION
The goals, policies, and plans identified in this Element are implemented through a variety of
City plans, ordinances, development requirements, capital improvements, and ongoing
collaboration with regional agencies and neighboring jurisdictions. Specific implementation
measures for this Element are contained in the General Plan Appendix.
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IMP-28 GPA 2010-0001 (8/10/10)
III. Conditions or Requirements Placed upon Applicants
during Development Review
Program III-1 California Environmental Quality Act
Comply with all provisions of CEQA. In addition to thresholds that may be established or
adopted by the City in the future, use the following thresholds and procedures for CEQA
analysis of proposed projects, consistent with policies adopted within the General Plan:
Circulation & Mobility
o In accordance with CEQA Guidelines Section 15064.3, the City shall utilize vehicle
miles traveled (VMT), to measure transportation impacts.
o A project would result in a significant project-generated VMT impact if the baseline
and/or cumulative project-generated VMT per service population exceeds the City of
Orange General Plan Buildout VMT per service population.
o The project’s effect on VMT would be considered significant if it resulted in baseline
and/or cumulative link-level boundary citywide VMT per service population increases
under the plus project condition compared to the no project condition.
o Level of service (LOS) D (volume-to-capacity [V/C] ratio less than or equal to 0.90)
shall be the lowest acceptable level of service for both roadway segments and peak-
hour intersection movements.
o Orange County’s Congestion Management Plan (CMP) specifies LOS E (V/C ratio less
than or equal to 1.00) as the operating standard for roadways on the CMP highway
system.
o Projects that increase V/C by .01 or more on affected roadway segments or
intersections experiencing LOS E or LOS F conditions without the proposed project
are considered to create significant impacts, and mitigation is required.
Parks and Recreation
o The City shall require dedication of parkland at a rate of 3.0 acres per 1,000
anticipated residents or payment of in-lieu fees for new residential projects.
Noise
o The City shall apply the noise standards specified in Tables N-3 and N-4 of the Noise
Element to proposed projects analyzed under CEQA.
o In addition to the foregoing, an increase in ambient noise levels is assumed to be a
significant noise impact if a proposed project causes ambient noise levels to exceed
the following:
Where the existing ambient noise level is less than 65 dBA, a project related
permanent increase in ambient noise levels of 5 dBA CNEL or greater.
Where the existing ambient noise level is greater than 65 dBA, a project related
permanent increase in ambient noise levels of 3 dBA CNEL or greater.
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IMP-29
Historic and Cultural Resources
o “Historical resource” for the purposes of CEQA shall mean “historic district” in the
case of a contributor to a historic district.
o Historic resources listed in the Historic Register shall have a presumption of
significance pursuant to CEQA Section 21084.1 and shall be treated as historical
resources under CEQA.
o The historical significance of an archaeological historic resource is evaluated using
the criteria of Public Resources Code Section 5024.1 and Section 15064.5 et seq. of
the state CEQA Guidelines.
All future development proposals shall be reviewed by the City for potential regional and
local air quality impacts per CEQA. If potential impacts are identified, mitigation will be
required to reduce the impact to a level less than significant, where technically and
economically feasible.
Agency/Department: Community Development Department, Public Works
Department, Community Services Department
Funding Source: General Fund, development fees
Time Frame: Ongoing
Related Policies:
Circulation & Mobility: 1.1, 1.2, 2.3
Natural Resources: 2.2, 2.8, 5.6
Cultural Resources &
Historic Preservation: 1.1, 1.3
Noise: 1.4
Growth Management: 1.1, 2.1
Program III–2 Site Development Review
Comply with all City procedures in the review of proposed development projects, and use the
site plan review process to ensure that applicable General Plan policies and City standards
and regulations are applied to proposals for specific development projects.
Agency/Department: Community Development Department, Public Works
Department, Police Department, Fire Department,
Community Services Department
Funding Source: Development fees
Time Frame: Ongoing
Related Policies:
Land Use: 1.6, 1.7, 2.5, 2.7, 2.8, 3.1, 3.4, 4.3, 4.5, 6.1, 6.2, 6.9, 6.10, 6.12
Circulation & Mobility: 1.1, 1.7, 5.1, 5.2
Natural Resources 1.3, 2.3, 2.6, 2.13, 2.14, 2.15, 2.16, 4.3, 4.4, 4.5, 5.4, 5.6, 5.7,
6.6, 7.5
Cultural Resources &
Historic Preservation: 1.3, 1.4, 1.5, 1.6, 4.1, 4.2, 4.3, 4.4, 4.5
Public Safety: 1.1, 2.5, 3.3, 3.5, 4.2, 4.3, 6.2, 7.2, 7.3, 7.4, 9.1
Noise: 1.1, 1.2, 1.3, 1.4, 1.5, 1.6, 2.1, 2.2, 5.1, 5.2, 5.3, 6.1, 6.2
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IMP-30 GPA 2010-0001 (8/10/10)
Urban Design: 2.4, 2.5, 2.6, 3.4, 3.5, 6.1
Infrastructure: 1.4, 1.5
Program III-3 Commission/Committee Review
Orange has several commissions and one committee whose purpose is to advise and assist
the City Council in dealing with issues related to each commission’s or committee’s area of
concern. The commissions and committee gather pertinent information, hear arguments,
weigh values, and make recommendations to the Council. Several of the commissions also
have some administrative powers.
The City will continue to use the commission/committee structure to inform the public
decision-making process.
The City will also consider expanding the authority of the Design Review Committee and
Community Development Department’s staff to administer the Orange Historic Resources
Inventory, Historic Register listings, and design review procedures for projects involving
architectural and archaeological resources.
Agency/Department: City Council, Community Development Department,
Community Services Department
Funding Source: General Fund
Time Frame: Ongoing
Related Policies:
Land Use: 2.5, 2.6, 2.7, 2.8, 3.1, 3.2, 4.5, 5.5, 5.8, 5.9, 6.1, 6.2, 6.3, 6.4,
6.7, 6.11, 8.1, 8.2, 8.3
Circulation & Mobility: 1.3, 2.3, 3.2, 4.1, 6.1
Cultural Resources &
Historic Preservation: 1.1, 1.3, 1.4, 4.5, 4.6
Urban Design: 1.1, 6.1
Public Safety: 1.1, 3.5, 4.3, 7.4
Economic Development: 1.2, 2.5, 3.3, 4.5, 5.1, 5.2, 5.3, 5.4, 5.5
Program III-4 Traffic Impact Analyses
Require preparation of traffic impact analyses for new discretionary development projects.
A traffic impact analysis which includes VMT assessment shall be required for a proposed
project that does not satisfy the project screening criteria. For projects that increase V/C by
0.01 or more on affected roadway segments or intersections experiencing LOS E or LOS F
conditions without the proposed project, traffic impact analyses must propose binding
mitigation reduction strategies to be incorporated within the project.
Continue to update guidelines for the preparation of traffic impact analyses to reflect local
conditions and industry standards.
Agency/Department: Public Works Department
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IMP-31
Funding Source: Development fees
Time Frame: Ongoing
Related Policies:
Land Use: 2.5, 6.10
Circulation & Mobility: 1.1
Growth Management: 1.2, 1.6
Program III-5 Transportation Demand Management Plans
Require major employers of 100 persons or more to institute transportation demand
management (TDM) plans. Such plans establish incentives to encourage employees to
carpool, take public transportation, bicycle, or use some means other than private
automobiles to get to and from work.
Agency/Department: Community Development Department, Public Works
Department
Funding Source: Development fees
Time Frame: Ongoing
Related Policies:
Circulation & Mobility: 2.6
Natural Resources: 2.1, 2.2
Growth Management: 1.12
Program III-6 National Pollutant Discharge
Elimination System Compliance
Before making land use decisions, the City will utilize available methods to estimate increases
in pollutant loads and flows resulting from projected future development.
The City will follow the most current NPDES permit and countywide Model WQMP and the
City Local Implementation Plan to ensure that the City complies with applicable federal and
state regulations. Applicants for new development and redevelopment projects shall prepare
and submit plans to the City, as well as implement plans demonstrating accomplishment of
the following:
Emphasize the need to implement and prioritize the use of low impact development
BMPs that provide onsite infiltration and retention;
Use biotreatment systems such as flow through planters, wetlands and bioswales where
infiltration, evapotranspiration, and harvest and reuse are not feasible;
Limit areas of impervious surfaces and preserve natural areas;
Limit directly connected areas of impervious surfaces;
Limit disturbance of natural water bodies, natural drainage systems, and highly erodable
areas;
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IMP-32 GPA 2010-0001 (8/10/10)
Use structural and nonstructural best management practices (BMPs) to mitigate
projected increases in pollutant loads and flows;
Use pollution prevention methods, source controls, and treatment with small collection
strategies located at or as close as possible to the source;
Control the velocity of pollutant loading flows during and after construction; and
Implement erosion protection during construction.
In addition, applicants for large development projects are required to prepare and implement
plans that meet site predevelopment hydrologic conditions and to control runoff on-site
where technically feasible.
Agency/Department: Public Works Department, Community Development
Department
Funding Source: Development fees
Time Frame: Ongoing
Related Policies:
Land Use; 4.3, 6.5
Natural Resources: 2.12, 2.13, 2.14, 2.15, 2.16, 2.17
Public Safety: 2.3
Program III-7 Water Services and Supplies
As needed, require studies to determine water infrastructure requirements for future
development projects, and require that any recommendations be incorporated into the
design of projects. Require the dedication of necessary right-of-way and construction of
water infrastructure improvements for development projects as needed. Developers shall
also be required to pay the cost of providing new and improved water services to project
sites.
For projects that satisfy the criteria set forth in Sections 10910–10915 of the California Water
Code and Section 66473.7 of the Government Code, a water supply assessment or water
supply verification demonstrating available water supplies exist to support development
shall also be prepared.
Agency/Department: Community Development Department, Public Works
Department
Funding Source: Development fees, General Fund
Time Frame: Ongoing
Related Policies:
Infrastructure: 1.1, 1.4, 1.6
Program III-8 Adequate Public Safety and Emergency
Response
During the development application process, consult with Fire and Police Departments to
evaluate the need for additional fire and police facilities or resources to serve new
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IMP-33
development projects and infill development areas. During updates to the Capital
Improvement Program process, coordinate with service providers to evaluate the level of fire
and police service provided to the community. Require adequate street widths and clearance
for emergency access. Provide all appropriate safety features. Continue to use state-of-the-
art techniques and technology to enhance public safety.
Adhere to requirements in the Municipal Code for adequate street widths and clearance for
emergency access. Integrate CPTED techniques into development projects and practice
active surveillance measures in high-risk areas such as parking lots.
The City shall use open space easements and other regulatory techniques to prohibit
development and avoid public safety hazards where the threat from seismic hazards cannot
be mitigated.
Agency/Department: Community Development Department, Public Works
Department, Police Department, Fire Department
Funding Source: Development fees, General Fund
Time Frame: Ongoing
Related Policies:
Public Safety: 3.4, 4.4, 6.1, 6.2, 6.3, 6.4
Program III-9 Geologic Hazard Assessments
Pursuant to state law, geologic and/or geotechnical studies are required for proposed new
development projects located in areas identified as susceptible to landslides and liquefaction
and binding mitigation strategies must be adopted. Compliance with the recommendations
set forth in site-specific geologic and/or geotechnical studies will be made a condition of
approval for new development. In addition, the City may require applicants to incorporate
measures to stabilize and maintain slopes on a site-by-site basis, such as proper planting,
irrigation, retaining walls, and benching.
Agency/Department: Community Development Department, Public Works
Department
Funding Source: Development fees
Time Frame: Ongoing
Related Policies:
Land Use: 6.9, 6.10
Public Safety: 1.1
Program III-10 Cultural Resources Inventories
Require cultural resources inventories of all new development projects in areas identified
with medium or high potential for archeological, paleontological, or cultural resources based
on resource sensitivity maps prepared in conjunction with the General Plan.
Where a preliminary site survey finds medium to high potential for substantial archaeological
remains, the City shall require a mitigation plan to protect the resource before issuance of
permits. Mitigation may include:
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Ensuring that a qualified archaeologist is present during initial grading or trenching
(monitoring),
Redesigning the project to avoid archaeological resources (this is considered the
strongest tool for preserving archaeological resources),
Capping the site with a layer of fill, and/or
Excavating and removing the archaeological resources (recovery) and implementing
curation in an appropriate facility under the direction of a qualified archaeologist
(interpretation).
Alert applicants for permits within early settlement areas to the potential sensitivity. If an
archaeological inventory survey is required, the final stage is the preparation of a
professional report detailing the findings and recommendations of the records search and
field survey. The final report containing site forms, site significance, and mitigation measures
should be submitted immediately to the Community Development Department. All
information regarding site locations, Native American human remains, and associated
funerary objects should be in a separate confidential addendum, and not be made available
for public disclosure.
If significant archaeological resources are discovered during construction or grading
activities, such activities shall cease in the immediate area of the find until a qualified
archaeologist can determine the significance of the resource and recommend alternative
mitigation. The final written report should be submitted to the appropriate regional
archaeological Information Center within three months after work has been completed. The
City shall ensure that project applicants contact the Native American Heritage Commission
for a Sacred Lands File Check and a list of appropriate Native American contacts f or
consultation concerning the project site and to assist in crafting the mitigation measures.
Agency/Department: Community Development Department
Funding Source: Development fees
Time Frame: Ongoing
Related Policies:
Land Use: 6.11
Cultural Resources &
Historic Preservation: 4.1, 4.5
Program III-11 Green Building, Energy Conservation,
and Sustainable Development
The City strongly encourages new development and major renovation projects to employ
green building techniques and materials. Encourage proposed development projects
throughout the City to use Leadership in Energy and Environmental Design (LEED) standards
developed by the U.S. Green Building Council or a similar third-party verified program.
Encourage building orientations and landscaping that enhance natural lighting and sun
exposure. Prepare guidelines for sustainable development to encourage incorporation of
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IMP-35
these practices in new development. These guidelines will include measures to maximize soil
permeability to address related stormwater and surface-water runoff issues.
Require compliance with state Title 24 building construction standards and Energy Star
conservation standards for all development projects.
Prepare and adopt an ordinance that requires and/or provides incentives for: (1) specified
new residential development to comply with a specified green building program or show
that its development provides comparable effectiveness to such a program; and (2) specified
non-residential development of a specified size comply with a specified green building
program or show that its development provides comparable effectiveness to such a
program.
Agency/Department: Community Development Department, Public Works
Department
Funding Source: Development fees
Time Frame: Ongoing; December 31, 2011 (For ordinance)
Related Policies:
Natural Resources: 2.6, 2.7
Program III-12 Mixed-Use Noise Property Notification
When the City exercises discretionary review, provides financial assistance, or otherwise
facilitates residential development within a mixed-use area, make providing written warnings
to potential residents about noise intrusion a condition of that approval, assistance, or
facilitation. The following language is provided as an example:
“All potential buyers and/or renters of residential property within mixed-use districts in the City
of Orange are hereby notified that they may be subject to audible noise levels generated by
business and entertainment related operations common to such areas, including amplified
sound, music, delivery and passenger vehicles, mechanical noise, pedestrians, and other urban
noise sources.”
Agency/Department: Community Development Department
Funding Source: Development fees
Time Frame: Ongoing
Related Policies:
Noise: 5.1, 5.3
Urban Design: 2.5
Program III-13 Ecological and Biological Resource
Assessments
Analyze development proposals for potential impacts on significant ecological and biological
resources. Require appropriate mitigation for all significant impacts if impact avoidance is
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IMP-36 GPA 2010-0001 (8/10/10)
not possible. Mitigation measures for habitat and species may include but are not limited to
avoidance, enhancement, restoration, compensatory mitigation, or a combination of these.
Agency/Department: Community Development Department
Funding Source: Development fees
Time Frame: Ongoing
Related Policies:
Land Use: 6.4, 6.11
Natural Resources: 4.1, 4.3, 4.4, 4.5
Program III-14 Archaeological Resources Management
Report (ARMR Preservation Bulletin)
Establish the Archaeological Resources Management Report (ARMR Preservation Bulletin) as
the standard report format for all documentation and accept reports only from registered
professional archaeologists knowledgeable in Native American cultures and/or historical
archaeology (qualified archaeologists).
Agency/Department: Community Development Department
Funding Source: Development fees
Time Frame: Ongoing
Related Policies:
Cultural Resources &
Historic Preservation: 4.1
Program III-15 Historic Resources Design Review
Continue to use the Secretary of the Interior’s Standards for the Treatment of Historic
Properties and Guidelines for Preserving, Rehabilitating, Restoring and Reconstructing Historic
Buildings as a basis for design review and incorporate them by reference into the Old Towne
Design Standards and other historic preservation design standards. Any approved demolition
permit for historic resources listed in the City’s Historic Register will be automatically subject
to a delay of 180 days before the permit for demolition may be issued. The property owner
will strive to develop alternatives to demolition that will preserve the historic resources.
The Design Review Committee or Historic Preservation Commission at such time such a
commission is established, shall serve as the review body for projects involving historic
resources.
Agency/Department: Community Development Department, City Council
Funding Source: General Fund
Time Frame: Ongoing
Related Policies:
Cultural Resources &
Historic Preservation: 1.1, 1.2, 1.3, 1.4, 1.5, 2.3, 3.2
IMPLEMENTATION
ORANGE GENERAL PLAN
IMP-37
Program III-16: Public Access to Santiago Creek and
Santa Ana River Public Interface
Ensure that new development does not preclude access to Santiago Creek and the Santa Ana
River and associated trails. Development review should ensure that commercial and retail
development in these areas support public access.
Agency/Department: Community Development Department
Funding Source: Development fees
Time Frame: Ongoing
Related Policies:
Land Use: 6.4, 6.6
Circulation & Mobility: 4.1
Natural Resources: 1.3, 5.5, 7.1, 7.2, 7.3, 7.4, 7.5
Urban Design: 2.6
Program III-17: Office Condominium Conversions
Evaluate applications for conversion of industrial properties to office condominiums to
determine the impact on the available balance of larger and smaller properties available for
industrial use.
Agency/Department: Community Development Department, Economic
Development Department
Funding Source: Development fees
Time Frame: Ongoing
Related Policies:
Land Use: 4.1, 4.2, 4.3, 4.4, 4.5
Economic Development: 3.1, 6.1, 6.2
Program III-18: Noise Reduction in New Construction
Require construction contractors to implement the following measures during construction
activities through contract provisions and/or conditions of approval as appropriate:
Construction equipment shall be properly maintained per manufacturers’ specifications
and fitted with the best available noise suppression devices (i.e., mufflers, silencers,
wraps, etc).
Shroud or shield all impact tools, and muffle or shield all intake and exhaust ports on
power equipment.
Construction operations and related activities associated with the proposed project shall
comply with the operational hours outlined in the City of Orange Municipal Code Noise
IMPLEMENTATION
ORANGE GENERAL PLAN
IMP-38 GPA 2010-0001 (8/10/10)
Ordinance, or mitigate noise at sensitive land uses to below Orange Municipal Code
standards.
Construction equipment should not be idled for extended periods of time in the vicinity
of noise sensitive receptors.
Locate fixed and/or stationary equipment as far as possible from noise sensitive
receptors (e.g., generators, compressors, rock crushers, cement mixers). Shroud or
shield all impact tools, and muffle or shield all intake and exhaust ports on powered
construction equipment.
Where feasible, temporary barriers shall be placed as close to the noise source or as close
to the receptor as possible and break the line of sight between the source and receptor
where modeled levels exceed applicable standards. Acoustical barriers shall be
constructed material having a minimum surface weight of 2 pounds per square foot or
greater, and a demonstrated Sound Transmission Class (STC) rating of 25 or greater as
defined by American Society for Testing and Materials (ASTM) Test Method E90.
Placement, orientation, size, and density of acoustical barriers shall be specified by a
qualified acoustical consultant.
Agency/Department: Community Development Department, Public Works
Department, Community Services Department
Funding Source: Development fees
Time Frame: Ongoing
Related Policies:
Noise: 1.1, 1.2, 1.4, 1.5, 7.2
Program III-19: Groundborne Noise and Vibration
Implement the following measures to reduce the potential for human annoyance and
architectural/structural damage resulting from elevated groundborne noise and vibration
levels.
Construction-Induced Vibration. The City shall implement or require implementation of
the following measures through contract provisions and/or conditions of approval as
appropriate:
o Pile driving required within a 50-foot radius of historic structures shall utilize
alternative installation methods where possible (e.g., pile cushioning, jetting, pre-
drilling, cast-in-place systems, resonance-free vibratory pile drivers). Specifically,
geo pier style cast-in-place systems or equivalent shall be used where feasible as
an alternative to pile driving to reduce the number and amplitude of impacts
required for seating the pile.
IMPLEMENTATION
ORANGE GENERAL PLAN
IMP-39
o The preexisting condition of all buildings within a 50-foot radius and of historic
buildings within the immediate vicinity of proposed construction-induced
vibration activities shall be recorded in the form of a preconstruction survey. The
preconstruction survey shall determine conditions that exist before construction
begins for use in evaluating damage caused by construction activities. Fixtures
and finishes within a 50-foot radius of construction activities susceptible to
damage shall be documented (photographically and in writing) prior to
construction. All damage will be repaired back to its preexisting condition.
o Vibration monitoring shall be conducted prior to and during pile driving
operations occurring within 100 feet of the historic structures. Every attempt
shall be made to limit construction-generated vibration levels in accordance with
Caltrans recommendations during pile driving and impact activities in the vicinity
of the historic structures.
o Provide protective coverings or temporary shoring of on-site or adjacent historic
features as necessary, in consultation with the Community Development Director
or designee.
Railroad-Induced Vibration:
o Vibration sensitive uses shall be located a minimum of 100 feet from the railroad
centerline, where feasible. To ensure compliance with FTA and Caltrans
recommended guidelines, a site-specific groundborne noise and vibration
assesment should be conducted. For sensitive uses located within 100 feet of the
railroad centerline, the acoustical noise and vibration assessment shall
demontrate that potential impacts will be below the level of significance. If
specific project-level impacts are identified, mitigation measures reducing the
impacts to below the level of significance will be required.
o A groundborne vibration assessment shall be conducted at proposed building
pad locations within 200 feet of railroad right-of-ways, prior to project approval.
Vibration monitoring and assessment shall be conducted by a qualified acoustical
consultant. The assessment will demonstrate that rail-associated groundborne
vibration and noise levels comply with recommended FTA and Caltrans guidance
of 80 VdB and 0.2 in/sec PPV (or equivalent), respectively, or propose project-
specific mitigation measures such as site design, building isolation, etc. to achieve
that standard.
Agency/Department: Community Development Department, Public Works
Department
Funding Source: General Fund, Development fees
Time Frame: Ongoing
Related Policies:
Noise: 1.1, 3.1, 3.2, 6.1, 7.2
IMPLEMENTATION
ORANGE GENERAL PLAN
IMP-40 GPA 2010-0001 (8/10/10)
Program III-20: Toxic Air Contaminant Exposure
Require each project applicant to implement the following measures to reduce the exposure
of sensitive receptors to TACs from mobile sources, as project design features or a condition
of project approval:
Activities involving idling trucks shall be oriented as far away from and downwind of
existing or proposed sensitive receptors as feasible.
Strategies shall be incorporated to reduce the idling time of main propulsion engines
through alternative technologies such as IdleAire, electrification of truck parking, and
alternative energy sources for TRUs to allow diesel engines to be completely turned off.
Proposed developments shall incorporate site plans that move sensitive receptors as far
as feasibly possible from major roadways (100,000+ average daily trips).
Projects containing sensitive receptors (such as residences, schools, day care centers,
and medical facilities) on sites within 500 feet of a freeway must demonstrate that health
risks relating to diesel particulates would not exceed acceptable health risk standards
prior to project approval.
Agency/Department: Community Development Department, Public Works
Department
Funding Source: Development fees
Time Frame: Ongoing
Related Policies:
Natural Resources: 2.1
CIRCULATION
& MOBILITY
ORANGE GENERAL PLAN
CM-1
REV. GPA 2014-0001 (12/8/15)
Rev. GPA 2010-0001 (8/10/10)
INTRODUCTION AND VISION FOR THE FUTURE
Orange’s circulation system has been influenced by a variety of historical factors, including
the presence of the Santa Fe Railroad, the vision of Alfred B. Chapman and William T. Glassell,
the agricultural history of the area, and alternative transportation modes including a historic
streetcar system.
In 1887, the Santa Fe Railroad came to Orange and built a station four blocks west of the
Plaza. The coming of the railroad set off a real estate boom that brought hundreds of settlers
to the area. The railroad also influenced the City’s early economic success by providing a
means to transport goods, especially citrus, to the entire country. Today, the railroad tracks
continue to serve freight trains and provide a critical link to the region via the Metrolink
heavy rail transit system.
In the 1870s, Alfred B. Chapman and William T. Glassell subdivided their land into residential
and small farm lots centered on a roundabout known today as Plaza Park. Plaza Park was
dedicated in 1886 and established the City’s two main streets – Chapman Avenue and Glassell
Street – as well as the compact street grid of Old Towne Orange. The street grid and railroad
system were supported historically by a streetcar system that connected the small towns and
settlements that make up the City today.
Over time, the small farms on the outer edges of Orange’s core district began to disappear.
Two factors influenced this change: the demand for housing after World War II and the
appearance of “Quick Decline” disease that destroyed the local citrus industry. As each farm
was developed independently, the grid system expanded outward and commercial corridors
were established. Orange’s roadways began to take on a more suburban pattern of
collectors, connectors, and arterials. As development reached the eastern portion of the City,
the grid gave way to curvilinear street patterns.
The historic roadways and railways that form the basis for the current circulation network
have been complemented over the years by the development of a streetcar system, a transit
service, an emerging and continually expanding bicycle trail and route network, and routes
for equestrian use in the eastern portion of the City. The City will continue to be served by
these multiple modes of transportation and other emerging mobility technologies.
CIRCULATION AND MOBILITY
ORANGE GENERAL PLAN
CM-2
Orange’s Vision for the Future, described in the General Plan Introduction, recognizes that
the circulation system is a key component of the quality of life in the City. Accordingly, the
vision includes the following objectives:
Residential areas will be connected to commercial, recreational, and open space areas, as
well as educational and cultural facilities via a balanced, multi-modal circulation network
that accommodates vehicles, pedestrians, cyclists, hikers, and equestrians. This network
will create additional opportunities for walking and biking, enhancing safety and well-
being for neighborhoods and businesses.
The City will work to define neighborhoods through the use of open space areas and a
trail system that provides a source of aesthetic beauty and recreational opportunities.
These open space areas support a healthy and active community.
We will develop a connected multi-modal network for traveling from one end of town to
the other that provides the option for residents from different neighborhoods to access
parks, open spaces, and scenic areas by vehicle, transit, foot, bicycle or, where
appropriate, horse.
Purpose of the Circulation & Mobility Element
California’s General Plan Guidelines mandate that the Circulation & Mobility Element fulfill
the following objectives:
Show a direct relationship to the Land Use Element to ensure that any changes to land
use as stated by the Land Use Element and growth occur with adequate circulation and
transportation facilities in mind.
Address relevant issues including the adequacy of “major thoroughfares, transportation
routes, terminals, other local public utilities and facilities.” The goal of the Circulation &
Mobility Element is to identify circulation problems related to these facilities in the early
stages and resolve them in local goals and policies without costly delays.
Other relevant issues discussed in the Circulation & Mobility Element include those that
address streets, highways, public transit routes, railroads, bicycle and pedestrian routes,
recreational trails, paratransit, parking, transportation system management, and air
pollution. The hierarchy of streets within the residential areas helps to frame the urban form.
Connections between neighborhoods can be achieved by a comprehensive network of
sidewalks and trails. Also, the commercial corridors can be enhanced with adequate street
capacity, public transit, and pedestrian-friendly environments.
The state also recommends that the Circulation & Mobility Element address coordination
efforts among the local, regional, and state transportation plans to better resolve circulation
issues. Since many transportation concerns are regional, addressing them requires
intergovernmental and regional transportation management plans and policy
implementation. These partnerships ensure the most efficient use of funding, infrastructure,
and other resources. The state also recommends the “preservation of transportation
corridors for future system improvements.”
CIRCULATION AND MOBILITY
ORANGE GENERAL PLAN
CM-3
The Circulation & Mobility Element prioritizes the issues and opportunities that exist within
Orange’s transit network. It is directly responsive to proposed changes in land use and
anticipates the impacts of those changes. This Element also seeks to reassure residents and
businesses that the City recognizes the link between transportation and land uses, and
provides a means to mitigate the impacts of growth.
Another goal of the Circulation & Mobility Element is to increase transportation options and
provide increased access to the circulation system for all residents of Orange. This goal
includes improved rail and bus transit connections and frequency, implementation of a
Bikeway Master Plan, and completion of a trails system. Transforming many of Orange’s
historically auto-oriented commercial corridors, such as Katella Avenue, Main Street, and
portions of La Veta Avenue, Chapman Avenue, and Glassell Street into more pedestrian-
friendly mixed-use environments is an overarching goal. Where possible, the development of
equestrian trails is also encouraged.
One of the main functions of the Circulation & Mobility Element is to guide and direct
enhancement of the current circulation system for existing and future developments. Thus,
circulation provisions correlate with the Land Use Element to avoid unchecked growth and
unnecessary congestion.
Another key objective of the Element is to work toward a future circulation network that
provides meaningful alternatives for getting around the community by less auto-dependent
means. The City’s topography, street and sidewalk system, transit and trail framework, and
land use relationships provide an excellent foundation for pursuit of this objective.
The Circulation & Mobility Element does not simply determine automobile routes. It also
guides the movement of people and goods, directly affecting Orange’s physical, social, and
economic environment. Since circulation permits accessibility to places and social amenities,
it can either improve or cause deterioration in quality of life. Circulation efficiency also plays a
major role in progress and development of the City’s economy.
Scope and Content of the Circulation & Mobility Element
The Circulation & Mobility Element comprises three sections:
(1) Introduction;
(2) Issues, Goals, and Policies; and
(3) The Circulation & Mobility Plan.
The first section introduces the contents of the Circulation & Mobility Element. The second
section presents issues, goals, and policies for improving circulation. The third section
includes the Circulation & Mobility Plan, which designates locations and standards for
roadways and non-motorized circulation facilities, and states the community’s desired level
of transportation service.
Implementation measures designed to promote achievement of the goals and policies are
provided in an Appendix to the General Plan.
CIRCULATION AND MOBILITY
ORANGE GENERAL PLAN
CM-4
Relationship to other General Plan Elements
California planning law requires that the Circulation & Mobility Element correlate and
maintain consistency with the other General Plan elements. The Circulation & Mobility
Element relates most closely to the Land Use, Natural Resources, Noise, Economic
Development, Housing, and Urban Design Elements.
The Circulation & Mobility Element is linked to the Land Use Element because the General
Plan land use designations identified in the Land Use Element serve as a basis for the
allocation of vehicle trips and establishment of capacity levels for circulation planning. The
Land Use Element also provides land use designations that accommodate mixed commercial
and residential development, which encourage shorter trips and improve the efficiency of
the transportation network. The Circulation & Mobility Plan is established to define and
provide for adequate levels of service and facilities to support future land uses. This Element
recommends roadway and intersection improvements that may require land acquisition.
Location of public transportation facilities will also influence pedestrian activity and transit -
oriented development, and the physical size of streets will affect urban land uses and the
physical appearance of the City.
The Natural Resources Element identifies regional air quality objectives and provides
appropriate mitigation efforts that affect the Circulation & Mobility Element. Improving
access, encouraging alternative modes of travel, and maintaining air quality and conservation
standards are common objectives of the Natural Resources and the Circulation & Mobility
Elements.
The Noise Element addresses future noise levels associated with roadways, rail, and other
transportation facilities. Future volumes of traffic on the circulation system are directly
related to future noise levels and mitigation strategies.
The Economic Development Element identifies desirable economic conditions and land uses
that enhance and promote business activity, employment growth, and economic stability.
The goals and policies of the Circulation & Mobility Element will determine road capacity in
Orange, which will impact the type and location of uses, and parking and access
considerations associated with future uses. Both elements share a common objective of
planning for future transportation infrastructure needs. Maintaining roadways, bikeways and
bus and rail transit facilities is critical to the success of both current and future businesses in
Orange.
The Urban Design Element is a framework for shaping the future form and character of
Orange. The quality of Orange’s physical environment contributes to its identity, attracts
new residents, and sets the stage for economic activity. The Urban Design Element builds on
the foundation of Orange’s already strong sense of place to preserve and strengthen the
streetscape environment of commercial corridors and landmarks within the city. The Urban
Design Element and Circulation & Mobility Element share a common objective to reinvent
City streets as more functional and walkable public places.
CIRCULATION AND MOBILITY
ORANGE GENERAL PLAN
CM-5
ISSUES, GOALS, AND POLICIES
The goals, policies, and implementation programs of the Circulation & Mobility Element seek
to achieve a better balance between vehicular, pedestrian, and bicycle travel, and to provide
a wide range of viable transportation options to Orange residents. The following six issues
are addressed: (1) enhancing the local circulation system; (2) maintaining the regional
circulation system; (3) maintaining a viable public transportation network; (4) creating a
comprehensive system of sidewalks, trails, and bikeways; (5) providing adequate parking
facilities; and (6) improving circulation system aesthetics and safety.
Local Circulation System
The local roadway system serves the community’s primary needs for mobility and access, and
consists of a hierarchy of City streets to meet those needs. The City’s original street system
was established as a grid pattern long before a Master Plan of Arterial Highways (MPAH) was
adopted. The Old Towne area and many postwar neighborhoods were designed in a classic
grid configuration, while in newer parts of the City, physical features such as the Santa Ana
River, Santiago Creek, hilly terrain, freeways and the presence of the City of Villa Park have
resulted in a system without a definitive pattern. Some major roads do not connect the
eastern and western portions of the City and consequently do not provide effective through
circulation. A well-designed roadway system will provide convenient access to activities in
Orange.
GOAL 1.0: Provide a safe, efficient, and comprehensive circulation system that serves
local needs, meets forecasted demands, and sustains quality of life in
neighborhoods.
Policy 1.1: Plan, build, and maintain an integrated, hierarchical, and multi-modal system
of roadways, pedestrian walkways, and bicycle paths throughout the City.
Policy 1.2: Identify key intersections and streets with historical or projected traffic
congestion problems and apply creative traffic management measures to
improve overall circulation.
Policy 1.3: Consider various methods to increase safety on City arterials and
neighborhood streets, including landscaping, provision of bike/transit lanes,
and consideration of traffic calming on neighborhood streets in accordance
with the City’s Neighborhood Residential Traffic Management Program.
Policy 1.4: Prohibit on-street parking where possible to reduce bicycle/automobile
conflicts in appropriate target areas as recommended by the Bikeways Master
Plan.
Policy 1.5: Address possible safety and noise effects of increased rail activity on grade
crossings throughout the City.
Policy 1.6: Maintain and repair roadways and sidewalks as necessary to improve
circulation and safety.
Policy 1.7: Consolidate driveways along roadways that provide access to commercial
uses to minimize side street interruption and promote smooth traffic flows.
CIRCULATION AND MOBILITY
ORANGE GENERAL PLAN
CM-6
On-street parking is prohibited on commercial access streets to provide
adequate curb-to-curb width for travel lanes.
Regional Circulation System
Mobility in Orange is directly related to the regional transportation network, as the City lies
at the confluence of several regional freeways: the Santa Ana Freeway (Interstate 5), Orange
Freeway (State Route [SR] 57), Garden Grove Freeway (SR-22), Costa Mesa Freeway (SR-55),
Riverside Freeway (SR-91) and Eastern Transportation Corridor (SR-241). In addition to the
freeways, other connections to the region include the commuter rail system known as
Metrolink, a freight and goods rail transport system, and a regional bikeways system with
connections to the Santa Ana River and other locations. Orange is also connected to the
region via the Orange County Transportation Authority (OCTA) bus system. City
infrastructure must accommodate regional through traffic originating in other communities
in addition to providing local residents access to the regional network.
GOAL 2.0: Provide an effective regional transportation network.
Policy 2.1: Ensure consistency with the County MPAH in order to qualify for funding
programs.
Policy 2.2: Coordinate with adjacent cities to plan and develop major east/west and
north/south arterials and rapid transit to connect the City with the cities of
Anaheim, Tustin, Santa Ana, Garden Grove, and Villa Park, as well as
developing areas within the City’s sphere of influence.
Policy 2.3: Cooperate with and support local and regional agencies’ efforts to improve
regional arterials and transit in order to address increasing traffic congestion.
Policy 2.4: Coordinate land use planning with anticipated future development of
roadways and other transportation facility improvements as well as the
expansion of commuter rail and bus service.
Policy 2.5: Ensure that transportation facilities and improvements do not degrade the
quality of Orange’s commercial and residential areas.
Policy 2.6: Encourage the use of regional rail, transit, bicycling, carpools , and vanpools
for work trips to relieve traffic congestion.
Policy 2.7: Continue to support the use of rail corridors within the City for the movement
of freight and goods, and work with rail operators to minimize associated
traffic delays.
Public Transportation
Public transportation is a crucial component of a comprehensive circulation system. In
addition to reducing air pollution and traffic congestion, a successful public transit system
provides an alternative mode of travel for those with limited mobility, residents who may not
have access to a car, and persons who choose not to drive.
GOAL 3.0: Connect centers within the City to each other and to the region through
efficient and accessible public transportation.
CIRCULATION AND MOBILITY
ORANGE GENERAL PLAN
CM-7
Policy 3.1: Work with OCTA and other agencies to assess City public transportation
needs and to ensure delivery of services when and where they are needed.
Policy 3.2: Enhance and encourage provision of convenient and attractive transit
amenities and streetscapes to encourage use of public transportation (e.g.,
benches, trash cans, shelters, and lighting).
Policy 3.3: Require incorporation of transit-oriented design features within major
commercial and employment areas as well as in medium density residential
and mixed-use development areas.
Sidewalks, Trails, and Bikeways
In addition to offering recreational and public health benefits, non-vehicular modes of
transportation offer commuting options. Also, the mixed-use environments advocated by
Land Use Element policies will encourage increased pedestrian activity on City sidewalks for
both business and pleasure. An effective pedestrian, bicycle, and equestrian network must
be safe and accessible, and must connect key activity centers within the City with each other
and with the regional trail system. A comprehensive network of on-street bicycle lanes, off-
street bicycle paths, sidewalks, and trails should be developed and maintained to increase
the safety and utility of the system, with a particular focus on the City’s sidewalk deficient
industrial areas
GOAL 4.0: Provide efficient and accessible modes of pedestrian, bicycle, and
equestrian transportation and improved facilities and amenities.
Policy 4.1: Create a comprehensive bicycle network that is integrated with other
transportation systems by establishing complementary on-street and off-
street facilities as identified in the City of Orange Bikeways Master Plan and
OCTA Commuter Bikeways Strategic Plan, including Santiago Creek, the Santa
Ana River, and the Tustin Branch Trail.
Policy 4.2: Install racks and safe storage facilities at parking areas for City facilities, as
appropriate, and encourage incorporation of such facilities within privately-
developed projects.
Policy 4.3: Improve citywide awareness of automobile and bicycle safety.
Policy 4.4: Encourage use of the bikeway system by providing adequate signage, trail
markings, and other amenities.
Policy 4.5: Ensure that pedestrian sidewalks, trails, and bikeways are safe environments
through the use of crime prevention-oriented trail design features, lighting
where appropriate, pedestrian and bicycle safety improvements at at-grade
rail crossings, access for emergency vehicles, and links to the roadway signal
system.
Policy 4.6: Explore opportunities to convert abandoned rail corridors into segments of
the City’s bikeway and pedestrian trail system.
Policy 4.7: Provide ADA accessible sidewalks and pedestrian amenities throughout the
City.
CIRCULATION AND MOBILITY
ORANGE GENERAL PLAN
CM-8
Policy 4.8: Expand and maintain an equestrian trail network and provide for appropriate
staging areas and infrastructure.
Parking Facilities
A shortage of parking can cause circulation problems and could lead to a reduction or loss of
business activity. Old Towne Orange has been identified as an area of particular concern. As
the City develops, providing adequate parking adjacent to other activity centers is
increasingly important.
GOAL 5.0: Provide adequate parking to meet the needs of activity centers throughout
the City.
Policy 5.1: Provide adequate parking to protect and support the economic vitality and
diversity of Old Towne.
Policy 5.2: Plan for and design parking facilities throughout the City that are adequate to
meet demand, but also consider land use-parking efficiencies, and the
surrounding natural and built environment.
Policy 5.3: Encourage adjacent businesses to consolidate parking facilities and access
points.
Policy 5.4: Encourage well-designed structured parking in commercial areas where such
features would be economically feasible, safe, and visually integrated with
existing development.
Circulation System Aesthetics
Streets that have been made or modified to include visual and pedestrian amenities can
improve the overall look and feel of City streets, as well as enhancing functionality for all
users. As major commercial corridors are beautified and changed to include a pleasant
pedestrian environment, this will have positive effects on the feelings of safety and security
for pedestrians, bicyclists, and motorists.
GOAL 6.0: Provide roadway corridors that are aesthetically pleasing and contribute to
a feeling of safety, security, and comfort for motorists, bicyclists, and
pedestrians.
Policy 6.1: Supply adequate, clear, and correctly placed signage to direct both motorists
and non-motorists toward destinations and away from hazards.
Policy 6.2: Provide clear indicators in the right-of-way for where pedestrians and
bicyclists are encouraged to walk, bike, or cross safely. These may include
special paving, line stripes, and crosswalks.
Policy 6.3: Provide lighting, landscaping, street trees, and other appropriately scaled
streetscape features that accommodate all users on commercial corridors.
Where appropriate, lighting should be scaled for autos as well as pedestrians.
CIRCULATION AND MOBILITY
ORANGE GENERAL PLAN
CM-9
CIRCULATION & MOBILITY PLAN
The objective of the Circulation & Mobility Plan is to document existing transportation
facilities in the planning area used for the movement of people and goods. The Element
addresses the desired future condition of these facilities, and their relationship to future land
uses identified in the Land Use Element. The Plan describes the circulation system, including
the arterial network and intersections, the public transit system, bicycle paths, recreation
facilities, parking, and railroad operations. The City’s circulation network includes an
extensive system of roadways, bus transit service, commuter rail, and freight rail.
Local Circulation System
A well-designed local arterial roadway system that connects to a well-developed regional
circulation system provides safe and convenient access to employment, housing, recreation,
and commercial areas in Orange. City arterial roadways located on the western side of SR-55
generally follow north-south and east-west orientations. On the eastern side of the freeway,
arterials are characterized by curvilinear streets due to undulating geographical
surroundings. Key north-south arterials include Tustin Street, Glassell Street, Main Street, and
The City Drive. Key east-west arterials include Chapman Avenue, Katella Avenue, Taft
Avenue, and parts of La Veta Avenue. These arterial roadways are in turn supported by a
network of collector and local streets that provide access to homes and businesses
throughout the City.
Roadway Classification System
The City’s roadway network is distinguished by a hierarchical classification system that
differentiates roads by size, function, and approximate daily capacity based upon Level of
Service D (LOS D). LOS is a qualitative measure that characterizes traffic congestion on a
scale of A to F with LOS A representing a free-flow condition and LOS F representing extreme
congestion. LOS standards can apply to either intersections or links (a section of street
between two intersections). Generally speaking, LOS represents the ability of a roadway or
an intersection to accommodate traffic.
In the City, intersections are used as actual control points. City roadways consist of both
divided and undivided roadways. Divided roadways generally contain a physical barrier or
buffer, such as a raised median or a continuous two-way left turn lane, between each
direction of travel. Divided roadways remove vehicles making a left turn from the travel lanes
so as not to impede through traffic and constrict roadway capacity. Undivided roadways do
not contain a buffer between each direction of travel, and therefore left-turning traffic can
impede through traffic. Undivided roadways may provide turn movement pockets at
intersections. The six categories of roadways in Orange are summarized in Table CM-1.
Proposed cross-sections for each type of roadway are shown in Figure CM-1.
The City’s policy is to use a link capacity standard of LOS D. The following paragraphs
represent link capacities of each roadway type at LOS D.
CIRCULATION AND MOBILITY
ORANGE GENERAL PLAN
CM-10
Smart Streets are typically four- to eight-lane roadways with enhanced capacity and
smoother traffic flow than standard arterial streets. These streets have enhanced features
such as traffic signal synchronization, bus bays, intersection improvements, and the addition
of travel lanes by removing on-street parking and consolidating driveways. The traffic
carrying capacities of Smart Streets can range from 60,000 to 79,000 vehicles per day,
depending on the number of lanes, degree of access control, peak period loading, and the
configurations of major intersections.
Principal Arterials are typically eight-lane divided roadways with medians or continuous two-
way left turn lanes. They can accommodate up to 67,500 vehicles on an average weekday at
LOS D conditions, depending on the degree of access control, peak period traffic loadings,
and lane configurations at major intersections. Principal arterials prohibit on-street, curbside
parking, and connect directly to freeways.
Major Arterials are six-lane divided roadways with medians or continuous two-way left turn
lanes. They can accommodate up to 50,700 vehicles on an average weekday at LOS D
conditions, depending on the degree of access control, peak period traffic loadings, and lane
configurations at major intersections. Major arterials facilitate traffic circulation within
Orange, and also prohibit on-street, curbside parking.
Primary Arterials are four-lane divided roadways with medians or continuous two-way left turn
lanes. They can accommodate up to 33,750 vehicles on an average weekday at LOS D
conditions, depending on the degree of access control and peak period loadings. Primary
Arterials provide for easy circulation in the City, and allow for limited on-street, curbside
parking.
Secondary Arterials are four-lane undivided roadways without medians. They can
accommodate up to 21,600 vehicles on an average weekday at LOS D conditions, depending
on the degree of access control and peak period loadings. Secondary arterials allow for on-
street, curbside parking.
Table CM-1
Roadway Classifications
Classification Facility Type Characteristics
Smart Street Smart Street 4-8 lane divided, with possible signal coordination, intersection capacity
improvements and/or grade separations
Principal Arterial 8 Lane Divided Primarily serves through traffic with limited local access
Major Arterial 6 Lane Divided Serves mostly through traffic with some local access allowed
Primary Arterial 4 Lane Divided Serves through and local traffic
Secondary Arterial 4 Lane Undivided Serves through and local traffic
Collector Street 2 Lane Serves mostly local traffic
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CM-11
Figure CM-1
Roadway Cross Sections
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CM-12
Collector Streets are typically two-lane roadways without medians that gather and distribute
traffic to higher-capacity arterials. They can accommodate up to 10,800 vehicles per average
weekday at LOS D conditions, depending on the degree of access control and peak period
traffic loadings. Centerline striping is typically not provided on collector streets, and on-street
parking is allowed. There are several types of two-lane streets in the City, including divided,
undivided, residential, and collector streets. Each type serves a slightly different purpose and
may have different capacity thresholds based on various factors.
Performance Criteria
Evaluating the ability of the circulation system to serve residents and businesses in Orange
requires establishing performance criteria. Performance criteria have a policy component
that establishes a desired LOS, and a technical component that specifies how traffic forecast
data can be used to measure criteria achievement.
The LOS definition for intersections is based on a volume-to-capacity (V/C) ratio and provides
a more quantitative description of traffic conditions. Table CM-2 presents LOS based on
traffic volumes and the design capacity of intersections.
Table CM-2
Level of Service Definitions for Intersections
Level of
Service
Volume-to-Capacity
Ratio Description
A 0.00-0.60 Free Flow/Insignificant Delays: No approach phase is fully utilized by traffic and
no vehicle waits longer than one red indication.
B 0.61-0.70 Stable Operation/Minimal Delays: An occasional approach phase is fully
utilized. Many drivers feel somewhat restricted within platoons of vehicles.
C 0.71-0.80 Stable Operation/Acceptable Delays: Major approach phases fully utilized.
Most drivers feel somewhat restricted.
D 0.81-0.90 Approaching Unstable/Tolerable Delays: Drivers may have to wait through
more than one red signal indication. Queues may develop but dissipate rapidly,
without excessive delays.
E 0.91-1.00 Unstable Operation/Significant Delays: Volumes at or near capacity. Vehicles
may wait through several signal cycles. Long queues form upstream from
intersection.
F N/A Forced Flow/Excessive Delays: Represents jammed conditions. Intersection
operates below capacity with low volumes. Queues may block upstream
intersections.
Source: Highway Capacity Manual, Transportation Research Board, Special Report No. 209, Washington DC, 2000.
Although roadway capacity is generally a function of peak hour intersection performance
and the corresponding peak hour volumes, daily arterial segment capacities (link capacities)
also provide a measure of the overall LOS of the arterial system. Generally, traffic impact
mitigation focuses on peak hour intersection performance, since system performance is
typically a function of intersection performance. The City’s policy is to use a link capacity
standard of LOS D. Table CM-3 presents arterial daily capacities at LOS D and LOS E.
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Table CM-3
Arterial Daily Capacity Threshold Assumptions
Street Type
Daily Capacity
LOS D LOS E
Smart Street – 6- to 8-lane divided 71,100 79,000
Principal – 8-lane divided 67,500 75,000
Major – 6-lane divided 50,700 56,300
Primary – 4-lane divided 33,750 37,500
Secondary – 4- lane undivided 21,600 24,000
Collector – 2-lane undivided 10,800 12,000
Source: City of Orange General Plan Update Traffic Report, 2008.
Various LOS policy standards have been established to evaluate observed traffic conditions,
future development plans, and circulation system modifications. At the local level, the City of
Orange has established LOS D as the lowest acceptable level of service for both roadway
segments and peak-hour signalized intersection movements. At the regional planning level,
Orange County’s Congestion Management Plan (CMP) specifies LOS E as the operating
standard for roadways and intersections on the CMP highway system. The CMP Highway
System consists of the Orange County smart street network plus the state highway system.
Thus, the SR-55 northbound and southbound ramps at Katella Avenue are CMP intersections
within the City’s jurisdiction. The City does not have an adopted LOS standard for
unsignalized intersections. Performance of unsignalized intersections is evaluated on a case-
by-case basis.
In addition to the LOS standards for roadways and intersections, the California
Environmental Quality Act (CEQA) Guidelines (Section 15064.3), require “vehicle miles
traveled” (VMT), to measure transportation impacts on the community. VMT refers to the
amount and distance of automobile travel attributable to a project.
For purposes of compliance with CEQA, a significant impact would occur if the baseline
and/or cumulative project-generated VMT per service population (population plus
employment) exceeds the anticipated City of Orange General Plan Buildout VMT per service
population. One vehicle traveling one mile would generate one VMT. Additionally, the
project’s effect on VMT would be considered significant if it resulted in the baseline and/or
cumulative link-level boundary citywide VMT per service population increases under the plus
project condition compared to the no project condition. Link-level boundary VMT is
calculated by summing all weekday VMT on a roadway network within the City boundary and
includes all trips including trips that pass through the City’s roadway network but do not
start and end with in City.
These thresholds are designed to reduce the number of miles traveled by automobiles, and
are implemented within the City of Orange Traffic Impact Analysis Guidelines.
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CM-14
In order to maximize the efficiency of its circulation system, the City will look at where
physical improvements to the circulation infrastructure can be made to expand capacity and
increase traffic flow. To maximize efficiency of the road system, the City will support traffic
signal coordination and spacing, and will
also discourage on-street parking along
arterials. In addition, the City will
explore ways to reduce the demand for
vehicular transportation, specifically
through the provision and maintenance
of bike lanes, bikeways, and trails, and
will also encourage additional regional
transit services and support facilities.
The City’s Transportation Demand
Management (TDM) ordinance (Chapter
10.83 of the Municipal Code) further
specifies a variety of techniques
available to employers with 100 or more
employees to advance the goals of efficiently utilizing the existing and planned
transportation system and reducing vehicle emissions.
City Master Plan of Streets and Highways
Land Use Element policy will allow land use changes and intensification to occur in specific
focus areas within the City. The City’s Master Plan of Streets and Highways displayed in
Figure CM-2 has been developed in close coordination with land use policy to ensure that
traffic generated by new development will not compromise the City’s goal to ensure that
intersections and roadway segments operate efficiently. The map identifies components of
the City’s roadway circulation system. The map also indicates where augmented roads are
needed, and pinpoints locations for enhanced intersections, including the future Meats
Avenue interchange at SR-55. Although most of Orange is already built out, most remaining
developable land is located in the eastern part of the City. New development in east Orange
will require construction of new roads to provide circulation and traffic flow to residents and
businesses. Land Use Element policies enabling reuse and redevelopment within established
portions of the City, particularly within the focus areas, may also necessitate roadway
widening and intersection enhancements. The City will continue to collect funds for
necessary circulation system capital improvements through a program that sets up a fee
structure for all new development and redevelopment projects. This program will require
developers to pay their fair share for transportation system improvements required by new
projects. The City will use the annual seven-year Capital Improvement Program (CIP) process
to prioritize, fund, and complete improvements required to achieve build-out of the
proposed roadway system identified in Figure CM-2.
Roadway Widening
Roadway widening in specific locations will be necessary to obtain new travel lanes.
Additional travel lanes may be acquired either by obtaining additional rights-of-way as
necessary or by constructing new lanes within existing rights -of-way. Parking restrictions
may be applied to allow additional lanes to be provided within existing rights-of-way.
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Old Towne Street Network
The Old Towne street network is a clear example of Orange’s grid street pattern. Parallel
roadways have been established in both the north-south and east-west direction to
distribute traffic evenly. The Plaza area at Glassell Street and Chapman Avenue is a unique
feature that creates discontinuous traffic flows along these two primary roadways. However,
no plans have been made to modify the National Register-listed Historic Plaza to increase its
traffic carrying capacity.
CM-15
Figure CM-2 City Master Plan of Streets and Highways
GPA 2014-0001 (12/8/15)
GPA 2010-0001 (8/10/10)
CM-16
(This Page Left Intentionally Blank)
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ORANGE GENERAL PLAN
CM-17
In light of these conditions, parallel roadways such as Almond Avenue, Palmyra Avenue,
Lemon Street, Olive Street, Shaffer Street, Grand Street, Palm Avenue, and Maple Street will
continue to serve as local collectors around The Plaza.
Metropolitan Drive Extension
Extending Metropolitan Drive behind the University of California, Irvine (UCI) Medical Center
will help facilitate the movement of north-south traffic near The Block at Orange shopping
area, improve access to Interstate 5 (I-5), and relieve congestion on The City Drive.
Metropolitan Drive will be extended from The City Drive/State College Boulevard to the
Metropolitan Drive/Rampart Street connection.
Critical Intersection Program
Intersections serve as traffic control points for the circulation system, regulating the flow of
vehicles along City streets and sometimes limiting the capacity of the system. In the long
term, system capacity and efficiency can both be increased if intersections are designed to
handle future anticipated traffic volumes. Typically, the design of the roadways forming an
intersection dictates the intersection configuration. Department of Public Works standards
indicate that a left-turn pocket may or may not be provided, depending on traffic volumes
through the intersection. However, one pocket may not be adequate to handle vehicles
during peak hours. Traffic may back up into a through travel lane, resulting in congestion at
the intersection and at other locations along the roadway.
One way of providing additional intersection capacity at critical locations is through the use
of special intersection configurations known as “critical intersections.” Critical intersections
deviate from typical City design standards by increasing the number of lanes at an
intersection beyond what typically would be required. By increasing capacity at the
intersection, the circulation link increases overall system capacity.
The Master Plan of Streets and Highways (Figure CM-2) identifies the locations of critical
intersections within Orange. A list of these intersections and diagrams depicting their
geometries are on file in the Public Works Department.
Regional Roadway System
The City’s local circulation network is connected to an efficient regional circulation system.
Figure CM-2 shows the freeways that traverse the Orange planning area. The Santa Ana
Freeway (I-5) provides interstate and regional access to the City. In addition, SR-57, SR-55,
and SR-22 all provide connections to the City from northern Orange County and neighboring
Los Angeles County, San Diego County, Riverside County, and San Bernardino County. SR-91
and SR-241 provide additional, more limited freeway access. SR-241 is a toll facility controlled
by the Transportation Corridor Agency (TCA).
I-5 is a northwest-southeast freeway that passes through the southwest corner of the City,
and provides direct access to Los Angeles County to the north and San Diego County to the
south. I-5 has two interchanges within Orange—one located at its junction with SR-57 and
SR-22 (commonly known as the Orange Crush) and the other at State College Boulevard/The
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ORANGE GENERAL PLAN
CM-18
City Drive. The junction at the Orange Crush currently has the most severe congestion, which
directly affects the roadway system in the City. With projected future growth in Orange and
in the region, traffic flow at this junction is expected to worsen. The City will continue to
work with and support the efforts of local and regional agencies to mitigate the increased
traffic congestion in this area.
SR-91 is an east-west freeway that provides access to key arterial facilities in Orange,
including interchanges at Tustin Street and Glassell Street. SR-91 also provides regional
access through interchanges with SR-55 and SR-57 and SR-241.
SR-22 is an east-west freeway that crosses through the southern portion of the City. Five SR-
22 interchanges are located in the City, at Tustin Street, Glassell Street, Main Street/La Veta
Avenue, Bristol Street, and The City Drive.
SR-55 is a north-south freeway that passes through the center of Orange, and provides
access to the coastal communities of Orange County. SR-55 has four interchanges in Orange,
located at Lincoln Avenue, Katella Avenue, Chapman Avenue, and SR-22. An additional future
interchange at Meats Avenue is contemplated within this General Plan.
SR-57 is a north-south freeway that originates at the junction of I-5 and SR-22 and extends to
San Dimas in Los Angeles County. It provides access for the eastern parts of Los Angeles
County, and central and northern parts of Orange County. SR-57 has three interchanges in
Orange, at Chapman Avenue, Orangewood Avenue, and the junctions of I-5 and SR-22.
The Eastern Transportation Corridor (SR-241) is a north-south toll facility located in the
eastern portion of the planning area. This facility provides direct access to east Orange. SR-
241 has three toll lanes in each direction and provides regional access through an interchange
at Santiago Canyon Road.
Consistency with County Master Plan of Arterial Highways
Maintaining consistency with the County’s Master Plan of Arterial Highways (MPAH) is
required in order to ensure that the City’s circulation system develops in a manner that
promotes regional mobility. At a practical level, consistency is also required in order for the
City to receive transportation funding under Measure M. Orange’s Master Plan of Streets and
Highways (Figure CM-2) is generally consistent with the MPAH.
