31a. Draft Subsequent Environmental Impact Report No. 352 Volume 1 — Anaheim City Council, April 16, 2024 (part 4 of 5)

Source: City of Anaheim 2021, HCD 2022.

Senate Bill 375
Signed into law on September 30, 2008, Senate Bill (SB) 375 provides for a new planning process to coordinate land use planning and regional transportation plans (RTPs) and funding priorities in order to help California meet the GHG reduction goals established in Assembly Bill (AB) 32. SB 375 requires Metropolitan Planning Organizations (MPOs), including SCAG, to incorporate a Sustainable Communities Strategy (SCS) in their regional transportation plans that will achieve GHG emission reduction targets set by CARB. There are two mutually important facets to SB 375:
reducing vehicle miles traveled and encouraging more compact, complete, and efficient communities for the future. SB 375 also includes provisions for exemptions from or streamlined CEQA review for projects classified as transit priority projects (SCAG 2016).

Regional
Southern California Association of Governments (SCAG)
Under federal law, SCAG is designated as a MPO and under state law as a Regional Transportation Planning Agency and a COG for Orange County and the Project site. The SCAG region encompasses six counties (Imperial, Los Angeles, Orange, Riverside, San Bernardino and Ventura) and 191 cities in an area covering more than 38,000 square miles. The agency develops long-range RTPs including sustainable communities strategy and growth forecast components, regional transportation improvement programs, RHNAs, and a portion of the South Coast Air Quality management plans (SCAG 2022b).

5.12-5 Section 5.12 – Population and Housing
land use and transportation strategies established over several planning cycles to increase mobility options and achieve a more sustainable growth pattern. It charts a path toward a more mobile, sustainable and prosperous region by making connections between transportation networks, between planning strategies and between the people whose collaboration can improve the quality of life for Southern Californians. Connect SoCal outlines more than $638 billion in transportation system investments through 2045. It was prepared through a collaborative, continuous, and comprehensive process with input from local governments, county transportation commissions, tribal governments, non-profit organizations, businesses and local stakeholders within the counties of Imperial, Los Angeles, Orange, Riverside, San Bernardino and Ventura (SCAG 2022c).

Local
The City of Anaheim General Plan
Adopted in May 2004, the City’s General Plan provides a road map for growth and development within the corporate boundaries and sphere of influence. Specifically, three components of the City’s General Plan are particularly relevant to assessing the potential growth impacts of the Project: the Housing, Land Use, and Growth Management Elements. 2021-2029 Housing Element
The Housing Element is a state-mandated chapter of the City’s General Plan that sets forth an eight-year plan (housing cycle) to address the City’s identified housing needs. The Housing Element describes, identifies, and analyzes the City’s housing needs, and addresses the maintenance and expansion of the housing supply to accommodate the households that currently live and/or are expected to live in Anaheim in the housing cycle. Through research and analysis, the Housing Element identifies available candidate housing sites and establishes a Housing Policy Program to accommodate the RHNA allocation, as determined by the SCAG and approved by the HCD.

The Draft Housing Element 6
th Cycle 2021–2029 was submitted to the HCD on October 15, 2021 for review and certification. On December 14, 2021, HCD issued a comment letter. On June 24, 2022, the Revised Draft Housing Element was sent to HCD for review and a second comment letter was received on August 23, 2022. On May 2, 2023, the City sent the Revised Draft Housing Element to HCD for review. Once HCD approves of the revised Housing Element, the Element will be considered for adoption by the City Council (City of Anaheim 2023). Housing Element policies relevant to the Project are identified in Table 5.10-1 in Section 5.10, Land Use and Planning.

5.12.3 PROJECT IMPACT ANALYSIS
A. Methodology
The assessment for potential impacts associated with growth inducement is based on consistency with the applicable planning programs that have been developed to ensure orderly development, while providing sufficient development to meet the long-term projections for the region. A key element of the analysis is an evaluation of the Project relative to the population, household, and employment trends forecasts for the City and County.

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5.12-6 Section 5.12 – Population and Housing
B. Thresholds of Significance
The following significance criteria are derived from the City of Anaheim Environmental Checklist.

Threshold 5.12a Would the project 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)?
The City evaluated Population and Housing threshold b (whether the Project would displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere) in Section 3.14 of the Initial Study prepared for the Project, and concluded the Project would have no impact related to this threshold. Therefore, this threshold is not discussed in this Subsequent EIR.

C. Standard Requirements
No standard requirements for this resource topic apply to the Project.

D. Impact Analysis
Threshold 5.12a Would the project 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)?
No New Impact from EIR No. 311; No New Impact from SEIR No. 340 – Project Impact Less Than Significant Impact. EIR No. 311 determined that The Disneyland Resort Project would result in minimal growth within the City, and that The Disneyland Resort Project would not create a significant impact to employment, population, or housing. According to SEIR No. 340, buildout of the ARSP would increase population and housing demand; however, the increases would be well within City and regional projections and would be a less than significant impact.

As discussed in Section 3.0, Project Description, of this Subsequent EIR, the Project would not add any additional square footage of theme park uses or retail entertainment uses, nor would it add any additional hotel rooms that were not previously analyzed and approved. Instead, the Project would allow the transfer of previously approved uses to other areas of the Project site.

The Project is not proposing construction of any new housing units that would have the potential to directly increase population in the City. Finally, the Project would not otherwise extend any roads or expand infrastructure beyond what was previously analyzed in EIR No. 311 and SEIR No. 340.

Employment
As described in Section 3.9, Employment, Population, and Housing, of EIR No. 311, The Disneyland Resort Project would result in the addition of 15,163 new jobs directly, 3,211 jobs induced throughout the City, and 14,277 jobs indirectly of which 2,142 would be in Anaheim, which total 20,516 total jobs in Anaheim. Although The Disneyland Resort Project does not include any new dwelling units that would lead to direct population growth, EIR No. 311 found that indirect population growth would occur that would increase the need for housing by 553 housing units.

According to EIR No. 313, implementation of the ARSP Project would create 18,113 jobs in the year 2010. Subsequently, SEIR No. 340 found that buildout of the ARSP Project would result in DisneylandForward
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the need for approximately 18,822 new jobs for the Commercial-Recreation (C-R) District and 810 new jobs for the Public Recreational (PR) District, or a total of 19,632 new jobs, at buildout of the ARSP that were not previously analyzed in EIR No. 313. However, only a portion of these new employees would be associated with the Disney ARSP Properties. Specifically, these properties have the potential to be developed with up to 5,562 hotel rooms which, using the employee generation rate of 0.9 employees per hotel room utilized in SEIR No. 340, would equate to 5,006 employment positions, as shown in Table 5.12-2, Employment Summary.

As of February 2022, The Disneyland Resort had approximately 30,000 employees (Disney 2022). Based on information provided by the Applicant related to remaining buildout that would be possible with the Project, it is anticipated that the Project would result in approximately 28,352 additional direct and indirect employment positions above current employment levels within The Anaheim Resort. Of this total, the Project would directly result in approximately 14,381 additional Disneyland Resort employees, some of whom would work at the Disney ARSP Properties, to which SEIR No. 340 assigned 5,006 employees at full buildout of the ARSP Project.

Accordingly, the Project would result in a total increase in Disneyland Resort employees of approximately 9,375. This would be a total of 39,375 employees overall, which is 13,853 more employees than were assumed in EIR No. 311 and SEIR No. 340 as shown in Table 5.12-2.

TABLE 5.12-2

EMPLOYMENT SUMMARY
Disneyland Resort Project Employment
Employment

Employment Assumed in EIR No. 311 20,516a
Employment Assumed in SEIR No. 340 for Disney ARSP Properties 5,006 Total Employment: EIR No. 311 and SEIR No. 340 25,522
Existing (February 2022) Employment 30,000
Additional Future Project Employment 9,375
Total Buildout Employment DisneylandForward 39,375
Total Increase in Employment Between the Proposed Project and Prior Approvals 13,853 a. Refer to Table 3.9-11 and pages 3-275 and 3-276 of EIR No. 311 Sources: City of Anaheim 1994, 1996, and 2012; Disney 2022.

The 13,853 new employees added by the Project would represent 0.69 percent of SCAG’s projected employment for Orange County in 2050, which anticipates that Orange County would have 2,006,000 jobs overall. Further, the new employees would represent 5.5 percent of SCAG’s projected total employment in the City of 250,500 in 2045 (SCAG 2020a) which would not represent a substantial increase or result in a significant impact when compared to local and regional projections. Implementation of PDF POP-1 would continue to implement special employment programs including summer employ ment for teachers and educational programs offering local high school students jobs and recruiting workers who are already a part of the resident work force in the region.

Temporary construction jobs would be associated with the Project. Given the short-term and mobile nature of construction work and the fact that the labor pool in Orange County and surrounding communities is extensive, it is unlikely that construction workers would relocate from outside the region in order to construct the Projec t. As the Project would draw from the existing available construction labor pool, there would be no significant housing or population impacts from construction of the Project.

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Population and Housing
Calculations associated with population generation and housing demand are shown in Table 5.12-3, Population Generation and Housing Demand Calculations, and discussed in detail below.

TABLE 5.12-3

POPULATION GENERATION AND HOUSING DEMAND CALCULATIONS
Total New Employment Relocated Cast Membersa Dwelling Unitsa Populationb 13,853 1,842 1,842 6,079
a Assumes that 13.3 percent of employees would choose to relocate to the City of Anaheim and each employee relocated to the City of Anaheim would require one dwelling unit
b Assumes 3.3 persons per dwelling unit

Approximately 15.7 percent2, or 2,175, of the 13,853 new employment positions would be filled by current Anaheim residents. SEIR No. 340 anticipated that approximately 13.3 percent of new employees would move to Anaheim to be closer to work. Using this same local employment generation factor, approximately 13.3 percent of the projected 13,853 employees would move to Anaheim, resulting in approximately 1,842 new employees associated with the Project anticipated to move to the City. This increase in residents would indirectly increase demand for housing within the City by 1,842 housing units, and assuming 3.3 persons per dwelling unit according to SEIR No. 340, new population in the City would be approximately 6,079 persons.

As discussed previously, housing projections for the City between 2016 and 2045 estimate an increase of 21,600 housing units (SCAG 2020a). Based on a conservative assumption that the full demand for new housing would occur during the initial stages of Project buildout, the projected increase of 1,842 additional housing units associated with Project would represent 8.5 percent of the projected growth. Therefore, the Project’s increased demand for housing would be within the housing projections for the City and would not r epresent a significant impact. Additionally, it is more likely that the demand for new housing would be spread throughout the 30-year Project buildout, which would decrease any potential impact.

Because the Project does not propose construction of any new housing, it would rely on other housing projects in the City to produce adequate housing to accommodate the projected increase in demand that would result from the Project. However, the Project’s employment and housing increases are within the projections for the City.

SCAG jurisdiction-level growth forecasts for the City anticipate a City population of 416,800 in 2045, total housing units in the City of 122,700 in 2045, and total employment in the City of 250,500 in 2045 (SCAG 2020a). The 6,079 new residents of the City of Anaheim would compose

1.5 percent of the City’s projected population which would not represent a substantial increase or result in a significant impact when compared to local and regional projections.

The Project would result in a less than significant impact related to population, housing, and employment; however, the Project would continue to implement PDF POP-1. This impact would not be new or substantially more severe when compared with the impact analyses in EIR No. 311 and SEIR No. 340.

2 Based on employment records analyzed by the Applicant, 15 .7 percent of existing employees live within the City of Anaheim.

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5.12.4 CUMULATIVE IMPACTS
According to EIR No. 311 and SEIR No. 340, buildout of The Disneyland Resort Project and ARSP Project would not result in significant and unavoidable cumulative growth impacts related to population and housing beyond those accounted for in the City’s General Plan or in the Orange County Projections. Thus, neither The Disneyland Resort Project nor the ARSP Project would contribute to a cumulative impact.

As noted above, operation of the Project would generate direct employment within the Project site. The new employees associated with implementation of the Project would be well within the regional employment growth forecasts for the County and the City. The Project would not construct new housing, nor would the Project indirectly lead to substantial unplanned growth through the extension of roads or other infrastructure.

The Project in combination with the cumulative Projects listed in Table 4-1 in Section 4.4, would result in increased growth in housing units, jobs, and population within the City of Anaheim and surrounding areas of the County. This growth, however, would be within projections forecasted by SCAG.

The Project would have a less than significant cumulative impact. This impact would not be new or substantially more severe when compared with the impact analyses in EIR No. 311 and SEIR No. 340.

5.12.5 MITIGATION PROGRAM
Mitigation Measures
EIR No. 311 and SEIR No. 340 presented mitigation measures (MM), Project Design Features (PDF), and standard requirements (SR) to reduce potential impacts associated with The Disneyland Resort Project and the ARSP Project, respectively. As appropriate, the measure number and section from EIR No. 311 and/or SEIR No. 340 are listed in parentheses.

Modifications to the original measure are shown as strikethrough for deleted text and bold for new, inserted text.

PDF POP-1 Ongoing during project operations, the existing Disneyl and theme park and the Disneyland Hotel special employment programs such as summer employment for teachers and educational programs offering local high school students jobs will continue. The Walt Disney Company will also aggressively recruit workers who are already a part of the resident work force in the region. Implementation of The Disneyland Resort Specific Plan will further efforts in offering employment opportunities at various socioeconomic levels. (EIR No. 311, PDF 3.9-1)

5.12.6 IMPACT SUMMARY
Threshold 5.12a Would the project 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)?
Impact Summary: The Project would result in a less than significant impact related to population, housing, and employment; however, the Project would continue to implement PDF POP-1.

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The Project would result in a less than significant impact related to population, housing, and employment; however, the Project would continue to implement PDF POP-1. This impact would not be new or substantially more severe when compared with the impact analyses in EIR No. 311 and SEIR No. 340.

Cumulative Impacts
Impact Summary: The Project would have a less than significant cumulative impact.

This impact would not be new or substantially more severe when compared with the impact analyses in EIR No. 311 and SEIR No. 340.

5.12.7 REFERENCES
Anaheim, City of. 2023 (May). 2021-2029 Draft Housing Element. Anaheim, CA: City of Anaheim. https://anaheim.net/5998/2021-2029-Draft-Housing-Element ———. 2022 (last accessed September 14, 2022). Anaheim Municipal Code. Anaheim, CA: City of Anaheim. https://codelibrary.amlegal.com/codes/anaheim/latest/anaheim_ca/0-0-0- 51668
———. 2012 (last accessed September 14, 2022). Final Environmental Impact Report 340 Amendment No. 14 to the Anaheim Resort Specific Plan and Mitigation Monitoring Program No. 85C. Anaheim, CA: Anaheim. http://anaheim.net/1009/Anaheim-Resort. ———. 2004 (May). General Plan for the City of Anaheim (City Council Resolution No. 2004-94).

Anaheim, CA: the City. http://www.anaheim.net/712/General-Plan ———. 1996 (last accessed September 14, 2022). The Disneyland Resort Specific Plan Final Environmental Impact Report No. 311 with Addendum and Modified Mitigation Monitoring Program 0067. Anaheim, CA: Anaheim. http://anaheim.net/1017/Disneyland-Resort. ———. 1994 (August). The Anaheim Resort Specific Plan Draft EIR No. 313 with Addendum .

Anaheim, City of: Anaheim, CA.
https://www.anaheim.net/DocumentCenter/View/2494/Master-Environmental-Impact- Report-Number-313-?bidId=
California Department of Housing and Community Development. 2022 (May 24, last accessed).

Regional Housing Needs Allocation. Sacramento, CA: HCD. https://www.hcd.ca.gov/community-development/rhna/index.shtml.

Disney. 2022 (May). Personal correspondence related to current staffing levels and anticipated future staffing needs for the Project. Anaheim, CA: Disney.

Southern California Association of Governments. 2022a (February 3). Connect SoCal 2024 Preliminary Regional and County Growth Forecast. Los Angeles, CA: SCAG. https://scag.ca.gov/sites/main/files/file-
attachments/jpc020322fullpacket.pdf?1643341995#page=51
———. 2022b (August 24, last accessed). SCAG – About Us – Webpage. Los Angeles, CA:

SCAG. https://scag.ca.gov/about-us
———. 2022c (August 24, last accessed). Connect SoCal webpage . Los Angeles, CA: SCAG. https://scag.ca.gov/connect-socal
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———. 2020a (September 3, adopted). Connect SoCal (2020-2045 Regional Transportation Plan/Sustainable Communities Strategy), Demographics & Growth Forecast Technical Report. Los Angeles, CA: SCAG. https://scag.ca.gov/sites/main/files/file- attachments/0903fconnectsocal_demographics-and-growth-forecast.pdf?1606001579. ———. 2020b (September). Connect SoCal (2020-2045 Regional Transportation Plan/Sustainable Communities Strategy . Los Angeles, CA: SCAG. https://scag.ca.gov/connect-
socal#:~:text=Adopted%20Final%20Connect%20SoCal%202020,- Overview%20November%2021&text=It%20charts%20a%20path%20toward,of%20life% 20for%20Southern%20Californians.

State of California Department of Finance. 2021 (July 19). Report P-2A: Total Estimated and Project Population for California and Counties: July 10, 2010 to 2060. Sacramento, CA:

DOF. https://dof.ca.gov/forecasting/demographics/projections. ———.2020 (June 10). P-4 Report: Household Projections for California Counties: 2020-2030.

Sacramento, CA: DOG. https://dof.ca.gov/forecasting/demographics/projections/ United States Census Bureau. 2022 (August 24, last accessed). QuickFacts, Orange County, California. Washington, DC: United States Census Bureau. https://www.census.gov/quickfacts/orangecountycalifornia

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5.13 PUBLIC SERVICES
This section discusses the existing public services setting of the Project Site and assesses the Project’s potential impacts related to public services.

5.13.1 SUMMARY OF PREVIOUS ENVIRONMENTAL DOCUMENTATION
The Disneyland Resort EIR No. 311
Fire Protection
EIR No. 311 reported that The Disneyland Resort Project would increase the demand for fire protection services, thus increasing response times; the number of service call responses; and the number of search, rescue, and disaster responses. However, EIR No. 311 determined that implementation of MMs 3.10.1-1 through 3.10.1-10 identified in EIR No. 311, which include installation of fire hydrants and sprinklers, implementation of an emergency fire access plan and construction fire protection plan, incorporating overhead clearances into design, and similar measures, would reduce impacts to less than significant.

Police Protection
According to EIR No. 311, development of The Disneyland Resort Project would increase the volume of calls for police services. However, implementation of MMs 3.10.2-1 through 3.10.2-6 and MM 3.8-11, which include providing security services within parking facilities, paying fair share funding for police personnel and equipment, providing space within The Disneyland Resort Security Office for the Anaheim Police Departmen t, incorporating safety measures into building design, and providing training for staff/employees, would reduce impacts to less than significant.

Schools
EIR No. 311 determined that development of The Disneyland Resort Project would not create any direct impacts to local schools because the Specific Plan does not allow for the construction of new dwelling units. However, school-aged children of project employees would create a potential indirect impact from development of The Disneyland Resort Project that would be mitigated through payment of state-mandated school impact fees as required by MM 3.10.5-2 and participation in youth educational programs as required by PDF 3.10.5-1. However, EIR No. 311 identified a significant and unavoidable indirect impact related to school enrollment due to over- capacity situations in the Anaheim Union High School District and the Anaheim City School District.

Parks
EIR No. 311 determined that development of The Disneyland Resort Project would result in increased use of ball fields by cast members (employees), but implementation of MM 3.10.4-2, which requires the provision of night lighting at two ball fields and a community park, and PDF 3.10.4-1, which requires the provision of pedestrian amenities in a park-like setting, and PDF 3.10.4-2, which requires the provision of an eating area outside the paid theme park gates within the Theme Park District, would reduce these impacts to less than significant.

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R:\Projects\WDI\3WDI000400\Environmental Documentation\PR_SEIR\5.13_Public_Services-090823.docx 5.13-2 Section 5.13 – Public Services EIR No. 311 Mitigation Measures and Project Design Features EIR No. 311 and Modified MMP No. 0067 1 required implementation of the following mitigation measures and project design features regarding public services to reduce potential impacts associated with full buildout of the Disneyland Resort Project.

Fire
MM 3.5-2 Ongoing during project operation of the Second Theme Park, the applicant shall obtain (on an annual basis) a permit for use of fireworks.

MM 3.6-5 Ongoing during project operations, the property owner/developer shall coordinate earthquake training with the Fire Department for hotel staff and cast members.

MM 3.6-6 Prior to final building and zoning inspections, for hotels, the property owner/developer shall submit an earthquake emergency response plan for review and approval. That plan shall require posted notices in all hotel rooms on earthquake safety procedures.
(Note: Environmental equivalent approved on 1/15/99 to change the timing of the measure.)
MM 3.8-10 Ongoing during demolition and construction, in the event that hazardous waste, including asbestos, is discovered during site preparation or construction, the property owner/developer shall ensure that the identified hazardous waste and/or hazardous material are handled and disposed of in the manner specified by the State of California Hazardous Substances Control Law (Health and Safety Code, Division 20, Chapter 6.5), according to the requirements of the California Administrative Code, Title 30, Chapter 22, and the Uniform Fire Code, Article 87.

MM 3.10.9-4 Prior to Issuance of Building Permit for the undergrounding of the SCE 220kV Electrical Lines, if the SCE 220kV electrical lines are to be undergrounded, then a leak response/safety plan shall be submitted for review and approval and will include, at a minimum, the following information:
a. Leak and spill procedure
b. Location of absorbent materials and containers
c. Storage and handling procedures
d. First aid measures
The plan shall outline the procedures for responding to a leak or other events identified by the Fire Department.

MM 3.10.1-1 The applicant shall implement all project design features or their environmental equivalent. The City of Anaheim Planning Department will ensure compliance through the mitigation monitoring process.

1 Addendum No. 1 to EIR No. 311, which t he City approved in 1996, modified MMP No. 0067.

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R:\Projects\WDI\3WDI000400\Environmental Documentation\PR_SEIR\5.13_Public_Services-090823.docx 5.13-3 Section 5.13 – Public Services MM 3.10.1-2 Prior to commencement of structural framing on each parcel or lot, onsite fire hydrants shall be installed and c harged, as required, by the property owner/developer.

MM 3.10.1-3 Prior to approval of each grading plan, the property owner/developer shall submit an emergency fire access plan to ensure that service to the site is in accordance with the Fire Department service requirements.

MM 3.10.1-4 Prior to issuance of each building permit, the property owner/developer shall submit a Construction Fire Protection Plan which shall include detailed design plans for accessibility of emergency fire equipment, fire hydrant location, and any other construction features required by the Fire Marshal. The property owner/developer shall be responsible for securing facilities acceptable to the Fire Department and hydrants shall be operational with required fire flow.

MM 3.10.1-5 Prior to issuance of each building permit; plans shall indicate that all buildings shall have fire sprinklers installed by property owner/developer , exclusive of parking structures, one-story detached accessory buildings of less than 120 square feet in floor area, and free-standing shade structures that are open on at least two sides to sufficiently prevent the accumulation of smoke and hot gases. Additionally, alternatives to automatic sprinkler systems (e.g., self-contained water mist systems) that provide an equivalent level of fire protection may be approved for other buildings on a case-by-case basis upon review and approval by the Fire Department. (Note: Environmental equivalent approved on 9/27/07 to change the measure to be consistent with applicable fire codes.)
MM 3.10.1-6 Prior to issuance of each building permit, plans shall be submitted to ensure that development is in accordance with the City of Anaheim Fire Department Standards, including:
a. Overhead clearance shall not be less than 14 feet for the full width of access roads.
b. Bridges and underground structures to be used for Fire Department access shall be designed to support Fire Department vehicles weighing 75,000 pounds. c. All underground tunnels shall have sprinklers. Water supplies are required at the entrances. Standpipes shall also be provided when determined to be necessary by the Fire Department.
d. Adequate off-site public fire hydrants contiguous to the Specific Plan area and onsite private fire hydrants shall be provided by the property owner/developer.

The precise number, types, and locations of the hydrants shall be determined during building permit review. Hydrants are to be a maximum of 400 feet apart. e. A minimum residual water pressure of 20 psi shall remain in the water system.

Flow rates for the public parking facilities shall be set at 1,000 to 1,500 gpm.

MM 3.10.1-7 Prior to issuance of the first building permit in Phase II, the property owner/developer shall enter into an agreement with the City of Anaheim to pay or cause to be paid its fair share of the funding for one additional fire inspector to maintain adequate levels of service of ongoing fire inspection of the Project and in the Anaheim Resort.

MM 3.10.1-8 Prior to issuance of the first building permit for Phase II of the Disneyland Resort, excluding permits for demolition or the relocation of the existing SCE transmission DisneylandForward
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R:\Projects\WDI\3WDI000400\Environmental Documentation\PR_SEIR\5.13_Public_Services-090823.docx 5.13-4 Section 5.13 – Public Services lines, the EIR identifies the following equipment in connection with the Project, other development within the CR Overlay and District A of The Disneyland Resort Specific Plan Area, and cumulative development in the Anaheim Resort:
 A vehicle equipped with specialty tools and equipment to enable the Fire Department to provide heavy search and rescue response capability.  A medical triage vehicle/trailer, equipped with sufficient trauma dressings, medical supplies, stretchers, etc., to handle 1,000 injured persons, and an appropriate storage facility.
 One additional fire truck company.
 One additional Paramedic company.
 Modification to existing fire stations to accommodate the additional fire units.

To implement this requirement as it applies to the applicant, the applicant shall provide or cause to be provided funding for the following equipment:
 One fire truck company;
 One paramedic company; and
 Modifications to existing fire stations to accommodate the fire truck company and the paramedic company.

The applicant shall not be required to contribute to the purchase of the other equipment identified in the Final EIR because the applicant has or will provide its own emergency response equipment and personnel.

The City recognizes that these improvements will serve not only the applicant but also other property owners/developers in the Specific Plan area, the Anaheim Resort, and the service area, each of which should contribute its allocable share of the cost of the improvements. To implement this requirement as it applies to other property owners/developers in the Specific Plan area, the Anaheim Resort, and the service area, the City shall, and shall make appropriate arrangements with other public agencies, if any, to reimburse the applicant to the extent that its contributions for these improvements exceed the applicant's allocable share of the cost. Such arrangements shall include one or more of the following: (1) creation of integrated financing districts; (2) entry into a reimbursement agreement with the applicant; (3) creation of appropriate community facilities districts, assessment districts, and/or the use of similar public financing districts and/or mechanisms; and (4) creation of such other mechanisms or districts as may be appropriate to provide for the reimbursement of these costs. The determination of the allocable share of improvement costs attributable to the applicant and other property owners/developers, and reimbursement amounts, shall be based on an apportionment of the costs of such equipment and personnel among property owners/developers, including the applicant, in the Specific Plan area, the Anaheim Resort, or the otherwise defined service area, as applicable, depending on the area served.

To implement this mitigation measure, the City has adopted the Fire Protection Facilities and Paramedic Serv ices Impact Fee Program. Compliance with this Program by the property owner/developer (per Ordinance No. 5496 and Resolution No. 95R-73 dated May 16, 1995) shall satisfy the requirements of this Mitigation DisneylandForward
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R:\Projects\WDI\3WDI000400\Environmental Documentation\PR_SEIR\5.13_Public_Services-090823.docx 5.13-5 Section 5.13 – Public Services Measure, or the City may enter into alternative financing arrangements with the applicant.

MM 3.10.1-9 Prior to approval of street improvement plans, the water supply system shall be designed by the property owner/developer to provide sufficient fire flow pressure and storage for the proposed land use and fire protection in accordance with Fire Department requirements.

MM 3.10.1-10 Prior to final building and zoning inspections; emergency telephone service numbers shall be posted for at least one telephone in each facility (for non-occupied facilities) and emergency telephone service numbers shall be posted at each telephone that is deemed appropriate by the Fire Department in each facility (for occupied facilities); prior to opening day, emergency telephone service numbers will be posted within the Disneyland Resort for all telephones that are deemed appropriate by the Fire Department; the property owner/developer shall place emergency telephone service numbers in prominent locations as approved by the Fire Department. (Note: Environmental equivalent approved on 2/7/00 to change the timing for this measure as the majority of The Disneyland Resort will not be open to the public nor occupied by employees of Disneyland prior to Opening Day, and therefore will not require the posting of emergency telephone service numbers at more than one telephone per facility. Prior to Opening Day, after which time all facilities will be open to the public and occupied by employees, all emergency telephone numbers will be posted, in accordance with the requirements of the Fire Department.) PDF 3.10.1-1 Prior to final building and zoning inspections for the second theme park; ongoing during project operation, the existing services and capabilities of the Disneyland Fire Department shall be extended within the Disneyland Resort. Existing services include preconstruction checks, pre-investigation of fires and alarms, preplanning for fires and evacuations, fire prevention program activities, and monitoring of pyrotechnics and special effects.

MM 3.11-2 Prior to Approval of the First Grading Plan or Issuance of the First Demolition Permit, Whichever Occurs First, for Each Phase, investigation for the presence of cryptic tanks using geophysical methods shall be conducted in the subject area for the property owner/developer by a qualified environmental professional in the areas of former service stations and those areas known or thought to have been formerly occupied by USTs and where tank removal has not been verified prior to excavation or grading in these areas.

Soil sampling or a soil organic vapor survey may be required if soil sampling results are not available or indicate contamination is present above regulatory guidelines.

MM 3.11-3 Prior to removal of underground storage tanks; and, during removal of underground storage tanks, a permit shall be obtained for removal of underground tanks by the property owner/developer. During removal of the underground storage tank, a representative from the Environmental Protection Section shall be onsite to direct soil sampling.

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R:\Projects\WDI\3WDI000400\Environmental Documentation\PR_SEIR\5.13_Public_Services-090823.docx 5.13-6 Section 5.13 – Public Services MM 3.11-4 Ongoing during remediation activities, remediation activities conducted on behalf of the property owner/developer of surface or subsurface contamination not related to USTs shall be overseen by the Orange County Health Department. Information on subsurface contamination from an underground storage tank shall be provided to the Fire Department.
(Note: Mitigation measure references “Fire Department.” This was changed prior to 3/98 to Public Utilities Department, Water Services Administration, Environmental Services inasmuch as the Public Utilities Department now oversees UST and subsurface contamination remediation).

MM 3.11-5 Prior to the approval of the first grading plan or the issuance of the First Phase demolition permit, whichever occurs first, the property owner/developer will submit a plan which details procedures that will be taken if a previously unknown UST or other unknown hazardous materials or waste is discovered onsite.

MM 3.11-6 Prior to approval of grading plan for the Miller Tools/Mobile Brake Site, a site reconnaissance survey of the Miller Tools/Mobile Brake building shall be conducted by a qualified environmental professional for the property owner/developer to assess any potential presence of hazardous materials at this facility. Where possible, interviews with property owners and/or company representatives shall be conducted to obtain information on the hazardous material usage histories and handling practices of the sites and, if available, copies of contaminant investigation reports shall be reviewed to evaluate the presence and level of hazardous substances in the soil at each property. The results of this investigation shall be submitted to the Orange County Health Department for review and approval. If warranted, subsurface investigation and sampling shall be undertaken by a qualified environmental professional in coordination with the Orange County Health Department. Appropriate remediation measures will be developed, if necessary, before demolition, excavation, or grading take place in these areas.

MM 3.11-7 Prior to approval of grading plan or issuance of demolition permit, whichever occurs first, a qualified environmental consultant shall attempt to contact the current and/or known former owners of the following on behalf of a property owner/developer within the C-R Overlay Area; the 7-11 convenience store and the vacant parcels at 1340 S. West Street/Disneyland Drive and 321 West Katella Avenue to obtain information regarding the status of underground tanks and/or tank closures at these sites. If necessary, subsurface investigation and sampling shall be undertaken by a qualified environmental professional. Results of those analyses shall be submitted to the Fire Department for review and approval. The following properties have completed this measure as of July 1996: Katella Car Wash, 350 W. Katella Avenue; the Shell Service Station, 2100 S. Harbor Boulevard; National Car Rental.

MM 3.11-10 Prior to approval of a grading plan or issuance of excavation permit, several representative samples of shallow soils shall be collected and analyzed by the property owner/developer for pesticide and herbicide residue in the West Street/Disneyland Drive agricultural area and the S&S Nurseries area. If soils containing pesticides or herbicides above regulated limits are found, remedial actions shall be carried out before disturbance of the soils. Remedial actions should consist of removal and disposal or treatment of affected soils according to all applicable local, state, and federal regulations.

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R:\Projects\WDI\3WDI000400\Environmental Documentation\PR_SEIR\5.13_Public_Services-090823.docx 5.13-7 Section 5.13 – Public Services PDF 3.11-1 Ongoing during project operation, the current compliance efforts for hazardous materials utilized at the existing Disneyland theme park and Disneyland Hotel described under Section 3.11.1.1, shall be expanded to encompass the Disneyland Resort to ensure compliance with applicable laws and regulations.

Police
MM 3.10.2-1 The applicant shall implement all project design features or their environmental equivalent. The City of Anaheim Planning Department will ensure compliance through the mitigation monitoring process.

MM 3.10.2-2 Ongoing during operation of the Disneyland Resort, the operator of the public parking facilities shall provide an adequate staff of private security officers for patrol and surveillance of the facilities.

MM 3.10.2-3 Prior to the issuance of the first building permit for Phase II of the Disneyland Resort (excluding the relocation of the SCE transmission lines), the property owner/developer shall enter into an agreement with the City of Anaheim to pay or cause to be paid its fair share of the funding for police personnel and equipment necessary to meet the service need of the Anaheim Resort.

MM 3.10.2-4 Prior to final building and zoning inspections for the second theme park, the applicant shall provide space within The Disneyland Security Office, to support the Anaheim Police Department to the satisfaction of the Police Department, based on the following criteria:
 During the design phase of the security area, a police representative shall be kept informed of the plans for the security area.
 All facilities shall be within The Disneyland Resort Security Office on a shared basis.
 Separate holding rooms for adult and juvenile offenders shall be provided for the use of the Disney land Security Department.
 Additional private interview rooms shall be made available for the shared use of the Anaheim Police Department and the Disneyland Security Department, including adequate areas for onsite storage needs and a common area for computers.

MM 3.10.2-5 Prior to issuance of each building permit for parking structures, the Police Department shall review the safety measures incorporated into the building plans for the parking structures within the Specific Plan area to be submitted by the property owner/developer. The security measures shall include the following or other substitute security measures as may be approved by the Police Department:
 For the West and East Public Parking Structure, and the Southwest Parking Facility, closed circuit television surveillance and recording equipment shall be provided.
 For the hotel parking structures, clos ed circuit television surveillance and recording equipment shall be provided.

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R:\Projects\WDI\3WDI000400\Environmental Documentation\PR_SEIR\5.13_Public_Services-090823.docx 5.13-8 Section 5.13 – Public Services  For the Disneyland Administration Building and the South Parking Area (south of Katella Avenue and west of Haster Street), guarded entrance and exit gates shall be provided.

MM 3.10.2-6 Ongoing during operation of the Disneyland Resort, the applicant shall continue to provide anti-gang and substance abuse educational programs which are currently provided for park security cast members.

PDF 3.10.2-1 Ongoing during operations, the Disneyland Security Department shall be expanded to provide equivalent levels of service to the entire Disneyland Resort.

These services will include initial response, investigation, and report writing. Entry points to the theme parks will be patrolled by the Disneyland Security Department.

PDF 3.10.2-2 Prior to issuance of each building permit for each parking facility; to be implemented prior to final building and zoning inspections, in the West and East Public Parking Structures and in the hotel parking structures, closed circuit television monitoring and recording or other adequate security measures will be used extensively.

PDF 3.10.2-3 Ongoing during project operation, the applicant shall continue to provide and expand its Court Liaison program to meet the needs of the Disneyland Resort.

Parks
MM 3.10.4-1 The applicant shall implement all project design features or their environmental equivalent. The City of Anaheim Planning Department will ensure compliance through the Mitigation Monitoring Program process.

MM 3.10.4-2 Prior to issuance of the first building permit for Phase II, the applicant shall enter into an agreement to pay the cost of providing night lighting to two existing ballfields at one or more existing City community parks complete with support amenities, including parking, security lighting, restrooms, spectator seating, and drinking fountains. The applicant shall enter into an agreement with the Parks, Recreation and Community Services Department that delineates the conditions under which payment for improvements will be provided.

PDF 3.10.4-1 Prior to final building and zoning inspections for the Second Theme Park, substantial area within the Disneyland Resort has been designed to encourage utilization by pedestrians in a park-like setting linking key areas of the project. The pedestrian amenities will include landscaped pedestrian walkways linking West Street/Disneyland Drive to Harbor Boulevard; and a new entry plaza for Disneyland and the Second Theme Park where the guest transportation system will drop off guests from the parking facilities and hotels.