While the City’s Master Plan of Streets and Highways has been consistent with the County
MPAH to maintain funding eligibility, both the City of Orange and OCTA have the goal of a
realistic and implementable MPAH. In keeping with this spirit, in 2010 as a follow up to
adoption of this General Plan, the City worked with OCTA on amendments to the MPAH and
Master Plan of Streets and Highways that downgraded the long-standing classification of
Chapman Avenue and Glassell Street from 4-lane Primary Arterials to 2-lane Collector Streets,
and removed the Critical Intersection classification of the Plaza. A remaining desire of the
City is to work with OCTA to downgrade La Veta Avenue between Glassell Street and
Cambridge Street from a Secondary Arterial to a Collector Street to reflect physical
constraints related to historic buildings and features in the Old Towne National Register
Historic District.
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CM-19
To initiate the MPAH amendment process, a local agency must submit a written request to
OCTA describing the amendment requested and provide documentation to support the basis
for the request. A copy of the request must be submitted concurrently to the City Managers
of adjoining cities. For the facilities under consideration, this would require a letter to be
forwarded to the City of Santa Ana.
Once the initial request is forwarded to OCTA, a conference between the City of Orange,
OCTA, and potential affected jurisdictions is held to determine whether mutual agreement
exists for the MPAH amendment. If mutual agreement exists, then Orange is expected to
proceed with adopting this revision to the Circulation & Mobility Element. Upon adoption,
the City of Orange would submit the Circulation & Mobility Element to OCTA and request
OCTA Board approval of the Orange County MPAH amendment.
Public Transportation
Effective regional transportation strategies are required to successfully implement City and
County plans for accommodating future growth. Such strategies must link the City of Orange
with other regional employment and commercial centers, as well as airports and other
transportation hubs, and should fully integrate alternatives to the automobile. Alternative
modes of transportation, including public transportation, bicycling, and walking, are
important components of a comprehensive circulation system. These modes of
transportation also help reduce air pollution and road congestion.
Public transportation plays a key role in future land use development and mobility. As the
roadway system reaches capacity, alternative modes of transportation provide additional
capacity as well as an enhanced degree of mobility for residents, workers , and visitors.
Existing services are expected to continue while enhancements, many of them currently in
the planning stages, will increase the viability of alternative modes of travel. The integration
into the circulation system of alternative modes of transportation, such as bus, rail, bicycle,
and pedestrian, is essential to maximizing mobility opportunities for residents, workers, and
visitors.
Bus Service
OCTA provides public bus service for the City of Orange. In addition, the Riverside Transit
Agency (RTA) provides long-distance service between The Village at Orange and the
Downtown Terminal in Riverside. Table CM-4 identifies local bus routes that connect various
activity centers in Orange to each other and to the region.
Table CM-5 shows the different community, station link, and inter- or intra-County routes that
serve Orange. Community routes are express bus routes that provide faster connections to
activity centers within and outside Orange County. Station link shuttles provide services
between the Orange Transportation Center (OTC) and Orange. Both community and station
link routes operate only at peak commuter times.
In addition to the fixed-route service, OCTA also offers several types of specialized
community transportation services, such as standard service (curb-to-curb service), door-to-
door service, subscription service, and same-day taxi service. Some of these services cater to
senior citizens and people with disabilities residing in the City.
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OCTA has forecast bus ridership to increase by approximately 75 percent by 2030. Some of
this ridership increase will be the result of enhanced services, including express bus routes
and introduction of bus rapid transit service. Much of the increase will be driven by increased
arterial and freeway congestion levels in conjunction with improved local bus service. OCTA
is planning to introduce bus rapid transit (BRT) services by 2011 on the Bristol Street-State
College Boulevard, Harbor Boulevard, and Westminster Avenue corridors. This service would
include planned BRT stops in Orange on State College Boulevard south of Orangewood
Avenue and on The City Drive south of Chapman Avenue. With the projected success of this
service, which is comparable to the Los Angeles Metro Rapid service, it is likely that BRT will
be implemented on other key corridors. Corridors that have been considered for potential
future application include Katella Avenue.
Convenient, accessible, frequent, and easy-to-use public transit is a cornerstone element of
the proposed land use plan. Planned mixed-use residential and commercial areas and
intensified commercial and professional office corridors must be coupled with increases in
transit service. Orange’s land use plan features mixed-use districts that strategically
concentrate population density near alternative transit facilities, such as the OTC in Old
Towne, transit hubs at The Block at Orange and South Main Street, and the future Anaheim
Regional Transportation Intermodal Center station in Anaheim near the City’s western
boundary at Katella Avenue.
Table CM-4
Local Bus Routes
Route # Route Type Route Service Service Corridors Key Orange Activity Centers Served
24 Local Fullerton–Orange Malvern Ave. / The Village at Orange
Chapman Ave. / Lincoln Park and Ride
Tustin St..
42 Local Orange–Seal Beach Lincoln Ave. / The Village at Orange
Los Alamitos Blvd. / Lincoln Park and Ride
Seal Beach Blvd.
46 Local Los Alamitos–Orange Ball Rd. / The Village at Orange
Taft Ave. Lincoln Park and Ride
47 Local Brea–Newport Beach Brea Blvd. / Theo Lacy Jail
Anaheim Blvd. / Orangewood Children's Home
Fairview St. UCI Medical Center
The Block at Orange
50 Local Long Beach–Orange Katella Ave. The Village at Orange
Lincoln Park and Ride
53 Local Brea–Irvine Main St. Batavia Industrial Parks
Children's Hospital – CHOC
St. Joseph's Hospital
OCTA Offices
54 Local Garden Grove–Orange Chapman Ave. Orange Civic Center
Orange Transportation Center
The Plaza
UCI Medical Center
The Block at Orange
Rancho Santiago Community College
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Table CM-4
Local Bus Routes
Route # Route Type Route Service Service Corridors Key Orange Activity Centers Served
56 Local Garden Grove–Orange Garden Grove Blvd. Orange Transportation Center
OCTA Offices
Children's Hospital–CHOC
St. Joseph's Hospital
57 Local Brea–Newport Beach State College Blvd. / The Block at Orange
Bristol St. UCI Medical Center
Theo Lacy Jail
Orangewood Children's Home
59 Local Brea–Irvine Kraemer Blvd. / Orange Transportation Center
Glassell St. / Chapman University
Grand Ave. / Orange Plaza
Von Karman Ave.
71 Local Yorba Linda–Balboa Tustin St. / The Village at Orange
Red Hill Ave. / Lincoln Park and Ride
Newport Blvd.
Source: Orange County Transportation Authority, 2006
Table CM-5
Community, Station Link, Intra- and Inter-County Bus Routes
Route # Route
Type Route Service Service Corridors Key Orange Activity Centers Served
131 Community Yorba Linda–Orange Lakeview Ave./ The Village at Orange
Riverdale Ave. / Lincoln Park and Ride
Tustin St.
147 Community Brea–Santa Ana Raiit St. / UCI Medical Center
Greenville St. / The Block at Orange
Fairview St. OCTA Offices
St. Joseph's Hospital
Children's Hospital – CHOC
167 Community Anaheim–Irvine Santiago Blvd. / The Village at Orange
Hewes St. / Lincoln Park and Ride
Bryan Ave.
453 Station Link Orange Transportation
Center Chapman Ave. / Orange Transportation Center
–St. Joseph's Hospital Main St. / Children's Hospital–CHOC
La Veta Ave. St. Joseph's Hospital
OCTA Offices
454 Station Link Orange Transportation
Center Chapman Ave. / Orange Transportation Center
–The Block at Orange Metropolitan Dr. UCI Medical Center
The Block at Orange
Bergen Brunswig
Nexus
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Table CM-5
Community, Station Link, Intra- and Inter-County Bus Routes
Route # Route
Type Route Service Service Corridors Key Orange Activity Centers Served
213 Intra County Brea–Irvine Express SR-55 Lincoln Park and Ride
The Village at Orange
757 Inter County Diamond Bar SR-57 UCI Medical Center
–Santa Ana Express The Block at Orange
RTA 149 Inter County Riverside–Orange SR-91 The Village at Orange
(Operated by RTA) Downtown Riverside
Source: Orange County Transportation Authority and Riverside Transit Agency, 2006.
The City recognizes that ridership of both the bus and rail transit systems will increase, and
has designed a land use plan that both enables and accommodates increased transit use. A
large part of the City’s role in accommodating additional transit use includes providing
convenient and attractive transit amenities and streetscape features that improve user
comfort and perception of safety, thus encouraging transit use. Transit-oriented
Development (TOD) design features will be encouraged in major commercial and
employment areas within the City, such as the Town and Country Road corridor, South Main
Street, Katella Avenue, Uptown Orange, and Old Towne. Such TOD features may consist of
streetscape measures such as bus turn-outs, benches, trash receptacles, shelters from wind
and rain, and lighting. TOD features may also be more fundamental to the permitted uses
and design within projects, such as incorporating child care centers, convenience stores, or
personal services within the retail component of mixed-use projects, or near professional
office concentrations. These and other measures help to make the transit system more
accessible to a wide range of people.
The City will continue to work with OCTA to pursue expanded community circulators, such as
the current Station Link service, that will connect people to rail transit, employment centers,
residential areas, and commercial corridors. Additional options, such as jitney services that
function as group taxis, will also be explored.
The City will also continue to support OCTA initiatives and services that promote the mobility
of Orange’s senior, disabled, and youth populations. To accommodate the needs of these
groups, the City will continue to work with OCTA to offer para-transit services, and will seek
ways to improve mobility for Orange youth through transit.
The City of Orange will continue to cooperate with OCTA and other regional providers to
establish new bus routes and stops, and to provide transit amenities. New subdivision plans
will be reviewed by OCTA to assess impacts on bus services, and to examine the need to
provide bus stops or bays. Orange will also work with OCTA to maintain and, if needed,
expand successful transfer stations in Old Towne, the Village at Orange, and The Block at
Orange.
Rail Transit
Many current passenger and commuter fixed-rail transit options in the City will be expanded
in the future, offering significant alternatives to automobile transit for many individuals who
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ORANGE GENERAL PLAN
CM-23
commute to or from the City for housing or employment. Rail transit now has a proven track
record in Orange, and Metrolink seeks to expand rail services in support of land use
transformations near current and future rail stations.
Metrolink
Metrolink operates seven commuter rail lines in Southern California, two of which pass
through Orange. The Orange County Line offers direct connections to Union Station in Los
Angeles to the north and to Oceanside to the south. The Inland Empire–Orange County Line
provides direct connections to Riverside/San Bernardino to the east and San Juan Capistrano
to the south. Roughly 30 Metrolink trains pass through the City on a daily basis. The
Metrolink station in Orange is located three blocks from The Plaza at the OTC, close to a
variety of stores and civic uses in Old Towne. Amtrak and Metrolink operate a cooperative
program called “Rail-2-Rail”, which allows all Metrolink monthly pass holders to use Amtrak
within the limits specified on the pass.
Another much-anticipated rail service improvement is intra-county rail service along the
County’s core transit corridor. This service, which will be provided by Metrolink on behalf of
OCTA, is an attempt to provide intra-county trips with a high degree of reliability. This 30-
minute service is planned to operate between the Irvine Transportation Center (and possibly
Laguna Niguel) and the Fullerton Transportation Center throughout the day to supplement
Metrolink’s peak period commuter service.
The City recognizes that plans to increase daily service on the current Metrolink lines,
improvements to the OTC, and future expansion of Metrolink services to new destinations
would be beneficial to Orange by providing multi-modal transportation options for people
living and working in the community, thus reducing auto dependence for business and leisure
purposes.
Anaheim Regional Transportation Intermodal Center
The Platinum Triangle, which borders Angel
Stadium in the City of Anaheim, proposes a
variety of high-density multiple-family high-rise
housing, office space, and commercial uses.
The Anaheim Regional Transportation
Intermodal Center (ARTIC) is located adjacent
to the proposed development, between Angel
Stadium and the Honda Center. ARTIC will be a
major regional transportation center similar in
scale to Union Station in Los Angeles and
Ontario International Airport in Ontario. The
intermodal center will be a stopping point for
Amtrak, Metrolink, buses, and future high-
speed rail systems that connect to Ontario Airport, Las Vegas, and the Bay Area.
The City of Orange will coordinate with the City of Anaheim, OCTA, and others to ensure that
the City is able to take full advantage of the regional mobility benefits offered by ARTIC.
Potential benefits offered to the City by ARTIC include:
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BRT service along Katella Avenue;
a dynamic mixed-use commercial and residential center at the westernmost end of
Katella Avenue; and
bicycle and pedestrian connections to the Santa Ana River.
California High Speed Rail Corridor
The California High-Speed Rail Authority was established as a state agency in 1996 to direct
the planning, design, construction, and operation of a future high-speed train system
extending from Sacramento, San Francisco, and Oakland in the north to Los Angeles and San
Diego in the south. This high-speed train is proposed to stop at ARTIC. OCTA estimates that
by 2025, the California High Speed Rail Corridor will serve between 150,000 and 230,000
passengers each week.
Magnetic Levitation Train
A magnetic levitation train is being planned that would connect Anaheim to Ontario,
Victorville, Barstow, Primm, and Las Vegas. The California-Nevada Super Speed Train (SST)
will use Magnetic Levitation Systems (Maglev), a type of transportation technology that uses
electric power and non-contact electromagnetic levitation to sustain speeds in excess of 300
mph.
The trip from ARTIC to Las Vegas on the California-Nevada SST will take about 90 minutes,
with an estimated 40.4 million annual riders. A key future benefit offered by the Maglev train
is a high-speed connection to Ontario International Airport, which is planned to grow
substantially and to expand international service in coming decades. The City will support
efforts of the California High-Speed Rail Authority, OCTA, and Southern California Association
of Governments to construct these important rail corridors, and will cooperate with all
parties involved in any future studies conducted to examine the noise and other impacts
associated with the corridors within Orange.
Sidewalks, Trails and Bikeways
Walking and biking contribute to a healthy community, and play increasingly significant roles
as alternatives to the automobile. The City recognizes this by providing and maintaining
sidewalks, trails, and bikeways to support pedestrians and cyclists.
Pedestrian Facilities
In addition to providing basic transportation routes, sidewalks and pathways offer the
opportunity to create appealing public spaces that reflect community pride and invite people
to walk. Proposed mixed-use areas and reinvigorated commercial areas throughout the City
will provide new and reinvented spaces for people to walk and shop. Walkability and access
are essential components of a circulation system that easily and specifically accommodates
pedestrians. Features that contribute to walkability include wide sidewalks, safe street
crossings, design elements that encourage cautious driving, and a pleasant and safe walking
environment. Sidewalks, walkways, well-designed pedestrian crossings, pathways, and
pedestrian short-cuts allow people to get from one destination point to another with ease.
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CM-25
Dedicated pedestrian paths can provide access between residential and activity areas,
especially if streets do not connect. Access strategies for school children, seniors, and people
with disabilities should also be incorporated into street and sidewalk plans. The City supports
proactive integration of pedestrian improvements and amenities within the circulation
system to improve walkability.
The City will create and implement a pedestrian-oriented streetscape master plan addressing
key commercial corridors, including Tustin Street, Chapman Avenue, Main Street, Lincoln
Avenue, and Katella Avenue. The master plan will address all functional aspects of the
pedestrian environment. It will identify pedestrian links that need improvement and
strengthening, determine new pedestrian links to underserved areas, ensure adequate
sidewalk widths to accommodate lighting and street trees, develop sidewalks in the
industrial area that create links between bus stops, encourage safe routes to schools and
recreation facilities, and minimize barriers to pedestrian and bicycle access.
Recreational Trails and Bikeways
A comprehensive network of recreational trails and bikeways greatly benefits Orange
residents and visitors by providing popular modes of transportation for recreation. In
addition to recreation activities, the City also supports walking and bicycling as viable
commute alternatives to the automobile. The City’s plan for recreational trails and bikeways
is shown in Figure CM-3.
The plan includes trails maintained by the County and private homeowners associations, and
is consistent with the OCTA Commuter Bikeways Strategic Plan. It is also consistent with the
County’s major riding and hiking trails and off-road paved bikeways. As described in the
Vision for the Future, the plan will enable the City to connect parks to activity centers and
residential areas using a combination of recreational trails and bikeways that truly allows
people to travel from place to place within the City without needing an automobile.
Recreational Trails
As shown in Figure CM-3, over 70 miles of existing recreational trails are located within the
City, connecting a large number of neighborhoods and community parks. In addition, 104
miles of proposed future trails are planned throughout Orange on land currently utilized for a
variety of purposes, including flood control, railroad rights-of-way, and roadways.
The City will use the annual seven-year Capital Improvement Program (CIP) process to
prioritize, fund, and build proposed trail segments identified in Figure CM-3. These trails have
been and will continue to be constructed and administered through cooperative efforts of
the City, County, developers, and private homeowner associations.
Desired cross-sections for recreational trails are identified in Figure CM -4. The City may
require construction of portions of proposed trails identified in Figure CM-3 as a condition of
development approval for projects located adjacent to the proposed trail alignments.
Funding for recreational trails and associated restoration projects comes from a variety of
federal, state, and regional sources. Priority for funding of trail improvements will be given to
projects that complete loops within the system, provide missing links for regional and local
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CM-26
trail systems, or serve as destination links to schools, parks, retail businesses, or regional
trails.
Priorities for the recreational trail system include:
trail connections to the Santiago Oaks Regional Park extension west of Cannon Street,
consisting of a connection between Calle Grande and Cannon Street, and the Jamestown
trail from the Orange Park Acres equestrian arena to Cannon Street;
trail connection from Serrano Avenue near Fred Barrera Park to Santiago Oaks Regional
Park;
Mabury Ranch Trail connection from the proposed Cerro Villa Park to the Santiago Oaks
Regional Park;
Serrano Avenue connection near Cannon Street; and
Additional trail connection into Santiago Oaks Regional Park from Orange Park Acres.
To increase the number of people using non-vehicular means of transportation, the City will
encourage putting in place a safe network of crosswalks, grade separations, and walkways to
ensure the safety of pedestrians, bicyclists, and equestrians. Where appropriate, traffic
calming devices and methods such as median landscaping and provision of bike or transit
lanes should be used to slow traffic, improve roadway capacity, and address potential safety
issues. The City will continue to work towards improving the overall condition, appearance,
and safety of both medians and sidewalks in Orange.
Bikeways
Orange’s relatively mild climate
permits bicycle riding year-round, and
the growing popularity of bicycling has
drawn enthusiasts onto the streets
and bike trails throughout the City. The
plan for recreational trails and
bikeways (Figure CM-3) shows the
planned system of bikeways within the
City. The Orange Bikeway Master Plan
has established three classes of bicycle
routes that adhere to California
Department of Transportation
(Caltrans) standards:
Class I Off-road bike paths are located on vacated rail lines, water corridors, or areas
otherwise separated from streets.
Class II On-road bike lanes are located along arterial roadways that are delineated by
painted stripes and other features.
Class III On-road bike routes share use with motor vehicle traffic. They provide a route
that is signed but not striped.
CM-27
Figure CM-3 Plan for Recreational Trails and Bikeways
CM-28
(This Page Left Intentionally Blank)
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CM-29
Figure CM-4
Trail Standards
Cross-sections for each type of route are shown in Figure CM-5.
As shown in Figure CM-3, several future bike routes are planned within Orange, including the
following high-priority projects:
Completing Class I bike routes along Santiago Creek and the Tustin Branch Trail
Establishing Class II bike lanes, including:
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Figure CM-5
Bikeway Standards
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o An east/west corridor on Walnut Avenue from the western City limits to
Santiago Boulevard
o North/south corridors on Main Street from Taft Street to Palm Street, on
Batavia Street from Chapman Avenue to La Veta Avenue, and on Parker
Street from La Veta Avenue to the City limits
Establishing Class III routes along Almond Street, Feldner Street, and Bedford Street
The City has recently completed a paved bike trail along Santiago Creek from Tustin Street to
the western City limit that continues on to Main Place Mall and the Discovery Science Center
as well as two additional segments to the bike trail, which will extend the Santiago Creek
Trail from Tustin Street to Grijalva Park, and also connect Grijalva Park at Santiago Creek to
Collins Avenue along the City-owned portion of the Tustin Branch Trail right-of-way between
Walnut and Collins Avenues. The Santiago Creek trail is planned to extend through and
beyond the City, connecting the regional Santa Ana River Trail to Santiago Oaks Regional
Park and wilderness areas east of Orange. The City will continue to work towards designing a
comprehensive bike trail system that is highly accessible and safe for those who wish to use
it.
The City has proposed Class II and III routes along many north-south and east-west arterials,
all of which connect to pedestrian trails and Class I routes. The City responds to the need to
provide safe and efficient bike travel by making every effort to provide bikeways separate
from the roadway. When bicyclists must share the road with automobiles, the City will work
to improve overall safety.
Currently, only one bicycle parking facility is located in Orange, at the OTC (Metrolink
station). The City will work to provide greater bike amenities including delineated bike lanes
and clear signage along bike trails. The City will also install bicycle racks and safe storage
facilities at parking areas for City facilities, as appropriate, and will require privately
developed projects to incorporate on-site bicycle facilities in accordance with the City’s
Zoning Code (Title 17 of the Orange Municipal Code).
Parking Facilities
Although parking is often considered a separate issue from vehicle circulation, it is important
to address on-street parking because it has a direct effect on roadway capacity. In order to
facilitate improved traffic flow along Orange’s major arterials, the City generally plans to
permit on-street parking only on streets
classified as Primary or Secondary
Arterials or Collector Streets.
Off-street parking deficiencies can
reduce business activity, and can cause
vehicles to re-circulate on public streets,
which increases traffic volumes and
congestion by reducing capacity for
through traffic. The City’s Zoning Code
includes parking requirements to ensure
that an adequate number of spaces are
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CM-32
provided on-site for most uses. The Code also establishes minimum stall dimensions
consistent with current standards for other jurisdictions. These regulations apply to all new
developments, and may be applied to current uses that are modified or expanded.
Particular concern has been expressed within the community regarding current and
expected future parking shortages in Old Towne. Figure CM-6 identifies the location of
existing public parking lots in Old Towne. Most Old Towne parking lots have a maximum time
limit of three hours, with or without a permit. However, some parking lots, such as the OTC
parking located off Chapman Avenue, have no time limit.
Orange will continue to provide sufficient parking to meet community demands. In Old
Towne, the City will study the benefits of creating a parking district and the feasibility of
developing underutilized parking lots surrounding The Plaza as public parking facilities. The
City may encourage the use of shared parking, consolidated parking facilities, and
underground parking or parking structures to provide additional off-street parking to meet
future demands in areas throughout the City with higher concentrations of commercial uses.
Circulation System Aesthetics
The City has determined that it is necessary and desirable to improve certain roadways and
their rights-of-way to enhance the experience for all users of these corridors. Major
commercial corridors have been designated within the Urban Design Element to be improved
with pedestrian-scale enhancements. Enhancements could include street trees, sidewalk
improvements, lighting, bus shelters, and crosswalks. These improvements not only offer a
more aesthetically-pleasing experience for all users in these corridors, they also may offer
increased safety and security.
Streetscape improvements offer safety and security to both motorists and non-motorists
through increased visual cues, better visibility, and increased activity. Many streetscape
enhancements provide not only a comfortable environment for the pedestrian and bicyclist,
but also offer drivers visual cues that a non-motorist could be expected in an area.
Improvements such as striping, bus shelters, and pedestrian-scaled signage guide the non-
motorist towards areas that are most appropriate for their use. These same cues help the
motorist to see where the presence of pedestrians and bicyclists is most likely to occur. For
example, a well-marked crosswalk guides the pedestrian towards the location in the right-of-
way most appropriate for crossing, while also alerting the motorist to slow down and look
out for pedestrian traffic.
Visibility offered by pedestrian-scaled lighting benefits non-motorists and motorists alike.
Pedestrians and bicyclists are better able to see their way, which increases their feelings of
security. Improvements that create a sense of security for pedestrians encourage increased
use and activity. This increased activity, in turn, leads to a greater feeling of safety. The City
has acknowledged the importance of improving the experience of users on many of its major
commercial corridors.
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CM-33
*Note: Possession of City issued parking permit enables holder to exceed specified time limit
GPA 2010-0001 (8/10/10)
Figure CM-6
Public Parking Lots in Old Towne Ora nge
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CM-34
CIRCULATION & MOBILITY IMPLEMENTATION
The goals, policies, and plans identified in this Element are implemented through a variety of
City plans, ordinances, development requirements, capital improvements, and ongoing
collaboration with regional agencies and neighboring jurisdictions. Specific implementation
measures for this Element are contained in the General Plan Appendix.
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IMP-28 GPA 2010-0001 (8/10/10)
III. Conditions or Requirements Placed upon Applicants
during Development Review
Program III-1 California Environmental Quality Act
Comply with all provisions of CEQA. In addition to thresholds that may be established or
adopted by the City in the future, use the following thresholds and procedures for CEQA
analysis of proposed projects, consistent with policies adopted within the General Plan:
Circulation & Mobility
o In accordance with CEQA Guidelines Section 15064.3, the City shall utilize vehicle
miles traveled (VMT), to measure transportation impacts.
o A project would result in a significant project-generated VMT impact if the baseline
and/or cumulative project-generated VMT per service population exceeds the City of
Orange General Plan Buildout VMT per service population.
o The project’s effect on VMT would be considered significant if it resulted in baseline
and/or cumulative link-level boundary citywide VMT per service population increases
under the plus project condition compared to the no project condition.
Parks and Recreation
o The City shall require dedication of parkland at a rate of 3.0 acres per 1,000
anticipated residents or payment of in-lieu fees for new residential projects.
Noise
o The City shall apply the noise standards specified in Tables N-3 and N-4 of the Noise
Element to proposed projects analyzed under CEQA.
o In addition to the foregoing, an increase in ambient noise levels is assumed to be a
significant noise impact if a proposed project causes ambient noise levels to exceed
the following:
Where the existing ambient noise level is less than 65 dBA, a project related
permanent increase in ambient noise levels of 5 dBA CNEL or greater.
Where the existing ambient noise level is greater than 65 dBA, a project related
permanent increase in ambient noise levels of 3 dBA CNEL or greater.
Historic and Cultural Resources
o “Historical resource” for the purposes of CEQA shall mean “historic district” in the
case of a contributor to a historic district.
o Historic resources listed in the Historic Register shall have a presumption of
significance pursuant to CEQA Section 21084.1 and shall be treated as historical
resources under CEQA.
o The historical significance of an archaeological historic resource is evaluated using
the criteria of Public Resources Code Section 5024.1 and Section 15064.5 et seq. of
the state CEQA Guidelines.
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IMP-29
All future development proposals shall be reviewed by the City for potential regional and
local air quality impacts per CEQA. If potential impacts are identified, mitigation will be
required to reduce the impact to a level less than significant, where technically and
economically feasible.
Agency/Department: Community Development Department, Public Works
Department, Community Services Department
Funding Source: General Fund, development fees
Time Frame: Ongoing
Related Policies:
Circulation & Mobility: 1.1, 1.2
Natural Resources: 2.2, 2.8, 5.6
Cultural Resources &
Historic Preservation: 1.1, 1.3
Noise: 1.4
Growth Management: 1.1, 2.1
Program III–2 Site Development Review
Comply with all City procedures in the review of proposed development projects, and use the
site plan review process to ensure that applicable General Plan policies and City standards
and regulations are applied to proposals for specific development projects.
Agency/Department: Community Development Department, Public Works
Department, Police Department, Fire Department,
Community Services Department
Funding Source: Development fees
Time Frame: Ongoing
Related Policies:
Land Use: 1.6, 1.7, 2.5, 2.7, 2.8, 3.1, 3.4, 4.3, 4.5, 6.1, 6.2, 6.9, 6.10, 6.12
Circulation & Mobility: 1.1, 1.7, 5.1, 5.2
Natural Resources 1.3, 2.3, 2.6, 2.13, 2.14, 2.15, 2.16, 4.3, 4.4, 4.5, 5.4, 5.6, 5.7,
6.6, 7.5
Cultural Resources &
Historic Preservation: 1.3, 1.4, 1.5, 1.6, 4.1, 4.2, 4.3, 4.4, 4.5
Public Safety: 1.1, 2.5, 3.3, 3.5, 4.2, 4.3, 6.2, 7.2, 7.3, 7.4, 9.1
Noise: 1.1, 1.2, 1.3, 1.4, 1.5, 1.6, 2.1, 2.2, 5.1, 5.2, 5.3, 6.1, 6.2
Urban Design: 2.4, 2.5, 2.6, 3.4, 3.5, 6.1
Infrastructure: 1.4, 1.5
Program III-3 Commission/Committee Review
Orange has several commissions and one committee whose purpose is to advise and assist
the City Council in dealing with issues related to each commission’s or committee’s area of
concern. The commissions and committee gather pertinent information, hear arguments,
IMPLEMENTATION
ORANGE GENERAL PLAN
IMP-30 GPA 2010-0001 (8/10/10)
weigh values, and make recommendations to the Council. Several of the commissions also
have some administrative powers.
The City will continue to use the commission/committee structure to inform the public
decision-making process.
The City will also consider expanding the authority of the Design Review Committee and
Community Development Department’s staff to administer the Orange Historic Resources
Inventory, Historic Register listings, and design review procedures for projects involving
architectural and archaeological resources.
Agency/Department: City Council, Community Development Department,
Community Services Department
Funding Source: General Fund
Time Frame: Ongoing
Related Policies:
Land Use: 2.5, 2.6, 2.7, 2.8, 3.1, 3.2, 4.5, 5.5, 5.8, 5.9, 6.1, 6.2, 6.3, 6.4,
6.7, 6.11, 8.1, 8.2, 8.3
Circulation & Mobility: 1.3, 2.3, 3.2, 4.1, 6.1
Cultural Resources &
Historic Preservation: 1.1, 1.3, 1.4, 4.5, 4.6
Urban Design: 1.1, 6.1
Public Safety: 1.1, 3.5, 4.3, 7.4
Economic Development: 1.2, 2.5, 3.3, 4.5, 5.1, 5.2, 5.3, 5.4, 5.5
Program III-4 Traffic Impact Analyses
Require preparation of traffic impact analyses for new discretionary development projects.
A traffic impact analysis which includes VMT assessment shall be required for a proposed
project that does not satisfy the project screening criteria. For projects that increase V/C by
0.01 or more on affected roadway segments or intersections experiencing LOS E or LOS F
conditions without the proposed project, traffic impact analyses must propose binding
reduction strategies to be incorporated within the project.
Continue to update guidelines for the preparation of traffic impact analyses to reflect local
conditions and industry standards.
Agency/Department: Public Works Department
Funding Source: Development fees
Time Frame: Ongoing
Related Policies:
Land Use: 2.5, 6.10
Circulation & Mobility: 1.1
Growth Management: 1.2, 1.6
IMPLEMENTATION
ORANGE GENERAL PLAN
IMP-31
Program III-5 Transportation Demand Management Plans
Require major employers of 100 persons or more to institute transportation demand
management (TDM) plans. Such plans establish incentives to encourage employees to
carpool, take public transportation, bicycle, or use some means other than private
automobiles to get to and from work.
Agency/Department: Community Development Department, Public Works
Department
Funding Source: Development fees
Time Frame: Ongoing
Related Policies:
Circulation & Mobility: 2.6
Natural Resources: 2.1, 2.2
Growth Management: 1.12
Program III-6 National Pollutant Discharge
Elimination System Compliance
Before making land use decisions, the City will utilize available methods to estimate increases
in pollutant loads and flows resulting from projected future development.
The City will follow the most current NPDES permit and countywide Model WQMP and the
City Local Implementation Plan to ensure that the City complies with applicable federal and
state regulations. Applicants for new development and redevelopment projects shall prepare
and submit plans to the City, as well as implement plans demonstrating accomplishment of
the following:
Emphasize the need to implement and prioritize the use of low impact development
BMPs that provide onsite infiltration and retention;
Use biotreatment systems such as flow through planters, wetlands and bioswales where
infiltration, evapotranspiration, and harvest and reuse are not feasible;
Limit areas of impervious surfaces and preserve natural areas;
Limit directly connected areas of impervious surfaces;
Limit disturbance of natural water bodies, natural drainage systems, and highly erodable
areas;
Use structural and nonstructural best management practices (BMPs) to mitigate
projected increases in pollutant loads and flows;
Use pollution prevention methods, source controls, and treatment with small collection
strategies located at or as close as possible to the source;
Control the velocity of pollutant loading flows during and after construction; and
Implement erosion protection during construction.
IMPLEMENTATION
ORANGE GENERAL PLAN
IMP-32 GPA 2010-0001 (8/10/10)
In addition, applicants for large development projects are required to prepare and implement
plans that meet site predevelopment hydrologic conditions and to control runoff on-site
where technically feasible.
Agency/Department: Public Works Department, Community Development
Department
Funding Source: Development fees
Time Frame: Ongoing
Related Policies:
Land Use; 4.3, 6.5
Natural Resources: 2.12, 2.13, 2.14, 2.15, 2.16, 2.17
Public Safety: 2.3
Program III-7 Water Services and Supplies
As needed, require studies to determine water infrastructure requirements for future
development projects, and require that any recommendations be incorporated into the
design of projects. Require the dedication of necessary right-of-way and construction of
water infrastructure improvements for development projects as needed. Developers shall
also be required to pay the cost of providing new and improved water services to project
sites.
For projects that satisfy the criteria set forth in Sections 10910–10915 of the California Water
Code and Section 66473.7 of the Government Code, a water supply assessment or water
supply verification demonstrating available water supplies exist to support development
shall also be prepared.
Agency/Department: Community Development Department, Public Works
Department
Funding Source: Development fees, General Fund
Time Frame: Ongoing
Related Policies:
Infrastructure: 1.1, 1.4, 1.6
Program III-8 Adequate Public Safety and Emergency
Response
During the development application process, consult with Fire and Police Departments to
evaluate the need for additional fire and police facilities or resources to serve new
development projects and infill development areas. During updates to the Capital
Improvement Program process, coordinate with service providers to evaluate the level of fire
and police service provided to the community. Require adequate street widths and clearance
for emergency access. Provide all appropriate safety features. Continue to use state-of-the-
art techniques and technology to enhance public safety.
IMPLEMENTATION
ORANGE GENERAL PLAN
IMP-33
Adhere to requirements in the Municipal Code for adequate street widths and clearance for
emergency access. Integrate CPTED techniques into development projects and practice
active surveillance measures in high-risk areas such as parking lots.
The City shall use open space easements and other regulatory techniques to prohibit
development and avoid public safety hazards where the threat from seismic hazards cannot
be mitigated.
Agency/Department: Community Development Department, Public Works
Department, Police Department, Fire Department
Funding Source: Development fees, General Fund
Time Frame: Ongoing
Related Policies:
Public Safety: 3.4, 4.4, 6.1, 6.2, 6.3, 6.4
Program III-9 Geologic Hazard Assessments
Pursuant to state law, geologic and/or geotechnical studies are required for proposed new
development projects located in areas identified as susceptible to landslides and liquefaction
and binding mitigation strategies must be adopted. Compliance with the recommendations
set forth in site-specific geologic and/or geotechnical studies will be made a condition of
approval for new development. In addition, the City may require applicants to incorporate
measures to stabilize and maintain slopes on a site-by-site basis, such as proper planting,
irrigation, retaining walls, and benching.
Agency/Department: Community Development Department, Public Works
Department
Funding Source: Development fees
Time Frame: Ongoing
Related Policies:
Land Use: 6.9, 6.10
Public Safety: 1.1
Program III-10 Cultural Resources Inventories
Require cultural resources inventories of all new development projects in areas identified
with medium or high potential for archeological, paleontological, or cultural resources based
on resource sensitivity maps prepared in conjunction with the General Plan.
Where a preliminary site survey finds medium to high potential for substantial archaeological
remains, the City shall require a mitigation plan to protect the resource before issuance of
permits. Mitigation may include:
Ensuring that a qualified archaeologist is present during initial grading or trenching
(monitoring),
Redesigning the project to avoid archaeological resources (this is considered the
strongest tool for preserving archaeological resources),
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IMP-34 GPA 2010-0001 (8/10/10)
Capping the site with a layer of fill, and/or
Excavating and removing the archaeological resources (recovery) and implementing
curation in an appropriate facility under the direction of a qualified archaeologist
(interpretation).
Alert applicants for permits within early settlement areas to the potential sensitivity. If an
archaeological inventory survey is required, the final stage is the preparation of a
professional report detailing the findings and recommendations of the records search and
field survey. The final report containing site forms, site significance, and mitigation measures
should be submitted immediately to the Community Development Department. All
information regarding site locations, Native American human remains, and associated
funerary objects should be in a separate confidential addendum, and not be made available
for public disclosure.
If significant archaeological resources are discovered during construction or grading
activities, such activities shall cease in the immediate area of the find until a qualified
archaeologist can determine the significance of the resource and recommend alternative
mitigation. The final written report should be submitted to the appropriate regional
archaeological Information Center within three months after work has been completed. The
City shall ensure that project applicants contact the Native American Heritage Commission
for a Sacred Lands File Check and a list of appropriate Native American contacts f or
consultation concerning the project site and to assist in crafting the mitigation measures.
Agency/Department: Community Development Department
Funding Source: Development fees
Time Frame: Ongoing
Related Policies:
Land Use: 6.11
Cultural Resources &
Historic Preservation: 4.1, 4.5
Program III-11 Green Building, Energy Conservation,
and Sustainable Development
The City strongly encourages new development and major renovation projects to employ
green building techniques and materials. Encourage proposed development projects
throughout the City to use Leadership in Energy and Environmental Design (LEED) standards
developed by the U.S. Green Building Council or a similar third-party verified program.
Encourage building orientations and landscaping that enhance natural lighting and sun
exposure. Prepare guidelines for sustainable development to encourage incorporation of
these practices in new development. These guidelines will include measures to maximize soil
permeability to address related stormwater and surface-water runoff issues.
Require compliance with state Title 24 building construction standards and Energy Star
conservation standards for all development projects.
IMPLEMENTATION
ORANGE GENERAL PLAN
IMP-35
Prepare and adopt an ordinance that requires and/or provides incentives for: (1) specified
new residential development to comply with a specified green building program or show
that its development provides comparable effectiveness to such a program; and (2) specified
non-residential development of a specified size comply with a specified green building
program or show that its development provides comparable effectiveness to such a
program.
Agency/Department: Community Development Department, Public Works
Department
Funding Source: Development fees
Time Frame: Ongoing; December 31, 2011 (For ordinance)
Related Policies:
Natural Resources: 2.6, 2.7
Program III-12 Mixed-Use Noise Property Notification
When the City exercises discretionary review, provides financial assistance, or otherwise
facilitates residential development within a mixed-use area, make providing written warnings
to potential residents about noise intrusion a condition of that approval, assistance, or
facilitation. The following language is provided as an example:
“All potential buyers and/or renters of residential property within mixed-use districts in the City
of Orange are hereby notified that they may be subject to audible noise levels generated by
business and entertainment related operations common to such areas, including amplified
sound, music, delivery and passenger vehicles, mechanical noise, pedestrians, and other urban
noise sources.”
Agency/Department: Community Development Department
Funding Source: Development fees
Time Frame: Ongoing
Related Policies:
Noise: 5.1, 5.3
Urban Design: 2.5
Program III-13 Ecological and Biological Resource
Assessments
Analyze development proposals for potential impacts on significant ecological and biological
resources. Require appropriate mitigation for all significant impacts if impact avoidance is
not possible. Mitigation measures for habitat and species may include but are not limited to
avoidance, enhancement, restoration, compensatory mitigation, or a combination of these.
Agency/Department: Community Development Department
Funding Source: Development fees
Time Frame: Ongoing
IMPLEMENTATION
ORANGE GENERAL PLAN
IMP-36 GPA 2010-0001 (8/10/10)
Related Policies:
Land Use: 6.4, 6.11
Natural Resources: 4.1, 4.3, 4.4, 4.5
Program III-14 Archaeological Resources Management
Report (ARMR Preservation Bulletin)
Establish the Archaeological Resources Management Report (ARMR Preservation Bulletin) as
the standard report format for all documentation and accept reports only from registered
professional archaeologists knowledgeable in Native American cultures and/or historical
archaeology (qualified archaeologists).
Agency/Department: Community Development Department
Funding Source: Development fees
Time Frame: Ongoing
Related Policies:
Cultural Resources &
Historic Preservation: 4.1
Program III-15 Historic Resources Design Review
Continue to use the Secretary of the Interior’s Standards for the Treatment of Historic
Properties and Guidelines for Preserving, Rehabilitating, Restoring and Reconstructing Historic
Buildings as a basis for design review and incorporate them by reference into the Old Towne
Design Standards and other historic preservation design standards. Any approved demolition
permit for historic resources listed in the City’s Historic Register will be automatically subject
to a delay of 180 days before the permit for demolition may be issued. The property owner
will strive to develop alternatives to demolition that will preserve the historic resources.
The Design Review Committee or Historic Preservation Commission at such time such a
commission is established, shall serve as the review body for projects involving historic
resources.
Agency/Department: Community Development Department, City Council
Funding Source: General Fund
Time Frame: Ongoing
Related Policies:
Cultural Resources &
Historic Preservation: 1.1, 1.2, 1.3, 1.4, 1.5, 2.3, 3.2
Program III-16: Public Access to Santiago Creek and
Santa Ana River Public Interface
Ensure that new development does not preclude access to Santiago Creek and the Santa Ana
River and associated trails. Development review should ensure that commercial and retail
development in these areas support public access.
IMPLEMENTATION
ORANGE GENERAL PLAN
IMP-37
Agency/Department: Community Development Department
Funding Source: Development fees
Time Frame: Ongoing
Related Policies:
Land Use: 6.4, 6.6
Circulation & Mobility: 4.1
Natural Resources: 1.3, 5.5, 7.1, 7.2, 7.3, 7.4, 7.5
Urban Design: 2.6
Program III-17: Office Condominium Conversions
Evaluate applications for conversion of industrial properties to office condominiums to
determine the impact on the available balance of larger and smaller properties available for
industrial use.
Agency/Department: Community Development Department, Economic
Development Department
Funding Source: Development fees
Time Frame: Ongoing
Related Policies:
Land Use: 4.1, 4.2, 4.3, 4.4, 4.5
Economic Development: 3.1, 6.1, 6.2
Program III-18: Noise Reduction in New Construction
Require construction contractors to implement the following measures during construction
activities through contract provisions and/or conditions of approval as appropriate:
Construction equipment shall be properly maintained per manufacturers’ specifications
and fitted with the best available noise suppression devices (i.e., mufflers, silencers,
wraps, etc).
Shroud or shield all impact tools, and muffle or shield all intake and exhaust ports on
power equipment.
Construction operations and related activities associated with the proposed project shall
comply with the operational hours outlined in the City of Orange Municipal Code Noise
Ordinance, or mitigate noise at sensitive land uses to below Orange Municipal Code
standards.
Construction equipment should not be idled for extended periods of time in the vicinity
of noise sensitive receptors.
Locate fixed and/or stationary equipment as far as possible from noise sensitive
receptors (e.g., generators, compressors, rock crushers, cement mixers). Shroud or
IMPLEMENTATION
ORANGE GENERAL PLAN
IMP-38 GPA 2010-0001 (8/10/10)
shield all impact tools, and muffle or shield all intake and exhaust ports on powered
construction equipment.
Where feasible, temporary barriers shall be placed as close to the noise source or as close
to the receptor as possible and break the line of sight between the source and receptor
where modeled levels exceed applicable standards. Acoustical barriers shall be
constructed material having a minimum surface weight of 2 pounds per square foot or
greater, and a demonstrated Sound Transmission Class (STC) rating of 25 or greater as
defined by American Society for Testing and Materials (ASTM) Test Method E90.
Placement, orientation, size, and density of acoustical barriers shall be specified by a
qualified acoustical consultant.
Agency/Department: Community Development Department, Public Works
Department, Community Services Department
Funding Source: Development fees
Time Frame: Ongoing
Related Policies:
Noise: 1.1, 1.2, 1.4, 1.5, 7.2
Program III-19: Groundborne Noise and Vibration
Implement the following measures to reduce the potential for human annoyance and
architectural/structural damage resulting from elevated groundborne noise and vibration
levels.
Construction-Induced Vibration. The City shall implement or require implementation of
the following measures through contract provisions and/or conditions of approval as
appropriate:
o Pile driving required within a 50-foot radius of historic structures shall utilize
alternative installation methods where possible (e.g., pile cushioning, jetting, pre-
drilling, cast-in-place systems, resonance-free vibratory pile drivers). Specifically,
geo pier style cast-in-place systems or equivalent shall be used where feasible as
an alternative to pile driving to reduce the number and amplitude of impacts
required for seating the pile.
o The preexisting condition of all buildings within a 50-foot radius and of historic
buildings within the immediate vicinity of proposed construction-induced
vibration activities shall be recorded in the form of a preconstruction survey. The
preconstruction survey shall determine conditions that exist before construction
begins for use in evaluating damage caused by construction activities. Fixtures
and finishes within a 50-foot radius of construction activities susceptible to
damage shall be documented (photographically and in writing) prior to
construction. All damage will be repaired back to its preexisting condition.
IMPLEMENTATION
ORANGE GENERAL PLAN
IMP-39
o Vibration monitoring shall be conducted prior to and during pile driving
operations occurring within 100 feet of the historic structures. Every attempt
shall be made to limit construction-generated vibration levels in accordance with
Caltrans recommendations during pile driving and impact activities in the vicinity
of the historic structures.
o Provide protective coverings or temporary shoring of on-site or adjacent historic
features as necessary, in consultation with the Community Development Director
or designee.
Railroad-Induced Vibration:
o Vibration sensitive uses shall be located a minimum of 100 feet from the railroad
centerline, where feasible. To ensure compliance with FTA and Caltrans
recommended guidelines, a site-specific groundborne noise and vibration
assesment should be conducted. For sensitive uses located within 100 feet of the
railroad centerline, the acoustical noise and vibration assessment shall
demontrate that potential impacts will be below the level of significance. If
specific project-level impacts are identified, mitigation measures reducing the
impacts to below the level of significance will be required.
o A groundborne vibration assessment shall be conducted at proposed building
pad locations within 200 feet of railroad right-of-ways, prior to project approval.
Vibration monitoring and assessment shall be conducted by a qualified acoustical
consultant. The assessment will demonstrate that rail-associated groundborne
vibration and noise levels comply with recommended FTA and Caltrans guidance
of 80 VdB and 0.2 in/sec PPV (or equivalent), respectively, or propose project-
specific mitigation measures such as site design, building isolation, etc. to achieve
that standard.
Agency/Department: Community Development Department, Public Works
Department
Funding Source: General Fund, Development fees
Time Frame: Ongoing
Related Policies:
Noise: 1.1, 3.1, 3.2, 6.1, 7.2
Program III-20: Toxic Air Contaminant Exposure
Require each project applicant to implement the following measures to reduce the exposure
of sensitive receptors to TACs from mobile sources, as project design features or a condition
of project approval:
Activities involving idling trucks shall be oriented as far away from and downwind of
existing or proposed sensitive receptors as feasible.
IMPLEMENTATION
ORANGE GENERAL PLAN
IMP-40 GPA 2010-0001 (8/10/10)
Strategies shall be incorporated to reduce the idling time of main propulsion engines
through alternative technologies such as IdleAire, electrification of truck parking, and
alternative energy sources for TRUs to allow diesel engines to be completely turned off.
Proposed developments shall incorporate site plans that move sensitive receptors as far
as feasibly possible from major roadways (100,000+ average daily trips).
Projects containing sensitive receptors (such as residences, schools, day care centers,
and medical facilities) on sites within 500 feet of a freeway must demonstrate that health
risks relating to diesel particulates would not exceed acceptable health risk standards
prior to project approval.
Agency/Department: Community Development Department, Public Works
Department
Funding Source: Development fees
Time Frame: Ongoing
Related Policies:
Natural Resources: 2.1
RESOLUTION NO. PC 13-20
A RESOLUTION OF THE PLANNING COMMISSION OF
THE CITY OF ORANGE RECOMMENDING THAT THE
CITY COUNCIL OF THE CITY OF ORANGE APPROVE
AN ORDINANCE AMENDING SECTION 17.10 OF THE
ORANGE MUNICIPAL CODE TO UPDATE
ENVIRONMENTAL REVIEW PROCEDURES TO
ESTABLISH CONSISTENCY WITH THE CALIFORNIA
ENVIRONMENTAL QUALITY ACT STATUTE AND CITY
PRACTICE
APPLICANT: CITY OF ORANGE
Moved by Commissioner ______________ and seconded by Commissioner
________________ that the following resolution be adopted:
WHEREAS, the California Legislature has amended the California Environmental
Quality Act (CEQA) (Public Resources Code Section 21000 et seq.), the California Natural
Resources Agency has amended the State CEQA Guidelines (California Code of Regulations,
Title 14, Section 15000 et seq.), and California courts have provided additional interpretations of
specific provisions of CEQA; and
WHEREAS, Chapter 17.10 of the Orange Municipal Code (OMC) establishes
regulations and procedures for environmental review of projects in compliance with CEQA and
was last updated in 1997; and
WHEREAS, the subject Ordinance revises provisions of Chapter 17.10 of the OMC
related to environmental review and mitigation monitoring and reporting programs for
consistency with State CEQA Statute and City practices; and
WHEREAS, the subject Ordinance revises provisions of the OMC related to
environmental assessment and mitigation monitoring and reporting programs to be consistent
with the goals and policies of the General Plan Land Use and Circulation and Mobility Elements;
and
WHEREAS, the Planning Commission has authority per OMC Section 17.08.020 to hold
a public hearing to make a finding by resolution stating its recommendation to the City Council
on amendments to the OMC and makes the following findings with respect to the Local CEQA
Guidelines.
NOW, THEREFORE, BE IT RESOLVED that the Planning Commission recommends
the City Council adopt the draft Ordinance Amendment contained in Attachment A, attached
hereto, based on the following findings:
SECTION 1- FINDINGS
1. The Zoning Ordinance Amendment updates the Orange Municipal Code to be consistent
with State law and City procedures.
SECTION 2-ENVIRONMENTAL REVIEW
The Ordinance Amendment is categorically exempt from the provisions of CEQA per CEQA
Guidelines Section 15308 (Class 8 – Class 8, Actions by Regulatory Agencies for Protection of
the Environment) because it involves an amendment to the Orange Municipal Code to make it
consistent with the current provisions and interpretations of CEQA and the State CEQA
Guidelines. It does not involve a specific site, development project, or focused geographic area,
does not change permitted land use or density and does not otherwise result in a physical change
that could cause an impact to the environment.
I hereby certify that the Planning Commission of the City of Orange adopted the foregoing
resolution on May 18th, 2020 by the following vote:
AYES:
NOES:
ABSTAIN:
ABSENT:
David Simpson, Planning Commission Chair
Date
Underline/Strikeout Version
DRAFT ORDINANCE NO. ____
AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF
ORANGE AMENDING SECTION 17.10 OF THE ORANGE
MUNICIPAL CODE TO UPDATE ENVIRONMENTAL
REVIEW PROCEDURES CONSISTENT WITH THE
CALIFORNIA ENVIRONMENTAL QUALITY ACT STATUTE
AND CITY PRACTICE
APPLICANT: CITY OF ORANGE
WHEREAS, the California Legislature has amended the California Environmental Quality
Act (CEQA) (Public Resources Code Section 21000 et seq.), the Natural Resources Agency has
amended the State CEQA Guidelines (California Code of Regulations, Title 14, Section 15000 et
seq.), and California courts have provided additional interpretations of specific provisions of
CEQA; and
WHEREAS, Chapter 17.10 of the Orange Municipal Code (OMC) establishes regulations
and procedures for environmental review of projects in compliance with CEQA and was last
updated in 1997; and
WHEREAS, the subject Ordinance revises provisions of Chapter 17.10 of the OMC
related to environmental review and mitigation monitoring and reporting programs for consistency
with State CEQA Statute and City practices; and
WHEREAS, the subject Ordinance revises provisions of the OMC related to
environmental assessment and mitigation monitoring and reporting program to be consistent with
the goals and policies of the General Plan Land Use and Circulation and Mobility Elements; and
WHEREAS, the Planning Commission has conducted a duly advertised public hearing
held on May 18, 2020, including review of the staff report and receiving public testimony on the
item, has determined the subject Ordinance is reasonable, appropriate and justified and
recommends approval thereof; and
WHEREAS, the City Council conducted one duly advertised public hearing on
, 2020, at which time interested persons had an opportunity to testify either in support of
or in opposition to the subject Ordinance; and
WHEREAS, the City wishes to update the language in the OMC regarding environmental
review and mitigation monitoring and reporting programs for consistency with State CEQA Statute
and local procedures.
NOW THEREFORE, THE CITY COUNCIL OF THE CITY OF ORANGE
HEREBY ORDAINS AS FOLLOWS:
Underline/Strikeout Version
SECTION I:
The subject Ordinance is categorically exempt from the provisions of CEQA per CEQA Guidelines
Section 15308 (Class 8 – Actions by Regulatory Agencies for Protection of the Environment)
because the activity undertaken is an amendment to the Orange Municipal Code to make it
consistent with the current provisions and interpretations of State CEQA Statute, CEQA
Guidelines, and local procedures. It does not involve a specific site, development project, or
focused geographic area, does not change permitted land use or density and does not otherwise
result in a physical change that could cause an impact to the environment.
SECTION II:
Section 17.10.080 of the Orange Municipal Code , Environmental Review, is hereby amended in
its entirety to read as follows:
Environmental assessments shall occur in accordance with California Environmental Quality Act
(CEQA) provisions and the City of Orange Environmental Review Guidelines Local CEQA
Guidelines.
SECTION III:
Section 17.10.085 of the Orange Municipal Code , Mitigation Monitoring Program, is hereby
amended in its entirety to read as follows:
17.10.085 - Mitigation Monitoring and Reporting Program.
A. Purpose and Intent. The mitigation monitoring and reporting program is a process used to
verify that mitigation measures, adopted in conjunction with project approval to reduce or avoid
significant environmental effects, are carried out during project development or implementation.
The program has been adopted to comply with the requirements of the California Environmental
Quality Act CEQA.
B. When Mitigation Monitoring and Reporting is Required. Mitigation monitoring and reporting
is required when the City has made the findings required relative to an environmental impact report
or adopted a mitigation negative declaration in conjunction with approving a project. on all projects
for which a mitigated negative declaration or environmental impact report has been prepared.
C. Initiation and Application. There is no formal application process, however fees shall be paid
in accordance with the City's adopted Master Schedule of Fees and Charges. Mitigation monitoring
and reporting shall occur in accordance with California Environmental Quality Act CEQA
provisions and the City of Orange Local CEQA Guidelines.
D. Mitigation Monitoring Program Manual. The guidelines for implementation of the mitigation
monitoring program are contained within the City's Mitigation Monitoring Program Manual.
E. Definitions. As used in this chapter, the following words and phrases shall have the meanings
set forth below:
Underline/Strikeout Version
1. "CEQA" means the California Environmental Quality Act as in force and amended
from time to time;
2. "DIRECTOR" means the Director of Community Development or his designee,
and/or such other City Staff position as may be given responsibility for managing and
enforcing the Mitigation Monitoring Program in the Mitigation Monitoring Program
Manual;
3. "PROJECT" refers to a development proposal subject to government approval defined
in CEQA Statutes and Guidelines Section 15378, partially reproduced as follows:
a. "Project" means the whole of an action, which has a potential for resulting in
a physical change in the environment, directly or ultimately, and that is any
of the following:
(1) An activity directly undertaken by any public agency including but not
limited to public works construction and related activities, clearing or
grading of land, improvements to existing public structures, enactment
and amendment of zoning ordinances, and the adoption and
amendment of local general plans or elements;
(2) An activity undertaken by a person which is supported in whole or in
part through public agency contracts, grants, subsidies, loans or other
forms of assistance from one or more public agencies;
(3) An activity involving the issuance to a person of lease, permit, license,
certificate, or other entitlement for use by one or more public agencies.
4. "MITIGATION MEASURE" shall mean any action and/or inaction specified in the
Environmental Documentation for the purpose of reducing or eliminating identified
environmental impacts, in accordance with CEQA.
5. "PROJECT PROPONENT" shall mean both the owner of real property during any
phase of a development project and the applicant for any development approval for
any stage of that Project.
6. "ENVIRONMENTAL DOCUMENTATION" shall mean the final environmental
impact report or mitigated negative declaration, together with all amendments,
addenda, supplements or other modifications as approved by the City Council for the
project, in accordance with CEQA and any rules regulations or orders implementing
CEQA adopted by any State or City agency.
FD. Compliance Required. The project proponent of any real property within the City shall fully
comply with all mitigation measures at the respective times specified for such mitigation measures
in the environmental documentation for the project and with the provisions of the City Mitigation
Monitoring Program Manual City of Orange Local CEQA Guidelines as adopted and amended
Underline/Strikeout Version
from time to time by resolution of the City Council. Failure to do so shall result in one or both of
the following:
1. Suspension of any and all rights to proceed with any previously granted development
approval or permit; and
2. Issuance of a stop work order requiring all work to cease except that necessary to
implement mitigation measures. Failure to comply with a stop work order shall be a
misdemeanor and will be enforced as such an offense. In the event that compliance
is not achieved by the time set forth in the approved environmental documentation,
no further permits for the project involved will be issued until the matter is resolved.
Furthermore, if a field inspection reveals a violation of or a failure to implement
mitigation measures, and immediate action is warranted, the Mitigation Manager
Community Development Director, or authorized monitoring staff designee, shall
have the authority to require all work to cease until resolution.
The City Council may, by resolution or in the Mitigation Monitoring Program Manual as adopted
from time to time, set forth procedures for enforcement of this chapter, for issuance of stop work
orders hereunder, and for resolution of disputes arising from the Mitigation Monitoring Program
or its enforcement. Failure to comply with this chapter or with any such stop work order shall be
a misdemeanor and each day that such failure to comply continues shall be a separate offense.
G. Cost to be Borne by Project Proponent. The Project Proponent shall pay to the City the
reasonable costs of administering the City of Orange Mitigation Monitoring Program with respect
to the Project Proponent's Project. Such costs shall include, but not be limited to, the time of City
employees necessary to monitor and ensure compliance by the Project Proponent, the cost of
materials, traveling expenses and other reasonable costs of administering the program, and a
reasonable allocation of the costs of equipment, computer facilities and other capital expenses
incurred by the City in order to administer the program. The City Council may establish by
resolution from time to time, the amounts of or methods for determining and collecting fees or
charges to recover such costs.
SECTION IV:
If any section, subdivision, paragraph, sentence, clause or phrase of this Ordinance is for
any reason held to be invalid or unconstitutional, such decision shall not affect the validity of the
remaining portions of this Ordinance. The City Council hereby declares that it would have passed
this Ordinance, and each section, subdivision, paragraph, sentence, clause and phrase thereof,
irrespective of the fact that any one (or more) section, subdivision, paragraph, sentence, clause or
phrase had been declared invalid or unconstitutional.
SECTION V:
The City Clerk is hereby directed to certify the adoption of this Ordinance and cause a
summary of the same to be published as required by law. This Ordinance shall take effect thirty
(30) days from and after the date of its final passage.
Underline/Strikeout Version
ADOPTED this day of , 2020.
Mark A. Murphy, Mayor, City of Orange
ATTEST:
Pamela Coleman, City Clerk, City of Orange
STATE OF CALIFORNIA )
COUNTY OF ORANGE )
CITY OF ORANGE )
I, PAMELA COLEMAN, City Clerk of the City of Orange, California, do hereby certify that the
foregoing Ordinance was introduced at the regular meeting of the City Council held on the
day of , 2020 and thereafter at the regular meeting of said City Council duly
held on the day of , 2020, was duly passed and adopted by the following
vote, to wit:
AYES: COUNCILMEMBERS:
NOES: COUNCILMEMBERS:
ABSENT: COUNCILMEMBERS:
ABSTAIN: COUNCILMEMBERS:
Pamela Coleman, City Clerk, City of Orange
N:\CDD\PLNG\Environmental Review (CEQA Compliance)\Local CEQA Guidelines\2020 Local CEQA Guidelines Update\Ordinance Update
DRAFT ORDINANCE NO. ____
AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF
ORANGE AMENDING SECTION 17.10 OF THE ORANGE
MUNICIPAL CODE TO UPDATE ENVIRONMENTAL
REVIEW PROCEDURES CONSISTENT WITH THE
CALIFORNIA ENVIRONMENTAL QUALITY ACT STATUTE
AND CITY PRACTICE
APPLICANT: CITY OF ORANGE
WHEREAS, the California Legislature has amended the California Environmental Quality
Act (CEQA) (Public Resources Code Section 21000 et seq.), the Natural Resources Agency has
amended the State CEQA Guidelines (California Code of Regulations, Title 14, Section 15000 et
seq.), and California courts have provided additional interpretations of specific provisions of
CEQA; and
WHEREAS, Chapter 17.10 of the Orange Municipal Code (OMC) establishes regulations
and procedures for environmental review of projects in compliance with CEQA and was last
updated in 1997; and
WHEREAS, the subject Ordinance revises provisions of Chapter 17.10 of the OMC
related to environmental review and mitigation monitoring and reporting programs for consistency
with State CEQA Statute and City practices; and
WHEREAS, the subject Ordinance revises provisions of the OMC related to
environmental assessment and mitigation monitoring and reporting program to be consistent with
the goals and policies of the General Plan Land Use and Circulation and Mobility Elements; and
WHEREAS, the Planning Commission has conducted a duly advertised public hearing
held on May 18, 2020, including review of the staff report and receiving public testimony on the
item, has determined the subject Ordinance is reasonable, appropriate and justified and
recommends approval thereof; and
WHEREAS, the City Council conducted one duly advertised public hearing on
, 2020, at which time interested persons had an opportunity to testify either in support of
or in opposition to the subject Ordinance; and
WHEREAS, the City wishes to update the language in the OMC regarding environmental
review and mitigation monitoring and reporting programs for consistency with State CEQA Statute
and local procedures.
NOW THEREFORE, THE CITY COUNCIL OF THE CITY OF ORANGE
HEREBY ORDAINS AS FOLLOWS:
SECTION I:
The subject Ordinance is categorically exempt from the provisions of CEQA per CEQA Guidelines
Section 15308 (Class 8 – Actions by Regulatory Agencies for Protection of the Environment)
because the activity undertaken is an amendment to the Orange Municipal Code to make it
consistent with the current provisions and interpretations of State CEQA Statute, CEQA
Guidelines, and local procedures. It does not involve a specific site, development project, or
focused geographic area, does not change permitted land use or density and does not otherwise
result in a physical change that could cause an impact to the environment.
SECTION II:
Section 17.10.080 of the Orange Municipal Code , Environmental Review, is hereby amended in
its entirety to read as follows:
Environmental assessments shall occur in accordance with CEQA provisions and the City of
Orange Local CEQA Guidelines.
SECTION III:
Section 17.10.085 of the Orange Municipal Code , Mitigation Monitoring Program, is hereby
amended in its entirety to read as follows:
17.10.085 - Mitigation Monitoring and Reporting Program.
A. Purpose and Intent. The mitigation monitoring and reporting program is a process used to
verify that mitigation measures, adopted in conjunction with project approval to reduce or avoid
significant environmental effects, are carried out during project development or implementation.
The program has been adopted to comply with the requirements of the CEQA.
B. When Mitigation Monitoring and Reporting is Required. Mitigation monitoring and reporting
is required when the City has made the findings required relative to an environmental impact report
or adopted a mitigation negative declaration in conjunction with approving a project.
C. Mitigation monitoring and reporting shall occur in accordance with CEQA provisions and
the City of Orange Local CEQA Guidelines.
D. Compliance Required. The project proponent of any real property within the City shall fully
comply with all mitigation measures at the respective times specified for such mitigation measures
in the environmental documentation for the project and with the provisions of the City of Orange
Local CEQA Guidelines as adopted and amended from time to time by resolution of the City
Council. Failure to do so shall result in one or both of the following:
1. Suspension of any and all rights to proceed with any previously granted development
approval or permit; and
2. Issuance of a stop work order requiring all work to cease except that necessary to
implement mitigation measures. Failure to comply with a stop work order shall be a
misdemeanor and will be enforced as such an offense. In the event that compliance
is not achieved by the time set forth in the approved environmental documentation,
no further permits for the project involved will be issued until the matter is resolved.
Furthermore, if a field inspection reveals a violation of or a failure to implement
mitigation measures, and immediate action is warranted, the Community
Development Director, or designee, shall have the authority to require all work to
cease until resolution.
SECTION IV:
If any section, subdivision, paragraph, sentence, clause or phrase of this Ordinance is for
any reason held to be invalid or unconstitutional, such decision shall not affect the validity of the
remaining portions of this Ordinance. The City Council hereby declares that it would have passed
this Ordinance, and each section, subdivision, paragraph, sentence, clause and phrase thereof,
irrespective of the fact that any one (or more) section, subdivision, paragraph, sentence, clause or
phrase had been declared invalid or unconstitutional.
SECTION V:
The City Clerk is hereby directed to certify the adoption of this Ordinance and cause a
summary of the same to be published as required by law. This Ordinance shall take effect thirty
(30) days from and after the date of its final passage.
ADOPTED this day of , 2020.
Mark A. Murphy, Mayor, City of Orange
ATTEST:
Pamela Coleman, City Clerk, City of Orange
STATE OF CALIFORNIA )
COUNTY OF ORANGE )
CITY OF ORANGE )
I, PAMELA COLEMAN, City Clerk of the City of Orange, California, do hereby certify that the
foregoing Ordinance was introduced at the regular meeting of the City Council held on the
day of , 2020 and thereafter at the regular meeting of said City Council duly
held on the day of , 2020, was duly passed and adopted by the following
vote, to wit:
AYES: COUNCILMEMBERS:
NOES: COUNCILMEMBERS:
ABSENT: COUNCILMEMBERS:
ABSTAIN: COUNCILMEMBERS:
Pamela Coleman, City Clerk, City of Orange
N:\CDD\PLNG\Environmental Review (CEQA Compliance)\Local CEQA Guidelines\2020 Local CEQA Guidelines Update\Ordinance Update
RESOLUTION NO. PC 14-20
A RESOLUTION OF THE PLANNING COMMISSION OF
THE CITY OF ORANGE RECOMMENDING THAT THE
CITY COUNCIL OF THE CITY OF ORANGE APPROVE
AN UPDATE TO THE CITY OF ORANGE LOCAL
CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA)
GUIDELINES TO UPDATE CITY PROCEDURES
CONSISTENT WITH THE STATE CEQA STATUTE AND
CITY PRACTICE
APPLICANT: CITY OF ORANGE
Moved by Commissioner ______________ and seconded by Commissioner
________________ that the following resolution be adopted:
WHEREAS, the Section 15022 of the State CEQA Guidelines (California Code of
Regulations, Title 14, Section 15000 et seq.) requires local agencies to adopt “objectives, criteria
and procedures” to implement the requirements of the State CEQA Statute (Public Resources
Code Section 21000 et seq.) and the State CEQA Guidelines; and
WHEREAS, the purpose of the Local CEQA Guidelines is to provide a structure and
process for City-implementation of the rules and regulations contained in CEQA; and
WHEREAS, on April 11, 2006, the City Council reviewed the recommendation of the
Planning Commission and adopted City Council Resolution No. 10073 updating the Local
CEQA Guidelines for the City of Orange; and
WHEREAS, the Local CEQA Guidelines have not been updated since 2006 and a
comprehensive update was deemed necessary to keep the City’s procedures consistent with the
State CEQA Statute and local practice, including implementation of Senate Bill 743 and
changing the metric to measure transportation impact from level of service to vehicle miles
traveled; and
WHEREAS, the adoption of the comprehensive update to the Local CEQA Guidelines
by the City Council will supersede the 2006 Local CEQA Guidelines; and
WHEREAS, the Planning Commission has authority per OMC Section 17.08.020 to hold
a public hearing to make a finding by resolution stating its recommendation to the City Council
on the comprehensive update of the Local CEQA Guidelines.
NOW, THEREFORE, BE IT RESOLVED that the Planning Commission recommends
the City Council adopt the Local CEQA Guidelines contained in Attachment A, attached hereto,
based on the following findings:
SECTION 1- FINDINGS
1. The revised Local CEQA Guidelines implement changes required by Senate Bill 743 and
other revisions in the State CEQA Statute by updating the City’s procedures to be consistent
with state law and local practice.
SECTION 2-ENVIRONMENTAL REVIEW
Revision to the Local CEQA Guidelines is categorically exempt from the provisions of the
California Environmental Quality Act (CEQA) per CEQA Guidelines Section 15308 (Class 8 –
Class 8, Actions by Regulatory Agencies for Protection of the Environment) because it involves
a comprehensive update of the Local CEQA Guidelines to make them consistent with the current
provisions and interpretations of CEQA and the State CEQA Guidelines. It does not involve a
specific site, development project, or focused geographic area, does not change permitted land
use or density and does not otherwise result in a physical change that could cause an impact to
the environment.
I hereby certify that the Planning Commission of the City of Orange adopted the foregoing
resolution on May 18th, 2020 by the following vote:
AYES:
NOES:
ABSTAIN:
ABSENT:
David Simpson, Planning Commission Chair
Date
City of Orange Local CEQA Guidelines
Community Development/
Planning Division
Community Development/
Planning Division
TABLE OF CONTENTS
Page Numbers
1. PURPOSE OF GUIDELINES AND REGULATORY AUTHORITY .................................................1
A. Procedures for Amending Local CEQA Guidelines ...............................................................1
2. DEFINITIONS AND COMMON ACRONYMS ............................................................................2
3. ENVIRONMENTAL REVIEW PROCESS ......................................................................................5
A. Community Development Department Responsibility ..........................................................5
B. Determining the Applicability of CEQA ................................................................................6
C. Projects that are Exempt from CEQA ....................................................................................7
D. Initial Study Process .............................................................................................................10
E. Negative Declaration Process .............................................................................................13
F. Environmental Impact Report Process .................................................................................16
G. Tiering .................................................................................................................................21
H. Mitigation Measures ............................................................................................................22
I. Mitigation Monitoring and Reporting Program ...................................................................25
4. HISTORICAL RESOURCES AND ENVIRONMENTAL REVIEW ................................................28
A. Identification of Historical Resources; Applicability.............................................................28
B. Impacts on Historical Resources; Design Standards ............................................................29
C. Exemptions ..........................................................................................................................33
D. Cumulative Impacts on Historical Resources .......................................................................34
5. TRANSPORTATION ANALYSIS .................................................................................................35
6. GREENHOUSE GAS EMISSIONS ANALYSIS ...........................................................................37
7. APPROVAL AUTHORITY ...........................................................................................................39
A. Planning Commission ..........................................................................................................39
B. City Council .........................................................................................................................39
8. APPEAL PROCESS ....................................................................................................................40
9. FEES ...........................................................................................................................................41
10. DOCUMENT PREPARATION ....................................................................................................42
11. APPENDICES
Appendix A CEQA Process Flow Chart
Appendix B City of Orange Environmental Checklist
Appendix C City of Orange Environmental Checklist for Subsequent Projects
Appendix D Mitigation Monitoring and Reporting Program Sample Format
Appendix E General Plan Implementation, Section III. Conditions or Requirements
Placed Upon Applicants during Development Review
Appendix F Guidance for Greenhouse Gas Emissions Analysis
1City of Orange Local CEQA Guidelines
1. PURPOSE OF GUIDELINES AND REGULATORY
AUTHORITY
The purpose of these Local CEQA Guidelines is to provide the City of
Orange (City) and anyone intending to carry out a project within the
City with the requirements of the environmental review process
established according to state law, local ordinance, and City
practices. These Local CEQA Guidelines serve to augment
those procedures contained in the California Environmental
Quality Act (Public Resources Code (PRC) Section 21000 et
seq.), referred to as CEQA or CEQA Statutes, and the State
CEQA Guidelines (Title 14, California Code of Regulations
(CCR), Chapter 3, Section 15000 et seq.), referred to as
State CEQA Guidelines or CEQA Guidelines. The intent of
CEQA is to ensure adequate consideration and analysis of
potential environmental impacts anticipated to result from
approval of discretionary actions. If any provision of these Local
CEQA Guidelines is in conflict with any provision of CEQA as it
now exists or as amended hereafter, CEQA shall control.
The authority to adopt these Local CEQA Guidelines is granted under PRC
Section 21082, which requires public agencies to adopt local environmental
review guidelines.
A copy of the CEQA Statutes and CEQA Guidelines are on file at the City Community Development
Department. The primary responsibility for implementing the provisions of CEQA and these Local
CEQA Guidelines for the City shall be with the Community Development Director.
A. Procedures for Amending Local CEQA Guidelines
The Local CEQA Guidelines may be amended by the City Council at any time.
The attached Appendices to the Local CEQA Guidelines are intended to provide sample forms
or supplementary guidance relative to the preparation of CEQA documentation. The Community
Development Director has the authority to revise, amend, or delete the appendices at any time
to ensure the information is consistent with CEQA, CEQA Guidelines, City procedures or policies,
or other planning practices that relate to the CEQA process. Updates to the appendices will be
made available on the City of Orange Community Development Department webpage and a
copy will be on file at the City Community Development Department.
2City of Orange Local CEQA Guidelines
2. DEFINITIONS AND COMMON ACRONYMS
A. Definitions
The following definitions, in addition to all other definitions contained in Chapter 2.5 of the
California Environmental Quality Act and Article 20 of the associated CEQA Guidelines, apply to
this document:
Applicant means a person who proposes to carry out a project that requires a lease, permit,
license, certificate, or other entitlement for use, or requires financial aid from one of more public
agencies when applying for governmental approval or assistance.
Approval means the decision by a public agency that commits the agency to a definite course of
action in regard to a project intended to be carried out by any person. The exact date of approval
of any project is a matter determined by each public agency according to its rules, regulations,
and ordinances (CEQA Guidelines Section 15352). A project is deemed to be finally approved
by the Planning Commission at the close of the appeal period (Orange Municipal Code (OMC)
Section 17.08.050.D), or by the City Council upon final adoption of a resolution or ordinance, as
the case may be (OMC Section 2.04.250.C).
California Environmental Quality Act (CEQA) means Public Resources Code (PRC) Section
21000 et seq.
CEQA Guidelines means the “Guidelines for Implementation of the California Environmental
Quality Act,” Title 14, California Code of Regulations (CCR), Chapter 3, Section 15000 et seq.
City means the City of Orange.
Community Development Director means the City of Orange Community Development Director
or designee.
Decision-Making Body means any person or group of people within a public agency permitted
by law to approve or disapprove the project at issue (CEQA Guidelines Section 15356).
Discretionary Project means a project which requires the exercise of judgment or deliberation
when the public agency or body decides to approve or disapprove a particular activity, as
distinguished from situations where the public agency or body merely has to determine whether
there has been conformity with applicable statutes, ordinances, or regulations (CEQA Guidelines
Section 15357).
Environment means the physical conditions which exist within the area which will be affected by
a proposed project including land, air, water, minerals, flora, fauna, ambient noise, and objects of
historical or aesthetic significance. The area involved shall be the area in which significant effects
would occur either directly or indirectly as a result of the project. The environment includes both
natural and man-made conditions (CEQA Guidelines Section 15360).
3City of Orange Local CEQA Guidelines
Lead Agency means the public agency which has the principal responsibility for carrying out
or approving a project (CEQA Guidelines Section 15367). For purposes of these Local CEQA
Guidelines, the Lead Agency is the City of Orange.
Major Transit Stop means a site containing an existing rail transit station, a ferry terminal served
by either a bus or rail transit service, or the intersection of two or more major bus routes with
a frequency of service interval of 15 minutes or less during the morning and afternoon peak
commute periods.
Ministerial describes a governmental decision involving little or no personal judgment by the
public official as to the wisdom or manner of carrying out the project (CEQA Guidelines Section
15369).
Orange Municipal Code (OMC) means all the regulatory and penal ordinances and certain of the
administrative ordinances of the City.
Tiering refers to the coverage of general matters in broader Environmental Impact Reports (EIR),
such as on General Plans or policy statements, with subsequent narrower EIRs or ultimately site-
specific EIRs incorporating by reference the general discussions and concentrating solely on the
issues specific to the EIR subsequently prepared. Tiering is appropriate when the sequence of
EIRs is:
(a) From a general plan, policy, or program EIR to a program, plan, or policy EIR of
lesser scope or to a site-specific EIR.
(b) From an EIR on a specific action at an early stage to a subsequent EIR or a supplement to
an EIR at a later stage. Tiering in such cases is appropriate when it helps the Lead Agency to
focus on the issues which are ripe for decision and exclude from consideration issues already
decided or not yet ripe. (CEQA Guidelines Section 15385).
Tribal Cultural Resources are either of the following:
(1) Sites, features, places, cultural landscapes, sacred places, and objects with cultural
value to a California Native American tribe that are either of the following:
(A) Included or determined to be eligible for inclusion in the California Register
of Historic Resources.
(B) Included in a local register of historic resources as defined in PRC Section 5020.1(k).
(2) A resource determined by the Lead Agency, in its discretion and supported by substantial
evidence, to be significant pursuant to criteria set forth in PRC Section 5024.1(c), In applying
the criteria set forth in PRC Section 5024.1(c) for the purposes of this paragraph, the Lead
Agency shall consider the significance of the resource to a California Native American tribe
(PRC Section 21074).
4City of Orange Local CEQA Guidelines
B. Common Acronyms
CCR California Code of Regulations
CDFW California Department of Fish and Wildlife
CEQA California Environmental Quality Act
EIR Environmental Impact Report
GHG Greenhouse Gas
IS Initial Study
MMRP Mitigation Monitoring and Reporting Program
MND Mitigated Negative Declaration
ND Negative Declaration
NOA Notice of Availability
NOC Notice of Completion
NOD Notice of Determination
NOE Notice of Exemption
NOI Notice of Intent
NOP Notice of Preparation
OMC Orange Municipal Code
OPR State of California Office of Planning and Research
PRC California Public Resources Code
SCH State Clearinghouse
VMT Vehicle Miles Traveled
5City of Orange Local CEQA Guidelines
3. ENVIRONMENTAL REVIEW PROCESS
A. Community Development Department
The primary responsibility for implementing the provisions of CEQA as specified in the CEQA
Guidelines and these Local CEQA Guidelines shall be with the Community Development
Director. The Community Development Director shall be responsible for coordinating CEQA
compliance for private development projects, and for projects initiated or authorized by other
City departments (in cooperation with that department). Community Development Director
responsibilities include the following:
11. Review proposed activities and determine the applicability of CEQA and these Local CEQA
Guidelines.
12. Determine whether a project is exempt from CEQA.
13. Prepare or cause preparation of an Initial Study and determine whether to prepare
a Negative Declaration, Mitigated Negative Declaration, or Environmental Impact
Report (EIR).
14. Prepare a Negative Declaration, Mitigated Negative Declaration or EIR pursuant to CEQA
and these Local CEQA Guidelines.
15. Coordinate internal review of environmental documentation with other City departments, as
necessary.
16. Coordinate the preparation and processing of environmental documentation through the
public review and decision-making process. Ensure adequate opportunity and time for
public review and comment as required by CEQA and these Local CEQA Guidelines.
17. Coordinate the preparation of required noticing and circulation of environmental documents,
including the circulation of documents through the Office of Planning and Research or other
agencies with reviewing and/or approving authority.
18. Prepare responses to public comments, pursuant to CEQA and these Local CEQA Guidelines.
19. File notices pursuant to CEQA and these Local CEQA Guidelines, including Notices of
Determination, Notices of Exemption, and California Department of Fish and Wildlife
(CDFW) Environmental Document Filing Fees or CDFW No Effect Determinations.
10. Maintain all environmental records such as Notices of Determination, Notices of Preparation,
Initial Studies, Negative Declarations, Mitigated Negative Declarations, and EIRs and related
documents.
11. For City projects, determine environmental scope of work, schedule, and budget; coordinate
preparation of environmental documents and required noticing; retain environmental
consultants if necessary; and oversee and direct consultant work products.
6City of Orange Local CEQA Guidelines
12. Assume the responsibility of the Mitigation Monitoring and Reporting Program.
Coordinate with other City departments regarding the adequacy and monitoring of
mitigation measures.
13. Coordinate the review and comment upon environmental documentation circulated by
other cities and agencies.
14. Update the Local CEQA Guidelines and internal procedures as necessary to ensure
consistency with CEQA and the State CEQA Guidelines. Revisions to internal procedures
for implementing these Local CEQA Guidelines shall be made at the discretion of the
Community Development Director.
B. Determining Whether a Project is Subject to CEQA
The first step in the environmental review process is to determine whether an activity is
subject to CEQA.
Activities Subject to CEQA
CEQA applies to Discretionary Projects proposed to be carried out or
approved by public agencies such as the City. Project means the whole of
an action, which has a potential for resulting in either a direct physical
change in the environment, or a reasonably foreseeable indirect
physical change in the environment (CEQA Guidelines Section
15378).
Typical City discretionary activities that are subject to CEQA include,
but are not limited to, public works construction; enactment and
amendment of zoning ordinances; the adoption or amendment of a
General Plan or its elements; or issuance of a lease, permit, license,
certificate or other entitlement for use (e.g., administrative adjustment,
temporary use permit, variance, minor site plan review, major site plan
review, conditional use permit, design review, and approval of parcel maps
and tentative tract maps).
Activities Not Subject to Environmental Review
An activity is not subject to CEQA if the activity does not result in physical changes to the
environment; does not involve discretionary action by the City; or is not a “project” as defined
by CEQA (CEQA Guidelines Sections 15060 and 15378).
Activities that are “ministerial” (not discretionary), as defined in CEQA Guidelines Sections
15268 and 15369, are not subject to CEQA review or these Local CEQA Guidelines.
A ministerial action is one that is approved or denied by a decision that a public official
7City of Orange Local CEQA Guidelines
makes that involved only the use of fixed standards or objective measurements without personal
judgement or discretion. City ministerial actions include, but are not limited to, issuance of grading
and building permit, certificate of occupancy, final subdivision map, approval of individual utility
service connections or disconnections, demolition permit that does not trigger “demolition
review”, outdoor dining permit, encroachment permit, haul permit, and business license.
When approval of a project has both ministerial and discretionary elements, the project approval
shall be deemed discretionary and subject to the requirements of CEQA (CEQA Guidelines
Section 15268).
C. Projects that are Exempt from CEQA
CEQA and the CEQA Guidelines exempt certain activities and provide that local agencies should
further identify and describe certain exemptions. The requirements of CEQA and the obligation
to prepare an EIR, ND or MND generally do not apply to the exempt activities that are set forth
in CEQA, the CEQA Guidelines and these Local CEQA Guidelines.
Exemption Determination
Once it has been established that an activity is a “project” and is subject to CEQA, the project
shall be reviewed to determine if it is statutorily, categorically, or otherwise exempt from CEQA.
The criteria for determining whether a project is exempt are identified in Articles 18 and 19 of
the CEQA Guidelines. The Community Development Director has the authority to determine
whether a project reasonably falls within an exemption category and meets the intent of the
CEQA Guidelines.
Statutory Exemptions
Statutory exemptions are exemptions established by the State Legislature for specific types of
projects, and are exempt from CEQA regardless of their environmental impacts. Project that qualify
for a statutory exemption are identified in CEQA Guidelines Article 18 and do not require further
environmental review. These projects include, but are not limit to, ongoing projects; feasibility
and planning studies; emergency projects; projects which are disapproved; rates, tolls, fares, and
charges; family day care homes; specified mass transit projects; transportation improvement and
congestion management programs; conversion of a mobile home park to a resident-initiated
subdivision; railroad grade separation projects; the adoption of an ordinance regarding second
units in a single-family or multi-family residential zone; the closing of a public school or transfer of
students from one public school to another; restriping of streets; new pipelines or maintenance or
demolition of existing pipelines less than one mile in length and located within the public right-
of-way; the adoption of bicycle transportation plans for urban areas; and the installation of solar
energy systems, including, but not limited to, solar panels.
8City of Orange Local CEQA Guidelines
Categorical Exemptions
Categorical exemptions are categories or classes of projects that are exempt from environmental
review requirements because they have been found by the State’s Secretary of Resources to be
generally (emphasis added) incapable of resulting in significant environmental effects. Projects
that qualify for a categorical exemption are discussed in CEQA Guidelines Article 19, and do not
require further environmental review. There are over 30 classifications of categorical exemptions
that include such activities as minor additions to existing buildings, construction of new small
structures, and conversion of small structures from one use to another (if only minor exterior
building modifications are involved).
The City Council hereby finds those classes of activities set forth in CEQA Guidelines Sections
15301 through 15333 to be categorically exempt, unless they are subject to one of the following
exceptions.
Exceptions to Categorical Exemptions
Pursuant to CEQA Guidelines Section 15300.2, there may be instances where unusual
circumstances cause a project that generally qualifies for a categorical exemption to be subject to
more extensive environmental review. A project shall not be categorically exempt if:
1. Classes 3, 4, 5, 6 and 11 are qualified by consideration of where the project is located – a
project that is ordinarily insignificant in its impact on the environment may in a particularly
sensitive environment be significant. Therefore, these classes are considered to apply in all
instances, except where the project may impact an environmental resource of hazardous or
critical concern that has been designated, precisely mapped, and officially adopted pursuant
to law by federal, state, or local agencies;
2. The project would result in significant cumulative impacts;
3. There is a reasonable possibility that the project could result in significant impacts to the
environment due to unusual circumstances;
4. The project would result in damage to scenic resources within a designated state scenic
highway;
5. The project is located on a hazardous waste site that is included on any list compiled pursuant
to Government Code Section 65962.5; or
6. The project may cause a substantial adverse change in the significance of a historical resource.
However, a project’s greenhouse gas emissions do not, in and of themselves, cause a categorical
exemption to be inapplicable if the project otherwise complies with all applicable regulations or
requirements of a statewide, regional, or local greenhouse gas emission reduction plan, consistent
with the description of such plans provided in CEQA Guidelines Section 15183.5.
9City of Orange Local CEQA Guidelines
“Comment Sense” Exemptions
A project is exempt from CEQA if the activity is covered by the comment sense exemption that
CEQA applies only to projects which have the potential for causing a significant effect on the
environment. Where it can be seen with certainty that there is no possibility that an activity may
have a significant effect on the environment, the activity is not subject to CEQA or these Local
CEQA Guidelines (CEQA Guidelines Section 15061(b)(3)).
Special Exemptions
Agricultural housing, affordable housing, and residential infill projects that meet certain site,
location, use, size/density, environmental and/or housing criteria as specified in Article 12.5 of
the CEQA Guidelines are exempt from CEQA review.
In addition, “Transit Priority Projects” that are consistent with the general use designation, density,
building intensity, and applicable policies specified for the project area in either a “Sustainable
Community Strategy” or an “Alternative Planning Strategy” may be exempt from CEQA. To
qualify for the exemption, the Decision-Making Body must hold a hearing and make findings that
the project meets all of the environmental criteria and requirements in PRC Section 21155.1.
Completing and Filing a Notice of Exemption
After approval of an exempt project, a Notice of Exemption (NOE) may be filed (emphasis added),
at the discretion of the Community Development Director. If the City exempts an agricultural
housing, affordable housing, or residential infill project under CEQA Guidelines Sections 15193,
15194 or 15195 and approves or determines to carry out that project, it must file a NOE pursuant
to CEQA Guidelines Section 15062.
A NOE will be prepared in compliance with CEQA Guidelines Section 15062. The NOE will
include a description of the project, the project location, a finding that the project is exempt from
CEQA, including a citation to the CEQA Guidelines section or statute under which it is found to
be exempt, a brief statement of reasons to support the finding, and the Applicant’s name and/or
the identity of the person undertaking the project, including any person undertaking an activity
that receives financial assistance from the City as part of the project or the person receiving a
lease, permit, license, certificate, or other entitlement for use from the City as part of the project.
The NOE shall be filed with the Orange County Clerk after project approval. The Orange County
Clerk typically requires a processing fee for filing the NOE, which is to be paid by the Applicant.
In addition, if a NOE will be filed and the project involves a state agency approval, then the NOE
will be filed with the Office of Planning and Research State Clearinghouse.
In accordance with the CEQA Guidelines, the Orange County Clerk or Office of Planning and
Research (as applicable) posts the NOE, and returns it to the City for the administrative record
after a 30-day posting period. Filing the NOE with the Orange County Clerk starts a 35-day
10City of Orange Local CEQA Guidelines
statute of limitations for legal challenge to the City’s determination that the project is exempt
from environmental review. If a NOE is not filed, the statute of limitations for legal challenge is
180 days in accordance with the CEQA Guidelines.
Permit Streamlining and Preliminary Review
For private projects, the determination of whether a project is subject
to CEQA and exempt from CEQA shall be made and evaluated
concurrently (emphasis added) with the initial review of the
application for completeness under the Permit Streamlining Act.
Under the Permit Streamlining Act, the City has 30 days from
the time of receipt of an application to notify the Applicant
in writing of whether an application is accepted as complete.
If the application is incomplete, the written notification
shall list and describe the specific information required to
complete the application. This written notification shall include
a determination by the City as to whether the application is
subject to CEQA, exempt from CEQA, or if additional information
(including environmental technical studies) are required in order to
make a CEQA determination. In making a determination as to whether
additional information is required, the Community Development Director
shall consult with representatives from other City departments. Typically, the
Community Development Director will obtain technical studies from the Applicant (as
necessary in order to evaluate the project) prior to accepting the application as complete.
If written notification is not provided within 30 days, then on the 30th day after receipt, the
application is automatically deemed complete. Accepting an application as complete does not
limit the authority of the City to require the Applicant to submit additional information needed
for environmental evaluation of the project. Requiring such additional information after the
application is complete does not change the status of the application.
D. Initial Study Process
If a project is subject to CEQA and is not exempt, the City shall conduct an Initial Study in
accordance with the requirements established in CEQA Guidelines Section 15063 to determine
if the project may have a significant effect on the environment. All phases of project planning,
implementation and operation must be considered in the Initial Study. An Initial Study may
rely upon expert opinion supported by facts, technical studies or other substantial evidence to
document its finding. However, an Initial Study is neither intended nor required to include the
level of detail included in an EIR. If the City determines that an EIR will clearly be required for
the project, an Initial Study is not required but may still be desirable.
11City of Orange Local CEQA Guidelines
The process for completing an Initial Study is as follows:
1. If a project is subject to CEQA and is not exempt, the Community Development Director will
prepare or cause preparation of an Initial Study to evaluate the potential for the project to cause
a significant effect on the environment, and make a determination as to the “significance” of
project impacts.
The Initial Study shall describe and evaluate the impacts of all phases of project planning,
construction, implementation, and operations. The Initial Study shall include a description
of the project including its location, objectives, components and characteristics. The project
description shall identify all discretionary approvals needed to implement the project and shall
identify all public agencies including “responsible” or “trustee” agencies with jurisdiction over
the project. The project description must be consistent throughout the environmental review
process.
The Initial Study shall describe the project’s environmental setting. The environmental setting
usually means the existing physical environmental conditions in the vicinity of the project,
as they exist at the time the Notice of Preparation is published for an EIR, or if no Notice of
Preparation is published, such as in the case of a Negative Declaration or Mitigated Negative
Declaration, at the time environmental analysis begins. The environmental setting should
describe both the project site and surrounding properties. This environmental setting will
normally constitute the “baseline” physical conditions against which the City will compare
the project to determine whether a project impact is significant. Notwithstanding the above,
the City has the discretion to identify a baseline that it determines most appropriately reflects
existing conditions based on the specific facts surrounding a particular project. For example,
a different baseline may be appropriate in cases where existing on-the-ground conditions are
cyclical or fluctuate over time.
The Initial Study shall include a written evaluation of the project’s environmental effects
including direct, indirect, individual, cumulative, and any reasonably foreseeable impacts. A
written analysis shall be provided to support a “potentially significant impact,” “less than
significant with mitigation incorporated,” “less than significant,” or “no impact” conclusion for
each Initial Study checklist question. The written analysis shall provide a reasoned evaluation of
potential impacts, and its conclusions shall be based on facts, reasonable assumptions based
on facts, expert opinion supported by facts, technical studies, or other substantial evidence.
The Initial Study shall include a discussion of the ways to mitigate the significant effects
identified, if any; an examination of whether the project would be consistent with existing
zoning, plans, and other applicable land use controls; and the name of the person or persons
who prepared or participated in the Initial Study.
12City of Orange Local CEQA Guidelines
The Initial Study will follow the format of the City’s Initial Study checklist as shown in
Appendix B of these Local CEQA Guidelines, or as subsequently amended by the
Community Development Director. The City’s Initial Study checklist is the same as the
checklist provided in Appendix G of the CEQA Guidelines, with the exception of additional
checklist questions in the Hydrology and Water Quality section. These additional checklist
questions are included pursuant to the recommendations of the County of Orange’
Drainage Area Management Plan (DAMP).
2. The Community Development Director will provide the Initial Study checklist and other
technical information to representatives from appropriate City departments for coordination
and concurrence prior to its release for public review. Each department is responsible for
evaluating the Initial Study (as related to its area of expertise), determining whether information
is accurate, determining whether the analysis sufficiently evaluates project impacts, and
recommending specific Initial Study revisions or project modifications (as appropriate) that will
address environmental concerns. Each department shall be responsible for providing timely
feedback to the Community Development Director in writing. The Community Development
Director shall be responsible for inter-departmental coordination, resolving internal conflicts,
communications with the Applicant, and overall compliance with CEQA requirements.
3. Based on preliminary project review and/or the evaluation in the Initial Study, within 30 days
after accepting the application as complete, the Community Development Director will
determine in accordance with CEQA Guidelines Section 15102 whether to:
a. Prepare an EIR; or
b. Use a previously prepared EIR which the City determines would adequately analyze the
project at hand; or
c. Determine, pursuant to a program EIR, tiering, or another appropriate process, which of a
project’s effects were adequately examined by an earlier EIR or Negative Declaration.
4. The Community Development Director will prepare or cause preparation of a Negative
Declaration if there is no substantial evidence that the project or any of its aspects may cause
a significant effect on the environment and if impacts are determined to
be “less than significant.” A Mitigated Negative Declaration shall
be prepared if project impacts are determined to be “less
than significant” with the implementation of mitigation
measures. An EIR shall be prepared if project impacts
are determined to be “potentially significant” or
“significant.” The Negative Declaration, Mitigated
Negative Declaration, or EIR shall be prepared
and processed concurrently with the application
for a permit or entitlement for use.
13City of Orange Local CEQA Guidelines
E. Negative Declaration Process
A Negative Declaration is prepared when an Initial Study shows that there is no substantial
evidence, in light of the whole record before the City, that the project may have a significant effect
on the environment. A Negative Declaration is a document that contains a project description,
the location of the project, the name of the project proponent, a specific finding that states that
the project will not have significant effects on the environment, and an attached copy of the Initial
Study documenting reasons to support the finding.
A Mitigated Negative Declaration is prepared for a project when the Initial Study identifies
potentially significant effects, but before the Mitigated Negative Declaration and Initial Study are
released for public review, revisions in the project plans or proposals are made by, or agreed to
by the Applicant that would avoid the effects or mitigate the effects to a point where clearly no
significant effects would occur, and there is no substantial evidence that the project as revised
may have a significant effect on the environment.
Negative Declaration or Mitigated Negative Declaration
The Applicant shall retain an environmental consultant to prepare the Negative Declaration or
Mitigated Negative Declaration, per Section 10 of these Local CEQA Guidelines. The Negative
Declaration or Mitigated Negative Declaration prepared under contract will be the City’s product.
Where a document is prepared by the Applicant’s environmental consultant, City staff shall be
responsible for reviewing the document to ensure that the document is objective and includes
an appropriate level of analysis. A Negative Declaration or Mitigated Negative Declaration made
available for public review must reflect the independent judgement of the City. No action may
be taken on the project until completion of the Negative Declaration or Mitigated Negative
Declaration process.
A Negative Declaration or Mitigated Negative Declaration circulated for public review shall
include a brief description of the project, including the commonly used name for the project, the
location of the project shown on a map, and the name of the Applicant, a proposed finding that
the project will not have a significant effect on the environment, an attached copy of the Initial
Study documenting reasons to support the finding, and mitigation measures, if any, included in
the project to avoid potentially significant effects.
Notice of Intent and Public Review for a Negative Declaration
Staff shall prepare and file a Notice of Intent (NOI) to adopt a Negative Declaration or Mitigated
Negative Declaration in compliance with CEQA Guidelines Sections 15072 and 15073. The NOI
shall be filed with the Orange County Clerk at least 20 days prior to the adoption of the Negative
Declaration or Mitigated Negative Declaration to allow for a 20-day public review period. The
NOI shall contain a description of the project; the project location; the starting and ending dates
for the public review period; contact name and address (including email address) where written
14City of Orange Local CEQA Guidelines
comments can be submitted; the date, time and place of any scheduled public meetings or
hearings on the project; and the address where copies of the Negative Declaration or Mitigated
Negative Declaration are available for public review.
The NOI shall be posted on the City’s website and at the Orange County Clerk’s Office, shall be
mailed to all organizations and individuals who previously requested the notice in writing, and
shall be otherwise made available to the public by at least one of the following three methods:
1. Publication in a local newspaper;
2. Posting the notice on and off site in the area where the project is to be located; and/or
3. Direct mailing to owners and occupants of properties within 300 feet of the project site.
The NOI and the Negative Declaration or Mitigated Negative Declaration shall be distributed (via
any method of transmittal that provides a record of receipt) to all responsible agencies, trustee
agencies and any other agencies with jurisdiction by law over resources affected by the project.
If a state agency is a responsible or trustee agency, or if the project is a project of “statewide,
regional or area wide significance” (as defined in CEQA Guidelines Section 15206), the public
review period shall be 30 days in accordance with CEQA Guidelines Sections 15072 and 15073, and
an appropriate number of copies of the Negative Declaration or Mitigated Negative Declaration
and a State Clearinghouse transmittal form shall be submitted to the Office of Planning and
Research (State Clearinghouse) for distribution to state agencies.
The Negative Declaration or Mitigated Negative Declaration and comments received during
the public review period shall be forwarded to the recommending body and the final Decision-
Making Body for consideration prior to a decision on the project (CEQA Guidelines Section
15074). The recommending and final Decision-Making Bodies are defined in Section VII of these
Local CEQA Guidelines.
The NOI and required public hearing notices should be combined whenever
possible. The Negative Declaration or Mitigated Negative Declaration must
be completed and approved within 180 days from the date when the
application was accepted as complete (CEQA Guidelines Section 15107).
Notice of Determination
Within five working days of the final approval of a project for which a
Negative Declaration or Mitigated Negative Declaration is prepared,
a Notice of Determination (NOD) shall be prepared, in accordance
with CEQA Guidelines Section 15075, and filed with the Orange
County Clerk. When the project requires discretionary approval from
a state agency and the Negative Declaration or Mitigated Negative
Declaration has been submitted to the Office of Planning and Research,
the NOD shall also be filed with the Office of Planning and Research.
15City of Orange Local CEQA Guidelines
The NOD shall contain the project name, project location, project description, date of project
approval, a determination as to whether the project will have a significant effect on the environment,
and the address where the record of project approval is available for public review.
The Orange County Clerk and/or the Office of Planning and Research will file the NOD and return
it to the City after a 30-day posting period. Filing the NOD starts a 30-day statute of limitations
for legal challenges to the approval. If an NOD is not filed, the statute of limitations for legal
challenge is 180 days (CEQA Guidelines Section 15075, 15112).
Compliance with California Fish and Game Code Section 711.4
If a Negative Declaration or Mitigated Negative Declaration is prepared for a project, and based
on the associated Initial Study, the Community Development Director determines that the project
would not have any adverse impact to fish or wildlife, then the Community Development Director
shall prepare and submit a request for a No Effect Determination to the California Department of
Fish and Wildlife. The request form and supporting information (such as the Initial Study) should
be submitted to the CDFW concurrently with the start of the CEQA public review period. The
CDFW will review the request and either provide a No Effect Determination to the City, or the
CDFW will notify the City that payment of the CDFW fees is required. If CDFW determines that
the project is Fee Exempt, then the City shall file the signed No Effect Determination letter with
the Orange County Clerk concurrently with the NOD, in compliance with Fish and Game Code
Section 711.4(c)(2). Fish and Game Code Section 89.5 defines “wildlife” as all wild animals, birds,
plants, fish, amphibians, and related ecological communities, including the habitat upon which
the wildlife depends for its continued viability.
If the CDFW determines that the project would have an adverse impact to “wildlife” and a
payment of CDFW fees is required, then the Applicant shall provide a cashier’s check to the City,
payable to the Orange County Clerk, in an amount specified in Fish and Game Code Section
711.4(d)(2), including applicable County filing fees. The City shall provide the cashier’s check to
the Orange County Clerk concurrently with the NOD.
Permit Streamlining and Time Limits for Negative Declarations
and Mitigated Negative Declarations
Pursuant to CEQA Guidelines Section 15107 the City must adopt a Negative Declaration
or Mitigated Negative Declaration (as applicable) within 180 days from the date on which it
accepted the application as complete. Under the Permit Streamlining Act, the City must approve
or disapprove the project application within 180 days from the date on which it adopts the
Negative Declaration or Mitigated Negative Declaration. These time limits will be suspended for
unreasonable delay by an Applicant in meeting requests by the City (CEQA Guidelines Section
15109).
16City of Orange Local CEQA Guidelines
F. Environmental Impact Report Process
An EIR shall be prepared whenever there is substantial evidence in light of the whole record
supporting a fair argument that the project may have a significant effect on the environment. The
record may include the Initial Study or other documents or studies prepared to assess the project’s
environmental impacts. The Applicant shall retain an environmental consultant to prepare the EIR,
per Section 10 of these Local CEQA Guidelines. The EIR prepared under contract will be the City’s
product. Where a document is prepared by the Applicant’s environmental consultant, City staff
shall be responsible for reviewing the document to ensure that the document is objective and
includes an appropriate level of analysis. The EIR made available for public review must reflect the
independent judgement of the City. No action may be taken on the project until completion of the
EIR process. The process for preparing an EIR occurs as follows:
Notice of Preparation and Public Comment
After determining that an EIR will be required for the proposed project, the City shall prepare and
send a Notice of Preparation (NOP). The NOP shall state that an EIR will be prepared for the project
and establish a 30-day public comment period during which written comments from agencies and
the public will be accepted. The NOP shall contain a description of the project, project location,
a description of the probable environmental effects of the project, the starting and ending dates
for the public comment period, the date, time and location of any scheduled public “scoping”
meetings for the project, and the address where copies of the project’s Initial Study (if prepared) are
available for public review. An Initial Study is not a required component of the NOP process, but
may be prepared at the discretion of the Community Development Director as a public information
tool, or as a means of focusing the topics addressed in the EIR.
The NOP shall be distributed, via any method of transmittal that provides a record of receipt, to
all responsible agencies involved with approving or funding the project, trustee agencies, and
agencies with jurisdiction by law over resources affected by the project. If a state agency is a
responsible or trustee agency, or if the project is a project of “statewide, regional or area wide
significance” (as defined in CEQA Guidelines Section 15206), the appropriate number of copies
of the NOP and a State Clearinghouse transmittal form shall be sent to the Office of Planning and
Research (State Clearinghouse) for distribution to state agencies. In addition, for certain projects,
consultation with water agencies may be required during the NOP process.
The NOP shall also be direct mailed to adjacent cities, the County of Orange, any person who has
requested (in writing) to be notified of the project review, and shall be otherwise made available to
the public by posting on the City’s website and at least one of the following three methods:
1. Publication in a local newspaper;
2. Posting the notice on and off site in the area where the project is to be located; and/or
3. Direct mailing to owners and occupants of properties within 300 feet of the project site.
17City of Orange Local CEQA Guidelines
Scoping Meetings
Scoping meetings shall be held for “projects of statewide, regional or area wide significance” as
described in CEQA Guidelines Sections 15082 and 15206. Scoping meetings are not required
by CEQA for projects that are not “projects of statewide, regional or area wide significance,”
but may be helpful to the project’s public participation process. Also, if held early in the process,
scoping meetings can be used to identify and address issues of public concern. Scoping meetings
should be held during the public comment period established for the NOP and noticing should
be combined with the NOP whenever possible.
Draft EIR
Preparation of the draft EIR shall appropriately address comments received as responses to the
NOP. The required contents of the draft EIR are described in CEQA Guidelines Article 9, and
include an executive summary, description of the existing setting, environmental impact analysis
including direct, indirect and cumulative impacts, mitigation measures, and an alternatives analysis.
Further, CEQA Guidelines Article 10 provides helpful guidance in preparing EIRs. If an EIR is
prepared by the Applicant and/or an environmental consultant, prior to release for public review
the Community Development Department shall review the EIR, coordinate with
other City departments on the adequacy of the document and the
appropriateness of mitigation measures, and direct revisions as
necessary to ensure that the analysis is adequate, objective,
and reflects the City’s independent judgment.
Notice of Completion, Notice of
Availability, and Public Review for
a Draft EIR
After completion of the draft EIR, a Notice of
Completion (NOC) and the appropriate number
of copies of the EIR must be filed with the Office
of Planning and Research in accordance with
CEQA Guidelines Section 15085 to begin the
public review period.
A Notice of Availability (NOA) for public review
of the draft EIR shall be prepared and distributed
at the same time the NOC is filed, in accordance
with CEQA Guidelines Section 15087. The NOA shall
include a description of the project and location, start
and end dates for the public review period during which the
City will receive comments and the manner in which the City
will receive those comments, contact name and address (including
email address) where written comments can be submitted, address where
18City of Orange Local CEQA Guidelines
copies of the EIR are available for public review, the date time and location for any scheduled
public meetings or hearings, a list of significant environmental effects anticipated to result from
the project, the address where copies of the EIR and all documents incorporated by reference in
the EIR will be available for public review, and the presence of the site on any of the lists of sites
enumerated under Government Code Section 65962.5.
The NOA shall be distributed, via any method of transmittal that provides a record of receipt, to
all responsible agencies, trustee agencies, other agencies with jurisdiction by law over resources
affected by the project, adjacent cities, the County of Orange, and the last known name and
address of all organizations and individuals who have previously filed a written notice with the
City to receive these notices. If the project is a project of “statewide, regional or area wide
significance”, the NOA and the EIR shall also be distributed to public transit agencies with
facilities within one-half mile of the proposed project (CEQA Guidelines Section 15086). In
addition, for certain projects, water agencies consulted during the NOP process may also be
required to receive the NOA and EIR.
The NOA shall be posted on the City’s website, direct mailed to any person who has requested
(in writing) to be notified of the project review, and shall be otherwise made available to the
public by at least one of the following three methods:
1. Publication in a local newspaper;
2. Posting notice on and off the site in the area where the project is to be located; and/or
3. Direct mailing to owners and occupants of properties within 300 feet of the project site.
The NOA is filed with the Orange County Clerk to begin the public review period. The public
review period for an EIR shall be a minimum of 45 days. The public review period may be 60
days at the discretion of the Community Development Director. Any requests to shorten the
required review period must be made by the Community Development Director to the State
Clearinghouse. The State Clearinghouse-established review period for state agencies and the
general public review period for the EIR should be coordinated whenever possible.
Copies of the draft EIR shall also be made available at the City of Orange City Hall for review by
members of the general public. The City may require any person obtaining a copy of the draft
EIR to reimburse the City for the actual cost of its reproduction. Copies of the draft EIR should
also be furnished to City public libraries.
The City is encouraged to make copies of filed notices and the draft EIR available in electronic
format on the City’s website. Such electronic postings are in addition to the procedures required
by the CEQA Guidelines and the PRC.
19City of Orange Local CEQA Guidelines
Response to Comments
After completion of the draft EIR public review period, the City shall evaluate the comments on
environmental issues received during the noticed comment period and any extensions
and shall prepare a written response to comments raising significant
environmental issues. The City may respond to late comments at its
discretion.
The written response shall describe the disposition of
significant environmental issues raised. In particular, the
major environmental issues raised when the City’s position
is at variance with recommendations and objections
raised in the comments must be addressed in detail
giving reasons why specific comments and suggestions
were not accepted. There must be good faith,
reasoned analysis in response. Conclusory statements
unsupported by factual information will not suffice.
The level of detail contained in the response, however,
may correspond to the level of detail provided in the
comment. A general response may be appropriate when
a comment does not contain or specifically refer to readily
available information, or does not explain the relevance of
evidence submitted with the comment (CEQA Guidelines
Section 15088).
Final EIR
After completion of the draft EIR public review period, a final EIR shall be prepared in accordance
with CEQA Guidelines Sections 15089. Required contents of a final EIR are specified in CEQA
Guidelines Section 15132, and consist of the draft EIR or revision of the draft; comments and
recommendations received on the draft EIR; a list of persons, organizations and public agencies
commenting on the draft EIR; the City’s response to comments; and any other information added
by the City.
The final EIR shall be forwarded to the recommending and final decision-making bodies (i.e.,
Planning Commission, City Council) as defined in Section 7 of these Local CEQA Guidelines for
consideration prior to certifying or recommending certification of the EIR. In addition, the final EIR
is required to be provided to public agencies that commented on the EIR (PRC Section 21092.5)
via any method of transmittal that provides a record of receipt, and shall also be made available
to the general public for review at least 10 days prior to a certification of the final EIR.
Prior to approving the project, the final Decision-Making Body must consider the information
presented in the final EIR, certify the EIR (CEQA Guidelines Section 15090), and make certain
findings for each significant impact identified in the final EIR (CEQA Guidelines Section 15091).
20City of Orange Local CEQA Guidelines
When the Lead Agency approves a project that will result in significant unavoidable impacts, a
Statement of Overriding Considerations must be adopted. If the Decision-Making Body finds
in the Statement of Overriding Considerations that specific benefits of a proposed project
outweigh the unavoidable adverse environmental effects, the adverse environmental effects may
be considered “acceptable.” Project benefits that are appropriate to consider in the Statement of
Overriding Considerations include the economic, legal, environmental, technological and social
value of the project. When the Lead Agency approves a project that will result in the occurrence
of significant effects which are identified in the final EIR but are not avoided or substantially
lessened, the agency will state in writing the specific reasons to support its action based on the
final EIR and/or other information in the record. The Statement of Overriding Considerations must
be supported by substantial evidence in the record (CEQA Guidelines Section 15093).
The final EIR must be completed and certified within one year from the date when the application
was accepted as complete. City procedures provide that a one-year time limit may be extended
once for a period of not more than 90 days upon consent of the City and the Applicant (CEQA
Guidelines Section 15108). An unreasonable delay by an Applicant in meeting requests by the
City necessary for the preparation of an EIR shall suspend the running of the time periods for the
period of the unreasonable delay. Alternatively, the City may disapprove a project application
where there is unreasonable delay in meeting requests. The City may allow a renewed application
to start at the same point in the process where the application was when it was disapproved
(CEQA Guidelines Section 15109).
Notice of Determination
Within five working days of the decision to approve a project for which an EIR is prepared, a
Notice of Determination shall be prepared, in accordance with CEQA Guidelines Section 15094,
and filed with the Orange County Clerk. The NOD shall also be filed with the Office of Planning
and Research. The filing and posting of a NOD with the County Clerk, and if necessary, with the
Office of Planning and Research, usually states a 30-day statute of limitations on court challenges
to the approval under CEQA. When separate notices are filed for successive phases of the same
overall project, the 30-day statute of limitations to challenge the subsequent phase begins to run
when the second notice is filed.
Permit Streamlining and Time Limits for EIRs
Pursuant to CEQA Guidelines Section 15108, the City must certify an EIR for a project within
one year from the date on which it accepted the application as complete. Under the Permit
Streamlining Act, the City must approve or disapprove the project application within 180 days
from the date on which it certifies the EIR, or within 90 days of certification of an EIR if an extension
for completing and certifying the EIR was approved by the Community Development Director.
These time limits will be suspended for unreasonable delay by an Applicant in meeting requests
by the City.
21City of Orange Local CEQA Guidelines
G. Tiering
“Tiering” refers to using the analysis of general matters contained in a previously certified broader
EIR in later EIRs, Negative Declarations, or Mitigated Negative Declarations prepared for narrower
projects. The later EIR, Negative Declaration, or Mitigated Negative Declaration may incorporate
by reference the general discussions from the broader EIR and may concentrate solely on the
issues specific to the later project (CEQA Guidelines Section 15152).
City of Orange Environmental Checklist for Subsequent Projects (Appendix C of these Local CEQA
Guidelines) will be used when the City is reviewing subsequent discretionary actions pursuant to
previously adopted or certified environmental document.
Subsequent EIRs and Negative Declarations
When an EIR has been certified or a Negative Declaration adopted for a project, a subsequent
EIR or Negative Declaration will be prepared if substantial changes are proposed to the project,
substantial changes occur with respect to the circumstances under which the project is undertaken,
or new information of substantial importance, which was not known and could not have been
known with the exercise of reasonable diligence at the time the previous EIR was certified or the
Negative Declaration was adopted, which will involve new significant environmental effects or a
substantial increase in the severity of previously identified significant effects. A subsequent EIR or
subsequent Negative Declaration will be given the same notice and public review as required
under CEQA Guidelines Sections 15087 or 15072. A subsequent EIR or Negative Declaration will
state where the previous document is available and can be reviewed (CEQA Guidelines Section
15162).
Supplement to an EIR
The City may choose to prepare a supplement to an EIR rather than a subsequent EIR if any of
the conditions described in CEQA Guidelines Section 15162 would require the preparation of a
subsequent EIR and only minor additions or changes would be necessary to make the previous
EIR adequately apply to the project in the changed situation. The supplement to the EIR need
contain only the information necessary to make the previous EIR adequate for the project as
revised. A supplement to an EIR will be given the same kind of notice and public review as given
to a draft EIR under CEQA Guidelines Section 15087 and may be circulated by itself without
recirculating the previous draft or final EIR (CEQA Guidelines Section 15163).
Addendum to an EIR or Negative Declaration
The City will prepare an addendum to a previously certified EIR or adopted Negative Declaration if
minor technical changes or additions are necessary but none of the conditions described in CEQA
Guidelines Section 15162 calling for preparation of a subsequent EIR or Negative Declaration have
22City of Orange Local CEQA Guidelines
occurred. An addendum does not need to be circulated for public review but can be included
in or attached to the final EIR or adopted Negative Declaration. The Decision-Making Body will
consider the addendum with the final EIR or adopted Negative Declaration prior to making a
decision on the project. A brief explanation of the decision not to prepare a subsequent EIR
pursuant to CEQA Guidelines Section 15162 should be included in the addendum, the findings
on the project, or elsewhere in the record. The explanation must be supported by substantial
evidence (CEQA Guidelines Section 15164).
Projects Pursuant to a Specific Plan
Certain residential, commercial, and mixed-use projects that are consistent with a specific plan
adopted pursuant to Title 7, Division 1, Chapter 3, Article 8 of the Government Code are exempt
from CEQA.
Where the City has prepared an EIR on a specific plan, any residential project, including land
subdivisions, zoning changes and residential planned unit development that is undertaken
pursuant to and in conformity to that specific plan is exempt from CEQA. If after the adoption of
the specific plan, an event described in CEQA Guidelines Section 15162 occurs, the exemption
will not apply until the City completes a subsequent EIR or a supplement to an EIR on the specific
plan. This exemption will again be available to residential projects after the City has filed a Notice
of Determination on the specific plan as reconsidered by the subsequent EIR or supplement to
the EIR (CEQA Guidelines Section 15182).
H. Mitigation Measures
The City, as Lead Agency, has the authority to require changes in the project to lessen or avoid
significant effects on the environment. The City shall prepare draft mitigation measures to
achieve the objective of mitigating or avoiding significant effects on the environment identified
in an Initial Study, Mitigated Negative Declaration, or EIR. These mitigation measures shall be
implemented by the Applicant as part of the project approvals. The final decision on which
effects are significant and how they are to be mitigated will be made by the approval authority.
Mitigation measures, per CEQA Guidelines Section 15370, are any action and/or inaction
specified for the purpose of mitigating identified environmental impacts in accordance with
CEQA, including:
1. Avoiding the environmental impact altogether by not taking a certain action or parts of an
action.
2. Minimizing impacts by limiting the degree or magnitude of the action and its implementation.
3. Rectifying the impact by repairing, rehabilitating or restoring the impacted environment.
23City of Orange Local CEQA Guidelines
4. Reducing or eliminating the impact over time by preservation and maintenance operations
during the life of the action.
5. Compensating for the impact by replacing or providing substitute resources or environments,
including through permanent protection of such resources in the form of conservation
easements.