PDF 3.10.4-2 Prior to final building and zoning inspections for the Second Theme Park, the applicant will provide an eating area, outside the paid gates, easily accessible to park guests, within the Theme Park District for those who bring their own food.

Design features will include a 50 table layout with comparable spacing to other theme park eating areas. Drinking fountains, security, landscaping, lighting, vending machines, and nearby restrooms/locker facilities will be provided.

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MM 3.10.5-1 The applicant shall implement all project de sign features or their environmental equivalent. The City of Anaheim Planning Department will ensure compliance through the mitigation monitoring process.

MM 3.10.5-2 Prior to issuance of each building permit, the property owner/developer shall provide proof that school impact fees have been paid consistent with State statute.

PDF 3.10.5-1 Ongoing during project operations, the existing Disneyland theme park has developed and/or has engaged in a series of educational programs in cooperation with the local community and regional agencies and organizations, designed to enhance and complement the educational opportunities and experiences for the youth. The 10 educational programs that currently exist are indicated below (see Section 3.10.5, Schools, for detailed information regarding these programs):

1. The Disneyland Creativity Challenge Awards Program

2. Orange County Young Listeners Concerts

3. Junior Achievement (JA)

4. Work Exposure Day at Disneyland

5. Disney Magic Music Days

6. Job Search Strategy Class

7. “Free From Drugs” Program

8. Job Training Opportunities

9. School Support Programs

10. CIF Champion Celebration
The applicant will continue these programs and/or substitute similar programs of equal importance.

Anaheim Resort Specific Plan SEIR No. 340
SEIR No. 340 is a supplemental EIR that reevaluated environmental changes in and around The Anaheim Resort since certification of EIR No. 313 in 1994. The findings of SEIR No. 340 related to public services are summarized below.

Fire Protection
SEIR No. 340 found that implementation of The Anaheim Resort would result in additional calls for fire and/or emergency rescue service, but implementation of standard conditions and MM 5.12- 6 through MM 5.12-17, which require the submitta l of emergency fire access plans to the Fire Department, installation of fire sprinklers, incorporating minimum access requirements, payment of fair share funding for fire protection services, and other related measures, would reduce impacts to less than significant..

Police Protection
SEIR No. 340 found that buildout of The Anaheim Resort would create additional demand for police services, but implementation of MM 5.12-1 through 5.12-5, which require incorporation of DisneylandForward
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R:\Projects\WDI\3WDI000400\Environmental Documentation\PR_SEIR\5.13_Public_Services-090823.docx 5.13-10 Section 5.13 – Public Services safety, accessibility, crime prevention, and secu rity provisions into the design of The Anaheim Resort, as well as the provision of a closed-circuit television monitoring and recording system and private parking lot security services, would reduce impacts to less than significant.

Schools
SEIR No. 340 found that although The Anaheim Resort does not include the development of new housing units, the Project would indirectly generate new school-aged students that would utilize local schools through the addition of new jobs. SEIR No. 340 found that build out of The Anaheim Resort would result in a less than significant impact with incorporation of MM 5.12-17, MM 5.12- 18 and 5.12-19, which require payment of fees and working with the City and schools district to identify opportunities for new schools and school expansion.

Parks
SEIR No. 340 found that implementation of The Anaheim Resort would result in indirect population increase that would increase the demand for parks and recreational facilities, but that such impacts would be less than significant, and no mitigation was required.

Libraries
SEIR No. 340 found that implementation of The Anaheim Resort would have a less than significant impact with implementation of MM 5.12-19 requiring the payment of fees.

SEIR No. 340 Mitigation Measures and Standard Requirements SEIR No. 340 required implementation of the following mitigation measures and compliance with standard requirements regarding public services to reduce potential impacts associated with full buildout of the ARSP.

Fire Protection
MM 5.5-4 Prior to the final building and zoning inspection for a hotel/motel, the property owner/developer shall submit an earthquake emergency response plan for review and approval by the Fire Department. The plan shall require posted notices in all hotel rooms on earthquake safety procedures and incorporate ongoing earthquake training for hotel staff to the satisfaction of the Fire Department.

MM 5.7-1 Prior to issuance of the first grading or demolition permit, whichever occurs first, in areas of former service stations, in areas known or thought to have been previously occupied by USTs, and in areas where tank removal has not been verified prior to excavation or grading the property owner/developer shall retain the services of a qualified environmental professional to conduct an investigation for known, or the presence of, cryptic tanks, using geophysical methods.

Soil sampling or a soil organic vapor survey may be required if soil sampling results are not available, or indicate contamination is present above regulatory guidelines.

MM 5.7-2 Prior to the removal of USTs, the property owner/developer shall obtain a permit from the Environmental Protection Hazardous Materials Management Section of DisneylandForward
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R:\Projects\WDI\3WDI000400\Environmental Documentation\PR_SEIR\5.13_Public_Services-090823.docx 5.13-11 Section 5.13 – Public Services the Fire Department for the removal of such tanks. During the removal of USTs, a representative from the Environmental Protection Section of the Fire Department shall be onsite to direct soil sampling.

MM 5.7-3 Ongoing during remediation all remediation activities of surface or subsurface contamination not related to USTs O ngoing during remediation all remediation activities of surface or subsurface contamination not related to USTs, conducted on behalf of the property owner/developer, shall be overseen by the Orange County Health Care Agency (OCHCA). Information on subsurface contamination from USTs shall be provided to the Public Utilities Department, Environmental Services Division. Santa Ana Regional Water Quality Control Board (SARWQCB) with a copy to Planning & Building.

Note: Per a memo dated October 22, 2014 from the Public Utilities Department, as of July 1, 2014, the Environmental Services Division of the Public Utilities Department is no longer responsible for overseeing the cleanup of new UST cases, and the responsibility has been delegated to the Santa Ana Regional Water Quality Control Board (SARWQCB). However, the Anaheim Fire Department will still be responsible for overseeing the removal of USTs. (amended February 26, 2015).

MM 5.7-4 Prior to issuance of the first grading or demolition permit, whichever occurs first, the property owner/developer shall submit a plan for review and approval by the Fire Department which details procedures that will be taken if previously unknown USTs, or other unknown hazardous material or waste, is discovered onsite.

MM 5.7-5 Prior to issuance of the first grading or demolition permit, whichever occurs first for future developments within the Anaheim Resort Specific Plan area affecting any property on a published list of leaking underground storage tanks (LUST) that has not been officially closed or resolved, a qualified environmental professional, retained by the property owner/developer, shall attempt to contact the current and/or known former property/business owners to obtain information regarding the status of USTs and/or tank closures at these sites. If warranted, subsurface investigation and sampling shall be undertaken by a qualified environmental professional, and results of these analyses shall be submitted to the Fire Department and the Environmental Services Division of the Public Utilities Department Santa Ana Regional Water Quality Control Board (SARWQCB), for review and approval. Appropriate remediation measures will be developed, if necessary, before demolition, excavation, or grading takes place in these areas. A copy of the approval letter with any appropriate remediation measures shall be submitted to Planning & Building.

MM 5.7-6 Ongoing during project demolition and construction, in the event that hazardous waste, including asbestos, is discovered during site preparation or construction, the property owner/developer shall ensure that the identified hazardous waste and/or hazardous material are handled and disposed of in the manner specified by the State of California Hazardous Substances Control Law (Health and Safety Code, Division 20, Chapter 6.5), and according to the requirements of the California Administrative Code, Title 30, Chapter 22.

MM 5.7-7 Prior to issuance of any discretionary permit for a current or former hazardous waste disposal site or solid waste disposal site, the project property owner/developer shall submit a Phase I Environmental Site Assessment to the City. If possible hazardous materials are identified during the site assessments, DisneylandForward
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R:\Projects\WDI\3WDI000400\Environmental Documentation\PR_SEIR\5.13_Public_Services-090823.docx 5.13-12 Section 5.13 – Public Services the appropriate response/remedial meas ures will be implemented in accordance with the requirements of the Orange County Health Care Agency (OCHCA) and/or the Regional Water Quality Control Board (RWQCB), as appropriate.

MM 5.12-5 Prior to commencement of structural framing on each parcel or lot, onsite fire hydrants shall be installed and char ged by the property owner/developer as required and approved by the Fire Department.

MM 5.12-6 Prior to issuance of each grading permit, the property owner/developer shall submit an emergency fire access plan to the Fire Department for review and approval to ensure that service to the site is in accordance with Fire Department service requirements.

MM 5.12-7 Prior to issuance of each building permit; to be implemented prior to the final building and zoning inspection, plans shall indicate that all buildings, exclusive of parking structures, shall have sprinklers installed by the property owner/developer in accordance with the Anaheim Municipal Code. Said sprinklers shall be installed prior to each final building and zoning inspection.

MM 5.12-8 Prior to issuance of each building permit, plans shall be submitted to ensure that development is in accordance with the City of Anaheim Fire Department Standards, including:
a. Overhead clearance shall not be less than 14 feet for the full width of access roads.
b. Bridges and underground structures to be used for Fire Department access shall be designed to support Fire Department vehicles weighing 75,000 pounds.
c. All underground tunnels shall have sprinklers. Water supplies are required at all entrances. Standpipes shall also be provided when determined to be necessary by the Fire Department.
d. Adequate off-site public fire hydrants contiguous to the Specific Plan area and onsite private fire hydrants shall be provided by the property owner/developer.

Flow rates for public parking facilities shall be set at 1,000 to 1,500 gpm.

MM 5.12-9 Prior to issuance of the first building permit, the property owner/developer shall enter into an agreement recorded against the property with the City of Anaheim to pay or cause to be paid their fair share of the funding to accommodate the following, which will serve the Anaheim Resort Specific Plan area:
a. One additional fire truck company.
b. One additional paramedic company.
c. Modifications to existing fire stations to accommodate the additional fire units, additional manpower, equipment, and facilities.
d. A vehicle equipped with specialty tools and equipment to enable the Fire Department to provide heavy search and rescue response capability.

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R:\Projects\WDI\3WDI000400\Environmental Documentation\PR_SEIR\5.13_Public_Services-090823.docx 5.13-13 Section 5.13 – Public Services e. A medical triage vehicle/trailer, equipped with sufficient trauma dressings, medical supplies, stretchers, etc., to handle 1,000 injured persons, and an appropriate storage facility.

The determination of the allocable share of costs attributable to the property owner/developer shall be based on an apportionment of the costs of such equipment/facilities among property owners/developers in the Hotel Circle Specific Plan Area, the Disneyland Resort Specific Plan Area and the Anaheim Resort Specific Plan Area or the otherwise defined service area, as applicable, depending on the area served. (Note: To implement this mitigation measure, the City has adopted the Fire Protection Facilities and Paramedic Services Impact Fee Program. Compliance with this Program by the property owner/developer (per Ordinance No. 5496 and Resolution No. 95R-73 dated May 16, 1995) shall satisfy the requirements of this Mitigation Measure, or the City may enter into alternative financing arrangements.)
MM 5.12-10 Prior to each final building and zoning inspection, the property owner/developer shall place emergency telephone service numbers in prominent locations as approved by the Fire Department.

MM 5.12-11 Prior to issuance of each building permit, the property owner/developer shall submit a Construction Fire Protection Plan to the Fire Department for review and approval detailing accessibility of emergency fire equipment, fire hydrant location, and any other construction features required by the Fire Marshal. The property owner/developer shall be responsible for securing facilities acceptable to the Fire Department and hydrants shall be operational with required fire flow.

MM 5.12-12 Prior to the approval of each Final Site Plan and prior to the issuance of each building permit, plans shall be reviewed and approved by the Fire Department as being in conformance with the Uniform Fire Code.

MM 5.12-13 Prior to the placement of building materials on a building site, an all-weather road shall be provided from the roadway system to and on the construction site and for fire hydrants at all times, as required by the Fire Department. Such routes shall be paved or, subject to the approval of the Fire Department, shall otherwise provide adequate emergency access. Every building constructed must be accessible to Fire Department apparatus. The width and radius of the driving surface must meet the requirements of Section 10.204 of the Uniform Fire Code, as adopted by the City of Anaheim.

MM 5.12-14 Prior to approval of building plans, the property owner/developer shall provide written evidence to the satisfaction of the Fire Department that all lockable pedestrian and/or vehicular access gates shall be equipped with “knox box” devices as required and approved by the Fire Department.

MM 5.12-15 Prior to approval of on-site water plans, unless each commercial building is initially connected to separate fire services, an unsubordinated covenant satisfactory to the City Attorney’s Office shall be recorded prohibiting any individual sale of buildings until separate fire services are in stalled in the building(s) subject to the sale.

MM 5.12-16 Prior to approval of water improvement plans, the water supply system shall be designed by the property owner/developer to provide sufficient fire flow pressure DisneylandForward
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MM 5.15-2 Prior to issuance of each building permit, all water supply planning for the project will be closely coordinated with, and be subject to the review and final approval of, the Public Utilities Department, Water Engineering Division and Fire Department.

SR 5.12-1 Prior to the final building and zoning inspection, the property owner/developer shall provide evidence to the Planning Director/Planning Services Manager of full payment of applicable fire facilities fees as deemed appropriate by the Fire Department.

Police Protection
MM 5.12-1 Prior to the approval of each Final Site Plan and issuance of each building permit, the property owner/developer shall submit plans to the Police Department for review and approval for safety, accessibility, crime prevention, and security provisions during both the construction and operative phases for the purpose of incorporating safety measures in the project design including the concept of crime prevention through environmental design (e.g., building design, circulation, site planning, and lighting of parking structures and parking areas).

MM 5.12-2 Prior to the issuance of each building permit for a parking structure, the property owner/developer shall submit plans to the Police Department for review and approval indicating the provision of closed-circuit television monitoring and recording or other substitute security measures as may be approved by the Police Department. Said measures shall be implemented prior to final building and zoning inspections.

MM 5.12-3 Ongoing during project operation, the property owner/developer shall provide private security on the premises to maintain adequate security for the entire project subject to review and approval of the Police Department. The use of security patrols and electronic security devices (i.e., video monitors) should be considered to reduce the potential for criminal activity in the area.

MM 5.12-4 Prior to issuance of each building permit, the project design shall include parking lots and parking structures with controlled access points to limit ingress and egress if determined to be necessary by the Police Department and shall be subject to the review and approval of the Police Department.

Schools
MM 5.12-17 Prior to issuance of each building permit, the property owner/developer shall provide proof of compliance with Government Code Section 53080 (Schools).

MM 5.12-18 Ongoing, the City will work cooperatively with school districts to identify opportunities for new schools and school expansion.

Library
MM 5.12-19 Prior to the issuance of a building permit, the property owner/developer shall comply with the Anaheim Municipal Code , Section 17.08.385, Public Library Facilities Services Areas – Payment of Fees Required.

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R:\Projects\WDI\3WDI000400\Environmental Documentation\PR_SEIR\5.13_Public_Services-090823.docx 5.13-15 Section 5.13 – Public Services

5.13.2 ENVIRONMENTAL SETTING
The following discussion details the existing conditions at the time the City published the NOP for Subsequent EIR No. 352; however, consistent with CEQA’s subsequent review standards, the previously approved projects serve as the baseline for the CEQA analysis, and Draft Subsequent EIR No. 352 compares the effects of the Project changes on the previously approved projects with the effects of the previously analyzed and approved projects, as detailed in EIR No. 311 and SEIR No. 340.

A. Existing Conditions
Fire Protection
The City of Anaheim Department of Fire & Rescue (AF&R) is a full-service organization designed to provide essential public safety and emergency services to the community and its visitors.

Currently 11 engines, 6 trucks, 2 battalion chiefs, and 2 medic units (assigned to the Disneyland Resort) are staffed daily by 70 members from 11 fire stations (12th fire station is pending in the Platinum Triangle District). Please refer to Table 5.13-1 for a summary of the Fire Protection resources in the City of Anaheim. The department operates its own AF&R ambulances. The department maintains a staffing of three to four firefighters per company on all front-line companies. The department recently re-activated one of the two companies that were closed during the recent economic downturn without adding staffing. This was accomplished by redistributing their concentration of resources while maintaining their effective response force (AF&R 2023).

The department operates a 3-shift system and has established a minimum staffing of 70 suppression personnel per shift, per day, at least 95 percent of the time. This includes personnel assigned, under contract, to the Disneyland Resort. The department maintains a minimum of 4 firefighters on 15 front line companies and 3 firefighters on 24 front line companies (AF&R 2023).

The department has adopted and follows the expectations of the National Incident Management System (NIMS), a program used in the United States to coordinate emergency preparedness and incident management among various federal, State, and local agencies (AF&R 2023).

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R:\Projects\WDI\3WDI000400\Environmental Documentation\PR_SEIR\5.13_Public_Services-090823.docx 5.13-16 Section 5.13 – Public Services TABLE 5.13-1

CITY OF ANAHEIM FIRE SERVICES FACILITIES

Station Station Address Equipment
Downtown Station 1 500 East Broadway Street Paramedic Engine 1, Truck 1, Type 3-301 and Ambulance 1 Rehab-1
Brookhurst Station 2 2141 West Crescent Avenue Paramedic Engine 2 and Truck 2 US&R 2 Ambulance 2
Resort Station 3 1717 South Clementine Street
Paramedic Engine 3, Truck 3, Type 3-309,
Paramedic 3 (Disney) and Ambulance 3
Light Air 3
Orange Station 4 2736 West Orange Avenue Paramedic Engine 4 La Palma Station 5 2540 East La Palma Avenue Paramedic Engine 5 Type 3-305, MMRS 1 and Ambulance 5
Euclid Station 6 1330 Euclid Street
Paramedic Engine 6, Truck 6, Battalion 2,
Ambulance 6, and Hazmat 6 Paramedic 6
(Disney)
Stadium Station 7 2222 East Ball Road Paramedic Engine 7 Riverdale Station 8 4555 East Riverdale Avenue Battalion 1, Paramedic Engine 8, Truck 8, Type 6-601 and Type 3-308
Anaheim Hills Station 9 6300 East Nohl Ranch Road Paramedic Engine 9 Type 6-602 Water Tender 1 and Ambulance 9
Weir Canyon Station 10 8270 East Monte Vista Avenue Paramedic Engine 10 Type 3-310 Twila Station 11 3078 West Orange Avenue Paramedic Engine 11 OES Engine 414 and Ambulance 11 OES Type 3-1211
USAR: Urban Search and Rescue; Hazmat: hazardous materials unit Source: Young 2022

Fire stations are strategically located to ensure an efficient demand response to all risk hazards and to maintain recommendations for response times. National response time standards for emergency response requires first engine response within 5 minutes to 90 percent of all incidents and 8 minutes to the remaining 10 percent. The department also requires a maximum of 10 minutes for truck company response to 100 percent of all incidents(AF&R 2023).

In addition to fire protection services, the department provides emergency rescue and medical services. Because the majority of calls placed to the department are requests for medical aid, the department maintains a Paramedic Membership Program that guarantees that participants pay no out-of-pocket expenses for emergency medical services provided by the AF&R. This program applies to residents of the City of Anaheim so the program has no bearing on the guests that visit The Disneyland Resort. However, the program does not cover ambulance services provided by a private company that coordinates with the department (AF&R 2023).

The City is also part of a regional coordination system with other firefighting agencies. Fire units are dispatched through the Metro Cities Fire Authority. The Metro Cities Fire Communications Center currently serves the citizens of eight cities: Anaheim, Brea, Fountain Valley, Fullerton, Garden Grove, Huntington Beach, Newport Beach, and Orange. The Communication Center, commonly referred to as Metro Net, is located in the City of Anaheim and dispatches fire and emergency medical services for more than 1.2 million citizens residing in 188 square miles in Orange County. The AF&R manages the day-to-day operations of the Center. In addition to fire protection services, the department provides emergency rescue and medical services to Anaheim residents and visitors (AF&R 2023).

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R:\Projects\WDI\3WDI000400\Environmental Documentation\PR_SEIR\5.13_Public_Services-090823.docx 5.13-17 Section 5.13 – Public Services The AF&R, Community Risk Reduction Division is comprised of four sections: life safety, community relations, hazardous materials, and new development. The division has a mission of reducing risk through a professional balance of engineering, education, and enforcement of adopted codes and standards. This mission is accomplished by use of a staff comprised of full and part-time employees. The staff members are trained and equipped to carry out the goals and objectives of the division that supports the overall department’s strategic plan (AF&R 2023).

The department operates an adequate, effective, and efficient program directed toward fire prevention; life safety; hazard risk reduction; the detection, reporting, and control of fires and other emergencies; the provision of occupant safety and exiting; and the provisions for first aid firefighting equipment (AF&R 2023).

The City adopted the 2022 California Fire Code as the fire prevention code by reference and the 2021 International Fire Code with California amendments (as codified within Part 9, Title 24 of the California Code of Regulations on January 1, 2023). The adopting ordinance also contains local amendments that are codified in Chapter 16.08 of the Anaheim Municipal Code (AF&R 2023).

The City entered into an agreement with Disney in 2001 to provide paramedic services for The Disneyland Resort Project. As part of this Project, this agreement would be amended to also cover the Disney ARSP Properties.

Police Protection
The City of Anaheim Police Department (Police Department) provides law enforcement services to over 330,000 residents and approximately 5,000 businesses in the City. Law enforcement services include traffic control and enforcement, nar cotics violations, crime control, community and tourist regulations, detention facilities, various investigations, and patrol. The Police Department is divided into four service districts (Main, South, East, and West) each containing a police station (see Table 5.13-2 below). The Project Site is located within the Main and South Districts and is served by the Main and South Stations. The Fullerton Municipal Airport, located at 4011 West Commonwealth Avenue in the City of Fullerton, has a police heliport and houses the Anaheim Police Department’s three helicopters.

TABLE 5.13-2

CITY OF ANAHEIM POLICE STATION FACILITIES

Police Station Location Distance to the Project Site
Main Station 425 South Harbor Boulevard 0.5 miles
South 1520 South Disneyland Drive 0 miles
West 320 South Beach Boulevard 3.9 miles
East 8201 East Santa Ana Canyon Road 10.5 miles
Source: Anaheim 2022

The Police Department prioritizes calls into five categories. With Priority 1 calls, Communications will immediately send the closest available patrol , traffic or K-9 unit based on availability. If no police units clear, nearest units from another area are dispatched. With Priority 2 calls, if no district unit is available, Communications will locally broadcast the information to district units to clear and respond. After one minute, if no district unit is available, Communications will immediately send the closest available patrol or K-9 unit. The goal is to send police units that are assigned to that particular geographical area. Priority 3 calls are calls that may hold for up to 25 minutes if area units are busy on the calls. If 25 minutes pass and no units are available, the dispatcher would send the closest available area unit. Priority 4 and 5 calls will remain in the pending call DisneylandForward
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R:\Projects\WDI\3WDI000400\Environmental Documentation\PR_SEIR\5.13_Public_Services-090823.docx 5.13-18 Section 5.13 – Public Services queue until an officer self-dispatches to an incident. Patrol Officers and Field Supervisors will continually monitor the queue, including the details of pending incidents, giving consideration to calls with potential to escalate in priority, to determine the order in which they will respond, usually consist of cold report calls or information for field units and can hold indefinitely if units are busy on higher priority calls (Carter, Griswold 2022).

The City entered into an agreement with Disney in 2000 to provide police services for The Disneyland Resort Project. As part of this Project, this agreement would be amended to also cover the Disney ARSP Properties.

Schools
The Anaheim Elementary School District (AESD) serves approximately 17,000 students, employs more than 2,000 people, and operates 24 elementary schools (kindergarten through sixth grades [K–6]) within the City limits (AESD 2021). The AESD has prepared the Anaheim City School District Facility Planning and Development Facilities Master Plan, 2010 – 2030, which outlines a strategy for significant new construction, modernization, and additions to the AESD.

The Anaheim Union High School District (AUHSD) has a student population of approximately 31,000 with 21 campuses, including Adult Education and employees almost 3,000 people (AUHSD 2022). The District covers 46 square miles and serves the Cities of Anaheim, Cypress, Buena Park, La Palma, and Stanton. The AUHSD serves grades 7–12 and includes 8 junior high schools (grades 6–8); 10 high schools (grades 9–12); 1 comprehensive school (grades 7-12); and 6 alternative education facilities.

Parks
On-site Recreational Resources
The City of Anaheim owns and operates nearly 50 developed parks totaling almost 700 acres.

Park facilities include neighborhood, community, and special use parks. Furthermore, the City has over 50 miles of developed and proposed riding and hiking trails. These trails link residents to parks and community facilities, and the Riding and Hiking Tails Master Plan links residents to the regional system, to the Cleveland National Forest, and the inter-county Santa Ana River Trail.

Open space areas are, by design, either active or passive. Active recreational areas typically include facilities such as tailored playing surfaces, buildings, parking areas, and similar modifications to a natural site. Passive recreational areas accommodate less structured recreational pursuits and typically include minor modifications such as trails, service vehicle access improvements, enhanced landscape materials, and similar non-intrusive changes to the Project Site.

The City of Anaheim has different types of public recreational open space areas, including special use parks, such as mini-parks, nature centers, and specialized recreation centers; neighborhood parks; and community parks (Anaheim 2004b).

Off-site Recreational Uses
State of California
Chino Hills State Park is a 13,452-acre natural open space area owned and operated by California State Parks and located just outside the eastern City limits. Amenities throughout the park include DisneylandForward
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R:\Projects\WDI\3WDI000400\Environmental Documentation\PR_SEIR\5.13_Public_Services-090823.docx 5.13-19 Section 5.13 – Public Services hiking, biking, and riding trails; picnic areas; and an equestrian staging area (California State Parks 2021). This park is designed to serve a regional population.

County of Orange
The County of Orange owns and operates three regional parks located in or near the City: Yorba, Featherly, and Santiago Oaks. Regional parks are usually 50 acres or more in size; generally serve between 50,000 and 100,000 people; and can be located up to 30 miles away. In addition to regional parks, the County operates approximately 30 miles of hiking, biking, and equestrian trails in or near the City, including the Santa Ana River Trail (Anaheim 2004a).

City of Anaheim
Local Parks
Within the City of Anaheim, local parks include both Neighborhood and Community Parks.

Community parks, by design, serve a larger area than neighborhood parks. Neighborhood parks are the most common type of park in Anaheim, with 24 facilities located throughout the City. These parks range in size from 5 to 15 acres; have a service radius of 0.5 mile; and are located in the neighborhoods they serve, thereby enabling people to walk or bike to the park. Community Parks are larger in size than Neighborhood Parks, ranging in size from 15 to 50 acres, and provide similar amenities to Neighborhood Parks (Anaheim 2004a).

Special Use Parks
Mini-Parks
Often called pocket parks, these are the smallest type of park and are usually less than five acres in size. They often consist of passive recreational uses (although basketball, children’s play areas and other active uses can be included); provide little to no parking; and serve a relatively small area. George Washington Park, Walnut Grove Park, Cottonwood Park, Little People’s Park, and Juliana Park are examples of this type of park (Anaheim 2004a).

Other Local Recreational Facilities
The City of Anaheim operates specialized recreation centers and Special Use Parks that serve specialized, citywide recreational needs and often focus on one specific activity. These facilities include nature centers, City-owned golf courses, the Downtown Community Center, and the Anaheim Wetlands (Anaheim 2004a).

Adequate Supply of Parks
The City currently maintains park dedication standards that require new development to ensure that 2 acres of parkland would be developed for each 1,000 residents added by the proposed development. Depending upon the magnitude of the residential development, the dedication may be in the form of direct dedication of improved land, the payment of fees in lieu of dedication, or a combination of both. The City has a dedication ordinance and park dedication fees are adjusted annually. While serving as important amenities for future development, private parks and open space amenities are not counted toward meeting park fee credits.

To supplement its own recreational facilities, the City has also entered into joint-use agreements with local school districts. School facilities such as gymnasiums, play equipment, sports fields, swimming pools, and classrooms play a very impor tant role in meeting residents’ recreational DisneylandForward
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R:\Projects\WDI\3WDI000400\Environmental Documentation\PR_SEIR\5.13_Public_Services-090823.docx 5.13-20 Section 5.13 – Public Services needs and are available to the public as a result of these agreements. City golf courses, regional parks, neighboring cities’ facilities and other specialized facilities, including the Angel Stadium of Anaheim, the Arrowhead Pond of Anaheim. Disneyland, Disney’s California Adventure, Disney Ice, and the Anaheim Convention Center also fill more specialized commercial recreational needs (Anaheim 2004a).

Libraries
The Anaheim library system includes a central library and six branch libraries along with the Anaheim Heritage Center, Founders Park, Books on the Go! (self-service kiosk at Anaheim Regional Transportation Intermodal Center), and mobile library services including a mobile library and STEAM Van.

Two Anaheim Public Libraries are within the vicinity of the Project Site. The Central Library, located at 500 West Broadway, is the largest of the locations with 222,664 items in its collection as of January 2022. Central Library opened in 1963 and is the main anchor for the Anaheim Public Library System. Ponderosa Joint Use Branch, located at 240 East Orangewood Ave, is the closest to the Project Site. This branch opened in 2010 and provides an after school public library location for the community as of January 2012. The Anaheim Public Library System has 315,842 library card holders and a total collection size of 545,890 items as of January 2022 (Lujan 2022).

B. Regulatory Framework
Fire Protection
California Fire Code
The California Fire Code and Office of the State Fire Marshal provides regulations and guidance for local agencies in the development and enforcement of fire safety standards. The California Fire Code also establishes minimum requirements that would provide a reasonable degree of safety from fire, panic, and explosion.

City of Anaheim General Plan Public Services and Facilities Element The Public Services and Facilities Element of the City of Anaheim General Plan addresses fire protection and emergency services. Applicable goal s and policies from the Public Services and Facilities Element that are related to fire protection and that are applicable to the Project are provided in Table 5.10-1 in Section 5.10, Land Use and Planning, with a project consistency analysis.

Police Protection
City of Anaheim General Plan Public Services and Facilities Element The Public Services and Facilities Element of the City of Anaheim General Plan addresses law enforcement and crime prevention. Applicable goal s and policies from the Public Services and Facilities Element that are related to police protection and that are applicable to the Project are provided in Table 5.10-1 in Section 5.10, Land Use and Planning, with a project consistency analysis.

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California Education Code
California Education Code Section 17620 authorizes school districts to require construction projects within the boundaries of the districts to pay a fee used for funding construction or reconstruction of school facilities.

City of Anaheim General Plan, Public Services and Facilities Element The Public Services and Facilities Element of the City of Anaheim General Plan addresses school facilities. Applicable goals and policies from the Public Services and Facilities Element that are related to schools and that are applicable to the Project are provided in Table 5.10-1 in Section

5.10, Land Use and Planning, with a project consistency analysis.

Senate Bill 50
Senate Bill 50 (SB 50 or “Leroy Greene School Facilities Act”), enacted in 1998, represents the most significant school facility finance and developer fee reform legislation for school facilities construction and modernization since the adoption of the 1986 School Facilities Act. The payment of school mitigation impact fees authorized by SB 50 is deemed to provide full and complete mitigation of project impacts on school facilities. SB 50 provides that a State or local agency may not deny or refuse to approve the planning, use, or development of real property on the basis of a developer’s refusal to provide mitigation in amounts in excess of that established by SB 50.

SB 50 authorized statewide bonds in the amount of $9.2 billion, with $2.9 billion for new kindergarten through twelfth grade (K–12) construction to add capacity to local school districts. In 2002, Assembly Bill 16 modified the School Facility Program and authorized two additional statewide bond measures. Proposition 47 provided $11.4 billion for K–12 schools and was approved by the voters in November 2002 ($8 billion for new construction). A second bond measure in the amount of $10 billion for K–12 schools ($7.7 billion for new construction) was approved by the voters in 2004.

California Government Code, Section 65995
California Government Code, Section 65995 establishes the statutory criteria for assessing construction fees, also known as “developer’s fees”. The legislation has recognized the need for the fees to be adjusted periodically to keep pace with inflation; therefore, the State Allocation Board increases the maximum fees according to the adjustment for inflation in the statewide cost index for Class B construction.

Parks
City of Anaheim General Plan, Green Element
The City of Anaheim General Plan’s Green Element addresses the provision of open space, conservation, recreation, and landscaping resources. It includes existing parks and open space, and also potential recreational opportunities such as schools, utility easements, water uses, and vacant land. Applicable goals and policies from the Green Element that are related to recreation and are applicable to the Project are provided in Table 5.10-1 of Section 5.10, Land Use and Planning, with a project consistency analysis.

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R:\Projects\WDI\3WDI000400\Environmental Documentation\PR_SEIR\5.13_Public_Services-090823.docx 5.13-22 Section 5.13 – Public Services City of Anaheim Municipal Code
Per the Anaheim Municipal Code (Section 17.08.250), the City currently maintains park dedication standards that require new development in the City to ensure that 2 acres of parkland would be developed for each 1,000 residents. The dedication may be in the form of improved land, the payment of fees in lieu of dedication, or a combination of both. Per Table 5.10-1 of Section 5.10, Land Use and Planning, this is consistent with Goal 1 of Policy 18.1 of the City of Anaheim General Plan’s Green Element.

The Quimby Act
The California Legislature first established the Quimby Act in 1975 and amended the act in 1982.

Per the Quimby Act, California allows a City or County to pass an ordinance that requires, as a condition of approval of a subdivision, the dedication of land; the payment of a fee in lieu of dedication; or a combination of both for park or recreational purposes (California Government Code § 66477). This legislation establishes maximum parkland dedication standards for new subdivision development unless the amount of existing neighborhood and community parkland exceeds the limit.

Libraries
City of Anaheim General Plan, Public Services and Facilities Element The Public Services and Facilities Element of the City of Anaheim General Plan addresses library services. Applicable goals and policies from the Public Services and Facilities Element that are related to library services and that are applicable to the Project are provided in Table 5.10-1 in Section 5.10, Land Use and Planning, with a project consistency analysis.

City of Anaheim Municipal Code
Per the Anaheim Municipal Code (Section 17.08.385), the City currently requires that any developer of a property that cannot be adequately or properly served by existing public library services either implement a public library services plan or be responsible for payment of fees based on the actual or estimated cost of public library services, as a condition of approval of any final map or parcel map.

5.13.3 PROJECT IMPACT ANALYSIS
A. Methodology
Fire Protection
The information in this section regarding fire protection services is summarized from the Anaheim General Plan and Zoning Code Update EIR 330 (May 2004); the Anaheim Fire and Rescue Strategic Plan 2015–2020 (AF&R 2015); the Accreditation Report (AF&R 2014); and Standards of Cover (AF&R 2013). In addition, the City of Anaheim Department of Fire & Rescue (AF&R) was contacted to determine the departments’ ability to provide services.

Police Protection
Information regarding current police services was generated from information in the Public Services and Facilities Element of the City of Anaheim General Plan (May 2004) and the Anaheim DisneylandForward
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R:\Projects\WDI\3WDI000400\Environmental Documentation\PR_SEIR\5.13_Public_Services-090823.docx 5.13-23 Section 5.13 – Public Services General Plan and Zoning Code Update EIR 330 (May 2004). In addition, the City of Anaheim Police Department was contacted to determine the Police Department’s ability to provide services.

Schools
The following information is based on the websites of the AESD and AUHSD and coordination with Disney.

Parks
Existing parks and recreational facility data was compiled from the City of Anaheim General Plan (May 2004), the Anaheim General Plan and Zoning Code Update EIR 330 (May 2004), and the California State Parks website (California State Parks 2021).

Libraries
The following information is based on data from the City of Anaheim General Plan (May 2004). In addition, City of Anaheim library services staff was contacted to determine if the Project would significantly impact the City’s abilities to provide library services.

B. Thresholds of Significance
The following significance criterion is derived from the City of Anaheim Environmental Checklist.

The Project would result in a significant impact related to public services if it would:

Threshold 5.13a: Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:
(i) Fire Protection?
(ii) Police Protection?
(iii) Schools?
(iv) Parks?
(v) Other Public Facilities?
C. Standard Requirements
No standard requirements for this resource topic apply to the Project.

D. Impact Analysis
Threshold 5.13a: Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause DisneylandForward
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R:\Projects\WDI\3WDI000400\Environmental Documentation\PR_SEIR\5.13_Public_Services-090823.docx 5.13-24 Section 5.13 – Public Services 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?
No New Impact from EIR No. 311; No New Impact from SEIR No. 340 – Project Impact Less Than Significant With Mitigation. EIR No. 311 determined that The Disneyland Resort Project would result in a less than significant impact related to fire protection services with implementation of mitigation. According to SEIR No. 340, buildout of the ARSP would create additional demand for fire and/or emergency rescue services; however, adherence to standard requirements and implementation of mitigation would reduce impacts to less than significant.

The Project Site is served by the AF&R for fire protection services. Implementation of the Project would allow the transfer of previously approved uses to Disney Properties in the Project Site, as detailed in Section 3.0, Project Description, of this Draft Subsequent EIR. No new uses are proposed, however, allowable uses would have the potential to occur in different locations and configurations within the Project Site. These changes have the potential to alter existing access routes and the anticipated density of development in certain areas. The Project would also result in changes to the interface with off-site properties through the introduction of different types of uses in new areas, including along the Project Site’s boundaries. According to AF&R, the Project would result in an additional demand for personnel, including one Community Risk Reduction Officer to handle construction related activities and one to handle all annual inspection, integrated systems testing, and permitting, as well as facilities to house the additional personnel (Young 2022). This increase in demand for fire protection services would represent a potentially significant impact. Implementation of MM PS-14, which requires construction of a substation in the Theme Park District, would reduce this impact to less than significant. Additionally, fees have been paid for fire services as required by the MMP for The Disneyland Resort Project to fund staffing, equipment and facilities as needed to serve the demand for fire protection services. The City entered into an agreement with Disney in 2001 to provide paramedic services for The Disneyland Resort Project. As part of this Project and through implementation of MM PS-7, Disney and the City would enter into a Fire Operations Agreement to replace the existing Paramedic Agreement and to cover all Disney Properties in the Project Site. Disney would be responsible for continued payment of fees. Further, consistent with existing conditions, AF&R has dedicated personnel under contract to the Disneyland Resort, and would continue to do so in the future.

Additionally, implementation of MM PS-1 through MM PS-15, MM HAZ-2 through MM HAZ-6, MM NOI-1, MM UTIL-3, and PDF PS-1 would further ensure adequate fire and safety services are provided and would minimize demand on fire and safety services. These mitigation measures address requirements related to fire hydrants, emergency access, emergency fire equipment, hazardous materials, building sprinklers, fire safety building specifications, fire flow pressure and storage, and visible emergency contact information.

The Project would result in a less than significant impact with mitigation related to fire protection services. This impact would not be new or substantially more severe when compared with the impact analyses in EIR No. 311 and SEIR No. 340.

R:\Projects\WDI\3WDI000400\Environmental Documentation\PR_SEIR\5.13_Public_Services-090823.docx 5.13-25 Section 5.13 – Public Services service ratios, response times or other performance objectives for any of the public services:
(ii) Police Protection?
No New Impact from EIR No. 311; No New Impact from SEIR No. 340 – Project Impact Less Than Significant With Mitigation. EIR No. 311 determined that The Disneyland Resort Project would result in a less than significant impact related to police protection services with implementation of mitigation. According to SEIR No. 340, buildout of the ARSP would create additional demand for police services, however, implementation of mitigation would reduce impacts to less than significant.

As stated previously, the Project Site is se rved by the Anaheim Police Department (APD). APD is responsible for patrol, investigations, traffic enforcement, traffic control, vice and narcotics enforcement, airborne patrol, crime suppression, community policing, tourist-oriented policing, and detention facilities. Implementation of the Project may increase the demand for police protection services. Implementation of the Projec t would reallocate previously approved uses among Disney Properties in the Project Site, as detailed in Section 3.0, Project Description, of this Draft Subsequent EIR. No new uses are proposed; therefore, the demand on police protection services would be consistent with what wa s previously analyzed in EIR No. 311 and SEIR No. 340. According to Anaheim Police, the Project would result in additional demand requiring new facilities, potential for expanding current facilities, additional staffing, and additional equipment (Griswold 2022). This increase in demand for police protection services would represent a potentially significant impact. Implementation of MM PS-24 and MM PS-25 , which require construction of a Police Substation in the Theme Park District and a Satellite Office in the Southeast District or the Theme Park East Overlay, all of which are within the defined development footprint for the DisneylandForward Project as evaluated throughout this Draft Subsequent EIR, would reduce this impact to less than significant. Additionally, fees have been paid for police services as required by the MMP for The Disneyland Resort Project to fund staffing, equipment and facilities as needed to serve the demand for police protection services. The City entered into an Agreement with Disney in 2000 to provide police services for The Disneyland Resort Project. As part of this Project, Disney and the City would enter into a Police Operations Agreement to replace the existing Agreement and to cover all Disney Properties in the Project Site. Therefore, implementation of MM PS-16, which requires payment of all applicable police protection fees, would reduce impacts related to provision of new or altered facilities to maintain service ratios to less than significant.

Additionally, implementation of MM PS-16 through MM PS-25 and PDF PS-2 would further ensure adequate police protection are provided and would minimize demand on police services. These MMs address requirements related to private security officers and surveillance; safety measures for parking structures; and anti-gang and substance abuse educational programs.

The Project would result in a less than significant impact with mitigation related to police protection services. This impact would not be new or substantially more severe when compared with the impact analyses in EIR No. 311 and SEIR No. 340.

R:\Projects\WDI\3WDI000400\Environmental Documentation\PR_SEIR\5.13_Public_Services-090823.docx 5.13-26 Section 5.13 – Public Services service ratios, response times or other performance objectives for any of the public services:
(iii) Schools?
Reduced Impact from EIR No. 311; No New Impact from SEIR No. 340 – Project Impact Less Than Significant With Mitigation. EIR No. 311 determined that The Disneyland Resort Project would not result in any direct impacts on local school districts. However, EIR No. 311 identified significant and unavoidable indirect impacts related to school enrollment due to over-capacity situations in the Anaheim Union High School District and the Anaheim City School District.

According to SEIR No. 340, buildout of the ARSP would generate new school-aged students, however, implementation of mitigation would reduce impacts to less than significant.

The Project does not involve the construction of new dwelling units. Additionally, development of the Project would not increase square footage that has already been entitled. Therefore, direct impacts on the AESD or the AUHSD are not expected to occur as a result of the Project. However, development of the Project could produce an indirect impact, increasing population in the City by approximately 6,079 related to new employees choosing to relocate to the City of Anaheim. This indirect increase in population has the potential to indirectly increase the number of school-aged children served by AESD and AUHSD. Although not required under State law, Disney entered into an agreement with the AESD, formerly known as the Anaheim City School District, for early payment of the fees for buildout of The Disneyland Resort Project. However, impacts to AUHSD would be potentially significant. Implementation of MM PS-26 requires payment of school impact fees intended to fund staffing, equipment and facilities as needed to serve the demand for schools; therefore, no additional fees are required to minimize impacts on schools. With payment of the required fees, less than significant impacts related to schools would occur. Additionally, with implementation of PDF PS-3, Disney would continue to provide educational programs in cooperation with the local community that are designed to enhance and complement the other existing educational opportunities and experiences within the community.

The Project would result in a less than significant impact with mitigation related to schools.

This impact would be reduced when compared wi th the impact analysis in EIR No. 311.

This impact would not be new or substantially more severe when compared with the impact analysis in SEIR No. 340.

Threshold 5.13a: Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:
(iv) Parks?
No New Impact from EIR No. 311; No New Impact from SEIR No. 340 – Project Impact Less Than Significant. EIR No. 311 determined that The Disneyland Resort Project would result in a less than significant impact related to parks with implementation of project design features.

According to SEIR No. 340, buildout of the ARSP would indirectly increase population. Because this increase would take place over and extended period of time and because the ARSP area is not located within a designated Park Deficiency Area, impacts related to the construction or expansion of recreational uses would be less than significant.

DisneylandForward
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R:\Projects\WDI\3WDI000400\Environmental Documentation\PR_SEIR\5.13_Public_Services-090823.docx 5.13-27 Section 5.13 – Public Services The Project would develop additional entertainment and visitor-serving uses, however, no parks or public recreation uses would be construct ed. According to Section 5.12, Population and Housing, of this Draft Subsequent EIR, the Project would indirectly increase population by approximately 6,079 residents associated with cast members choosing to relocate to the City of Anaheim. No direct increase in demand for City park lands or recreational facilities is expected to result from project implementation because the Pr oject would function primarily as a visitor- serving use. Additionally, while the Project has the potential to indirectly increase the residential base of the City, the number of potential new residents associated with the increase in employment positions is expected to be minor; therefore, the related increase in demand for and use of parks would be minor. Additionally, as part of The Disneyland Resort Project, Disney has funded improvements to the local area, including night lighting of two ballfields and upgrades to two City parks in compliance with MM 3.10.4-2 identified in EIR No. 311. Implementation of PDF PS-4 and PDF PS-5 would require future development to include park-like areas and spaces for non-ticketed visitors to eat to encourage pedestrian circulation and use. With continued implementation of these project design features, a less than significant impact related to parks would occur with mitigation.

The Project would result in a less than significant impact. This impact would not be new or substantially more severe when compared with the impact analyses in EIR No. 311 and SEIR No. 340.

Threshold 5.13a: Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:
(v) Other Public Facilities?
New Impact from EIR No. 311; No New Impact from SEIR No. 340 – Project Impact Less Than Significant With Mitigation. EIR No. 311 did not analyze impacts to other public facilities such as library services. According to SEIR No. 340, buildout of the ARSP would introduce new borrowers to the Anaheim Public Library service area, however, implementation of mitigation would reduce impacts to less than significant.

Anaheim residents and visitors that use library services online, whether from their personal residence or a hotel, affects the availability of online resources because of the limited number of licenses. Databases, eBooks, and other digital resources are generally priced based on the population of the library’s service area. For in-library use visitors are provided with a visitor pass to use the library public computers. With additional users to serve, the Project would reduce the overall availability per capita of books, media, computers, and library public service space.

Therefore, in order to maintain current per capita levels and licensing agreements, the City would need to provide additional physical and virtual resources to the Anaheim library system. The Anaheim Municipal Code Section 17.08.385, Public Library Facilities Services Areas – Payment of Fees Required, specifies that developer fees shall be deposited in a public library services fund. This fund shall be used for the construction, equipping, and supplying of said services, as set forth in the public library services plan (Lujan 2022). Implementation of MM PS-27 requires payment of developer fees, intended to fund staffing, resources, and facilities as needed to serve the demand for library services for all approved entitlements; therefore, no additional fees are required to minimize impacts on library resources and services. With payment of required fees, a less than significant impact would occur.

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R:\Projects\WDI\3WDI000400\Environmental Documentation\PR_SEIR\5.13_Public_Services-090823.docx 5.13-28 Section 5.13 – Public Services The Project would result in a less than significant impact with mitigation. This impact would be new when compared with the impact analysis in EIR No. 311, which did not address impacts to other public facilities such as library services. This impact would not be new or substantially more severe when compared with the impact analysis in SEIR No. 340.

5.13.4 CUMULATIVE IMPACTS
Fire Protection
EIR No. 311 determined that The Disneyland Resort Project would result in a less than significant cumulative impact related to fire protection services with implementation of mitigation. According to SEIR No. 340, buildout of the ARSP and reasonably foreseeable projects within the vicinity of the ARSP and Disneyland Resort, would result in an increased cumulative demand for recreational amenities; however, cumulative impacts of Project development would be less than significant with implementation of mitigation.

The geographic area for the cumulative analysis of fire protection services is defined as the service territory for the AF&R. The City is undergoing continuous development and redevelopment. While the contribution of these projects to area growth is largely reflected in population and housing estimates and has been considered in long-range planning efforts undertaken by agencies, the Project’s modifications as discussed previously in addition to future development within the AF&R service area have the potential to create significant impacts related to need for additional resources to serve the Project and cumulative development. However, the Project would be required to construct and maintain a Substation within the DisneylandForward Project site and enter into a Fire Operations Agreement to address future staffing needs according to MM PS-14 and MM PS-7 , respectively, which would help meet the anticipated increased demand for fire services. Therefore, implementation of these and all other applicable mitigation measures noted would reduce the Project’s contribution to a cumulative impact to less than significant.

The Project’s cumulative impact would be less than significant with mitigation. This impact would not be new or substantially more severe when compared with the impact analyses in EIR No. 311 and SEIR No. 340.

Police Protection
EIR No. 311 determined that The Disneyland Resort Project would result in a less than significant cumulative impact related to police protection services with implementation of mitigation.

According to SEIR No. 340, demand for police protection services associated with buildout of the ARSP would not result in or contribute to any significant cumulative impact to police protection services; however, compliance with the proposed mitigation would further ensure adequate police protection services are provided and would minimize demand on police protection services.

The geographic area for cumulative analysis of police protection services is defined as the service territory for the Police Department. The City is undergoing continuous development and redevelopment. While the contribution of these projects to area growth is largely reflected in population and housing estimates and has been considered in long-range planning efforts undertaken by agencies, the Project’s modifications as discussed previously in addition to future development within the Police Department’s service area have the potential to create significant impacts related to need for additional resources to serve the Project and cumulative development.

However, the Project would be required to construct and maintain a Substation within the Theme Park District and a Satellite Office in the Southeast District/Theme Park East Overlay according to MM PS-24 and MM PS-25, respectively, which would help meet the anticipated increased DisneylandForward
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R:\Projects\WDI\3WDI000400\Environmental Documentation\PR_SEIR\5.13_Public_Services-090823.docx 5.13-29 Section 5.13 – Public Services demand for police protection services. Therefore, implementation of these and all other applicable mitigation measures noted would reduce the Project’s contribution to a cumulative impact to a less than significant level.

Schools
EIR No. 311 determined The Disneyland Resort Project would have a less than significant direct impact on schools, but identified a significant and unavoidable indirect impact related to school enrollment due to over-capacity situations in the Anaheim Union High School District and the Anaheim City School District. According to SEIR No. 340, buildout of the ARSP would result in an increased student population; however, all new growth would occur in compliance with applicable goals and policies of the City’s General Plan and standard requirements such as SB 50.

Therefore, potential impacts related to schools would be less than significant and would not be cumulatively considerable.

Future development under the Project could result in increased student population, which when considered in combination with future cumulative development within the AESD and AUHSD boundaries, has the potential to represent a significant impact related to the adequacy of school facilities and resources, and additional facilities and resources may be required. However, all new growth associated with the Project as well as cumulative projects would occur in compliance with applicable goals and policies of the City’s General Plan and standard requirements such as payment of fees pursuant to SB 50. As previously discussed, Disney entered into an agreement with the AESD, formerly known as the Anaheim City School District, for early payment of the fees for buildout of the Disneyland Resort Project. Additionally, with implementation of MM PS-26 which requires payment of school impact fees, potential project-level impacts to AUHSD related to Project implementation would be reduced to less than significant levels. Therefore, payment of the required fees would also reduce the Project’s contribution to a cumulative impact to a less than significant level.

The Project’s cumulative impact would be less than significant with mitigation. This impact would be reduced when compared with the im pact analysis in EIR No. 311. This impact would not be new or substantially more se vere when compared with the impact analysis in SEIR No. 340.

Parks
EIR No. 311 determined that The Disneyland Resort Project would result in a less than significant cumulative impact related to parks with implementation of project design features. According to SEIR No. 340, buildout of the ARSP and reasonably foreseeable projects within the vicinity of the ARSP and Disneyland Resort would result in an increased cumulative demand for recreational amenities; however, these impacts would be reduc ed to less than significant levels through payment of fees by individual projects or the dedication of land, the payment of a fee in lieu of dedication, or a combination of both for park or recreational purposes. Compliance with standard requirement would reduce the potential cumulative impact to less than significant.

The Project would not result in a direct increase in population. As previously noted, the City of Anaheim currently maintains park dedication standards that require new development to ensure that 2 acres of parkland would be developed for each 1,000 residents added by proposed development. New park dedication standards or in-lieu fees can also be developed for non- DisneylandForward
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R:\Projects\WDI\3WDI000400\Environmental Documentation\PR_SEIR\5.13_Public_Services-090823.docx 5.13-30 Section 5.13 – Public Services residential or mix-use development. The City also enters into joint-use agreements with local school districts in which residents are able to use school facilities such as gymnasiums, play equipment, sports fields, swimming pools and classrooms. The Project is creating a benefit by offsetting the cumulative need for parks created by other projects. As such, the Project’s contribution to cumulative impacts related to parks and recreational facilities is less than considerable and, therefore less than cumulatively significant.

The Project’s cumulative impact would be less than significant. This impact would not be new or substantially more severe when compared with the impact analyses in EIR No. 311 and SEIR No. 340.

Libraries
EIR No. 311 did not analyze potential cumulative impacts to other public facilities such as library services. According to SEIR No. 340, buildout of the ARSP would incrementally contribute to cumulative impacts. However, potential cumulative impacts would be reduced to less than significant with implementation of mitigation.

Implementation of the Project would affect the provision of library services, which when considered in combination with future cumulative development within the City limits, has the potential to represent a significant impact related to library services. All future development projects, including the Project, would be required to assess potential impacts to library services and mitigate such impacts through the payment of fees as detailed in the Anaheim Municipal Code Section 17.08.385, Public Library Facilities Services Areas – Payment of Fees Required.

These fees would fund purchase of additional resources or construction of physical improvements. Therefore, with implementation of MM PS-27 which requires payment of developer fees, potential project-level library impacts related to Project implementation would be reduced to less than significant levels. Therefore, payment of the required fees would also reduce the Project’s contribution to a cumulative impact to a less than significant level.

The Project’s cumulative impact would be less than significant with mitigation. This impact would be new when compared with the impact analysis in EIR No. 311, which did not address other public services, including library services. This impact would not be new or substantially more severe when compared with the impact analysis in SEIR No. 340.

5.13.5 MITIGATION PROGRAM
Mitigation Measures
EIR No. 311 and SEIR No. 340 presented MMs to reduce potential impacts associated with the Disneyland Resort Project and Anaheim Resort Specific Plan Project, respectively. As appropriate, the measure number and section from EIR No. 311 and/or SEIR No. 340 are listed in parentheses. Modifications to the original measure are shown as strikethrough for deleted text and bold for new, inserted text.

Fire
MM PS-1 Prior to issuance of each building permit for development in the ARSP Parking and Theme Park Overlaysthe final building and zoning inspection, the property owner/developer shall provide evidence to the Planning Director/Planning Services Manager of full payment of app licable fire facilities fees as deemed appropriate by the Fire Department pay all applicable fire fees in the amount then in effect and in accordance with the City-adopted Fire Protection DisneylandForward
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R:\Projects\WDI\3WDI000400\Environmental Documentation\PR_SEIR\5.13_Public_Services-090823.docx 5.13-31 Section 5.13 – Public Services Facilities and Paramedic Services Impact Fee Program (initially established through City Council Resolution No. 95R-73). Alternatively, the City and the Property Owner/Developer may enter into alternative financing arrangements. (EIR No. 311, MM 3.10.1-8; SEIR No. 340, MM 5.12-9 and SR 5.12-1) MM PS-2 Prior to commencement of structural framing on each parcel or lot, onsite fire hydrants shall be installed and c harged, as required, by the property owner/developer. (EIR No. 311, MM 3.10.1-2; SEIR No. 340, MM 5.12-5) MM PS-3 Prior to approval of each grading plan, the property owner/developer shall submit an emergency fire access plan to ensure that service to the site is in accordance with the Fire Department service requirements. (EIR No. 311, MM 3.10.1-3; SEIR No. 340, MM 5.12-6)
MM PS-4 Prior to issuance of each building permit, the property owner/developer shall submit a Construction Fire Protection Plan which shall include detailed design plans for accessibility of emergency fire equipment, fire hydrant location, and any other construction features required by the Fire Marshal. The property owner/developer shall be responsible for securing facilities acceptable to the Fire Department and hydrants shall be operational with required fire flow. A construction plan providing a complete timeline and construction goals shall be provided and approved by the Fire Department for all new construction projects. (EIR No. 311, MM 3.10.1-4; SEIR No. 340, MM 5.12-11)
MM PS-5 Prior to issuance of each building permit; to be implemented prior to each final building and zoning inspection, plans shall indicate that all buildings, exclusive of parking structures, shall have sprinklers installed by property owner/developer, to include all open and closed parking structures, exclusive of one-story detached accessory buildings of less than 120 square feet in floor area, and free standing shade structures that ar e open on at least two sides to sufficiently prevent the accumulation of smoke and hot gases. Additionally, alternatives to automatic sprinkler systems (e.g., self-contained water mist systems) that provide an equivalent level of fire protection may be approved for other buildings on a case-by-case basis upon review and approval by the Fire Department. (EIR No. 311, MM 3.10.1-5; SEIR No. 340, MM 5.12-7) MM PS-6 Prior to issuance of each building permit, plans shall be submitted to ensure that development is in accordance with the City of Anaheim Fire Department Standards, including:
a. Overhead clearance shall not be less than 14 feet for the full minimum width of 26 feet for all designated fire access roads.
b. All fire access roads, bBridges and underground structures to be used for Fire Department access shall be designed to support Fire Department vehicles weighing 78,000 75,000 pounds.
c. All underground tunnels shall have sprinklers. Water supplies (hydrants) are required at the entrances. Standpipes shall also be provided when determined to be necessary by the Fire Department.
d. Adequate off-site public fire hydrants contiguous to the Specific Plan area and onsite private fire hydrants shall be provided by the property owner/developer.

The precise number, types, and locations of the hydrants shall be determined DisneylandForward
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R:\Projects\WDI\3WDI000400\Environmental Documentation\PR_SEIR\5.13_Public_Services-090823.docx 5.13-32 Section 5.13 – Public Services during building permit review. Hydrants are to be a maximum of 300 400 feet apart.
e. A minimum residual water pressure of 20 psi shall remain in the water system.

Flow rates for all structures the public parking facilities shall be a minimum of set at 1,000 to 1,500 gallons per minute gpm.
f. Fire access roads shall be provided with vertical and horizontal clearance in compliance with Fire Department standards. Any changes to emergency vehicle access roads shall be included in the overall emergency vehicle access plans for the Resort area, and maintained by property owner/developer. The Fire Code Official shall review all proposed changes and determine whether to approve any deviations from these standards.
g. Temporary structure regardless of type of construction shall be considered temporary if at a location for less than 6 months. Other than pre-fabricated construction trailers, structures that are at a location for more than 6 months shall be provided with a fire suppression system and/or fire notification/life safety systems applicable to the use of the structure.
h. Integrated Safety Systems (ISS) testing as designed by the property owner/developer or an updated equivalent shall be required for all attractions on an annual basis. The property owner/developer shall provide advance notice to the Fire Department to coordinate witnessing of such testing at the Fire Code Official’s discretion. (EIR No. 311, MM

3.10.1-6; SEIR No. 340, MM 5.12-8)
MM PS-7 Prior to issuance of the first building permit in phase II for the DisneylandForward Project or as otherwise specified in the Development Agreement between the City and Disney, the property owner/developer shall enter into a Fire Operations Agreement with the City of Anaheim to pay or cause to be paid its fair share of the funding for one additional fire inspector to address the Operations and Community Risk Reduction staffing needs to maintain adequate levels of service of response and ongoing fire inspection of the Project and in the Anaheim Resort. (EIR No. 311, MM 3.10.1-7)
MM PS-8 Prior to approval of street improvement plans and water improvement plans, the water supply system shall be designed by the property owner/developer to provide sufficient fire flow pressure and storage for the proposed land use and fire protection in accordance with Fire Department requirements. (EIR No. 311, MM 3.10.1-9; SEIR No. 340, MM 5.12-6)
MM PS-9 Prior to the final building and zoning inspection for a hotel/motel, the property owner/developer shall submit an earthquake emergency evacuation response plan for review and approval by the Fire Department. The plan shall require posted notices in all hotel rooms on emergency evacuation earthquake safety procedures and incorporate ongoing emergency evacuationearthquake training for hotel staff to the satisfaction of the Fire Department. (EIR No. 311, MM 3.6-5 and MM 3.6-6; SEIR No. 340, MM 5.5-4)
MM PS-10 Prior to the approval of each Final Site Plan and prior to the issuance of each building permit, plans shall be reviewed and approved by the Fire Department as DisneylandForward
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R:\Projects\WDI\3WDI000400\Environmental Documentation\PR_SEIR\5.13_Public_Services-090823.docx 5.13-33 Section 5.13 – Public Services being in conformance with the CaliforniaUniform Fire Code. (SEIR No. 340, MM

5.12-12)
MM PS-11 Prior to the placement of building materials on a building site, an all-weather fire access road shall be provided from the roadway system to and on the construction site and for fire hydrants at all times, as required by the Fire Department. Such routes shall be paved or, subject to the approval of the Fire Department, shall otherwise provide adequate emergency access. Every building constructed must be accessible to Fire Department apparatus. The width and radius of the driving surface must meet the requirements noted in the Anaheim Municipal Code and in accordance with City of Anaheim Fire Department Standards of Section

The Substation shall meet the below minimum criteria, and is subject to the review and approval of the Fire Chief:

1. Designated parking stalls, for a medic truck, ambulance, medic golf cart, and 2 staff vehicles

2. Equipped with dedicated fiber optic line (services for cable, wifi)

3. Two offices with two workstations each

4. Breakroom/kitchen type area

5. Day room able to accommodate up to 8 personnel (4 paramedics, 2 ambulance, 2 Community Risk Reduction)

6. Restrooms with showers/locker rooms
MM PS-15 Prior to issuance of building permits for any structure greater than 75 feet tall, the property owner/developer shall conduct an analysis to determine if the structure would interfere with the Emergency Radio Response Communication (ERRC) System signal. If warranted based on the analysis, the property owner/developer shall be responsible for installation of new or relocated equipment.

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R:\Projects\WDI\3WDI000400\Environmental Documentation\PR_SEIR\5.13_Public_Services-090823.docx 5.13-34 Section 5.13 – Public Services PDF PS-1 Prior to final building and zoning inspections for the Second Theme Park, Oongoing during project operation, the existing services and capabilities of the Disneyland Fire Department shall be maintained within the for the DisneylandForward Project Site . Existing services include preconstruction checks, pre-investigation of fires and alarms, preplanning for fires and evacuations, fire prevention program activities, and monitoring of pyrotechnics and special effects. (EIR No. 311, PDF 3.10.1-1)
MM HAZ-2 Ongoing during demolition and construction, in the event that hazardous waste, including asbestos, is discovered during site preparation or construction, the property owner/developer shall ensure that the identified hazardous waste and/or hazardous material are handled and disposed of in the manner specified by the State of California Hazardous Substances Control Law (Health and Safety Code, Division 20, Chapter 6.5), according to the requirements of the California Administrative Code, Title 30, Chapter 22, and the Uniform Fire Code, Article 87. • Providing trash compactors for nonrecyclable materials whenever feasible to reduce the total volume of solid waste and the number of trips required for collection.
• Prohibition of curbside pick-up within the Disneyland Resort. (EIR No. 311, MM 3.8-10; SEIR No. 340, MM 5.7-6)
MM HAZ-3 Prior to approval of the first a grading plan or issuance of a the first Phase I dDemolition pPermit, whichever occurs first, the property owner/developer shall submit a Phase I Environmental Site Assessment (ESA) prepared pursuant to current ASTM Standard Practice for Environmental Site Assessments to identify potential threats to human health and the environment plan for review and approval by the Fire Department by the City. If possible hazardous materials are identified during the site assessments, the appropriate response/remedial measures will be implemented in accordance with the requirements of the Orange County Health Care Agency (OCHCA) and/or the Regional Water Quality Control Board (RWQCB), as appropriate. The ESA shall which details procedures that shall be taken if a previously unknown underground storage tank (UST) or other unknown hazardous materials or waste is discovered onsite. The ESA shall outline where hazardous materials may be found, types of hazardous materials anticipated, how to screen for them, and what to do in the event they are identified. The ESA shall identify the party responsible for the screening, and training requirements for those responsible for undertaking the screening effort. The ESA shall specify requirements for reporting, handling, staging, disposal, and recordkeeping.

The ESA shall also identify contingencies in the event that significant contamination is identified that is 1) above regulatory thresholds and 2) cannot be removed/mitigated remediated by proposed construction. (EIR No. 311 MM 3.11-5; SEIR No. 340, MM 5.7-4 and MM 5.7-7)
MM HAZ-4 Prior to Approval of the First Grading Plan or issuance of the first a grading or demolition permit, whichever occurs first, in areas known or thought to have been previously occupied by underground storage tanks (USTs), or other hazardous materials or waste, and in areas where tank removal has not been verified prior to excavation or grading; for Each Phase, the property owner/developer shall retain the services of a qualified environmental professional to conduct an investigation for known, or the presence of, cryptic DisneylandForward
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R:\Projects\WDI\3WDI000400\Environmental Documentation\PR_SEIR\5.13_Public_Services-090823.docx 5.13-35 Section 5.13 – Public Services tanks using geophysical methods that include the potential use of ground penetrating radar (GPR) or similar technologies to determine no abandoned USTs are present shall be conducted in the subject area for the property owner/developer by a qualified environmental professional in the areas of former service stations and those areas known or thought to have been formerly occupied by USTs and where tank removal has not been verified prior to excavation or grading in these areas.

Soil sampling or a soil organic vapor survey may be required if soil sampling results are not available or indicate contamination is present above regulatory guidelines.

If warranted, subsurface investigation and sampling shall be undertaken in these areas, and appropriate remediation measures developed, if necessary, before demolition, excavation, or grading takes place in these areas. (EIR No. 311, MM 3.11-2; SEIR No. 340, MM 5.7-1)
MM HAZ-5 Prior to the removal of underground storage tanks (USTs), the property owner/developer shall obtain a permit from the Hazardous Materials Management section of the Fire Department shall be obtained for removal of such underground tanks by the property owner/developer. During removal of the underground storage tank, a representative from the Hazardous Materials Section (HMS) of the Fire Department Environmental Protection Section shall be onsite to direct soil sampling. (EIR No. 311, MM 3.11-3; SEIR No. 340, MM 5.7-2) MM HAZ-6 Ongoing during remediation, all remediation activities of surface or subsurface contamination not related to underground storage tanks (USTs), conducted on behalf of the property owner/developer of surface or subsurface contamination not related to underground storage tanks shall be overseen by the Santa Ana Regional Water Quality Control Board (SARWQCB) and witnessed by Anaheim Fire Department/Hazardous Material Management Section (HMS).Orange County Health Department. Information on subsurface contamination from an underground storage tank shall be provided to the Santa Ana Regional Water Quality Control Board (SARWQCB) with a copy to Planning & Building. (EIR No. 311, MM 3.11-4; SEIR No. 340, MM 5.7-3) MM NOI-1 Ongoing during project operation s of the second theme park, the property owner/developerapplicant shall obtain pyrotechnic permits (on an annual basis. Additions or modifications to fireworks shoots shall require a separate permit.) a permit for use of fireworks. (EIR No. 311, MM 3.5-2) MM UTIL-3 Prior to issuance of each building permit, all water supply planning for the project will be closely coordinated with, and be subject to the review and final approval of, the Public Utilities Department, Water Engineering Division and Fire Department. (SEIR No. 340, MM 5.15-2)
Police
MM PS-16 Prior to issuance of each applicable building permit, the property owner/developer shall pay all applicable police protection fees in the amount then in effect.

Alternatively, the City and the property owner/developer may enter into alternative financing arrangements.

MM PS-17 Ongoing during operation of the Disneyland Resort Disneyland Resort, the operator of the public parking facilities shall provide an adequate staff of private DisneylandForward
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R:\Projects\WDI\3WDI000400\Environmental Documentation\PR_SEIR\5.13_Public_Services-090823.docx 5.13-36 Section 5.13 – Public Services security officers for patrol and surveillance of the facilities on approval of the Chief of Police or their designee. (EIR No. 311, MM 3.10.2-2) MM PS-18 Prior to the issuance of the first building permit for DisneylandForward Project or as otherwise specified in the Development Agreement between the City of Anaheim and Walt Disney Parks and Resorts U.S., Inc. Phase II of the Disneyland Resort (excluding the relocation of the SCE transmission lines), the property owner/developer shall enter into an Police Operations Aagreement with the City of Anaheim to pay or cause to be paid its fair share of the funding for police personnel and equipment necessary to meet the service need of the Anaheim Resort as determined by the Chief of Police. (EIR No. 311, MM 3.10.2-3) MM PS-19 Prior to issuance of each building permit for parking structures, the Police Department shall review the safety measures incorporated into the building plans for the parking structures within the DisneylandForward Project Site Specific Plan area to be submitted by the property owner/developer. The security measures shall include the following or other substitute security measures as may be approved by the Police Department:
 Immediate access in priority criminal cases, where an urgent need or demand exists and time is of the essence.
 For the West and East Parking Structure, and the Southwest Parking Facility, Closed circuit television surveillance and recording equipment or other adequate security measures reviewed and approved by the Police Department shall be provided.
 For the hotel parking structures, clos ed circuit television surveillance and recording equipment shall be provided.
 For the Disneyland Administration Building and the South Parking Area (south of Katella Avenue and west of Haster Street), Guarded entrance and exit gates shall be provided. (EIR No. 311, MM 3.10.2-5; SEIR No. 340, MM 5.12-2) MM PS-20 Ongoing during operation of the Disneyland Resort Disneyland Resort, the property owner/developerapplicant shall continue to provide anti-gang, human trafficking, child exploitation and substance abuse educational programs which are currently provided for park security cast members . (EIR No. 311, MM 3.10.2- 6)
MM PS-21 Ongoing during operations, the Disneyland Security Department shall be maintainedexpanded to provide equivalent levels of service to the entire Disneyland Resort Disneyland Resort. These services will include initial response, investigation, and report writing. Entry points to the theme parks will be patrolled by the Disneyland Security Department. (EIR No. 311, PDF 3.10.2-1; SEIR No. 340, MM 5.12-3)
MM PS-22 Prior to the approval of each Final Site Plan and issuance of each building permit for a hotel , the property owner/developer shall submit plans to the Police Department for review and approval by the Chief of Police, or their designee, for safety, accessibility, crime prevention, a nd security provisions during both the construction and operative phases for the purpose of incorporating safety measures in the project design including the concept of crime prevention through DisneylandForward
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R:\Projects\WDI\3WDI000400\Environmental Documentation\PR_SEIR\5.13_Public_Services-090823.docx 5.13-37 Section 5.13 – Public Services environmental design (e.g., building design, circulation, site planning, and lighting of parking structures and parking areas). (SEIR No. 340, MM 5.12-1) MM PS-23 Prior to issuance of each building permit for or including a parking lot and/or parking structure , the project design shall include parking lots and parking structures with controlled access points to limit ingress and egress if determined to be necessary by the Police Department and shall be subject to the review and approval of the Police Department. (SEIR No. 340, MM 5.12-4) MM PS-24 Prior to issuance of the first building permit for the DisneylandForward Project or as otherwise specified in the Development Agreement between the City of Anaheim and Walt Disney Parks and Resorts U.S., Inc., the property owner/developer shall coordinate with the Police Department to construct and maintain a Substation in the Theme Park District which meets the following minimum criteria:
 Designated parking stalls, including EV charging stations, for approximately 4-6 EV, 15-20 regular spaces

 Equipped with dedicated fiber optic line
 Minimum of two private offices
 Conference/briefing room
 Interview room
 Kitchen
 Breakroom
 Locker rooms with showers, restrooms, and lockers
 Enclosed bicycle storage for at least 12 bicycles
 Equipment storage (size equivalent to two offices)
The location and facility components are subject to the review and approval of the Chief of Police. A designee of the Chief of Police shall be included in the initial design phase of the Substation, and shall be regularly consulted during design and construction. Any subsequent modification or relocation to either facility is subject to the review and approval of the Chief of Police.

MM PS-25 Prior to issuance of the first building permit for development of over 10,000 sf in the Southeast District or Theme Park East Overlay or as otherwise determined in the Development Agreement between the City of Anaheim and Walt Disney Parks and Resorts U.S., Inc., the property owner/developer shall coordinate with the Police Department to constr uct and maintain a Satellite Office in the Southeast District or the Theme Park East Overlay which meets the following minimum criteria:
 Designated parking stalls, including 2 -4 EV charging stations, 6 - 8 regular spaces

 Equipped with dedicated fiber optic line
 Breakroom
 Conference/briefing room
 Interview room
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R:\Projects\WDI\3WDI000400\Environmental Documentation\PR_SEIR\5.13_Public_Services-090823.docx 5.13-38 Section 5.13 – Public Services  Restrooms
 Enclosed bicycle storage for at least 6 bicycles
The location and facility components are subject to the review and approval of the Chief of Police. A designee of the Chief of Police shall be included in the initial design phase of the Satellite Office, and shall be regularly consulted during design and construction. Any subsequent modification or relocation to either facility is subject to the review and approval of the Chief of Police.

PDF PS-2 Ongoing during project operation, the property owner/developer shall continue to provide and expand its Court Liaison program to meet the needs of the Disneyland Resort. (EIR No. 311, PDF 3.10.2-3)
Schools
MM PS-26 Prior to issuance of each building permit, the property owner/developer shall provide proof that school impact fees have been paid consistent with State statute. (EIR No. 311, MM 3.10.5-2; SEIR No. 340, MM 5.12-17)
PDF PS-3 Ongoing during project operations, the existing Disneyland Resorttheme park has developed and/or engaged in a series of educational programs in cooperation with the local community and regional agencies and organizations, designed to enhance and complement the educational opportunities and experiences for the youth.