The discussion of mitigation measures will distinguish between the measures which are
proposed by project proponents and other measures proposed by the lead, responsible or
trustee agencies. This discussion will identify mitigation measures for each
significant environmental effect identified in the Mitigated Negative
Declaration or EIR.
Where several measures are available to mitigate an impact,
each should be disclosed and the basis for selecting a
particular measure should be identified. Formulation
of mitigation measures will not be deferred until
some future time. The specific details of a mitigation
measure, however, may be developed after project
approval when it is impractical or infeasible to include
those details during the project’s environmental
review provided that the City (1) commits itself to the
mitigation, (2) adopts specific performance standards
the mitigation will achieve, and (3) identifies the
type(s) of potential action(s) that can feasibly achieve
that performance standard and that will be considered,
analyzed, and potentially incorporated in the mitigation
measure. Compliance with a regulatory permit or other
similar process may be identified as mitigation if compliance
would result in implementation of measures that would be
reasonably expected, based on substantial evidence in the record,
to reduce the significant impact to the specified performance standards.
If mitigation measures would cause one or more significant effects in addition to those that would
be caused by the project as proposed, the effects of the mitigation measures shall be disclosed
but in less detail than the significant effects of the project itself.
Mitigation measures must be fully enforceable through permit conditions, agreements, or other
legally binding instruments. In the case of the adoption of a plan, policy, regulation, or other
public project, mitigation measures can be incorporated into the plan, policy, regulation, or
project design. Mitigation measures must also be consistent with all applicable constitutional
requirements such as the “nexus” and “rough proportionality” standards – i.e., there must be
24City of Orange Local CEQA Guidelines
an essential nexus between the mitigation measure and a legitimate governmental interest, and
the mitigation measure must be “roughly proportional” to the impacts of the project. Mitigation
measures are not required for effects which are not found to be significant (CEQA Guidelines
Section 15126.4).
Energy Conservation
Energy conservation measures, as well as other appropriate mitigation measures will be discussed
when relevant. Examples of energy conservation measures are provided in Appendix F of the
CEQA Guidelines (CEQA Guidelines Section 15126.4(a)).
Mitigation Measures Related to Impacts on Historic Resources
Where maintenance, repair, stabilization, rehabilitation, restoration, preservation, conservation or
reconstruction of the historic resource will be conducted in a manner consistent with the Secretary
of the Interior’s Standards for the Treatment of Historic Properties with Guidelines for Preserving,
Rehabilitating, Restoring, and Reconstructing Historic Buildings (1995), Weeks and Grimmer, the
project’s impact on the historical resource will generally be considered mitigated below a level of
significance and thus is not significant. Please see Section IV of these Local CEQA Guidelines for
additional information on the analysis of Historic Resources.
In some circumstances, documentation of a historical resource, by way of historic narrative,
photographs or architectural drawings, as mitigation for the effects of demolition of the resource
will not mitigate the effects to a point where clearly no significant effects on the environment
would occur.
The City should, whenever feasible, seek to avoid damaging effects on any historical resource of
an archaeological nature. The following must be considered in an environmental document for a
project involving such an archaeological site:
1. Preservation in place is the preferred manner of mitigating impacts to archaeological sites; and
2. Preservation in place may be accomplished by, but is not limited to, the following:
(a) Planning construction to avoid archaeological sites;
(b) Incorporation of sites within parks, greenspace, or other open space;
(c) Covering the archaeological sites with a layer of chemically stable soil before building
tennis courts, parking lots, or similar facilities on the site; or
(d) Deeding the site into a permanent conservation easement.
3. When data recovery through excavation is the only feasible mitigation, a data recovery plan,
which makes provisions for adequately recovering the scientifically consequential information
from and about the historical resources, will be prepared and adopted prior to any excavation
being undertaken. Such studies must be deposited with the California Historical Resources
Regional Information Center.
25City of Orange Local CEQA Guidelines
4. Data recovery will not be required for a historical resource if the City determines that testing
or studies already completed have adequately recovered the scientifically consequential
information from and about the archaeological or historical resource, provided that the
determination is documented in the environmental document and that the studies are deposited
with the California Historical Resources Regional Information Center (CEQA Guidelines Section
15126.4(b)).
Mitigation Measures Related to Greenhouse Gas Emissions
Consistent with Section 15126.4(c) of the CEQA Guidelines, the Lead Agency will consider feasible
means, supported by substantial evidence and subject to monitoring or reporting, of mitigating
the significant effects of greenhouse gas emissions. Measures to mitigate the significant effects of
greenhouse gas emissions may include, but are not limited to:
1. Measures in an existing plan or mitigation program for the reduction of emissions that are
required as part of the Lead Agency’s decision;
2. Reductions in emissions resulting from a project through implementation of project features,
project design, or other measures;
3. Off-site measures, including offsets that are not otherwise required to mitigate a project’s
emissions;
4. Measures that sequester greenhouse gases;
5. In the case of the adoption of a plan, such as a general plan, long range development plan, or
plans for the reduction of greenhouse gas emissions, mitigation may include the identification
of specific measures that may be implemented on a project-by-project basis. Mitigation may
also include the incorporation of specific measures or policies found in an adopted ordinance
or regulation that reduces the cumulative effect of emissions.
I. Mitigation Monitoring and Reporting Program
A Mitigation Monitoring and Reporting Program is required when the City has made the findings
required under CEQA Guidelines Section 15091 relative to an EIR or adopted a Mitigated
Negative Declaration in conjunction with approving a project (CEQA Guidelines Section 15097).
General Requirements
Pursuant to PRC Section 21081.6, all jurisdictions must have a method for monitoring compliance
and implementation of adopted mitigation measures. All Mitigation Monitoring and Reporting
Programs (MMRP) shall be in conformance with CEQA Guidelines Section 15097 as augmented
by the provisions listed below.
26City of Orange Local CEQA Guidelines
Adoption
At the time the Decision-Making Body adopts the required findings regarding the Mitigated
Negative Declaration or EIR, it shall also adopt the MMRP. Conformance with the MMRP
program shall be a condition of project approval.
Contents
The MMRP shall include, at a minimum, the following information for each mitigation measure:
1. The individual, department, agency, or other entity responsible for performing the mitigation
measure;
2. The timing for implementation of the mitigation measure;
3. The specific results or performance standards that the mitigation is intended to accomplish if
not clearly stated in the mitigation measure;
4. The individual, department, agency, or other entity responsible for ensuring implementation
of the mitigation measure;
5. The frequency of inspections or other monitoring activities;
6. When compliance is completed; and
7. A statement that the Applicant shall pay all monitoring
costs including, but not limited to, those incurred by
the City.
Mitigation Monitoring and Reporting
Program Compliance
Community Development Department staff
shall be responsible for the preparation and
management of the MMRP, including assigning
monitoring responsibilities for individual
mitigation measures to the appropriate City
department, coordinating with the Applicant
and the appropriate City departments to
verify that individual mitigation measures are
implemented, and managing the City’s mitigation
monitoring administrative record. Refer to Appendix
D of these Local CEQA Guidelines, for the Mitigation
Monitoring and Reporting Program Sample Format.
27City of Orange Local CEQA Guidelines
Revisions to the Mitigation Monitoring and Reporting Program
Any proposed change in mitigation measures shall require an amendment to the project
approval. Amendments may be initiated by any City reviewing body (i.e. City Council, Planning
Commission, Design Review Board, or Zoning Administrator) or Department, or by the Applicant,
and shall be submitted in writing to the Community Development Department. Any amendment
to the project decision may require additional conditions of approval or mitigation measures,
as determined by the reviewing body. Notification of the proposed change shall be handled in
accordance with City procedures.
When a proposed change to a mitigation measure is requested by any of the parties listed above,
the requesting party shall prepare a written letter request and submit it to the Project Planner.
The letter request shall include a complete description of the proposed change, the necessity for
the proposed change, and the environmental effects (if any) of the proposed change. The Project
Planner shall review the information to determine whether the proposed change is in “substantial
conformance” with the original mitigation measure, such that the “intent” of the measure is
met. This determination is made by the Project Planner in consultation with the Director of
Community Development, and is documented by memo to the project file and to the Applicant.
This conformance determination does not require further approvals or public notifications. The
actual cost of reviewing and processing the request shall be billed to the Applicant under the
Mitigation Monitoring fee deposit system, which is included in the City’s Master Schedule of Fees.
The “substantial conformance” determination and memo shall be based on information that
clearly supports that the revised mitigation measure mitigates the significant impact to an
equivalent level (i.e., the revision cannot result in a new adverse environmental effect or in an
increase in the severity of a previously disclosed environmental effect) when compared to the
original mitigation measure.
This staff level conformance review process shall not apply to requests to delete a mitigation
measure or to substantially modify a mitigation measure, such that the environmental impacts
of the project are not clearly mitigated to the same extent as the original mitigation measure. In
these cases, the requested change to the mitigation measure shall be considered a modification
of the project approval and a change to the project. When a change to a project is proposed after
project approval, CEQA Guidelines Sections 15162 through 15164 apply, and the environmental
documentation process for completing a subsequent, supplement or addendum to the previously
certified EIR will commence. The approval process will then follow the CEQA Guidelines and
City procedures for modification of an approval as presented in OMC Section 17.08.030.I,
Modifications to Previously Approved Projects.
28City of Orange Local CEQA Guidelines
4. HISTORICAL RESOURCES AND
ENVIRONMENTAL REVIEW
A. Identification of Historical Resources; Applicability
PRC Section 21084.1 defines a “historical resource,” as a resource listed in, or determined eligible
for listing in, the California Register of Historical Resources. Historical resources included in a
local register of historical resources, as defined in PRC Section 5020.1(k), or deemed significant
pursuant to criteria set forth in PRC Section 5024.1(g), are presumed to be historically or culturally
significant for purposes of this section, unless the preponderance of the evidence demonstrates
that the resource is not historically or culturally significant.
The fact that a resource is not listed in, or determined to be eligible for listing
in the California Register of Historical Resources, not included in a local
register of historical resources, or not deemed significant pursuant to
criteria set forth in PRC Section 5024.1(g) does not preclude the
City from determining whether the resource may be a historical
resource.
The City of Orange Historic Resources Inventory was originally
prepared in 1982, and subsequently updated in 1992, 2005
and 2010. This survey served as the informational basis for
the Old Towne Orange National Register nomination. The
Plaza Historic District was placed on the National Register
on March 19, 1982, and the Old Towne Orange Historic
District on July 11, 1997. On these dates, these Districts
were also placed on the California Register of Historical
Resources. Therefore, the California Register listing of these
historic districts makes them historical resources for the purposes
of CEQA.
The City’s Historic Resources Inventory adopted by City Council in 2010
identified the three tracts in the City developed by Eichler Homes, Inc. as
potential historic districts and included a historic context statement describing
the historic significance of the Orange Eichlers, which forms the basis of the historic district
overlay zone. At a November 13, 2018 public hearing, the City Council approved historic district
designation for the three Orange Eichler tracts under OMC Chapter 17.17.
Historical resources in the City have a historic district overlay zoning defined in OMC Chapter
17.17, Historic Districts, hereinafter “local historic district.” The local historic district as defined in
the OMC is presumed to be a historical resource for the purposes of CEQA.
29City of Orange Local CEQA Guidelines
In addition, because the City’s Historic Resources Inventory served as the informational basis
for the Cultural Resources and Historic Preservation Element of the General Plan (which was
updated in 2010 and adopted by resolution of the City Council), the Historic Resources Inventory
constitutes a recognized list of historical resources within the City pursuant to PRC Section
5020.1(k), and resources that are identified as significant resources in the inventory (i.e., any
inventory designation except “not contributing” (NC) and “not significant” (NS)), both within
and outside of the local historic districts and the National Register and California Register listed
districts, are presumed to be historical resources for purposes of CEQA.
Pursuant to CEQA Guidelines Section 15064.5(a)(4), the fact that a structure or other resource is
not listed in or determined to be eligible for listing in the California Register or a local register
does not preclude the City from determining that it may be a historical resource. If a structure
or other resource is not identified as a historical resource in the City of Orange Historical
Resources Inventory, but during the course of project review documentation is submitted to the
City demonstrating the structure or resource’s historical significance, a formal historical resource
evaluation shall be prepared by a qualified professional who meets the Secretary of Interior’s
Professional Qualifications Standards for Historic Architecture, Architectural History, and/or
History (36 Code of Federal Regulations (CFR) Part 61 Appendix A).
The historical resource evaluation shall, at a minimum, describe architectural elements,
conditions, alterations, and additions, and include a photographic record and description of the
structure or resource and its context. The evaluation shall address the age of the structure or
resource and evaluate its architectural and structural integrity. The evaluation shall evaluate the
historical significance of the structure or resource, both individually and as a contributor to the
City’s designated historic district(s), and shall ultimately make a determination as to whether the
structure meets the definition of a historical resource as defined in CEQA Guidelines Section
15064.5.
Upon Community Development Director review and concurrence with the conclusions of the
historical resource evaluation supporting the historical significance of the property, the property
shall be considered a historical resource for purposes of CEQA review.
B. Impacts on Historical Resources; Design Standards
The following Local CEQA Guidelines shall employ a combination of CEQA Guidelines and local
rules and regulations.
Design Standards Authority
Projects shall be judged for consistency with both the Secretary of the Interior’s Standards for
Rehabilitation and Guidelines for Rehabilitating Historic Buildings, and the applicable adopted
design standards. The Old Towne Design Standards and the Orange Eichler Design Standards
30City of Orange Local CEQA Guidelines
both incorporate the Secretary of the Interior’s Standards for Rehabilitation and are more specific
in nature; therefore, projects which are determined to be consistent with the applicable design
standards are also deemed to be consistent with the Secretary of the Interior’s Standards for
Rehabilitation.
CEQA Guidelines Section 15064.5, Determining the Significance of Impacts to Archeological and
Historical Resources, contains the following provision:
Historic Preservation Design Standards for Old Towne (the “Old Towne Design Standards”),
originally approved by City Council on June 13, 1995, and most recently revised by City
Council Resolution No. 11053 on December 12, 2017, incorporate the Secretary of the Interior’s
Standards for Rehabilitation. The Old Towne Design Standards shall be used in assessing effects
a rehabilitation project may have on historical resources.
Rehabilitation projects that comply with both the Old Towne Design Standards and the Secretary
of Interior’s Standards for Rehabilitation do not have a significant impact to historical resources. For
projects involving preservation, restoration or reconstruction of historic buildings, the Secretary
of Interior’s Standards for the Treatment of Historic Properties with Guidelines for Preserving,
Restoring and Reconstructing Historic Buildings continue to be the relevant guidance document
for assessing effects.
The Orange Eichler Design Standards, adopted by City Council Ordinance No. 14-18, incorporate
the Secretary of the Interior’s Standards for Rehabilitation. The Orange Eichler Design Standards
shall be used in assessing effects a rehabilitation project may have on historical resources.
Rehabilitation projects that comply with both the Orange Eichler Design Standards and the
Secretary of Interior’s Standards for Rehabilitation do not have a significant impact to historical
resources. For projects involving preservation, restoration or reconstruction of historic buildings,
the Secretary of Interior’s Standards for the Treatment of Historic Properties with Guidelines for
Preserving, Restoring and Reconstructing Historic Buildings continue to be the relevant guidance
document for assessing effects.
“(b)(3) Generally, a project that follows the Secretary of the Interior’s
Standards for Treatment of Historic Properties with Guidelines for
Preserving, Rehabilitating, Restoring, and Reconstructing Historic
Buildings or the Secretary of the Interior’s Standards for Rehabilitation
and Guidelines for Rehabilitating Historic Buildings (1995), Weeks and
Grimmer, shall be considered as mitigated to a level of less than a
significant impact on the historical resource.”
31City of Orange Local CEQA Guidelines
Substantial Adverse Change Defined
PRC Section 21084.1, Effects on Historical Resources, contains the following provision:
CEQA Guidelines Section 15064.5(b)(1) states:
The significance of a historical resource is materially impaired when a project demolishes or
materially alters in an adverse manner those physical characteristics of a historical resource
that convey its historical significance and that justify its eligibility or inclusion on the California
Register, or its inclusion on a local register of historic resources pursuant to PRC Section
5020.1(k) or 5024.1(g) (CEQA Guidelines Section 15064.5(b)(2)).
City Application of Substantial Adverse Change
The City has determined that the following projects may involve substantial adverse changes
to historical resources and are not exempt from CEQA review.
1. The basic threshold for substantial adverse change to a historical resource under these
Local CEQA Guidelines shall be a project which threatens loss or destruction of the qualities
which caused original formation of the local historic district, listing in and/or determination
of eligibility for listing in the National Register or California Register as determined by
the Community Development Director. (36 CFR § 60.15, Removing properties from the
National Register).
Determinations about substantial adverse change to a historical resource should include
consultation of the Orange Historic Resources Inventory, on file in the Community
Development Department.
“Substantial adverse change in the significance of a historical resource
means physical demolition, destruction, relocation or alteration of the
resource or its immediate surroundings such that the significance of an
historical resource would be materially impaired.”
“A project that may cause a substantial adverse change in the
significance of a historical resource is a project that may have a
significant effect on the environment.”
32City of Orange Local CEQA Guidelines
2. Thresholds for substantial adverse change under these Local CEQA Guidelines include any
of the following. Projects meeting these criteria may have the potential for adverse impacts
and shall not be exempt from CEQA.
a. Any demolition, destruction, or relocation of a historical resource.
b. Partial demolitions involving the removal of historical floor area, or an exterior wall that
includes a distinctive character-defining historical architectural feature, of a historical
resource.
c. Alteration to property of a historical resource including exterior alterations, additions, new
buildings, hardscape, or landscape which does not clearly comply with the Secretary of
Interior’s Standards for Rehabilitation and the applicable design standards.
d. Alteration which removes existing exterior historic building material from a primary
historical resource including but not limited to siding, windows, doors, and related trim
and does not replace these elements with in kind materials (emphasis added), or other
appropriate materials as identified in the applicable design standards.
e. Infill development within the boundaries of a local historic district, as designated in OMC
Chapter 17.17, including the construction of new residential or non-residential structures
that do not comply with the Secretary of the Interior’s Standards for Rehabilitation and the
applicable design standards.
f. Alteration to a non-historic resource or property located within the boundaries of a local
historic district, including exterior alterations, additions, or new buildings, which does not
comply with the applicable design standards and is incompatible with the predominant
streetscape and building pattern on the block on which it is located. The factors that
shall be considered when determining incompatibility include bulk and mass, architectural
articulation, and the placement and orientation of additions or accessory buildings on the
site.
g. Alterations or additions to a structure that is a historical resource involving a variation in
the height or width that results in an incompatible change in the resource’s relationship
to the predominant streetscape and building pattern on the block on which it is located.
In addition to height and width, factors that shall be considered when determining
incompatibility include bulk and mass, architectural articulation, and the placement and
orientation of additions on the site.
h. Demolitions that adversely affect features of a property or objects associated with an
event or person of significance to the history of the City that are determined to be a
historical resource.
33City of Orange Local CEQA Guidelines
C. Exemptions
Categorical Exemptions
Article 19 of the CEQA Guidelines identifies a number of categorical exemptions that may be
applicable to projects involving historical resources, provided that the proposed activity does not
have the potential to cause substantial adverse change. However, only one exemption applies
specifically to restoration and rehabilitation activities associated with historical resources.
Per CEQA Guidelines Section 15331, Class 31 consists of projects limited to maintenance, repair,
stabilization, rehabilitation, restoration, preservation, conservation or reconstruction of historical
resources in a manner consistent with the Secretary of the Interior’s Standards for the Treatment of
Historic Properties with Guidelines for Preserving, Rehabilitating, Restoring, and Reconstructing
Historic Buildings.
City Application of Categorical Exemptions
The City has determined that the following activities reasonably fall within
the exemption categories established by the CEQA Guidelines.
Determinations regarding the applicability of exemptions shall be
made by the Community Development Director and may require
a Certificate of Appropriateness to ensure consistency with the
applicable design guidelines.
1. Demolition of non-historical building components
(such as materials or additions) attached to a historical
resource, or removal of an exterior wall that does
not contain distinctive character-defining historical
architectural features, that furthers an alteration or
addition that is in conformance with the applicable
design guidelines.
2. Replacement of severely deteriorated or irreparable
exterior historic building material or architectural features
including but not limited to siding, windows, doors, and
related trim, with in kind materials matching existing materials
in species, design, profile, texture and color (emphasis added),
or other appropriate materials as identified in the applicable design
guidelines.
3. Alteration to a property of a historical resource including additions, new buildings, hardscape
or landscape, which clearly complies with the applicable design standards and the Secretary of
Interior’s Standards and does not adversely affect the historical resource, adjoining properties
or immediately surrounding neighborhood.
34City of Orange Local CEQA Guidelines
D. Cumulative Impacts on Historical Resources
Cumulative Impacts Defined
As provided in CEQA Guidelines Section 15355:
Cumulative impacts are also discussed in CEQA Guidelines Section 15064(h).
City Application of Cumulative Impacts
The City shall consider the following when making determinations about whether a project results
in a cumulative impact to historical resources:
1. Project conformance to the applicable design standards and the Secretary of Interior Standards
for Rehabilitation.
2. Project involving alterations or additions to a historical resource preserves the contextual
integrity of the local historic district by incorporating site planning and design features that
are consistent with the established building pattern and streetscape relationship on the block
on which it is located, and the district as a whole. Characteristics to be considered include
bulk, massing, architectural articulation, and placement of buildings on the lot.
3. Project involving new infill development within the local historic district is compatible with
the scale, character, building pattern, and streetscape relationship of the block on which it is
located and the district as a whole.
4. The limited representation of a particular architectural style or building type in any proposed
alteration, addition, or demolition.
5. The cultural significance to the community of a historical resource in any proposed demolition,
including but not limited to documented events, individuals, groups of people, or activities in
the evolution of the City.
Any project that conflicts with subsections 1, 2, or 3, or results in adverse effects to those resources
addressed in subsections 4 and 5 may constitute a significant cumulative impact and is not exempt
from CEQA review.
“Cumulative impacts refers to two or more individual effects which, when
considered together, are considerable or which compound or increase other
environmental impacts. (a) The individual effects may be changes resulting from
a single project or a number of separate projects. (b) The cumulative impact
from several projects is the change in the environment which results from the
incremental impact of the project when added to other closely related past,
present, and reasonably foreseeable probable future projects. Cumulative
impacts can result from individually minor but collectively significant projects
taking place over a period of time.”
35City of Orange Local CEQA Guidelines
5. TRANSPORTATION ANALYSIS
Effective December 28, 2018, the California Natural Resources Agency added
CEQA Guidelines Section 15064.3, Determining the Significance of
Transportation Impacts. The City hereby elects to be governed by
the provisions of Section 15064.3 effective immediately and
incorporates those provisions herein.
CEQA Guidelines Section 15064.3 provides:
(a) Purpose
This section describes specific considerations
for evaluating a project’s transportation impacts.
Generally, vehicle miles traveled is the most
appropriate measure of transportation impacts. For
the purpose of this section, “vehicles miles traveled”
refers to the amount and distance of automobile travel
attributable to a project. Other relevant considerations
may include the effects of the project on transit and
non-motorized travel. Except as provided in subdivision
(b)(2) below (regarding roadway capacity), a project’s
effect on automobile delay shall not constitute a significant
environmental impact.
(b) Criteria for Analyzing Transportation Impacts
(1) Land Use Projects. Vehicle miles traveled exceeding an applicable threshold of significance may
indicate a significant impact. Generally, projects within one-half mile of either an existing high
quality transit corridor should be presumed to cause a less than significant transportation impact.
Projects that decrease vehicle miles traveled in the project area compared to existing conditions
should be presumed to have a less than significant transportation impact.
(2) Transportation Projects. Transportation projects that reduce, or have no impact on, vehicle
miles traveled should be presumed to cause a less than significant transportation impact. For
roadway capacity projects, agencies have discretion to determine the appropriate measure of
transportation impact consistent with CEQA and other applicable requirements. To the extent
that such impacts have already been adequately addressed at a programmatic level, such as in a
regional transportation plan EIR, a lead agency may tier from that analysis as provided in CEQA
Guidelines Section 15152.
36City of Orange Local CEQA Guidelines
(3) Qualitative Analysis. If existing models or methods are not available to estimate the vehicle
miles traveled for the particular project being considered, a lead agency may analyze the
project’s vehicle miles traveled qualitatively. Such a qualitative analysis would evaluate factors
such as the availability of transit, proximity to other destinations, etc. For many projects, a
qualitative analysis of construction traffic may be appropriate.
(4) Methodology. A lead agency has discretion to choose the most appropriate methodology to
evaluate a project’s vehicle miles traveled, including whether to express the change in absolute
terms, per capita, per household or in any other measure. A lead agency may use models
to reflect professional judgement based on substantial evidence. Any assumptions used to
estimate vehicle miles traveled and any revisions to model outputs should be documented
and explained in the environmental document prepared for the project. The standard
of adequacy in CEQA Guidelines Section 15151 shall apply to the analysis described in
this section.
(c) Applicability. The provisions of this section shall apply prospectively as described in CEQA
Guidelines Section 15007. A lead agency may elect to be governed by the provisions of this section
immediately. Beginning on July 1, 2020, the provisions of this section will apply statewide.
Consistent with CEQA Guidelines Section 15064.3, the City has adopted the thresholds of significance
set forth in the City of Orange Traffic Impact Analysis Guidelines to guide when the City will normally
determine that a project will have a significant transportation impact.
The thresholds of significance set forth in the City of Orange Traffic Impact Analysis Guidelines,
maintained by the Traffic Division of the City Public Works Department, shall be considered when
determining a proposed project’s potential transportation impacts.
37City of Orange Local CEQA Guidelines
6. GREENHOUSE GAS EMISSIONS ANALYSIS
A. Calculating a Project’s Greenhouse
Gas Emissions.
The City shall analyze the greenhouse gas emissions of its
projects as required by CEQA Guidelines Section
15064.4. For projects subject to CEQA, the City shall
make a good faith effort, based to the extent
possible on scientific and factual data, to
describe, calculate or estimate the amount
of greenhouse gas emissions resulting
from a project.
In performing analysis of greenhouse
gas emissions, the City shall have
discretion to determine, in the context
of a particular project, whether to:
(1) Quantify greenhouse gas
emissions resulting from a
project; and/or
(2) Rely on a qualitative analysis or
performance-based standards.
B. Determining Significance of
Greenhouse Gas Emissions.
In determining the significance of a project’s
greenhouse gas emissions, the City will focus its analysis
on the reasonably foreseeable incremental contribution of
the project’s emissions to the effects of climate change. A project’s
incremental contribution may be cumulatively considerable even if it appears relatively
small compared to statewide, national, or global emissions. The City’s analysis will
consider a timeframe that is appropriate for the project. The City’s analysis will also
reasonably reflect evolving scientific knowledge and state regulatory schemes. The City
will consider the following factors, among others, when determining the significance of
impacts from greenhouse gas emissions on the environment:
38City of Orange Local CEQA Guidelines
(1) The extent to which the project may increase or reduce greenhouse gas emissions as
compared to the existing environmental setting;
(2) Whether the project emissions exceed a threshold of significance that the City determines
applies to the project. The City may rely on thresholds of significance developed by experts
or other agencies, provided that application of the threshold and the significance conclusion
is supported by substantial evidence, in accordance with CEQA Guidelines Section 15064.7.
When relying on thresholds developed by other agencies, the City should ensure that the
threshold is appropriate for the project and the project’s location; and
(3) The extent to which the project complies with regulations or requirements adopted to
implement a statewide, regional, or local plan for the reduction or mitigation of greenhouse
gas emissions (see CEQA Guidelines Section 15183.5(b)). Such requirements must be
adopted by the relevant public agency through a public review process and must reduce
or mitigate the project’s incremental contribution to greenhouse gas emissions. If there is
substantial evidence that the possible effects of a particular project are still cumulatively
considerable notwithstanding compliance with the adopted regulations or requirements, an
EIR must be prepared for the project. In determining the significance of impacts, the City
may consider a project’s consistency with the State’s long-term climate goals or strategies,
provided that substantial evidence supports the analysis of how those goals or strategies
address the project’s incremental contribution to climate change and its conclusion that the
project’s incremental contribution is not cumulatively considerable.
The City may use a model or methodology to estimate greenhouse gas emissions resulting from a
project. The City has discretion to select the model or methodology it considers most appropriate
to enable decision-makers to intelligently take into account the project’s incremental contribution
to climate change. The City must support its selection of a model or methodology with substantial
evidence. The City should explain the limitations of the particular model or methodology for
use. See Appendix F of these Local CEQA Guidelines, Guidance for Greenhouse Gas Emissions
Analysis for guidance in evaluating greenhouse gas emissions.
39City of Orange Local CEQA Guidelines
7. APPROVAL AUTHORITY
A. Planning Commission
The City Planning Commission’s authority as related to
environmental documents is described in OMC Section
17.08.020.B. The Planning Commission has authority
to hear and take final action on certain applications
for Negative Declarations and Mitigated Negative
Declarations. The Planning Commission has the
authority to review and make recommendations
to the City Council on EIRs, and certain
Negative Declarations, and Mitigated Negative
Declarations.
The CEQA public review period shall be
completed prior to the Planning Commission
public meeting or hearing regardless of
whether the Planning Commission decision is
a recommendation to the City Council or a final
action. Public comments received by the City during
the public review period and the City’s response to
comments shall be forwarded to the Planning Commission
for consideration prior to the public hearing. The hearing
shall be scheduled to provide a reasonable time frame in which to
prepare a response to comments for the Planning Commission’s review.
B. City Council
The City Council has the final approval authority over environmental documentation, as follows:
1. If prepared in conjunction with a project requiring discretionary action by the City Council,
including but not limited to those actions defined in the administrative procedures established
in Chapter 17.08 of the OMC;
2. If an EIR is prepared in conjunction with a project;
3. When reviewing a recommendation made by the Planning Commission; and
4. When a project decision is appealed.
40City of Orange Local CEQA Guidelines
8. APPEAL PROCESS
Any final action taken by the Community Development Director in the
administration of these Local CEQA Guidelines may be appealed
by any person aggrieved, or by an officer, commission or
department in the City, in accordance with the appeal
procedure described in OMC Chapter 17.08.050. Such
appeals may be made to the Planning Commission. Any
final action taken by the Planning Commission may be
appealed to the City Council.
41City of Orange Local CEQA Guidelines
9. FEES
A filing fee, as determined by City Council resolution, shall accompany environmental review
applications for any action taken under the provisions of these Local CEQA Guidelines. When an
application for a permit or entitlement for use is submitted for which CEQA documents are required,
the Applicant shall submit a deposit for processing of environmental documentation in the amount
identified in the City’s Master Schedule of Fees. A deposit is collected for the preparation and
processing of a Negative Declaration, Mitigated Negative Declaration or EIR, as well as for the filing
of environmental notices such as a Notice of Determination.
Following the selection of an environmental consultant to prepare CEQA documents as described
in Section 10 of these Local CEQA Guidelines, the Applicant shall deposit an amount equal to the
contracted cost to complete the environmental documents plus any fees required by the City. The
Community Development Director shall use the Applicant’s deposit to pay for work completed by
the consultant and for all City costs in reviewing, revising, processing, coordinating and managing
the same. After the City renders a decision on the CEQA document, the Community Development
Director, in conjunction with the City Finance Department, shall undertake a final accounting for the
CEQA environmental document. In the event the amount of the deposit exceeds the City’s costs,
including all consulting, staff, legal, and publishing costs, a refund in the amount of the excess shall
be provided to the Applicant. In the event such costs exceed the Applicant’s deposit, the City shall
bill the Applicant for the overage. Any applications made by the City shall be exempted from this
requirement.
42City of Orange Local CEQA Guidelines
10. DOCUMENT PREPARATION
Preparation of required CEQA documentation, including notices, an Initial Study, Negative
Declaration, Mitigated Negative Declaration, EIR, and/or supporting technical studies, shall be
done by the Community Development Director, or by private consultants under contract with the
City pursuant to OMC Section 3.08.400. All documentation shall be prepared by or under direct
supervision of the Community Development Director, and according to the requirements of the
City. The City may require the Applicant to supply data and information both to determine whether
the project may have a significant effect on the environment and to assist the City as the Lead
Agency in preparing the CEQA documentation.
The City may choose one of the following arrangements or a combination of them for preparing a
CEQA document:
(1) Preparing the document directly with its own staff.
(2) Contracting with another entity, public or private, to prepare the document.
(3) Accepting a draft prepared by the Applicant, a consultant retained by the Applicant,
or any other person.
(4) Executing a third party contract or Memorandum of Understanding with the Applicant to
govern the preparation of a document by an independent contractor.
(5) Using a previously prepared document.
All documentation shall be the City’s product and reflect the City’s independent judgment and
analysis (CEQA Guidelines Section 15084).
43
APPENDICES
Planning Division, 300 E Chapman Avenue, Orange CA 92866
Office: 714-000-0000 Website: www.cityoforange.org
PROJECT TITLE
ENVIRONMENTAL DOCUMENT NO.
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:
Date:
TABLE OF CONTENTS
Sections Page #
Section XX: Introduction .............................................................................................. XX
Section XX: Existing Setting ........................................................................................ XX
Section XX: Project Description ................................................................................... XX
Section XX: Environmental Impact Analysis ............................................................... XX
Section XX: References ................................................................................................ XX
Section XX: Preparers and Persons Consulted.............................................................. XX
Section XX: Mitigation Monitoring and Reporting Program ....................................... XX
Figures
Tables
Appendices
ENVIRONMENTAL DOCUMENT NO.
Project Title:
Reference Application Numbers:
Lead Agency:
Contact Person and Telephone No.:
Project Proponent and Address:
Contact Person and Telephone No.:
Project Location:
Existing General Plan Designation: Existing Zoning Classification:
INTRODUCTION
(Summarize project and describe compliance with CEQA and purpose of Initial Study)
EXISTING SETTING
Regional Setting:
Existing Site Conditions:
(Describe the project site)
Surrounding Land Uses:
(Describe the land uses and characteristics of the surrounding area)
PROJECT DESCRIPTION
(Describe the components of the project including proposed physical improvements,
construction, operations, phasing, and City approvals required to accommodate the project).
Other Public Agencies Whose Approval is Required (Responsible or Trustee Agencies):
(Identify other public agencies whose approval is required for project implementation and
agencies with jurisdiction over affected natural resources)
Scheduled Public Meetings or Hearings:
(Describe the date, time and location for all scheduled public meetings and hearings)
2
ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED
The environmental factors checked below would be potentially affected by this project, involving at
least one impact that is a “Potentially Significant Impact” as indicated by the checklist on the following
pages.
Aesthetics Agriculture & Forest Resources Air Quality
Biological Resources Cultural Resources Energy
Geology/Soils Greenhouse Gas Emissions Hazards & Hazardous
Materials
Hydrology/Water Quality Land Use/Planning Mineral Resources
Noise Population/Housing Public Services
Recreation Transportation Tribal Cultural Resources
Utilities/Service Systems Wildfire Mandatory Findings of
Significance
DETERMINATION. On the basis of this initial evaluation:
1. I find that the project could not have a significant effect on the environment, and a
NEGATIVE DECLARATION will be prepared.
2. I find that although the proposed project could have a significant effect on the
environment, there will not be a significant effect in this case because revisions in the
project have been made by or agreed to by the project proponent. A MITIGATED
NEGATIVE DECLARATION will be prepared.
3. I find the proposed project may have a significant effect on the environment, and an
ENVIRONMENTAL IMPACT REPORT is required.
4. I find that the proposed project may have a “potentially significant impact” or
“potentially significant unless mitigated impact” on the environment, but at least one
effect 1) has been adequately analyzed in an earlier document pursuant to applicable
legal standards, and 2) has been addressed by mitigation measures based on the earlier
analysis as described on attached sheets. An ENVIRONMENTAL IMPACT
REPORT is required, but it must analyze only the effects that remain to be addressed.
5. I find that although the proposed project could have a significant effect on the
environment, because all potentially significant effects (a) have been analyzed
adequately in an earlier EIR or Negative Declaration pursuant to applicable standards,
and (b) have been avoided or mitigated pursuant to that earlier EIR or Negative
Declaration, including revisions or mitigation measures that are imposed upon the
proposed project, nothing further is required.
________________________________________ ___________________________
Name, Title Date
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 pa rentheses 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 th at 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, 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.
4
CHECKLIST OF ENVIRONMENTAL IMPACT ISSUES:
1.
AESTHETICS. Except as provided in Public Resources Code
Section 21099, 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) In non-urbanized areas, substantially degrade the existing visual
character or quality of public views of the site and its surroundings?
(Public views are those that are experienced from publicly accessible
vantage point). If the project is in an urbanized area, would the
project conflict with applicable zoning or other regulations
governing scenic quality?
(d) Create a new source of substantial light or glare which would
adversely affect day or nighttime views in the area?
Impact Analysis
a)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
b)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
c)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
d)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
5
2. AGRICULTURE & FOREST 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.) In determining whether impacts to forest resources,
including timberland, are significant environmental effects, lead
agencies may refer to information compiled by the California
Department of Forestry and Fire Protection regarding the state’s
inventory of forest land, including the Forest and Range Assessment
Project and the Forest Legacy Assessment project; and forest carbon
measurement methodology provided in Forest Protocols adopted by
the California Air Resources Board.) 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?
Impact Analysis:
a)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
b)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
c)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
6
d)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
e)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
7
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) 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?
(c) Expose sensitive receptors to substantial pollutant concentrations?
(d) Result in other emissions (such as those leading to odors) adversely
affecting a substantial number of people?
Impact Analysis:
a)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
b)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
c)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
d)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
8
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 state or federally protected
wetlands (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?
Impact Analysis:
a)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
b)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
c)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
d)
Significance Determination:
9
Mitigation Measures:
Significance Determination After Mitigation:
e)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
f)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
10
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 pursuant to in §15064.5?
(b) Cause a substantial adverse change in the significance of an
archaeological resource pursuant to §15064.5?
(c) Disturb any human remains, including those interred outside of
dedicated cemeteries?
Impact Analysis:
a)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
b)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
c)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
11
6.
ENERGY. Would the project: Potentially
Significant
Impact
Less than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
(a) Result in potentially significant environmental impact due to
wasteful, inefficient, or unnecessary consumption of energy
resources, during project construction or operation?
(b) Conflict with or obstruct a state or local plan for renewable energy or
energy efficiency?
Impact Analysis:
a)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
b)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
12
7.
GEOLOGY AND SOILS. Would the project: Potentially
Significant
Impact
Less than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
(a) Directly or indirectly cause 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 direct or indirect
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?
(f) Directly or indirectly destroy a unique paleontological resource or site
or unique geologic feature?
Impact Analysis:
a)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
b)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
c)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
d)
13
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
e)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
f)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
14
8.
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)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
b)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
15
9. 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 or
excessive noise for people residing or working in the project area?
(f) Impair implementation of or physically interfere with an adopted
emergency response plan or emergency evacuation plan?
(g) Expose people or structures, either directly or indirectly to a
significant risk of loss, injury or death involving wildland fires?
Impact Analysis:
a)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
b)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
c)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
d)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
16
e)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
f)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
g)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
17
10.
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
or otherwise substantially degrade surface or ground water quality?
(b) Substantially decrease groundwater supplies or interfere substantially
with groundwater recharge such that the project may impede
sustainable groundwater management of the basin?
(c) Substantially alter the existing drainage pattern of the site or area,
including through the alteration of the course of a stream or river or
through the addition of impervious surfaces, in a manner which
would:
(i) result in substantial erosion or siltation on- or off-site;
(ii) increase the rate or amount of surface runoff in a manner which
would result in flooding in- or off-site;
(iii) 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; or
(iv) impede or redirect flood flows?
(d) In flood hazard, tsunami, or seiche zones, risk release of pollutants
due to project inundation?
(e) Conflict with or obstruct implementation of a water quality control
plan or sustainable groundwater management plan?
(f) Result in the potential for discharge of stormwater to affect the
beneficial uses of the receiving waters from construction activities or
post-construction activities?
(g) 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?
(h) Create the potential for significant changes in the flow velocity or
volume of stormwater runoff to cause environmental harm?
Impact Analysis:
a)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
b)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
c)
18
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
d)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
e)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
f)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
g)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
h)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
19
11.
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) Cause a significant environmental impact due to a conflict with any
applicable land use plan, policy, or regulation adopted for the
purpose of avoiding or mitigating an environmental effect?
Impact Analysis:
a)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
b)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
20
12.
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?
Impact Analysis:
a)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
b)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
21
13.
NOISE. Would the project result in: Potentially
Significant
Impact
Less than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
(a) Generation of a substantial temporary or permanent increase in
ambient noise levels in the vicinity of the project in excess of
standards established in the local general plan or noise ordinance, or
applicable standards of other agencies?
(b) Generation of excessive groundborne vibration or groundborne noise
levels?
(c) For a project located within the vicinity of a private airstrip or 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?
Impact Analysis:
a)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
b)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
c)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
22
14.
POPULATION AND HOUSING. Would the project:
Potentially
Significant
Impact
Less than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
(a) Induce substantial unplanned 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 people or housing,
necessitating the construction of replacement housing elsewhere?
Impact Analysis:
a)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
b)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
23
15.
PUBLIC SERVICES. 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?
Impact Analysis:
(a) i)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
ii)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
iii)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
iv)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
v)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
24
16.
RECREATION. 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?
Impact Analysis:
a)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
b)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
25
17.
TRANSPORTATION. Would the project: Potentially
Significant
Impact
Less than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
(a) Conflict with a program, plan, ordinance or policy addressing the
circulation system, including transit, roadway, bicycle and pedestrian
facilities?
(b) Would the project conflict or be inconsistent with CEQA Guidelines
Section 15064.3, subdivision (b)?
(c) Substantially increase hazards due to a geometric design feature (e.
g., sharp curves or dangerous intersections) or incompatible uses
(e.g., farm equipment)?
(d) Result in inadequate emergency access?
Impact Analysis:
a)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
b) (In accordance with CEQA Guidelines Section 15064.3(c), the City of Orange, as the lead agency,
will implement the provisions of Section 15064.3 of the CEQA Guidelines, when the provisions go into
effect statewide beginning July 1, 2020.)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
c)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
d)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
26
18.
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:
a)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
b)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
27
19.
UTILITIES/SERVICE SYSTEMS. Would the project: Potentially
Significant
Impact
Less than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
(a) Require or result in the relocation or construction of new or
expanded water, wastewater treatment or storm water drainage,
electric power, natural gas, or telecommunication facilities, the
construction or relocation of which could cause significant
environmental effects?
(b) Have sufficient water supplies available to serve the project and
reasonably foreseeable future development during normal, dry and
multiple dry years?
(c) 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?
(d) Generate solid waste in excess of State or local standards, or in
excess of the capacity of local infrastructure, or otherwise impair the
attainment of solid waste reduction goals?
(e) Comply with federal, state, and local management and reduction
statutes and regulations related to solid wastes?
Impact Analysis:
a)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
b)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
c)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
d)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
28
e)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
29
20.
WILDFIRE. If located in or near state responsibility areas or
lands classified as very high fire hazard severity zones, would the
project:
Potentially
Significant
Impact
Less than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
(a) Substantially impair an adopted emergency response plan or
emergency evacuation plan?
(b) Due to slope prevailing winds, and other factors, exacerbate wildfire
risks, and thereby expose project occupants to, pollutant
concentrations from a wildfire or the uncontrolled spread of a
wildfire?
(c) Require the installation or maintenance of associated infrastructure
(such as roads, fuel breaks, emergency water sources, power lines or
other utilities) that may exacerbate fire risk or that may result in
temporary or ongoing impacts to the environment?
(d) Expose people or structures to significant risks, including downslope
or downstream flooding or landslides, as a result of r unoff, post-fire
slope instability, or drainage changes?
Impact Analysis:
a)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
b)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
c)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
d)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
30
21.
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 substantially 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, substantially 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)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
b)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
c)
Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
31
REFERENCES
(Identify all references used in the environmental impact analysis)
PREPARERS AND PERSONS CONSULTED
(Identify preparers, including preparers of technical studies, as well as persons consulted in person, by
phone or in correspondence for the environmental impact analysis)
MITIGATION MONITORING AND REPORTING PROGRAM
(Refer to City’s Mitigation Monitoring Program template on the City’s website)
APPENDICES
(Include any technical studies used in the environmental impact analysis)
ENVIRONMENTAL CHECKLIST FOR SUBSEQUENT
PROJECTS FORM
FOR USE WHEN THE CITY IS REVIEWING SUBSEQUENT DISCRETIONARY
ACTIONS PURSUANT TO A PREVIOUSLY ADOPTED OR CERTIFIED
ENVIRONMENTAL DOCUMENT
Project Title:
Reference Application Numbers:
Lead Agency:
Contact Person and Telephone No.:
Project Proponent and Address:
Contact Person and Telephone No.:
Project Location:
Existing General Plan Designation: Existing Zoning Classification:
INTRODUCTION
(Summarize project and describe compliance with CEQA and purpose of Initial Study)
EXISTING SETTING
Regional Setting:
Existing Site Conditions:
(Describe the project site)
Surrounding Land Uses:
(Describe the land uses and characteristics of the surrounding area)
PREVIOUS ENVIRONMENTAL DOCUMENT
(Describe the previously adopted ND or MND or the previously certified EIR (include the date
the document was adopted or certified, the date the project was approved by the City, the date
the NOD was filed with the County, and a summary of potentially significant effects identified in
the CEQA document).
PROJECT DESCRIPTION
(Describe the components of the project including proposed physical improvements,
construction, operations, phasing, and City approvals required to accommodate the project).
Other Public Agencies Whose Approval is Required (Responsible or Trustee Agencies):
(Identify other public agencies whose approval is required for project implementation and
agencies with jurisdiction over affected natural resources)
Consultation with California Native American tribes traditionally and culturally affiliated
with the project area requested pursuant to Public Resources Code Section 21080.3.1:
(Identify agency efforts with respect to consultation and if any tribes have requested
consultation)
Note: Conducting consultation early in the CEQA process allows tribal governmen ts, lead agencies, and project
proponents to discuss the level of environmental review, identify and address potential adverse impacts to tribal
cultural resources, and reduce the potential for delay and conflict in the environmental review process. (See P ublic
Resources Code §21083.3.2.) Information may also be available from the California Native American Heritage
Commission’s Sacred Lands File per Public Resources Code §5097.96 and the California Historical Resources
Information System administered by the California Office of Historic Preservation. Please also note that Public
Resources Code §21082.3(c) contains provisions specific to confidentiality.
2
ENVIRONMENTAL CHECKLIST
NEW SIGNIFICANT ENVIRONMENTAL EFFECTS OR SUBSTANTIALLY MORE SEVERE
SIGNIFICANT ENVIRONMENTAL EFFECTS COMPARED TO THOSE IDENTIFIED IN THE
PREVIOUS CEQA DOCUMENT.
The subject areas checked below were determined to be new significant environmental effects or to be
previously identified effects that have a substantial increase in severity either due to a change in project,
change in circumstances or new information of substantial importance, as indicated by the checklist and
discussion on the following pages.
Aesthetics Agriculture & Forest Resources Air Quality
Biological Resources Cultural Resources Energy
Geology/Soils Greenhouse Gas Emissions Hazards & Hazardous
Materials
Hydrology/Water Quality Land Use/Planning Mineral Resources
Noise Population/Housing Public Services
Recreation Transportation Tribal Cultural Resources
Utilities/Service Systems Wildfire Mandatory Findings of
Significance
DETERMINATION. On the basis of this initial evaluation:
1. No substantial changes are proposed in the project and there are no substantial changes in
the circumstances under which the project will be undertaken that will require major
revisions to the previous approved Negative Declaration or Mitigated Negative
Declaration or certified EIR due to the involvement of new significant environmental
effects or a substantial increase in the severity of previously identified significant
effects. Also, there is no "new information of substantial importance" as that term is used
in CEQA Guidelines Section 15162(a)(3). Therefore, the previously adopted Negative
Declaration or Mitigated Negative Declaration or previously certified EIR adequately
discusses the potential impacts of the project without modification.
2. No substantial changes are proposed in the project and there are no substantial changes in
the circumstances under which the project will be undertaken that will require major
revisions to the previous approved Negative Declaration or Mitigated Negative
Declaration or certified EIR due to the involvement of new significant environmental
effects or a substantial increase in the severity of previously identified significant
effects. Also, there is no "new information of substantial importance" as that term is used
in CEQA Guidelines Section 15162(a)(3). Therefore, the previously adopted Negative
Declaration or Mitigated Negative Declaration or previously certified EIR adequately
discusses the potential impacts of the project; however, minor changes require the
preparation of an ADDENDUM.
3
3. Substantial changes are proposed in the project or there are substantial changes in the
circumstances under which the project will be undertaken that will require major revisions
to the previously adopted Negative Declaration or Mitigated Negative Declaration or
previously certified EIR due to the involvement of significant new environmental effects
or a substantial increase in the severity of previously identified significant effects. Or,
there is "new information of substantial importance," as that term is used in CEQA
Guidelines Section 15162(a)(3). However, all new potentially significant environmental
effects or substantial increases in the severity of previously identified significant effects
are clearly reduced to below a level of significance throu gh the incorporation of
mitigation measures agreed to by the project applicant. Therefore, a SUBSEQUENT
MITIGATED NEGATIVE DECLARATION is required.
4. Substantial changes are proposed in the project or there are substantial changes in the
circumstances under which the project will be undertaken that will require major revisions
to the previous environmental document due to the involvement of significant new
environmental effects or a substantial increase in the severity of previously identified
significant effects. Or, there is "new information of substantial importance," as that term
is used in CEQA Guidelines Section 15162(a)(3). However, only minor changes or
additions or changes would be necessary to make the previously certified EIR adequate
for the project in the changed situation. Therefore, a SUPPLEMENTAL
ENVIRONMENTAL IMPACT REPORT is required.
5. Substantial changes are proposed in the project or there are substantial changes in the
circumstances under which the project will be undertaken that will require major revisions
to the previous environmental document due to the involvement of significant new
environmental effects or a substantial increase in the severity of previously identified
significant effects. Or, there is "new information of substantial importance," as that term
is used in CEQA Guidelines Section 15162(a)(3). Therefore, a SUBSEQUENT
ENVIRONMENTAL IMPACT REPORT is required.
________________________________________ ___________________________
Name, Title Date
4
EVALUATION OF ENVIRONMENTAL IMPACTS:
1. A finding of “No New Impact/No Impact” means that the potential impact was fully analyzed and/or mitigated
in the prior CEQA document and no new or different impacts will result from the proposed activity. A brief
explanation is required for all answers except "No New Impact/No Impact" answers that are adequately
supported by the information sources a lead agency cites in the parentheses following each question. A "No
New Impact/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 New Impact/No Impact" answer should be explained where it is based on proj ect-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. A finding of “New Mitigation is Required” means that the project have a new potentia lly significant impact
on the environment or a substantially more severe impact than analyzed in the previously approved or certified
CEQA document and that new mitigation is required to address the impact.
3. A finding of “New Potentially Significant Impact” means that the project may have a new potentially
significant impact on the environment or a substantially more severe impact than analyzed in the previously
approved or certified CEQA document that cannot be mitigated to below a level of significance or be avoided.
4. A finding of “Reduced Impact” means that a previously infeasible mitigation measure is now available, or a
previously infeasible alternative is now available that will reduce a significant impact identified in the
previously prepared environmental document.
5. 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
6. 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. 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 proposed action.
c. Infeasible Mitigation Measures. Since the previous EIR was certified or previous N egative Declaration
or Mitigated Negative Declaration was adopted, discuss any mitigation measures or alternatives
previously found not to be feasible that would in fact be feasible or that are considerably different from
those previously analyzed and would substantially reduce one or more significant effects of the project,
but the project proponents decline to adopt the mitigation measures or alternatives.
d. Changes in Circumstances. Since the previous EIR was certified or previous Negative Declaration or
Mitigated Negative Declaration was adopted, discuss any changes in the project, changes in circumstances
under which the project is undertaken and/or "new information of substantial importance" that cause a
change in conclusion regarding one or more effects discussed in the original document.
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.
5
9. The explanation of each issue should identify:
a. the significance criteria or threshold, if any, used to evaluate each question; and
b. differences between the proposed activity and the previously approved project described in the adopted
Negative Declaration or Mitigated Negative Declaration or certified EIR; and
c. the previously approved mitigation measure identified, if any, to reduce the impact to less than
significance.
6
CHECKLIST OF ENVIRONMENTAL IMPACT ISSUES:
1.
AESTHETICS. Except as provided in Public Resources Code
Section 21099, would the project:
New
Potentially
Significant
Impact
New
Mitigation is
Required
No New
Impact/No
Impact
Reduced
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) In non-urbanized areas, substantially degrade the existing visual
character or quality of public views of the site and its surroundings?
(Public views are those that are experienced from publicly accessible
vantage point). If the project is in an urbanized area, would the project
conflict with applicable zoning or other regulations governing scenic
quality?
(d) Create a new source of substantial light or glare which would
adversely affect day or nighttime views in the area?
Impact Analysis
a)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
b)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
c)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
d)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
7
2. AGRICULTURE & FOREST 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.) In
determining whether impacts to forest resources, including
timberland, are significant environmental effects, lead agencies ma y
refer to information compiled by the California Department of
Forestry and Fire Protection regarding the state’s inventory of forest
land, including the Forest and Range Assessment Project and the
Forest Legacy Assessment project; and forest carbon measurement
methodology provided in Forest Protocols adopted by the California
Air Resources Board.) Would the project:
New
Potentially
Significant
Impact
New
Mitigation is
Required
No New
Impact/No
Impact
Reduced
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?
Impact Analysis:
a)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
b)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
c)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
d)
8
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
e)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
9
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:
New
Potentially
Significant
Impact
New
Mitigation is
Required
No New
Impact/No
Impact
Reduced
Impact
(a) Conflict with or obstruct implementation of the applicable air quality
plan?
(b) 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?
(c) Expose sensitive receptors to substantial pollutant concentrations?
(d) Result in other emissions (such as those leading to odors) adversely
affecting a substantial number of people?
Impact Analysis:
a)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
b)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
c)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
d)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
10
4.
BIOLOGICAL RESOURCES. Would the project:
New
Potentially
Significant
Impact
New
Mitigation is
Required
No New
Impact/No
Impact
Reduced
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 state or federally protected
wetlands (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?
Impact Analysis:
a)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
b)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
c)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
d)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
11
e)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
f)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
12
5.
CULTURAL RESOURCES. Would the project:
New
Potentially
Significant
Impact
New
Mitigation is
Required
No New
Impact/No
Impact
Reduced
Impact
(a) Cause a substantial adverse change in the significance of a historical
resource pursuant to in §15064.5?
(b) Cause a substantial adverse change in the significance of an
archaeological resource pursuant to §15064.5?
(c) Disturb any human remains, including those interred outside of
dedicated cemeteries?
Impact Analysis:
a)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
b)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
c)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
13
6.
ENERGY. Would the project:
New
Potentially
Significant
Impact
New
Mitigation is
Required
No New
Impact/No
Impact
Reduced
Impact
(a) Result in potentially significant environmental impact due to wasteful,
inefficient, or unnecessary consumption of energy resources, during
project construction or operation?
(b) Conflict with or obstruct a state or local plan for renewable energy or
energy efficiency?
Impact Analysis:
a)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
b)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
14
7.
GEOLOGY AND SOILS. Would the project:
New
Potentially
Significant
Impact
New
Mitigation is
Required
No New
Impact/No
Impact
Reduced
Impact
(a) Directly or indirectly cause 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 direct or indirect
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?
(f) Directly or indirectly destroy a unique paleontological resource or site
or unique geologic feature?
Impact Analysis:
a)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
b)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
c)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
d)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
15
e)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
f)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
16
8.
GREENHOUSE GAS EMISSIONS. Would the project:
New
Potentially
Significant
Impact
New
Mitigation is
Required
No New
Impact/No
Impact
Reduced
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)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
b)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
17
9. HAZARDS AND HAZARDOUS MATERIALS.
Would the project:
New
Potentially
Significant
Impact
New
Mitigation is
Required
No New
Impact/No
Impact
Reduced
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 or
excessive noise for people residing or working in the project area?
(f) Impair implementation of or physically interfere with an adopted
emergency response plan or emergency evacuation plan?
(g) Expose people or structures, either directly or indirectly to a
significant risk of loss, injury or death involving wildland fires?
Impact Analysis:
a)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
b)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
c)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
d)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
e)
18
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
f)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
g)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
19
10.
HYDROLOGY AND WATER QUALITY.
Would the project:
New
Potentially
Significant
Impact
New
Mitigation is
Required
No New
Impact/No
Impact
Reduced
Impact
(a) Violate any water quality standards or waste discharge requirements
or otherwise substantially degrade surface or ground water quality?
(b) Substantially decrease groundwater supplies or interfere substantially
with groundwater recharge such that the project may impede
sustainable groundwater management of the basin?
(c) Substantially alter the existing drainage pattern of the site or area,
including through the alteration of the course of a stream or river or
through the addition of impervious surfaces, in a manner which
would:
(i) result in substantial erosion or siltation on- or off-site;
(ii) increase the rate or amount of surface runoff in a manner which
would result in flooding in- or off-site;
(iii) 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; or
(iv) impede or redirect flood flows?
(d) In flood hazard, tsunami, or seiche zones, risk release of pollutants
due to project inundation?
(e) Conflict with or obstruct implementation of a water quality control
plan or sustainable groundwater management plan?
(f) Result in the potential for discharge of stormwater to affect the
beneficial uses of the receiving waters from construction activities or
post-construction activities?
(g) 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?
(h) Create the potential for significant changes in the flow velocity or
volume of stormwater runoff to cause environmental harm?
Impact Analysis:
a)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
b)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
c)
Previous Significance Determination:
Mitigation Measures:
20
Significance Determination After Mitigation:
d)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
e)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
f)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
g)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
h)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
21
11.
LAND USE/PLANNING. Would the project:
New
Potentially
Significant
Impact
New
Mitigation is
Required
No New
Impact/No
Impact
Reduced
Impact
(a) Physically divide an established community?
(b) Cause a significant environmental impact due to a conflict with any
applicable land use plan, policy, or regulation adopted for the purpose
of avoiding or mitigating an environmental effect?
Impact Analysis:
a)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
b)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
22
12.
MINERAL RESOURCES. Would the project:
New
Potentially
Significant
Impact
New
Mitigation is
Required
No New
Impact/No
Impact
Reduced
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?
Impact Analysis:
a)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
b)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
23
13.