The 10 educational programs that currently exist are indicated below (see Section 3.10.5, Schools, for detailed information regarding these programs):

1. The Disneyland Creativity Challenge Awards Program Anaheim Union High School District’s Anaheim’s Innovative Mentoring Experience (AIME) program

2. Orange County Young Listeners Concerts Big Brothers & Big Sisters of Orange County’s Workplace Mentoring Program at Anaheim Union High School District

3. Junior Achievement (JA) United Way’s Youth Career Connections and Speakers Bureaus at the Anaheim Union High School District

4. Work Exposure Day at Disneyland Anaheim Family YMCA Avanza Program

5. Disney Magic Music Days Orange County Asian Pacific Islander Community Alliance’s ROOTED Career Development Program at Anaheim Union High School District

6. Job Search Strategy Class Hola Readers at Anaheim Elementary School District

7. “Free From Drugs” Program Anaheim Elementary School District’s Broadway Bound: Empowering Young Performers in Anaheim

8. Job Training Opportunities Boys & Girls Clubs of Greater Anaheim-Cypress gEARed Up for the Future

9. School Support Programs Girls Inc.’s Girls Meet the Workforce/Project Accelerate

10. CIF Champion Celebration Girl Scouts of Orange County’s Career Exploration Program – Dreams to Reality
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R:\Projects\WDI\3WDI000400\Environmental Documentation\PR_SEIR\5.13_Public_Services-090823.docx 5.13-39 Section 5.13 – Public Services The property owner/developer applicant will continue these programs and/or substitute similar programs of equal importance. (EIR No. 311, PDF 3.10.5-1) Parks
PDF PS-4 Ongoing during operations Prior to final building and zoning inspections for the Second Theme Park, substantial area within the Disneyland Resort shall be has been designed to encourage utilization by pedestrians in a park-like setting linking key areas of the project as described in the Disneyland Resort Specific Plan .

The pedestrian amenities will include landscaped pedestrian walkways linking West Street/Disneyland Drive to Harbor Boulevard; and a new entry plaza for Disneyland and the Second Theme Park where the guest transportation system will drop off guests from the parking facilities and hotels. (EIR No. 311, PDF 3.10.4-1)
PDF PS-5 Ongoing during operations, the property owner/developer applicant will shall provide space(s) an eating area, outside the paid ticketed theme park gates, easily accessible to theme park guests and non-ticketed visitors, within the Theme Park District for where those who bring have brought their own food can eat. Design features will include a 50-table layout with comparable spacing to other theme park eating areas, The proximity of amenities such as drinking fountains, security, landscaping, lighting, vending machines, and nearby restrooms/locker facilities will be considered in the siting and design or such space(s) provided. (EIR No. 311, PDF 3.10.4-2)
Libraries
MM PS-27 Prior to the issuance of a building permit for development in the ARSP Parking and Theme Park Overlays, with the exception of theme park square footage transferred from the DRSP, the property owner/developer shall comply with the Anaheim Municipal Code , Section 17.08.385, Public Library Facilities Services Areas – Payment of Fees Required. (SEIR No. 340, MM 5.12-19) The following mitigation measures are either are not applicable to the Project or completed:
 EIR No. 311 MM 3.10.1-10 and SEIR No. 340 MM 5.12-10 are no longer applicable as they do not reflect current Fire Department practices regarding posting of emergency phone numbers. Any applicable posting would be in accordance with Fire Department standards.
 EIR No. 311 MM 3.10.2-4 has been replaced by MM PS-23;  EIR No. 311 MM 3.10.4-2 was satisfied with the 1996 approval of the Infrastructure and Parking Finance Agreement and the issuance of the bonds authorized by the Agreement.  EIR No. 311 MM 3.11-10 was completed at the time of construction of Disneyland Drive and Magic Way and adjacent parking lots in the Hotel District and the Parking District, West Parking Area;
 EIR No. 311 MM 3.11-6 is not applicable to this Project. This mitigation measure is specifically applicable to the Anaheim Gardenwalk Overlay, which does not include any Disney Properties;
 EIR No. 311 MM 3.11-7 is not applicable to this Project. Portions of this mitigation measure mentioning 321 West Katella Avenue relate to the Anaheim GardenWalk Overlay, which DisneylandForward
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R:\Projects\WDI\3WDI000400\Environmental Documentation\PR_SEIR\5.13_Public_Services-090823.docx 5.13-40 Section 5.13 – Public Services does not include any Disney Properties. For the other properties, the requirements in this mitigation measure were implemented when these sites were developed between approximately 2000 and 2010;
 EIR No. 311 PDF 3.11-1 is not applicable as it has been replaced by SR HAZ-1 through SR HAZ-4;
 SEIR No. 340 MM 5.12-18 is not applicable as it is an obligation of the City.

5.13.6 IMPACT SUMMARY
Threshold 5.13a: Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:
(i) Fire Protection?
Impact Summary: The Project would result in a less than significant impact with mitigation related to fire protection services. This impact would not be new or substantially more severe when compared with the impact analyses in EIR No. 311 and SEIR No. 340.

Threshold 5.13a: Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:
(ii) Police Protection?
Impact Summary: The Project would result in a less than significant impact with mitigation related to police protection services. This impact would not be new or substantially more severe when compared with the impact analyses in EIR No. 311 and SEIR No. 340.

Threshold 5.13a: Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:
(iii) Schools?
Impact Summary: The Project would result in a less than significant impact with mitigation related to schools. This impact would be reduced when compared with the impact analysis in EIR No. 311. This impact would not be new or substantially more severe when compared with the impact analysis in SEIR No. 340.

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R:\Projects\WDI\3WDI000400\Environmental Documentation\PR_SEIR\5.13_Public_Services-090823.docx 5.13-41 Section 5.13 – Public Services Threshold 5.13a: Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:
(iv) Parks?
Impact Summary: The Project would result in a less than significant impact. This impact would not be new or substantially more severe when compared with the impact analyses in EIR No. 311 and SEIR No. 340.

Threshold 5.13a: Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:
(v) Other Public Facilities?
Impact Summary: The Project would result in a less than significant impact with mitigation. This impact would be new when compared with the impact analysis in EIR No. 311, which did not address impacts to other public facilities such as library services. This impact would not be new or substantially more severe when compared with the impact analysis in SEIR No. 340.

Cumulative Impact
Fire Protection
Impact Summary: The Project’s cumulative impact would be less than significant with mitigation. This impact would not be new or substantially more severe when compared with the impact analyses in EIR No. 311 and SEIR No. 340.

Police Protection
Impact Summary: The Project’s cumulative impact would be less than significant with mitigation. This impact would not be new or substantially more severe when compared with the impact analyses in EIR No. 311 and SEIR No. 340.

Schools
Impact Summary: The Project’s cumulative impact would be less than significant with mitigation. This impact would be reduced when compared with the impact analysis in EIR No. 311. This impact would not be new or substantially more severe when compared with the impact analysis in SEIR No. 340.

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Impact Summary: The Project’s cumulative impact would be less than significant. This impact would not be new or substantially more severe when compared with the impact analyses in EIR No. 311 and SEIR No. 340.

Libraries
Impact Summary: The Project’s cumulative impact would be less than significant with mitigation. This impact would be new when compared with the impact analysis in EIR No. 311, which did not address other public services, including library services. This impact would not be new or substantially more se vere when compared with the impact analysis in SEIR No. 340.

5.13.7 REFERENCES
Anaheim, City of. 2022 (July 21, access date). Anaheim Police Department: Locations. Anaheim, CA: https://anaheim.net/363/Locations.
———. 2004a (May). City of Anaheim General Plan. Anaheim, CA: the City. https://www.anaheim.net/generalplan/.
———. 2004b (May). Final Anaheim General Plan and Zoning Code Update Environmental Impact Report No. 330 (SCH #2003041105, prepared by The Planning Center). Anaheim, CA: the City. https://www.anaheim.net/913/Environmental-Impact-Reports.

Anaheim Elementary School District (AESD). 2021 (September 29, las modified). District Overview. Anaheim, CA: District Overview – Anaheim Elementary School District.

Anaheim, CA: AESD.https:// anaheimelementary.org/district-overview/ Anaheim Fire and Rescue (AF&R). 2023. Communication from D. Rodriquez (AF&R). ———. 2015. Anaheim Fire and Rescue Strategic Plan 2015–2020. Anaheim, CA: AF&R. https://www.anaheim.net/DocumentCenter/View/9501/Strategic-Plan-2015-2020?bidId=. ———. 2014. Accreditation Report, Anaheim Fire and Rescue, 201 South Anaheim Boulevard, Anaheim, California, United States. Anaheim, CA: AFR.
https://www.anaheim.net/DocumentCenter/View/3863/Accreditation-Report?bidId=. ———. 2013. Anaheim Fire and Rescue Standards of Cover 2013–2018. Anaheim, CA: AFR. https://www.anaheim.net/DocumentCenter/View/3864/Standards-of-Cover-?bidId=.

Anaheim Union High School District (AUHSD). 2022 (June 21, last accessed). About Anaheim Union High School District. Anaheim, CA: AUHSD.
https://www.auhsd.us/District/Department/14207-ANAHEIM-UHSD/80408-About- Anaheim-Union-High-School-District.html.

California Department of Parks and Recreation. 2021 (December 7, last accessed). Chino Hills State Park. Sacramento, CA: California State Parks.
https://www.parks.ca.gov/?page_id=648.

Carter, J. 2022 (May 26). Email from J. Carter (Anaheim Police Department) to M. Larum entitled RE: Dispatch Protocol Verification (Psomas).

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R:\Projects\WDI\3WDI000400\Environmental Documentation\PR_SEIR\5.13_Public_Services-090823.docx 5.13-43 Section 5.13 – Public Services Griswold, J. 2022 (April 25). Email from J. Griswold (Anaheim Police Department) to M. Larum entitled RE: Request for Information for the DisneylandForward Project - Police (Psomas).

Lujan, A. 2022 (February 22). Personal communica tion. Email from A. Lujan (Anaheim Public Library) to M. Larum (Psomas) entitled Request for Information for the DisneylandForward Project.

Young, L. 2022 (February 11). Personal communication. Email from L. Young (Anaheim Fire Department) to M. Larum (Psomas) entitled Request for Information for the DisneylandForward Project.

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5.14-1 Section 5.14 – Transportation/Traffic

5.14 TRANSPORTATION
This section discusses the existing transportation setting of the Project Site and surrounding area and assesses the Project’s potential impacts related to transportation. This section is based on the CEQA Transportation Analysis for the Dis neylandForward Project, (CEQA Transportation Analysis) prepared by Gibson Transportation Consulting, Inc (August 2023a), which is included as Appendix J-1. While not required by CEQA, the Operational Traffic Analysis for the DisneylandForward Project was prepared by Gibson Transportation Consulting, Inc (August 2023b), which is included as Appendix J-2, using level of service (LOS) in accordance with City of Anaheim Traffic Study Guidelines.

5.14.1 SUMMARY OF PREVIOUS ENVIRONMENTAL DOCUMENTATION
As detailed in this section, EIR No. 311 and SEIR No. 340 focused their transportation impact analysis on an examination of whether a project is likely to cause automobile delay at intersections and congestion on nearby individual highway segments, traditionally known as LOS analysis, as this was the type of analysis required by CEQA at the time. Senate Bill (SB) 743, signed into law in 2013, initiated an update to the CEQA Guidelines which modified how lead agencies evaluate transportation impacts under CEQA. Beginning July 1, 2020, lead agencies are required to review projects under a metric known as vehicle mile s traveled (VMT) instead of LOS. VMT measures how much actual vehicle travel (additional miles driven) a project would create on California roads.

To the extent possible, comparisons have been made to analyses in EIR No. 311 and SEIR No. 340. This analysis also discloses where the methodology and underlying basis for analysis have changed.

The Disneyland Resort EIR No. 311
The evaluation of traffic impacts associated with development of The Disneyland Resort in EIR No. 311 analyzed City intersections in years 2000 and 2010 (City of Anaheim 1996). With substantial infrastructure improvements, through the implementation of project design features (PDFs) and mitigation measures (MMs), summariz ed below, City streets and intersections were projected to operate at acceptable LOS – LOS D or better during the afternoon peak hour. EIR No. 311 also projected traffic volumes on various freeway segments under the Orange County Transportation Authority’s (OCTA’s) congestion management program guidelines that were in effect at the time. EIR No. 311 found The Disneyland Resort Project would generate hundreds of peak hour trips on the freeway system, including the mainline freeway lanes and the high occupancy vehicle lanes. It identified afternoon peak hour deficiencies by year 2000 on Interstate (I)-5 between State Route (SR) 91 and Harbor Boulevard, between Harbor Boulevard and Katella Avenue, and between Katella Avenue and SR-22, although the I-5 widening project, which has since been completed, was expected to fully mitigate these deficiencies. EIR No. 311 also projected substantial impacts on Disney Way (formerly Freedman Way) between Manchester Avenue/Clementine Street and I-5 during the morning and late-night peak hours, although those hours were not quantitatively analyzed in EIR No. 311. The Final EIR concluded that the significant transportation and circulation impacts of the project could be mitigated by implementation of the PDFs and MMs identified in the Final EIR. Nevertheless, the Final EIR noted that significant and unavoidable impacts could occur to the extent that future background traffic growth was not accommodated by project-specific improvements, or if the Katella Avenue Smart Street improvements were not implemented, or if sufficient right-of-way could not be acquired to accommodate the roadway and intersection improvements identified in the Final EIR.

The City adopted a Statement of Overriding Considerations with regard to these significant and unavoidable impacts. The trips that would be generated by The Disneyland Resort Project were analyzed in EIR No. 311, which required implementation of MMs. According to EIR No. 311, two changes were proposed in the Disneyland Resort Specific Plan (DRSP) to allow for the DisneylandForward
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5.14-2 Section 5.14 – Transportation/Traffic
realignment/modification of Cerritos Avenue and West Street/Disneyland Drive. These changes required an amendment to the Master Plan of Arterial Highways (MPAH), which was analyzed in EIR No. 311, the impacts of which were determined to be less than significant.

EIR No. 311 Mitigation Measures
EIR No. 311 and Modified MMP No. 0067
1 required implementation of the following mitigation
measures and project design features regarding transportation to reduce potential impacts associated with full buildout of The Disneyland Resort Project. However, as discussed previously, transportation impacts would remain potentially significant and unavoidable even with implementation of mitigation.

MM 3.3-1 The applicant shall implement all project design features or their environmental equivalent. The City of Anaheim Planning Department will ensure compliance through the mitigation monitoring process.

MM 3.3-2 Prior to issuance of each building permit, appropriate traffic signal assessment fees shall be paid by the property owner/developer to the City of Anaheim in amounts determined by the City Council Resolution in effect at the time of issuance of the building permit or credit given for City-authorized improvements.

MM 3.3-3A Prior to approval of the first final subdivision map or issuance of the first building permit (other than for Phase I), whichever occurs first; or pursuant to a mutually agreed-upon schedule for dedication and public improvements, the property owner/developer shall irrevocably offer for dedication (with subordination of easements), including necessary construction easements, the ultimate rights-of- way (as indicated in the General Plan Circulation Element, as amended per GPA No. 331) for the following arterial highway/intersection half-sections (where the property owner/developer owns only one side of the ultimate right-of-way) or full sections (where the property owner/developer owns both sides of the ultimate right-of-way) on or adjacent to parcels under its ownership to the City of Anaheim:

a. Katella Avenue (to ultimate 8-lane facility)
b. Walnut Street
c. West Street/Disneyland Drive
d. Ball Road
e. Harbor Boulevard
f. Freedman Way
g. Clementine Street
h. Manchester Avenue
i. Cerritos Avenue
j. Haster Street
MM 3.3-3B Within 120 days of acquiring properties adjacent to arterial highways/street intersection half sections included in (3.3-3A), if, after the initial dedications, any additional parcels are acquired by the applicant adjacent to the arterial highway/street intersection half-sections included in (MM 3.3-3A), the applicant

1 Addendum No. 1 to EIR No. 311, which t he City approved in 1996, modified MMP No. 0067.

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5.14-3 Section 5.14 – Transportation/Traffic
shall notify the City in writing of said acquisition and the ultimate rights-of-way for said properties shall be irrevocably offered for dedication to the City of Anaheim.

MM 3.3-4 Prior to the issuance of building permit for the Disneyland administration building; to be implemented prior to final building and zoning inspections for the Disneyland administration building, the applicant shall provide a cast guard entrance 400’ south of Ball Road at the entrance to the Disneyland Administration Building with three inbound and a minimum of two outbound lanes to minimize queuing onto Ball Road.
(Note: Environmental Equivalent measure approved 8/30/94 which included the provision of a gate guard entrance located 400’ south of the intersection of Ball Road/Disneyland Administration Building driveway).

MM 3.3-5 Prior to approval of the First Grading Plan for each phase of the Disneyland Resort, a phasing plan shall be submitted for review and approval to the appropriate City Engineer in Anaheim and/or Garden Grove (for improvements within Garden Grove) demonstrating how the improvements shown in Table 3.3-16, as approved by the City Engineer, will be constructed.

MM 3.3-6 In accordance with the timing set forth in the phasing plan, Excluding the Disney Administration Building, relocation of the SCE transmission lines and demolition, but including the South Parking Area, the applicant shall mitigate (through constructing or paying the actual total costs for consultant/contractor services for preliminary and final engineering, soils analysis, right-of-way acquisition, demolition, relocation, construction and inspection, and other related expenses) the traffic impacts of the Disneyland Resort by implementing the improvements identified in Table 3.3-16, as approved by the City Engineer, in accordance with the phasing plan approved by the City Engineer.

If the City of Anaheim adopts a traffic impact fee, as discussed in Section 3.3.1.3 of the EIR, funds collected under this program with nexus to these improvements may be used to reimburse the applicant for the portion of the baseline improvements (as identified in Table 3.3-16) which exceed the project share of the improvements. Improvements otherwise funded by public sources prior to approval of the Final Site Plan for each phase will be deleted from project participation.

MM 3.3-8 In accordance with the Approved Phasing Plan, the following improvements are required:

 Add eastbound and westbound dual left-turn lanes and an eastbound right- turn lane to the Clementine Street/Katella Avenue intersection, with a storage length of 200 feet accommodating six lanes on Katella Avenue with a 24-foot wide median tapering to 4 feet median nose through the left turn pockets.

 Add a southbound right-turn pocket to the right-turn-in- only entrance to the South Parking Area on Haster Street, with a storage length of 150 feet; and, provide west half-width of ultimate six lane arterial south of Katella Avenue to the southern property line of the South Parking Area.

MM 3.3-9 In accordance with the Approved Phasing Plan for the Disneyland Administration Building, the following improvements shall be required:
 Add a westbound right-turn lane at Anaheim Boulevard/Ball Road.

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 Restripe existing left-turn lane westbound to provide a minimum of 150 feet of dual lane storage or a minimum of 250 feet of single-lane storage at Ball Road/Disneyland Administration Building driveway.
 Provide an eastbound right-turn pocket with 250 feet of storage at Ball Road/Disneyland Administration building driveway.
(Note: Environmental equivalent measure approved on August 30, 1994 (Administration Building MMP No. 0067) which required that the eastbound right- turn pocket at Ball Road/Disneyland Administration Building driveway shall maintain existing storage and be designed as a free right-turn. Applicant to irrevocably offer for dedication the right-of-way adjacent to right-turn pocket for full buildout of Ball Road).
 Redesign the Disneyland Administration Building entrance driveway to provide three inbound and a minimum of two outbound lanes, with its own entrance gate located a minimum of 400 feet south of the intersection at Ball Road/Disneyland Administration Building driveway.
(Note: Environmental equivalent measure approved on August 30, 1994 (Administration Building MMP No. 0067) for this item which required the provision of the gate guard entrance to be located 400 feet south of the intersection of Ball Road/Disneyland Administration Building driveway).

PDF 3.3-1 Prior to demolition of the existing Disneyland parking lot, replacement parking for the existing Disneyland Theme Park parking spaces removed will be constructed; prior to final building and zoning inspections for the second theme park, the west parking area will be constructed,
Access Improvements and Public Parking Facilities Included in Project Design (Exhibits 3.2-2 and 3.2-3)
Public Parking Facilities . New public parking facilities will be constructed at opposite sides of The Disneyland Resort Specific Plan area to receive traffic from the I-5. At Phase II, Code required parking will be provided. At buildout of Phase III, a minimum of 24,500 guest and cast parking spaces will be provided. The West Parking Area will be oriented to receive southbound I-5 traffic, and the parking facilities in the southern areas of the Theme Park and Hotel Districts and/or East Parking Area will be oriented to receive northbound I-5 traffic.

PDF 3.3-2 To be shown on street improvement plans ; to be implemented prior to final building and zoning inspections for each the east and west parking structures/facilities
Improved Access. Access roads leading up to the parking facilities shall be sized to accommodate traffic at peak hours, thereby substantially reducing the likelihood of backups onto City streets and freeway ramps.

Guest vehicles will enter and exit the West Parking Area via the proposed extension of West Street/Disneyland Drive. Cast access will enter and exit either at West Street/Disneyland Drive or via a single access on Cerritos Avenue with right-turn in and left-turn out only. No cast or guest access or egress will occur from Walnut Street.

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PDF 3.3-3 Prior to issuance of each building permit; to be implemented prior to final building and zoning inspections for both the east and west parking structures, Speed Parking. Building plans shall show direct ramps to each level of the East and West Parking Area facilities to minimize internal circulation within the garages and accommodate the project's "speed parking" operation.

PDF 3.3-4 To be shown on street improvement plans; to be implemented prior to final building and zoning inspection for each parking structure and/or facility, Conveyance Systems . In addition to an extensive network of landscaped pedestrian thoroughfares, conveyance systems will transport Disneyland Resort guests around the project. Guest transportation systems will move guests from the parking facilities to the Theme Park District. The monorail/guest transportation systems shall move guests from the Hotel District to the Theme Park District. Future connections may also be provided to the Future Expansion District.

PDF 3.3-5 To be shown on street improvement plans; to be implemented prior to final building and zoning inspections for the second theme park for Phase II; and if pursued, to be implemented prior to final building and zoning inspections for the east public parking structure or other accessible location in Phase III, Theme Park Drop-Off Area . To provide access to the attractions in the Specific Plan area to people staying outside of The Disneyland Resort area, a bus and shuttle drop-off area will be located adjacent to Harbor Boulevard north of Freedman Way in Phase II as shown on Exhibit 4.4.2a of the Specific Plan; or, in Phase III, the facility may be located adjacent or internal to the East Public Parking Structure, or other accessible location in the Theme Park or Hotel Districts. The types of vehicles served at this facility may include public and private passenger shuttles and buses.

PDF 3.3-6 To be shown on street improvement plans; to be implemented prior to the final building and zoning inspections for the second theme park Roadway Improvements Included in Project Design
I-5 - West Street/Disneyland Drive Southbound Mixed Flow Offramp A mixed-flow offramp currently proposed as part of the 1-5 widening project is planned from southbound I-5 to West Street/Disneyland Drive to replace the existing Ball Road offramp.
(Note: Environmental equivalent approved on 4/12/99 to change the timing of this measure as Disney’s California Adventure theme park would not be open to the public generating vehicular traffic until the I-5 West Street/Disneyland Drive southbound mixed flow offramp opened. This would be monitored and verified by the City prior to Final Building and Zoning Inspection for the Second Theme Park.) PDF 3.3-7 To be shown on street improvement plans; to be implemented prior to final building and zoning inspections for the second theme park, West Street/Disneyland Drive/Ball Road Overcrossing (Exhibits 3.2-3 and 3.2-4) DisneylandForward
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To reduce congestion for vehicles entering the West Parking Area from I-5, an overcrossing is planned at West Street/Disneyland Drive and Ball Road. The intersection of West Street and Ball Road shall be constructed with a two- lane flyover over Ball Road as a project design feature. The overcrossing would take southbound I-5 traffic exiting at West Street/Disneyland Drive over Ball Road, and then allow convenient access to the entrance of the parking facility.

The design of the Ball Road and West Street/Disneyland Drive intersection, shall provide a north leg (southbound Disneyland Drive) of two through lanes, one shared left-turn/through lane, and one left-turn lane; a south leg (northbound Disneyland Drive) of one right-turn lane, one shared right- turn/through lane, one shared left-turn/through lane, and one left-turn lane; an east leg (westbound Ball Road) of three through lanes and two left turn lanes; and, a west leg (eastbound Ball Road) of one right turn lane, three through lanes and two left turn lanes.

This overcrossing may be one-way inbound in the morning, two-way during the afternoon, then one-way outbound during the outbound peak. Access and egress points will be provided both north and south of Ball Road. Both the HOV ramp and the mixed-use off ramp at 1-5 and West Street/Disneyland Drive would have access to the overcrossing. A full intersection at West Street/Disneyland Drive will still be provided at grade. When the overcrossing is one-way, counter-flow movements can be made along West Street/Disneyland Drive.
(Note: Environmental equivalent approved on 7/27/20 to reflect the Ball Road/Disneyland Drive intersection lane configuration that was implemented by 2001 (and still in place on 7/27/20 and to change the Monitoring Responsibility to the Public Works Department, City Engineer.).

PDF 3.3-8 To be shown on street improvement plans; to be implemented prior to final building and zoning inspection for the second theme park,
West Street/Disneyland Drive Intersections and Turn Pockets To facilitate traffic flow along West Street/Disneyland Drive between Katella Avenue and Ball Road, signalized intersections will be provided at major hotel entrances.

Appropriate turn pockets including double left-turn lanes and right-turn only lanes will also be provided as needed to maintain acceptable service levels. West Street/Disneyland Drive itself will have two travel lanes in each direction.

PDF 3.3-9 To be shown on street improvement plans; to be implemented in accordance with the approved phasing plan,
Freedman Way Widening
The addition of the northbound HOV offramp at Freedman Way and the realignment of the southbound onramp will require the widening of Freedman Way between Harbor Boulevard and Clementine Street; Clementine Street to I-5. Three through lanes, where possible, and necessary turn lanes in each direction will be provided.

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PDF 3.3-10 To be shown on street improvement plans; to be implemented prior to final building and zoning inspection for the Second Theme Park,
Speed/Capacity Restrictions on Walnut Street
Between Cerritos Avenue and Ball Road, Walnut Street will be improved adjacent to the strawberry field in accordance with the City of Anaheim General Plan Circulation Element. To discourage any increase in traffic on Walnut Street, the capacity of the road will be restrained, from Katella Avenue to Ball Road. Possible methods include narrowing the street entrances at Katella Avenue and Ball Road and replacing the existing signal with a stop sign at the existing intersection of Walnut Street and Cerritos Avenue. This and other options will be evaluated, and a plan to maintain the current character of Walnut Street will be developed.

PDF 3.3-11 To be shown on street improvement plans; to be implemented prior to final building and zoning inspection for the Second Theme Park,
Cerritos Avenue Realignment
With the development of the Hotel District, Cerritos Avenue between Walnut Street and West Street/Disneyland Drive will be moved up to approximately 1,100 feet to the north and will be renamed. The new roadway will be two lanes wide and will be designed to discourage access from or onto Walnut Street. Southbound left turns will not be allowed at the Walnut Street/Cerritos Avenue intersection.

Westbound Cerritos Avenue left turns at Walnut Street will not be allowed.

PDF 3.3-12 To be shown on street improvement plans; to be implemented by Caltrans in conjunction with the I-5 Widening Project. (The I-5 High Occupancy Vehicle (HOV) Offramps are part of Caltrans' I-5 Widening Project and will be completed independent of The Disneyland Resort Project. The HOV ramps were not assumed in the analysis of traffic impacts of the Disneyland Resort and are not required as a condition of the opening or operation of the Disneyland Resort.) I-5-West Street/Disneyland Drive Southbound HOV Offramp Caltrans' I-5 Widening Project includes a new HOV offramp from southbound I-5 to West Street/Disneyland Drive. This ramp would be built at the same time as the I-5 Widening Project. The ramp will bring high occupancy vehicles (HOVs) conveniently from the HOV lane in the median of I-5 to the West Parking Area.

PDF 3.3-13 To be shown on street improvement plans; to be implemented by Caltrans in conjunction with the I-5 Widening Project. (The I-5 High Occupancy Vehicle (HOV) Offramps are part of Caltrans' I-5 Widening Project and will be completed independent of The Disneyland Resort Project. The HOV ramps were not assumed in the analysis of traffic impacts of the Disneyland Resort and are not required as a condition of the opening or operation of the Disneyland Resort.) I-5/Freedman Way Northbound HOV Offramp
Caltrans' I-5 Widening Project includes a proposed HOV offramp connecting the northbound HOV lanes on I-5 to Freedman Way and an undercrossing of Anaheim Boulevard to Freedman Way. This ramp will carry a substantial DisneylandForward
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5.14-8 Section 5.14 – Transportation/Traffic
number of vehicles to the East Parking Area and remove them from Harbor Boulevard and Katella Avenue.

This ramp (shown in Exhibit 3.2-2 of Volume I of the EIR) will allow northbound I-5 traffic to access the parking facility conveniently from the freeway and also provide access for other vehicles to Harbor Boulevard. It will improve the level of service of the section of Katella Avenue crossing I-5, as well as the intersections of Katella Avenue with Anaheim Boulevard, Haster Street, Clementine Street, and Harbor Boulevard. The ramp is discussed in detail in Appendix C-1, Volume III.

PDF 3.3-14 To be shown on street improvement pl ans; to be implemented prior to final building and zoning inspection for the Second Theme Park, Intersection Improvements Included in Project Design

The following intersection improvements, which are assumed in the analysis of project traffic, will be implemented unless otherwise indicated by the year 2001 (0pening of Second Theme Park) as part of the project design that will enhance the overall performance of the surrounding circulation system :
 Redesign and reconstruct the intersection of Ball Road/West Street/Disneyland Drive to include an overcrossing.
 Redesign the Harbor Boulevard/Freedman Way intersection by accommodating three lanes eastbound and three lanes westbound through the intersection and adding double left turn lane southbound. In Phase III, the entrance to the surface parking lot may be removed.
 At the intersection of Anaheim Boulevard and Freedman Way, add a third through lane eastbound and westbound and a second left-turn lane eastbound, or equivalent improvements as defined by Caltrans during the final geometric design of the I-5 interchange.
 At the intersection of Clementine Street and Freedman Way, add the following improvements or equivalent improvements as defined by Caltrans during the final geometric design of the I-5 interchange
:
- third through lanes eastbound and westbound
- left-turn lanes eastbound and westbound
- second through lanes northbound and southbound
- left-turn lane southbound
- remove right-tum lane northbound
 Reconfigure the Walnut Street/Cerritos Avenue intersection.  Reconfigure the West Street/Disneyland Drive/Cerritos Avenue intersection to satisfaction of the City Engineer.

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PDF 3.3-15 Prior to final building and zoning inspection for the Second Theme Park; and, on-going during project operation,
Transportation Demand Management Program
The need to minimize cast vehicle trips to reduce congestion and improve air quality, consistent with the goals of both the Air Quality Management Plan (AQMP) of the South Coast Air Quality Management District (SCAQMD) and with the Regional Mobility Plan of the Southern California Association of Governments (SCAG), is recognized. The Disneyland Resort will implement and administer a comprehensive Transportation Demand Management (TDM) program for all cast, which will strive to achieve an average vehicle ridership (AVR) goal of 1.5 persons per vehicle and, an average length of out-of-area guest stay of 1.72 days, by 2001.

At this point in project development, it is not possible to predict precisely which programs and activities would be most successful for the Disneyland Resort in meeting these goals. In addition, applicant will review annually with the City any changes to the TDM Program and the Program's effectiveness toward achieving a 1.5 AVR. In consultation with the SCAQMD, the City of Anaheim and other agencies, and after analyzing the effectiveness of these items, The Walt Disney Company will select specific programs for implementation.

Objectives of the TDM program are:

 Increase ridesharing and use of alternative transportation modes by guests.  Meet the cast 1.5 AVR target.
 Provide a menu of commute alternatives for the Disneyland Resort cast, to reduce project-generated trips.
 Provide transportation "linkages" to existing and future transportation modes (other than single-occupant vehicle travel) for both the Disneyland Resort cast and guests
.

Implementation strategies and elements of the TDM program for cast and guest trips are described below
.

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 Vanpooling. A computer listing of all cast members may be developed for the purpose of matching numbers of cast who live in geographic proximity to one another and could comprise a vanpool to the Disneyland Resort.  Transit Pass. Southern California Rapid Transit District and Orange County Transportation Authority (including commuter rail) passes may be promoted through financial assistance and onsite sales to encourage cast to use the various transit and bus services to the Disneyland Resort from throughout the region.

 Commuter Bus. As commuter "express" bus service expands throughout the region, passes for use on these lines may be provided for cast members who choose to use this service. Financial incentives will be provided.

 Shuttle Service. A computer listing of all cast members living in proximity to the Disneyland Resort may be generated, and a local shuttle program will be offered to encourage cast members to travel to work by means other than the automobile.

 Bicycling. A Disneyland Resort Bicycling Program may be developed to offer a bicycling alternative to cast members. Secure bicycle racks, lockers, and showers will be provided as part of th is program. Maps of bicycle routes throughout the area would be provided to inform potential bicyclists of these options.
 Rental Car Fleet. A "fleet vehicle" program may be developed to provide cast members who travel to work by means other than an automobile with access to automobiles in case of emergency, medical appointments, etc. This service would help cast members use alternative modes of transportation by ensuring that they would be able to have personal transportation in the event of special circumstances.
 Guaranteed Ride Home Program. The program may provide cast members who rideshare, or use transit or other means of commuting to work, with a prearranged ride home in a taxi, rental car, shuttle, or other vehicle, in the event of emergencies during the work shift. In essence, this program addresses the concerns of the cast member who rideshares and might be stranded without a vehicle in the event of an emergency.  Housing Coordinator and Referral Program and Local Hiring Efforts.

- Compressed Work Week. The Disneyland Resort may review the possibility of developing a "compressed work week" program, which provides for fewer work days but longer daily shifts, as an option for cast DisneylandForward
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members. This program would help eliminate certain trips on certain days that would otherwise be generated daily by the Disneyland Resort Cast. - Telecommuting. The Disneyland Resort employs a variety of cast in different positions, cast members include clerical, office support, and administrative members. The Disneyland Resort may explore the possibility of a "telecommuting" program that would link some of these cast members to The Disneyland Resort via electronic means (e.g., computer with modem). This would help to eliminate certain trips that would otherwise be generated by a cast member who would otherwise physically need to be at the Disneyland Resort.
 Work Environment/Facility Management
- Parking Management. The Disneyland Resort may develop a parking management program that provides incentives to those who rideshare or use transit means other than single-occupant auto to travel to work. - Management Staff. The existing Disneyland theme park transportation management staff may be expanded onsite to accommodate new employees and to explore relationships with adjacent employers to determine whether joint efforts can lead to greater reductions in VMT by project employees.
- Amenities. Transit systems, transit shelters, bicycle storage areas, and other amenities may be provided with efficient parking management for cast and guests.
- Access. Preferential access to high occupancy vehicles and shuttles may be provided.
- Delivery Management. Schedule deliveries in nonpeak traffic congestion hours to the extent reasonably practicable.
 Financial Incentives
In addition to the above items, certain financial incentives will be integrated into The Disneyland Resort TDM program, such as:

- Financial Incentive for Ridesharing and/or Public Transit. Currently, federal law provides tax-free status for up to $60 per month per employee contributions to employees who vanpool or use public transit (including commuter rail and/or express bus pools).

- Financial Incentive for Bicycling. Cast members may be offered financial incentives for bicycling to work; they would be provided with secure bicycle racks, lockers, and showers.

- Special “Premium" for the Participation and Promotion of Trip Reduction.

Tickets/passes to project theme parks and/or vacations could be offered to employees who recruit other cast members for vanpool, carpool, or other Disney trip reduction programs.

- Delivery Management. Schedule deliveries in non- peak traffic congestion hours to the extent reasonably practicable.

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 Guests
Even though visitors are estimated to average nearly four persons per vehicle, additional programs and incentives could and will be provided to encourage even more guest use of ridesharing, transit, and other modes of travel to and from The Disneyland Resort. The applicant is currently developing a list of potential programs and is working with the City of Anaheim and OCTA on the provision of convenient linkages to other modes of transportation. Marketing materials for the Disneyland Resort will describe it as an "auto-free" zone with a range of transportation amenities where cars are not needed.