NOISE. Would the project result in:
New
Potentially
Significant
Impact
New
Mitigation is
Required
No New
Impact/No
Impact
Reduced
Impact
(a) Generation of a substantial temporary or permanent increase in
ambient noise levels in the vicinity of the project in excess of
standards established in the local general plan or noise ordinance, or
applicable standards of other agencies?
(b) Generation of excessive groundborne vibration or groundborne noise
levels?
(c) For a project located within the vicinity of a private airstrip or 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?
Impact Analysis:
a)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
b)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
c)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
24
14.
POPULATION AND HOUSING. Would the project:
New
Potentially
Significant
Impact
New
Mitigation is
Required
No New
Impact/No
Impact
Reduced
Impact
(a) Induce substantial unplanned 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 people or housing,
necessitating the construction of replacement housing elsewhere?
Impact Analysis:
a)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
b)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
25
15.
PUBLIC SERVICES.
New
Potentially
Significant
Impact
New
Mitigation is
Required
No New
Impact/No
Impact
Reduced
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?
Impact Analysis:
(a) i)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
ii)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
iii)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
iv)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
v)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
26
16.
RECREATION.
New
Potentially
Significant
Impact
New
Mitigation is
Required
No New
Impact/No
Impact
Reduced
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?
Impact Analysis:
a)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
b)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
27
17.
TRANSPORTATION. Would the project:
New
Potentially
Significant
Impact
New
Mitigation is
Required
No New
Impact/No
Impact
Reduced
Impact
(a) Conflict with a program, plan, ordinance or policy addressing the
circulation system, including transit, roadway, bicycle and pedestrian
facilities?
(b) Would the project conflict or be inconsistent with CEQA Guidelines
Section 15064.3, subdivision (b)?
(c) Substantially increase hazards due to a geometric design feature (e. g.,
sharp curves or dangerous intersections) or incompatible uses (e.g.,
farm equipment)?
(d) Result in inadequate emergency access?
Impact Analysis:
a)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
b) (In accordance with CEQA Guidelines Section 15064.3(c), the City of Orange, as the lead agency,
will implement the provisions of Section 15064.3 of the CEQA Guidelines, when the provisions go into
effect statewide beginning July 1, 2020.)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
c)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
d)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
28
18.
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:
New
Potentially
Significant
Impact
New
Mitigation is
Required
No New
Impact/No
Impact
Reduced
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:
a)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
b)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
29
19.
UTILITIES/SERVICE SYSTEMS. Would the project:
New
Potentially
Significant
Impact
New
Mitigation is
Required
No New
Impact/No
Impact
Reduced
Impact
(a) Require or result in the relocation or construction of new or expanded
water, wastewater treatment or storm water drainage, electric power,
natural gas, or telecommunication facilities, the construction or
relocation of which could cause significant environmental effects?
(b) Have sufficient water supplies available to serve the project and
reasonably foreseeable future development during normal, dry and
multiple dry years?
(c) 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?
(d) Generate solid waste in excess of State or local standards, or in excess
of the capacity of local infrastructure, or otherwise impair the
attainment of solid waste reduction goals?
(e) Comply with federal, state, and local management and reduction
statutes and regulations related to solid wastes?
Impact Analysis:
a)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
b)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
c)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
d)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
e)
Previous Significance Determination:
Mitigation Measures:
30
Significance Determination After Mitigation:
31
20.
WILDFIRE. If located in or near state responsibility areas or
lands classified as very high fire hazard severity zones, would the
project:
New
Potentially
Significant
Impact
New
Mitigation is
Required
No New
Impact/No
Impact
Reduced
Impact
(a) Substantially impair an adopted emergency response plan or
emergency evacuation plan?
(b) Due to slope prevailing winds, and other factors, exacerbate wildfire
risks, and thereby expose project occupants to, pollutant
concentrations from a wildfire or the uncontrolled spread of a
wildfire?
(c) Require the installation or maintenance of associated infrastructure
(such as roads, fuel breaks, emergency water sources, power lines or
other utilities) that may exacerbate fire risk or that may result in
temporary or ongoing impacts to the environment?
(d) Expose people or structures to significant risks, including downslope
or downstream flooding or landslides, as a result of runoff, post-fire
slope instability, or drainage changes?
Impact Analysis:
a)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
b)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
c)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
d)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
32
21.
MANDATORY FINDINGS OF SIGNIFICANCE.
New
Potentially
Significant
Impact
New
Mitigation is
Required
No New
Impact/No
Impact
Reduced
Impact
(a) Does the project have the potential to substantially 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,
substantially 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)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
b)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
c)
Previous Significance Determination:
Mitigation Measures:
Significance Determination After Mitigation:
33
REFERENCES
(Identify all references used in the environmental impact analysis)
PREPARERS AND PERSONS CONSULTED
(Identify preparers, including preparers of technical studies, as well as persons consulted in person, by
phone or in correspondence for the environmental impact analysis)
MITIGATION MONITORING AND REPORTING PROGRAM
(Refer to City’s Mitigation Monitoring Program template on the City’s website)
APPENDICES
(Include any technical studies used in the environmental impact analysis)
Mitigation Monitoring Report- Page1
MITIGATION MONITORING AND REPORTING PROGRAM
ENVIRONMENTAL DOCUMENT REFERENCE NUMBER
PROJECT NAME:
PROJECT LOCATION:
PROJECT DESCRIPTION:
LEAD AGENCY:
CONTACT PERSON/ TELEPHONE NO.:
APPLICANT:
CONTACT PERSON/ TELEPHONE NO.:
No.
Mitigation Measure
Time Frame
and Responsible
Party for
Implementation
Time Frame and
Responsible
Party for
Monitoring
Verification of Compliance
Initials
Date
Remarks
Aesthetics
Agriculture and Forestry Resources
Air Quality
Biological Resources
Cultural Resources
Energy
Mitigation Monitoring Report- Page2
No.
Mitigation Measure
Time Frame
and Responsible
Party for
Implementation
Time Frame and
Responsible
Party for
Monitoring
Verification of Compliance
Initials
Date
Remarks
Geology and Soils
Greenhouse Gas Emissions
Hazards and Hazardous Materials
Hydrology and Water Quality
Land Use and Planning
Mineral Resources
Noise
Population and Housing
Public Services
Mitigation Monitoring Report- Page3
No.
Mitigation Measure
Time Frame
and Responsible
Party for
Implementation
Time Frame and
Responsible
Party for
Monitoring
Verification of Compliance
Initials
Date
Remarks
Recreation
Transportation
Tribal Cultural Resources
Utilities and Service Systems
Wildfire
IMPLEMENTATION
ORANGE GENERAL PLAN
IMP-28 GPA 2010-0001 (8/10/10)
III. Conditions or Requirements Placed upon Applicants
during Development Review
Program III-1 California Environmental Quality Act
Comply with all provisions of CEQA. In addition to thresholds that may be established or
adopted by the City in the future, use the following thresholds and procedures for CEQA
analysis of proposed projects, consistent with policies adopted within the General Plan:
Circulation & Mobility
o In accordance with CEQA Guidelines Section 15064.3, the City shall utilize vehicle
miles traveled (VMT), to measure transportation impacts.
o A project would result in a significant project-generated VMT impact if the baseline
and/or cumulative project-generated VMT per service population exceeds the City of
Orange General Plan Buildout VMT per service population.
o The project’s effect on VMT would be considered significant if it resulted in baseline
and/or cumulative link-level boundary citywide VMT per service population increases
under the plus project condition compared to the no project condition.
Parks and Recreation
o The City shall require dedication of parkland at a rate of 3.0 acres per 1,000
anticipated residents or payment of in-lieu fees for new residential projects.
Noise
o The City shall apply the noise standards specified in Tables N-3 and N-4 of the Noise
Element to proposed projects analyzed under CEQA.
o In addition to the foregoing, an increase in ambient noise levels is assumed to be a
significant noise impact if a proposed project causes ambient noise levels to exceed
the following:
Where the existing ambient noise level is less than 65 dBA, a project related
permanent increase in ambient noise levels of 5 dBA CNEL or greater.
Where the existing ambient noise level is greater than 65 dBA, a project related
permanent increase in ambient noise levels of 3 dBA CNEL or greater.
Historic and Cultural Resources
o “Historical resource” for the purposes of CEQA shall mean “historic district” in the
case of a contributor to a historic district.
o Historic resources listed in the Historic Register shall have a presumption of
significance pursuant to CEQA Section 21084.1 and shall be treated as historical
resources under CEQA.
o The historical significance of an archaeological historic resource is evaluated using
the criteria of Public Resources Code Section 5024.1 and Section 15064.5 et seq. of
the state CEQA Guidelines.
IMPLEMENTATION
ORANGE GENERAL PLAN
IMP-29
All future development proposals shall be reviewed by the City for potential regional and
local air quality impacts per CEQA. If potential impacts are identified, mitigation will be
required to reduce the impact to a level less than significant, where technically and
economically feasible.
Agency/Department: Community Development Department, Public Works
Department, Community Services Department
Funding Source: General Fund, development fees
Time Frame: Ongoing
Related Policies:
Circulation & Mobility: 1.1, 1.2
Natural Resources: 2.2, 2.8, 5.6
Cultural Resources &
Historic Preservation: 1.1, 1.3
Noise: 1.4
Growth Management: 1.1, 2.1
Program III–2 Site Development Review
Comply with all City procedures in the review of proposed development projects, and use the
site plan review process to ensure that applicable General Plan policies and City standards
and regulations are applied to proposals for specific development projects.
Agency/Department: Community Development Department, Public Works
Department, Police Department, Fire Department,
Community Services Department
Funding Source: Development fees
Time Frame: Ongoing
Related Policies:
Land Use: 1.6, 1.7, 2.5, 2.7, 2.8, 3.1, 3.4, 4.3, 4.5, 6.1, 6.2, 6.9, 6.10, 6.12
Circulation & Mobility: 1.1, 1.7, 5.1, 5.2
Natural Resources 1.3, 2.3, 2.6, 2.13, 2.14, 2.15, 2.16, 4.3, 4.4, 4.5, 5.4, 5.6, 5.7,
6.6, 7.5
Cultural Resources &
Historic Preservation: 1.3, 1.4, 1.5, 1.6, 4.1, 4.2, 4.3, 4.4, 4.5
Public Safety: 1.1, 2.5, 3.3, 3.5, 4.2, 4.3, 6.2, 7.2, 7.3, 7.4, 9.1
Noise: 1.1, 1.2, 1.3, 1.4, 1.5, 1.6, 2.1, 2.2, 5.1, 5.2, 5.3, 6.1, 6.2
Urban Design: 2.4, 2.5, 2.6, 3.4, 3.5, 6.1
Infrastructure: 1.4, 1.5
Program III-3 Commission/Committee Review
Orange has several commissions and one committee whose purpose is to advise and assist
the City Council in dealing with issues related to each commission’s or committee’s area of
concern. The commissions and committee gather pertinent information, hear arguments,
IMPLEMENTATION
ORANGE GENERAL PLAN
IMP-30 GPA 2010-0001 (8/10/10)
weigh values, and make recommendations to the Council. Several of the commissions also
have some administrative powers.
The City will continue to use the commission/committee structure to inform the public
decision-making process.
The City will also consider expanding the authority of the Design Review Committee and
Community Development Department’s staff to administer the Orange Historic Resources
Inventory, Historic Register listings, and design review procedures for projects involving
architectural and archaeological resources.
Agency/Department: City Council, Community Development Department,
Community Services Department
Funding Source: General Fund
Time Frame: Ongoing
Related Policies:
Land Use: 2.5, 2.6, 2.7, 2.8, 3.1, 3.2, 4.5, 5.5, 5.8, 5.9, 6.1, 6.2, 6.3, 6.4,
6.7, 6.11, 8.1, 8.2, 8.3
Circulation & Mobility: 1.3, 2.3, 3.2, 4.1, 6.1
Cultural Resources &
Historic Preservation: 1.1, 1.3, 1.4, 4.5, 4.6
Urban Design: 1.1, 6.1
Public Safety: 1.1, 3.5, 4.3, 7.4
Economic Development: 1.2, 2.5, 3.3, 4.5, 5.1, 5.2, 5.3, 5.4, 5.5
Program III-4 Traffic Impact Analyses
Require preparation of traffic impact analyses for new discretionary development projects.
A traffic impact analysis which includes VMT assessment shall be required for a proposed
project that does not satisfy the project screening criteria. For projects that increase V/C by
0.01 or more on affected roadway segments or intersections experiencing LOS E or LOS F
conditions without the proposed project, traffic impact analyses must propose binding
reduction strategies to be incorporated within the project.
Continue to update guidelines for the preparation of traffic impact analyses to reflect local
conditions and industry standards.
Agency/Department: Public Works Department
Funding Source: Development fees
Time Frame: Ongoing
Related Policies:
Land Use: 2.5, 6.10
Circulation & Mobility: 1.1
Growth Management: 1.2, 1.6
IMPLEMENTATION
ORANGE GENERAL PLAN
IMP-31
Program III-5 Transportation Demand Management Plans
Require major employers of 100 persons or more to institute transportation demand
management (TDM) plans. Such plans establish incentives to encourage employees to
carpool, take public transportation, bicycle, or use some means other than private
automobiles to get to and from work.
Agency/Department: Community Development Department, Public Works
Department
Funding Source: Development fees
Time Frame: Ongoing
Related Policies:
Circulation & Mobility: 2.6
Natural Resources: 2.1, 2.2
Growth Management: 1.12
Program III-6 National Pollutant Discharge
Elimination System Compliance
Before making land use decisions, the City will utilize available methods to estimate increases
in pollutant loads and flows resulting from projected future development.
The City will follow the most current NPDES permit and countywide Model WQMP and the
City Local Implementation Plan to ensure that the City complies with applicable federal and
state regulations. Applicants for new development and redevelopment projects shall prepare
and submit plans to the City, as well as implement plans demonstrating accomplishment of
the following:
Emphasize the need to implement and prioritize the use of low impact development
BMPs that provide onsite infiltration and retention;
Use biotreatment systems such as flow through planters, wetlands and bioswales where
infiltration, evapotranspiration, and harvest and reuse are not feasible;
Limit areas of impervious surfaces and preserve natural areas;
Limit directly connected areas of impervious surfaces;
Limit disturbance of natural water bodies, natural drainage systems, and highly erodable
areas;
Use structural and nonstructural best management practices (BMPs) to mitigate
projected increases in pollutant loads and flows;
Use pollution prevention methods, source controls, and treatment with small collection
strategies located at or as close as possible to the source;
Control the velocity of pollutant loading flows during and after construction; and
Implement erosion protection during construction.
IMPLEMENTATION
ORANGE GENERAL PLAN
IMP-32 GPA 2010-0001 (8/10/10)
In addition, applicants for large development projects are required to prepare and implement
plans that meet site predevelopment hydrologic conditions and to control runoff on-site
where technically feasible.
Agency/Department: Public Works Department, Community Development
Department
Funding Source: Development fees
Time Frame: Ongoing
Related Policies:
Land Use; 4.3, 6.5
Natural Resources: 2.12, 2.13, 2.14, 2.15, 2.16, 2.17
Public Safety: 2.3
Program III-7 Water Services and Supplies
As needed, require studies to determine water infrastructure requirements for future
development projects, and require that any recommendations be incorporated into the
design of projects. Require the dedication of necessary right-of-way and construction of
water infrastructure improvements for development projects as needed. Developers shall
also be required to pay the cost of providing new and improved water services to project
sites.
For projects that satisfy the criteria set forth in Sections 10910–10915 of the California Water
Code and Section 66473.7 of the Government Code, a water supply assessment or water
supply verification demonstrating available water supplies exist to support development
shall also be prepared.
Agency/Department: Community Development Department, Public Works
Department
Funding Source: Development fees, General Fund
Time Frame: Ongoing
Related Policies:
Infrastructure: 1.1, 1.4, 1.6
Program III-8 Adequate Public Safety and Emergency
Response
During the development application process, consult with Fire and Police Departments to
evaluate the need for additional fire and police facilities or resources to serve new
development projects and infill development areas. During updates to the Capital
Improvement Program process, coordinate with service providers to evaluate the level of fire
and police service provided to the community. Require adequate street widths and clearance
for emergency access. Provide all appropriate safety features. Continue to use state-of-the-
art techniques and technology to enhance public safety.
IMPLEMENTATION
ORANGE GENERAL PLAN
IMP-33
Adhere to requirements in the Municipal Code for adequate street widths and clearance for
emergency access. Integrate CPTED techniques into development projects and practice
active surveillance measures in high-risk areas such as parking lots.
The City shall use open space easements and other regulatory techniques to prohibit
development and avoid public safety hazards where the threat from seismic hazards cannot
be mitigated.
Agency/Department: Community Development Department, Public Works
Department, Police Department, Fire Department
Funding Source: Development fees, General Fund
Time Frame: Ongoing
Related Policies:
Public Safety: 3.4, 4.4, 6.1, 6.2, 6.3, 6.4
Program III-9 Geologic Hazard Assessments
Pursuant to state law, geologic and/or geotechnical studies are required for proposed new
development projects located in areas identified as susceptible to landslides and liquefaction
and binding mitigation strategies must be adopted. Compliance with the recommendations
set forth in site-specific geologic and/or geotechnical studies will be made a condition of
approval for new development. In addition, the City may require applicants to incorporate
measures to stabilize and maintain slopes on a site-by-site basis, such as proper planting,
irrigation, retaining walls, and benching.
Agency/Department: Community Development Department, Public Works
Department
Funding Source: Development fees
Time Frame: Ongoing
Related Policies:
Land Use: 6.9, 6.10
Public Safety: 1.1
Program III-10 Cultural Resources Inventories
Require cultural resources inventories of all new development projects in areas identified
with medium or high potential for archeological, paleontological, or cultural resources based
on resource sensitivity maps prepared in conjunction with the General Plan.
Where a preliminary site survey finds medium to high potential for substantial archaeological
remains, the City shall require a mitigation plan to protect the resource before issuance of
permits. Mitigation may include:
Ensuring that a qualified archaeologist is present during initial grading or trenching
(monitoring),
Redesigning the project to avoid archaeological resources (this is considered the
strongest tool for preserving archaeological resources),
IMPLEMENTATION
ORANGE GENERAL PLAN
IMP-34 GPA 2010-0001 (8/10/10)
Capping the site with a layer of fill, and/or
Excavating and removing the archaeological resources (recovery) and implementing
curation in an appropriate facility under the direction of a qualified archaeologist
(interpretation).
Alert applicants for permits within early settlement areas to the potential sensitivity. If an
archaeological inventory survey is required, the final stage is the preparation of a
professional report detailing the findings and recommendations of the records search and
field survey. The final report containing site forms, site significance, and mitigation measures
should be submitted immediately to the Community Development Department. All
information regarding site locations, Native American human remains, and associated
funerary objects should be in a separate confidential addendum, and not be made available
for public disclosure.
If significant archaeological resources are discovered during construction or grading
activities, such activities shall cease in the immediate area of the find until a qualified
archaeologist can determine the significance of the resource and recommend alternative
mitigation. The final written report should be submitted to the appropriate regional
archaeological Information Center within three months after work has been completed. The
City shall ensure that project applicants contact the Native American Heritage Commission
for a Sacred Lands File Check and a list of appropriate Native American contacts f or
consultation concerning the project site and to assist in crafting the mitigation measures.
Agency/Department: Community Development Department
Funding Source: Development fees
Time Frame: Ongoing
Related Policies:
Land Use: 6.11
Cultural Resources &
Historic Preservation: 4.1, 4.5
Program III-11 Green Building, Energy Conservation,
and Sustainable Development
The City strongly encourages new development and major renovation projects to employ
green building techniques and materials. Encourage proposed development projects
throughout the City to use Leadership in Energy and Environmental Design (LEED) standards
developed by the U.S. Green Building Council or a similar third-party verified program.
Encourage building orientations and landscaping that enhance natural lighting and sun
exposure. Prepare guidelines for sustainable development to encourage incorporation of
these practices in new development. These guidelines will include measures to maximize soil
permeability to address related stormwater and surface-water runoff issues.
Require compliance with state Title 24 building construction standards and Energy Star
conservation standards for all development projects.
IMPLEMENTATION
ORANGE GENERAL PLAN
IMP-35
Prepare and adopt an ordinance that requires and/or provides incentives for: (1) specified
new residential development to comply with a specified green building program or show
that its development provides comparable effectiveness to such a program; and (2) specified
non-residential development of a specified size comply with a specified green building
program or show that its development provides comparable effectiveness to such a
program.
Agency/Department: Community Development Department, Public Works
Department
Funding Source: Development fees
Time Frame: Ongoing; December 31, 2011 (For ordinance)
Related Policies:
Natural Resources: 2.6, 2.7
Program III-12 Mixed-Use Noise Property Notification
When the City exercises discretionary review, provides financial assistance, or otherwise
facilitates residential development within a mixed-use area, make providing written warnings
to potential residents about noise intrusion a condition of that approval, assistance, or
facilitation. The following language is provided as an example:
“All potential buyers and/or renters of residential property within mixed-use districts in the City
of Orange are hereby notified that they may be subject to audible noise levels generated by
business and entertainment related operations common to such areas, including amplified
sound, music, delivery and passenger vehicles, mechanical noise, pedestrians, and other urban
noise sources.”
Agency/Department: Community Development Department
Funding Source: Development fees
Time Frame: Ongoing
Related Policies:
Noise: 5.1, 5.3
Urban Design: 2.5
Program III-13 Ecological and Biological Resource
Assessments
Analyze development proposals for potential impacts on significant ecological and biological
resources. Require appropriate mitigation for all significant impacts if impact avoidance is
not possible. Mitigation measures for habitat and species may include but are not limited to
avoidance, enhancement, restoration, compensatory mitigation, or a combination of these.
Agency/Department: Community Development Department
Funding Source: Development fees
Time Frame: Ongoing
IMPLEMENTATION
ORANGE GENERAL PLAN
IMP-36 GPA 2010-0001 (8/10/10)
Related Policies:
Land Use: 6.4, 6.11
Natural Resources: 4.1, 4.3, 4.4, 4.5
Program III-14 Archaeological Resources Management
Report (ARMR Preservation Bulletin)
Establish the Archaeological Resources Management Report (ARMR Preservation Bulletin) as
the standard report format for all documentation and accept reports only from registered
professional archaeologists knowledgeable in Native American cultures and/or historical
archaeology (qualified archaeologists).
Agency/Department: Community Development Department
Funding Source: Development fees
Time Frame: Ongoing
Related Policies:
Cultural Resources &
Historic Preservation: 4.1
Program III-15 Historic Resources Design Review
Continue to use the Secretary of the Interior’s Standards for the Treatment of Historic
Properties and Guidelines for Preserving, Rehabilitating, Restoring and Reconstructing Historic
Buildings as a basis for design review and incorporate them by reference into the Old Towne
Design Standards and other historic preservation design standards. Any approved demolition
permit for historic resources listed in the City’s Historic Register will be automatically subject
to a delay of 180 days before the permit for demolition may be issued. The property owner
will strive to develop alternatives to demolition that will preserve the historic resources.
The Design Review Committee or Historic Preservation Commission at such time such a
commission is established, shall serve as the review body for projects involving historic
resources.
Agency/Department: Community Development Department, City Council
Funding Source: General Fund
Time Frame: Ongoing
Related Policies:
Cultural Resources &
Historic Preservation: 1.1, 1.2, 1.3, 1.4, 1.5, 2.3, 3.2
Program III-16: Public Access to Santiago Creek and
Santa Ana River Public Interface
Ensure that new development does not preclude access to Santiago Creek and the Santa Ana
River and associated trails. Development review should ensure that commercial and retail
development in these areas support public access.
IMPLEMENTATION
ORANGE GENERAL PLAN
IMP-37
Agency/Department: Community Development Department
Funding Source: Development fees
Time Frame: Ongoing
Related Policies:
Land Use: 6.4, 6.6
Circulation & Mobility: 4.1
Natural Resources: 1.3, 5.5, 7.1, 7.2, 7.3, 7.4, 7.5
Urban Design: 2.6
Program III-17: Office Condominium Conversions
Evaluate applications for conversion of industrial properties to office condominiums to
determine the impact on the available balance of larger and smaller properties available for
industrial use.
Agency/Department: Community Development Department, Economic
Development Department
Funding Source: Development fees
Time Frame: Ongoing
Related Policies:
Land Use: 4.1, 4.2, 4.3, 4.4, 4.5
Economic Development: 3.1, 6.1, 6.2
Program III-18: Noise Reduction in New Construction
Require construction contractors to implement the following measures during construction
activities through contract provisions and/or conditions of approval as appropriate:
Construction equipment shall be properly maintained per manufacturers’ specifications
and fitted with the best available noise suppression devices (i.e., mufflers, silencers,
wraps, etc).
Shroud or shield all impact tools, and muffle or shield all intake and exhaust ports on
power equipment.
Construction operations and related activities associated with the proposed project shall
comply with the operational hours outlined in the City of Orange Municipal Code Noise
Ordinance, or mitigate noise at sensitive land uses to below Orange Municipal Code
standards.
Construction equipment should not be idled for extended periods of time in the vicinity
of noise sensitive receptors.
Locate fixed and/or stationary equipment as far as possible from noise sensitive
receptors (e.g., generators, compressors, rock crushers, cement mixers). Shroud or
IMPLEMENTATION
ORANGE GENERAL PLAN
IMP-38 GPA 2010-0001 (8/10/10)
shield all impact tools, and muffle or shield all intake and exhaust ports on powered
construction equipment.
Where feasible, temporary barriers shall be placed as close to the noise source or as close
to the receptor as possible and break the line of sight between the source and receptor
where modeled levels exceed applicable standards. Acoustical barriers shall be
constructed material having a minimum surface weight of 2 pounds per square foot or
greater, and a demonstrated Sound Transmission Class (STC) rating of 25 or greater as
defined by American Society for Testing and Materials (ASTM) Test Method E90.
Placement, orientation, size, and density of acoustical barriers shall be specified by a
qualified acoustical consultant.
Agency/Department: Community Development Department, Public Works
Department, Community Services Department
Funding Source: Development fees
Time Frame: Ongoing
Related Policies:
Noise: 1.1, 1.2, 1.4, 1.5, 7.2
Program III-19: Groundborne Noise and Vibration
Implement the following measures to reduce the potential for human annoyance and
architectural/structural damage resulting from elevated groundborne noise and vibration
levels.
Construction-Induced Vibration. The City shall implement or require implementation of
the following measures through contract provisions and/or conditions of approval as
appropriate:
o Pile driving required within a 50-foot radius of historic structures shall utilize
alternative installation methods where possible (e.g., pile cushioning, jetting, pre-
drilling, cast-in-place systems, resonance-free vibratory pile drivers). Specifically,
geo pier style cast-in-place systems or equivalent shall be used where feasible as
an alternative to pile driving to reduce the number and amplitude of impacts
required for seating the pile.
o The preexisting condition of all buildings within a 50-foot radius and of historic
buildings within the immediate vicinity of proposed construction-induced
vibration activities shall be recorded in the form of a preconstruction survey. The
preconstruction survey shall determine conditions that exist before construction
begins for use in evaluating damage caused by construction activities. Fixtures
and finishes within a 50-foot radius of construction activities susceptible to
damage shall be documented (photographically and in writing) prior to
construction. All damage will be repaired back to its preexisting condition.
IMPLEMENTATION
ORANGE GENERAL PLAN
IMP-39
o Vibration monitoring shall be conducted prior to and during pile driving
operations occurring within 100 feet of the historic structures. Every attempt
shall be made to limit construction-generated vibration levels in accordance with
Caltrans recommendations during pile driving and impact activities in the vicinity
of the historic structures.
o Provide protective coverings or temporary shoring of on-site or adjacent historic
features as necessary, in consultation with the Community Development Director
or designee.
Railroad-Induced Vibration:
o Vibration sensitive uses shall be located a minimum of 100 feet from the railroad
centerline, where feasible. To ensure compliance with FTA and Caltrans
recommended guidelines, a site-specific groundborne noise and vibration
assesment should be conducted. For sensitive uses located within 100 feet of the
railroad centerline, the acoustical noise and vibration assessment shall
demontrate that potential impacts will be below the level of significance. If
specific project-level impacts are identified, mitigation measures reducing the
impacts to below the level of significance will be required.
o A groundborne vibration assessment shall be conducted at proposed building
pad locations within 200 feet of railroad right-of-ways, prior to project approval.
Vibration monitoring and assessment shall be conducted by a qualified acoustical
consultant. The assessment will demonstrate that rail-associated groundborne
vibration and noise levels comply with recommended FTA and Caltrans guidance
of 80 VdB and 0.2 in/sec PPV (or equivalent), respectively, or propose project-
specific mitigation measures such as site design, building isolation, etc. to achieve
that standard.
Agency/Department: Community Development Department, Public Works
Department
Funding Source: General Fund, Development fees
Time Frame: Ongoing
Related Policies:
Noise: 1.1, 3.1, 3.2, 6.1, 7.2
Program III-20: Toxic Air Contaminant Exposure
Require each project applicant to implement the following measures to reduce the exposure
of sensitive receptors to TACs from mobile sources, as project design features or a condition
of project approval:
Activities involving idling trucks shall be oriented as far away from and downwind of
existing or proposed sensitive receptors as feasible.
IMPLEMENTATION
ORANGE GENERAL PLAN
IMP-40 GPA 2010-0001 (8/10/10)
Strategies shall be incorporated to reduce the idling time of main propulsion engines
through alternative technologies such as IdleAire, electrification of truck parking, and
alternative energy sources for TRUs to allow diesel engines to be completely turned off.
Proposed developments shall incorporate site plans that move sensitive receptors as far
as feasibly possible from major roadways (100,000+ average daily trips).
Projects containing sensitive receptors (such as residences, schools, day care centers,
and medical facilities) on sites within 500 feet of a freeway must demonstrate that health
risks relating to diesel particulates would not exceed acceptable health risk standards
prior to project approval.
Agency/Department: Community Development Department, Public Works
Department
Funding Source: Development fees
Time Frame: Ongoing
Related Policies:
Natural Resources: 2.1
City of Orange
Community Development Department
Memo
To: Planning Division Staff
From: Ashley Brodkin, Associate Planner
Date: March 24, 2020
Re: Guidance for Greenhouse Gas Emissions Analysis
This memo is intended to provide guidance to City Planning Division staff for evaluating
greenhouse gas (GHG) emissions analyses in CEQA documents for all non-exempt
projects in which the City of Orange is the lead agency, including GHG emissions analyses
prepared by Project Applicants. As such, it may also be reviewed by Project Applicants
and their consultants, as appropriate.
STATE LAW AND REGULATORY FRAMEWORK
Executive Order S-3-05 was issued by the California Governor in 2005 and established
statewide GHG reduction targets for California. The Executive Order required GHG
emissions to be reduced to 2000 levels by 2010, to 1990 levels by 2020, and to 80 percent
below 1990 levels by 2050.
Assembly Bill (AB) 32, the California Global Warming Solutions Act, was signed in 2006
and formally recognized California as a substantial source of GHG emissions contributing
to global warming. It further stated that global warming is a “serious threat” to the
“economic well being, public health, natural resources, and the environment of California,”
and identified impacts to air quality, water supply, sea level rise (flooding), fire hazards,
and an increase in health-related problems as environmental consequences of global
warming.
AB 32 designated the California Air Resources Board (CARB) as the lead agency for
implementing GHG targets. As such, CARB adopted the “California Greenhouse Gas
Emissions Inventory” (December 2007) and its “Scoping Plan” (2008) which outlines how
GHG reductions to 1990 levels would be achieved. The 2008 Scoping Plan identifies the
2002-2004 “existing” average GHG emissions as 469 million metric tons of CO2
equivalent (MMTCO2e). The 2020 “business as usual” GHG emissions were projected at
596 MMTCO2e, and the 1990 GHG emissions were projected at 433 MMTCO2e.
CARB approved the First Update to the Scoping Plan (Update) in 2014. The Update
identifies the next steps for California’s climate change strategy. The Update shows how
GHG Guidance Memo Page 2
California continues on its path to meet the near-term 2020 GHG limit, but also sets a path
towards long-term, deep GHG emissions reductions.
Senate Bill (SB) 32 was signed in 2016, and codified a 2030 GHG emissions reduction
target of 40 percent below 1990 levels. With SB 32, the State passed companion legislation
AB 197, which provided additional direction for developing the Scoping Plan. The Second
Update to Scoping Plan addressing the SB 32 targets was adopted on December 14, 2017.
Senate Bill (SB) 375, signed in September 2008, aligns regional transportation planning
efforts, regional GHG reduction targets, and land use and housing allocation. SB 375
requires Metropolitan Planning Organizations (MPOs) to adopt a sustainable communities’
strategy (SCS) or alternative planning strategy that will prescribe land use allocation in that
MPOs regional transportation plan. CARB, in consultation with MPOs, will provide each
affected region with reduction targets for GHGs emitted by passenger cars and light trucks
in the region for the years 2020 and 2035. The SCS contains land use, housing and
transportation strategies that allow regions to meet their GHG emissions reductions targets.
The Southern California Association of Governments (SCAG) is responsible for the
adoption of the SCS for the region and it is a required element of the Regional
Transportation Plan, which is adopted every four years.
In August 2010, CARB released the proposed GHG reduction targets for the MPOs to be
adopted in September 2010. The proposed reduction targets for the SCAG region were 8
percent by year 2020 and 13 percent by year 2035. In September 2010 and February 2011,
the 8 percent and the 13 percent targets were adopted, respectively.
On April 4, 2012, SCAG’s Regional Council adopted the 2012-2035 Regional
Transportation Plan/Sustainable Communities Strategy: Towards a Sustainable Future.
(2012 RTP/SCS). On April 7, 2016, SCAG’s Regional Council adopted an update to the
2012 RTP/SCS, the 2016-2040 Regional Transportation Plan/Sustainable Communities
Strategy (2016 RTP/SCS). Through proactive land use planning and improvements to the
transportation network, implementation of the 2016 RTP/SCS will result in an 8 percent
reduction in greenhouse gas emissions per capita by 2020, an 18 percent reduction by 2035,
and a 21 percent reduction by 2040 when compared with 2005 levels.
State CEQA Guidelines Updates
Senate Bill (SB) 97, signed in 2007, added Section 21083.05 to the Public Resources Code
(PRC) and directed the California Office of Planning and Research (OPR) to draft State
CEQA Guidelines (CEQA Guidelines) for GHG emissions analysis and mitigation by July
1, 2009 (to be adopted by the California Resources Agency by January 1, 2010).
The California Resources Agency adopted State CEQA Guidelines that address GHG
emissions on December 30, 2009. The guidelines became effective on March 18, 2010. In
GHG Guidance Memo Page 3
summary, the State CEQA Guidelines provide the following guidance regarding
greenhouse gas emissions analysis in CEQA documents.
CEQA documents must make a good faith effort to describe, calculate or estimate
GHGs from a project and determine whether that contribution is “cumulatively
considerable”.
A GHG analysis may be quantitative, qualitative or rely on performance based
standards. Which methodology or model to use for a quantitative analysis is left to
the discretion of the lead agency.
In determining whether a GHG impact is significant, the GHG analysis should
consider the following:
o A project’s GHG emissions compared to the existing environment;
o Whether a project exceeds a “threshold of significance”; and
o Whether a project complies with regulations adopted to implement a
statewide, regional or local plan to reduce GHG emissions.
The GHG analysis must discuss a project’s consistency with general plans, specific
plans or regional plans (including plans to reduce greenhouse gas emissions);
In adopting thresholds, the CEQA Guidelines allow lead agencies to consider
thresholds previously adopted or recommended by other agencies, or experts,
provided there is substantial evidence to support the threshold.
The CEQA Guidelines list options for mitigating impacts, including:
o Measures incorporated into an existing plan, program, ordinance or
regulation to reduce GHGs;
o Project features that reduce GHGs;
o Offsite measures including offsets;
o Measures that sequester GHGs.
Appendix G of the CEQA Guidelines (the Initial Study checklist) was amended to
add “Greenhouse Gas Emissions” as a separate environmental issue area with two
new checklist questions. Appendix F (Energy Conservation) of the CEQA
Guidelines was also amended.
In 2018, the California Natural Resources Agency finalized amendments to the State
CEQA Guidelines, including changes to CEQA Guidelines Section 15064.4, which
addresses the analysis of GHG emissions. The amendments became effective on December
28, 2018. The revision of CEQA Guidelines Section 15064.4 clarified several points,
including the following:
Lead agencies must analyze the greenhouse gas emissions of proposed projects.
The focus of the lead agency’s analysis should be on the project’s effect on climate
change.
GHG Guidance Memo Page 4
A project’s incremental contribution may be cumulatively considerable even if it
appears relatively small compared to statewide, national or global emissions.
Lead agencies should consider a timeframe for the analysis that is appropriate for
the project.
A lead agency’s analysis must reasonably reflect evolving scientific knowledge and
state regulatory schemes.
Lead agencies may rely on plans prepared pursuant to CEQA Guidelines Section
15183.5 in evaluating a project’s GHG emissions.
In determining the significance of a project’s impacts, the lead agency may consider
a project’s consistency with the State’s long-term climate goals or strategies,
provided that substantial evidence supports the agency’s analysis of how those
goals or strategies address the project’s incremental contribution to climate change
and its conclusion that the project’s incremental contribution is consistent with
those plans, goals, or strategies.
The lead agency has discretion to select the model or methodology it considers most
appropriate to enable decision makers to intelligently take into account the project’s
incremental contribution to climate change.
LOCAL GUIDANCE
Based on the above described regulatory framework, GHG analysis is required to be
included in CEQA documents for all non-exempt projects for which the City of Orange is
the lead agency.
Who should prepare a GHG analysis?
In the City of Orange, Project Applicants are allowed to prepare or directly retain
consultants to prepare environmental studies and CEQA documents, per the City’s Local
CEQA Guidelines. GHG analysis should principally be prepared by a qualified technical
expert in the air quality modeling and analysis field. As the lead agency, Planning Division
staff are responsible for ensuring that the analysis reflects the City’s independent judgment
and analysis of the issue.
What are the required components of a GHG analysis?
The required content of a GHG analysis should generally follow the guidance provided in
the CEQA Guidelines. The City’s Initial Study checklist template has been revised to
reflect the changes made to Appendix G of the CEQA Guidelines. The intent of this memo
is to supplement the guidance provided by the State, where needed.
Regulatory Background
The greenhouse gas emissions analysis should briefly review State law and the regulat ory
framework applicable to GHGs.
GHG Guidance Memo Page 5
Environmental Setting
The analysis should define “greenhouse gases” and provide a description of the following
seven GHGs and their major sources: carbon dioxide (CO2), methane (CH4), nitrous oxide
(N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), sulfur hexafluoride (SF6),
and nitrogen trifluoride (NF3). The cumulative effects of GHGs should also be discussed.
Quantify Greenhouse Gas Emissions Generated by the Project
The CEQA Guidelines state that a lead agency must make a good faith effort to describe,
calculate or estimate GHGs from a project and determine whether that contribution is
“cumulatively considerable,” but it defers to the lead agency as to the methodology or
model used to estimate project GHGs.
The City of Orange is located within the South Coast Air Basin, overseen by the South
Coast Air Quality Management District (SCAQMD). The California Emissions Estimator
Model (CalEEMod) is a statewide land use emissions computer model designed to provide
a uniform platform to quantify potential criteria pollutant and GHG emissions associated
with both construction and operational from a variety of land use models. SCAQMD staff
recommends all projects evaluate emissions with CalEEMod if software is used for the
analysis. Therefore, as a matter of policy, most CEQA documents for non-exempt projects
in the City will be required to contain a quantitative analysis of GHGs using CalEEMod
(or another approved model accepted by SCAQMD, subject to City approval).
In some cases and at the discretion of the Community Development Director or designee,
a qualitative analysis may be accepted for very small projects which clearly could not
generate significant GHG emissions. For example, a qualitative GHG analysis may be
accepted for projects that are consistent with the CEQA categorical exemption classes, but
for some reason unrelated to project size, density, or other factors affecting GHG
emissions, the project is not exempt from CEQA. As another example, a qualitative
analysis may be accepted for projects that are so small that they do not trigger the need for
a traffic study per the City’s Traffic Impact Analysis Guidelines.
The quantitative GHG analysis must identify the type and source of GHG’s generated by
the project and should follow the methodology recommended in Chapters 3 and 4 of the
SCAQMD’s Interim Thresholds document. Generally, GHG estimates should include
emissions from indirect sources, and direct sources including construction emissions
(amortized over a 30-year period) and operational emissions. Operational emissions will
typically include mobile source emissions and building emissions (including emissions
from building energy usage, energy usage due to water consumption, etc.). Emissions
should be expressed in metric tons of CO2 equivalent (MTCO2e) per year.
GHG Guidance Memo Page 6
Determine Significance
The CEQA Guidelines include “Greenhouse Gas Emissions” as an environmental issue
area in the Initial Study checklist and include the following two checklist questions:
“Would the project:
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?”
The CEQA Guidelines also suggest that in determining significance a lead agency may
consider a project’s GHG emissions compared to the existing environment, whether a
project exceeds a “threshold of significance” and whether a project complies with
regulations adopted to implement a statewide, regional, or local plan aimed at reducing
GHG emissions. However, the CEQA Guidelines are silent on an appropriate quantitative
threshold for GHGs and initial efforts by CARB to establish a statewide threshold are no
longer being pursued. Therefore, the following approach is recommended to determine
significance in CEQA documents for which the City is the lead agency.
The GHG analysis should identify the project’s GHG contribution compared to existing
conditions (citing the adopted State inventory, the GHG estimates contained in the City’s
2010 General Plan EIR, and/or other regional or local inventory, if available). A project’s
consistency with the goals, policies and implementation programs of the City’s 2010
General Plan related to GHGs must also be discussed. In particular, the analysis should
review Table NR-1 in the Natural Resources Element of the General Plan and discuss the
project’s consistency with identified climate change-related policies. In addition, the
analysis should discuss CARB’s 2017 Scoping Plan or future updates to the Scoping Plan,
as well as the most recent draft of the SCAG Regional Transportation Plan/Sustainable
Communities Strategies (RTP/SCS), and identify the extent to which the project complies
with emissions reduction measures and policies applicable to the project (if any).
The City has not adopted a quantitative threshold of significance for GHG. Nonetheless,
as a CEQA lead agency, the City desires to have a consistent GHG analysis methodology
in its CEQA documents, and to this end, offers the following threshold guidance.
In 2008, the SCAQMD formed a working group to identify GHG emissions thresholds for
land use projects that could be used by local lead agencies in the air basin. The working
group developed several different options that are contained in the “Interim Greenhouse
Gas Emissions Significance Thresholds” that could be applied by lead agencies. The
working group has not provided additional guidance since release of the interim guidance
in 2008. The SCAQMD Board has not approved the thresholds; however, the Guidance
Document provides substantial evidence supporting the approaches to significance of GHG
GHG Guidance Memo Page 7
emissions that can be considered by the lead agency in adopting its own threshold. The
current interim thresholds consist of the following tiered approach:
Tier 1 consists of evaluating whether or not the project qualifies for any applicable
exemption under CEQA.
Tier 2 consists of determining whether the project is consistent with a GHG
reduction plan. If a project is consistent with a qualifying local GHG reduction plan,
it does not have significant GHG emissions.
Tier 3 consists of screening values, which the lead agency can choose, but must be
consistent with all projects within its jurisdiction. A project’s construction
emissions are averaged over 30 years and are added to the project’s operational
emissions. If a project’s emissions are below one of the following screening
thresholds, then the project is less than significant:
o All land use types: 3,000 metric tons (MT) carbon dioxide equivalents
(CO2e) per year
o Based on land use type: residential: 3,500 MTCO2e per year; commercial:
1,400 MTCO2e; or mixed use: 3,000 MTCO2e
Tier 4 has the following options:
o Option 1: Reduce business as usual (BAU) emissions by a certain
percentage; this percentage is currently undefined.
o Option 2: Early implementation of applicable Assembly Bill (AB) 32
Scoping Plan measures
o Option 3: 2020 target: 3.0 MTCO2e/SP/year for projects and 4.1
MTCO2e/SP/year for plans
Tier 5 involves mitigation offsets to achieve target significance threshold.
The SCAQMD’s draft thresholds uses the Executive Order S-3-05 Year 2050 goal as the
basis for the Tier 3 screening level. Achieving the Executive Order’s objective would
contribute to worldwide effort to cap CO2 concentrations at 450 parts per million, thus
stabilizing global climate.
The City will accept GHG analyses that use the “Tier 3” quantitative thresholds
recommended in the SCAQMD’s Interim Thresholds document for commercial,
residential, mixed use, and industrial development projects, as follows.
o Industrial Projects - 10,000 MTCO2e per year.
o Residential, Commercial, and Mixed Use Projects (including industrial parks,
warehouses, etc.) - 3,000 MTCO2e per year. (This is generally equivalent to an
approximately 70 unit single family residential development.)
Projects that would be considered “Industrial Projects” would be facilities that use
stationary sources of GHG emissions requiring a permit from the SCAQMD. Examples
include: cement plants, landfills, wastewater treatment plants, and industrial boilers.
GHG Guidance Memo Page 8
The City will accept documents that use this threshold because it has been recommended
by SCAQMD and SCAQMD is the expert agency and regional authority for air quality in
the South Coast Air Basin. Further, the Interim Thresholds document provides substantial
evidence that the thresholds are consistent with the policy goals and GHG reduction targets
set by the State. Specifically, the thresholds were set at levels that capture 90 percent of the
GHG emissions from the above described uses, consistent with the Executive Order S-3-
05 target of reducing GHGs to 80 percent below 1990 levels by 2050. Further, the threshold
is a reasonable threshold because it will require medium and large size projects to reduce
project GHGs, while allowing smaller projects, which are generally infill development
projects and are not the focus of future GHG reductions, to proceed.
It should be noted that due to the global scale of the effects of GHG emissions, the
thresholds above function as both the project-level threshold and the cumulative impact
threshold of significance for GHG analysis.
If a project generates GHG emissions below the threshold, it is acceptable to conclude that
the project’s GHG contribution is not “cumulatively considerable” and is therefore “less
than significant” under CEQA. If a project generates GHG emissions above the threshold,
the analysis must identify mitigation measures to reduce GHG emissions.
Identify Mitigation Measures
The CEQA Guidelines suggest mitigating GHG impacts through measures incorporated
into an existing GHG reduction plan; project design features that reduce GHGs; offsite
mitigation measures including offsets; and measures that sequester GHGs.
As stated above, at the time of the writing of this memo, the City does not have an adopted
Climate Action Plan and no other regional GHG reduction plans have yet been adopted.
Further, although the CARB Scoping Plan is an applicable Statewide GHG reduction plan,
implementation of its GHG reduction measures may not specifically apply to or mitigate a
local project’s GHG emissions, as required by CEQA. In addition, the CARB Cap-and-
Trade Program is only applicable to electricity generators and large industrial facilities
emitting 25,000 MTCO2e or more annually. Therefore, at this time, it is largely not feasible
to mitigate GHG impacts under CEQA by demonstrating compliance with an existing GHG
reduction plan or through offsets. As such, if a project generates GHG’s above the
quantitative thresholds identified above, the analysis should focus on project design
features or mitigation measures that reduce or sequester GHGs, such that project emissions
are reduced to below the SCAQMD threshold. Feasible offsite GHG reduction projects
could also be considered as a last option.
Determine Significance After Mitigation
The GHG reductions resulting from project design features and mitigation measures should
be estimated using best available information, and the analysis should show the project
GHG emissions before- and after-mitigation. If it can be demonstrated that project design
GHG Guidance Memo Page 9
features and mitigation measures reduce the project’s GHG emissions to below the
SCAQMD threshold, it is acceptable to conclude that the project’s GHG contribution is
not “cumulatively considerable” and the GHG impact is either “less than significant” or
“less than significant with mitigation incorporated” under CEQA.
If the project continues to generate emissions above the threshold after all feasible
mitigation measures have been incorporated into the project, the analysis should conclude
that the project contributes GHG emissions that may be “cumulatively considerable” and
the impact is significant and unavoidable. In this case, an Environmental Impact Report,
Findings, and a Statement of Overriding Considerations would be required in accordance
with CEQA.
ADDITIONAL INFORMATION
GHG technical guidance and regulatory mandates are constantly evolving. The guidance
provided in this memo is based on information available at the time. If plans, strategies or
other specific thresholds, such as performance based standards, are developed or adopted
by the State or SCAQMD in the future, the City will update its guidance and/or defer to
those thresholds at that time. In all cases, the City will use its independent judgment in
determining whether the GHG analysis submitted by Project Applicants or prepared for
City project is acceptable for CEQA purposes. If you have any questions regarding this
memo, please contact Ashley Brodkin at abrodkin@cityoforange.org or (714) 744-7238.
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sb 743 implementation study
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City of Orange SB 743 Implementation Threshold Selection
4.22.2020
Page | 1
The City of Orange has set its threshold of significance for the evaluation of impacts related to Vehicle
Miles Traveled (VMT) as:
A project would result in a significant project-generated1 VMT impact if either of the following
conditions are satisfied:
1. The baseline project-generated VMT per service population exceeds the City of Orange
General Plan Buildout VMT per service population, or
2. The cumulative project-generated VMT per service population exceeds the City of Orange
General Plan Buildout VMT per service population
Background Information
This threshold was set based on the requirements of Senate Bill (SB) 743, which changed the way
transportation impacts related to development projects are identified from Level-of-Service (LOS) to
VMT.
In anticipation of the change to VMT, seven North Orange County Cities (Fullerton, La Habra, Brea,
Buena Park, Orange, Placentia, and Yorba Linda) formed a collaborative and completed the North
Orange County Cities (NOCC) SB 743 Implementation Study to assist with answering important
implementation questions about the methodology, thresholds, and mitigation approaches for VMT
impact analysis. The NOCC study included the following main components.
Thresholds Evaluation Memorandum – Potential thresholds north county cities could consider
when establishing thresholds of significance for VMT assessment
Sample Projects Memorandum – Types of VMT that could be considered for impact assessment
and how project assessment could be performed
Tools Evaluation Memorandum – Types of tools that could be used to estimate VMT and the
pros/cons associated with each tool
Mitigation Memorandum – Types of mitigation that can be considered for VMT mitigation
VMT Screening and Mitigation Testing Tool – A spreadsheet tool that can be used for VMT
screening.
OPR Threshold Discussion
All north county cities utilized the information produced through the Implementation Study to adopt
their own methodology and significance thresholds for use in CEQA compliance. As noted in CEQA
Guidelines Section 15064.7(b) below, lead agencies are encouraged to formally adopt their significance
thresholds, and this is key part of the SB 743 implementation process.
(b) Each public agency is encouraged to develop and publish thresholds of significance that the agency uses in the
determination of the significance of environmental effects. Thresholds of significance to be adopted for general use as
1 VMT will be evaluated in two ways: the project -generated VMT and the project effect on VMT. Project-generated
VMT is the VMT produced by the project. It is calculated by multiplying the trip generation of the proposed project
by the average trip length. Project effect on VMT (also known as “cumulative impacts”) is the change in VMT in the
region due to the project. It is calculated by summing of all weekday VMT on a roadway network within the City.
This memorandum discusses the impact threshold for project -generated VMT. The threshold set by the City of
Orange for project effect on VMT is consistent with the OPR Technical advisory.
City of Orange SB 743 Implementation Threshold Selection
4.22.2020
Page | 2
part of the lead agency’s environmental review process must be adopted by ordinance, resolution, rule, or regulation,
and developed through a public review process and be supported by substantial evidence. Lead agencies may also use
thresholds on a case-by-case basis as provided in Section 15064(b)(2).
The State of California Office of Planning and Research (OPR) has developed a potential threshold for
consideration by local agencies that is almost exclusively based on GHG and air pollution reduction goals
from the State’s perspective. While this is one of the SB 743 legislative intent objectives, a less clear
connection is made to the other legislative intent objectives to encourage infill development and promote
active transportation. Since greenhouse gas (GHG) impacts are already addressed in other CEQA sections,
utilization of a GHG reduction target as a transportation metric does not address how VMT can be used
as an efficiency metric to inform the efficiency of the land use and transportation network (which is a key
consideration and value for the City). Three additional concerns arise from reliance on the OPR
recommendations:
The OPR recommended threshold does not establish a level of VMT reduction that would result
in the state meeting its air quality and GHG goals according to the California Air Resources Board
(ARB) 2017 Scoping Plan-Identified VMT Reductions and Relationship to State Climate Goals
(2019). The ARB Scoping Plan utilized a Department of Finance projection that has since been
updated to decrease the state population by approximately 10%, indicating that the OPR
recommendation and scoping plan thresholds may over-estimate the VMT reduction due to a
forecast in population which is now outdated.
The OPR recommended thresholds do not illustrate a connection to the other SB 743 objectives
related to statewide goals to promote public health through active transportation, infill
development, multimodal transportation networks, and a diversity of land uses. Recommending
a reduction below baseline levels is consistent with these objectives, but the numerical value has
not been tied to specific statewide values for each objective or goal.
State expectations for air quality and GHG may not align with local/lead agency expectations.
Using state expectations for a local lead agency threshold may create inconsistencies with local
city or county general plans.
City of Orange Considerations
Given these concerns, City of Orange staff considered the following information when choosing an
alternative threshold:
The other cities in the NOCC shared concerns about using the statewide threshold and expressed
a desire for some sub-regional consistency when setting a reasonable threshold.
The collaborative cities expressed an interest in considering their General Plans as a basis for their
VMT thresholds as their General Plans were adopted through a public process, account for t he
local context of their cities, and reflect the goals and values of their communities.
City of Orange staff reviewed the Orange General Plan to determine if it was consistent with the
legislative intent of SB 743. The General Plan advocates primarily compact “infill” future
development, focusing on introducing urban-scale mixed-use projects located at locations near
transportation corridors and transit, and creating additional retail and employment opportunities
City of Orange SB 743 Implementation Threshold Selection
4.22.2020
Page | 3
within the City that increase the range of goods and services available to residents and improve
the community’s job-housing balance. The following General Plan goals and policies support the
three goals of SB 743:
o Promotion of Infill Development
Land Use Element, Policy 2.1: Encourage development of mixed-use projects to
revitalize older commercial areas throughout the City and industrial areas
surrounding the historic Santa De Depot.
Circulation & Mobility Element, Policy 2.4: Coordinate land use planning with
anticipated future development of roadways and other transportation facility
improvements as well as the expansion of commuter rail and bus service.
Circulation & Mobility Element, Policy 5.2: Plan for and design parking facilities
throughout the City that are adequate to meet demand, but also consider land
use parking efficiencies, and the surrounding natural and built environment.
Growth Management Element, Policy 2.4: Explore infill development or mixed-
use opportunities wherever possible as developable space becomes more
limited.
Housing Element, Policy 7: Facilitate Infill Construction
o Promotion of Active Transportation
Land Use Element, Goal 2.0: Create successful, high quality mixed-use districts
consisting of a mix of residential, commercial, office, civic, and common open
space land uses, supported by alternative modes of transportation.
Land Use Element, Policy 2.6: Encourage linkage in and around mixed-use areas
using a multi-modal circulation network, particularly transit, pedestrian
sidewalks, paths and paseos, bicycle and trail systems.
Land Use Element, Policy 5.9: Promote attractive and safe pedestrian access
between the Santa Fe Depot and the Plaza.
Land Use Element, Policy 6.3: Establish and maintain greenways, and pedestrian
and bicycle connections that complement the residential, commercial and open
space areas they connect.
Land Use Element, Policy 6.6: Enhance the walkability of both new and current
development.
Circulation & Mobility Element, Policy 1.1: Plan, build, and maintain an
integrated, hierarchical, and multi-modal system of roadways, pedestrian
walkways, and bicycle paths throughout the City.
Circulation & Mobility Element, Policy 1.4: Prohibit on-street parking where
possible to reduce bicycle/automobile conflicts in appropriate target areas as
recommended by the Bikeways Master Plan.
Circulation & Mobility Element, Policy 2.6: Encourage the use of regional rail,
transit, bicycling, carpools, and vanpools for work trips to relieve traffic
congestions.
City of Orange SB 743 Implementation Threshold Selection
4.22.2020
Page | 4
Circulation & Mobility Element, Goal 3.0: Connect centers within the City to each
other and to the region through efficient and accessible public transportation.
Circulation & Mobility Element, Goal: 4.0: Provide efficient and accessible modes
of pedestrian, bicycle, and equestrian transportation and improved facilities and
amenities.
Growth Management Element, Policy 1.7: Promote the expansion and
development of alternative methods of transportation.
Growth Management Element, Policy 1.9: Ensure that new developments
incorporate non-motorized and alternative transit amenities such as bike racks,
bus benches and shelters, and pedestrian connections.
Growth Management Element, Policy 2.5: Continue to work with OCTA and other
regional transit agencies to provide such amenities as bus shelters, shade, and
other special streetscape treatments at transit stations that encourage the use of
regional bus and train services.
Natural Resources Element, Policy 2.2: Support alternative transportation modes,
alternative technologies, and bicycle- and pedestrian-friendly neighborhoods to
reduce emissions related to vehicular travel.
Natural Resources Element, Policy 2.8: Encourage development that incorporates
pedestrian- and transit-oriented design and landscape elements.
o Reducing GHGs
The General Plan includes a broad spectrum of policies related to climate change.
These policies have been integrated throughout the relevant General Plan
elements and are detailed in Table NR-1 in the Natural Resources Element.
Data produced by extracting VMT from the Orange County Transportation Analysis Model showed
that the City of Orange average VMT per service population under General Plan conditions
represented a reduction in VMT per service population as compared with existing conditions.
The City wanted to balance the need to reduce GHG and VMT while meeting the goals of their
community. Using the City’s General Plan to set their VMT threshold was determined by City Staff
to be the most reasonable option to achieve this.
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City of Orange Limits
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Figu re 1
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C:\Users\smusharrat\Downloads\OC19-0661_NOCC_Orange_OD_City.mxdFigure 2
OCTAM ModelDaily Total OD VMT per Service Population for Base Year 2012Comparison to City Average
< -15% below City of Orange Average *
0 to -15% below City of Orange Average
Higher than City of Orange Average
Transit Priority Area
City of Orange Limits
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* City Average calculatedusing OCTAM Model.
1 | P a g e
TECHNICAL MEMORANDUM
Date: 10.23.19
To: City of Orange, City of Fullerton, City of La Habra, City of Placentia, City of Brea, City of Buena
Park, and City of Yorba Linda
From: Jason Pack, PE and Delia Votsch, PE
Subject: North Orange County Collaborative (NOCC) SB 743 Implementation Thresholds Assessment
OC19-0661
This technical memorandum summarizes the consultant team assessment of potential VMT thresholds for
land use projects and land use plans to comply with SB 743. For transportation projects, lead agencies
have the discretion to select their own metrics and thresholds and no change to current practice is
required. Hence, the remainder of this memo will focus on land use thresholds and is organized into four
sections.
• Section 1 - Background on CEQA Thresholds
• Section 2 - OPR VMT Threshold Recommendations
• Section 3 - Recommendations for North Orange County Cities
Section 1 – Background on CEQA Thresholds
Establishing thresholds requires complying with the new statutes added by SB 743 and traditional
guidance contained in CEQA Guidelines Section 15064.7 and new language being proposed as part of the
Proposed Updates to the CEQA Guidelines, December 2018, California Governor’s Office of Planning and
Research (see excerpts below).
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Source: http://resources.ca.gov/ceqa/docs/2018_CEQA_FINAL_TEXT_122818.pdf
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Source: http://resources.ca.gov/ceqa/docs/2018_CEQA_FINAL_TEXT_122818.pdf
In summary, this threshold setting guidance emphasizes the need to use substantial evidence to help
determine when a project will cause an unacceptable environmental condition or outcome. For SB 743,
the specific outcome of focus is the change a project will cause in vehicle miles of travel (VMT). Since
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VMT is already used to determine air quality, energy, and greenhouse gas (GHG) impacts as part of CEQA
compliance, the challenge for lead agencies is to answer the question, “What type or amount of change
in VMT constitutes a significant impact solely for transportation purposes ?”
Section 2 - OPR VMT Threshold Recommendations
SB 743 includes the following two legislative intent statements, which were used to help guide OPR’s VMT
threshold decisions.
1) Ensure that the environmental impacts of traffic, such as noise, air pollution, and safety concerns,
continue to be properly addressed and mitigated through the California Environmental Quality Act.
2) More appropriately balance the needs of congestion management with statewide goals related to infill
development, promotion of public health through active transportation, and reduction of greenhouse
gas emissions.
The threshold recommendations are found in the CEQA Guidelines and the Technical Advisory. Specific
excerpts and threshold highlights are provided below.
CEQA Guidelines Section 15064.3
(b) Criteria for Analyzing Transportation Impacts.
(1) Land Use Projects. Vehicle miles traveled exceeding an applicable threshold of significance may
indicate a significant impact. Generally, projects within one-half mile of either an existing major
transit stop or a stop along an existing high quality transit corridor should be presumed to cause a
less than significant transportation impact. Projects that decrease vehicle miles traveled in the
project area compared to existing conditions should be considered to have a less than significant
transportation impact.
(2) Transportation Projects. Transportation projects that reduce, or have no impact on, vehicle miles
traveled should be presumed to cause a less than significant transportation impact . For roadway
capacity projects, agencies have discretion to determine the appropriate measure of transportation
impact consistent with CEQA and other applicable requirements. To the extent that such impacts
have already been adequately addressed at a programmatic level, such as in a regional
transportation plan EIR, a lead agency may tier from that analysis as provided in Section 15152.
Technical Advisory on Evaluating Transportation Impacts in CEQA (page 10)
Based on OPR’s extensive review of the applicable research, and in light of an assessment by the
California Air Resources Board quantifying the need for VMT reduction in order to meet the State’s
long-term climate goals, OPR recommends that a per resident or per employee VMT that is
fifteen percent below that of existing development may be a reasonable threshold .
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Technical Advisory on Evaluating Transportation Impacts in CEQA (page 18)
As with projects, agencies should analyze VMT outcomes of land use plans across the full area over
which the plan may substantively affect travel patterns, including beyond the boundary of the plan
or jurisdiction’s geography. And as with projects, VMT should be counted in full rather than split
between origin and destination. (Emissions inventories have sometimes spit cross -boundary trips in
order to sum to a regional total, but CEQA requires accounting for the full impact without
truncation or discounting). Analysis of specific plans may employ the same thresholds described
above for projects. A general plan, area plan, or community plan may have a significant impact on
transportation if proposed new residential, office, or retail land uses would in aggreg ate exceed the
respective thresholds recommended above.
Technical Advisory on Evaluating Transportation Impacts in CEQA – Rural Projects Outside of
MPOs (page 19)
In rural areas of non-MPO counties (i.e., areas not near established or incorporated cities or towns),
fewer options may be available for reducing VMT, and significance thresholds may be best
determined on a case-by-case basis. Note, however, that clustered small towns and small town main
streets may have substantial VMT benefits compared to isolated rural development, similar to the
transit oriented development described above.
These (and the other) threshold recommendations in the Technical Advisory rely on the following evidence
associated with the state’s GHG reduction goals and targets in combination with environmental case law.
• Assembly Bill 32 (2006) requires statewide greenhouse gas reductions to 1990 levels by 2020 and
continued reductions beyond 2020.
• Senate Bill 32 (2016) requires at least a 40 percent reduction in greenhouse gas e missions by
2030.
• Pursuant to Senate Bill 375 (2008), the California Air Resources Board establishes greenhouse gas
reduction targets for metropolitan planning organizations (MPOs) to achieve based on land use
patterns and transportation systems specified in Regional Transportation Plans and Sustainable
Community Strategies. Current targets for the largest metropolitan planning organizations range
from 13% to 16% reductions by 2035.
• Executive Order B-30-15 (2015) sets a GHG emissions reduction target of 40 percent below 1990
levels by 2030.
• Executive Order S-3-05 (2005) sets a GHG emissions reduction target of 80 percent below 1990
levels by 2050.
• Executive Order B-16-12 (2012) specifies a GHG emissions reduction target of 80 percent below
1990 levels by 2050 specifically for transportation.
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• Senate Bill 391 requires the California Transportation Plan to support 80 percent reduction in
GHGs below 1990 levels by 2050.
• The California Air Resources Board Mobile Source Strategy (2016) describes California’s strategy
for containing air pollutant emissions from vehicles and quantifies VMT growth compatible with
achieving state targets.
• The California Air Resources Board’s 2017 Climate Change Scoping Plan Update: The Strategy for
Achieving California’s 2030 Greenhouse Gas Target describes California’s strategy for containing
greenhouse gas emissions from vehicles and quantifies VMT growth compatible with achieving
state targets.
• The Caltrans Strategic Management Plan (2015) calls for a 15 percent reduction in VMT per
resident compared to 2010 levels, by 2020.
• California Air Resources Board 2017 Scoping Plan-Identified VMT Reductions and Relationship to
State Climate Goals (2019) identifies a 16.8 percent reduction in automobile VMT per resident
below existing (2018) levels to achieve statewide GHG reduction goals.
Lead agencies should note that the OPR recommended VMT thresholds are almost exclusively based on
GHG and air pollution reduction goals. While this is one of the SB 743 legislative intent objectives, a less
clear connection is made to the other legislative intent objectives to encourage infill development and
promote active transportation. And, as noted above, GHG impacts are already addressed in another CEQA
section.
Another important distinction within the Technical Advisory is how projects within different land use
contexts are treated. The general expectation that a 15 percent reduction below that of existing
development may be reasonable is proposed for projects within metropolitan planning organizations
(MPOs). For rural areas outside MPOs, the Technical Advisory recognizes that VMT mitigation options are
limited so thresholds may need to be set on a case-by-case basis.
The recognition that land use context matters when it comes to the potential VMT mitigation options and
effectiveness is important. The MPO boundary distinction is not relevant to the feasibility of VMT
mitigation. A rural or suburban area inside or outside an MPO boundary will have very similar limitations
when it comes to the feasibility of VMT reduction options. As such, land use context and not MPO status
should be the defining criteria for setting threshold expectations. The land use context is also relevant to
the potential range of effectiveness associated with VMT reduction strategies. The Technical Advisory
relies on the Quantifying Greenhouse Gas Mitigation Measures, CAPCOA, 2010 resource document to help
justify the 15 percent reduction threshold stating, “…fifteen percent reduction in VMT are achievable at
the project level in a variety of place types…”. A more accurate reading of the CAPCOA document is that a
fifteen percent is the maximum reduction when combining multiple mitigation strategies for the
suburban center place type. For suburban place types, 10% is the maximum and requires a project to
contain a diverse land use mix, workforce housing, and project-specific transit. It is also important to note
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that the maximum percent reductions were not based on data or research comparing the actual
performance of VMT reduction strategies in these place types. Instead, the percentages were derived
from a limited comparison of aggregate citywide VMT performance for Sebastopol, San Ra fael, and San
Mateo where VMT performance ranged from 0 to 17 percent below the statewide VMT/resident average
based on data collected prior to 2002. Little to evidence exists about the long-term performance of
similar TDM strategies in different land use contexts. As such, VMT reductions from TDM strategies
cannot be guaranteed in most cases.
California VMT Trends
Source: 2018 Progress Repot California’s Sustainable Communities and Climate Protection Act, California Air Reserves
Board, 2018
Section 3 - Recommendations for North Orange County Cities
How should lead agencies approach VMT threshold setting given their discretion? Since an impact under
CEQA begins with a change to the existing environment, a starting level for potential thresholds would the
baseline (i.e., existing condition) VMT, VMT per resident, VMT per employee, or VMT per service
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population. Since VMT will increase or fluctuate with population and employment growth, changes in
economic activity, and expansion of new vehicle travel choices (i.e., Uber, Lyft, Chariot, autonomous
vehicles, etc.), expressing VMT measurement in an efficiency metric form allows for more direct
comparisons to baseline conditions when it comes to land use projects, land use plans, and transportation
projects. Establishing a threshold such as baseline VMT per service population would be essentially
setting an expectation that future land uses perform similar to existing land uses. If this is the floor, then
expectations for VMT reduction can increase depending on a community’s values related to vehicle use
and its associated effects on mobility, economic activity, and environmental consequences. Working
towards the 15-percent reduction recommended in the Technical Advisory becomes more feasible as the
land use context becomes more urban with higher densities and high-quality transit systems. In central
cities, the 15-percent reduction can be surpassed because of the close proximity of land uses and the
multiple options for accessing destinations by walking, using bicycles or scooters, sharing vehicles, and
using transit.
While OPR has developed specific VMT impact thresholds for project -related impacts, current practice has
not sufficiently evolved where a clear line can be drawn between ‘acceptable ’ and ‘unacceptable’ levels of
VMT change for the sole purpose of determining a significant transportation impact especially when
considering land use context. Until SB 743, VMT changes were viewed through an environmental lens
that focused on the relationship to fuel consumption and emissions. For transportation purposes, VMT
has traditionally been used to evaluate whether land use or transportation decisions resulted in greater
dependency on vehicle travel. Trying to determine whether a portion of someone’s daily vehicle travel is
unacceptable or would constitute a significant transportation impact is generally not clear to lead
agencies.
Another consideration in threshold setting is how to address cumulative VMT impacts and whether
addressing them in the general plan EIR is advantageous for streamlining the review of subsequent land
use and transportation projects given CEQA relief available through SB 375 or CEQA Guidelines Section
15183. This section of the Guidelines relieves a project of additional environmental review if the
environmental impact was adequately addressed in the general plan EIR and the project is consistent with
the general plan (see below).
15183. PROJECTS CONSISTENT WITH A COMMUNITY PLAN OR ZONING
(a) CEQA mandates that projects which are consistent with the development density established by existing
zoning, community plan, or general plan policies for which an EIR was certified shall not require additional
environmental review, except as might be necessary to examine whether there are project-specific significant
effects which are peculiar to the project or its site. This streamlines the review of such projects and reduces
the need to prepare repetitive environmental studies.
The use of Section 15183 also addresses cumulative impacts as acknowledged in Section 15130(e).
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15130. DISCUSSION OF CUMULATIVE IMPACTS
(e) If a cumulative impact was adequately addressed in a prior EIR for a community plan, zoning
action, or general plan, and the project is consistent with that plan or action, then an EIR for
such a project should not further analyze that cumulative impact, as provided in Section
15183(j).
For cities in the North Orange County County region, addressing VMT impacts in general plan EIRs could
be useful in understanding how VMT reduction should be balanced against other community values when
it comes to setting new VMT impact thresholds for SB 743.
Given this information, lead agencies have at least five options for setting thresholds as outlined below.
Under any option, the lead agency must develop its own substantial evidence to support their preferred
threshold and should consider multiple perspectives. These perspectives include those from the
community in general as well as specific stakeholder perspectives from the development community and
environmental protection groups. A threshold that is too stringent could lead to a permanent significant
and unavoidable VMT impact finding increasing the cost of environmental review for developers.
Conversely, a threshold that does not result in any significant impacts could lead to missed opportunities
to reasonably reduce VMT and related environmental impacts. In either case, attracting the attention of
specific stakeholder groups can lead to CEQA challenges, which are often determined based on the
strength of substantial evidence supporting lead agency decisions.
OPTION 1 – Rely on the OPR Technical Advisory Thresholds
The first option is to simply rely on the threshold recommendations contained in the OPR Technical
Advisory. As noted above, the general expectation is that land use projects should be measured against a
15 percent reduction below that of existing baseline conditions. Specific VMT thresholds for residential,
office (work-related), and retail land uses are summarized below.
• Residential projects – A proposed project exceeding a level of 15 percent below existing
(baseline) VMT per resident may indicate a significant transportation impact. Existing VMT per
resident may be measured as regional VMT per resident or as city VMT per resident.
• Office projects – A proposed project exceeding a level of 15 percent below existing (baseline)
regional VMT per employee may indicate a significant transportation impact.
• Retail projects – A net increase in total VMT may indicate a significant transportation impact.
For land use plans (i.e., a general plan, area plan, or community plan), a significant impact would occur if
the respective thresholds above were exceeded in aggregate. This means that new population and
employment growth combined the planned transportation network would need to generate future VMT
per resident or VMT per worker that is less than 85 percent of the baseline value to be considered less
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than significant. Land use project and land use plans would also need to be consistent with the applicable
RTP/SCS.
A potential limitation of the OPR recommendations is that the substantial evidence used to justify the
thresholds is largely based on the state’s air quality and GHG goals. Three issues arise from this reliance.
• The OPR recommended threshold does not establish a level of VMT reduction that would result in
the state meeting it’s air quality and GHG goals according to the California Air Resources Board
2017 Scoping Plan-Identified VMT Reductions and Relationship to State Climate Goals (2019). This
may create confusion with air quality and GHG impact analysis in environmental documents,
which should already address the influence of VMT.
• The OPR recommended thresholds do not directly reflect expectations related to the other SB 743
objectives related to statewide goals to promote public health through active transportation, infill
development, multimodal networks, and a diversity of land uses. Recommending a reduction
below baseline levels is consistent with these objectives, but the numerical value has not been
tied to specific statewide values for each objective or goal.
• State expectations for air quality and GHG may not align with local/lead agency expectations.
Using state expectations for a local lead agency threshold may create inconsistencies with local
city or county general plans.
OPTION 2 – Set Thresholds Consistent with Lead Agency Air Quality, GHG Reduction, and Energy
Conservation Goals
This option sets a threshold consistent with a lead agency’s air quality, GHG reduction, and energy
conservation goals. This approach requires that local air quality and GHG reduction goals in general
plans, climate action plans, or GHG reduction plans comply with the legislation and associated plans
described above on pages 5 and 6. In general, most of the expectations set through legislation are
related to the state’s GHG reduction goals that were originally captured in EO S-3-05.
• 2000 levels by 2010
• 1990 levels by 2020
• 80 percent below 1990 levels by 2050
SB 32 expanded on these goals and added the expectation that the state should reach 40 percent below
1990 levels by 2030 followed by SB 391 that requires the California Transportation Plan to support 80
percent reduction in GHGs below 1990 levels by 2050 . With respect to the land use and transportation
sectors, SB 375 tasked ARB with setting specific GHG reduction goals through the RTP/SCSs prepared by
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MPOs. The ARB Scoping Plan and Mobile Source Strategy provide analysis related to how the state can
achieve the legislative and executive goals while the Caltrans Strategic Management Plan and Smart
Mobility Framework provide supportive guidance and metrics. An important recognition of the ARB
Scoping Plan and Mobile Source Strategy is that the initial SB 375 targets were not aggressive enough. The
state needs to achieve a reduction of 7 percent below projected 2030 VMT levels and 15 percent below
projected 2050 VMT levels associated with the first round of RTP/SCSs (see chart below).
Statewide On-Road GHG Emissions
Source: https://www.arb.ca.gov/cc/sb375/final_staff_proposal_sb375_target_update_october_2017.pdf (pg. 12)
Note that the baseline trend in the chart did not consider key disruptive trends such as transportation
network companies (TNCs) and autonomous vehicles (AVs) so it is possible that baseline VMT may be
higher. Further, the climate planning scenario did not consider the recently issued Governor’s Executive
Order (EO) B-55-18 that establishes the goal to achieve carbon neutrality no later than 2045.
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Consideration of these factors would increase the level of VMT reduction needed to achieve the State’s
climate goals.
The most recent ARB analysis contained in California Air Resources Board 2017 Scoping Plan-Identified
VMT Reductions and Relationship to State Climate Goals, January 2019 recommends project specific VMT
reduction thresholds of 16.8 percent reduction from baseline for light-duty vehicle VMT (i.e., passenger
cars and light trucks) or a 14.3 percent reduction for total VMT (i.e., all vehicles) – see excerpt below.
These reductions are dependent on MPO RTP/SCS targets being met, which may not be a reasonable
assumption for CEQA purposes given the information presented above from the 2018 Progress Report
California’s Sustainable Communities and Climate Protection Act . Also, ARB does not provide details about
whether the VMT values should be compared against jurisdictional or regional baseline values . Since the
analysis was based on statewide data, it may be reasonable to presume that the reduction expectation is a
fair-share expectation for all jurisdictions.
ARB Recommended Total VMT per Resident Threshold
Source: California Air Resources Board 2017 Scoping Plan-Identified VMT Reductions and Relationship to State Climate
Goals, January 2019
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One benefit of relying on ARB or other state agencies for a threshold recommendation is the CEQA
Guidelines provision in Section 15064.7(c) highlighted below.
ARB meets the criteria of being a public agency and having noted expertise in the areas of VMT and
emissions analysis. Further, the recommended threshold values above were developed in specific
consideration of SB 743 requirements.
One other agency threshold to consider is Caltrans. The Local Development-Intergovernmental Review
(LD-IGR) Branch at Caltrans (http://www.dot.ca.gov/hq/tpp/offices/ocp/igr_ceqa.html) has responsibility to
reduce potential adverse impacts of local development on the state transportation system. As part of its
responsibilities, each district branch performs reviews of CEQA environmental documents for local land
use projects. These reviews include providing expectations for transportation impact analysis such as
metrics and thresholds. Caltrans has published initial guidance related to SB 743 implementation.
• Local Development – Intergovernmental Review Program Interim Guidance, Caltrans, November 9,
2016 (http://www.dot.ca.gov/hq/tpp/documents/RevisedInterimGuidance11092016.pdf)
An important part of the Caltrans guidance are the following expectations for thresholds and impact
findings related to VMT.
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Source: http://www.dot.ca.gov/hq/tpp/documents/RevisedInterimGuidance11092016.pdf
When Caltrans reviews CEQA documents, they may function as a reviewing agency or a responsible
agency. In a responsible agency role, Caltrans has approval authority over some component of the
project such as an encroachment permit for access to the state highway system. Comments from Caltrans
should be adequately addressed, and special attention should be paid to those comments when Caltrans
serves as a responsible agency since an adequate response may be required to obtain their required
approval. The interim guidance above does not endorse the Technical Advisory recommendations for
thresholds; it only requires IGR staff to ‘comment’ on VMT analysis. However, Caltrans is working to
establish specific VMT thresholds per conversations with Alyssa Begley, SB 743 Program Implementation
Manager with Caltrans. Further, Caltrans may have already establish GHG thresholds that could also serve
as VMT thresholds.
In the draft Interim Guidance: Determining CEQA Significance For Greenhouse Gas Emissions for Projects on
the State Highway System, California Department of Transportation, 2018, Caltrans recommends that any
increase in GHG emissions would constitute a significant impact (see excerpt below).
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Interim Caltrans GHG Thresholds
Source: Interim Guidance: Determining CEQA Significance For Greenhouse Gas Emissions for Projects on the State
Highway System, California Department of Transportation, 2018
Since any increase in VMT would result in an increase in GHG emissions, lead agencies could rely on this
Caltrans threshold for VMT purposes using the same 15064.7(c) provision above. Using this threshold
would result in most land use projects and land use plans resulting in significant impacts but it would also
result in the maximum feasible mitigation for VMT.
OPTION 3 – Set Thresholds Consistent with RTP/SCS Future Year VMT Projections by Jurisdiction or
Sub-Region
VMT is a composite metric that is created as an output of combining a community’s long-term population
and growth projections with its long-term transportation network (i.e., the general plan). Other variables
are also in play related to travel behavior, but land use changes and transportation network modifications
are the items largely influenced or controlled by cities and counties. As such, every city within Orange
County already has a VMT growth budget. This is the amount of VMT that is forecast to be generated
from their general plans combined with other travel behavior inputs for the region as captured in the
RIVTAM or SCAG regional travel forecasting models as part of regional planning and the RTP/SCS. This
VMT growth has already been ‘approved’ by the community, the region, and the state and could serve as
the basis of a VMT threshold expressed as a VMT growth budget or as a V MT efficiency metric based on
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the future year VMT per resident, VMT per employee, or VMT per service population. The measurement
of VMT could occur at the jurisdictional or sub-region level.
Potential limitations of this approach relate to model sensitivity and forecast accuracy/reasonableness. If a
general plan includes policies or implementation programs designed to reduce VMT through
transportation demand management (TDM) strategies, the regional models did not likely include these
effects. Further, current regional models do not capture major disruptive trend effects such as TNCs, AVs,
and internet shopping. The regional models may also have other issues with forecasting accuracy or
reasonableness due to a disconnect between RTP/SCS expectations and the realities of transportation
investments and local agency land use decisions as noted in the 2018 Progress Report California’s
Sustainable Communities and Climate Protection Act, California Air Resources Board, November 2018.
OPTION 4 – Set Thresholds Based on Baseline VMT Performance
As noted above, an impact under CEQA begins with a change to the existing or baseline environment.
There are a range of approaches to using this starting point for VMT impact analysis. At one end of the
spectrum is ‘total daily VMT’ generated under baseline conditions. Setting this value as the threshold for
a jurisdiction could result in a fixed budget that would limit increases such that even small increases could
result in a significant impact. Alternatively, the baseline VMT per resident, VMT per employee, or VMT per
service population could be used to establish an efficiency metric basis for impact evaluation. Using this
form of VMT would mean that future land use projects would be expected to perform no worse than
existing land use projects and only projects that cause an increase in the rate of VMT generation would
cause significant impacts. Since VMT will increase or fluctuate with population and employment growth,
changes in economic activity, and expansion of new vehicle travel choices (i.e., Uber, Lyft, AVs, etc.),
expressing VMT measurement in an efficiency metric form allows for more direct comparisons to baseline
conditions when it comes to land use projects, land use plans, and transportation projects. Setting a
threshold based on baseline levels should consider how the threshold complies with the SB 743 statute
provisions described at the beginning of this memo as well as whether VMT reduction strategies are
feasible in the jurisdiction.
OPTION 5 – Set Thresholds Based on Maximum Achievable VMT Reduction
Programs and practices designed to reduce VMT are referred to as transportation demand management
(TDM) strategies. TDM strategies range from programs such as employers providing subsidized or free
transit passes to constructing new infrastructure such as bicycle or pedestrian paths. The VMT reduction
associated with different TDM measures has been published in research papers. In August 2010 the
California Air Pollution Control Officers Association (CAPCOA) published Quantifying Greenhouse Gas
Mitigation Measures. This report identified 50 transportation measures, 41 of which are applicable at the
building and site level. Of these strategies, some are likely to be effective in denser areas, while others will
be less applicable in rural or suburban setting. In North Orange County, key factors that determine which
reduction measures will be effective such as density and access to transit vary throughout and within the
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jurisdictions. As such, a threshold could be based on the maximum achievable reduction in VMT, based on
the TDM measures that would be feasible in the jurisdiction in which the project is located.
The August 2010 CAPCOA report identified an estimate for the expected reduction associated with each
TDM measure. The most current research now suggests that these expected reduction targets are
aggressive and not achievable in most areas. Implementation of several TDM measures can vary
significantly for similar areas and uses. For example, any TDM measures associated with employment uses
are dependent upon the employer. Office buildings in the same neighborhood with different tenants may
not achieve the same reduction targets.
The maximum achievable reduction is also influenced by key factors such as urban context , the size of the
project, and access to transit. Detailed analysis would be required to determine the feasible mitigation
measures for a specific project and location. However, a 15% threshold, as identified by OPR, would not
be feasible throughout suburban areas of North Orange County. Areas such as downtown Orange or
Fullerton with high quality transit could potentially achieve a reduction between 5% and 10%, while the
more suburban neighborhoods without access to high quality transit would have a lower maximum
achievable reduction, likely less than 10%.
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TECHNICAL MEMORANDUM
Date: January 31, 2020
To: City of Orange, City of Fullerton, City of La Habra, City of Placentia, City of Brea, City of Buena
Park, and City of Yorba Linda
From: Jason D. Pack, PE and Delia Votsch, PE
Subject: North Orange County Collaborative (NOCC) SB 743 Implementation: Case Studies OC19-0661
This technical memorandum presents land use project case studies to evaluate the methodologies
associated with different threshold options. Lead agencies have the discretion to select their own thresholds
presuming they provide substantial evidence to support their selection (see the Thresholds Evaluation
Technical Memorandum for more details). The following land use projects were evaluated as case studies
in this effort:
1. Beckman Business Center – An industrial business park in Fullerton
2. CSU Fullerton University House – A mixed-use project including student housing and retail in
Fullerton
3. Aldi Grocery Store – A small grocery store in La Habra
4. Valentia Apartments- multifamily residential in La Habra
5. Orange Olive -single family homes in Orange
6. Springhill Suites – a new hotel in Placentia
7. Senior Housing – Multifamily affordable senior units in Yorba Linda
8. Hines – A mixed-use project including multifamily residential units and office in Brea
9. Beach and Orangethorpe Specific Plan - A mixed-use project including multifamily residential units,
hotel, retail, and office in Buena Park
The remainder of this memo is organized as follows.
· Potential Project Screening for Land Use Projects
· VMT Analysis for Land Use Projects
· VMT Analysis for Land Use Plans
· VMT Analysis for Transportation Projects
· Land Use Project Case Study Tests
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Potential Project Screening for Land Use Projects
Lead agencies may choose to use an impact screening procedure to streamline land use project review for
VMT impacts. A screening tool is currently under development that could be utilized by North County
Cities, depending on the criteria ultimately chosen for screening. If a project does not pass an initial
screening test, then a full impact analysis is warranted. In all, the process may include up to three steps as
outlined below.
Step 1: Transit Priority Area (TPA) Screening
Projects located within a TPA1 may be presumed to have a less than significant impact absent substantial
evidence to the contrary. This presumption may NOT be appropriate if the project:
1. Has a Floor Area Ratio (FAR) of less than 0.75;
2. Includes more parking for use by residents, customers, or employees of the project than required
by the City or County (if the City or County requires the project to supply parking);
3. Is inconsistent with the applicable Sustainable Communities Strategy (as determined by the lead
agency, with input from the Metropolitan Planning Organization); or
4. Replaces affordable residential units with a smaller number of moderate- or high-income
residential units.
Step 2: Low VMT Area Screening
Residential and office projects located within a low VMT generating area may be presumed to have a less
than significant impact absent substantial evidence to the contrary. In addition, other employment-related
and mixed-use land use projects may qualify for the use of screening if the project can reasonably be
expected to generate VMT per resident, per worker, or per service population that is similar to the existing
land uses in the low VMT area. For this screening in Orange County, the OCTAM travel forecasting model
was used to measure VMT performance for individual jurisdictions and for individual traffic analysis zones
(TAZs). TAZs are geographic polygons similar to census block groups used to represent areas of
homogenous travel behavior. Total daily VMT per service population (population plus employment) was
estimated for each TAZ. Those TAZs that perform at or below the jurisdictional average of total VMT per
service population under base year (2012) conditions are considered low VMT areas for purposes of this
memo. Individual lead agencies may choose a different baseline threshold to define their low VMT areas.
1 A TPA is defined as a half mile area around an existing major transit stop or an existing stop along a high-quality
transit corridor per the definitions below.
Pub. Resources Code, § 21064.3 - ‘Major transit stop’ means a site containing an existing rail transit station, a ferry
terminal served by either a bus or rail transit service, or the intersection of two or more major bus routes with a
frequency of service interval of 15 minutes or less during the morning and afternoon peak commute periods.
Pub. Resources Code, § 21155 - For purposes of this section, a ‘high-quality transit corridor’ means a corridor with
fixed route bus service with service intervals no longer than 15 minutes during peak commute hours.
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This presumption may not be appropriate if the project land uses would alter the existing built environment
in such a way as to increase the rate or length of vehicle trips.
Step 3: Project Type Screening
Projects of certain sizes and function may be screened from VMT assessment. Local serving retail projects
less than 50,000 square feet may be presumed to have a less than significant impact absent substantial
evidence to the contrary. Local serving retail generally improves the convenience of shopping close to home
and has the effect of reducing vehicle travel. Projects which serve the local community and have the
potential to reduce VMT, such as public K-12 schools, affordable housing, daycare facilities, student housing,
public libraries, and fire stations may also be screened from VMT assessment. Projects that generate less
than 110 net daily trips have also been recommended by OPR to be small enough to be screened from
analysis.2 Fehr & Peers recommends each jurisdiction consider the substantial evidence presented by OPR
and determine if it is reasonable for their jurisdiction.
Since trip generation is one component of VMT, and a screening criterion may be more appropriate if it
considers both trip generation and trip length when screening a project. As such, if a jurisdiction would
rather use a VMT screening criteria (instead of the 110-trip threshold noted above), we have provided
several options below that are tiered from existing CEQA exemptions:
The following document provides substantial evidence to support the screening on ‘small’ projects for SB
743 purposes. The OPR Technical Advisory relies on a trip trigger based on CEQA exemptions.
2 Per the Technical Advisory on Evaluating Transportation Impacts in CEQA, December 2018, CEQA provides a
categorical exemption for existing facilities, including additions to existing structures of up to 10,000 square feet, so
long as the project is in an area where public infrastructure is available to allow for maximum planned development
and the project is not in an environmentally sensitive area. (CEQA Guidelines, § 15301, subd. (e)(2).) Typical project
types for which trip generation increases relatively linearly with building footprint (i.e., general office building, single
tenant office building, office park, and business park) generate or attract an additional 110-124 trips per 10,000
square feet.
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Two potential limitations of this trigger have been identified. First, the trigger is not tied to a VMT
estimate. Second, the trigger does not consider residential land uses. To strengthen the evidence, we
used specific CEQA exemptions related to residential projects and 2012 California Household Travel
Survey (CHTS) household VMT estimates to develop the following modification to the OPR approach. The
CEQA exemption sections are provided below.
15303. NEW CONSTRUCTION OR CONVERSION OF SMALL STRUCTURES
Class 3 consists of construction and location of limited numbers of new, small facilities or structures; installation of
small new equipment and facilities in small structures; and the conversion of existing small structures from one use to
another where only minor modifications are made in the exterior of the structure. The numbers of structures
described in this section are the maximum allowable on any legal parcel. Examples of this exemption include, but are
not limited to:
(a) One single-family residence, or a second dwelling unit in a residential zone. In urbanized areas, up to three single-
family residences may be constructed or converted under this exemption.
(b) A duplex or similar multi-family residential structure, totaling no more than four dwelling units. In urbanized areas,
this exemption applies to apartments, duplexes and similar structures designed for not more than six dwelling units.
(c) A store, motel, office, restaurant or similar structure not involving the use of significant amounts of hazardous
substances, and not exceeding 2500 square feet in floor area. In urbanized areas, the exemption also applies to up to
four such commercial buildings not exceeding 10,000 square feet in floor area on sites zoned for such use if not
involving the use of significant amounts of hazardous substances where all necessary public services and facilities are
available and the surrounding area is not environmentally sensitive.
Note: Authority cited: Section 21083, Public Resources Code; Reference: Sections 21084, Public Resources Code.
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15315. MINOR LAND DIVISIONS
Class 15 consists of the division of property in urbanized areas zoned for residential, commercial, or industrial use into
four or fewer parcels when the division is in conformance with the General Plan and zoning, no variances or
exceptions are required, all services and access to the proposed parcels to local standards are available, the parcel
was not involved in a division of a larger parcel within the previous 2 years, and the parcel does not have an average
slope greater than 20 percent.
Note: Authority cited: Sections Section 21083, Public Resources Code; Reference: Section 21084, Public Resources
Code.
Based on the 2012 CHTS, here are a range of VMT estimates for 2, 4, and 6 units based on the statewide
average VMT generation per household.
CA Average – 41.6 VMT per household
· 2 units = 83.2 VMT per day
· 4 units = 166.4 VMT per day
· 6 units = 249.6 VMT per day (urban areas only)
Another option is to rely on the maximum level of development allowed by CEQA exemptions and
convert that value to a ‘dwelling unit equivalent’ measure similar to impact fee programs. OPR estimated
that non-residential uses could generate 110-124 daily trips based on a maximum project exemption size
of 10,000 square feet (KSF). Using the lower end of the range and CHTS trip lengths produces a VMT
equivalent for 10 KSF for the state of 836. This equates to about 20 residential households. The 836 VMT
could be utilized to identify the total VMT that could be deemed exempt.
VMT Analysis for Land Use Projects
Projects not screened through the steps above should complete VMT analysis and forecasting through the
OCTAM model to determine if they have a significant VMT impact. This analysis should include ‘project
generated VMT’ and ‘project effect on VMT’ estimates for the project TAZ (or TAZs).
VMT Methods
Three methods for calculating VMT are available using the OCTAM model.
1. Production/Attraction VMT
The Production/Attraction (PA) method for calculating VMT sums all weekday VMT generated by trips with
at least one trip end in the study area. The PA method is completed after the fourth (out of five) loops of
assignment in the travel demand model, while trips are still tracked by trip purpose (Note, the trips at this
stage are person trips that need to converted to vehicle trips for VMT estimate. Productions are land use
types that generate trips (residences) and attractions are land use that attract trips (employment).
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Productions and attractions are converted from person trips to vehicle trips for the purposes of calculating
VMT.
PA matrices do not include trips that have one trip end outside of the model boundary (IX-XI trips) and,
therefore, do not include those trips in the VMT estimates.
The PA method allows project VMT to be evaluated based on trip purpose. For example, a single-use project
such as an office building could be analyzed based only on the commute VMT, or home-based work (HBW)
VMT per employee.
2. Origin/Destination VMT
The Origin/Destination (OD) method for calculating VMT sums all weekday VMT generated by trips with at
least one trip end in the study area. The OD method is completed after the fifth and final loops of
assignment in the travel demand model. Origins are all vehicle trips that start in a specific traffic analysis
zone, and destinations are all vehicle trips that end in a specific traffic analysis zone.
OD does account for trips that have one trip end outside of the model boundary (IX-XI trips)and therefore
provides a more complete capture of all travel within the study area; however, the OCTAM and SCAG models
cannot keep track of trips by trip purposes separately in this format.
3. Boundary Method VMT
The boundary method is the sum of all weekday VMT on a roadway network within a designated
boundary.3 Boundary method VMT includes all trips, including those that trips that do not begin or end in
the designated boundary. This is the only VMT method that captures the effect of cut-through and/or
displaced traffic and is evaluated in the cumulative year for land use projects.
VMT Metrics
VMT should be normalized based on the number of residents and employees present in the zone, City or
regional area for comparative purposes to determine impacts. The following presents the metrics to
normalize VMT.
Total VMT per service population
Total VMT per service population includes the VMT generated divided by the population and employment
in a given area (TAZ, City, or sub-region). Total VMT per service population can be presented with or without
3 OPR recommends against using “arbitrary” boundaries such as City or County lines, however the model-wide results
would include all six counties in the model. The addition of a single project in such a large area would be negligible.
The only way to distinguish between no project and plus project results to determine the effect on VMT is to set a
boundary at a scale where the effect on VMT from an individual project can be measured. Therefore, Fehr & Peers
recommends the City or sub-regional level boundary would be an appropriate scale for this methodology.
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truck VMT when calculated from PA VMT and includes truck VMT when calculated from OD VMT. Total VMT
per service population would also be presented when calculating VMT using the Boundary Method.
An important note regarding service population is the calculation includes the employment and population
coded into the travel demand model. This calculation excludes VMT-generating groups such as visitors and
students. Each Project should consider if it is appropriate to add VMT-generating groups to its service
population.
Home-based VMT per resident (automobile only)
Home-based VMT per resident includes the VMT generated only by home-based work and home-based
other productions divided by the population in a given area (TAZ, City, or sub-region). This method can
only be calculated from PA VMT and does not include truck VMT or trips with one trip end outside of the
model. Zones without any residential uses will generate zero home-based VMT per resident.
Home-based work VMT per worker (automobile only)
Home-based work VMT per worker includes the VMT generated only by home-based work attractions
divided by the number of employees in a given area (TAZ, City, or sub-region). This method can only be
calculated from PA VMT and does not include truck VMT or trips with one trip end outside of the model.
Zones with no commercial uses will generate zero home-based VMT per worker.
VMT Scenarios
Project testing was performed under the following scenarios.
· Baseline conditions - This data has been extracted from OCTAM and is available. Future projects
should confirm that this baseline data represents the latest version of the regional travel model.
VMT was evaluated using the Production Attraction (PA) and Origin Destination (OD) Method.4
· Baseline plus project for the project - The project land use was added to the project TAZ or a
separate TAZ would be created to contain the project land uses. A full model run was performed
and VMT changes would be isolated for the project TAZ and across the full model network. The
model output must include reasonableness checks of the production and attraction balancing to
ensure the project effect is accurately captured. If this scenario results in a less-than-significant
impact, then additional cumulative scenario analysis may not be required (more information
about this outcome can be found in the Thresholds Evaluation memo).
· Cumulative no project - This data is available from OCTAM. VMT was calculated using the OD, PA,
and Boundary Method.
· Cumulative plus project – The project land use would either be added to the project TAZ or a
separate TAZ would be created to contain the project land uses. The addition of project land uses
4 Once a local jurisdiction identifies either PA or OD as the most appropriate method for calculating VMT for their
projects, VMT would need to be calculated using only one method to assess project generated impacts.
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should be accompanied by a reallocation of a similar amount of land use from other TAZs. Land
use projects will generally not change the cumulative no project control totals for population and
employment growth. Instead, they will influence the land use supply through changes in general
plan land use designations and zoning. If project land uses are simply added to the cumulative no
project scenario, then the analysis should reflect this limitation in the methodology and
acknowledge that the analysis may overestimate the project’s effect on VMT. VMT was calculated
using the OD, PA. and Boundary Method5.
VMT Analysis for Land Use Plans
Land use plans are not subject to screening and require specific VMT analysis. Land use plans can be tested
for significant impacts under cumulative conditions using the same cumulative threshold options (or lead
agency thresholds) below. These thresholds require modeling the land use plan changes in the OCTAM
model to determine VMT impacts. To capture the project effect, the same cumulative year population and
employment growth totals should be used model wide. The land use plan only influences land use
allocation, so land use in other areas of the model should be adjusted such that the growth totals model-
wide remain the same between the cumulative year no project and plus project scenarios.
Land Use Project Case Study Tests
For the case studies, four threshold options were tested to determine if the land use projects would cause
a significant impact under baseline plus project conditions. Normally, baseline will represent the year in
which the notice of preparation (NOP) is published for the project. Since all the case studies are completed
projects, the baseline year has simply been set to 2012, the base year of the OCTAM model. Future projects
may need to create specific baseline years and should consider methods such as interpolating VMT results
between the 2012 base year output from OCTAM and 2040 horizon year output.
5 Once a local jurisdiction identifies either PA or OD as the most appropriate method for calculating VMT for their
projects, VMT would need to be calculated using only one method to assess project generated impacts. Boundary
method would be required to assess the project effect on VMT.
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Threshold Options
Threshold Significant Impact Method Scenarios
Project Generated VMT
Option 1 – OPR Guidance
15%
A significant impact would occur if the addition of a
project to the base year model causes its
corresponding TAZ to generate daily home-based
production VMT per resident or daily home-based-
work attraction VMT per employee or daily total
VMT per service population (VMT per Res/Emp/SP)
more than 15 percent below the applicable
jurisdictional average under baseline conditions.
PA/OD Base Year
Cumulative Year
Option 2 – ARB GHG Goals
14.3%
A significant impact would occur if the addition of a
project to the base year model causes its
corresponding TAZ to generate daily VMT per
Res/Emp/SP more than 14.3 percent below the
applicable jurisdictional average under baseline
conditions.
PA/OD Base Year
Cumulative Year
Option 3 – Better than
General Plan Buildout
A significant impact would occur if the addition of a
project to the base year model causes its
corresponding TAZ to generate daily VMT per
Res/Emp/SP more than the applicable jurisdiction
average under General Plan buildout conditions.
PA/OD Base Year
Cumulative Year
Option 4 – Better than
Existing
A significant impact would occur if the addition of a
project to the base year model causes its
corresponding TAZ to generate daily VMT per
Res/Emp/SP above the applicable jurisdictional
average under baseline conditions.
PA/OD Base Year
Cumulative Year
Project Effect on VMT
Increase Citywide
A significant impact would occur if the addition of a
project to the cumulative year model causes an
increase to its citywide daily VMT per SP above
the applicable jurisdictional average without the
project under baseline conditions.
Boundary Cumulative Year
Source: Fehr & Peers, 2020
Lead agencies have discretion to set their own thresholds as explained in the Thresholds Evaluation
memo. The case study tests will compare against the City average and the County average.
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Beckman Business Center
Beckman Business Center is a project in Fullerton, located at 4300 N. Harbor Blvd. The project includes eight
buildings of industrial business park totaling 980,000 square feet.
The Beckman Business Center project could be considered for project screening. It is located in a TPA and
is in a low VMT-generating zone; although additional checks would be required related to parking and
density. It cannot be screened based on land use type as it would generate more than 110 daily trips.
Although the Project could be considered for screening, a full VMT analysis was performed for the
purposes of testing. The OD and PA VMT per service population (VMT/SP) are lower than the City and
County Existing (Base Year) and General Plan Buildout (Cumulative Year) averages. The home-based-work
(HBW) VMT per employment (VMT/Emp) is lower than City and County Existing (Base Year) and General
Plan Buildout (Cumulative Year) averages.
In the cumulative year model VMT was also calculated using the boundary method. Citywide VMT
decreases with the addition of the project.
11 | P a g e Beckman Business Center: OD/PA Method TAZ – With Project City – No Project County – No Project OD VMT/SP PA HB VMT/Pop PA HBW VMT/Emp PA VMT/SP OD VMT/SP PA HB VMT/Pop PA HBW VMT/Emp PA VMT/SP OD VMT/SP PA HB VMT/Pop PA HBW VMT/Emp PA VMT/SP 22.94 0.00 21.16 22.96 Base Year (Existing) 30.10 16.50 23.27 29.08 29.73 17.63 24.04 28.60 Cumulative Year (General Plan Buildout) 29.42 15.58 22.94 28.33 29.90 17.65 24.70 28.78 Impacts Option 1 – OPR Guidance 15% Below Existing No Impact No Project HB VMT/Pop Impact No Impact No Impact No Project HB VMT/Pop Impact No Impact Option 2 – ARB GHG Goals 14.3% Below Existing No Impact Impact No Impact No Impact Impact No Impact Option 3 – Better than General Plan Buildout No Impact No Impact No Impact No Impact No Impact No Impact Option 4 – Better than Existing No Impact No Impact No Impact No Impact No Impact No Impact Source: Fehr & Peers, 2020 Beckman Business Center: Boundary Method Citywide VMT/SP Scenario VMT/SP No Project 13.30 With Project 13.26 Impacts Increase Citywide VMT/SP No Impact Source: Fehr & Peers, 2020
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CSU Fullerton University House
CSU Fullerton University House is a project in located on the existing CSUF campus in Fullerton. The project
includes 350 units of student housing and 31,000 square feet of retail.
CSU Fullerton University House could potentially be screened. It is located in a TPA but is not located a low
VMT-generating zone. The retail portion of the project is under 50,000 square feet, and university housing
is a land use type that potentially be screened. The project generates more than 110 daily trips.
Although the Project could be considered for screening, a full VMT analysis was performed for the
purposes of testing. The OD and PA VMT per service population (VMT/SP) are lower than the City and
County Existing (Base Year) and General Plan Buildout (Cumulative Year) averages.
In the cumulative year model VMT was also calculated using the boundary method. Citywide VMT
decreases with the addition of the project.
13 | P a g e CSU Fullerton University House: OD/PA Method TAZ – With Project City – No Project County – No Project OD VMT/SP PA HB VMT/Pop PA HBW VMT/Emp PA VMT/SP OD VMT/SP PA HB VMT/Pop PA HBW VMT/Emp PA VMT/SP OD VMT/SP PA HB VMT/Pop PA HBW VMT/Emp PA VMT/SP 6.69 0.00 20.82 6.70 Base Year (Existing) 30.10 16.50 23.27 29.08 29.73 17.63 24.04 28.60 Cumulative Year (General Plan Buildout) 29.47 15.63 22.96 28.38 29.91 17.66 24.71 28.78 Impacts Option 1 – OPR Guidance 15% Below Existing No Impact VMT/SP is the recommended metric for mixed-use projects No Impact No Impact VMT/SP is the recommended metric for mixed-use projects No Impact Option 2 – ARB GHG Goals 14.3% Below Existing No Impact No Impact No Impact No Impact Option 3 – Better than General Plan Buildout No Impact No Impact No Impact No Impact Option 4 – Better than Existing No Impact No Impact No Impact No Impact Source: Fehr & Peers, 2020 CSU Fullerton University House: Boundary Method Citywide VMT/SP Scenario VMT/SP No Project 13.27 With Project 13.26 Impacts Increase Citywide VMT/SP No Impact Source: Fehr & Peers, 2020
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Aldi Grocery Store
The Project is a proposed 18,783 grocery store located at 951 E. Imperial Highway in La Habra.
The Project could potentially be screened. It is not located in a low VMT-generating zone but is located
within a TPA. The Project is a retail use under 50,000 square feet and generates fewer than 110 daily trips.
Although the Project could be considered for screening, a full VMT analysis was performed for the
purposes of testing. The OD and PA VMT per service population (VMT/SP) are higher than the City and
County Existing (Base Year) and General Plan Buildout (Cumulative Year) averages. The home-based-work
(HBW) VMT per employment (VMT/Emp) is lower than City and County Existing (Base Year) and General
Plan Buildout (Cumulative Year) averages.
In the cumulative year model VMT was also calculated using the boundary method. Citywide VMT
decreases with the addition of the project.
As noted above, some specific uses with high visitor rates have high VMT per service population as those
visitors are generating VMT but are not included in the denominator of the rate development.
15 | P a g e Aldi Grocery Store: OD/PA Method TAZ – With Project City – No Project County – No Project OD VMT/SP PA HB VMT/Pop PA HBW VMT/Emp PA VMT/SP OD VMT/SP PA HB VMT/Pop PA HBW VMT/Emp PA VMT/SP OD VMT/SP PA HB VMT/Pop PA HBW VMT/Emp PA VMT/SP 61.60 0.00 18.86 59.25 Base Year (Existing) 24.43 17.07 20.99 23.44 29.73 17.63 24.04 28.60 Cumulative Year (General Plan Buildout) 23.82 16.71 20.91 22.98 29.91 17.66 24.71 28.78 Impacts Option 1 – OPR Guidance 15% Below Existing Impact No Project HB VMT/Pop Impact Impact Impact No Project HB VMT/Pop No Impact Impact Option 2 – ARB GHG Goals 14.3% Below Existing Impact Impact Impact Impact No Impact Impact Option 3 – Better than General Plan Buildout Impact No Impact Impact Impact No Impact Impact Option 4 – Better than Existing Impact No Impact Impact Impact No Impact Impact Source: Fehr & Peers, 2020 Aldi Grocery Store: Boundary Method Citywide VMT/SP Scenario VMT/SP No Project 9.32 With Project 9.24 Impacts Increase Citywide VMT/SP No Impact Source: Fehr & Peers, 2020
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Valentia Apartments
The Valentia Apartments project is a 335-unit multifamily development at 951 S. Beach Boulevard in La
Habra.
This Project does not meet screening criteria. It is not located in a low VMT-generating zone or TPA. The
apartments were assumed to be market rate apartments, so they could not be screened based on land use
type (if the apartments were designated affordable housing they could be screened). The project generates
more than 110 daily trips.
Below are project-level VMT estimates prepared using OCTAM and both OD and PA methodologies. The
OD and PA VMT per service population (VMT/SP) are lower than the City and County Existing (Base Year)
and General Plan Buildout (Cumulative Year) averages. The home-based (HB) VMT per population
(VMT/Pop) is higher than City and County Existing (Base Year) and General Plan Buildout (Cumulative
Year) averages.
In the cumulative year model VMT was also calculated using the boundary method. Citywide VMT
increases with the addition of the project.
17 | P a g e Valentia Apartments: OD/PA Method TAZ – With Project City – No Project County – No Project OD VMT/SP PA HB VMT/Pop PA HBW VMT/Emp PA VMT/SP OD VMT/SP PA HB VMT/Pop PA HBW VMT/Emp PA VMT/SP OD VMT/SP PA HB VMT/Pop PA HBW VMT/Emp PA VMT/SP 21.90 20.15 0.00 21.86 Base Year (Existing) 24.43 17.07 20.99 23.44 29.73 17.63 24.04 28.60 Cumulative Year (General Plan Buildout) 23.86 16.75 20.86 23.02 29.90 17.65 24.70 28.78 Impacts Option 1 – OPR Guidance 15% Below Existing Impact Impact No Project HBW VMT/Emp Impact No Impact Impact No Project HBW VMT/Emp No Impact Option 2 – ARB GHG Goals 14.3% Below Existing Impact Impact Impact No Impact Impact No Impact Option 3 – Better than General Plan Buildout No Impact Impact No Impact No Impact Impact No Impact Option 4 – Better than Existing No Impact Impact No Impact No Impact Impact No Impact Source: Fehr & Peers, 2020 Valentia Apartments: Boundary Method Citywide VMT/SP Scenario VMT/SP No Project 9.31 With Project 9.34 Impacts Increase Citywide VMT/SP Impact Source: Fehr & Peers, 2020
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Orange Olive
The Orange Olive Project is a 25-unit single family home development located at 2025 North Orange-Olive
road in Orange.
The Orange Olive project could be considered for project screening. It is located in a low VMT-generating
zone, although is not located in a TPA. It cannot be screened based on land use type and would generate
more than 110 daily trips.
Although the Project could be considered for screening, a full VMT analysis was performed for the
purposes of testing. The OD and PA VMT per service population (VMT/SP) are lower than the City and
County Existing (Base Year) and General Plan Buildout (Cumulative Year) averages. The home-based (HB)
VMT per population (VMT/Pop) is lower than City and County Existing (Base Year) and General Plan
Buildout (Cumulative Year) averages.
In the cumulative year model VMT was also calculated using the boundary method. Citywide VMT
decreases with the addition of the project.
19 | P a g e Orange Olive: OD/PA Method TAZ – With Project City – No Project County – No Project OD VMT/SP PA HB VMT/Pop PA HBW VMT/Emp PA VMT/SP OD VMT/SP PA HB VMT/Pop PA HBW VMT/Emp PA VMT/SP OD VMT/SP PA HB VMT/Pop PA HBW VMT/Emp PA VMT/SP 17.36 14.83 0.00 17.04 Base Year (Existing) 31.83 16.91 23.71 30.98 29.73 17.63 24.04 28.60 Cumulative Year (General Plan Buildout) 30.88 16.70 23.87 29.92 29.90 17.65 24.70 28.78 Impacts Option 1 – OPR Guidance 15% Below Existing No Impact Impact No Project HBW VMT/Emp No Impact No Impact No Impact No Project HBW VMT/Emp No Impact Option 2 – ARB GHG Goals 14.3% Below Existing No Impact Impact No Impact No Impact No Impact No Impact Option 3 – Better than General Plan Buildout No Impact No Impact No Impact No Impact No Impact No Impact Option 4 – Better than Existing No Impact No Impact No Impact No Impact No Impact No Impact Source: Fehr & Peers, 2020 Orange Olive: Boundary Method Citywide VMT/SP Scenario VMT/SP No Project 19.02 With Project 19.00 Impacts Increase Citywide VMT/SP No Impact Source: Fehr & Peers, 2020
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Springhill Suites
Springhill Suites proposes to control a 116-room hotel at 380 S. Placentia in Placentia.
This Project could potentially be screened. It is located in a TPA and in a low VMT generating zone. A hotel
could potentially be designated as a local serving land use and screened based on land use type. The Project
could not be screened based on total daily trips, as it would generate more than 110 daily trips.
Note: The NOCC VMT Screening Tool does not currently support a hotel use. However, the location was
entered to determine if the project was located in a low VMT zone or TPA.
Although the Project could be considered for screening, a full VMT analysis was performed for the
purposes of testing. The OD and PA VMT per service population (VMT/SP) are lower than the City and
County Existing (Base Year) and General Plan Buildout (Cumulative Year) averages. The home-based-work
(HBW) VMT per employment (VMT/Emp) is lower than City Existing (Base Year) and General Plan Buildout
(Cumulative Year) averages, but higher than the County Existing (Base Year) and General Plan Buildout
(Cumulative Year) averages.
In the cumulative year model VMT was also calculated using the boundary method. Citywide VMT
decreases with the addition of the project.
21 | P a g e Springhill Suites: OD/PA Method TAZ – With Project City – No Project County – No Project OD VMT/SP PA HB VMT/Pop PA HBW VMT/Emp PA VMT/SP OD VMT/SP PA HB VMT/Pop PA HBW VMT/Emp PA VMT/SP OD VMT/SP PA HB VMT/Pop PA HBW VMT/Emp PA VMT/SP 11.81 0.00 24.80 11.76 Base Year (Existing) 25.95 17.03 25.32 24.91 29.73 17.63 24.04 28.60 Cumulative Year (General Plan Buildout) 26.00 16.52 25.49 24.96 29.90 17.65 24.70 28.78 Impacts Option 1 – OPR Guidance 15% Below Existing No Impact No Project HB VMT/Pop Impact No Impact No Impact No Project HB VMT/Pop Impact No Impact Option 2 – ARB GHG Goals 14.3% Below Existing No Impact Impact No Impact No Impact Impact No Impact Option 3 – Better than General Plan Buildout No Impact No Impact No Impact No Impact Impact No Impact Option 4 – Better than Existing No Impact No Impact No Impact No Impact Impact No Impact Source: Fehr & Peers, 2020 Springhill Suites: Boundary Method Citywide VMT/SP Scenario VMT/SP No Project 11.77 With Project 11.76 Impacts Increase Citywide VMT/SP No Impact Source: Fehr & Peers, 2020
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Senior Housing
The Senior Housing project proposes to construct 48 units of affordable multi-family senior housing at
Lakeview Avenue and Altrudy Lane in Yorba Lina.
This Project could potentially be screened. It is not located in a TPA or in a low VMT generating zone, but
is designated affordable housing projects can be screened based on land use type. The Project could not
be screened based on total daily trips, as it would generate more than 110 daily trips.
Although the Project could be considered for screening, a full VMT analysis was performed for the
purposes of testing. The OD and PA VMT per service population (VMT/SP) are lower than the City and
County Existing (Base Year) and General Plan Buildout (Cumulative Year) averages. The home-based (HB)
VMT per population (VMT/Pop) is lower than City Existing (Base Year) and General Plan Buildout
(Cumulative Year) averages, but higher than the County Existing (Base Year) and General Plan Buildout
(Cumulative Year) averages.
In the cumulative year model VMT was also calculated using the boundary method. Citywide VMT
decreases with the addition of the project.
23 | P a g e Senior Housing: OD/PA Method TAZ – With Project City – No Project County – No Project OD VMT/SP PA HB VMT/Pop PA HBW VMT/Emp PA VMT/SP OD VMT/SP PA HB VMT/Pop PA HBW VMT/Emp PA VMT/SP OD VMT/SP PA HB VMT/Pop PA HBW VMT/Emp PA VMT/SP 21.31 18.30 0.00 20.95 Base Year (Existing) 35.76 27.24 31.23 34.54 29.73 17.63 24.04 28.60 Cumulative Year (General Plan Buildout) 36.33 27.20 32.96 35.14 29.91 17.66 24.71 28.78 Impacts Option 1 – OPR Guidance 15% Below Existing No Impact No Impact No Project HBW VMT/Emp No Impact No Impact Impact No Project HBW VMT/Emp No Impact Option 2 – ARB GHG Goals 14.3% Below Existing No Impact No Impact No Impact No Impact Impact No Impact Option 3 – Better than General Plan Buildout No Impact No Impact No Impact No Impact Impact No Impact Option 4 – Better than Existing No Impact No Impact No Impact No Impact Impact No Impact Source: Fehr & Peers, 2020 Senior Housing: Boundary Method Citywide VMT/SP Scenario VMT/SP No Project 27.21 With Project 27.20 Impacts Increase Citywide VMT/SP No Impact Source: Fehr & Peers, 2020
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Hines
The Hines proposes to construct 653 multifamily residential units and 556,000 square feet of office in Brea.
This Project could potentially be screened. It is not located in a TPA but is in a low VMT generating zone.
The retail portion of the project is over 50,000 square feet and the multi-family residential units could only
be screened if they were designated low income or permanent supportive housing units. The Project could
not be screened based on total daily trips, as it would generate more than 110 daily trips.
Although the Project could be considered for screening, a full VMT analysis was performed for the
purposes of testing. The OD and PA VMT per service population (VMT/SP) are higher than the City and
County Existing (Base Year) and General Plan Buildout (Cumulative Year) averages.
In the cumulative year model VMT was also calculated using the boundary method. Citywide VMT
decreases with the addition of the project.