PDF 3.3-17 Prior to final building and zoning inspection for the Second Theme Park Transportation Management Association,
Other measures to achieve trip reductions and other TDM program objectives will be explored, including the formation of a Disneyland Resort Transportation Management Association (TMA), or an Anaheim Resort Area TMA. To increase the likelihood of success of the TDM program, cooperation among other groups and businesses who either have existing TDM programs or have a need for TDM programming could be networked with cast participants. By expanding the number of participants in the various programs, more benefit in trip reduction is likely to be achieved. The TMA would be responsible for matching cast and guest commute services; marketing/promoting ridesharing alternatives (i.e., vanpooling, bicycling, etc.); and providing a "fair share" payment of local TDM programs provided through the TMA.

MM 3.8-11 Ongoing during construction, if Anaheim Police Department or Anaheim TMC personnel are required to provide temporary traffic control services, the property owner/developer shall reimburse the City, on a fair share basis, if applicable, for reasonable costs associated with such services.

MM 3.8-12 Prior to issuance of the first demolition, grading or building permit for Phase II, whichever occurs first, excluding permits for relocation of the SCE transmission lines, or for demolition related to relocation of the SCE transmission lines as specified in the Phasing Plan, the applicant will establish an onsite public information office (which is conveniently and accessibly located) where construction scheduling and phasing information will be available to the public. The public information office shall be open during construction hours. A telephone "hotline" will be provided to the community to allow members of the public to call the office with questions or comments during business hours. At least one liaison officer will be staffed at the office. The liaison officer shall be available to answer questions from the public and shall coordinate with the City of Anaheim, other public agencies, and major developers in the area regarding the coordination of construction activities and infrastructure improvements. The City shall be provided with a monthly summary of the calls received and follow-up actions.

PDF 3.8-1 Prior to issuance each building permit for the Disneyland Resort or, any other timing specifically provided in this meas ure, excluding the relocation of SCE Transmission lines or the Disneyland Administration Building, the applicant shall submit a Traffic Mitigation and Construction Phasing and Control Plan. To the extent needed, as determined by the Public Works Department, the following DisneylandForward
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project design features (PDF 3.8-1 - 3.8-8) require the applicant to submit at different times the plans for construction of both Phase II and Phase III development. The Traffic Mitigation and Construction Phasing and Control Plan shall identify the following:
a. A Construction Staging Area Plan showing the location and size of the construction staging area. The Plan shall also show how the staging area will be screened from view in compliance with the City of Anaheim Municipal Code. (Note from 1997 DRSP Mitigation Monitoring Guide: Screening will be reviewed in compliance with the Disneyland Resort Specific Plan in as much as the City of Anaheim Municipal Code contains no specific requirements for screening.)
(Note: Environmental equivalent approved prior to 3/98 which allows the Construction Staging Area Plan to be prepared for each project component to ensure the Plan includes sufficient detail to address said component).

PDF 3.8-3 Prior to approval of each grading plan or issuance of each demolition or building permit, whichever occurs first; implemented during grading and construction, a Truck Route Plan identifying truck routes along arterials, avoiding residential areas to the extent feasible and in compliance with the Sound Pressure Level Ordinance.

The Plan shall show conformance with the external noise limits for construction between 7 p.m. and 7 a.m. The Plan shall also prohibit construction traffic on residential streets where improvements are not planned and shall provide measures to ensure that truck drivers are directed away from residential streets and travel on approved routes only. Measures to assist in guiding truck movement on the arterial roadway system include, but are not limited to, provision of truck route maps to truck drivers and placement of flagpersons and construction signage at appropriate locations. The Truck Route Plan shall provide for monitoring of street conditions and potential repairing and/or repaving by property owner/developer after completion of construction as required by the City Engineer. (Note: Environmental equivalency approved on 3/13/97 to clarify the plan shall be submitted prior to approval of each grading plan or issuance of each demolition or building permit. The Planning Department also clarified Code Enforcement was the responsible Division.)
PDF 3.8-4 Prior to approval of each grading plan or issuance of each demolition or building permit, whichever occurs first; implemented during grading and construction, a Construction Traffic Management Plan which includes mechanisms to reduce construction-related traffic congestion which shall be implemented during grading and construction, including, but not limited to, the following:

1. Configure construction parking to minimize onsite and offsite traffic interference.

2. Minimize obstruction of through-traffic lanes.

3. Provide flagpersons to guide traffic, as determined in the plan. (Note: Environmental equivalency approved on 3/13/97 to clarify the plan shall be submitted prior to approval of each grading plan or issuance of each DisneylandForward
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demolition or building permit. The Planning Department also clarified Traffic was the responsible Division).

PDF 3.8-5 Prior to approval of each grading plan for phase ii and iii southwest parking facility a Trip Reduction Plan (excluding the demolition for or relocation of the SCE transmission lines) for construction crew vehicles shall be prepared to reduce potential vehicle trips on the road and identify parking locations for construction employees and equipment.
(Notes: Environmental equivalent approved on 4/1/97 which allows the Trip Reduction Plan to be prepared for each project component to ensure the Plan includes sufficient detail to address said component).

PDF 3.8-6 Prior to approval of each building permit, a Traffic Management Plan for phasing of roadway improvements, specifying the sequencing of construction to do the following:

1. Coordinate scheduling with other planned construction in the area, including the I-5 widening project.

2. Coordinate scheduling with other infrastructure improvements to allow them to be facilitated efficiently during roadway improvements, such as sewer, storm drain, and water line improvements.

3. Outline procedures for any required traffic detours during construction, including provision of tour bus stops.

4. Phase each roadway improvement to allow access to all existing businesses/residential areas. In some instances this will require lane-by- lane renovation, temporary bypass roads, or traffic reroutes.

5. Employ vertical shoring as often as possible. This will minimize the amount of road surface that will be disturbed at a given location.

6. Sequence the construction of each roadway improvement to minimize disruption to residents and businesses.

7. Establish offsite parking and staging areas, where practical and possible, to minimize the impact to existing level of service on adjacent roadways.

These offsite parking and staging areas will allow a dispersion of traffic flow to noncritical areas and will encourage bussing of construction workers from the offsite areas to the construction sites.

8. Identify how the project improvement construction schedules and haul routes will be coordinated with other areawide improvements. The applicant shall coordinate with the Convention Center and area hotels to ensure continued operations of these facilities, as well as the continued operation of the existing Disneyland theme park and Disneyland Hotel. (Note: Environmental equivalent approved on 7/24/97 to integrate the requirements of PDF 3.8-7 into the Traffic Management Plan. It also changes the timing for the measure as development of the South Parking Facility constitutes an early minor component of the Disneyland Resort and, therefore does not warrant preparation and implementation of a project-wide Traffic Management Plan, rather, it provides for the preparation of a Traffic Management Plan for the South Parking Facility only at this point. The need DisneylandForward
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for a project-wide Traffic Management Plan will be assessed with each Grading Plan and will be required when determined warranted by the City.) PDF 3.8-7 (Note: Environmental equivalent for PDF 3.8-6 approved on 7/24/97 which combined the monitoring requirement for this feature with PDF 3.8-6 in that infrastructure coordination is a component of the Traffic Management Plan and separate monitoring of this feature would result in a redundant effort.) PDF 3.8-8 Prior to approval of each grading plan for Phase II and III Southwest Parking Facility an Infrastructure Improvement Master Phasing Plan containing (a) infrastructure layout, and (c) infrastructure construction phasing. (Note: The following Environmental Equivalencies were approved:

On 3/21/97, environmental equivalent approved to change the timing of this measure as development of the Southwest Parking Lot constitutes an early minor component of the Disneyland Resort and, therefore, does not warrant preparation and implementation of a proj ect-wide infrastructure Improvement Master Phasing Plan, rather it provides for the preparation of a Infrastructure Improvement Master Plan for the Southwest Parking Lot only at that date. The need for a project-wide Infrastructure Improvement Master Phasing Plan would be assessed with each Grading Plan and would be required when determined warranted by the City.

Prior to 3/98, an environment equivalent was approved to eliminate the requirement for sizing, including supporting calculations, as this information is required with the actual improvement plans and is not addressed as part of a phasing plan.)
PDF 3.8-9 Ongoing during project construction, the applicant shall submit a quarterly update report showing construction activities for the upcoming quarter which shall include traffic mitigation and control planning and construction scheduling.

PDF 3.8-11 Prior to approval of each grading plan the applicant shall show how the project will be in compliance with the Traffic Mitigation and Construction Phasing and Control Plan.

Anaheim Resort Specific Plan SEIR No. 340
SEIR No. 340, which was certified by the City in 2012, is a supplemental EIR that reevaluated environmental changes in and around The Anaheim Resort since certification of EIR No. 313 in 1994. SEIR No 340 projected traffic conditions for “Interim Year” 2015 and “General Plan Buildout” 2030 based on the Anaheim Traffic Analysis Model, which included development of The Disneyland Resort Project based on EIR No. 311. As evaluated in SEIR No. 340, traffic impacts associated with buildout of the ARSP Project would result in significant impacts at area intersections, arterial segments, and freeway ramp termini intersections. However, after implementation of the identified MMs 5.14-1 through 5.14-22, these impacts would be reduced to less than significant levels for all but eight locations (Euclid Street/Katella Avenue, Disneyland Drive/Ball Road, Disneyland Drive/West Street/Katella Avenue, Harbor Boulevard/Ball Road, Anaheim Boulevard/Haster Street/Katella Avenue, State College Boulevard/Katella Avenue, State College Boulevard/Orangewood Avenue, Orangewood Avenue/SR-57 Southbound Ramps) and 1 ramp termini intersection (Orangewood Avenue/SR-57 Southbound Ramps). SEIR No. 340 indicated impacts to these intersections would remain significant and unavoidable because of the DisneylandForward
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infeasibility of mitigation measures due to high project cost or the inability to undertake right-of- way acquisitions as a matter of policy to preserve existing businesses, environmental constraints, or jurisdictional considerations. The Anaheim City Council adopted a Statement of Overriding Considerations with regard to these significant and unavoidable impacts. Additionally, SEIR No. 340 indicated no impacts would occur on intersections identified in the Congestion Management Program (CMP) for Orange County.

SEIR No. 340 Mitigation Measures
SEIR No. 340 required implementation of the following mitigation measures regarding transportation to reduce potential impacts associated with full buildout of the ARSP Project.

However, as discussed previously, transportation impacts would remain potentially significant and unavoidable even with implementation of mitigation.

MM 5.14-1 Prior to approval of a final site plan for any project forecast to generate 100 or more peak hour trips, as determined by the City Traffic and Transportation Manager utilizing Anaheim Traffic Analysis Model Trip Generation Rates, the property owner/developer shall prepare traffic improvement phasing analyses to identify when the improvements identified in this traffic analysis shall be designed and constructed.

MM 5.14-2 Prior to issuance of the first building permit for each building, the property owner/developer shall pay the appropriate Traffic Signal Assessment Fees and Transportation Impact and Improvement Fees to the City of Anaheim in amounts determined by the City Council Resolution in effect at the time of issuance of the building permit with credit given for City-authorized improvements provided by the property owner/developer. The property owner shall also participate in all applicable reimbursement or benefit districts, which have been established.

MM 5.14-3 Prior to approval of the first final subdivision map or issuance of the first building permit, whichever occurs first, the property owner/developer shall irrevocably offer for dedication (with subordination of easements), including necessary construction easements, the ultimate arterial highway right(s)-of-way adjacent to their property as shown in the Circulation Element of the Anaheim General Plan.

MM 5.14-4 Prior to the issuance of the first building permit, the property owner shall join and financially participate in a clean fuel shuttle program such as the Anaheim Resort Transportation (ART) system, and shall participate in the Anaheim Transportation Network (ATN) in conjunction with the on-going operation of the project. Proof of compliance with this requirement shall be submitted by the Anaheim Transportation Network to the City Traffic Engineer. The property owner shall also record a covenant on the property that requires participation in these programs ongoing during project operation. The form of the covenant shall be approved by the City Attorney’s Office prior to recordation. Proof of compliance with this requirement shall be the submittal of a copy of the recorded covenant to the City Traffic Engineer.

MM 5.14-5 Prior to the issuance of grading permits, the property owner/developer shall provide to the City of Anaheim Public Works Department a plan to coordinate rideshare services for construction em ployees with the Anaheim Transportation Network (ATN) for review and approval and shall implement ATN recommendations to the extent feasible.

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MM 5.14-6 Prior to the issuance of each building permit for a hotel development that exceeds 100 rooms per gross acre within the Commercial Recreation (C-R) District (Development Area 1) within the Convention Center (CC) Medium density category, the property owner shall record a covenant on the property requiring that ongoing during project implementation, the property owner/developer shall implement TDM measures sufficient to reduce the actual trip generation from the development to no more than the trips assumed by the City’s traffic model. The form of the covenant shall be approved by the City Attorney’s Office.

MM 5.14-7 Ongoing during construction, if the Anaheim Police Department or the Anaheim Traffic Management Center (TMC) personnel are required to provide temporary traffic control services, the property owner/developer shall reimburse the City, on a fair-share basis, if applicable, for reasonable costs associated with such services.

MM 5.14-8 Prior to the issuance of the first building permit, the property owner shall record a covenant on the property requiring that ongoing during project implementation, the property owner/developer shall implement and administer a comprehensive TDM program for all employees. The form of the covenant shall be approved by the City Attorney’s Office and proof of compliance with this requirement shall be the submittal of a copy of the recorded covenant to the City Traffic Engineer.

Objectives of the TDM program shall be:
a. Increase ridesharing and use of alternative transportation modes by guests. b. Provide a menu of commute alternatives for employees to reduce project- generated trips.
c. Conduct an annual commuter survey to ascertain trip generation, trip origin, and Average Vehicle.

MM 5.14-9 Prior to the issuance of the first building permit, the property owner/developer shall provide to the City of Anaheim Public Works Department, City Traffic Engineer, for review and approval a menu of TDM program strategies and elements for both existing and future employees’ commute options, and incentives for hotel patrons transportation options. These options may include, but not be limited to, the list below. The property owner shall also record a covenant on the property requiring that the approved TDM strategies and elements be implemented ongoing during project operation. The form of the covenant shall be approved by the City Attorney’s Office prior to recordation and proof of compliance with this requirement shall be the submittal of a copy of the recorded covenant to the City Traffic Engineer.
a. On-site services. Provide, as feasible and permitted, on-site services such as the food, retail, and other services.
b. Ridesharing. Develop a commuter listing of all employee members for the purpose of providing a “matching” of employees with other employees who live in the same geographic areas and who could rideshare.
c. Vanpooling. Develop a commuter listing of all employees for the purpose of matching numbers of employees who live in geographic proximity to one another and could comprise a vanpool or participate in the existing vanpool programs.

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d. Transit Pass. Promote Orange County Transportation Authority (including commuter rail) passes through financial assistance and on-site sales to encourage employees to use the various transit and bus services from throughout the region.
e. Shuttle Service. Generate a commuter listing of all employees living in proximity to the project, and offer a local shuttle program to encourage employees to travel to work by means other than the automobile. When appropriate, event shuttle service shall also be made available for guests. f. Bicycling. Develop a Bicycling Program to offer a bicycling alternative to employees. Secure bicycle racks, lockers, and showers should be provided as part of this program. Maps of bicycle routes throughout the area should be provided to inform potential bicyclists of these options. g. Guaranteed Ride Home Program. Develop a program to provide employees who rideshare, or use transit or other means of commuting to work, with a prearranged ride home in a taxi, rental car, shuttle, or other vehicle, in the event of emergencies during the work shift.
h. Target Reduction of Longest Commute Trip. Promote an incentive program for ridesharing and other alternative transportation modes to put highest priority on reduction of longest employee commute trips.
i. Work Shifts. Stagger work shifts
j. Compressed Work Week. Develop a “compressed work week” program, which provides for fewer work days but longer daily shifts as an option for employees. k. Telecommuting. Explore the possibility of a “telecommuting” program that would link some employees via electronic means (e.g., computer with modem). l. Parking Management. Develop a parki ng management program that provides incentives to those who rideshare or use transit means other than single- occupant auto to travel to work.
m. Access. Provide preferential access to high occupancy vehicles and shuttles. n. Financial Incentive for Ridesharing and/or Public Transit. Offer employees financial incentives for ridesharing or using public transportation. Currently, federal law provides tax-free status for up to $65 per month per employee contributions to employees who vanpool or use public transit including commuter rail and/or express bus pools.
o. Financial Incentive for Bicycling. Offer employees financial incentives for bicycling to work.
p. Special “Premium” for the Participation and Promotion of Trip Reduction. Offer ticket/passes to special events, vacations, etc. to employees who recruit other employees for vanpool, carpool, or other trip reduction programs. q. Incentive Programs. Design incentive programs for carpooling and other alternative transportation modes so as to put highest priority on reduction of longest commute trips.

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MM 5.14-10 Prior to approval of each tentative tract or parcel map, the following Street Design Elements shall be shown on each tentative tract or parcel map:
a. Street cross-sections, including dimensions, labels, circulation designation (i.e., Resort Secondary) and whether public or private. b. Street grades and vertical alignment.
c. Horizontal alignment, including radii, and cul-de-sac radii.

MM 5.14-11 Prior to the recordation of a subdivision map or issuance of the first building permit, whichever occurs first, in the event that a parcel is subdivided and there is a need for common on-site circulation and/or parking, prior to recordation of a subdivision map, an unsubordinated covenant providing for reciprocal access and/or parking, as appropriate, approved by the Planning Director or Planning Services Manager, shall be recorded with the Office of the Orange County Recorder. A copy of the recorded covenant shall then be submitted to the Planning Division of the Planning Department. If the reciprocal access is across parcel lines or if public rights of way are required for reciprocal access; Public Works approval shall be required.

MM 5.14-12 Prior to the issuance of the first building permit, the location of any proposed gates across a driveway shall be subject to the review and approval of the City Engineer.

Gates shall not be installed across any driveway or private street in a manner which may adversely affect vehicular traffic on the adjacent public streets. Installation of any gates shall conform to the current version of Engineering Standard Detail No. 475.

MM 5.14-13 Prior to the issuance of building permits, plans shall show that all driveways shall be constructed with a minimum fifteen (15) foot radius curb returns as required by the City Engineer, unless otherwise approved by the City Engineer.

MM 5.14-14 Prior to the issuance of building permits or final map approval, whichever occurs first, security in the form of a bond, certificate of deposit, letter of credit, completion guarantee, or cash, in an amount and form satisfactory to the City Engineer shall be posted with the City to guarantee the satisfactory completion of all engineering requirements of the City of Anaheim, including preparation of improvement plans and installation of all improvements, such as curbs and gutters, sidewalks, water facilities, street grading and pavement, sewer and drainage facilities and other appurtenant work, as required by the City Engineer and in accordance with the specifications on file in the office of the City Engineer, as may be modified by the City Engineer. Installation of said improvements shall occur prior to final building and zoning inspections.

MM 5.14-15 Based upon the improvement phasing analysis in the project traffic study, the property owner/developer shall implement traffic improvements as identified in the project traffic study to maintain satisfactory levels of service as defined by the City’s General Plan, based on thresholds of significance, performance standards, and methodologies established by the Orange County Congestion Management Program and the City of Anaheim Traffic Study Guidelines. The improvement phasing analyses will specify the timing, funding, construction, and fair-share responsibilities for all traffic improvements necessary to maintain satisfactory levels of service within the City of Anaheim and surrounding jurisdictions. The property owner/developer shall construct, bond for or enter into a funding agreement for necessary circulation system improvements, as determined by the DisneylandForward
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City Traffic and Transportation Manager, unless alternative funding sources have been identified.

MM 5.14-16 Prior to approval of a Final Site Plan for any project forecast to generate 100 or more peak hour trips, as determined by the City Traffic and Transportation Manager utilizing Anaheim Traffic Analysis Model Trip Generation Rates, in conjunction with the preparation of any traffic improvement phasing analyses as required in MM 5.14-1, property owners/developers will determine when the intersection improvements shall be constructed, subject to the conditions identified in MM 5.14-1.

MM 5.14-17 Prior to approval of a Final Site Plan for any project forecast to generate 100 or more peak hour trips, as determined by the City Traffic and Transportation Manager utilizing Anaheim Traffic Analysis Model Trip Generation Rates, in conjunction with the preparation of any traffic improvement phasing analyses as required in MM 5.14-1, the following actions shall be taken in cooperation with the City of Orange:
a. The traffic improvement phasing analysi s shall identify any impacts created by the project on facilities within the City of Orange. The fair-share percentage responsibility for mitigating these impacts shall be calculated in this analysis. b. The City of Anaheim shall estimate the cost of the project’s fair-share responsibility in cooperation with the City of Orange.
c. The property owner/developer shall pay the City of Anaheim the fair-share cost prior to issuance of a building permit. The City of Anaheim shall hold the amount received in trust, and then, once a mutually agreed upon joint program is executed by both cities, the City of Anaheim shall allocate the fair-share contribution to traffic mitigation programs that result in improved traffic flow at the impacted locations, via an agreement mutually acceptable to both cities.

MM 5.14-18 Prior to approval of a Final Site Plan for any project forecast to generate 100 or more peak hour trips, as determined by the City Traffic and Transportation Manager utilizing Anaheim Traffic Analysis Model Trip Generation Rates, in conjunction with the preparation of any traffic improvement phasing analyses as required in MM 5.14-1, and assuming that a regional transportation agency has not already programmed and funded the warranted improvements to the impacted freeway mainline or freeway ramp locations, property owners/developers and the City will take the following actions in cooperation with Caltrans:
a. The traffic study will identify the project’s proportionate impact on the specific freeway mainline and/or freeway ramp locations and its fair-share percentage responsibility for mitigating these impacts based on thresholds of significance, performance standards, and methodologies established in the Orange County Congestion Management Program and the City of Anaheim Traffic Study Guidelines.
b. The City shall estimate the cost of the project’s fair-share responsibility in cooperation with Caltrans.

MM 5.14-19 Prior to the approval of the final subdivision map or issuance of building permits, whichever occurs first, the property owner/developer shall pay the identified fair- share responsibility as determined by the City as set forth in MM 5.14-15. The City DisneylandForward
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shall allocate the property owner/developer’s fair-share contribution to traffic mitigation programs that result in improved traffic flow on the impacted mainline and ramp locations, via an agreement mutually acceptable to Caltrans and the City.

MM 5.14-20 Prior to the approval of a Final Site Plan, the property owner/developer shall meet with the Traffic and Transportation Manager to determine whether a bus stop(s) is required to be placed adjacent to the property. If a bus stop(s) is required, it shall be placed in a location that least impacts traffic flow and may be designed as a bus turnout or a far side bus stop as required by the Traffic and Transportation Manager and per the approval of the Orange County Transportation Authority (OCTA).

MM 5.14-21 Prior to the first final building and zoning Inspection every property owner and/or lessee shall designate an on-site contact that will be responsible for coordinating with the ATN and implementing all trip mitigation measures. The on-site coordinator shall be the one point of contact representing the project with the ATN.

The TDM requirements shall be included in the lease or other agreement with all of the project participants.

MM 5.14-22 Subsequent to the certification of SEIR No. 340, and prior to the approval of the first Final Site Plan, if the costs of the identified improvements in the Traffic Study Report for Amendment No. 14 to the Anaheim Resort Specific Plan cannot be covered by the total funding allocation under the existing City fee programs and funding sources, an update of the existing City traffic fee program or other fee programs shall be developed by the City of Anaheim to ensure completion of the recommended improvements.

5.14.2 ENVIRONMENTAL SETTING
The following discussion details the existing conditions at the time the City published the NOP for Subsequent EIR No. 352; however, consistent with CEQA’s subsequent review standards, the previously approved projects serve as the baseline for the CEQA analysis, and Subsequent EIR No. 352 compares the effects of the Project changes on the previously approved projects with the effects of the previously analyzed and approved projects, as detailed in EIR No. 311 and SEIR No. 340.

A. Existing Conditions
Existing Roadway Network
The existing roadway network within the Project Site consists of a system of freeways, arterials, and smart streets. These facilities provide regional, sub-regional, and local access and circulation to and within the Project Site. The freeway system provides regional access to the Project Site.

I-5 provides the primary regional access to the Pr oject Site; however, vehicles also get to the Project Site using SR-57, SR-22, and SR-91. Together these freeways also provide extensive regional connectivity to the Project Site (Gibson 2023a). The following arterial roadways provide access to the Project Site: Harbor Boulevard, Manchester Avenue/Clementine Street, Ball Road, Katella Avenue, Disneyland Drive, Disney Way, Haster Street, and Walnut Street. The following non-arterial streets also provide access to the Project Site: West Street, Cast Place, and Convention Way.

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Existing Public Transit System
A variety of public transit options are available to access the Project Site, including: OCTA Route 37; OCTA Route 43; OCTA Route 46; OCTA Route 47; OCTA Route 50; OCTA Route 83; OCTA Bravo Route 543; Los Angeles County Metropolitan Transportation Authority (Metro) Route 460; Riverside Transit Agency CommuterLink Route 200; and the Anaheim Resort Transportation (ART) Anaheim Regional Transportation Intermodal Center (ARTIC) Express. Additionally, ARTIC is located approximately 2.9 miles east of the Project Site on Katella Avenue and is a major transit hub with additional local bus and commuter rail services (Gibson 2023a).

Buses and shuttles provided by Disney carry guests from the Mickey and Friends and Pixar Pals parking structures in the Parking District, West Parking Area, to the west side of the theme park entry plaza, and a bus service carries guests from the Toy Story Lot to the East Esplanade transportation hub on the east side of the theme park entry plaza. Also, some of the non-Disney hotels in the vicinity offer complimentary guest shuttles to the East Esplanade transportation hub.

The ART system provides a number of short distance routes throughout The Anaheim Resort area (Gibson 2023a).

Existing Bicycle and Pedestrian Facilities
There is a substantial amount of pedestrian traffic within the Project Site and surrounding area, particularly along Katella Avenue and Harbor Boulevard within The Anaheim Resort. The Disneyland Resort and the Anaheim Convention Center are the primary drivers of pedestrian activity within the Project Site. Pedestrian trips occur between the theme parks, the Anaheim Convention Center, and surrounding restaurants, hotels, and parking areas. Sidewalks, signalized crosswalks, and accessible curb ramps are provided throughout the Project Site.

Private pedestrian infrastructure also exists within the Project Site, including pedestrian bridges over Magic Way adjacent to Disneyland Drive and over Disneyland Drive as part of Downtown Disney entertainment district (Gibson 2023a).

Existing and planned bicycle facilities in the City are classified in the City of Anaheim General Plan Circulation Element as Class I Bike Paths, Class II Bike Lanes, and Class III Bike Routes.

Within the Project Site, there are no existing Class I Bike Paths, however, the following Class I Bike Lanes, Class II Bike Lanes, and Class III Bike Routes are either existing or planned within or near the Project Site:

Planned Class I Bike Lanes:
 Union Pacific rail right of way and Southern California Edison right of way west of Walnut Street
 Southern California Edison property north of Disney Way and extending east past Anaheim Boulevard to Harbor Boulevard
Existing Class II Bike Lanes:
 Euclid Avenue north of Ball Road
 Cerritos Avenue west of Walnut Street and east of Anaheim Boulevard  Ball Road west of Loara Street and between Anaheim Boulevard and Claudina Street  Anaheim Boulevard north of Cerritos Avenue
 9
th Street south of Katella Avenue
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 Orangewood Avenue west of Janette Lane and east of Harbor Boulevard Planned Class II Bike Lanes:
 Euclid Street south of Ball Road
 9 th Street between Cerritos Avenue and Katella Avenue  Walnut Street
 Cerritos Avenue between Euclid Street and Carnelian Street  Ball Road between Loara Street and Flore Street/West Place, between Lemon Street and Anaheim Boulevard, and east of Claudina Steet
 Vermont Avenue east of Citron Street
 Anaheim Boulevard between Cerritos Avenue and Katella Avenue  Haster Street between Katella Avenue and Simmons Avenue  Orangewood Avenue between West Street and Harbor Boulevard Existing Class III Bike Routes:
 Cerritos Avenue between Euclid Street and Carnelian Street  Ball Road between Loara Steet and Walnut Street
 Walnut Street north of Ball Road
Each of these Class III Bike Routes are planned to be upgraded to Class II Bike Lanes:
 Citron Street north of Vermont Avenue
 Lemon Street (Gibson 2023a)
B. Regulatory Framework
Federal
Manual on Uniform Traffic Control Devices
The Federal Highway Administration’s (FHWA) Manual on Uniform Traffic Control Devices (MUTCD) is contained in the Code of Federal Regulations (CFR, Title 23, Part 655, Subpart F).

The FHWA requires that the most recent Manual on Uniform Traffic Control Devices (MUTCD) be adopted by individual states as their legal State standard for traffic-control devices within two years of the update. The MUTCD identifies the standards that should be used to install and maintain traffic-control devices on all public streets, highways, bikeways, and private roads that are open to public traffic. The City uses the MUTCD for determining the necessary traffic-control devices (e.g., signs, barricades, gates, warning signs, object markers, guide signs, pavement and curb markings, traffic-control signs, pedestrian control signs, in-roadway lights, and flagger control) on public streets, highways, bikeways, and school areas in the City, including temporary traffic-control devices in and near construction work areas.

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State
Senate Bill 743
With the adoption of SB 743, the State of California changed the method of traffic analysis required by the California Environmental Quality Act (CEQA) for projects. The law changed the way local jurisdictions analyze transportation impacts from development projects and identify mitigation measures to reduce those impacts. SB 743 became effective on July 1, 2020. The previous practice of evaluating traffic transportation impacts used vehicular LOS on the local roadway system. SB 743 requires the amount of driving and length of trips — as measured by VMT — be used to assess transportation impac ts under CEQA. These impacts would be reduced or “mitigated” by options such as increasing tr ansit, providing for active transportation such as walking and biking, and participating in mitigation banks. All jurisdictions have the option to tailor requirements to their unique communities.

Regional
Southern California Association of Governments (SCAG)
Under federal law, Southern California Association of Governments (SCAG) is designated as a Metropolitan Planning Organization (MPO) and under state law as a Regional Transportation Planning Agency and a Council of Governments for Orange County and the Project Site. The SCAG region encompasses six counties (Imperial, Los Angeles, Orange, Riverside, San Bernardino and Ventura) and 191 cities in an area covering more than 38,000 square miles. The agency develops long-range regional transportation plans, including sustainable communities' strategies and growth forecast components, regional transportation improvement programs, regional housing needs allocations, and a portion of the South Coast Air Quality management plans (SCAG 2022a).

Connect SoCal
On September 3, 2020, SCAG’s Regional Council unanimously voted to approve and fully adopt Connect SoCal (2020–2045 Regional Transportation Plan/Sustainable Communities Strategy) (RTP/SCS) (SCAG 2020). Connect SoCal is a long-range plan that builds upon and expands land use and transportation strategies established over several planning cycles to increase mobility options and achieve a more sustainable growth pattern. It charts a path toward a more mobile, sustainable and prosperous region by making connections between transportation networks, between planning strategies and between the people whose collaboration can improve the quality of life for Southern Californians. Connect SoCal outlines more than $638 billion in transportation system investments through 2045. It was prepared through a collaborative, continuous, and comprehensive process with input from local governments, county transportation commissions, tribal governments, non-profit organizations, businesses and local stakeholders within the counties of Imperial, Los Angeles, Orange, Riverside, San Bernardino and Ventura (SCAG 2022b).

Master Plan of Arterial Highways
The Master Plan of Arterial Highways (MPAH) was initially established by the County of Orange in 1956 to ensure that a regional arterial highway network would be planned, developed, and preserved, in order to supplement the County’s developing freeway system. This vision has withstood the test of time and is consistent with the U.S. Department of Transportation’s view today “that multiagency collaboration is a critical element in developing 21st century solutions for 21st century transportation challenges, such as reducing traffic congestion”. Arterial highways are DisneylandForward
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shown on the MPAH map as either: (1) established alignments depicted by solid lines on the map, including existing highways where the centerline is the precise centerline; and (2) future highways where the Board of Supervisors, a City Council, or the subdivision process has established a precise alignment; and conceptually proposed alignments, defined by intermittent lines indicating future facilities whose precise alignment has not yet been determined (OCTA 2017).

Local
The City of Anaheim General Plan
The State of California requires that every city and county prepare and adopt a general plan. State law also specifies the content of the plan and requires that it be comprehensive and consistent and that it have a long-term perspective. The City of Anaheim General Plan is comprehensive, not only in terms of the geographic planning area that it considers, but also in the range of issues addressed (City of Anaheim 2004). Issues associated with the City’s development include physical, social, and economic concerns. By law, the General Plan must address the following seven subject areas or elements: land use, circulation, housing, conservation, open space, noise, and safety. It may also address any other issues or include any other elements that relate to the physical development of the city or county. The City of Anaheim has also elected to include an Economic Development Element, a Growth M anagement Element, a Public Services and Facilities Element, and a Community Design Element. The City of Anaheim General Plan is described in Section 5.10, Land Use and Planning. Applicable goals and policies that are related to traffic and circulation are provided in Table 5.10-1 of Section 5.10, Land Use, along with a Project consistency analysis. The Circulation Element is described in general below.

Circulation Element
The Circulation Element describes the existing circulation system and serves as an infrastructure plan that addresses the mobility of people, goods and services, energy, water, sewage, storm drainage, and communications. According to the City of Anaheim General Plan, the purpose of the Circulation Element “is to design and improve a circulation system to meet the current and future needs of all Anaheim residents and visitors”. Within or adjacent to its borders, the Project area includes several major circulation routes including the I-5 Freeway and City streets such as Harbor Boulevard, Ball Road, and Katella Avenue. According to Figure C-1 of the Circulation Element, several area roadways within or adjacent to the Project area are classified on the City’s Planned Roadway Network, including:
 Anaheim Boulevard, Primary Arterial;
 Ball Road, Primary Arterial;
 Cerritos Avenue, Secondary Arterial west of Walnut Street and Primary Arterial east of Anaheim Boulevard;
 Clementine Street, Secondary Arterial;
 Disney Way, Major Arterial;
 Disneyland Drive, Secondary Arterial;
 Euclid Street, Primary Arterial;
 Flore Street/West Place, Local Street;
 Gene Autry Way, Primary Arterial;
 Harbor Boulevard, Major Arterial;
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 Haster Street, Primary Arterial;
 Katella Avenue, Major Arterial west of Walnut Street and Resort Smart Street between Walnut Street and I-5;
 Magic Way, local roadway;
 Manchester Avenue, Secondary Arterial;
 Orangewood Avenue, Secondary Arterial west of Manchester Avenue and Primary Arterial east of Manchester Avenue;
 Ox Road/Cast Place, Local Street;
 Walnut Street, Secondary Arterial; and
 West Street, Secondary Arterial.

Bicycle Master Plan
The City’s Bicycle Master Plan is a 20-year plan to close gaps in the existing bicycle network, provide new bicycle connections between key points, and maximize implementation of new bicycle lanes. It is included in the General Plan Circulation Element as Appendix B and the plan is summarized in the Existing and Planned Bicycle Facilities Map, provided therein as Figure C-5.

Transportation Fee Program
Chapter 17.32 - Transportation Impact and Improvement Fee of the Anaheim Municipal Code requires the payment of transportation impact fees by the developer of new projects to pay for their fair share of the costs of needed roadway and intersection improvements identified in the City of Anaheim Circulation Element.

Transportation Demand Management Program
Transportation Demand Management (TDM) Program Chapter 14.60 - Transportation Demand of the Anaheim Municipal Code serves as the City’s Trip Reduction and Travel Demand Ordinance for compliance with the Orange County Congestion Management Program. The City of Anaheim’s Transportation Demand Management (TDM) program promotes increased ridesharing and the use of alternative modes of transportation by employees. The TDM program provides a menu of commute alternatives for employees to reduce project-generated trips and requires employers to conduct an annual commuter survey to ascertain project trip generation, trip origin, and average vehicle ridership. Projects with over 250 employees are required to submit annual commuter surveys to the South Coast Air Quality Management District (SCAQMD) under SCAQMD’s Rule 2202. The City’s TDM program is coordinated with the ATN, as all projects requiring compliance with the TDM program also are required to join the ATN.

5.14.3 PROJECT IMPACT ANALYSIS
A. Methodology
This section is based on the CEQA Transportation Analysis, included as Appendix J-1. Under SB 743 and CEQA Guidelines Section 15064.3, subdivision (b), CEQA requires that transportation analysis be based on VMT. The City approved VMT as the basis for determining significant impacts under CEQA in a City Council meeting on June 23, 2020. The CEQA Transportation Analysis, therefore, analyzed the effects of the Project based on City of Anaheim Traffic Impact Analysis Guidelines for CEQA Analysis, which describes the City’s approach to analyzing VMT.

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The CEQA Transportation Analysis evaluated the Project based on future cumulative conditions, or Project buildout, in 2045.

While not required by CEQA, the Operational Traffic Analysis was prepared using LOS in accordance with City of Anaheim Traffic Study Guidelines and outside of the CEQA process.