25 | P a g e Hines: OD/PA Method TAZ – With Project City – No Project County – No Project OD VMT/SP PA HB VMT/Pop PA HBW VMT/Emp PA VMT/SP OD VMT/SP PA HB VMT/Pop PA HBW VMT/Emp PA VMT/SP OD VMT/SP PA HB VMT/Pop PA HBW VMT/Emp PA VMT/SP 33.65 12.38 26.56 33.74 Base Year (Existing) 32.88 17.89 25.47 31.81 29.73 17.63 24.04 28.60 Cumulative Year (General Plan Buildout) 32.13 18.57 26.08 31.09 29.91 17.66 24.71 28.78 Impacts Option 1 – OPR Guidance 15% Below Existing Impact VMT/SP is the recommended metric for mixed-use projects Impact Impact VMT/SP is the recommended metric for mixed-use projects Impact Option 2 – ARB GHG Goals 14.3% Below Existing Impact Impact Impact Impact Option 3 – Better than General Plan Buildout Impact Impact Impact Impact Option 4 – Better than Existing Impact Impact Impact Impact Source: Fehr & Peers, 2020 Hines: Boundary Method Citywide VMT/SP Scenario VMT/SP No Project 13.83 With Project 13.47 Impacts Increase Citywide VMT/SP No Impact Source: Fehr & Peers, 2020
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Beach and Orangethorpe Specific Plan
The Beach and Orangethorpe Specific Plan is a project in Buena Park, at Beach Blvd and Orangethorpe Ave.
The project includes 1,000 multifamily residential units, 355,000 square feet of retail, 195,000 square feet of
office, and a 300-room hotel
This Project could potentially be screened. It is located in a TPA but not in a low VMT generating zone. The
retail portion of the project is over 50,000 square feet and the multi-family residential units could only be
screened if they were designated low income or permanent supportive housing units. The Project could
not be screened based on total daily trips, as it would generate more than 110 daily trips.
Note: The NOCC VMT Screening Tool does not currently support a hotel use. This portion of the project
could not be captured for screening.
Although the Project could be considered for screening, a full VMT analysis was performed for the
purposes of testing. The PA VMT per service population (VMT/SP) is higher than the City Existing (Base
Year) and General Plan Buildout (Cumulative Year) averages, but lower than the County Existing (Base
Year) and General Plan Buildout (Cumulative Year) averages. The OD VMT per service population
(VMT/SP) is lower than the City and County Existing (Base Year) and General Plan Buildout (Cumulative
Year) averages.
In the cumulative year model VMT was also calculated using the boundary method. Citywide VMT
decreases with the addition of the project.
27 | P a g e Beach and Orangethorpe Specific Plan: OD/PA Method TAZ – With Project City – No Project County – No Project OD VMT/SP PA HB VMT/Pop PA HBW VMT/Emp PA VMT/SP OD VMT/SP PA HB VMT/Pop PA HBW VMT/Emp PA VMT/SP OD VMT/SP PA HB VMT/Pop PA HBW VMT/Emp PA VMT/SP 26.05 12.49 20.59 26.08 Base Year (Existing) 26.99 17.82 21.64 26.05 29.73 17.63 24.04 28.60 Cumulative Year (General Plan Buildout) 26.47 17.07 22.07 25.49 29.91 17.66 24.71 28.78 Impacts Option 1 – OPR Guidance 15% Below Existing Impact VMT/SP is the recommended metric for mixed-use projects Impact Impact VMT/SP is the recommended metric for mixed-use projects Impact Option 2 – ARB GHG Goals 14.3% Below Existing Impact Impact Impact Impact Option 3 – Better than General Plan Buildout No Impact Impact No Impact No Impact Option 4 – Better than Existing No Impact Impact No Impact No Impact Source: Fehr & Peers, 2020 Beach and Orangethorpe Specific Plan: Boundary Method Citywide VMT/SP Scenario VMT/SP No Project 20.33 With Project 19.67 Impacts Increase Citywide VMT/SP No Impact Source: Fehr & Peers, 2020
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TECHNICAL MEMORANDUM
Date: 9.20.19
To: City of Orange, City of Fullerton, City of La Habra, City of Placentia, City of Brea, City of Buena
Park, and City of Yorba Linda
From: Jason Pack, PE and Delia Votsch, PE
Subject: Review and Assessment of Existing Planning/Travel Demand Tools for SB 743 OC19-0661
This technical memorandum presents a review of existing sketch planning tools and travel demand
forecasting models available for SB 743 VMT analysis in the North Orange County region. This study
includes the cities of Orange, Fullerton, La Habra, Placentia, Brea, Buena Park, and Yorba Linda (North
County Cities). We identified three travel forecasting models and 11 sketch planning tools that produce
VMT forecasts or test VMT reduction strategies. However, SB 743 has an additional requirement that
limits which models or tools are potentially acceptable for VMT analysis. The Technical Advisory on
Evaluating Transportation Impacts in CEQA, State of California, Governor’s Office of Planning and
Research, December 2018 contains the following specification for models and methodologies.
Models and methodologies used to calculate thresholds, estimate project VMT, and estimate VMT
reduction due to mitigation should be comparable. For example:
• A tour-based assessment of project VMT should be compared to a tour-based threshold, or
a trip-based assessment to a trip-based VMT threshold.
• Where a travel demand model is used to determine thresholds, the same model should
also be used to provide trip lengths as part of assessing project VMT.
• Where only trip-based estimates of VMT reduction from mitigation are available, a trip-
based threshold should be used, and project VMT should be assessed in a trip-based
manner.
Presuming that the North County Cities will rely on the OCTAM or SCAG travel forecasting models to
establish VMT thresholds, then these models (or their inputs/outputs) would need to be used for project
analysis. As a result, current sketch tools ‘off the shelf’ would not be used to estimate VMT for SB 743
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purposes. Instead, these tools would largely be used for testing VMT mitigation measures such as
transportation demand management (TDM) strategies.
Defining Tool Adequacy
The CEQA Guidelines contain clear expectations for environmental analysis as noted below; however, the
Guidelines are silent about what data, analysis methods, models, and mitigation approaches are adequate
for transportation impacts.
CEQA Guidelines – Expectations for Environmental Impact Analysis
§ 15003 (F) = fullest possible protection of the environment…
§ 15003 (I) = adequacy, completeness, and good-faith effort at full disclosure…
§ 15125 (C) = EIR must demonstrate that the significant environmental impacts of the proposed
project were adequately investigated…
§ 15144 = an agency must use its best efforts to find out and disclose…
§ 15151 = sufficient analysis to allow a decision which intelligently takes account of environmental
consequences…
All of these suggest accuracy is important and have largely been recognized by the courts as the context
for judging an adequate analysis. So, then what is the basis for determining adequacy, completeness, and
a good faith effort when it comes to forecasting and transportation impact analysis? A review of relevant
court cases suggests the following conclusions.
· CEQA does not require the use of any specific methodology. Agencies must have substantial
evidence to support their significance conclusions. (Association of Irritated Residents v. County of
Madera (2003) 107 Cal.App.4th 1383.)
· CEQA does not require a lead agency to conduct every test or perform all research, study, and
experimentation recommended or demanded by commenters. (CEQA Guidelines, § 15204, subd.
(a))
· CEQA does not require perfection in an EIR but rather adequacy, completeness and a good faith
effort at full disclosure while including sufficient detail to enable those who did not participate in
the EIR preparation to understand and consider meaningfully the issues raised by the project.
(Kings County Farm Bureau v. City of Hanford (1990) 221 Cal.App.3d 692)
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· Lead agencies should not use scientifically outdated information in assessing the significance of
impacts. (Berkeley Keep Jets Over the Bay Comm. v. Board of Port Comm. (2001) 91 Cal.App.4th
1344.)
· Impact analysis should improve as more and better data becomes available and as scientific
knowledge evolves. (Cleveland National Forest Foundation v. San Diego Association of
Governments, Cal. Supreme Ct. S223603, 2017).
These conclusions tend to reinforce the basic tenet of CEQA that requires having substantial evidence to
support all aspects of the impact analysis and related decisions. Further, analysis should rely on the latest
state of the practice, or even best practice methods, to provide accurate and meaningful results. This
expectation is grounded in the basic purpose behind environmental regulations like CEQA that attempt to
accurately identify and disclose potential impacts and to develop effective mitigation. Having accurate
and reliable travel forecasts is essential for meeting these expectations. A key challenge in following the
state-of-the-practice is that it can vary depending on many factors. Some of the key factors are listed
below:
· Complexity of the transportation network and number of operating modes
· Available data
· Urban versus rural setting
· Planned changes in the transportation network (particularly to major roads or transit systems)
· Availability of resources to develop and apply travel demand models
· Population and employment levels
· Congestion levels
· Regulatory requirements
· Types of technical and policy questions posed by decision makers
· Desired level of confidence in the analysis findings
· Anticipated level of legal scrutiny
In California, travel forecasts are generated using various forms of models that range from simple
spreadsheets based on historic traffic growth trends to complex computer models that account for
numerous factors that influence travel demand. According to Transportation and Land Development, 2nd
Edition, ITE, 2002, the appropriate model depends on the size of the development project and its ability to
affect the surrounding area. As projects increase in size, the likelihood of needing a complex model (such
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as a four-step model) increases because of the number of variables that influence travel demand and
transportation network operations. The study area can also influence the type of model needed especially
if congestion occurs or if multiple transportation modes operate in the study area. Either of these
conditions requires robust models that can account for the myriad of travel demand responses that can
occur from land use or transportation network changes.
The other relevant national guidance on model applications and forecasting is the NCHRP Report 765,
Analytical Travel Forecasting Approaches for Project-Level Planning and Design, Transportation Research
Board, 2014. This is a detailed resource with many applicable sections. A few highlights related to
forecasting expectations for models are listed below.
· A travel forecasting model should be sensitive to those policies and project alternatives that the
model is expected to help evaluate.
· A travel forecasting model should be capable of satisfying validation standards that are
appropriate to the application.
· Project-level travel forecasts, to the extent that they follow a conventional travel model, should be
validated following the guidelines of the Travel Model Validation and Reasonableness Checking
Manual, Second Edition from FHWA. Similar guidelines are provided in NCHRP Report 716. This
level of validation is necessary, but not sufficient, for project-level forecasts. Project-level forecasts
often require better accuracy than can be obtained from a travel model alone.
· The model should be subject to frequent recalibrations to ensure that validation standards are
continuously met.
Travel Forecasting Models
Three travel forecasting models are available for VMT forecasting in North Orange County including the
California Statewide Travel Demand Model (CSTDM), the SCAG travel forecasting model, and the OCTAM
travel forecasting model.
Public agencies that develop travel forecasting models for planning and impact analysis must maintain
those models and frequently update and recalibrate them as explained above to ensure they remain
accurate and dependable for generating travel demand forecasts. To assess the status of model
ownership and maintenance, each agency responsible for the available travel forecasting models in the
region were contacted to determine if the agency controlled the following model components:
documentation, input and output files, and distribution. Caltrans, SCAG, and OCTA require model user
agreements to protect the agencies from liability while also providing expectations for appropriate model
use.
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Model Adequacy Assessment
The following section details the model assessment for each of the travel forecasting models within the
North County region. This assessment is to help inform agencies about potential improvements that may
be necessary for future model applications intended for CEQA purposes and does not indicate that
previous applications of the model were not appropriate. The assessment used the following specific
criteria.
· Model documentation – this criterion relies on the availability of documentation about the
model’s development including its estimation, calibration, and validation as well as a user’s guide.
· Completed calibration and validation within the past 5 years – recent calibration and validation is
essential for ensuring the model accurately captures evolving changes in travel behavior. Per
NCHRP Report 765, “The model should be subject to frequent recalibrations to ensure that
validation standards are continuously met.”
· Demonstrated sensitivity to VMT effects across demographic, land use, and multimodal network
changes - validation reporting will be checked for static and dynamic tests per the 2017 Regional
Transportation Plan Guidelines for Metropolitan Transportation Planning Organizations, CTC, 2017
and Travel Model Validation and Reasonableness Checking Manual, Second Edition, TMIP, FHWA,
2010.
· Capable of producing both “project-generated VMT” and “project effect on VMT” estimates for
households, home-based trips, and total trips – both metrics are essential for complete VMT
analysis. Project-generated VMT is useful for understanding the VMT associated with the trips
traveling to/from a project site. The ‘project’s effect on VMT’ is more essential for understanding
the full influence of the project since it can alter the VMT generation of neighboring land uses
· Capable of producing regional, jurisdictional, and project-scale VMT estimates – VMT analysis for
air quality, greenhouse gases, energy, and transportation impacts requires comparisons to
thresholds at varying scales. For SB 743, the Technical Advisory on Evaluating Transportation
Impacts in CEQA, December 2018, California Governor’s Office of Planning and Research (OPR)
recommends thresholds based on comparisons to regional or city-wide averages.
· Level of VMT estimates that truncate trip lengths at model or political boundaries – The OPR
Technical Advisory states that lead agencies should not truncate any VMT analysis because of
jurisdictional or model boundaries. The intent of this recommendation is to ensure that VMT
forecasts provide a full accounting of project effects.
To perform the model evaluation, each agency was contacted and requested to submit their model
development documentation, user guides, and the official model files for base year and future year
scenarios. The results of the evaluation are summarized in the table below. For a quick assessment, the
main findings are color coded as follows.
· Green – model meets criterion expectations.
· Orange – model partially meets criterion expectations.
· Red – model does not meet criterion expectations.
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California Statewide Travel Demand Model (CSTDM)
Screening Check Screening Determination Notes
Model documentation Available Includes full reports of model overview, each sub-model
development, and user guide:
· CSTDM Statewide Travel Demand Model Version 2.0
Final Report (June 2014)
· CSDTM09: User Guide Final (May 2011)
These documents were previously available through the
Caltrans website
(https://dot.ca.gov/programs/transportation-
planning/office-of-smart-mobility-climate-change/sb-743)
but the website is being updated (as of September 1,
2019) and not all documents may be available.
Completed calibration and
validation within the past 5
years
No - 2010
Demonstrated sensitivity to
VMT effects across
demographic, land use, and
multimodal network
changes
Documentation does not reflect
any sensitivity tests for
demographic or land use
changes.
The model has inputs for demographic and land use;
however, was not reported in the model documentation
regarding sensitivity to these types of changes.
Documentation does show sensitivity testing for changes
to transit service, but not any testing related to changes in
the roadway network.
Documentation reflect sensitivity
test for some multimodal
network changes.
Capable of producing both
“project-generated VMT”
and “project effect on VMT”
estimates for households,
home-based trips, and total
trips.
Project-generated VMT – scale
of model is too large for project
level applications without
substantial refinement.
The model is not currently available due to Caltrans
website updates and continued work on the future year
model. Base year model VMT outputs were previously
available on the Caltrans website, but those are also
currently not available. Project effect on VMT – same
note as above.
Total VMT – yes
Household VMT – no
Home-based VMT - no
Capable of producing
regional, jurisdictional, and
project-scale VMT
estimates.
Regional VMT - yes Scale of model may be too large for some project level
applications. Verification of model sensitivity in project
area required along with potential project scale
refinements.
Jurisdictional VMT – yes
Project-scale VMT - uncertain
Level of VMT estimates that
truncate trip lengths at
model or political
boundaries.
Low Only trips leaving the California state boundary will be
truncated.
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The CSTDM was developed by Caltrans and produces passenger travel demand forecasts. Details about
the model can be found at the following website.
· https://dot.ca.gov/programs/transportation-planning/multi-modal-system-planning/statewide-
modeling
In addition, Caltrans has produced VMT output data by traffic analysis zone (TAZ) for purposes of SB 743
implementation and that data can be accessed at the following website.
· https://dot.ca.gov/programs/transportation-planning/multi-modal-system-planning/statewide-
modeling/sb-743-vmt-impact-assessment
As a statewide model, the level of detail for local project applications may not be sufficient to produce
reasonable results since the model was not validated at a local scale. The traffic analysis zones (TAZs) are
large as shown in the map excerpt below; so the resulting VMT outputs would have limited sensitivity to
small scale land use projects and the influences of land use context.
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Southern California Association of Governments Travel Demand Model (SCAG)
Screening Check Screening Determination Notes
Model documentation Available Includes full reports of model overview, model validation,
and user guide.
This document is available on SCAG’s website:
http://www.scag.ca.gov/Documents/SCAG_RTDM_2012Mo
delValidation.pdf
Completed calibration and
validation within the past 5
years
Yes - 2016 A new activity-based model (ABM) is currently under
development.
Although the model is currently being updated, the base
year information is four years older than the RTP year that
the model is made consistent with. This may not fully
“accurately capture evolving changes in travel behavior”.
Demonstrated sensitivity to
VMT effects across
demographic, land use, and
multimodal network
changes
Documentation includes
sensitivity tests for demographic
or land use changes.
The model has inputs for demographic and land use;
however, was not reported in the model documentation
regarding sensitivity to these types of changes.
Documentation shows sensitivity testing for changes to
transit service, roadway network, and mode choice.
However, given the size of the traffic analysis zones (TAZs)
and level of detail of the roadway network, the model may
not be sensitive to smaller or localized projects.
Documentation reflects
sensitivity test for multimodal
network changes.
Capable of producing both
“project-generated VMT”
and “project effect on VMT”
estimates for households,
home-based trips, and total
trips.
Project-generated VMT – scale
of model is too large for project
level applications without
substantial refinement.
The trip-based SCAG model (2016 RTP) cannot produce
household VMT. The activity-based model (ABM) that is
currently under development will be able to generate
household VMT.
Project effect on VMT – same
note as above.
Total VMT – yes
Household VMT
Home-based VMT
Capable of producing
regional, jurisdictional, and
project-scale VMT estimates.
Regional VMT - yes Scale of model may be too large for some project level
applications. Verification of model sensitivity in project
area required along with potential project scale
refinements.
Jurisdictional VMT – yes
Project-scale VMT - uncertain
Level of VMT estimates that
truncate trip lengths at
model or political
boundaries.
Medium All trips leaving the SCAG region will be truncated.
SCAG has developed its own models for regional planning purposes including a trip-based model and an
activity-based model (ABM). The SCAG ABM is currently under development. A variety of other models
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have also been created for specific purposes related to sub-regional modeling, heavy duty trucks, air
quality, and scenario planning. As shown in the image below, SCAG is transitioning from the trip-based
model, which was used for previous regional transportation plans/sustainable communities strategies
(RTP/SCS) to the ABM for future versions.
The SCAG trip-based and ABM model outputs can be post-processed to produce total VMT estimates at
the traffic analysis zone (TAZ) level or for any aggregation of TAZs. The ABM can also produce household
generated VMT estimates. These estimates are limited to trips that have origins and destinations within
the model boundary. Trips to or from external model origins and destinations are not included, and trip
lengths are truncated at the model boundary. The models are sensitive to built-environment effects and
have been calibrated and validated to represent the SCAG region as explained in the model development
documentation available at the following website.
· http://www.scag.ca.gov/DataAndTools/Pages/TransportationModels.aspx
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Orange County Transportation Authority Travel Demand Model (OCTAM)
Screening Check Screening Determination Notes
Model documentation Available upon request Includes full reports of model overview and user guide.
This document is not available online but is provided by
OCTA when a modeling user agreement is signed, and the
latest version of the model is transmitted.
Completed calibration and
validation within the past 5
years
Yes - 2017 Although the model was updated in 2017 to reflect the
2016 RTP, the base year information is four years older
than the RTP year that the model is made consistent with.
This may not fully “accurately capture evolving changes in
travel behavior”.
Demonstrated sensitivity to
VMT effects across
demographic, land use, and
multimodal network
changes
Documentation includes
sensitivity tests for demographic
or land use changes.
The model has inputs for demographic and land use;
however, was not reported in the model documentation
regarding sensitivity to these types of changes.
Documentation shows sensitivity testing for changes to
transit service, roadway network, and mode choice.
Documentation reflects
sensitivity test for multimodal
network changes.
Capable of producing both
“project-generated VMT”
and “project effect on VMT”
estimates for households,
home-based trips, and total
trips.
Project-generated VMT –
appropriate for most zones,
some may need minor
refinements.
Trip based models cannot produce household VMT. This
requires a tour-based model that captures all travel
throughout the day for each resident of the household.
Project effect on VMT – same
note as above.
Total VMT – yes
Household VMT
Home-based VMT
Capable of producing
regional, jurisdictional, and
project-scale VMT estimates.
Regional VMT - The model is well suited for project-scale applications in
most areas. Projects located in less developed or larger
TAZs may require verification of model sensitivity in
project area required along with potential project scale
refinements.
Jurisdictional VMT
Project-scale VMT – in most
cases
Level of VMT estimates that
truncate trip lengths at
model or political
boundaries.
Medium All trips leaving the model boundaries will be truncated.
The model includes the entire SCAG region except for
Imperial County and parts of San Bernardino and Riverside
Counties.
The final model evaluated is the OCTAM travel forecasting model, which represents a sub-area of the
SCAG region. The current version of OCTAM was completed in April 2017 and includes a 2012 base year
to reflect the 2016 RTP and a 2040 forecast year. The model was designed to provide a greater level of
detail and sensitivity in Orange County compared to regional SCAG model (see image below of the
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current TAZ system). Like the SCAG model, trips to or from external model origins and destinations are
not included, and trip lengths are truncated at the model boundary. Unlike the SCAG model, the OCTAM
model does not include the entire SCAG region, and does not include Imperial County or parts of San
Bernardino and Riverside Counties. An update is expected in the next two years to reflect a 2016 base year
based on the 2020 RTP and 2045 horizon year.
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Sketch Planning Tools
This review evaluated 11 sketch model tools using the following criteria. We also incorporated
information from reviews conducted through academic research by UC Davis and UC Berkeley.
1. Defensibility – How defensible is the use of this tool in terms of the accuracy of its outputs and
frequency of use by other agencies.
2. Sensitivity - How sensitive is to the tool to the specific land use contexts and TDM strategies (e.g.,
does the tool allow the user to import details related to the context surrounding the project site
and the proposed TDM mitigation measures).
3. Utility – How easy is the tool to use to evaluate VMT and TDM strategies.
The 11 sketch model tools reviewed are listed below:
· CalEEMod - is a statewide computer model designed to estimate emissions of criteria air
pollutant and greenhouse gas (GHG) associated with land use projects. This model also provides
VMT estimates that are a part of the emissions modeling process.
· Sketch 7 - is a spreadsheet tool that estimates percent reductions to VMT based on the 7 Ds (i.e.,
density, diversity, distance, design, destination, demographics, and development scale).
· VMT Impact Tool/Salon – is a spreadsheet tool created by Deborah Salon at UC Davis for the
California Air Resources Board that quantifies how much VMT will change in response to changes
in land use and transportation system variables.
· GreenTRIP Connect - is an online tool for residential projects that allows users to evaluate the
VMT and GHG emissions of their project and to test a limited set of built-in TDM strategies.
· MXD/MXD+ - is a mixed-use development trip generation tool developed for U.S. EPA that
adjusts ITE daily trip generation estimates to reflect built environment effects. MXD+
incorporates the ITE mixed-use trip generation method to produce a.m. and p.m. peak hour trip
generation estimates for mixed use projects. To estimate VMT, the trip generation results from
MXD/MXD+ must be multiplied by trip lengths from observed data or regional/local travel
forecasting models.
· UrbanFootprint (UF) - is a scenario planning tools that produces VMT estimates relying on the
MXD trip generation methodology. Trip lengths are calculated within the model but do not
reflect network-based routing. SCAG uses a version of UF as part of its sketch planning model.
· Envision Tomorrow - is a scenario planning tool that produces VMT estimates.
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· California Smart-Growth Trip Generation Adjustment Tool – is a spreadsheet tool that
provides the number of trips generated by land use projects implementing smart growth
principles.
· TRIMMS – is a visual basic application spreadsheet model that estimates mode share and VMT
changes brought about by a number of TDM strategies.
· VMT+ - is a web-based application that estimates VMT and emissions using ITE trip rates and
user-defined trip and land use inputs.
· TDM+ - is a spreadsheet tool that estimates the percent reduction in VMT due to the
implementation of one or many different TDM strategies identified in the Quantifying Greenhouse
Gas Mitigation Measures, CAPCOA, 2010.
The matrix in Attachment A provides a summary of the tool review. Each of the sketch models reviewed,
except for the CA Smart Growth Tool and MXD/MXD+, provide direct estimates of ‘project generated
VMT’ or calculates the percent change in VMT. None of the models are capable of fully evaluating the
‘project’s effect on VMT’ or evaluating cumulative VMT impacts. Only CalEEMod, GreenTRIP Connect,
TRIMMS, and TDM+ evaluate the impacts of TDM strategies for VMT mitigation.
Tool Recommendations for North County Cities
According to the OPR technical advisory, the tools used to evaluate VMT must be consistent with the
methodology used to determine VMT thresholds. To maintain consistency between methods and
thresholds, we do not recommend using the available sketch planning tools off the shelf to estimate
project generated VMT for land use projects if thresholds are based on the OCTAM or SCAG model.
However, the sketch tools may be useful for evaluating the impacts of potential TDM strategies.
Of the available travel forecasting models, the SCAG model covers a larger area than OCTAM and would
limit the amount of trip length truncation that occurs at the model boundary. However, the model would
have less sensitivity for project-scale applications in North Orange County and would require more time
and effort to perform modeling runs. Both models require modifications to comply with the Technical
Advisory/CEQA expectations. Making these modifications to the OCTAM model would provide additional
benefits to the North Orange County agencies that use the model for other purposes. As such, the
OCTAM model should be consider the best available model to start with for SB 743 implementation.
We presume the OCTAM model would also be used to forecast VMT as an input to air quality, energy,
and greenhouse gas (GHG) impact analysis. As such, the North Orange County agencies will need to
verify all forms of the VMT metric desired from the model. The typical combination of VMT metrics
necessary for a complete analysis includes total VMT, total VMT per service population, home-based VMT
per resident, and home-based work VMT per employee. Since the model only produces weekday
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forecasts, all of these forms of the metric also represent typical weekday conditions. For SB 743 purposes,
total VMT or an efficiency form of the metric may be used. The Technical Advisory recommends different
efficiency metric forms depending on the type of land use (i.e., residential versus work) with
corresponding thresholds varying depending on the land use. We recommend preparing the model to
produces all of the VMT metric forms listed above.
For lead agencies that want to relying VMT impact screening as outlined in the Technical Advisory, we
would recommend the development of a customized screening and forecasting tool reflects the specific
transportation and land use context of the North County Cities by relying on OCTAM model inputs and
outputs. The tool could be used for the following assessment and forecasting steps.
· Identify the TAZ associated with the project location.
· Identify the local jurisdiction of the project, based on the project’s associated TAZ.
· Determine if the project meets screening criteria related to being located within a transit priority
area (TPA).
· Determine if project meets screening criteria related to being located within a low VMT
generating TAZ. This test would largely apply to residential and work-related land uses. Retail
land uses have a separate screening related to whether the project is local serving, which could be
based on size (e.g., less than 50,000 square feet). This step would rely on the model’s base year
(or baseline) estimate of the TAZ VMT per service population and would compare that value to
the proposed threshold measured at the jurisdictional or a reasonable sub-regional area (i.e.,
Valley, Mountain, or Desert regions).
· Provide baseline and cumulative estimates of project generated VMT if the project fails to be
screened out including VMT estimates for use in other sections of CEQA analysis, such as air
quality, greenhouse gases, and energy based on TAZ VMT averages.
Tool setup would include running the base year and future year scenarios of the travel demand model to
obtain VMT and land use data for each TAZ, jurisdiction, and reasonable sub-region. Key features of this
tool are described in Table 1.
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Table 1: VMT Screening and Forecasting Tool Specifications
Feature Description Elements Comments
Setup
inputs
Parcel boundaries,
TPA boundaries, and
travel demand model
data required to
prepare tool for use
· Parcel boundaries
· TPA boundaries
· Model data for each TAZ, jurisdiction, under base year
and future year conditions:
o Jurisdiction boundaries
o Land use, population, employment (and possibly
students)
o Total VMT
o Total VMT per service population
Only needs to
be updated
when model is
updated
Project
inputs
Data required for
each project
· Project baseline year (year Notice of Preparation is
filed)
· Land use, population, employment (and possibly
students)
· Is project consistent with General Plan? (yes/no)
· Is project consistent with RTP/SCS? (yes/no)
· Does the project consist exclusively of local serving
retail uses with a total project size of less than 50,000
square feet? (yes/no)
Tool
outputs
Results provided for
each project
· Does project satisfy screening criteria? If yes, basis for
determination
· Estimated project total VMT per service population
(project baseline and future years)
· Estimated project total VMT (project baseline and
future years)
VMT estimates
based on TAZ
average
For evaluating the impacts of TDM strategies for VMT mitigation, CalEEMod, GreenTRIP Connect, and
TDM+ are available sketch tools, but each as potential limitations. The data supporting the VMT
reductions associated with the TDM strategies in these tools is largely derived from urban areas. Their
application in suburban and especially rural areas may not be valid without a detailed assessment of how
the strategy is affected by the background land use context. As to individual tool limitations, GreenTrip
Connect only applies to residential projects with just a few TDM strategies. CalEEMod includes the TDM
strategies from Quantifying Greenhouse Gas Mitigation Strategies, CAPCOA, 2010, but has operational
issues noted in the tool review in Attachment A that can misrepresent project generated VMT. TDM+ also
includes the CAPCOA strategies plus recent ARB research documented in the “SB 743 Implementation
TDM Strategy Assessment,” June 11, 2018; however, this tool is proprietary and would need to be applied
through Fehr & Peers.
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ATTACHMENT A – Review of Available Sketch Models
FEHR & PEERS 9/20/2019 ATTACHMENT A: SKETCH MODEL TOOL APPLICABILITY FINDINGS Sketch Tool Output Defensibility Sensitivity Utility Comments User Experience: Benefits (UC Davis1) User Experience: Drawbacks (UC Davis1) Conclusions (UC Berkeley2) Conclusion CalEEMod VMT ++ Widespread use by air districts. Defensibility depends on use by others due to lack of documentation for trip lengths and known calculation problems. + Many parameters, but limited sensitivity to land use context, requires use of mitigation function to accurately represent mixed-use or infill projects, does not directly capture internalization, and mitigation function is not current or fully sensitive to TDM strategies. ++ Requires installation, which can cause errors due to older programming (not updated since 2016). Use of the tool is relatively straightforward but use of mitigation function is often necessary to accurately represent proposed projects. CAPCOA/Trinity Consultants product, may not be able to make changes. Many, customizable inputs; program interface reduces back-end error. Many, customizable inputs; defaults and land use categories may misrepresent project and/or context area. Easier data demands; difficult to determine location attributes, especially to avoid double counting; documentation did not provide enough guidance on method selection. Not recommended for VMT calculations but could be used for TDM mitigation evaluation. Sketch 7 % Change in VMT + Household (HH) VMT only. Hasn’t been updated since 2012. + No internalization, no TDM reduction, no trip purpose. Produces % change in VMT, generic place types. + Must have regional travel demand model data as input. Straightforward inputs & interface; system-level outputs; outputs include walk, bike, and transit trips. Spreadsheet interface can become “buggy”, break; regional TAZ data used to calibrate tool may be difficult to obtain. [Not reviewed] Not recommended. VMT Impact Tool/Salon % Change in VMT + HH VMT only + No internalization, no TDM reduction, no trip purpose. + Not intuitive as a project analysis tool. Scenario testing for census tract level & above; not project-level. [Not reviewed] [Not reviewed] [Not reviewed] Not recommended. GreenTRIP Connect VMT; Change in VMT + HH VMT only + Affordable housing, TDM credit for 4 strategies, ++ Easy to use, but limited to residential land uses. Would need to work with TransForm. Simple user interface; straightforward outputs. Measures only residential travel, even in mixed-use projects. [Not reviewed] Not recommended for VMT calculations, but could be used for TDM mitigation evaluation. Application in rural areas may not be valid. UrbanFootprint VMT ++ Uses MXD for trip generation. Trip lengths not based on observed data. ++ Many parameters. Sensitive to land use changes from adjacent parcels. No TDM reduction. + Robust tool but requires training to learn. California acquired licenses for all cities and counties. [Not reviewed] [Not reviewed] [Not reviewed] Not recommended. Envision Tomorrow VMT + Added parameters diluted research. ++ Many parameters. No TDM reduction. + Open source, complex spreadsheet tool. Primarily scenario planning; owned by Fregonese. [Not reviewed] [Not reviewed] [Not reviewed] Not recommended. CA Smart Growth Tool Trips ++ + No trip purposes, no TDM reduction. + Few, intuitive inputs with direction of where to find them. Calculates trips one land use at a time, and in limited context areas; calculates trips, not VMT. [Not reviewed] Not recommended. TRIMMS VMT ++ Used by SJCOG. ++ Includes TDM reductions for employees (not LU). + Has a few elements that do not exist in CAPCOA. [Not reviewed] [Not reviewed] [Not reviewed] Not recommended. MXD/MXD+ Trips +++ ++ Many parameters, no TDM reduction. ++ Simple inputs categories; straightforward outputs. Important input data may be difficult to find. High data input demands; obtaining data required GIS capability.3 Not recommended. VMT+ VMT + Educational Tool. + Limited parameters. ++ Easy to use. [Not reviewed] [Not reviewed] [Not reviewed] Not recommended. TDM+ % Change in VMT +++ CAPCOA-based. ++ ++ Only does TDM reductions; needs to be coupled with VMT estimator. Being updated based on new TDM research from ARB Net Zero Building Feasibility Study. [Not reviewed] [Not reviewed] [Not reviewed] Could be used for TDM mitigation evaluation. Application in rural areas may not be valid. Sources: Fehr & Peers, 2018; UC Davis, 2017; UC Berkeley, 2018. Notes: + = lowest score, +++ = highest score 1Amy Lee, Kevin Fang, and Susan Handy; “Evaluation of Sketch-Level Vehicle Miles Traveled (VMT) Quantification Tools,” National Center for Sustainable Transportation, August 2017. 2Elisa Barbour, Dan Chatman, Sarah Doggett, Stella Yip, and Manuel Santana; “SB 743 implementation: Challenges and Opportunities [Draft Final],” June 5, 2018. 3Analysis based on earlier, public spreadsheet tool; more advanced proprietary versions available.
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TECHNICAL MEMORANDUM
Date: 10.23.19
To: City of Orange, City of Fullerton, City of La Habra, City of Placentia, City of Brea, City of Buena
Park, and City of Yorba Linda
From: Jason Pack, PE and Delia Votsch, PE
Subject: SB 743 Implementation Mitigation and TDM Strategy Assessment OC19-0661
This technical memorandum summarizes our assessment of new research related to transportation
demand management (TDM) effectiveness for reducing vehicle miles of travel (VMT). The purpose of this
work was to understand what options are available to mitigate VMT, to compile new TDM information
that has been published in research papers since release of the Quantifying Greenhouse Gas Mitigation
Measures, CAPCOA, August 2010 and to identify those strategies suited to North Orange County Cities
jurisdictions given the varying land use context. The land use and transportation context for North Orange
County presents a challenge to the effectiveness of common TDM strategies for VMT reduction when
applied at individual project sites due to limited travel choices. The matrix in Attachment A summarizes
the overall evaluation of all the CAPCOA strategies while the matrix in Attachment B identifies the top
twelve strategies suited for the study area.
Mitigation Programs
The approach to the overall assessment includes two parts. The first part evaluated how VMT reduction
strategies or projects could be developed or incorporated into existing funding programs such as
Transportation Impact Fee (TIF) program. The purpose of incorporating VMT reduction strategies directly
into existing programs is to provide greater certainty and effectiveness for VMT impact mitigation. The
second part of the assessment identified potential new mitigation program concepts that may be worthy
of further evaluation.
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Existing Programs
The Cities of Fullerton, Yorba Linda, Brea, Buena Park, and Orange all maintain Traffic Impact Fees. The
City of La Habra maintains a Transportation Demand Management fee in addition to their Traffic
Improvement Program fee, and the City of Placentia collects a fee specific to Transit Oriented
Development (TOD) instead of their standard impact fee. Some areas within the City of Orange are also
subject to a fee from the Eastern Transportation Corridor Agency (TCA).
These programs collect a fair-share fee payment from new development to contribute to the cost of a
capital improvement program (CIP) consisting of long-term transportation network expansion projects
identified to accommodate planned population and employment growth. A common theme for the
existing programs is that they focus on vehicle trips or vehicle LOS as the key metric for determining
deficiencies and developing CIP projects although the City of La Habra Transportation Demand
Management fee includes non-vehicular TDM strategies and an active transportation element.
In their current form, most of the impact fees would not qualify as VMT impact mitigation programs. The
exception would be the City of La Habra Transportation Demand Management fee, as it could include
TDM strategies which effectively mitigate VMT impacts. However, most City’s CIPs include roadway
capacity expansion that contributes to VMT increases. Expanding roadway capacity in congested areas
induces new vehicle travel that diminishes congestion relief benefits and generates new VMT and
emissions. Refer to the following websites for more research information and technical details.
· http://www.dot.ca.gov/newtech/researchreports/reports/2015/10-12-2015-
NCST_Brief_InducedTravel_CS6_v3.pdf
· https://www.arb.ca.gov/cc/sb375/policies/hwycapacity/highway_capacity_brief.pdf
· https://trrjournalonline.trb.org/doi/abs/10.3141/2653-02
Many CIPs also include operational improvements, such as signal coordination projects, which would not
contribute to an increase in VMT. Most CIPs also include some transit, bicycle, and pedestrian projects
that could contribute to VMT reduction. For example, the following excerpts from the City of Buena Park
and City of Fullerton CIPs show the inclusion of a multimodal trail expansion, and a bicycle and pedestrian
safety program, respectively.
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If the transit, bicycle, and pedestrian projects were separated into a stand-alone CIP with a supporting
nexus study based on VMT reduction, then a new VMT fee program could be developed that is dedicated
to VMT impact mitigation. This could be a new program implemented by the North County Cities as a
collaborative or as individual jurisdictions. An example of this type of program has been developed the
City of Los Angeles as part of their Coastal Transportation Corridor Specific Plan and West Los Angeles
Transportation Improvement and Mitigation Specific Plan. Details are provided at the following website.
http://www.westsidemobilityplan.com/ctcspwla-timp-final-eir/
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It may also be possible for a development project applicant to fully fund a transit, bicycle, or pedestrian
project from a CIP as an alternative to paying the fee directly. Some fee programs currently allow fee
credits for development that expedites and completes CIP-identified projects. Using this option requires
inclusion of the mitigation in a development agreement or an EIR.
Managing and reducing demand could accomplish the goal of reducing peak period VMT. The main
source of congestion is typically defined as vehicles move too slowly (i.e., peak period speeds are lower
than posted speed limits). This definition of congestion describes a symptom and fails to recognize that
peak period travel consists of vehicles with poor seat utilization caused by not managing demand more
effectively and mispricing travel demand. The existing roadway network has a limited capacity and this
capacity is routinely filled up during peak periods in Orange County by vehicles with solo drivers (i.e., low
seat utilization). Further, limited facilities exist that prioritize travel by high occupancy vehicles. Increasing
vehicle speeds and reducing delays substantially requires much greater seat utilization in existing vehicles
(i.e., private vehicles and public transit). This change would also reduce VMT. Hence, refocusing on the
combination of congestion management and VMT reduction would result in a different CIP that could
qualify as VMT impact mitigation.
New Mitigation Program Concepts
Beyond the conventional programs described above are two new concepts that are not currently available
in North Orange County. For purposes of this study, these programs are defined as follows.
· VMT Mitigation Exchange – An exchange program is a concept where VMT generators can
select from a pre-approved list of mitigation projects that may be located within the same
jurisdiction or possibly from a larger area. The intent is to match the project’s needed VMT
reduction with a specific mitigation project of matching size and to provide evidence that the
VMT reduction will reasonably occur.
· VMT Mitigation Bank – A mitigation bank is intended to serve as an entity or organization that
pools fees from development projects across multiple jurisdictions to spend on larger scale
mitigation projects. This concept differs from the more conventional impact fee program
approach described above in that the fees are directed to a few larger projects that have the
potential for a more significant reduction in VMT and the program is regional in nature.
As these new mitigation program concepts are still evolving, the specific descriptions and elements of the
programs will likely change. The first resource document to describe and assess these programs was
recently published by U.C. Berkeley and is entitled, “Implementing SB 743, An Analysis of Vehicle Miles
Traveled Banking and Exchange Frameworks,” The University of California Institute of Transportation
Studies, October 2018. This document is a useful starting place for a dialogue about these programs.
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The findings of the report are supportive of these concepts noting the following about the reasoning for
their consideration.
Yet while methods for reducing VMT impacts—such as mileage pricing mechanisms, direct
investments in new public transit infrastructure, transit access subsidies, and infill development
incentives—are well understood, they may be difficult in some cases to implement as mitigation
projects directly linked or near to individual developments. As a result, broader and more flexible
approaches to mitigation may be necessary. In response, state and local policy makers are
considering the creation of mitigation “banks” or “exchanges.” In a mitigation bank, developers
would commit funds instead of undertaking specific on-site mitigation projects, and then a local or
regional authority could aggregate these funds and deploy them to top-priority mitigation projects
throughout the jurisdiction. Similarly, in a mitigation exchange, developers would be permitted to
select from a list of pre-approved mitigation projects throughout the jurisdiction (or propose their
own), without needing to mitigate their transportation impacts on-site. Both models can be applied
at a city, county, regional, and potentially state scale, depending on local development patterns,
transportation needs and opportunities, and political will.
This reasoning is important for lead agencies in North Orange County because mitigating VMT impacts on
a project-by-project basis is challenging especially in suburban land use contexts where travel choices are
limited. That said, the UCB report and research conducted for this study identified the following key
challenges with these types of programs.
· Challenges for Mitigation Exchanges
o Potential mismatch between funds and mitigation projects available
o Potential for reduced oversight of project selection
o Difficulty in verifying VMT reductions and their sustainability especially with VMT
generation changing over time due to disruptive transportation trends such as
transportation network companies (TNCs) and autonomous vehicles (AVs)
o Difficulty in demonstrating an essential nexus
o Potential opposition to mitigation not directly occurring in the project impact area
especially if impacts are concentrated in or near disadvantaged communities and the
mitigation occurs in more affluent areas
· Challenges for Mitigation Banks
o Increased need to conduct careful CEQA/Mitigation Fee Act analysis
o Accounting challenge in delay from fee payment to project funding
o Greater need for program administration budget
o Political difficulty in distributing mitigation projects and coordinating across jurisdictions
o Difficulty in verifying VMT reductions and their sustainability especially with VMT
generation changing over time due to disruptive transportation trends such as
transportation network companies (TNCs) and autonomous vehicles (AVs)
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o Difficulty in demonstrating an essential nexus
o Potential opposition to mitigation not directly occurring in the project impact area
especially if impacts are concentrated in or near disadvantaged communities and the
mitigation occurs in more affluent areas
Another important element for either of these concepts is to have an entity that is responsible for
establishing, operating, and maintaining the program. This is a potential role for a sub-regional or
regional entity especially for programs that would extend mitigation projects beyond individual
jurisdictional boundaries. A key part of ‘operations’ is that the entity will need the capability to provide
verification of the VMT reduction performance and to adjust the program projects over time. Whether
the entity is regional or sub-regional is another important consideration. A sub-regional entity could help
minimize potential concerns about mitigation not occurring near the project site or in the same
community.
The potential desire for VMT Mitigation Exchanges or Banks may depend on how lead agencies and
developers respond to the initial implementation of SB 743 currently schedule to go into effect July 1,
2020. If many projects are found to have significant VMT impacts and problems occur with finding
feasible mitigation measures for individual projects, then interest may grow for more program-based
mitigation.
TDM Strategies
This information can be used as part of the SB 743 implementation to determine potentially feasible VMT
mitigation measures for individual land use projects in North Orange County. An important consideration
for the mitigation effectiveness is the scale for TDM strategy implementation. The biggest effects of TDM
strategies on VMT (and resultant emissions) derive from regional policies related to land use location
efficiency and infrastructure investments that support transit, walking, and bicycling. While there are many
measures that can influence VMT and emissions that relate to site design and building operations, they
have smaller effects that are often dependent on final building tenants. Figure 1 presents a conceptual
illustration of the relative importance of scale.
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Figure 1: Transportation-Related GHG Reduction Measures
Of the 50 transportation measures presented in the CAPCOA 2010 report Quantifying Greenhouse Gas
Mitigation Measures, 41 are applicable at building and site level. The remaining nine are functions of, or
depend on, site location and/ or actions by local and regional agencies or funders. Table 1 summarizes
the strategies according to the scope of implementation and the agents who would implement them.
TABLE 1: SUMMARY OF TRANSPORTATION-RELATED CAPCOA MEASURES
Scope Agents CAPCOA Strategies (see full CAPCOA list below)
Building Operations Employer, Manager
26 total from five CAPCOA strategy groups:
· 3 from 3.2 Site Enhancements group
· 3 from 3.3 Parking Pricing Availability group
· 15 from 3.4 Commute Trip Reduction group
· 2 from 3.5 Transit Access group
· 3 from 3.7 Vehicle Operations group
Site Design Owner, Architect
15 total from three strategy groups:
· 6 from 3.1 Land Use group
· 6 from 3.2 Site Enhancements group
· 1 from 3.3 Parking group
· 2 from 3.6 Road Access group
Location Efficiency Developer, Local
Agency 3 shared with Regional and Local Policies
Alignment with Regional and
Local Policies
Regional and local
agencies 3 shared with Location Efficiency
Regional Infrastructure and
Services
Regional and local
agencies 6 total
Of these strategies, some are likely to be effective in denser areas, while others will be less applicable in
rural or suburban setting. In North Orange County, key factors that determine which reduction measures
will be effective such as density and access to transit vary throughout and within the jurisdictions. To help
narrow the list, we reviewed how land use context could influence each strategy’s effectiveness and
identified the twelve for more detailed review. Of these 12 strategies, 5 have been identified as most
appropriate for transit-rich or “downtown” contexts, and the remaining 7 strategies have been identified
Building Operations
Site Design
Location Efficiency
Regional Policies
Regional Infrastructure
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as appropriate for denser, transit- rich neighborhoods and more residential areas. These strategies are
described in Attachment B and listed below. Please note that disruptive trends, including but not limited
to, transportation network companies (TNCs), autonomous vehicles (AVs), internet shopping, and micro-
transit may affect the future effectiveness of these strategies.
1. Increase diversity of land uses – This strategy is appropriate for both downtown and suburban
contexts and focuses on inclusion of mixed uses within projects or in consideration of the
surrounding area to minimize vehicle travel in terms of both the number of trips and the length of
those trips.
2. Increase Transit Accessibility – This strategy is most appropriate for downtown contexts only
and focuses on establishing Transit Oriented Development (TOD) within ½ mile of high-quality
transit, with connected facilities for walking and biking.
3. Provide pedestrian network improvements – This strategy is appropriate for both downtown and
suburban contexts and focuses on creating a pedestrian network within the project and
connecting to nearby destinations. Projects in the North Orange County area range in size, so the
emphasis of this strategy for smaller projects would likely be the construction of network
improvements that connect the project sites directly to nearby destinations. For larger projects,
this strategy could focus on the development of a robust pedestrian network within the project
itself. Alternatively, implementation could occur through an impact fee program such as the
TUMF or benefit/assessment district based on local or regional plans.
4. Provide traffic calming measures and low-stress bicycle network improvements – This strategy is
appropriate for both downtown and suburban contexts and combines the CAPCOA research
focused on traffic calming with new research on providing a low-stress bicycle network. Traffic
calming creates networks with low vehicle speeds and volumes that are more conducive to
walking and bicycling. Building a low-stress bicycle network produces a similar outcome.
Implementation options are similar to strategy 2 above. One potential change in this strategy
over time is that e-bikes (and e-scooters) could extend the effective range of travel on the bicycle
network, which could enhance the effectiveness of this strategy.
5. Implement car-sharing program – This strategy is appropriate for both downtown and suburban
contexts and reduces the need to own a vehicle or reduces the number of vehicles owned by a
household by making it convenient to access a shared vehicle for those trips where vehicle use is
essential. Note that implementation of this strategy would require regional or local agency
implementation and coordination and would not likely be applicable for individual development
projects.
6. Implement Market Price Public Parking - This strategy is most appropriate for downtown
contexts only and focuses on pricing all central business district/employment center/retail center
public parking to encourage behavior where patrons park once and visit multiple destinations.
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7. Expand Transit Network - This strategy is most appropriate for downtown contexts only and
reduces vehicle trips by increasing existing transit service hours and coverage. This creates a more
convenient experience for transit riders and encourages higher rates of transit ridership. Please
refer to the discussion below in “Increase transit service frequency and speed” for discussion of
alternative options for demand-responsive service. Note that implementation of this strategy
would require regional or local agency implementation, substantial changes to current transit
practices, and would not likely be applicable for individual development projects.
8. Increase transit service frequency and speed – This strategy is appropriate for both downtown
and suburban contexts and focuses on improving transit service convenience and travel time
competitiveness with driving. While the North Orange County area has fixed route rail and bus
service that could be enhanced, it’s also possible that new forms of low-cost demand-responsive
transit service could be provided. The demand-responsive service could be provided as
subsidized trips by contracting to private TNCs or Taxi companies. Alternatively, a public transit
operator could provide the subsidized service but would need to improve on traditional cost
effectiveness by relying on TNC ride-hailing technology, using smaller vehicles sized to demand,
and flexible driver employment terms where drivers are paid by trip versus by hour. This type of
service would reduce wait times for travelers and improve the typical in-vehicle travel time
compared to traditional transit. Note that implementation of this strategy would require regional
or local agency implementation, substantial changes to current transit practices, and would not
likely be applicable for individual development projects.
9. Provide a Bus Rapid Transit System - This strategy is most appropriate for downtown contexts
only and reduces vehicle trips by converting a standard bus system to a Bus Rapid Transit (BRT)
system. This provides a dedicated travel lane for buses, and improves travel time for buses.
implementation of this strategy would require regional or local agency implementation,
substantial changes to current transit practices, and would not likely be applicable for individual
development projects.
10. Implement Subsidized or Discounted Transit Program - This strategy is most appropriate for
downtown contexts only and focuses on incentivizing employees, students, or residents to take
transit by subsidizing their transit fare. The effectiveness of the strategy depends on the ultimate
building tenants and this should be a factor in considering the potential VMT reduction.
11. Encourage telecommuting and alternative work schedules – This strategy is appropriate for both
downtown and suburban contexts and relies of effective internet access and speeds to
individual project sites/buildings to provide the opportunity for telecommuting. The effectiveness
of the strategy depends on the ultimate building tenants and this should be a factor in
considering the potential VMT reduction.
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12. Provide ride-sharing programs – This strategy is appropriate for both downtown and suburban
contexts and focuses on encouraging carpooling and vanpooling by project site/building tenants
and has similar limitations as strategy 10 above.
Because of the limitations noted above, strategies 1, 2, 3, 4, 10, 11, and 12 are initially considered the
highest priorities for individual land use project mitigation subject to review and discussion with the
project team.
The VMT reduction strategies can be quantified using CACPOA calculation methodologies and recent ARB
research findings. Attachment C provides calculation methodologies for each of the mitigations provided
above, along with their range of effectiveness.
Summary
To help understand the full range of VMT impact mitigation and their benefits and challenges, Table 2
provides a high-level summary comparison.
11 | P a g e Table 2 – Summary of VMT Impact Mitigation Options Mitigation Option Description Benefits Challenges No feasible action This option recognizes that feasible mitigation is not available due to the land use or transportation context. - Recognizes the limitations of VMT impact mitigation when alternatives to driving are not reasonably available. Could result in more significant and unavoidable (SAU) impacts that require an EIR instead of a negative declaration. Change project This option would tend to focus on changing built environment characteristics of a project such as its land use density or diversity to reduce vehicle travel. - Mitigation may not require long-term monitoring (see substantial evidence summarized in the SB 743 Implementation TDM Strategy Assessment Technical Memorandum dated 6.11.18). - Mitigation reduces VMT (and other vehicle travel) in immediate vicinity of the project site. Project applicants may resist land use or other built environment changes due to financial concerns and market feasibility. TDM This option relies on strategies to reduce vehicle travel through incentives and disincentives often tied to the cost and convenience of vehicle travel. - Mitigation reduces VMT (and other vehicle travel) in immediate vicinity of the project site. - Multiple mitigation strategies to choose from such that a project applicant may find co-benefits from the strategies also serving as project amenities. - Mitigation monitoring required because effectiveness depends on building tenants, which can change over time. As a result, impacts will remain SAU. - Creates potential financial equity issues between existing and new land uses. Existing land use with TDM mitigation will have lower operating costs. - Limited reduction based on applicable or relevant strategies
12 | P a g e Table 2 – Summary of VMT Impact Mitigation Options Mitigation Option Description Benefits Challenges Impact fee program This option requires developing a new impact fee program with a nexus based on VMT reduction. This type of nexus would allow the fee program capital improvement program (CIP) to include transit, bicycle, pedestrian and other types of projects that can demonstrate VMT reduction effectiveness. - Provides clear expectations for developers about the VMT mitigation costs. - Increases funding for VMT reduction projects such that larger and more effective projects may be implemented. - May result in greater levels of VMT reduction compared to project-by-project mitigation. - Requires lead agency to develop stakeholder support and funding to create and maintain the fee program. - Mitigation (e.g., CIP projects) may not occur in immediate vicinity of the project site where impacts of vehicle travel will be most directly felt by neighbors. Mitigation bank/exchange This option matches VMT generators with VMT reducers within or beyond jurisdictional boundaries through a third party. - Could create mitigation options that may not otherwise be available or feasible. - Not limited to jurisdictional boundaries. - Could create incentive for new innovative mitigation ideas. - Requires an entity capable of operating and maintaining the program with the ability to verify VMT reductions. - Mitigation may not occur in immediate vicinity of the project site where impacts of vehicle travel will be most directly felt by neighbors. General plan coverage This option would address VMT impacts through a general plan update or amendment EIR and rely on CEQA Guidelines Section 15183 for subsequent project streamlining (as summarized in the SB 743 Implementation Thresholds Assessment Technical Memorandum dated 10.31.18). - Addresses VMT reduction expectations in consideration of other jurisdictional objectives. - Offers a wider range of mitigation options than at the project-scale. - For subsequent projects consistent with the general plan, additional VMT impact analysis would not be required. - General plan updates or amendments require substantial time and funding commitments.
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ATTACHMENT A
New informationChange in VMT reduction compared to CAPCOA Literature or Evidence CitedLand Use/Location 3.1.1 LUT-1 Increase Density 0.8% - 30% VMT reduction due to increase in densityAdequate Increasing residential density is associated with lower VMT per capita. Increased residential density in areas with high jobs access may have a greater VMT change than increases in regions with lower jobs access. The range of reductions is based on a range of elasticities from -0.04 to -0.22. The low end of the reductions represents a -0.04 elasticity of demand in response to a 10% increase in residential units or employment density and a -0.22 elasticity in response to 50% increase to residential/employment density. 0.4% -10.75% Primary sources:Boarnet, M. and Handy, S. (2014). Impacts of Residential Density on Passenger Vehicle Use and Greenhouse Gas Emissions - Policy Brief and Technical Background Document. California Air Resources Board. Retrieved from: https://arb.ca.gov/cc/sb375/policies/policies.htmSecondary source:Stevens, M. (2017). Does Compact Development Make People Drive Less? Journal of the American Planning Association, 83(1), 7-18.Land Use/Location 3.1.9 LUT-9 Improve Design of Development 3.0% - 21.3% reduction in VMT due to increasing intersection density vs. typical ITE suburban developmentAdequate No update to CAPCOA literature; advise applying CAPCOA measure only to large developments with significant internal street structure.Same N/ALand Use/Location 3.1.4 LUT-4 Increase Destination Accessibility6.7%-20% VMT reduction due to decrease in distance to major job center or downtownAdequate Reduction in VMT due to increased regional accessibility (jobs gravity). Locating new development in areas with good access to destinations reduces VMT by reducing trip lengths and making walking, biking, and transit trips more feasible. Destination accessibility is measured in terms of the number of jobs (or other attractions) reachable within a given travel time, which tends to be highest at central locations and lowest at peripheral ones.0.5%-12% Primary sources:Handy, S. et al. (2014). Impacts of Network Connectivity on Passenger Vehicle Use and Greenhouse Gas Emissions - Policy Brief and Technical Background Document. California Air Resources Board. Retrieved from: https://arb.ca.gov/cc/sb375/policies/policies.htmHandy, S. et al. (2013). Impacts of Regional Accessibility on Passenger Vehicle Use and Greenhouse Gas Emissions - Policy Brief and Technical Background Document. California Air Resources Board. Retrieved from: https://arb.ca.gov/cc/sb375/policies/policies.htmSecondary source:Holtzclaw, et al. (2002.) Location Efficiency: Neighborhood and Socioeconomic Characteristics Determine Auto Ownership and Use – Studies in Chicago, Los Angeles, and Chicago. Transportation Planning and Technology, Vol. 25, pp. 1–27.TDM STRATEGY EVALUATION - DRAFT V 1.0Comparison of CAPCOA Strategies Versus New Research Since 2010New Information Since CAPCOA Was Published in 2010CAPCOA Category CAPCOA # CAPCOA Strategy CAPCOA ReductionStrength of Substantial Evidence for CEQA Impact Analysis?