Thus, the Operational Traffic Analysis analyzes only non-CEQA effects of the Project in accordance with the City Guidelines. This report is included as Appendix J-2.

This analysis utilizes info rmation from the CEQA Transportation Analysis related to the existing transportation system, VMT, emergency access, and construction access (Gibson 2023a). While the Project allows the transfer of previously approved uses among Disney Properties, the CEQA Transportation Analysis analyzed a specific scenario that was identified as having the greatest change to traffic conditions compared with the current entitlements (i.e., development of the Project Site to the full permitted density at the currently permitted locations). This scenario includes developing the maximum 1,852 hotel rooms (along with the permitted 5,100 parking spaces) within the Southeast District and developing the remaining allowed 1,406 hotel rooms along the north side of the Theme Park District south of Ball Road (rather than developing additional hotels within the current Hotel District). Five hundred of those hotel rooms would be located west of Disneyland Drive, with access from Ball Road at Flore Street/West Place, and the remaining 906 hotel rooms would be located east of Disneyland Drive, with access from Ball Road at Ox Road/Cast Place. This scenario also includes development of 5,700 parking spaces at Harbor Cast Member Lot at 333 West Ball Road, which represents an increase of 4,376 spaces over what is currently provided. While development of theme park square footage and retail, dining, and entertainment uses would be permitted in the Southeast District and the ARSP Theme Park Overlays, parking for those uses would not change from current entitlements (other than the proposed additional parking at the Harbor Cast Member Lot) and, therefore, any relocations of those uses would not affect traffic patterns. This scenario also assumes development of the hotel rooms currently permitted within the Disney ARSP Properties.

B. Thresholds of Significance
The following significance criteria are derived from the City of Anaheim Environmental Checklist.

Threshold 5.14a Would the project conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities?
Threshold 5.14b Would the project conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b)?
Threshold 5.14c Would the project substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses?
Threshold 5.14d Would the project result in inadequate emergency access? C. Standard Requirements
No standard requirements for this topic apply to the Project.

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D. Impact Analysis
Threshold 5.14a Would the project conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities?
No New Impact from EIR No. 311; Reduced Impact from SEIR No. 340 – Project Impact Less Than Significant With Mitigation. EIR No. 311 generally addressed this threshold through consistency analyses contained in Section 3.1, Land Use-Related Plans and Policies, and concluded buildout of The Disneyland Resort Project would result in less than significant impacts related to Transportation Planning Programs. SEIR No. 340 found a significant and unavoidable impact based on the LOS analysis used at the time, and which is no longer an applicable threshold for transportation analyses.

A project would not conflict with a program, plan, ordinance, or policy if it were generally consistent with and would not obstruct implementation of that program, plan, ordinance, or policy.

Additionally, a project would not be inconsistent merely based on whether a project would not implement a particular program, plan, policy, or ordinance. In many cases, such programs, plans, policies, and ordinances are intended to be implemented at the jurisdictional level. If a conflict is identified, mitigation measures would focus on improving access, comfort, and safety for all road users, especially pedestrians, bicyclists, and transit riders.

The following programs, plans, policies, and ordinances were reviewed below:
 California Senate Bill 743;
 Connect SoCal;
 Orange County Master Plan of Arterial Highways;
 Orange County Congestion Management Program;
 General Plan Circulation Element;
 Bicycle Master Plan;
 Disneyland Resort Specific Plan; and
 Anaheim Resort Specific Plan.

In addition to Project-level consistency, a cumulative analysis is provided of the consistency of the Project in combination with other development projects in the Project area.

California Senate Bill 743 (SB 743)
With the adoption of SB 743, which became effective on July 1, 2020, the State of California changed the way local jurisdictions analyze transportation impacts from development projects and identify mitigation measures to reduce those impacts under CEQA. SB 743 requires the amount of driving and length of trips — as measured by VMT — be used to assess transportation impacts on the environment for CEQA review. These impacts would be reduced or “mitigated” by options such as increasing transit, providing for active transportation such as walking and biking, and participating in mitigation banks. All jurisdictions have the option to tailor requirements to their unique communities. SB 743 replaced the previous practice that evaluated traffic transportation impacts using the vehicular LOS on the local roadway system.

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The analysis for Threshold 5.14b, below, presents a quantitative analysis of Project-related impacts on VMT based on the City’s adopted methodologies and significance criteria. As detailed therein, the Project would result in a significant impact on the basis of Project-generated VMT per capita (based on a modified service population estimate) prior to mitigation. As detailed in MM TRA-8, Disney will continue to operate and monitor a TDM program for cast members.

Therefore, the Project would not conflict with SB 743.

Connect SoCal
In the development of the demographic and growth assumptions associated with Connect SoCal, SCAG utilized parcel-level existing and future (general plan) land use designations. The Project would allow the transfer of previously approved uses to other Disney Properties within the Project Site. As such, the Project would not result in additional development over that previously analyzed and approved for full buildout of The Disneyland Resort Project and the ARSP Project; therefore, the Project would be consistent with the assumptions utilized to develop Connect SoCal.

Orange County Master Plan of Arterial Highways (MPAH)
The MPAH was established in 1956 to ensure that the regional arterial roadway network would be sufficient to support the County’s freeway system as it developed. Administered by OCTA, the MPAH identifies through lane requirements and traffic signal synchronization on arterial roads which are required for local jurisdictions to be eligible for funding through the Renewed Measure M Transportation Investment Plan, a half-cent sales tax for transportation improvements approved in November 2006, and the Orange County Comprehensive Transportation Funding Program, a grant program for street improvement funding. The City’s current arterial street classifications (i.e., Secondary Arterial and above) detailed in the CEQA Transportation Analysis [Appendix J-1] are consistent with the classifications in the MPAH. The Project proposes amendments to the MPAH, including:
 Removal of the planned future extensions of Clementine Street between Katella Avenue and Orangewood Avenue and Gene Autry Way between Harbor Boulevard and Haster Street; and
 Reclassification of Disney Way between Anaheim Boulevard and Harbor Boulevard from a six-lane Major Arterial to a four-lane Primary Arterial.

The MPAH seeks to balance regional mobility and local access and to coordinate with local jurisdictions’ land use plans. None of the three streets that would be modified with the proposed amendments serve regional traffic circulation needs. They provide local access to uses within The Anaheim Resort area, including Project uses. The proposed MPAH amendments are consistent with proposed amendments to the City of Anaheim General Plan, the ARSP, and DRSP, and therefore are consistent with the purpose of the MPAH. Therefore, the Project would not conflict with the MPAH.

Orange County Congestion Management Program
The 2021 Orange County Congestion Management Progr am Report (OCTA, November 2021) (CMP) is designed to maintain adopted LOS standards on key intersections throughout the County as well as to identify and implement improvement programs when necessary to bring those facilities into compliance with the standards. CMP facilities should operate at LOS E or better based on the intersection capacity utilization (ICU) methodology.

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There are a total of five CMP-monitored intersections within the Project area:
 Intersection #8, Harbor Boulevard and I-5 Northbound Ramps;  Intersection #9, Harbor Boulevard and I-5 Southbound Ramps;  Intersection #12, Harbor Boulevard and Katella Avenue;  Intersection #25, Manchester Avenue/I-5 Southbound Ramps and Katella Avenue; and  Intersection #26, Anaheim Way and Katella Avenue.

According to the CMP, each of those five intersections currently (as of year 2021) operates at LOS A during both the morning and afternoon peak hours. With the Project and full buildout of all land use density permitted under the General Plan, each of those monitoring intersections would operate at LOS E or better. Thus, the Project would not conflict with the CMP.

City of Anaheim General Plan
The City of Anaheim General Plan, and in particular the General Plan Circulation Element, serve to ensure that the City’s transportation system serves its current and future needs by:
 Facilitating the design and operation of arterial streets;  Encouraging multi-modal transportation, including public transit;  Encouraging traffic calming measures for pedestrian safety and neighborhood livability;  Identifying bicycle and pedestrian pathways to facilitate alternative modes; and  Providing for the efficient mobility of people and goods.

The General Plan Circulation Element also endeavors to maintain peak hour operating conditions not worse than LOS D at intersections. The General Plan Circulation Element is consistent with regional plans including the MPAH and CMP. It also incorporates the City’s Bicycle Master Plan via the Existing and Planned Bicycle Facilities Map (Figure C-5 of the General Plan Circulation Element).

The Project proposes to amend the General Plan Circulation Element as detailed in Section 3.5.2, Project Characteristics, to accommodate the requested modifications to the City’s transportation system, as described in Section 5.10, Land Use. These amendments would upgrade proposed bicycle infrastructure on Disney Way, Clementine Street, and Walnut Street, modify the classification of Disney Way to better serve access to the East Parking Area, and remove planned future extensions of Clementine Street and Gene Autry Way to allow for contiguous development of the Southeast District and Theme Park East Overlay. They would thus improve bicycle infrastructure, improve access, and improve land utilization within a portion of the Project Site.

With approval of those amendments, the Project would be consistent with and help to further the general goals of the General Plan Circulation Element. The Project would also be consistent with Goal 2.1, which establishes the LOS D intersection operating standard, because it would maintain LOS D or better at virtually all intersections within the vicinity, and would implement transportation improvements at several intersections. Because there are several intersections that would operate at LOS E and cannot feasibly be improved, the Project would contribute funding toward operational improvements within The Anaheim Resort area. Table 5.10-1 of Section 5.10, Land Use and Planning, provides a detailed discussion of the Project’s consistency with specific enumerated Goals and Policies in the General Plan Circulation Element.

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Bicycle Master Plan
The City’s Bicycle Master Plan is a 20-year plan to close gaps in the existing bicycle network, provide new bicycle connections between key points, and maximize implementation of new bicycle lanes. It is included in the General Plan Circulation Element as Appendix B and the plan is summarized in the Existing and Planned Bicycle Facilities Map, provided therein as Figure C-5.

The Project Site is adjacent to proposed bicycle infrastructure in several places. The Project would not affect the ability of the City to install proposed Class II Bike Lanes on Ball Road between Walnut Street and Flore Street/West Place, the eastern portion of which is adjacent to the Theme Park District. The Project also would not affect the ability of the City to install proposed Class II Bike Lanes on Haster Street south of Katella Avenue, as the proposed traffic signal at the Southeast District driveway on Haster Street would be designed to safely incorporate these lanes.

As required by MM TRA-1 , Disney would dedicate the required right-of-way and pay in-lieu contributions to the City for these bicycle facilities adjacent to the Project Site on Ball Road and Haster Street.

The Project proposes to amend the Circulation Element of the city of Anaheim General Plan and the Bicycle Master Plan to modify the classification of the planned bicycle facility on Walnut Avenue between Katella Avenue and Ball Road from a Class II Bike Lane to a Class I Bike Path on the east side of Walnut Avenue. The Project would install the single two-way, off-street, shared- use pedestrian and bicycle path with a minimum width of 10 feet on the east side of Walnut Street from Ball Road to Katella Avenue with development of theme park uses in the expanded Theme Park District. As a protected off-street Bike Path, this Class I facility would be an upgrade over the planned Class II facility consisting of on-street Bike Lanes.

The Project proposes to amend the Circulation Element of the City of Anaheim General Plan and the Bicycle Master Plan (1) to remove the Class I Bike Path in the Southern California Edison right-of-way between Harbor Boulevard and Anaheim Boulevard, (2) to add a Class I Bike Path on the north side of Disney Way between Clementine Street and Anaheim Boulevard, and (3) to add a Class I Bike Path on the west side of Clementine Street between Alro Way and Disney Way. The Project would also install the single two-way, off-street, shared-use bike path on the west side of Clementine Street between Alro Way and Disney Way and the bike lane on Disney Way between the east side of Clementine Street and the southbound I-5 off-ramp with development of a parking structure in the DRSP Parking District East Parking Area and/or in the ARSP Parking Overlay north of Disney Way. Additionally, the Project would install a bike parking facility in the DRSP East Parking Area and/or the ARSP Parking Overlay just north of the East Parking Area with development of such parking structure. These features, though providing a shorter overall Bike Path compared to the current plan for the Class I Bike Path on Disney Way between Harbor Boulevard and Anaheim Boulevard, are collectively an upgrade because the endpoint within the East Parking Area or adjacent Parking Overlay would provide bicycle parking and a more direct connection into The Anaheim Resort pedestrian system.

The Bicycle Master Plan also identifies locations in the City where bicycle parking is existing or proposed. Several of these locations are within the Project Site, including both existing and proposed bicycle parking. The Project would add additional bicycle parking as required by the City, including at the locations identified in the Bicycle Master Plan.

Therefore, with approval of the proposed amendment to the Existing and Planned Bicycle Facilities Maps and provision of bicycle paths consistent with the Bicycle Master Plan, the Project would be consistent with the Bicycle Master Plan.

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Disneyland Resort Specific Plan (DRSP)
The DRSP provides development standards for The Disneyland Resort, a subarea of The Anaheim Resort. It was first adopted in 1993 with the goal of changing Disneyland from a single- day attraction to a multi-day resort destination. It created the original Districts and permitted development according to the summary provided in Table 3-2, Uses Currently Allowed Under DRSP/ARSP for Disney Properties, of Section 3, Project Description. The DRSP is consistent with the ARSP and the General Plan Circulation Element.

The Project proposes to amend the DRSP to allow the transfer of previously approved uses to other Disney Properties as described in Table 3-3, Proposed Development Summary for Disney Properties, in Section 3, Project Description, and modify certain roadways (including Magic Way, Disney Way, Clementine Street, and Walnut Street) as described above. It would also amend the DRSP with regard to changes to street classifications and configurations as follows:
 Remove the planned future extensions of Clementine Street between Katella Avenue and Orangewood Avenue and Gene Autry Way between Harbor Boulevard and Haster Street, which are planned through the Southeast District of the DRSP and the adjacent Theme Park East Overlay in the ARSP;
 Reclassify Disney Way between Anaheim Boulevard and Harbor Boulevard from a six lane Major Arterial to a four-lane Primary Arterial (with no reduction to the width of the ultimate public ROW);
 Remove the Class I Bike Path in the Southern California Edison ROW between Harbor Boulevard and Anaheim Boulevard;
 Abandon and close Magic Way to public traffic between Walnut Street and Disneyland Drive (emergency access and pedestrian access would be provided);  Abandon public ROW on Clementine Street between Katella Avenue and the southern property line of the proposed Southeast District of the DRSP;  Abandon public ROW on Hotel Way north of Disney Way;
 Install a pedestrian signal on Walnut Street at Magic Way  Install a traffic signal at the existing driveway to the Southeast District on Haster Street south of Katella Avenue;
 Install a traffic signal on Manchester Avenue / Clementine Street at Alro Way;  Modify intersection lane configurations at Harbor Boulevard and Convention Way to provide two left-turn lanes, one shared through/right-turn lane, and one exclusive right- turn lane on the eastbound approach and one left-turn lane, one shared through/right-turn lane, and one exclusive right-turn lane on the westbound approach (consistent with existing configuration);
 Modify intersection lane configurations at Haster Street and Gene Autry Way to provide a single shared left-turn/through/right-turn lane for the eastbound approach and three left- turn lanes and two right-turn lanes for the westbound approach. The northbound approach would be equipped with a right-turn lane signal overlapping with the westbound left-turn signal phase;
 Modify the classification of the planned bike facility on Walnut Street between Katella Avenue and Ball Road from Class II Bike Lanes to a Class I Bike Path on the east side of Walnut Street;
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 Modify the configuration of Walnut Street between Ball Road and Katella Avenue to provide a Class I Bike Lane with a single two-way, off-street, shared-use pathway for pedestrians and bicycles with a minimum width of 10 feet on the east side of Walnut Street (in lieu of currently proposed Class II Bike Lanes); and  Modify the configuration of Disney Way and Clementine Street to provide for a Class I Bike Path with a minimum width of 10 feet on the north side of Disney Way between Clementine Street and Anaheim Boulevard, (2) to add a Class I Bike Path on the west side of Clementine Street between Alro Way and Disney Way (limits subject to change based on determination of proposed dedication); and (3) add a bike parking facility in the DRSP East Parking Area and/or the ARSP Parking Overlay just north of the DRSP East Parking Area;
 Install (1) a single two-way, off-street, shared-use pathway for pedestrians and bicycles with a minimum width of 10 feet on the west side of Clementine Street between Alro Way and Disney Way; and (2) a bike parking facility in the East Parking Area and/or the Parking Overlay just north of the East Parking Area;
 Provide in-lieu contribution and dedicate ROW adjacent to the Project Site on Ball Road and Haster Street for proposed Class II Bicycle Lanes on those streets.

The purpose of the DRSP is to provide for the development of a multi-day vacation destination resort through a land use plan, public facilities plan, design plan, and zoning and development standards to ensure a high-quality resort area. The Project would not increase the total amount of allowable development compared with the DRSP as currently approved, but the amendments listed above would improve the public facilities to better implement the land use plan and better serve visitors to the resort area. Therefore, with approval of the proposed amendments, the Project would be consistent with the DRSP.

Anaheim Resort Specific Plan (ARSP)
The ARSP provides development and zoning standards for the ARSP area aimed at maintaining and enhancing its recreation and tourist/convention-related setting. It was first adopted in 1994 and has since been amended. The ARSP is compatible with the DRSP and is consistent with the General Plan, including roadway classifications, land use plans, and policies. The Project would amend the ARSP to add the various zoning overlays at the Disney ARSP Properties as described in Section 3, Project Description. It would also amend the ARSP with regard to changes to street classifications and configurations as discussed above for the DRSP.

Similar to the DRSP, the ARSP is an area designated for recreation and tourist/convention-related activities with a unified set of zoning and development standards, design guidelines, and public facilities plans, all of which are supported or improved by the proposed amendments. Therefore, with approval of the proposed amendments, the Project would be consistent with the ARSP.

A more detailed discussion of the Project’s consistency with applicable programs, plans, ordinances, and policies is provided in response to Threshold 5.10b in Section 5.10, Land Use and Planning, of this SEIR. Specifically, the Project’s consistency with the City’s General Plan, is provided in Table 5.10-1. As described in response to Threshold 5.10b, the Project would be consistent with applicable programs, plans, ordinances, and policies, including those addressing the circulation system.

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Active Transportation and Public Transit
The City’s impact threshold for Active Transportation and Public Transit analysis requires not only review of potential conflicts with adopted policies, plans, or programs regarding public transit, bicycle, or pedestrian facilities, but also analysis of any potential performance or safety decrease in such facilities.

Public Transit
During development of the Project, Disney may relocate the East Esplanade transportation center from the west side of Harbor Boulevard to the East Parking Area or adjacent ARSP Parking Overlay. The relocated transportation center would continue to provide loading areas for public and private buses and shuttles and would be fully integrated into the pedestrian circulation system for The Disneyland Resort. PDF 3.3-5 of EIR No. 311, under which the transportation center was first developed, proposed that it would initially be located west of Harbor Boulevard but could eventually be relocated to the East Parking Area and, therefore, this potential relocation is not a new feature of the Project. There would be no performance or safety decrease resulting from this feature and, therefore, no significant impact. Further, implementation of MM TRA-9 would encourage increased use of transit options.

Bicycle Facilities
The discussion of Project consistency with the Bicycle Master Plan above provides a detailed description of the Project’s proposed amendments and features relating to bicycle infrastructure.

In each case, the Project proposes to maintain or upgrade facilities from current plans. The Project would pay in-lieu contributions to the City and dedicate ROW adjacent to the Project Site on Ball Road and Haster Street for proposed Class II Bike Lanes on those streets. The Project would result in an upgrade to the proposed bicycle facilities on Walnut Street. The proposed Class I Bike Path on Disney Way also would be upgraded to connect to a proposed Class I Bike Path on Clementine Street leading to a proposed bicycle parking area within the East Parking Area or the adjacent ARSP Parking Overlay, which would be fully integrated into the pedestrian circulation system for The Disneyland Resort. This particular feature, though a shorter overall Bike Path compared to the current plan for the Class I Bike Path to travel on Disney Way between Harbor Boulevard and Anaheim Boulevard, is an upgrade because the endpoint within the East Parking Area or adjacent ARSP Parking Overlay would provide bicycle parking and a more direct connection into The Disneyland Resort pedestrian system. Overall, the Project would improve the safety and performance of the bicycle infrastructure within the Anaheim Resort area.

Pedestrian Facilities
The Project would upgrade the pedestrian circulation system through the installation of at least one and up to three pedestrian bridges over Harbor Boulevard between Manchester Avenue and Disney Way. It would also install a pedestrian signal on Walnut Street at Magic Way. It would maintain a non-ticketed pedestrian route for east-west circulation between Harbor Boulevard and Disneyland Drive between the two existing theme parks, maintaining connectivity between Harbor Boulevard and Walnut Street and the theme parks, hotels, Downtown Disney, and parking facilities along Disneyland Drive. With the development of a parking structure in the East Parking Area of the Parking District, there would not be a pedestrian sidewalk on the north side of Disney Way adjacent to the structure. However, a pedestrian pathway would connect the East Parking Area to the sidewalk west of the East Parking Area continuing west to Harbor Boulevard, providing more direct pedestrian access to the primary pedestrian destination in the area. Future development within the Project Site would be subject to specific development standards intended to enhance the pedestrian experience with a focus on accessibility and safe passage. Overall, DisneylandForward
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the Project would improve the safety and performance of the pedestrian infrastructure within the Anaheim Resort area. Additionally, implementation of MM TRA-6 would require development of alternative pedestrian infrastructure to efficiently move guests from the parking facilities to the Theme Park District. Future connections may also be provided to the Southeast District.

Conclusion
As discussed above, implementation of specific mitigation measures which support implementation of new and improvement to existing roadway systems, parking, and access would reduce impacts to less than significant levels. Further, implementation of MM TRA-1 through MM TRA-15 would reduce impacts to less than significant levels.

The Project would result in a less than significant impact with mitigation. This impact would not be new or substantially more severe when compared with the impact analysis in EIR No. 311. This impact would be reduced when compared with the analysis in SEIR No. 340, which focused on the LOS analysis methodology.

Threshold 5.14b Would the project conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b)?
New Impact from EIR No. 311/New Impact from SEIR No. 340 – Project Impact Less Than Significant With Mitigation. Neither EIR No. 311 nor SEIR No. 340 addressed impacts related to conflicting or being inconsistent with CEQA Guidelines Section 15064.3, subdivision (b).

As previously discussed, EIR No. 311 and SEIR No. 340 analyzed transportation impacts on the basis of LOS. CEQA, including CEQA Guidelines Section 15064.3(b), now requires that transportation analysis be based on VMT. The City Council approved VMT as the basis for determining significant impacts under CEQA on June 23, 2020. This analysis, therefore, analyzes the effects of the Project based on City of Anaheim Traffic Impact Analysis Guidelines for CEQA Analysis, which describes the City’s approach to analyzing VMT. Under the City Guidelines, the VMT analysis must be conducted using the Orange County Transportation Analysis Model (OCTAM) to assess Project-generated VMT and the Project’s effect on VMT. The Project- generated VMT per service population is com pared against a threshold based on the County- wide VMT per service population. The Project’s effect on VMT is measured based on the City- wide VMT per service population, with and without the Project.

The City Guidelines identify two thresholds for identifying significant VMT impacts for a development project:

1. A project would result in a significant project-generated VMT impact if the baseline project generated or cumulative project-generated VMT per service population exceeds 15percent below the County of Orange baseline VMT per service population; or,

2. The project’s effect on VMT would be considered significant if the baseline or cumulative link-level boundary Citywide VMT per service population increases under the “plus project” condition compared to the “no project” condition.

Under Criteria 1, the Project-generated VMT per service population is estimated using the origin- destination (OD) Method, which uses the total VMT generated by the specific Traffic Analysis Zones (TAZs) encompassing the Project divided by the modified service population (MSP) for those TAZs. The County baseline VMT per service population is based on the total VMT generated by the entire County (encompassing all TAZs within the County) divided by the MSP for the County. The significance threshold is 85 percent of the County baseline VMT per MSP DisneylandForward
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(i.e., 15 percent less than the County VMT per MSP based on the existing “Baseline” scenario in Orange County Transportation Analysis Model [OCTAM]). If the Project-generated VMT per MSP would exceed that threshold, the Project would have a significant VMT impact under Criteria 1.

Under Criteria 2, the total City-wide VMT per MSP (encompassing all TAZs within the City) is calculated using the Boundary Method. The resulting VMT per MSP is compared between “plus Project” and “no Project” conditions under both baseline and cumulative OCTAM scenarios. If the “plus Project” condition would generate more VMT per MSP on a City-wide basis, the Project would have a significant VMT impact under Criteria 2.

Four scenarios were run in OCTAM (Baseline no Project, Baseline plus Project, Cumulative no Project, and Cumulative plus Project). VMT was calculated in two ways (the total VMT by TAZ used in Criteria 1 and the link-based VMT used in Criteria 2), and it was calculated for multiple geographic areas (County-wide and for the specific Project TAZs for Criteria 1 and Citywide for Criteria 2). The “no Project” scenarios were run without modifications to OCTAM and the “plus Project” scenarios included changes resulting from the Project.

The Project-specific changes made to OCTAM’s baseline included the following:
 Relocation of a portion of DRSP hotel rooms from the original Hotel District to the Southeast District and the portion of the Theme Park District along Ball Road;  Removal of planned future extension of Gene Autry Way to through traffic between Harbor Boulevard and Haster Street;
 Removal of planned future extension of Clementine Street to through traffic between Katella Avenue and Orangewood Avenue;
 Closure of Magic Way at Walnut Street; and
 Reduction on Disney Way between Harbor Boulevard and Anaheim Boulevard from six lanes to four lanes without changing the width of the public right-of-way (ROW).

Additionally, the traffic analysis calculated the MSP for each geographic area used in the analysis.

OCTAM provides the residential population and total employment for each TAZ, so the number of theme park visitors was separately estima ted. The employee and visitor patterns for theme park space at The Disneyland Resort are expected to be consistent regardless of the location of that space (i.e., space developed at one of the Theme Park Overlays would behave similarly to space developed in the Theme Park District). The EIR No. 311 included forecasts of daily theme park attendance with the buildout of theme park space permitted under the DRSP and, upon consultation with City staff, these estimates were determined appropriate for use. EIR No. 311 estimated 39,550 average daily theme park visitors during the shoulder season, which is a non- summer weekday as defined in the traffic study
supporting EIR No. 311, and 104,125 average
daily theme park visitors during peak season, which is a busy summer weekday. This analysis conservatively used the shoulder season estimate of 39,550 daily visitors in the calculation of the MSP as it produced a larger VMT per capita compared to peak season visitor assumptions.

Table 5.14-1, VMT Analysis – Criteria 1, Before Mitigation, summarizes the results of the VMT analysis using the OD Method and application of Criter ia 1, prior to mitigation. As shown, the County-wide VMT per MSP is 26.0 miles under OCTAM baseline conditions and 28.2 miles under OCTAM cumulative conditions. The impact thresholds, which are 15 percent below those levels, are 22.1 miles and 24.0 miles, respectively. The Project-generated VMT per MSP is 23.7 miles under baseline conditions and 25.1 miles under cumulative conditions. In both analysis periods, the Project- generated VMT per MSP would exceed the threshold of significance. Therefore, prior DisneylandForward
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to mitigation, the Project would result in a significant impact with respect to VMT under Criteria 1.

As shown, the Project VMT impact would exceed the threshold by approximately 7.2 percent under baseline conditions and 4.6 percent under cumulative conditions.

TABLE 5.14-1
VMT ANALYSIS – CRITERIA 1, BEFORE MITIGATION
Description
Baseline
[a]
Cumulative
[b]
County
Total VMT 150,035,379 171,690,341
Modified Service Population
Employees / Residents / Students
Theme Park Visitors
5,729,834
39,550
6,038,857
39,550
Total 5,769,384 6,078,407
VMT per Modified Service Population 26.0 28.2
Impact Threshold 22.1 24.0
Project, Before Mitigation
Total VMT 1,797,862 2,019,725
Modified Service Population
Employees / Residents / Students
Theme Park Visitors
36,344
39,550
40,886
39,550
Total 75,894 80,436
VMT per Modified Service Population 23.7 25.1
Significant Impact, Before Mitigation [c] YES YES
Amount Above Impact Threshold 7.2% 4.6%
Notes:
[a] Baseline condition is based on OCTAM's ex isting baseline (calibrated to year 2016). [b] Cumulative condition is based on OCTAM's future cumulative condition (estimated to year 2045). [c] A significant impact is identified if the Project-generated VMT per Modified Serv ice Population exceeds the impact threshold, which is 15% below the County-wide VMT per Modified Service Population.

Source: Gibson 2023a

Table 5.14-2, VMT Analysis – Criteria 2, Before Mitigation, summarizes the results of the VMT analysis using the Boundary Method and application of Criteria 2, prior to mitigation. The total VMT is the Citywide VMT as calculated using the Boundary Method. Because of the relocations of hotels and the changes to the roadway network, the total Citywide VMT is slightly changed by the Project. The MSP, however, does not change because those Project effects do not affect populations. As shown, the City-wide VMT per MSP is 11.52 miles under OCTAM baseline conditions and 11.40 miles under OCTAM cumulative conditions without the Project. With the Project, the City-wide VMT per MSP would increase to 11.55 miles under baseline conditions and decrease to 11.39 miles under cumulative conditions. Therefore, prior to mitigation, the Project would result in a significant impact with respect to VMT under Criteria 2 under baseline conditions because the Citywide VMT per MSP would increase by approximately 0.3 percent.

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TABLE 5.14-2
VMT ANALYSIS – CRITERIA 2, BEFORE MITIGATION
Description
Baseline
[a]
Cumulative
[b]
No Project Conditions
Citywide Total VMT 8,531,141 9,787,591
Modified Service Population
Employees / Residents / Students
Theme Park Visitors
700,784
39,550
818,683
39,550
Total 740,334 858,233
VMT per Modified Service Population 11.52 11.40
With Project Conditions, Before Mitigation
Citywide Total VMT 8,550,197 9,778,064
Modified Service Population
Employees / Residents / Students
Theme Park Visitors
700,784
39,550
818,683
39,550
Total 740,334 858,233
VMT per Modified Service Population 11.55 11.39
Significant Impact, Before Mitigation [c] YES NO
Amount Above Impact Threshold 0.3% n/a
Notes:
[a] Baseline condition is based on OCTAM's existing baseline (calibrated to year 2016). [b] Cumulative condition is based on OCTAM's future cumulative condition (estimated to year 2045). [c] A significant impact is identified if the VMT per Modified Service Population is greater with the Project than without the Project.

Source: Gibson 2023a

Based on the analyses above, summarized in Tables 5.14-1 and 5.14-2, the Project would result in a significant impact with respect to VMT under both Criteria 1 and Criteria 2. Under Criteria 1, the Project VMT per MSP would exceed the threshold by approximately 7.2 percent under baseline conditions and 4.6 percent under cumulative conditions. Under Criteria 2, the With Project Conditions Citywide VMT per MSP would increase by approximately 0.3 percent under baseline conditions. Accordingly, mitigation is required to reduce the VMT impacts below the applicable thresholds.

While OCTAM incorporates regional public transportation such as rail and major bus service into its transportation network and travel forecasts, it does not account for local Transportation Demand Management (TDM) measures or local bus and shuttle services. Rather, the trips estimated in OCTAM are based on a primarily automobile-centric region with no special considerations of existing or proposed programs to reduce trips. While most regional guest trips to and from The Disneyland Resort are made by passenger automobiles, many short-distance trips within The Disneyland Resort are made on foot or using one of the many local transit services in the vicinity. Additionally, Disney implemented and continues to operate a TDM program as MM TRA-8, which reduces many cast member trips to and from The Disneyland Resort.

Therefore, the VMT analysis and significant im pact conclusion presented above is highly conservative in that Disney’s on-going TDM efforts and other VMT-reducing Project features, described in detail below, reduce VMT per capita below the OCTAM estimations.

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Disney’s Transportation Demand Management (TDM) Program Disney’s current TDM program would continue to be implemented as MM TRA-8. Disney’s TDM program is designed to reduce VMT from cast members driving to and from The Disneyland Resort. Based on Disney’s annual report to the South Coast Air Quality Management District (SCAQMD), the following measures are currently in place:
 Bicycle Parking and Amenities: In addition to standard bicycle parking, The Disneyland Resort provides cast member bicycle amenities including secure bicycle storage lockers and bicycle service and repair areas, as well as discounts at local bicycle shops, to facilitate and encourage bicycle use;
 Online Ride-matching and Carpool/Vanpool Program: An online portal is available for Disney to relay commuter information, TDM measures, and programs that further reduce the number of vehicle trips to and from the area. The online portal also provides ride- matching services for cast members to organize carpools and vanpools and personalized transit routes and schedule information. Vanpool leasing programs are also available and financial subsidies are provided to participating cast members;  Guaranteed Return Trip: This program assures transportation service to individuals who commute without their personal automobiles. This program overcomes one of the primary objections of those who could choose alternative modes of transportation, which is how to get home or to a child’s school in case of an emergency. This program provides cast members with transportation to or from The Disneyland Resort in the event of a personal emergency, unplanned business-related activity, or inclement weather for cyclists and walkers. This support service is an important part of TDM implementation that assures individuals they will not be dependent on a ridesharing or transit schedule in the event of an emergency;
 Incentives for Using Alternative Travel Modes: The TDM program incorporates various incentives for use of alternative travel modes (e.g., transit, bus, walking, bicycling, carpool, vanpool, etc.) and other commuter programs. For example, eligible cast members are entered into prize drawings for participation in the employee commute reduction program and are also given direct financial awards for use of carpool or alternative travel mode. All eligible cast members are also offered an annual complimentary OCTA Perk Pass for transit service. Carpool and vanpool users are offered preferential parking locations;  Flex Schedule and Telecommuting : Flexible or alternative work schedules (e.g., 4-10 and 9-80 work schedules) are available to some cast members. Additionally, cast members who work in office settings have the option to work from home two days per week. These options reduce the number of workdays that cast members must travel to and from The Disneyland Resort, and thereby substantially reduce trips and VMT;  Electric Vehicle Parking and Incentives : Electric vehicle charging stations have been installed and increased as needed to meet growing demand. Additionally, Disney provides cast members with annual financial incentives toward the purchase or ownership of clean vehicles. While the use of electric vehicles does not reduce VMT, it does reduce greenhouse gas emissions, which is the underlying goal of reducing VMT under CEQA;  Shuttle Services: A backstage shuttle service is provided seven days a week with scheduled routes throughout the cast areas of The Disneyland Resort. This allows cast members to get from one area of The Disneyland Resort to another without using individual passenger vehicles; and
 Promotions, Marketing, and Education: A key component of a successful TDM program is to make employers and employees aware of the various programs and benefits offered.

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To raise awareness about the programs and incentives described above, Disney publishes quarterly newsletters and holds annual rideshare events and regular new hire orientations. These materials and events provide information about transit schedules, commute planning, rideshare services, telecommuting, and bicycle and pedestrian plans.

Other VMT-Reducing Project Features
In addition to MM TRA-8, various characteristics of the Project contribute to low average VMT per guest and were accounted for in assessing the effectiveness of Project mitigation measures.

Single-day guests who drive to The Disneyland Resort have a high average vehicle occupancy (AVO) (i.e., the number of people per car) – stated to be 4.0 in the EIR No. 311 – due to the large number of families visiting The Disneyland Resort. Additionally, many guests visit for multiple days, staying in nearby hotels. Combined entitlements associated with EIR No. 311 and SEIR No. 340 permit the development of up to 40,600 hotel rooms within The Anaheim Resort (approximately 18,000 are currently in operation) from which guests can get to The Disneyland Resort without needing a private automobile. These hotel guests generate minimal, if any, passenger vehicle trips to and from The Disneyland Resort. This is noted in MM TRA-8 which is derived from PDF 3.3-15 from EIR No. 311, which sets a target average length of stay for out-of- area guests of 1.72 nights for the purpose of reducing VMT. Based on data provided by Disney, the average length of stay within the three Disney-operated hotels is over 2.60 nights (both in 2019, prior to the COVID-19 pandemic, and in 2022), thus suggesting an even greater decrease in VMT.