New informationChange in VMT reduction compared to CAPCOA Literature or Evidence CitedTDM STRATEGY EVALUATION - DRAFT V 1.0Comparison of CAPCOA Strategies Versus New Research Since 2010New Information Since CAPCOA Was Published in 2010CAPCOA Category CAPCOA # CAPCOA Strategy CAPCOA ReductionStrength of Substantial Evidence for CEQA Impact Analysis?Land Use/ Location 3.1.3 LUT-3 Increase Diversity of Urban and Suburban Developments 9%-30% VMT reduction due to mixing land uses within a single developmentAdequate 1] VMT reduction due to mix of land uses within a single development. Mixing land uses within a single development can decrease VMT (and resulting GHG emissions), since building users do not need to drive to meet all of their needs. 2] Reduction in VMT due to regional change in entropy index of diversity. Providing a mix of land uses within a single neighborhood can decrease VMT (and resulting GHG emissions), since trips between land use types are shorter and may be accommodated by non-auto modes of transport. For example when residential areas are in the same neighborhood as retail and office buildings, a resident does not need to travel outside of the neighborhood to meet his/her trip needs. At the regional level, reductions in VMT are measured in response to changes in the entropy index of land use diversity.1] 0%-12% 2] 0.3%-4% 1] Ewing, R. and Cervero, R. (2010). Travel and the Built Environment - A Meta-Analysis. Journal of the American Planning Association,76(3),265-294. Cited in California Air Pollution Control Officers Association. (2010).Quantifying Greenhouse Gas Mitigation Measures. Retrieved from: http://www.capcoa.org/wp-content/uploads/2010/11/CAPCOA-Quantification-Report-9-14-Final.pdfFrank, L., Greenwald, M., Kavage, S. and Devlin, A. (2011). An Assessment of Urban Form and Pedestrian and Transit Improvements as an Integrated GHG Reduction Strategy. WSDOT Research Report WA-RD 765.1. Washington State Department of Transportation. Retrieved from: http://www.wsdot.wa.gov/research/reports/fullreports/765.1.pdfNasri, A. and Zhang, L. (2012). Impact of Metropolitan-Level Built Environment on Travel Behavior. Transportation Research Record: Journal of the Transportation Research Board, 2323(1), 75-79.Sadek, A. et al. (2011). Reducing VMT through Smart Land-Use Design. New York State Energy Research and Development Authority. Retrieved from: https://www.dot.ny.gov/divisions/engineering/technical-services/trans-r-and-d-repository/C-08-29%20Final%20Report_December%202011%20%282%29.pdf Spears, S.et al. (2014). Impacts of Land-Use Mix on Passenger Vehicle Use and Greenhouse Gas Emissions- Policy Brief and Technical Background Document. California Air Resources Board. Retrieved from: https://arb.ca.gov/cc/sb375/policies/policies.htm2] Zhang, Wengia et al. "Short- and Long-Term Effects of Land Use on Reducing Personal Vehicle Miles of Travel."Land Use/ Location 3.1.5 LUT-5 Increase Transit Accessibility 0.5%-24.6% reduce in VMT due to locating a project near high-quality transitAdequate 1] VMT reduction when transit station is provided within 1/2 mile of development (compared to VMT for sites located outside 1/2 mile radius of transit). Locating high density development within 1/2 mile of transit will facilitate the use of transit by people traveling to or from the Project site. The use of transit results in a mode shift and therefore reduced VMT.2] Reduction in vehicle trips due to implementing TOD. A project with a residential/commercial center designed around a rail or bus station, is called a transit-oriented development (TOD). The project description should include, at a minimum, the following design features:• A transit station/stop with high-quality, high-frequency bus service located within a 5-10 minute walk (or roughly ¼ mile from stop to edge of development), and/or• A rail station located within a 20 minute walk (or roughly ½ mile from station to edge of development)• Fast, frequent, and reliable transit service connecting to a high percentage of regional destinations• Neighborhood designed for walking and cycling1] 0%-5.8% 2] 0%-7.3% 1] Lund, H. et al. (2004). Travel Characteristics of Transit-Oriented Development in California. Oakland, CA: Bay Area Rapid Transit District, Metropolitan Transportation Commission, and Caltrans. Tal, G. et al. (2013). Policy Brief on the Impacts of Transit Access (Distance to Transit) Based on a Review of the Empirical Literature. California Air Resources Board. Retrieved from: https://www.arb.ca.gov/cc/sb375/policies/transitaccess/transit_access_brief120313.pdf2] Zamir, K. R. et al. (2014). Effects of Transit-Oriented Development on Trip Generation, Distribution, and Mode Share in Washington, D.C., and Baltimore, Maryland. Transportation Research Record: Journal of the Transportation Research Board. 2413, 45–53. DOI: 10.3141/2413-05Land Use/ Location 3.1.6 LUT-6 Integrate Affordable and Below Market Rate Housing0.04%-1.20% reduction in VMT for making up to 30% of housing units BMRWeak - Should only be used where supported by local data on affordable housing trip generation.Observed trip generation indicates substantial local and regional variation in trip making behavior at affordable housing sites. Recommend use of ITE rates or local data for senior housing.N/A “Draft Memorandum: Infill and Complete Streets Study, Task 2.1: Local Trip Generation Study.” Measuring the Miles: Developing new metrics for vehicle travel in LA. City of Los Angeles, April 19, 2017.
New informationChange in VMT reduction compared to CAPCOA Literature or Evidence CitedTDM STRATEGY EVALUATION - DRAFT V 1.0Comparison of CAPCOA Strategies Versus New Research Since 2010New Information Since CAPCOA Was Published in 2010CAPCOA Category CAPCOA # CAPCOA Strategy CAPCOA ReductionStrength of Substantial Evidence for CEQA Impact Analysis?Neighborhood Site Enhancements3.2.1 SDT-1 Provide Pedestrian Network Improvements0%-2% reduction in VMT for creating a connected pedestrian network within the development and connecting to nearby destinationsAdequateVMT reduction due to provision of complete pedestrian networks. Only applies if located in an area that may be prone to having a less robust sidewalk network. 0.5%-5.7% Handy, S. et al. (2014). Impacts of Pedestrian Strategies on Passenger Vehicle Use and Greenhouse Gas Emissions - Policy Brief and Technical Background Document. California Air Resources Board. Retrieved from: https://arb.ca.gov/cc/sb375/policies/policies.htmNeighborhood Site Enhancements3.2.2 SDT-2 Provide Traffic Calming Measures0.25%-1% VMT reduction due to traffic calming on streets within and around the developmentAdequate Reduction in VMT due to expansion of bike networks in urban areas. Strategy only applies to bicycle facilities that provide a dedicated lane for bicyclists or a completely separated right-of-way for bicycles and pedestrians. Project-level definition: Enhance bicycle network citywide (or at similar scale), such that a building entrance or bicycle parking is within 200 yards walking or bicycling distance from a bicycle network that connects to at least one of the following: at least 10 diverse uses; a school or employment center, if the project total floor area is 50% or more residential; or a bus rapid transit stop, light or heavy rail station, commuter rail station, or ferry terminal. All destinations must be 3-mile bicycling distance from project site. Include educational campaigns to encourage bicycling. 0%-1.7% Zahabi, S. et al. (2016). Exploring the link between the neighborhood typologies, bicycle infrastructure and commuting cycling over time and the potential impact on commuter GHG emissions. Transportation Research Part D: Transport and Environment. 47, 89-103.Neighborhood Site Enhancements3.2.3 SDT-3 Implement an NEV Network 0.5%-12.7% VMT reduction for GHG-emitting vehicles, depending on level of local NEV penetrationWeak - not recommended without supplemental data.Limited evidence and highly limited applicability. Use with supplemental data only.N/A City of Lincoln, MHM Engineers & Surveyors, Neighborhood Electric Vehicle Transportation Program Final Report, Issued 04/05/05, and City of Lincoln, A Report to the California Legislature as required by Assembly Bill 2353, Neighborhood Electric Vehicle Transportation Plan Evaluation, January 1, 2008. Cited in: California Air Pollution Control Officers Association. (2010). Quantifying Greenhouse Gas Mitigation Measures. Retrieved from: http://www.capcoa.org/wp-content/uploads/2010/11/CAPCOA-Quantification-Report-9-14-Final.pdfNeighborhood Site Enhancements3.4.9 TRT-9 Implement Car-Sharing Program 0.4% - 0.7% VMT reduction due to lower vehicle ownership rates and general shift to non-driving modesAdequate Vehicle trip reduction due to car-sharing programs; reduction assumes 1%-5% penetration rate. Implementing car-sharing programs allows people to have on-demand access to a shared fleet of vehicles on an as-needed basis, as a supplement to trips made by non-SOV modes. Transit station-based programs focus on providing the “last-mile” solution and link transit with commuters’ final destinations. Residential-based programs work to substitute entire household based trips. Employer-based programs provide a means for business/day trips for alternative mode commuters and provide a guaranteed ride home option. The reduction shown here assumes a 1%-5% penetration rate. 0.3%-1.6% Lovejoy, K. et al. (2013). Impacts of Carsharing on Passenger Vehicle Use and Greenhouse Gas Emissions - Policy Brief and Technical Background Document. California Air Resources Board. Retrieved from: https://arb.ca.gov/cc/sb375/policies/policies.htm Need to verify with more recent UCD research.
New informationChange in VMT reduction compared to CAPCOA Literature or Evidence CitedTDM STRATEGY EVALUATION - DRAFT V 1.0Comparison of CAPCOA Strategies Versus New Research Since 2010New Information Since CAPCOA Was Published in 2010CAPCOA Category CAPCOA # CAPCOA Strategy CAPCOA ReductionStrength of Substantial Evidence for CEQA Impact Analysis?Parking Pricing 3.3.1 PDT-1 Limit Parking Supply 5%-12.5% VMT reduction in response to reduced parking supply vs. ITE parking generation rateWeak - not recommended. Fehr & Peers has developed new estimates for residential land use only that may be used.CAPCOA reduction range derived from estimate of reduced vehicle ownership, not supported by observed trip or VMT reductions. Evidence is available for mode shift due to presence/absence of parking in high-transit urban areas; additional investigation ongoingHigher Fehr & Peers estimated a linear regression formula based on observed data from multiple locations. Resulting equation produces maximum VMT reductions for residential land use only of 30% in suburban locations and 50% in urban locations based on parking supply percentage reductions.Parking Pricing 3.3.2 PDT-2 Unbundle Parking Costs from Property Cost2.6% -13% VMT reduction due to decreased vehicle ownership ratesAdequate - conditional on the agency not requiring parking minimums and pricing/managing on-street parking (i.e., residential parking permit districts, etc.).Reduction in VMT, primarily for residential uses, based on range of elasticities for vehicle ownership in response to increased residential parking fees. Does not account for self-selection. Only applies if the city does not require parking minimums and if on-street parking is priced and managed (i.e., residential parking permit districts). 2%-12% Victoria Transport Policy Institute (2009). Parking Requirement Impacts on Housing Affordability. Retrieved March 2010 from: http://www.vtpi.org/park-hou.pdf.Parking Pricing 3.3.3 PDT-3 Implement Market Price Public Parking 2.8%-5.5% VMT reduction due to "park once" behavior and disincentive to drivingAdequate Implement a pricing strategy for parking by pricing all central business district/employment center/retail center on-street parking. It will be priced to encourage park once" behavior. The benefit of this measure above that of paid parking at the project only is that it deters parking spillover from project supplied parking to other public parking nearby, which undermine the vehicle miles traveled (VMT) benefits of project pricing. It may also generate sufficient area-wide mode shifts to justify increased transit service to the area. VMT reduction applies to VMT from visitor/customer trips only. Reductions higher than top end of range from CAPCOA report apply only in conditions with highly constrained on-street parking supply and lack of comparably-priced off-street parking.2.8%-14.5% Clinch, J.P. and Kelly, J.A. (2003). Temporal Variance Of Revealed Preference On-Street Parking Price Elasticity. Dublin: Department of Environmental Studies, University College Dublin. Retrieved from: http://www.ucd.ie/gpep/research/workingpapers/2004/04-02.pdf. Cited in Victoria Transport Policy Institute (2017). Transportation Elasticities: How Prices and Other Factors Affect Travel Behavior. Retrieved from: http://www.vtpi.org/tdm/tdm11.htmHensher, D. and King, J. (2001). Parking Demand and Responsiveness to Supply, Price and Location in Sydney Central Business District. Transportation Research A. 35(3), 177-196.Millard-Ball, A. et al. (2013). Is the curb 80% full or 20% empty? Assessing the impacts of San Francisco's parking pricing experiment. Transportation Research Part A. 63(2014), 76-92. Shoup, D. (2011). The High Cost of Free Parking. APA Planners Press. p. 290. Cited in Pierce, G. and Shoup, D. (2013). Getting the Prices Right. Journal of the American Planning Association. 79(1), 67-81. Transit System 3.5.3 TST-3 Expand Transit Network 0.1-8.2% VMT reduction in response to increase in transit network coverageAdequate Reduction in vehicle trips due to increased transit service hours or coverage. Low end of reduction is typical of project-level implementation (payment of impact fees and/or localized improvements).0.1%-10.5% Handy, S. et al. (2013). Impacts of Transit Service Strategies on Passenger Vehicle Use and Greenhouse Gas Emissions - Policy Brief and Technical Background Document. California Air Resources Board. Retrieved from: https://arb.ca.gov/cc/sb375/policies/policies.htmTransit System 3.5.4 TST-4 Increase Transit Service Frequency/Speed0.02%-2.5% VMT reduction due to reduced headways and increased speed and reliabilityAdequate Reduction in vehicle trips due to increased transit frequency/decreased headway. Low end of reduction is typical of project-level implementation (payment of impact fees and/or localized improvements).0.3%-6.3% Handy, S. et al. (2013). Impacts of Transit Service Strategies on Passenger Vehicle Use and Greenhouse Gas Emissions - Policy Brief and Technical Background Document. California Air Resources Board. Retrieved from: https://arb.ca.gov/cc/sb375/policies/policies.htmTransit System 3.5.1 TST-1 Provide a Bus Rapid Transit System0.02%-3.2% VMT reduction by converting standard bus system to BRT systemAdequate No new information identified. Same N/A
New informationChange in VMT reduction compared to CAPCOA Literature or Evidence CitedTDM STRATEGY EVALUATION - DRAFT V 1.0Comparison of CAPCOA Strategies Versus New Research Since 2010New Information Since CAPCOA Was Published in 2010CAPCOA Category CAPCOA # CAPCOA Strategy CAPCOA ReductionStrength of Substantial Evidence for CEQA Impact Analysis?Commute Trip Reduction3.4.1 TRT-1 Implement CTR Program - Voluntary1.0%-6.2% commute VMT reduction due to employer-based mode shift programAdequate - Effectiveness is building/tenant specific. Do not use with "TRT-2 Implement CTR Program - Required Implementation/Monitoring" or with CAPCOA strategies TRT-3.4.3 through TRT-3.4.9.Reduction in vehicle trips in response to employer-led TDM programs. The CTR program should include all of the following to apply the effectiveness reported by the literature:• Carpooling encouragement• Ride-matching assistance• Preferential carpool parking• Flexible work schedules for carpools• Half time transportation coordinator• Vanpool assistance• Bicycle end-trip facilities (parking, showers and lockers)1.0%-6.0% Boarnet, M. et al. (2014). Impacts of Employer-Based Trip Reduction Programs and Vanpools on Passenger Vehicle Use and Greenhouse Gas Emissions - Policy Brief and Technical Background Document. California Air Resources Board. Retrieved from: https://arb.ca.gov/cc/sb375/policies/policies.htmCommute Trip Reduction3.4.2 TRT-2 Implement CTR Program - Required Implementation/Monitoring4.2%-21.0% commute VMT reduction due to employer-based mode shift program with required monitoring and reportingAdequate - Effectiveness is building/tenant specific. Do not use with "TRT-1 Implement CTR Program - Voluntary" or with CAPCOA strategies TRT-3.4.3 through TRT-3.4.9. Limited evidence available. Anecdotal evidence shows high investment produces high VMT/vehicle trip reductions at employment sites with monitoring requirements and specific targets.Same Nelson/Nygaard (2008). South San Francisco Mode Share and Parking Report for Genentech, Inc.(p. 8) Cited in: California Air Pollution Control Officers Association. (2010). Quantifying Greenhouse Gas Mitigation Measures. Retrieved from: http://www.capcoa.org/wp-content/uploads/2010/11/CAPCOA-Quantification-Report-9-14-Final.pdfCommute Trip Reduction3.4.4 TRT-4 Implement Subsidized or Discounted Transit Program0.3%-20% commute VMT reduction due to transit subsidy of up to $6/dayAdequate - Effectiveness is building/tenant specific. Do not use with "TRT-1 Implement CTR Program - Voluntary" or "TRT-2 Implement CTR Program - Required Implementation/Monitoring." 1] Reduction in vehicle trips in response to reduced cost of transit use, assuming that 10-50% of new bus trips replace vehicle trips; 2] Reduction in commute trip VMT due to employee benefits that include transit 3] Reduction in all vehicle trips due to reduced transit fares system-wide, assuming 25% of new transit trips would have been vehicle trips. 1] 0.3%-14%2] 0-16%3] 0.1% to 6.9%1] Victoria Transport Policy Institute. (2017). Understanding Transport Demands and Elasticities. Online TDM Encyclopedia. Retrieved from: http://www.vtpi.org/tdm/tdm11.htm2] Carolina, P. et al. (2016). Do Employee Commuter Benefits Increase Transit Ridership? Evidence rom the NY-NJ Region. Washington, DC: Transportation Research Board, 96th Annual Meeting.3] Handy, S. et al. (2013). Impacts of Transit Service Strategies on Passenger Vehicle Use and Greenhouse Gas Emissions - Policy Brief and Technical Background Document. California Air Resources Board. Retrieved from: https://arb.ca.gov/cc/sb375/policies/policies.htmCommute Trip Reduction3.4.15 TRT-15 Employee Parking Cash-Out 0.6%-7.7% commute VMT reduction due to implementing employee parking cash-outWeak - Effectiveness is building/tenant specific. Research data is over 10 years old (1997). Shoup case studies indicate a reduction in commute vehicle trips due to implementing cash-out without implementing other trip-reduction strategies. 3%-7.7% Shoup, D. (1997). Evaluating the Effects of Cashing Out Employer-Paid Parking: Eight Case Studies. Transport Policy. California Air Resources Board. Retrieved from: https://www.arb.ca.gov/research/apr/past/93-308a.pdf. This citation was listed as an alternative literature in CAPCOA.Commute Trip Reduction3.4.14 TRT-14 Price Workplace Parking 0.1%-19.7% commute VMT reduction due to mode shift Adequate - Effectiveness is building/tenant specific. Reduction in commute vehicle trips due to priced workplace parking; effectiveness depends on availability of alternative modes. Workplace parking pricing may include: explicitly charging for parking, implementing above market rate pricing, validating parking only for invited guests, not providing employee parking and transportation allowances, and educating employees about available alternatives.0.5%-14% Primary sources:Concas, S. and Nayak, N. (2012), A Meta-Analysis of Parking Price Elasticity. Washington, DC: Transportation Research Board, 2012 Annual Meeting.Dale, S. et al. (2016). Evaluating the Impact of a Workplace Parking Levy on Local Traffic Congestion: The Case of Nottingham UK. Washington, DC: Transportation Research Board, 96th Annual Meeting.Secondary sources:Victoria Transport Policy Institute. (2017). Understanding Transport Demands and Elasticities. Online TDM Encyclopedia. Retrieved from: http://www.vtpi.org/tdm/tdm11.htmSpears, S. et al. (2014). Impacts of Parking Pricing on Passenger Vehicle Use and Greenhouse Gas Emissions - Policy Brief and Technical Background Document. California Air Resources Board. Retrieved from: https://arb.ca.gov/cc/sb375/policies/policies.htmCommute Trip Reduction3.4.6 TRT-6 Encourage Telecommuting and Alternative Work Schedules0.07%-5.5% commute VMT reduction due to reduced commute tripsAdequate - Effectiveness is building/tenant specific. Do not use with "TRT-1 Implement CTR Program - Voluntary" or "TRT-2 Implement CTR Program - Required Implementation/Monitoring." VMT reduction due to adoption of telecommuting. Alternative work schedules could take the form of staggered starting times, flexible schedules, or compressed work weeks.0.2%-4.5% Handy, S. et al. (2013). Policy Brief on the Impacts of Telecommuting Based on a Review of the Empirical Literature. California Air Resources Board. Retrieved from: https://www.arb.ca.gov/cc/sb375/policies/telecommuting/telecommuting_brief120313.pdf
New informationChange in VMT reduction compared to CAPCOA Literature or Evidence CitedTDM STRATEGY EVALUATION - DRAFT V 1.0Comparison of CAPCOA Strategies Versus New Research Since 2010New Information Since CAPCOA Was Published in 2010CAPCOA Category CAPCOA # CAPCOA Strategy CAPCOA ReductionStrength of Substantial Evidence for CEQA Impact Analysis?Commute Trip Reduction3.4.7 1] TRT-7 Implement CTR Marketing2] Launch Targeted Behavioral Interventions0.8%-4.0% commute VMT reduction due to employer marketing of alternativesAdequate - Effectiveness is building/tenant specific. Do not use with "TRT-1 Implement CTR Program - Voluntary" or "TRT-2 Implement CTR Program - Required Implementation/Monitoring." 1] Vehicle trips reduction due to CTR marketing; 2] Reduction in VMT from institutional trips due to targeted behavioral intervention programs1] 0.9% to 26%2] 1%-6% 1] Pratt, Dick. Personal communication regarding the Draft of TCRP 95 Traveler Response to Transportation System Changes – Chapter 19 Employer and Institutional TDM Strategies. Transit Cooperative Research Program. Cited in California Air Pollution Control Officers Association. (2010).Quantifying Greenhouse Gas Mitigation Measures. Retrieved from: http://www.capcoa.org/wp-content/uploads/2010/11/CAPCOA-Quantification-Report-9-14-Final.pdfDill, J. and Mohr, C. (2010). Long-Term Evaluation of Individualized Marketing Programs for Travel Demand Management. Portland, OR: Transportation Research and Education Center (TREC). Retrieved from: http://pdxscholar.library.pdx.edu/usp_fac2] Brown, A. and Ralph, K. (2017.) "The Right Time and Place to Change Travel Behavior: An Experimental Study." Washington, DC: Transportation Research Board, 2017 Annual Meeting. Retrieved from: https://trid.trb.org/view.aspx?id=1437253Commute Trip Reduction3.4.11 TRT-11 Provide Employer-Sponsored Vanpool/Shuttle0.3%-13.4% commute VMT reduction due to employer-sponsored vanpool and/or shuttle serviceAdequate - Effectiveness is building/tenant specific.1] Reduction in commute vehicle trips due to implementing employer-sponsored vanpool and shuttle programs; 2] Reduction in commute vehicle trips due to vanpool incentive programs; 3] Reduction in commute vehicle trips due to employer shuttle programs 1] 0.5%-5.0%2] 0.3%-7.4%3] 1.4%-6.8%1] Concas, Sisinnio, Winters, Philip, Wambalaba, Francis, (2005). Fare Pricing Elasticity, Subsidies, and Demand for Vanpool Services. Transportation Research Record: Journal of the Transportation Research Board, 1924, pp 215-223. 2] Victoria Transport Policy Institute. (2015). Ridesharing: Carpooling and Vanpooling. Online TDM Encyclopedia. Retrieved from: http://vtpi.org/tdm/tdm34.htm3] ICF. (2014). GHG Impacts for Commuter Shuttles Pilot Program.Commute Trip Reduction3.4.3 TRT-3 Provide Ride-Sharing Programs 1%-15% commute VMT reduction due to employer ride share coordination and facilities Adequate - Effectiveness is building/tenant specific. Do not use with "TRT-1 Implement CTR Program - Voluntary" or "TRT-2 Implement CTR Program - Required Implementation/Monitoring." Commute vehicle trips reduction due to employer ride-sharing programs. Promote ride-sharing programs through a multi-faceted approach such as:• Designating a certain percentage of parking spaces for ride sharing vehicles• Designating adequate passenger loading and unloading and waiting areas for ride-sharing vehicles• Providing an app or website for coordinating rides2.5%-8.3% Victoria Transport Policy Institute. (2015). Ridesharing: Carpooling and Vanpooling. Online TDM Encyclopedia. Retrieved from: http://vtpi.org/tdm/tdm34.htmCommute Trip Reduction3.4.10 TRT-10 Implement a School Pool Program7.2%-15.8% reduction in school VMT due to school pool implementationAdequate - School VMT only. Limited new evidence available, not conclusiveSame Transportation Demand Management Institute of the Association for Commuter Transportation. TDM Case Studies and Commuter Testimonials. Prepared for the US EPA. 1997. (p. 10, 36-38) WayToGo 2015 Annual Report. Accessed on March 12, 2017 from http://www.waytogo.org/sites/default/files/attachments/waytogo-annual-report-2015.pdf Commute Trip Reduction3.4.13 TRT-13 Implement School Bus Program 38%-63% reduction in school VMT due to school bus service implementationAdequate - School VMT only. VMT reduction for school trips based on data beyond a single school district. School district boundaries are also a factor to consider. VMT reduction does not appear to be a factor that was considered in a select review of CA boundaries.VMT reductions apply to school trip VMT only.5%-30% Wilson, E., et al. (2007). The implications of school choice on travel behavior and environmental emissions. Transportation Research Part D: Transport and Environment 12(2007), 506-518.Not Applicable - not a CAPCOA strategyNot Applicable - not a CAPCOA strategyNot Applicable - not a CAPCOA strategyNot Applicable - not a CAPCOA strategyNot Applicable - not a CAPCOA strategyBikeshare car trip substitution rate of 7-19% based on data from Washington DC, and Minneapolis/St. Paul. Annual VMT reduction of 151,000 and 57,000, respectively. Includes VMT for rebalancing and maintenance.VMT reduction of 0.023 miles per day per bikeshare member estimated for Bay Area bikeshare, utilizing Minneapolis/St. Paul data from study above.57,000-151,000 annual VMT reduction, based on two large US cities.VMT reduction of 0.023 miles per day per member, based on one large US city estimate.Fishman, E., Washington, S., & Haworth, N. (2014). Bike share’s impact on car use: Evidence from the United States, Great Britain, and Australia. Transportation Research Part D: Transport and Environment, 31, 13-20.TDM Methodology: Impact of Carsharing Membership, Transit Passes, Bikesharing Membership, Unbundled Parking, and Parking Supply Reductions on Driving. Center for Neighborhood Technology, Peter Haas and Cindy Copp, with TransForm staff, May 5, 2016.
ATTACHMENT B
New informationChange in VMT reduction compared to CAPCOALand Use/ Location 3.1.3 LUT-3 Increase Diversity of Urban and Suburban Developments Downtown and suburban 9%-30% VMT reduction due to mixing land uses within a single developmentAdequate1] VMT reduction due to mix of land uses within a single development; 2] Reduction in VMT due to regional change in entropy index of diversity.1] 0%-12% 2] 0.3%-4% Land Use/ Location 3.1.5 LUT-5 Increase Transit Accessibility Downtown only 0.5%-24.6% reduce in VMT due to locating a project near high-quality transitAdequate1] VMT reduction when transit station is provided within 1/2 mile of development (compared to VMT for sites located outside 1/2 mile radius of transit). Locating high density development within 1/2 mile of transit will facilitate the use of transit by people traveling to or from the Project site. The use of transit results in a mode shift and therefore reduced VMT; 2] Reduction in vehicle trips 1] 0%-5.8% 2] 0%-7.3% Strength of Substantial Evidence for CEQA Impact Analysis?New Information Since CAPCOA Was Published in 2010Appropriate Context?TDM STRATEGY EVALUATION - DRAFT V 1.0Relevant Strategies for Implementation in North Orange County Jurisdictions Due to Land Use Context CAPCOA Category CAPCOA # CAPCOA Strategy CAPCOA Reduction
New informationChange in VMT reduction compared to CAPCOAStrength of Substantial Evidence for CEQA Impact Analysis?New Information Since CAPCOA Was Published in 2010Appropriate Context?TDM STRATEGY EVALUATION - DRAFT V 1.0Relevant Strategies for Implementation in North Orange County Jurisdictions Due to Land Use Context CAPCOA Category CAPCOA # CAPCOA Strategy CAPCOA ReductionNeighborhood Site Enhancements3.2.1 SDT-1 Provide Pedestrian Network ImprovementsDowntown and suburban 0%-2% reduction in VMT for creating a connected pedestrian network within the development and connecting to nearby destinationsAdequateVMT reduction due to provision of complete pedestrian networks. 0.5%-5.7% Neighborhood Site Enhancements3.2.2 SDT-2 Provide Traffic Calming MeasuresDowntown and suburban 0.25%-1% VMT reduction due to traffic calming on streets within and around the developmentAdequateReduction in VMT due to building out a low-stress bike network; reduction in VMT due to expansion of bike networks in urban areas. 0%-1.7%Neighborhood Site Enhancements3.4.9 TRT-9 Implement Car-Sharing Program Downtown and suburban 0.4% - 0.7% VMT reduction due to lower vehicle ownership rates and general shift to non-driving modesAdequateVehicle trip reduction due to car-sharing programs; reduction assumes 1%-5% penetration rate.Car sharing effect on VMT is still evolving due to TNC effects. UCD research showed less effect on car ownership due to car sharing 0.3%-1.6% Parking Pricing 3.3.3 PDT-3 Implement Market Price Public Parking Dowtown only 2.8%-5.5% VMT reduction due to "park once" behavior and disincentive to drivingAdequateImplement a pricing strategy for parking by pricing all central business district/employment center/retail center on-street parking. It will be priced to encourage park once" behavior. Reduction applies to VMT from visitor/customer trips only2.8%-14.5%
New informationChange in VMT reduction compared to CAPCOAStrength of Substantial Evidence for CEQA Impact Analysis?New Information Since CAPCOA Was Published in 2010Appropriate Context?TDM STRATEGY EVALUATION - DRAFT V 1.0Relevant Strategies for Implementation in North Orange County Jurisdictions Due to Land Use Context CAPCOA Category CAPCOA # CAPCOA Strategy CAPCOA ReductionTransit System 3.5.3 TST-3 Expand Transit Network Dowtown only 0.1-8.2% VMT reduction in response to increase in transit network coverageAdequateReduction in vehicle trips due to increased transit service hours or coverage.0.1%-10.5% Transit System 3.5.4 TST-4 Increase Transit Service Frequency/SpeedDowntown and suburban 0.02%-2.5% VMT reduction due to reduced headways and increased speed and reliabilityAdequateReduction in vehicle trips due to increased transit frequency/decreased headway. 0.3%-6.3%Transit System 3.5.1 TST-1 Provide a Bus Rapid Transit SystemDowtown only 0.02%-3.2% VMT reduction by converting standard bus system to BRT systemAdequateNo new information identified.SameCommute Trip Reduction3.4.4 TRT-4 Implement Subsidized or Discounted Transit ProgramDowtown only 0.3%-20% commute VMT reduction due to transit subsidy of up to $6/dayAdequate - Effectiveness is building/tenant specific. Do not use with "TRT-1 Implement CTR Program - Voluntary" or "TRT-2 Implement CTR Program - Required Implementation/Monitoring." 1] Reduction in vehicle trips in response to reduced cost of transit use, assuming that 10-50% of new bus trips replace vehicle trips; 2] Reduction in commute trip VMT due to employee benefits that include transit 3] Reduction in all vehicle trips due to 1] 0.3%-14%2] 0-16%3] 0.1% to 6.9%Commute Trip Reduction3.4.6 TRT-6 Encourage Telecommuting and Alternative Work SchedulesDowntown and suburban 0.07%-5.5% commute VMT reduction due to reduced commute tripsAdequate - Effectiveness is building/tenant specific. Do not use with "TRT-1 Implement CTR Program - Voluntary" or "TRT-2 Implement CTR Program - Required Implementation/Monitoring." VMT reduction due to adoption of telecommuting0.2%-4.5%
1
City of Orange Traffic Impact Analysis
Guidelines for Vehicle Miles Traveled and
Level of Service Assessment
April 2020
2
Table of Contents
When is a TIA Required? 3
Non-CEQA Transportation Assessment 5
Level-of-Service Analysis Procedure ............................................................................................................................ 6
Site Access Analysis ............................................................................................................................................................ 9
On-Site Parking Analysis .................................................................................................................................................10
Analysis of New Facilities ................................................................................................................................................10
CEQA Assessment - VMT Analysis 11
Analysis Methodology .....................................................................................................................................................11
CEQA VMT Impact Thresholds .....................................................................................................................................16
VMT Mitigation Measures ..............................................................................................................................................16
CEQA Assessment - Active Transportation and Public Transit Analysis 18
Transportation Impact Study Format 19
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When is a TIA Required?
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An applicant seeking project approval will submit the proposed project to the Community
Development Department (CDD) with a planning and land used approval application. The project
planner will transmit the application to Public Works Traffic Engineering for preliminary review, as
part of the Streamlined Multi-Discipline Accelerated Review Team (SMART) project review process.
After a preliminary review of the project by Traffic Engineering, the applicant will be notified by the
project planner in writing within 30 days of the application submittal date as to whether a Traffic
Impact Analysis (TIA) is required.
The TIA should consider deficiencies in Level-of-Service (LOS) and impacts under CEQA on Vehicle
Miles Traveled (VMT).
A TIA which includes LOS analysis shall be required for a proposed project that meets any of the
following criteria:
When either the AM or PM peak hour trip generation is expected to exceed 100 vehicle
trips from the proposed development.
Projects on the Arterial Highway System which generate 1,600 Average Daily Trips (ADT).
Projects that will add 51 or more trips during either the AM or PM peak hours to any
intersection.
Any project where variations from the standards and guidelines provided in this manual
are being proposed.
When determined by the City Traffic Engineer that existing or proposed traffic conditions
in the project vicinity have unique characteristics that warrant evaluation.
A TIA which includes VMT assessment shall be required for a proposed project that does not satisfy
the identified project screening criteria:
Transit Priority Areas Screening
Low VMT-generating Areas Screening
Project Type Screening
See Section, “CEQA Assessment - VMT Analysis” for details on these screening criteria.
Projects may be screened from VMT analysis and require LOS analysis, or vice-versa. In cases where
insufficient information is available to make a preliminary assessment of a proposal’s effect on
traffic, the City Traffic Engineer shall determine, at his or her discretion, whether a TIA will be
required.
A TIA must be prepared under the direction of a registered traffic engineer or a registered civil
engineer with documented experience in traffic engineering and transportation planning. The TIA
shall be submitted to the Traffic Engineering Division in a draft form. Comments relative to the
analysis shall be provided by the City Traffic Engineer, or designee, in writing to the project
proponent and its engineer so that any necessary revisions can be made prior to final submittal.
The TIA is not deemed complete or final until it incorporates all necessary revisions and is prepared
to the City’s satisfaction.
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Non-CEQA Transportation
Assessment
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Level-of-Service Analysis Procedure
Within the study area identified by the City Traffic Engineer, level-of-service (LOS) analysis shall be
conducted at:
(1) Identified Intersections (signalized and unsignalized);
(2) Identified Midblock Segments; and
(3) Proposed access points to the project.
Methodology
Intersection capacity calculations for signalized and unsignalized intersections will be made using
the Intersection Capacity Utilization (ICU) method unless the consultant conducting the traffic study
and/or City Traffic Engineer or designee identify locations that can be better evaluated using the
Operational or Planning Analysis methodologies found in the latest editions of the Highway
Capacity Manual (HCM). Pre-approval to use HCM for signalized and unsignalized intersections
shall be obtained in writing from the City Traffic Engineer or designee. Use of the HCM
methodology, in addition to an ICU-type analysis, will be required at any study area intersection
under the control of Caltrans.
Roadway segment LOS will be calculated using capacities defined in the City’s General Plan. Un -
signalized intersection analysis shall be calculated using the HCM methodology.
Volume Development
All traffic volume information used to represent existing conditions shall be no more than two years
old. Additionally, the raw data from sources other than the City, on which existing conditions are
based, must be supplied in the traffic study appendix identifying the source. The following five
analysis scenarios should be evaluated (at the discretion of the City Traffic Engineer in coordination
with Community Development) and summarized in a single table and throughout the analysis using
the following designations:
a. Existing Conditions
Existing traffic conditions: data must have been collected within the previous 24-month
period.
b. Existing Conditions + Approved and Pending Projects:
Existing traffic conditions plus ambient growth and traffic from all the development within
the study area for which an application has been submitted (“pending projects”), or that
have been approved but not yet constructed. This scenario represents project opening year
“Without Project” scenario.
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c. Existing Conditions + Approved and Pending Projects + Project:
Existing traffic conditions of existing, plus ambient growth and approved and pending
developments, plus traffic generated by the proposed project. This scenario represents the
project opening year “With Projects” scenario.
d. General Plan Development:
Build-out of City General Plan combined with build -out of circulation system. Orange
County Traffic Analysis Model (OCTAM) Build-out projections will be used for this purpose.
A General Plan build out analysis is generally required for any project that contributes traffic
to an intersection projected to have unacceptable LOS, any project that requires a General
Plan Amendment or otherwise proposes development that exceeds the land use intensity
assumed for the General Plan, and/or at the discretion of the City Traffic Engineer.
e. General Plan Development + Project:
Cumulative traffic conditions of General Plan build-out plus proposed project.
For projects planned for construction more than two years beyond existing conditions, an ambient
traffic growth factor shall be included to account for annual increases in background traffic (i.e., 1%
per year). This factor will be determined by the City Traffic Engineer or designee.
Projects that are to be constructed in more than one phase will require interim year future analysis
to address each phase of the development and its associated traffic effects. The year(s) to be
analyzed will coincide with the scheduled phasing and will be approved by the City Traffic Engineer
or designee.
When calculating future traffic conditions, vehicular volumes and LOS associated with existing
conditions and the various categories of projected volumes should be identified individually.
Volume/capacity calculations that demonstrate the result of proposed improvements will be
required for intersections where unsatisfactory LOS are identified, and improvements are necessary.
Trip Generation
Trip generation will be calculated using the OCTAM and/or ITE rates, as directed by City. If the
generation rates do not address proposed land use in sufficient detail, rates from other
documented sources (e.g., SCAG) may be used with prior approval from the City.
Trip Distribution/Assignment
Description of trip distribution and directional approach for vehicle trips to and from the site along
with the specific roadways that will be utilized by site-generated traffic is required. The basic
methodology and assumptions used to develop trip distribution and assignments must be clearly
stated. The City’s Traffic Engineering staff will have significant input into t hese areas. Trip
distribution and assignment assumptions are required during the preliminary stages of the study
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and subject to approval of the City Traffic Engineer or designee prior to inclusion within the study
report.
Assumptions
Lost Time and Lane Capacity
A minimum clearance interval of 0.05 in conjunction with lane capacities of 1,700 per hour of green
time for through and turn lanes will be used for all volume/capacity calculations. Where atypical
geometry and/or operational constraints exist, the City Traffic Engineer or designee may adjust
these values at their discretion.
Right Turns
If the distance from the edge of the outside through lane is at least 19 feet and parking is prohibited
during the peak period, right turning vehicles may be assu med to utilize this de facto right turn
lane. Otherwise, all right turn traffic shall be assigned to the outside through lane. If a right turn
lane exists, right turn overlap may be assumed, if not prohibited at that location. However, the
assumption of the number of vehicles turning right during the overlap phase cannot conflict with
any other critical movement at that intersection. Any signal overlap assumptions must be clearly
stated.
Pedestrians
Pedestrian adjustments shall be performed on a case -by-case basis and assessed according to the
procedures outlined in Chapter 16 of the latest version of the HCM for those intersections that have
more than 100 pedestrians in the peak period.
Transportation Effects
Per the City’s General Plan Circulation Element and Growth Management Element requirements, a
volume/capacity (V/C) ratio of 0.90 (LOS D) shall be the lowest acceptable Service Level at
intersections following implementation of roadway improvements. Improvements required to bring
intersections and roadway segments to the acceptable service levels must be identified. In order to
maintain LOS “D” at intersections, arterial highway links should be maintained at LOS “C” or better.
An intersection will be deemed deficient and require improvements to achieve an acceptable LOS
when the LOS is E or F (Final V/C Ratio>0.90) and the project-related increase in V/C is equal to or
greater than 0.010.
For purposes of this calculation, the “Final V/C Ratio” shall mean t he future V/C ratio at an
intersection considering effects with Project, Ambient Growth and Approved and Pending Projects
but without any proposed roadway improvements.
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Transportation Systems Improvement Program (TSIP)
If the traffic analysis indicates unacceptable service levels at mid-block arterial segments and/or
intersections within the study area, a description of proposed improvements to mitigate the
deficiencies shall be included. The following areas are required to be addressed in the discussion
of improvements:
1. The location and nature of the improvements (This information should be summarized in exhibit
form).
2. V/C calculations showing the result of all proposed capacity improvements.
3. Implementation feasibility (including project cost).
4. Feasibility of right-of-way acquisition where additional right-of-way is needed to implement
improvements.
5. Consistency with acceptable design standards.
6. Timing of the proposed improvements.
7. A table shall be submitted showing the V/C ratios and LOS of all studied intersections with and
without project, and, with and without proposed improvements.
8. A single or a series of sketch plans shall be included within the body of the traffic report
graphically depicting all improvements dealing with roadway, parking, and access points. In cases
where phased development of a project is proposed, a schedule identifying the improvements
needed to improve traffic deficiencies at each phase will also be required.
The traffic analysis should provide the nexus between a project and the overall traffic effects on City
arterials and intersections. For cumulative or long-range analysis (e.g.., General Plan build-out) the
project is expected to participate in future improvements on a fair-share basis. In circumstances
where a project proponent will be receiving a substantial benefit from an identified infrastructur e
improvement or where an improvement is proposed that specifically serves the private
development (i.e., mid-block access and signalization at the project entry and/or associated striping
modification) the project will take full responsibility towards providing the necessary infrastructure
improvement.
Site Access Analysis
The project’s effect on access points and on-site circulation shall be analyzed. The analysis shall, as
appropriate, include the following:
Number of access points proposed for the project site.
Spacing between driveways and intersections.
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Potential signalization of driveways.
On-site stacking distance. (Including uses with a drive-thru.)
Shared access.
Turn conflicts/restrictions.
Adequate sight distance.
Driveway improvements.
Pedestrian connections.
Any other operational characteristics (as identified by City staff).
If the proposed project is a residential or commercial use with privacy gates, the applicant shall
provide a stacking analysis for review and approval. The adequacy of the interface with the arterial
network will need to be demonstrated and necessary improvements to adjacent intersections may
be required.
On-Site Parking Analysis
A project provides adequate parking capacity if the project meets Orange Municipal Code (OMC)
parking code requirements. Parking studies are required to support deviations from parking code
requirements or the use of reciprocal parking. The parking rates to be used are based on OMC
Chapter 17.34, “Off-Street Parking and Loading.” In cases where the code does not address parking
rates for a specific land use, or where deviations from code are proposed, documentation must be
provided by the applicant showing how or where the proposed rates were obtained. The parking
analysis must demonstrate that proposed parking supply is adequate to accommodate demand.
Analysis of New Facilities
Whenever new public streets, full access driveways, or private streets are proposed to intersect
arterial streets, an evaluation of the intersection capacity, spacing, queuing and turn pocket lengths
will be required.
Justification for installation of new traffic signal(s), or other traffic control devices, shall be discussed
in the TIA, and based on the warrants stated in the latest edition of the Manual of Uniform Traffic
Control Devices (MUCTD) or California Supplement. All traffic signal warrant calcul ations shall be
provided in the appendix of the traffic study.
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CEQA Assessment - VMT
Analysis
A key element of Senate Bill (SB) 743, signed in 2013, is the elimination of automobile delay and
LOS as the sole basis of determining CEQA impacts. The updated CEQA Guidelines, released in
December 2018, recommend VMT as the most appropriate measure of project transportation
impacts. However, SB 743 does not prevent a city or county from continuing to analyze delay or
LOS as part of other plans (e.g., the general plan), studies, or ongoing network monitoring.
Analysis Methodology
For purposes of SB 743 compliance, a VMT analysis should be conducted for land use projects as
deemed necessary by the Traffic Division and would apply to projects that have the poten tial to
increase the baseline VMT per service population (i.e., population plus employment) for the City of
Orange. Normalizing VMT per service population essentially provides a transportation efficiency
metric that the analysis is based on.
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Project Screening
There are three types of screening that may be applied to effectively screen projects from project-
level assessment. These screening steps are summarized below:
Step 1: Transit Priority Area (TPA) Screening
Projects located within a TPA1 may be presumed to have a less than significant impact absent
substantial evidence to the contrary. This presumption may NOT be appropriate if the project:
1. Has a Floor Area Ratio (FAR) of less than 0.75;
2. Includes more parking for use by residents, customers, or employees of the project than
required by the City;
3. Is inconsistent with the applicable Sustainable Communities Strategy (as determined by
the lead agency, with input from the Southern California Association of Governments
[SCAG]); or
4. Replaces affordable residential units with a smaller number of moderate- or high-income
residential units.
To identify if the project is in a TPA, the analyst may review “NOCC+”, a spreadsheet tool developed
for the use of North County Cities in identifying projects that could be considered for screening
from project-generated VMT impacts. Additionally, the analyst should confirm with all local transit
providers that no recent changes in transit service have occurred in the Project area.
Step 2: Low VMT Area Screening
Residential and office projects located within a low VMT-generating area may be presumed to have
a less than significant impact absent substantial evidence to the contrary. In addition, other
employment-related and mixed-use land use projects may qualify for the use of screening if the
project can reasonably be expected to generate VMT per resident, per worker, or per service
population that is similar to the existing land uses in the low VMT area.
1 A TPA is defined as a half mile area around an existing major transit stop or an existing stop along a high-
quality transit corridor per the definitions below.
Pub. Resources Code § 21064.3 - ‘Major transit stop’ means a site containing an existing rail transit station,
a ferry terminal served by either a bus or rail transit service, or the intersection of two or more major bus
routes with a frequency of service interval of 15 minutes or less during the morning and afternoon peak
commute periods.
Pub. Resources Code § 21155 - For purposes of this section, a ‘high-quality transit corridor’ means a
corridor with fixed route bus service with service intervals no longer than 15 minutes during peak commute
hours.
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For this screening in the North Orange County area, the OCTAM travel forecasting model was used
to measure VMT performance for individual jurisdictions and for individual traffic analysis zones
(TAZs). TAZs are geographic polygons similar to Census block groups used to represent areas of
homogenous travel behavior. Total daily VMT per service population (population plus employment)
was estimated for each TAZ. This presumption may not be appropriate if the project land uses
would alter the existing built environment in such a way as to increase the rate or leng th of vehicle
trips. The Project applicant should document whether or not any increase to the rate or length of
vehicle trips is expected.
To identify if the project is in a low VMT-generating area, the analyst may review “NOCC+”.
Additionally, as noted above, the analyst must identify if the project is consistent with the existing
land use (e.g., if the project is proposing single-family housing, there should be existing single-
family housing of approximately the same density) within that TAZ and use professional judgement
that there is nothing unique about the project that would otherwise be misrepresented utilizing the
data from the travel demand model.
Step 3: Project Type Screening
Some project types have been identified as having the presumption of a less than significant impact.
The following uses can be presumed to have a less than significant impact absent substantial
evidence to the contrary as their uses are local serving in nature:
Local-serving K-12 public schools
Local parks
Day care centers
Local-serving retail uses less than 50,000 square feet, including:
o Gas stations
o Banks
o Restaurants
o Shopping Center
Local-serving hotels (e.g., non-destination hotels)
Student housing projects on or adjacent to college campuses
Local-serving assembly uses (places of worship, community organizations)
Community institutions (public libraries, fire stations, local government)
Affordable, supportive or transitional housing
Assisted living facilities
Senior housing (as defined by HUD)
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Projects generating less than 110 daily vehicle trips2
o This generally corresponds to the following “typical” development potentials:
11 single family housing units
16 multi-family, condominiums, or townhouse housing units
10,000 sq. ft. of office
15,000 sq. ft. of light industrial3
63,000 sq. ft. of warehousing7
79,000 sq. ft. of high cube transload and short-term storage warehouse7
VMT Assessment for Non-Screened Development
Projects not screened through the steps above should complete VMT analysis and forecasting
through the OCTAM model to determine if they have a significant VMT impact. This analysis should
include ”project generated VMT” and ”project effect on VMT” estimates for the project TAZ (or
TAZs) under the following scenarios:
Baseline conditions - This data is available from OCTAM. The NOCC+ VMT Project
Screening spreadsheet tool also provides the baseline VMT per service population in the
City of Orange.
Baseline plus project - The project land use would be added to the project TAZ or a
separate TAZ would be created to contain the project land uses. A full base year model
run would be performed and VMT changes would be isolated for the project TAZ and
across the full model network. The model output must include reasonableness checks of
the production and attraction balancing to ensure the project effect is accurately
captured. If this scenario results in a less-than-significant impact, then additional
cumulative scenario analysis may not be required (more information about this outcome
can be found in the Thresholds Evaluation discussion later in this chapter).
The NOCC+ tool provides an estimate of the Baseline plus project conditions. This data
could be presented in lieu of results from the full model run. However, it is recommended
2 This threshold ties directly to the OPR technical advisory and notes that CEQA provides a categorical
exemption for existing facilities, including additions to existing structures of up to 10,000 square feet, so
long as the project is in an area where public infrastructure is available to allow for maximum planned
development and the project is not in an environmentally sensitive area. (CEQA Guidelines, § 15301, subd.
(e)(2).) Typical project types for which trip generation increases relatively linearly with building footprint
(e.g., general office building, single tenant office building, office park, and business park) generate or
attract an additional 110-124 trips per 10,000 square feet. Therefore, absent substantial evidence otherwise,
it is reasonable to conclude that the addition of 110 or fewer trips could be considered not to lead to a
significant impact.
3 Threshold may be higher depending on the tenant and the use of the site. This number was estimated
using rates from ITE’s Trip Generation Manual.
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that a base year plus project run always be performed as a check for reasonableness and
consistency with the cumulative year results.
Cumulative no project - This data is available from OCTAM.
Cumulative plus project - The project land use would either be added to the project TAZ
or a separate TAZ would be created to contain the project land uses. The addition of
project land uses should be accompanied by a reallocation of a similar amount of land
use from other TAZs; especially if the proposed project is significant in size such that it
would change other future developments. Land use projects will generally not change
the cumulative no project control totals for population and employment growth. Instead,
they will influence the land use supply through changes in general plan land use
designations and zoning. If project land uses are simply added to the cumulative no
project scenario, then the analysis should reflect this limitation in the methodology and
acknowledge that the analysis may overestimate the project’s effect o n VMT.
The model output should include total VMT, which includes all vehicle trips and trip purposes, and
VMT per service population (population plus employment). Total VMT (by speed bin) is needed as
an input for air quality, greenhouse gas (GHG), and energy impact analysis while total VMT per
service population is recommended for transportation impact analysis 4.
Both “plus project” scenarios noted above will summarize two types of VMT: (1) project generated
VMT per service population and comparing it back to the appropriate benchmark noted in the
thresholds of significance, and (2) the project effect on VMT, comparing how the project changes
VMT on the network looking at citywide VMT per service population comparing it to the no project
condition.
Project-generated VMT shall be extracted from the travel demand forecasting model using the
origin-destination trip matrix and shall multiply that matrix by the final assignment skims. The
project-effect on VMT shall be estimated using the City boundary and extracting the total link-level
VMT for both the no project and with project condition.
A detailed description of this process is attached to these guidelines. See “Detailed VMT Forecasting
Information.”
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CEQA VMT Impact Thresholds
VMT Impacts
An example of how VMT thresholds would be applied to determine potential VMT impacts is
provided below.
A project would result in a significant project-generated VMT impact if either of the
following conditions are satisfied:
1. The baseline project-generated VMT per service population exceeds the City of
Orange General Plan Buildout VMT per service population, or
2. The cumulative project-generated VMT per service population exceeds the City of
Orange General Plan Buildout VMT per service population
The project’s effect on VMT would be considered significant if it resulted in either of the
following conditions to be satisfied:
1. The baseline link-level boundary Citywide VMT per service population increases
under the plus project condition compared to the no project condition, or
2. The cumulative link-level boundary Citywide VMT per service population increases
under the plus project condition compared to the no project condition.
Please note that the cumulative no project shall reflect the adopted RTP/SCS; as such, if a project is
consistent with the SCAG RTP/SCS, then the cumulative impacts (project effect on VMT) shall be
considered less than significant subject to consideration of other substantial evidence.
VMT Mitigation Measures
To mitigate VMT impacts, the following choices are available to the applicant:
1. Modify the project’s built environment characteristics to reduce VMT generated by the
project.
2. Implement Transportation Demand Management (TDM) measures to reduce VMT
generated by the project.
3. Participate in a VMT fee program and/or VMT mitigation exchange/banking program (if
available) to reduce VMT from the project or other land uses to achieve acceptable levels.
As part of the North Orange County Cities Implementation Study, key TDM measures that are
appropriate to the region were identified. Measures appropriate for most of the City of Orange are
summarized in Attachment B of the TDM Strategies Evaluation Memorandum. The NOCC+ tool
includes information on these mitigation measures and can be used to test which combination of
measures can achieve the desired level of mitigation.
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VMT reductions should be evaluated using state-of-the-practice methodologies recognizing that
many of the TDM strategies are dependent on building tenant performance over time. As such,
actual VMT reduction cannot be reliably predicted and monitoring may be necessary to gauge
performance related to mitigation expectations.
When a Project is found to have a significant impact under CEQA, the City of Orange requires
developers and the business community to assist in reducing peak hour and total vehicular trips by
implementing TDM plans. The potential of a proposed project to reduce traffic through the use of
a TDM plan should be addressed in the traffic study.
If a TDM plan is proposed as a mitigation measure for a project, and the traffic study attributes a
reduction in peak and total traffic to the TDM plan, the following information must be provided:
1. A detailed description of the major components of the TDM plan and how it would be
implemented and maintained on a continuing basis.
2. Case studies or empirical data that supports the anticipated reduction of traffic attributed
to the TDM plan.
3. Additional V/C ratio calculations that illustrate the circulation benefits of the TDM plan.
4. Enforcement Measures – how it will be monitored and enforced.
5. How it complies with the South Coast Air Quality Management District Regulations.
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CEQA Assessment - Active
Transportation and Public
Transit Analysis
Potential impacts to public transit, pedestrian facilities and travel, and bicycle facilities and travel
can be evaluated using the following criteria:
A significant impact occurs if the project conflicts with adopted policies, plans, or programs
regarding public transit, bicycle, or pedestrian facilities, or otherwise decreases the
performance or safety of such facilities.
Therefore, the TIA should include analysis of a project to examine if it is consisten t with adopted
policies, plans, or programs regarding active transportation or public transit facilities, or otherwise
increases or decreases the performance or safety of such facilities and make a determination as to
whether it has the potential to conflict with existing or proposed facilities supporting these travel
modes.
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Transportation Impact Study
Format
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Prior to the beginning of any study, the project proponent shall coordinate with staff from
Community Development and Traffic Engineering. A tentative schedule for reviewing and
processing the TIA will be developed. Initial discussions shall also include a discussion of any key
issues along with the development scope and boundaries of the study area. The proponent will
submit a detailed site plan at this meeting. City staff will provide input into the following specific
areas of the analysis:
Defining the general study area boundaries.
Project access.
Approved development in the vicinity of the project for cumulative analysis.
Approved General Plan (build-out) traffic volumes.
Appropriate Trip Generation rates for the project.
The project proponent shall coordinate with the Traffic Engineering staff so that detailed and
technical aspects of the analysis can be discussed prior to a formal submittal. Topics of discussion
will include:
Trip distribution and assignment assumptions.
Intersections and roadway segments where capacity analysis will be required.
o As a minimum, intersections where the project will add 51 or more trips during
either the AM or PM peak hours will need to be analyzed. This threshold may be
reduced, at the discretion of the City Traffic Engineer, for intersections that are
projected to or currently operate at LOS “E” or “F”.
Intersection Capacity Analysis assumptions.
Potential for project-level VMT screening.
VMT Analysis assumptions.
Inclusion of a TDM Plan to mitigate traffic impacts and promote the use of alternate modes
of transportation.
Any specific issues that require special consideration such as pedestrian circulation, access,
parking and on-site circulation.
The content and level of analysis necessary to evaluate a project will vary and are dependent on
the scope of lane use proposal and location within the City. All traffic studies will be organized and
contain, as a minimum, the information provided in the following outline.
2. Executive Summary
A clear concise summary of the study area, findings, and proposed improvements are required in
the Executive Summary.,
3. Introduction
a. Site Location and Study Area Boundaries
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Briefly describe the proposed development and the general geographical location of the
project. Provide the study area limits mutually agreed upon by the developer, its engineer,
and the City.
b. Existing Land Uses and Project Proposals
The existing site conditions, the proposed project and, if applicable, the previously
proposed land use(s) associated with the site shall be identified. The specific land use
proposed will be presented since a variety of uses and land use densities may be perm itted
under existing general plan or zoning designations with varying degrees of impact.
c. Committed and Proposed Developments in the Vicinity of the Proposed Project
Information pertaining to projects that would contribute traffic to the project study area,
including both approved developments and proposed developments where an application
has been submitted, shall be identified. The TIA should include a brief description of these
projects, and their traffic-related impacts. During its preliminary meetings with the
applicant, City staff will identify the need to assess impacts associated with approved and
proposed developments.
d. Existing and Proposed Roadways and Intersections
Identify and describe the roadways and intersections within the study area and the role
each will play in providing circulation and access to the project. Number of lanes, driveways
locations, ultimate right-of-way, intersection geometrics, bus stops, bike lanes, sidewalks
and traffic controls shall be included.
To summarize the information presented in the introduction, a vicinity map depicting the project
site, study boundaries, existing lane configurations, traffic controls and any additional features that
are pertinent to the study shall be provided.
4. Methodology and Thresholds
Identify the methodology used to calculate LOS and VMT. Include the criteria used for screening
projects from project-level VMT analysis, if applicable. Identify the impact threshold for VMT, and
deficient LOS operations for roadways and intersections.
5. LOS Analysis
Refer to Page xx. A table summarizing the types of lane use; the corresponding generation rates
and land use units and the resulting a.m. peak, p.m. peak, and total daily trip ends generated by
the project is required.
Refer to Page xx. As part of the analysis, a graphic that shows project distribution by percentage
and the direction of travel shall be included. The results of the various LOS and V/C calculations
should be summarized using figures that graphically represent the roadways within the study area.
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6. Traffic Signal Warrant Analysis
Identify any unsignalized intersections which were studied and operate deficiently. Perform a signal
warrant analysis to determine if the installation of a traffic signal is warranted.
7. Site Access Analysis
See the Site Access Analysis on Page 10.
8. On-site Parking Analysis
See the On-Site Parking Analysis on Page 10.
9. Active Transportation and Public Transit Analysis
Refer to Page 19.
10. Improvements and Recommendations
a. Proposed improvements at intersections
b. Proposed improvements at roadway segments
c. Recommended improvements categorized by whether they are included in fee plan or
not. (Identify if these improvements are included in an adopted fee program)
11. Vehicle Miles Traveled (VMT) Analysis
Present the Project VMT per service population for all analysis scenarios and the Project effect on
VMT for all analysis scenarios. Data should be presented in tabular format. If the project meets the
criteria for screening from project-generated VMT analysis, this should be documented. All VMT
impacts should be identified in accordance with the VMT Impact Thresholds described above.
Proposed VMT mitigation measures should be identified.
13. Appendix
a. Approved scope of work
b. Traffic counts
c. Intersection analysis worksheets
d. VMT and TDM calculations
e. VMT and TDM mitigation calculations
f. Signal warrant worksheets