The Disneyland Resort also provides infrastructure and proposes more improvements as part of the Project, which reduce guest VMT:
 East Esplanade Transportation Center: The East Esplanade transportation center, located on the west side of Harbor Boulevard between the guest entrances to The Disneyland Resort and Disney’s California Adventure theme parks, provides front-door passenger loading areas for ART buses, hotel shuttles, guest parking shuttles, and cast member parking shuttles. This space, provided free-of-charge, supports convenient non- automobile transportation to and from the existing Disney theme parks by many operators, collectively serving thousands of guests and cast members per day. The Project may relocate the transportation center to the DR SP Parking District East Parking Area or adjacent ARSP Parking Overlay in accordance with MM TRA-7 but would continue to provide direct pedestrian access between it and the theme parks via walkways and pedestrian bridges, described below; and
 Pedestrian Bridges: Disney has already constructed pedestrian bridges over Magic Way (between Downtown Disney and the Pixar Pals parking structure) and Disneyland Drive (connecting the two sides of Downtown Disney and providing pedestrian access to the theme park gates). The Project further proposes at least one and up to three pedestrian bridges over Harbor Boulevard north of Disney Way and south of Manchester Avenue, improving pedestrian connectivity and safety within The Disneyland Resort. The Project may also construct two additional pedestrian bridges over Disneyland Drive between Magic Way and Katella Avenue. These bridges provide safer and more efficient pedestrian flow around The Disneyland Resort and reduce VMT by reducing vehicle congestion (with fewer at-grade pedestrian conflicts), thereby promoting more direct vehicular travel routes.

VMT Reduction with Mitigation
As mitigation for the Project’s significant impact with respect to VMT, Disney would continue to operate its TDM program and continue to support local transit and mobility in the manner DisneylandForward
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summarized above. Further, the TDM measures would be extended, as applicable, to new developments within the Disney ARSP Properties. These measures have been shown to be effective at reducing VMT both in published technical studies as well as based on empirical data at The Disneyland Resort. Table 5.14-3, Effectiveness of Transportation Demand Management Measures, summarizes the range of effectiveness of the TDM measures employed as Project mitigation measures or project design features based on Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity:

Designed for Local Governments, Communities, and Project Developers (California Air Pollution Control Officers Association, December 2021) (CAPCOA Handbook). As shown, many of the measures employed by Disney have the potential, on their own, to reduce VMT by more than

7.2 percent.

TABLE 5.14-3

EFFECTIVENESS OF TRANSPORTATION DEMAND MANAGEMENT MEASURES

CAPCOA Code and Measure Name Measure Description
Range of
VMT
Reduction Project Support
Quantified GHG Reduction Measures
T-3 Provide Transit-Oriented
Development
Locate a project in a walkable
area with a mix of uses and
access to transit.

6.9 - 31.0%
Incorporation of the East
Esplanade transportation
center into the design of
The Disneyland Resort
a
T-6 Implement Commute Trip
Reduction Program with Mandatory
Implementation and Monitoring
Provide a combination of
measures T-7 through T-11
below with required annual
monitoring.
0 - 26%
b
The measures below, with
annual reporting to the
South Coast Air Quality
Management District
T-7 Implement Commute Trip
Reduction Marketing
Use marketing strategies,
promotions, and new
employee orientations to
encourage use of TDM
programs.
0 - 4%
Quarterly newsletters, new-
hire orientations, and
events and promotions
including financial
incentives
T-8 Provide Ridesharing Program
Promote ridesharing with
designated parking, loading
and unloading areas, and
offering ridematching
services
0 - 8%
Ridematching and
designated parking as well
as financial incentives
T-9 Implement Subsidized or
Discounted Transit Program
Provide subsidized daily or
monthly public transit passes
for employees.

0.0 - 5.5%
75% subsidy for cast
members commuting by
transit, up to $100 per
month
T-10 Provide End-of-Trip Bicycle
Facilities
Provide bicycle parking,
showers, and lockers for
employee use.

0.1 - 4.4%
Bicycle parking, including
secure bike storage
and repair services,
including bicycle parking
within the East Parking
Area
T-11 Provide Employer-Sponsored
Vanpool
Provide an employer-
sponsored commuter vanpool
service.

3.4 - 20.4%
Ridematching, financial
incentives, and vanpool
subsidies as well as
designated parking; also,
backstage cast member
shuttles to move around
the Project site
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TABLE 5.14-3

EFFECTIVENESS OF TRANSPORTATION DEMAND MANAGEMENT MEASURES CAPCOA Code and Measure Name Measure Description
Range of
VMT
Reduction Project Support
T-18 Provide Pedestrian Network
Improvements
Provide a pedestrian access
network linking areas of the
Project site to encourage
walking instead of driving.

0.0 - 6.4%
Pedestrian walkways and
bridges, existing and
proposed
Overall Range of VMT Reduction 6.9% - 20.0%c
Non-Quantified GHG Reduction Measures
T-32 Orient Project Toward Transit,
Bicycle, or Pedestrian Facility
Minimize distance between
the project and planned or
existing transit, bicycle, and
pedestrian corridors.

Incorporation of the East
Esplanade transportation
center into the design of
The Disneyland Resort
a
T-34 Provide Bike Parking
Provide short-term and long-
term bicycle parking facilities
for employees and visitors.

Bicycle parking, including
secure bike storage
and repair services,
including bicycle parking
within the East Parking
Area
T-39 Implement Preferential Parking
Permit Program
Provide reduced price or
preferentially located parking
for carpools, vanpools, and
rideshares.

Preferential vanpool
parking.

T-42 Implement Telecommute and/or
Alternative Work Schedule Program
Encourage telecommuting,
flexible schedules, and
alternative work schedules.

Office cast members may
work from home
two days per week.

Other Project Features that Could Reduce VMT
T-2 Increase Job Density
Increased employment
density results in shorter and
fewer trips by single-occupant
vehicles.

Project would increase
employee concentration in
The Anaheim Resort.

T-19A Construct or Improve Bike
Facility
Construct or improve a
bicycle lane that connects to
a larger bicycle network.

Project would construct
Class I Bike Paths on
Walnut Street, Disney Way,
and Clementine Street and
a bicycle parking area
within the East Parking
Area. Project would also
contribute right-of-way and
in-lieu payments
supporting installation of
bicycle lanes on Ball Road
and Haster Street adjacent
to the Project Site.

CAPCOA: California Air Pollution Control Officers Association.

a The Project may relocate the transportation center to t he East Parking Area and/or adjacent ARSP Parking Overlay on Manchester Avenue.
b This measure represents the cumulative maximum range of e ffectiveness of a combination of measures including T-7 through T-11. The individual ranges of effectiveness for those measures represent individual maximums, but when combined together they were found not to exceed the range of effectiveness of T-6 (26%). c The upper bound of VMT reduction is capped at 20% based on the maximum value for suburban centers identified in Quantifying Greenhouse Gas Mitigation Measures: A Resource fo r Local Government to Assess Emission Reductions from Greenhouse Gas Mitigation Measures (CAPCOA, 2010).

Source: Gibson 2023a

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An earlier CAPCOA publication, Quantifying Greenhouse Gas Mitigation Measures: A Resource for Local Government to Assess Emission Reductions from Greenhouse Gas Mitigation Measures (CAPCOA, August 2010), also provides guidance on maximum effectiveness of TDM programs when multiple measures are combined. The maximum value for effectiveness of transportation- based VMT reduction measures is based on research into maximum VMT reductions in different types of geographic settings. The Anaheim Resort area falls between a “compact infill” setting (defined as within the central city or inner-ring suburb with high-frequency transit service) and a “suburban center” setting (defined as a cluster of multi-use development within dispersed, low- density, automobile dependent land use patterns). The CAPCOA Handbook identifies a maximum 40 percent reduction for compact infill sites and 20 percent reduction for suburban center sites.

As shown in Table 5.14-3, conservatively assuming The Anaheim Resort area is a suburban center, the TDM program has the potential to reduce VMT between 6.9 percent and 20 percent.

Effectiveness of Disney’s TDM Program. Disney annually reports to the SCAQMD on the effectiveness of its TDM program for cast members at The Disneyland Resort. The report is based on a representative survey of cast members about their trip activity to and from The Disneyland Resort over a five-day period. Each cast member reported on their commute mode, including whether they carpooled, telecommuted, had the day off, etc. Based on the survey completed in year 2019 prior to the COVID-19 pandemic, approximately 77 percent of cast members drove alone to and from The Disneyland Resort during the morning and afternoon peak periods and the remaining 23 percent used alternative modes (including transit, walking or riding bicycles, carpool or vanpool) or telecommuted (less than 1 percent) resulting in an average of approximately 0.83 vehicle round trips per employee. Based on the most recent survey completed in 2022, which used data collected in April 2022, approximately 69 percent of cast members drove alone to and from The Disneyland Resort during the morning and afternoon peak periods and the remaining 31 percent used alternative modes or telecommuted, resulting in an average of approximately

0.74 vehicle round trips per employee. While transit and carpool/vanpool modes were down slightly, telecommuting was substantially increased to approximately 14 percent of workers, reflecting cast members taking advantage of work from home policies. A new policy allows office- based cast members to work from home two days per week and, therefore, it is anticipated that the majority of the increase in telecommuting will persist indefinitely. Regardless, based on both the year 2019 survey and the year 2022 survey, cast member trips (and, thus, VMT) were reduced by greater than the 7.2 percent needed to reduce the VMT impacts to a less-than significant level.

While guest trips are not included in the SCAQMD reporting, as described above, there is ample evidence that VMT per guest is substantially lower than VMT per MSP estimated in Tables 5.14-1 and 5.14-2. For one thing, there is a high average vehicle occupancy for guests traveling to and from The Disneyland Resort. For another, thousands of guests stay for multiple days at hotels in The Anaheim Resort, supported by the pedestrian and transit infrastructure in the area, especially those facilities installed by Disney. Guests staying at nearby hotels generate substantially less VMT per guest than those arriving from their residences or hotels throughout the broader region.

Based on the continued operation of Disney’s robust TDM program and design features within The Disneyland Resort and the information provided above, it is estimated that VMT would be reduced by at least 10 percent compared to a scenario in which those programs and features were not provided. This is supported by the estimates of TDM effectiveness from Table 5.14-3, whether or not including any effects of those measures not quantified by the CAPCOA Handbook.

Table 5.14-4, VMT Analysis – Criteria 1, After Mitigation, shows the VMT results after mitigation under Criteria 1.

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TABLE 5.14-4
VMT ANALYSIS – CRITERIA 1, AFTER MITIGATION
Description Baseline Cumulative
County VMT Impact Threshold [a] 22.1 24.0
Project VMT per Modified Service Population [a] 23.5 24.9 Significant Impact, Before Mitigation [a] YES YES
Amount Above Impact Threshold [a] 6.5% 3.9%
Estimated Mitigation Effectiveness 10%
Project VMT per Modified Service Population, After Mitigation 21.2 22.4 Significant Impact, After Mitigation NO NO
Notes:
[a] See Table 5.14-1.

Source: Gibson 2023a

As shown, with the 10 percent reduction in Project-related VMT, the baseline Project VMT per MSP would be reduced to 21.2 miles, which is less than the baseline impact threshold of 22.1 miles. The cumulative Project VMT per MSP would be reduced to 22.4 miles, which is less than the cumulative impact threshold of 24.9 miles. Therefore, the identified VMT impact under Criteria 1 would be reduced to a less-than-significant level. Table 5.14-5, VMT Analysis – Criteria 2, After Mitigation, shows the VMT results after mitigation under Criteria 2.

TABLE 5.14-5
VMT ANALYSIS – CRITERIA 2, AFTER MITIGATION
Description
Baseline
[a]
Cumulative
[b]
No Project Conditions [c]
Citywide Total VMT 8,531,141 9,787,591
Modified Service Population 740,334 858,233
VMT per Modified Service Population 11.52 11.40
Mitigation Effectiveness
Project-Only VMT, Before Mitigation [d] 1,797,862 2,019,725 Estimated Mitigation Effectiveness 10% 10%
Project VMT Reduction due to Mitigation (179,786) (201,973) With Project Conditions, After Mitigation
Citywide Total VMT, Before Mitigation [c] 8,550,197 9,778,064 Project VMT Reduction due to Mitigation (179,786) (201,973) Citywide Total VMT, After Mitigation 8,370,411 9,576,091 Modified Service Population 740,334 858,233
VMT per Modified Service Population 11.31 11.16
Significant Impact, After Mitigation [e] NO NO
Notes:
[a] Baseline condition is based on OCTAM's ex isting baseline (calibrated to year 2016). [b] Cumulative condition is based on OCTAM's future cumulative condition (estimated to year 2045). [c] See Table 5.14-2.

Source: Gibson 2023a

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As shown, the 10 percent reduction in Projec t-related VMT would reduce the Citywide VMT per MSP to 11.31 miles under baseline conditions, whic h is less than the baseline impact threshold of 11.52 miles. Therefore, the identified VMT impact under Criteria 2 would also be reduced to a less-than-significant level.

The Project’s VMT analysis found that the Project would generate VMT in exceedance of the City’s thresholds of significance for VMT. Therefore, prior to mitigation, the Project would result in a significant impact related to VMT. With implementation of MM TRA-3, MM TRA-6, MM TRA-7, MM TRA-8, and MM TRA-9, which include parking facilities design, a guest transportation system, theme park drop-off areas, continued implementation of Disney’s existing Transportation Demand Management (TDM) program, and support for existi ng transit programs, the Project’s impact related to VMT would be reduced to less than significant levels.

The Project would result in a less than significant impact with mitigation. This impact would be new when compared with the impact analyses in EIR No. 311 and SEIR No. 340, neither of which addressed CEQA Guidelines Section 15064.3, subdivision (b).

Threshold 5.14c Would the project substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses?
New Impact from EIR No. 311; No New Impact from SEIR No. 340 – Project Impact Less Than Significant With Mitigation. EIR No. 311 did not directly address impacts related to hazards. According to Section 2.4.2, Effects Found Not to be Significant, in SEIR No. 340, buildout of the ARSP would not result in a significant impact related to increasing hazards; a detailed analysis was not prepared.

The Project would have many access points spread throughout the Project Site, including to and from arterial streets such as Ball Road, Disneyland Drive, Katella Avenue, Harbor Boulevard, and Haster Street. As discussed in the Operation Traffic Analysis, Appendix J-2, the existing driveway on Haster Street to the Southeast District would be equipped with a traffic signal, subject to a technical study proving the signal would meet warrants, as would the intersection of Manchester Avenue/Clementine Street and Alro Way. Additionally, the Project would develop new transportation infrastructure including internal roadways, pedestrian bridges, and, potentially, vehicular flyovers (e.g., to provide direct access to the DRSP Parking District East Parking Area from Disney Way). These access points and infrastructure improvements have not been designed in detail, but such features were originally contemplated in EIR No. 311 and continue to be proposed as features of the Project.

All proposed improvements and features of the Project would be designed and developed in compliance with City standards from the Building Division, Public Works, and the Fire & Rescue Department and would be reviewed and approved by City staff. The designs would not result in hazardous conditions due to geometric configuration. The Project is a destination resort with retail, dining, entertainment, theme park, and hotel uses and is located in a specially designated resort district within the City and, therefore, it is compatible with surrounding land uses.

Implementation of MMsTRA-4, MM TRA-5, MM TRA-12, MM TRA-13, MM TRA-14, MM TRA-16, MM TRA-17 , MM TRA-18 , MM TRA-19 , MM TRA-20 , MM TRA-21 , and MM TRA-22 would reduce potential impacts related to increased hazards due to geometric designs or incompatible adjacent land uses to less than significant with mitigation.

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The Project would result in a less than significant impact with mitigation. This impact would be new when compared with the impact analysis in EIR No. 311. This impact would not be new or substantially more severe when compared with the impact analysis in SEIR No. 340.

Threshold 5.14d Would the project result in inadequate emergency access? New Impact from EIR No. 311; No New Impact from SEIR No. 340 – Project Impact Less Than Significant With Mitigation. EIR No. 311 did not directly addressed impacts related to emergency access. According to Section 2.4.2, Effects Found Not to be Significant, in SEIR No. 340, buildout of the ARSP would not result in a significant impact related to inadequate emergency access; a detailed analysis was not prepared.

All Project access points and infrastructure improvements would be designed and developed in compliance with City standards from the Planning and Building, Public Works, and the Fire & Rescue Departments. All designated fire lanes would meet requirements and would be reviewed and approved by the Fire & Rescue Department prior to issuance of a building permit.

The Project’s closure of Magic Way to public through traffic would not impede emergency access.

Emergency vehicle access to uses within The Disneyland Resort would be maintained to the satisfaction of the City, including emer gency vehicle access at Magic Way. Temporary construction activities are not expected to result in the full closure of any public streets and, thus, public routes for emergency response would be maintained during construction to the satisfaction of the City. As discussed in Section 5.13, Public Services, of this Draft Subsequent EIR, development of the Project would allow for future development of land uses in different locations and configurations within the Project Site, which has the potential to alter existing access routes.

However, implementation of MM TRA-10 regarding use of Anaheim Police Department or Anaheim TMC personnel during construction and MM PS-3 , MM PS-4 , MM PS-6 , MM PS-7 , MM PS-9, MM PS-20 , MM PS-11 , MM PS-12 , MM PS-19 , MM PS-22 , and MM PS-23 would address potential impacts related to emergency access, reducing potential impacts to less than significant.

The Project would result in a less than significant impact with mitigation. This impact would be new when compared with the impact analysis in EIR No. 311. This impact would not be new or substantially more severe when compared with the impact analysis in SEIR No. 340.

5.14.4 CUMULATIVE IMPACTS
According to EIR No. 311, The Disneyland Resort would not result in significant cumulative impacts on intersections, street segments, freeways, or freeway ramps with implementation of mitigation. Additionally, EIR No. 311 identified a less than significant impact related to plan incompatibilities and a beneficial cumulative effect associated with transit services. According to SEIR No. 340, buildout of the ARSP would contribute to a significant and unavoidable cumulative impact related to operation of several area intersections, arterial roadways, and freeway ramps, mainlines and weaving areas. However, as discussed above, EIR No. 311 and SEIR No. 340 used an LOS analysis and not the VMT analysis now required by CEQA.

In addition to potential Project-specific impacts, the Project must be reviewed in combination with nearby development projects to determine if t here may be a cumulatively significant impact resulting from inconsistency with a particular program, plan, policy, or ordinance. There are a number of proposed, approved, or under-construction development projects within the Project area, as detailed in Table 4-1 of Section 4, Environmental Setting, most of which are hotels.

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Each of the other developments considered in this cumulative analysis of consistency with programs, plans, policies, and ordinances was, or would be, separately reviewed and approved by the City, including a check for their consistency with applicable policies. Considered cumulatively, the addition of new hotels within the ARSP provides more capacity for Disney theme park guests to stay within walking distance of The Disneyland Resort. Most of the hotels are on ART routes that provide service directly to the East Esplanade. Therefore, the addition of new hotels and related amenities (i.e., in-hotel retail and restaurant space) within the Project area would help to reduce auto trips to and from The Disneyland Resort and Disney ARSP Properties, supporting many of the programs, plans, policies, and ordinances summarized above. The Project’s effect on cumulative conditions is limited because it does not substantially change land use or public facilities plans compared to the current DRSP and ARSP. The VMT analysis provided in Section 5.14b includes analysis of cumulative conditions, and determined the Project, with implementation of mitigation, would not create a cumulatively considerable impact. Further, the Project’s effect on traffic circulation is limited because, even with potential development of theme park space in the Theme Park Overlays, theme park guest parking would still be concentrated at the West Parking Area and East Parking Area, as in the current DRSP. Therefore, with implementation of mitigation measures, MM TRA-1 through MM TRA-22 and MM PS-3, MM PS-4, MM PS-6, MM PS-7, MM PS-9, MM PS-20, MM PS-11, MM PS-12, MM PS-19, MM PS- 22, and MM PS-23, detailed above, the Project, together with nearby development projects, would not create inconsistencies nor result in cumulative impacts with respect to the identified programs, plans, policies, and ordinances.

The Project would result in a less than significant cumulative impact with mitigation.

Because neither EIR No. 311 nor SEIR No. 340 evaluated impacts related to VMT which is a key component in the analysis presented above, this impact would be new when compared with the impact analyses in EIR No. 311 and SEIR No. 340.

5.14.5 MITIGATION PROGRAM
Mitigation Measures
EIR No. 311 and SEIR No. 340 presented MMs and PDFs to reduce potential impacts associated with The Disneyland Resort Project and the Anaheim Resort Specific Plan Project, respectively.

As appropriate, the measure number and section from EIR No. 311 and/or SEIR No. 340 are listed in parentheses. Modifications to the original measure are shown as strikethrough for deleted text and bold for new, inserted text.

MM TRA-1 Prior to issuance of each building permit, appropriate traffic signal assessment fees shall be paid by the property owner/developer to the City of Anaheim in amounts determined by the City Council Resolution in effect at the time of issuance of the building permit or credit given for City-authorized improvements. Ongoing during project development and operations, the property owner/developer shall implement the improvements and pay in lieu fees described in Table 19 (Recommended Intersection Improvements) and Table 20 (Other Transportation Improvements) of the Operational Traffic Analysis for the DisneylandForward Project (Gibson 2023), as set forth in Appendix J-2 of Subsequent EIR No. 352, within the time frames described in those tables .

Prior to the issuance of each building permit, any remaining applicable Traffic Signal Assessment Fees and Transportation Impact and Improvement Fees (Fees) relating to the building permit site shall be paid by the property owner/developer to the City of Anaheim in the amounts determined by the City Council Resolution in effect at the time of issuance of the building permit, except to the extent such fees may have been DisneylandForward
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previously paid or satisfied pursuant to one or more separate agreements between Walt Disney Parks and Resorts U.S., Inc. and the City of Anaheim relating to The Disneyland Resort Project or The DisneylandForward Project. (SEIR No. 340, MM 5.14-2)
MM TRA-2 Within 120 days of acquiring properties adjacent to arterial highways/street intersection half sections included in (3.3-3A), if, after the initial dedications, any additional parcels are acquired by the applicant adjacent to the arterial highway/street intersection half-sections included in (MM 3.3-3A), the applicant shall notify the City in writing of said acquisition and the ultimate rights-of-way for said properties shall be irrevocably offered for dedication to the City of Anaheim.

Prior to approval of the first final subdivision map or issuance of the first building permit, whichever occurs first, or as otherwise established in Development Agreement between the City of Anaheim and Walt Disney Parks and Resorts U.S., Inc. or as approved pursuant to a Discretionary Exemption to establish the timing of Street and Other Right-of-Way Dedications and Improvements (Anaheim Municipal Code Section 18.40.060 Dedications and Improvements), the property owner/developer shall irrevocably offer for dedication (with subordination of easements), including necessary construction easements, the ultimate arterial highway right(s)-of-way adjacent to their property as shown in the Circulation Element of the Anaheim General Plan. (EIR No. 311, MM 3.3-3B; SEIR No. 340, MM 5.14-3)
MM TRA-3 Prior to demolition of the an existing Disneyland Resort parking lot, replacement parking for the existing Disneyland Theme Park parking spaces removed will be constructed or secured.; prior to final building and zoning inspections for the second theme park, the west parking area will be constructed,
Access Improvements and Public Parking Facilities Included in Project Design (Exhibit 4.3.1b – Interstate 5-West Street/Disneyland Drive Interchange (Showing Entrance to West Parking Facility) and Exhibit

4.3.1c – Interstate 5/Katella Interchange (Showing Entrance to East Parking Facility) (Exhibits 3.2-2 and 3.2-3)
Public Parking Facilities. New public parking facilities will be constructed at opposite sides of The Disneyland Resort Specific Plan area to receive traffic from the I-5. At Phase II, Code required parking will be provided. At buildout of Phase IIIOngoing during project operation , a minimum of 24,500 guest and cast parking spaces will be provided. The West Parking Area iswill be oriented to receive southbound I-5 traffic, and the parking facilities in the southern areas of the Theme Park and Hotel Districts and/or East Parking Area and adjacent ARSP Parking Overlay will be oriented to receive northbound I-5 traffic. (EIR No. 311, PDF 3.3-1)
MM TRA-4 To be shown on street improvement plans ; to be implemented prior to final building and zoning inspections for each the east and west parking structures/facilities
Improved Access. Access roads leading up to the parking facilities shall be sized to accommodate traffic at peak hours, thereby substantially reducing the likelihood of backups onto City streets and freeway ramps , subject to the approval of the City Engineer.

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Guest vehicles will enter and exit the West Parking Area via the proposed extension of West Street/Disneyland Drive. Cast access will enter and exit either at West Street/Disneyland Drive or via a single access on Cerritos Avenue with right-turn in and left-turn out only. No cast or guest access or egress will occur from Walnut Street. (EIR No. 311, PDF 3.3-2) MM TRA-5 Prior to issuance of each building permit; to be implemented prior to final building and zoning inspections for both the east and west parking structures, Speed Parking. Building plans shall show direct ramps to each level of the East and West Parking Area facilities to minimize internal circulation within the garages and accommodate the project's "speed parking" operation. (EIR No. 311, PDF 3.3-3)
MM TRA-6 To be shown on street improvement plans; to be implemented prior to final building and zoning inspection for each parking structure and/or facility, Conveyance Systems . In addition to an extensive network of landscaped pedestrian thoroughfares, conveyance systems will transport Disneyland Resort guests around the projectThe Anaheim Resort. Guest transportation systems will move guests from the parking facilities to the Theme Park District. The monorail/guest transportation systems shall move guests from the Hotel District to within the Theme Park District. Future connections may also be provided to the Future Expansion Southeast District. (EIR No. 311, PDF 3.3-4) MM TRA-7 To be shown on street improvement plans; to be implemented prior to final building and zoning inspections for the second theme park for Phase II; and if pursued, to be implemented prior to final building and zoning inspections for the east public East Parking Area or adjacent ARSP Parking Overlay parking structure(s) or other accessible location in Phase IIIIV,
Theme Park Drop-Off Area . To provide access to the attractions in the Specific Plan area to people staying outside of The Disneyland Resort area, a bus and shuttle drop-off area will be located adjacent to Harbor Boulevard north of Freedman Disney Way in Phase II as shown on Exhibit 4.4.2a of the Specific Plan; or, in Phase IIIIV, the facility may be located adjacent or internal to the East Public Parking StructureParking Area or the adjacent ARSP Parking Overlay Parking Structure(s), or other accessible location in the Theme Park or Hotel Districts. The types of vehicles served at this facility may include public and private passenger shuttles and buses. (EIR No. 311, PDF 3.3-5; SEIR No. 340, MM 5.14-20) MM TRA-8 Transportation Demand Management Program
Prior to final building and zoning inspection for the Second Theme Park; and, oOn-going during project operation, the need to minimize cast vehicle trips to reduce congestion and improve air quality, consistent with the goals of both the Air Quality Management Plan (AQMP) of t he South Coast Air Quality Management District (SCAQMD) and with the Regional Mobility Plan of the Southern California Association of Governments (SCAG), is recognized. The Disneyland Resort will implement and administer a comprehensive Transportation Demand Management (TDM) program for all cast, which will strive to achieve an average vehicle ridership (AVR) goal of 1.5 persons per vehicle and, an average length of out-of-area guest stay of 1.72 days, by 2001.

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At this point in project development, it is not possible to predict precisely which programs and activities would be most successful for t The Disneyland Resort in meeting these goals. In addition, applicant property owner/developer will review annually with the City any changes to the TDM Program and the Program's effectiveness toward achieving a 1.5 AVR. In consultation with the SCAQMD, the City of Anaheim and other agencies, and after analyzing the effectiveness of these items, The Walt Disney Company Walt Disney Parks and Resorts U.S., Inc. will select specific programs for implementation.

Objectives of the TDM program are:
 Increase ridesharing and use of alternative transportation modes by guests .  Meet the cast 1.5 AVR target .
 Provide a menu of commute alternatives for t The Disneyland Resort cast, to reduce project-generated trips.
 Provide transportation "linkages" to existing and future transportation modes (other than single-occupant vehicle travel) for both t The Disneyland Resort cast and guests.

Implementation strategies and elements of the TDM program for cast and guest trips are described below.

Cast
Making a commitment to commute management and trip reduction will become an integral part of the new-hire training. A menu of TDM program strategies and elements for both, existing and future cast commute options would be examined, including, but not limited to, the following
:
 Onsite Service. Onsite services, such as the food, retail, and other services may be provided to the cast.
 Ridesharing. An online computer listing of all cast members living in proximity to The Disneyland Resort may be developed for the purpose of providing a "matching" of members with other cast members who live in the same geographic areas and who could rideshare to tThe Disneyland Resort.  Vanpooling. An online computer listing of all cast members living in proximity to The Disneyland Resort may be developed for the purpose of matching numbers of cast who live in geographic proximity to one another and could comprise a vanpool to tThe Disneyland Resort.
 Transit Pass. Southern California Rapid Transit District and Orange County Transportation Authority (including commuter rail) passes may be promoted through financial assistance and onsite sales to encourage cast to use the various transit and bus services to tThe Disneyland Resort from throughout the region.
 Commuter Bus. As commuter "express" bus service expands throughout the region, passes for use on these lines may be provided for cast members who choose to use this service. Financial incentives will be provided.

 Shuttle Service. A computer listing of all cast members living in proximity to tThe Disneyland Resort may be generated, and a local shuttle program will be offered to encourage cast members to travel to work by means other than the automobile.

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 Bicycling. A Disneyland Resort Bicycling Program may be developed to offer a bicycling alternative to cast members. Secure bicycle racks, lockers, and showers will be provided as part of this program. Maps of bicycle routes throughout the area would be provided to inform potential bicyclists of these options.

 Rental Car Fleet. A "fleet vehicle" program may be developed to provide cast members who travel to work by means other than an automobile with access to automobiles in case of emergency, medical appointments, etc. This service would help cast members use alternative modes of transportation by ensuring that they would be able to have personal transportation in the event of special circumstances.
 Guaranteed Emergency Ride Home Program. The program may provide cast members who rideshare, or use transit or other means of commuting to work, with a prearranged ride home in a taxi, rental car, shuttle, or other vehicle, in the event of emergencies during the work shift. In essence, this program addresses the concerns of the cast member who rideshares and might be stranded without a vehicle in the event of an emergency.  Local Hiring Efforts. Continue to actively recruit prospective employees within 20 miles.
 Housing Coordinator and Referral Program and Local Hiring Efforts .

Continue to provide referral service to facilitate employees in finding housing and actively recruit prospective employees residing within 30-minute commute shed.
 Target Reduction of Longest Commute Trip. Design an incentives program for ridesharing and other alternative transportation modes to put highest priority on reduction of longest employee commute trips.
 Work Schedule
 Staggered Shifts. The Disneyland Resort cast may work different hours throughout the daily hours of park operation. A thorough review of cast shifts would be undertaken to provide the potential for cast shifts during nonpeak travel times, thus lessening peak hour congestion.  Compressed Work Week. The Disneyland Resort may review the possibility of developing a "compressed work week" program, which provides for fewer work days but longer daily shifts, as an option for cast members. This program would help eliminate certain trips on certain days that would otherwise be generated daily by tThe Disneyland Resort Cast.  Telecommuting. The Disneyland Resort employs cast members in a wide a variety of jobs including clerical, administrative and professional roles. Sometimes that work can be completed at home.

Telecommuting will be encouraged on a limited basis as operational needs allow. cast in different positions, cast members include clerical, office support, and administrative members. The Disneyland Resort may explore the possibility of a "telecommuting" program that would link some of these cast members to The Disneyland Resort via electronic means (e.g., computer with modem). This would help to eliminate certain trips that would otherwise be generated by a cast member who would otherwise physically need to be at the Disneyland Resort.

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 Work Environment/Facility Management
 Parking Management. The Disneyland Resort may develop a parking management program that provides incentives to those who rideshare or use transit means other than single-occupant auto to travel to work.  Management Staff. The existing Disneyland theme park transportation management staff may be expanded onsite to accommodate new employees and to explore relationships with adjacent employers to determine whether joint efforts can lead to greater reductions in VMT by Disneyland Resort cast members and other project employees in the Anaheim Resort.
 Amenities. Transit systems, transit shelters, bicycle storage areas, and other amenities may be provided with efficient parking management for cast and guests.
 Access. Preferential access to high occupancy vehicles and shuttles may be provided.
 Delivery Management. Schedule deliveries in nonpeak traffic congestion hours to the extent reasonably practicable.
 Financial Incentives
In addition to the above items, certain financial incentives will be integrated into The Disneyland Resort TDM program, such as:
 Financial Incentive for Ridesharing and/or Public Transit. Currently, federal law provides tax-free status for up to $60 $300 per month per employee contributions to employees who vanpool or use public transit (including commuter rail and/or express bus pools). In addition, The Disneyland Resort provides free OCTA passes and a 75% subsidy (up to $100/month) for other transit passes.

 Financial Incentive for Bicycling and Walking. Cast members may be offered financial incentives for bicycling to work; they would be provided with secure bicycle racks, lockers, and showers. Cast members may also receive a cash incentive for reporting a bike or walk commute.

 Financial Incentive for Carpooling. Cast members may be offered a cash incentive for carpooling to work.
 Special “Premium" for the Participation and Promotion of Trip Reduction. Tickets/passes to project theme parks and/or vacations could be offered to employees who recruit other cast members for vanpool, carpool, or other Disney trip reduction programs.

 Delivery Management. Schedule deliveries in non- peak traffic congestion hours to the extent reasonably practicable.
 Guests
- Even though visitors to The Disneyland Resort are estimated to average nearly four persons per vehicle, additional programs and incentives could and will be provided to encourage even more guest use of ridesharing, transit, and other modes of travel to and from tT he Disneyland Resort. The applicant property owner/developer is currently developing a list of potential programs and is working with the City of Anaheim and OCTA on DisneylandForward
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the provision of convenient linkages to other modes of transportation.

Marketing materials for tThe Disneyland Resort will describe it as an "auto- free" zone with a range of transportation amenities where cars are not needed.
- Bicycle spaces for guests shall be visible from the primary entrance, illuminated at night, and protected from damage from moving or parked vehicles.
 Construction Contractors

The property owner/developer shall provide notification to the general construction contractors regarding the coordination of rideshare services for construction employees provided by the Anaheim Transportation Network (ATN). (EIR No. 311, PDF 3.3-15; SEIR No. 340, MM 5.14-5, MM 5.14-6, MM 5.14-8, MM 5.14-9, and MM 5.14-23) MM TRA-9 Ongoing during project operations, the property owner/developer shall continue to participate in a clean fuel shuttle program such as the Anaheim Resort Transportation (ART) system, and shall participate in the Anaheim Transportation Network (ATN) in conjunction with the ongoing operation of The Disneyland Resort, including the Disney ARSP Properties. Proof of compliance with this measure shall be submitted to the City Traffic Engineer.

Prior to the issuance of the first building permit, the property owner shall join and financially participate in a clean fuel shuttle program such as the Anaheim Resort Transportation (ART) system, and shall participate in the Anaheim Transportation Network (ATN) in conjunction with the on-going operation of the project. Proof of compliance with this requirement shall be submitted by the Anaheim Transportation Network to the City Traffic Engineer. The property owner shall also record a covenant on the property that requires participation in these programs ongoing during project operation. The form of the covenant shall be approved by the City Attorney’s Office prior to recordation. Proof of compliance with this requirement shall be the submittal of a copy of the recorded covenant to the City Traffic Engineer. (EIR No. 311, PDF 3.3-17; SEIR No. 340, MM 5.14-4) MM TRA-10 Ongoing during construction, if Anaheim Police Department or Anaheim TMC personnel are required to provide temporary traffic control services, the property owner/developer shall reimburse the City, on a fairshare basis, if applicable, for reasonable costs associated with such services. (EIR No. 311, MM 3.8-11; SEIR No. 340, MM 5.14-7)
MM TRA-11 Prior to issuance of the first demolition, grading or building permit for Phase II, whichever occurs first, excluding permits for relocation of the SCE transmission lines, or for demolition related to relocation of the SCE transmission lines as specified in the Phasing Plan, Ongoing during project operations, the applicant property owner/developer will establish an onsite public information office (which is conveniently and accessibly located) where construction scheduling and phasing information will be available to the public. The public information office shall be open during construction hours. A telephone "hotline" will be provided to the community to allow members of the public to call the office with questions or comments during business hours. At least one liaison officer will be staffed at the office. The liaison officer shall be available to answer questions from the public and shall coordinate with the City of Anaheim, other public agencies, and major DisneylandForward
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developers in the area regarding the coordination of construction activities and infrastructure improvements. The City shall be provided with a monthly summary of the calls received and follow-up actions. (EIR No. 311, MM 3.8-12) MM TRA-12 Prior to issuance of each building permit for The Disneyland Resort or, any other timing specifically provided in this meas ure, excluding the relocation of SCE Transmission lines or the Disneyland Administration Building, the applicant property owner/developer shall submit a Traffic Mitigation and Construction Phasing and Control Plan. To the extent needed, as determined by the Public Works Department, the following project design features (PDF 3.8-1 - 3.8-8) require the applicant to submit at different times the plans for construction of both Phase II and Phase III development. Tthe Traffic Mitigation and Construction Phasing and Control Plan shall identify the following:
b. A Construction Staging Area Plan showing the location and size of the construction staging area. The Plan shall also show how the staging area will be screened from view in compliance with the City of Anaheim Municipal Code. (EIR No. 311, PDF 3.8-1)
MM TRA-13 Prior to approval of each grading plan or issuance of each demolition or building permit, whichever occurs first; implemented during grading and construction, a Truck Route Plan identifying truck routes along arterials, avoiding residential areas to the extent feasible and in compliance with the Sound Pressure Level Ordinance.

The Plan shall show conformance with the external noise limits for construction between 7 p.m. and 7 a.m. The Plan shall also prohibit construction traffic on residential streets where improvements are not planned and shall provide measures to ensure that truck drivers are directed away from residential streets and travel on approved routes only. Measures to assist in guiding truck movement on the arterial roadway system include, but are not limited to, provision of truck route maps to truck drivers and placement of flagpersons and construction signage at appropriate locations. The Truck Route Plan shall provide for monitoring of street conditions and potential repairing and/or repaving by property owner/developer after completion of construction as required by the City Engineer. (EIR No. 311, PDF 3.8-3)
MM TRA-14 Prior to approval of each grading plan or issuance of each demolition or building permit, whichever occurs first; implemented during grading and construction, a Construction Traffic Management Plan which includes mechanisms to reduce construction-related traffic congestion which shall be implemented during grading and construction, including, but not limited to, the following:

1. Configure construction parking to minimize onsite and offsite traffic interference.

2. Minimize obstruction of through-traffic lanes.

3. Provide flagpersons to guide traffic, as determined in the plan. (EIR No. 311, PDF 3.8-4)
MM TRA-15 Prior to approval of each grading plan or issuance of each demolition or building permit, whichever occurs first; implemented during construction, for Phase II and III Southwest Parking Facility, a Trip Reduction Plan (excluding the demolition for or relocation of the SCE transmission lines) for construction crew vehicles shall be prepared to reduce potential vehicle trips on the road and identify DisneylandForward
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parking locations for construction employees and equipment. (EIR No. 311, PDF 3.8-5)
MM TRA-16 Prior to approval of each building permit, a Traffic Management Plan for phasing of roadway improvements, specifying the sequencing of construction to do the following:

1. Coordinate scheduling with other planned construction in the area, including the I-5 widening project.

2. Coordinate scheduling with other infrastructure improvements to allow them to be facilitated efficiently during roadway improvements, such as sewer, storm drain, and water line improvements.

3. Outline procedures for any required traffic detours during construction, including provision of tour bus stops.

4. Phase each roadway improvement to allow access to all existing businesses/residential areas. In some instances this will require lane-by-lane renovation, temporary bypass roads, or traffic reroutes.

5. Employ vertical shoring as often as possible. This will minimize the amount of road surface that will be disturbed at a given location.

6. Sequence the construction of each roadway improvement to minimize disruption to residents and businesses.

7. Establish offsite parking and staging areas, where practical and possible, to minimize the impact to existing level of service on adjacent roadways. These offsite parking and staging areas will allow a dispersion of traffic flow to noncritical areas and will encourage bussing of construction workers from the offsite areas to the construction sites.

8. Identify how the project improvement construction schedules and haul routes will be coordinated with other areawide improvements. The applicant property owner/developer shall coordinate with the City of Anaheim Traffic Management Center (TMC), the Anaheim Convention Center and area hotels to ensure continued operations of these facilities, as well as the continued operation of the existing Disneyland theme park and Disneyland Hotel The Disneyland Resort. (EIR No. 311, PDF 3.8-6 and PDF 3.8-8) MM TRA-17 Ongoing during project construction, the applicant property owner/developer shall submit a quarterly update report show ing construction activities for the upcoming quarter which shall include traffic mitigation and control planning and construction scheduling. (EIR No. 311, PDF 3.8-9)
MM TRA-18 Prior to approval of each grading plan the applicant property owner/developer shall show how the project will be in compliance with the Traffic Mitigation and Construction Phasing and Control Plan. (EIR No. 311, PDF 3.8-11) MM TRA-19 Prior to the issuance of the first building permit, the location of any proposed gates across a driveway shall be subject to the review and approval of the City Engineer.

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MM TRA-20 Prior to the issuance of building permits, plans shall show that all driveways shall be constructed with a minimum fifteen (15) foot radius curb returns as required by the City Engineer, unless otherwise approved by the City Engineer. (SEIR No. 340, MM 5.14-13)
MM TRA-21 Prior to the issuance of building permits or final map approval, whichever occurs first, security in the form of a bond, certificate of deposit, letter of credit, completion guarantee, or cash, in an amount and form satisfactory to the City Engineer shall be posted with the City to guarantee the satisfactory completion of all engineering requirements of the City of Anaheim, including preparation of improvement plans and installation of all improvements, such as curbs and gutters, sidewalks, water facilities, street grading and pavement, sewer and drainage facilities and other appurtenant work, as required by the City Engineer and in accordance with the specifications on file in the office of the City Engineer, as may be modified by the City Engineer. Installation of said improvements shall occur prior to final building and zoning inspections. (SEIR No. 340, MM 5.14-14)
MM TRA-22 Prior to approval of each tentative tract or parcel map, the following Street Design Elements shall be shown on each tentative tract or parcel map:
a. Street cross-sections, including dimensions, labels, circulation designation (i.e., Resort Secondary) and whether public or private. b. Street grades and vertical alignment.
c. Horizontal alignment, including radii, and cul-de-sac radii. (SEIR No. 340, MM 5.14-10)
MM PS-3 Prior to approval of each grading plan, the property owner/developer shall submit an emergency fire access plan to ensure that service to the site is in accordance with the Fire Department service requirements. (EIR No. 311, MM 3.10.1-3; SEIR No. 340, MM 5.12-6)
MM PS-4 Prior to issuance of each building permit, the property owner/developer shall submit a Construction Fire Protection Plan which shall include detailed design plans for accessibility of emergency fire equipment, fire hydrant location, and any other construction features required by the Fire Marshal. The property owner/developer shall be responsible for securing facilities acceptable to the Fire Department and hydrants shall be operational with required fire flow. A construction plan providing a complete timeline and construction goals shall be provided and approved by the Fire Department for all new construction projects. (EIR No. 311, MM 3.10.1-4; SEIR No. 340, MM 5.12-11)
MM PS-6 Prior to issuance of each building permit, plans shall be submitted to ensure that development is in accordance with the City of Anaheim Fire Department Standards, including:
a. Overhead clearance shall not be less than 14 feet for the full minimum width of 26 feet for all designated fire access roads.
b. All fire access roads, bBridges and underground structures to be used for Fire Department access shall be designed to support Fire Department vehicles weighing 78,000 75,000 pounds.

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c. All underground tunnels shall have sprinklers. Water supplies (hydrants) are required at the entrances. Standpipes shall also be provided when determined to be necessary by the Fire Department.
d. Adequate off-site public fire hydrants contiguous to the Specific Plan area and onsite private fire hydrants shall be provided by the property owner/developer.

The precise number, types, and locations of the hydrants shall be determined during building permit review. Hydrants are to be a maximum of 300 400 feet apart.
e. A minimum residual water pressure of 20 psi shall remain in the water system.

3.10.1-6; SEIR No. 340, MM 5.12-8)
MM PS-7 Prior to issuance of the first building permit for the DisneylandForward Project or as otherwise specified in the Development Agreement between the City and Disney in phase II, the property owner/developer shall enter into a Fire Operations Agreement with the City of Anaheim to pay or cause to be paid its fair share of the funding to address the Operations and Community Risk Reduction staffing needs for one additional fire inspector to maintain adequate levels of service of response and ongoing fire inspection, plan check, special event inspections, new construction inspections, to support all current and future expansion operations of the Project and in the Anaheim Resort. (EIR No. 311, MM 3.10.1-7) MM PS-9 Prior to the final building and zoning inspection for a hotel/motel, the property owner/developer shall submit an earthquake emergency evacuation response plan for review and approval by the Fire Department. The plan shall require posted notices in all hotel rooms on emergency evacuation earthquake safety procedures and incorporate ongoing emergency evacuationearthquake training for hotel staff to the satisfaction of the Fire Department. (EIR No. 311, MM 3.6-5 and MM 3.6-6; SEIR No. 340, MM 5.5-4)
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MM PS-10 Prior to the approval of each Final Site Plan and prior to the issuance of each building permit, plans shall be reviewed and approved by the Fire Department as being in conformance with the CaliforniaUniform Fire Code. (SEIR No. 340, MM 5.12-12)
MM PS-11 Prior to the placement of building materials on a building site, an all-weather fire access road shall be provided from the roadway system to and on the construction site and for fire hydrants at all times, as required by the Fire Department. Such routes shall be paved or, subject to the approval of the Fire Department, shall otherwise provide adequate emergency access. Every building constructed must be accessible to Fire Department apparatus. The width and radius of the driving surface must meet the requirements noted in the Anaheim Municipal Code and in accordance with City of Anaheim Fire Department Standards of Section

10.204 of the Uniform Fire Code, as adopted by the City of Anaheim. (SEIR No. 340, MM 5.12-13)
MM PS-12 Prior to approval of building plans, the property owner/developer shall provide written evidence to the satisfaction of the Fire Department that all lockable pedestrian and/or vehicular access gates shall be equipped with “knox box” devices as required and approved by the Fire Department. (SEIR No. 340, MM 5.12-14)
MM PS-19 Prior to issuance of each building permit for parking structures, the Police Department shall review the safety measures incorporated into the building plans for the parking structures within the DisneylandForward Project Site Specific Plan area to be submitted by the property owner/developer. The security measures shall include the following or other substitute security measures as may be approved by the Police Department:
 Immediate access in priority criminal cases, where an urgent need or demand exists and time is of the essence.
 For the West and East Parking Structure, and the Southwest Parking Facility, Closed circuit television surveillance and recording equipment or other adequate security measures reviewed and approved by the Police Department shall be provided.
 For the hotel parking structures, clos ed circuit television surveillance and recording equipment shall be provided.
 For the Disneyland Administration Building and the South Parking Area (south of Katella Avenue and west of Haster Street), Guarded entrance and exit gates shall be provided. (EIR No. 311, MM 3.10.2-5; SEIR No. 340, MM 5.12-2) MM PS-22 Prior to the approval of each Final Site Plan and issuance of each building permit for a hotel , the property owner/developer shall submit plans to the Police Department for review and approval by the Chief of Police, or their designee, for safety, accessibility, crime prevention, a nd security provisions during both the construction and operative phases for the purpose of incorporating safety measures in the project design including the concept of crime prevention through environmental design (e.g., building design, circulation, site planning, and lighting of parking structures and parking areas). (SEIR No. 340, MM 5.12-1) DisneylandForward
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MM PS-23 Prior to issuance of each building permit for or including a parking lot and/or parking structure , the project design shall include parking lots and parking structures with controlled access points to limit ingress and egress if determined to be necessary by the Police Department and shall be subject to the review and approval of the Police Department. (SEIR No. 340, MM 5.12-4) The following mitigation measures and project design features either are not applicable to the Project, have been completed or are now covered by a standard requirement:
 The following measures were satisfied by the approval of the 1996 Infrastructure and Parking Finance Agreement, issuance of bonds and construction of improvements:

EIR No. 311 MM 3.3-5, MM 3.3-6, MM 3.3-8, MM 3.3-9, PDF 3.3-6, PDF 3.3-7, PDF

3.3-8, PDF 3.3-9, PDF 3.3-10, PDF 3.3-11 and PDF 3.3-14.  EIR No. 311 MM 3.3-2 was satisfied by the approval of Development Agreement No. 96-01 between the City of Anaheim and Walt Disney World Company (now Walt Disney Parks and Resorts U.S., Inc.), the approval of the 1996 Infrastructure and Parking Finance Agreement, issuance of bonds and construction of improvements.  EIR No. 311 MM 3.3-3A was completed by the property owner’s dedication of the ultimate public right-of-way along the streets listed in the measure to the City of Anaheim.
 EIR No. 311 MM 3.3-4 was completed with the installation of the improvements described in the measure (installation of the cast guard entrance and drive aisle improvements).
 EIR No. 311 PDF 3.3-12 and PDF 3.3-13 were satisfied by Caltrans as part of the I- 5 Freeway Widening Project in the City of Anaheim.
 SEIR No. 340 MM 5.14-6 is not applicable as the Disneyland Resort is not located in the C-R District, Development Area 1, Convention Center Medium Density area.  SEIR No. 340 MMs 5.14-1, 5.14-17, 5.14-18, 5.14-19 and 5.14-22 were addressed by completion of the Operational Traffic Analysis for the DisneylandForward Project, Anaheim, California (Appendix J-2).

5.14.6 IMPACT SUMMARY
Threshold 5.14a Would the project conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities?
Impact Summary: The Project would result in a less than significant impact with mitigation. This impact would not be new or substantially more severe when compared with the impact analysis in EIR No. 311. This impact would be reduced when compared with the analysis in SEIR No. 340, which focused on the LOS analysis methodology.

Threshold 5.14b Would the project conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b)?
Impact Summary: The Project would result in a less than significant impact with mitigation. This impact would be new when compared with the impact analyses in EIR No. 311 and SEIR No. 340, neither of which addressed CEQA Guidelines Section 15064.3, subdivision (b).

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Threshold 5.14c Would the project substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses?
Impact Summary: The Project would result in a less than significant impact with mitigation. This impact would be new when compared with the impact analysis in EIR No. 311. This impact would not be new or substantially more severe when compared with the impact analysis in SEIR No. 340.

Threshold 5.14d Would the project result in inadequate emergency access? Impact Summary: The Project would result in a less than significant impact with mitigation. This impact would be new when compared with the impact analysis in EIR No. 311. This impact would not be new or substantially more severe when compared with the impact analysis in SEIR No. 340.

Cumulative Impact
Impact Summary: The Project would result in a less than significant cumulative impact with mitigation. Because neither EIR No. 311 nor SEIR No. 340 evaluated impacts related to VMT which is a key component in the analysis presented above, this impact would be new when compared with the impact analyses in EIR No. 311 and SEIR No. 340.

5.14.7 REFERENCES
Anaheim, City of. 2020 (June). City of Anaheim Tr affic Impact Analysis Guidelines for CEQA Analysis. Anaheim, CA: Anaheim. http://anaheim.net/409/Traffic-Impact-Analysis- Guidelines.
———. 2012 (last accessed September 14, 2 022). Final Environmental Impact Report 340 Amendment No. 14 to the Anaheim Resort Specific Plan and Mitigation Monitoring Program No. 85C. Anaheim, CA: Anaheim. http://anaheim.net/1009/Anaheim-Resort. ———. 2004 (May). General Plan for the City of Anaheim (City Council Resolution No. 2004-94).

Anaheim, City of: Anaheim, CA.
https://www.anaheim.net/DocumentCenter/View/2494/Master-Environmental-Impact- Report-Number-313-?bidId=
Gibson Transportation Consulting (Gibson), Inc. 2023a (August). CEQA Transportation Analysis for the DisneylandForward Project, Anaheim, California. Los Angeles, CA: Gibson. (Appendix J-1)
———. 2023b (August). Operational Traffic Analysis for the DisneylandForward Project, Anaheim, California. Los Angeles, CA; Gibson. (Appendix J-2) DisneylandForward
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Orange County Transportation Authority. 2017. Master Plan of Arterial Highways (MPAH). Santa Ana, CA: OCTA. https://www.octa.net/News-and-Resources/Open-Data/MPAH- Overview/
Southern California Association of Governments. 2022a. SCAG – About Us – Webpage. Los Angeles, CA: SCAG. https://scag.ca.gov/about-us
———. 2022b (last accessed September 14, 2022). Connect SoCal webpage. Los Angeles, CA:

SCAG. https://scag.ca.gov/connect-socal
———. 2020 (September). Connect SoCal (2020-2045 Regional Transportation Plan/Sustainable Communities Strategy. Los Angeles, CA: SCAG. https://scag.ca.gov/connect- socal#:~:text=Adopted%20Final%20Connect%20SoCal%202020,- Overview%20November%2021&text=It%20charts%20a%20path%20toward,of%20life% 20for%20Southern%20Californians.

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5.15-1 Section 5.15 – Tribal Cultural Resources

5.15 TRIBAL CULTURAL RESOURCES
This section discusses the existing tribal cultural resources setting of the Project Site and assesses the Project’s potential impacts on tribal cultural resources. The analysis in this section is based on the Development History Report for the DisneylandForward Project prepared by South Environmental in July 2023 (Appendix E-1), which focused on prior disturbance at the Disney ARSP Properties, the Pumbaa parking lot just north of Disney Way, and the Simba parking lot just south of the Paradise Pier Hotel, the Historic Resources Technical Report for DisneylandForward that was prepared by Historic Resources Group (HRG) in May 2023 (Appendix E-2), which documents the disturbance at and around Disneyland, and the results of consultation with California Native American Tribes conducted by City of Anaheim staff, as required by CEQA, as amended by California Assembly Bill (AB) 52. The consultation letters are included as Appendix K to this Draft Subsequent EIR; all information gathered through the consultation process is confidential and not included as part of this appendix.

5.15.1 SUMMARY OF PREVIOUS ENVIRONMENTAL DOCUMENTATION
The Disneyland Resort EIR No. 311
EIR No. 311, certified by the City in 1993, did not directly address the specific tribal cultural resources thresholds that were adopted as additions to CEQA Guidelines Appendix G in 2016; however, Section 3.13, Cultural Resources, of EIR No. 311 concluded that no impacts to cultural resources were expected to occur from development of The Disneyland Resort Project, however, the City required the implementation of the mitigation measure below regarding archaeological resources in case of an unforeseen discovery of archaeological materials. The City found implementation of MM 3.13-1, below, would mitigate potential impacts to archaeological resources to less than significant.

EIR No. 311 Mitigation Measure
EIR No. 311 and Modified MMP No. 0067
1 required implementation of the following mitigation
measure regarding cultural resources to reduce potential impacts on archaeological resources associated with full buildout of The Disneyland Resort Project to less than significant.

MM 3.13-1 Prior to approval of each grading plan, the applicant shall submit a letter identifying the certified archaeologist that has been hired to ensure that the following actions are implemented:
a. The archaeologist must be present at the pre-grading conference in order to establish procedures for temporarily halting or redirecting work to permit the sampling, identification, and evaluation of artifacts if potentially significant artifacts are uncovered. If artifacts are uncovered and determined to be significant, the archaeological observer shall determine appropriate actions in cooperation with the property owner/developer for exploration and/or salvage. b. Specimens that are collected prior to or during the grading process will be donated to an appropriate educational or research institution. c. Any archaeological work at the site shall be conducted under the direction of the certified archaeologist. If any artifacts are discovered during grading operations when the archaeological monitor is not present, grading shall be diverted around the area until the monitor can survey the area.

1 Addendum No. 1 to EIR No. 311, which t he City approved in 1996, modified MMP No. 0067.

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d. A final report detailing the findings and disposition of the specimens shall be submitted to the City Engineer. Upon completion of the grading, the archaeologist shall notify the City as to when the final report will be submitted.

Anaheim Resort Specific Plan SEIR No. 340
SEIR No. 340 is a Supplemental EIR, certified by the City in 2012, that reevaluated environmental changes in and around the Anaheim Resort since certification of EIR No. 313 in 1994. SEIR No. 340 did not directly address impacts to the specific tribal cultural resources thresholds that were adopted as additions to CEQA Guidelines Appendix G in 2016; however, Section 5.4, Cultural Resources, of SEIR No. 340 concluded that there is no evidence of Native American human remains in the ARSP area and that adherence to Section 5097.98 of the California Public Resources Code and Section 7050.5 of the California Health and Safety Code would ensure that a significant impact would not occur. In compliance with the standard requirements, the City of Anaheim contacted known Native American groups to solicit consultation requests, pursuant to Senate Bill 18, in October 2009. No concerns were raised during this process.

SEIR No. 340 Mitigation Measure and Standard Requirement SEIR No. 340 required implementation of the following mitigation measure and standard requirement regarding cultural resources to reduce potential impacts on archaeological resources associated with the ARSP Project to less than significant.

MM 5.4-1 Prior to issuance of each grading permit, the property owner/developer shall submit a letter identifying the certified archaeologist that has been hired to ensure that the following actions are implemented:
a. The archaeologist must be present at the pre-grading conference in order to establish procedures for temporarily halting or redirecting work to permit the sampling, identification, and evaluation of artifacts if potentially significant artifacts are uncovered. If artifacts are uncovered and determined to be significant, the archaeological observer shall determine appropriate actions in cooperation with the property owner/developer for exploration and/or salvage. b. Specimens that are collected prior to or during the grading process will be donated to an appropriate educational or research institution. c. Any archaeological work at the site shall be conducted under the direction of the certified archaeologist. If any artifacts are discovered during grading operations when the archaeological monitor is not present, grading shall be diverted around the area until the monitor can survey the area.
d. A final report detailing the findings and disposition of the specimens shall be submitted to the City Engineer. Upon completion of the grading, the archaeologist shall notify the City as to when the final report will be submitted.

SR 5.4-1 Before and during construction, if human remains are discovered on-site, no further disturbance shall occur until the County Coroner has made a determination of origin, and disposition pursuant to California Public Resources Code Section 5097.98 and California Health and Safety Code Section 7050.5 has occurred.

SR 5.4-2 Prior to approval of any amendment to the ARSP or the City of Anaheim General Plan, the project property owner/developer shall coordinate with the City Planning Department to undergo a solicitation of Native American consultation pursuant to Senate Bill (SB) 18 (California Government Code, Section 65352.3).

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5.15.2 ENVIRONMENTAL SETTING
The following discussion details the existing conditions at the time the City published the NOP for Subsequent EIR No. 352; however, consistent with CEQA’s subsequent review standards, the previously approved projects serve as the baseline for the CEQA analysis, and Subsequent EIR No. 352 compares the effects of the Project changes on the previously approved projects with the effects of the previously analyzed and approved projects, as detailed in EIR No. 311 and SEIR No. 340.

A. Existing Conditions
Records Search Results
Section 5.4, Cultural Resources, of this Draft Subsequent EIR provides an evaluation of cultural resources, including archaeological and historic resources. As noted in that section, a cultural resource record search and literature review was conducted at the California Historical Resources Information System (CHRIS), which maintains records and literature regarding cultural resources within California. The South Central Coastal Informational Center (SCCIC) is a designated branch of the CHRIS and houses records recorded in San Bernardino, Los Angeles, Orange, and Ventura Counties. The CHRIS office for Orange County is located at the SCCIC at California State University, Fullerton. Although the literature review at the SCCIC revealed that 50 cultural resources studies have been undertaken within one mile of the Project Site, only one is located within the Project Site. This report consisted of an Archaeological and Paleontological Resources Monitoring Compliance Report for Disney’s California Adventure Expansion, Cars Land Project located in Anaheim, California. The prior studies are listed in Table 5.4-3 of Section 5.4, Cultural Resources, and the records search results summary from the SCCIC is presented in Appendix E-3. No known archaeological resources, including prehistoric archaeological sites, are located on the Project Site or within a ½-mile of the Project Site. As noted in Table 5.4-3, of Section 5.4, Cultural Resources, Report OR-03936, an Archaeological and Paleontological Resources Monitoring Compliance Report for Dis ney’s California Adventure Expansion, Cars Land Project located in Anaheim, California was conducted within the Project Site; however, no resources were recorded.

Regional Ethnographies
Ethnography is a cultural anthropologic research method that strives to answer anthropological questions about different cultures. The following section describes the ethnographic background of the Project Site.

Gabrielino/Tongva
At the time of European contact, this part of Orange County, including Anaheim, was the home of the Gabrielino, or Tongva. The Gabrielino and their descendants are those people who became associated with Mission San Gabriel Arcángel, which was established in south-central Los Angeles County on September 8, 1771, in what has ever since been called the San Gabriel Valley.

Today, these people are sometimes referred to as the Tongva, although the term apparently originally (i.e., before the arrival of Euro-Americans) referred to the inhabitants of the San Gabriel Valley only. In either case, the inhabitants of Santa Catalina Island and San Clemente Island are often included as being part of this tribe, as are the Fernandeño, who inhabited most of the San Fernando Valley. Note that Chester King distinguishes between the Eastern Gabrielino, who lived south of the San Gabriel Mountains, mainly in the San Gabriel Valley, and the Western Gabrielino, who lived along the western coast of Los Angeles County, from Malibu to Palos Verdes, and the San Fernando Valley.

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The ancestral Gabrielino arrived in the Los Angeles Basin probably before 500 BCE (Before Common Era) as part of the so-called Shoshonean (Takic speaking) Wedge from the Great Basin region, and gradually displaced the indigenous peoples who were probably Hokan speakers.

Large, permanent villages were established in the fertile lowlands along rivers and streams and in sheltered areas along the coast. Eventually, Gabrielino territory encompassed the watersheds of the Los Angeles, San Gabriel, Rio Hondo, and Santa Ana Rivers which include the greater Los Angeles Basin, to perhaps as far south as Aliso Creek, as well as portions of the San Fernando, San Gabriel, and San Bernardino Valleys. Gabrielino territory also included the islands of San Clemente, San Nicholas, and Santa Catalina. Recent studies suggest the population may have numbered as many as 10,000 individuals at their peak in the Precontact Period.

The subsistence economy of the Gabrielino was one of hunting and gathering. The surrounding environment was rich and varied, and the natives were able to exploit resources in the mountains, foothills, valleys, deserts, and coasts. As was the case for most native Californians, acorns were the staple food (by the Intermediate Horizon), supplemented by the roots, leaves, seeds, and fruit of a wide variety of flora (i.e., cactus, yucca, sage, and agave). Fresh and saltwater fish, shellfish, birds, insects, and large and small mammals were also eaten.

A wide variety of tools and implements were employed by the Gabrielino to gather, collect, and process food resources. The most important hunting tool was the bow and arrow. Traps, nets, blinds, throwing sticks, and slings were also employed. Fish were an important resource and nets, traps, spears, harpoons, hooks, and poisons were utilized to catch them. Ocean-going plank canoes and tule balsa canoes were used for fishing and for travel by those groups residing near the Pacific Ocean.

The processing of food resources was accomplished in a variety of ways: nuts were cracked with hammer stone and anvil; acorns were ground with mortar and pestle; and seeds and berries were ground with mano and metate. Yucca, a valuable resource in many areas, was eaten by the natives and exploited for its fibers.

Strainers, leaching baskets and bowls, knives, bone saws, and wooden drying racks were also employed. Food was consumed from a variety of vessels. Catalina Island steatite was used to make ollas and cooking vessels.

Gabrielino houses were circular domed structures of willow poles thatched with tule. They were actually quite large and could, in some cases, hold 50 individuals. Other structures served as sweathouses, menstrual huts, and ceremonial enclosures (Bean and Smith 1978).

Kroeber (1925:621) considered the Gabrielino:
…to have been the most advanced group south of Tehachapi, except perhaps the Chumash. They certainly were the wealthiest and most thoughtful of all the Shoshoneans of the State, and dominated these civilizationally wherever contacts occurred.

Anaheim
In 1852, Reid reported that the community of Hotuuknga was located on “Santa Ana [Yorbes]”, referring to the 79,000-acre Mexican land grant of Rancho Santiago de Santa Ana owned by the Yorba family. This information was confirmed by Kroeber. An entry in the San Gabriel mission registers states “Jutucunga en el rio Santa Ana [on the Santa Ana River].” Writing sometime before 1933, Harrington reported on Hotuuknga as follows:

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the site of the former Bernardo Yorba adobe house, on the north bank of Wanawna, the Santa Ana River, a little downstream of Santa Ana Canyon [sic], ¼-mile upstream of the Yorba church, across the river from Peralta. The old adobe house was visited by me [Harrington] with Acu [a Juaneño consultant, Jose de la Gracia Cruz] . . . It was torn down about 1926 . . . The Yorba church is on the south side of the main north-bank road, between [the] road and [the] Santa Fe railway.

The Yorba house site is on the north side of this road.

When the Portolá Expedition forded the Santa Ana River on July 28, 1769, Father Crespi described it as “a river which has a bed of running water about 10 varas wide 2 and half vara3 deep
. . . Its course is from northeast to southwest. The bed of the river is overgrown with sycamores, alders, willows, and other trees . . .” He reported the following existed on the right bank of the river:
…a populous village of Indians, who received us with great friendliness. Fifty-two of them came to the camp, and their chief told us by signs which we understood very well that we must come to live with them; that they would make houses for us, and provide us with food, such as antelope, hares, and seeds. They urged us to do this, telling us that all the land we saw, and there was certainly a great deal of it, was theirs, and that they would divide it with us.

These Indians were seen by Father Crespi again the following day at the fiesta near Brea Canyon.

Although Father Crespi did not report a name for this community, it appears to have been situated near the location of the Hotuuknga.

Jose Zalvidea reported to Harrington that Hotuuknga “… means night for at the beginning of the world, they went no more in the night” (McCawley 1996: 59–60).

Independence from Spain in 1821 marks the beginning of the Mexican Period (1821-1848), which closed with the signing of the Treaty of Guadalupe Hidalgo which ended the Mexican–American War. Extensive land grants were made in the interior region during the Mexican Period. During the supremacy of the ranchos (1834–1848), landowners largely focused on the cattle industry and devoted large tracts to grazing. Cattle hides became a primary Southern California export, providing a commodity to trade for goods, and were known as “California bank notes.” A steadily growing California population contributed to the introduction and rise of diseases foreign to the Native American population, who had no associated immunities (South Environmental 2023).

B. Regulatory Framework
Federal
National Historic Preservation Act
The National Historic Preservation Act (NHPA) of 1966, as amended, promotes the preservation, enhancement, and productive use of historic resources. The NHPA established the Advisory Council on Historic Preservation (ACHP) and provided procedures for the ACHP and federal agencies in promoting historic preservation.

2 A Spanish vara was about 33 inches, so the River was about 27 feet wide. 3 About 16 inches
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Section 106 of the NHPA, which is codified as 36 CFR Part 800, requires that federal actions and the use of federal funds take into account their potential effects on historic properties or those listed in or eligible for listing in the National Register of Historic Places (NRHP, National Register).

National Register of Historic Places
The National Historic Preservation Act of 1966 established the National Register as “an authoritative guide to be used by federal, state, and local governments, private groups and citizens to identify the Nation’s historic resources and to indicate what properties should be considered for protection from destruction or impairment.” The National Register recognizes a broad range of historical and cultural resources that are significant at the national, state, and local levels and can include districts, buildings, structures, objects, prehistoric archaeological sites, historic-period archaeological sites, traditional cultural properties, and cultural landscapes. Within the National Register, approximately 2,500 (3 percent) of the more than 90,000 districts, buildings, structures, objects, and sites are recognized as National Historic Landmarks or National Historic Landmark Districts as possessing exceptional nat ional significance in American history and culture.

Whereas individual historic properties derive their significance from one or more of the criteria discussed in the subsequent section, a historic district derives its importance from being a unified entity, even though it is often composed of a variety of resources. With a historic district, the historic resource is the district itself. The identity of a district results from the interrelationship of its resources, which can be an arrangement of historically or functionally related properties. A district is defined as a geographic area of land containing a significant concentration of buildings, sites, structures, or objects united by historic events, architecture, aesthetic, character, and/or physical development. A district’s significance and historic integrity determine its boundaries.

A resource that is listed in or eligible for listing in the National Register is considered an “historic property” under Section 106 of the National Historic Preservation Act.

Criteria
To be eligible for listing in the National Register, a resource must be at least 50 years of age, unless it is of exceptional importance as defined in Title 36 CFR, Part 60, Section 60.4(g). In addition, a resource must be significant in American history, architecture, archaeology, engineering, or culture. Four criteria for evaluation have been established to determine the significance of a resource:

A. Are associated with events that have made a significant contribution to the broad patterns of our history;
B. Are associated with the lives of persons significant in our past; C. Embody the distinctive characteristics of a type, period, or method of construction or that represent the work of a master, or that possess high artistic values, or that represent a significant and distinguishable entity whose components may lack individual distinction; or D. Have yielded, or may be likely to yield, information important in prehistory or history.

Historic Districts
The National Park Service defines a historic district as “a significant concentration, linkage, or continuity of sites, buildings, structures, or objects united historically or aesthetically by plan or physical development.” A district must be “a definable geographic area that can be distinguished from surrounding properties by changes such as density, scale, type, age, style of sites, buildings, DisneylandForward
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structures, and objects, or by documented differences in patterns of historic development or associations.” Boundaries must be based upon a shared relationship among the properties constituting the district.

Within a historic district, a building, structure, or feature is considered a contributor if it was constructed during the period of significance, cont ributes to the property’s historic significance and character, and retains sufficient integrity to convey that significance. Non-contributors are those buildings that were constructed outside of the period of significance, do not contribute to the property’s historic significance and character, and/or do not retain sufficient integrity.

Period of Significance
According to the National Park Service, in addition to the above criteria, significance is defined by the area of history in which the property made important contributions and by the period of time when these contributions were made. This is referred to as the period of significance. The period of significance is the length of time when a property was associated with important events, activities or persons, or attained the characteristics which qualify it for listing. The period of significance usually begins with the date when significant activities or events began giving the property its historic significance; this is often a date of construction. The period of significance can be as brief as a single year; many, however, span many years and consist of beginning and closing dates. Identification and definition of the period of significance is based on “specific events directly related to the significance of the property,” for example, the date of construction, years of ownership, or length of operation as a particular entity.

Integrity
In addition to meeting one or more of the criteria of significance, a property must have integrity, which is defined as “the ability of a property to convey its significance.” The National Register recognizes seven qualities that, in various combinations, define integrity. The seven factors that define integrity are location, design, setting, materials, workmanship, feeling, and association. To retain historic integrity a property must possess several, and usually most, of these seven aspects. Thus, the retention of the specific aspects of integrity is paramount for a property to convey its significance. In general, the National Register has a higher integrity threshold than State or local registers.

The National Register recognizes seven aspects or qualities that comprise integrity: location, design, setting, materials, workmanship, feeling, and association. These qualities are defined as follows:
 Location is the place where the historic property was constructed or the place where the historic event took place.
 Design is the combination of elements that create the form, plan, space, structure, and style of a property.
 Setting is the physical environment of a historic property.  Materials are the physical elements that were combined or deposited during a particular period of time and in a particular pattern or configuration to form a historic property.  Workmanship is the physical evidence of the crafts of a particular culture or people during any given period in history or prehistory.
 Feeling is a property’s expression of the aesthetic or historic sense of a particular period of time.

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 Association is the direct link between an important historic event or person and a historic property.

State
California Register of Historical Resources
The California Register of Historical Resources (CRHR) program encourages public recognition and protection of resources of architectural, histor ical, archaeological, tribal cultural resources, and cultural significance; identifies historical resources for State and local planning purposes; determines eligibility for State historic preservation grant funding; and affords certain protections under the California Environmental Quality Act (CEQA). The criteria established for eligibility for the CRHR are directly comparable to the national criteria established for the National Register (as discussed in in Section 5.4, Cultural Resources).

In order to be eligible for listing in the CRHR, a building, object, or structure must satisfy at least one of the following four criteria:

1. It is associated with events that have made a significant contribution to the broad patterns of local or regional history or the cultural heritage of California or the United States;

2. It is associated with the lives of persons important to local, California, or national history;

3. It embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of a master or possesses high artistic values; or

4. It has yielded, or has the potential to yield, information important to the prehistory or history of the local area, California, or the nation.

Archaeologists and Tribal Representatives assess sites based on all four of the above criteria but usually focus on the fourth criterion provided above. Historical resources eligible for listing in the CRHR must also retain enough of their historic character or appearance to be recognizable as historical resources and to convey the reasons for their significance. For the purposes of eligibility for the CRHR, integrity is defined as “the authenticity of an historical resource’s physical identity evidenced by the survival of characteristics that existed during the resource’s period of significance”. This general definition is generally strengthened by the more specific definition offered by the NRHP—the criteria and guidelin es on which the CRHR criteria and guidelines are based upon.

California Environmental Quality Act
Archaeological and Historical Resources
CEQA requires a lead agency to determine whether a project would have a significant effect on the environment, including historical resources. CEQA Guidelines Section 15064.5, Determining the Significance of Impacts to Archeological and Historical Resources, requires that all private and public activities not specifically exempted should be evaluated against the potential for environmental damage, including effects to histor ical resources. Historical resources are recognized as part of the environment under CEQA. According to Section 5020.1 of the Public Resources Code, historical resources are defined as “any object, building, structure, site, area, place, record, or manuscript which a lead agency determines to be historically significant or significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, military, or cultural annals of California”. An archeological site may be considered an historical resource if it is significant in the architectural, engineering, scientific, economic, DisneylandForward
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agricultural, educational, social, political, military or cultural annals of California (Public Resource Code § 5020.1(j)) or if it meets the criteria for listing on the California Register (14 CCR § 4850).

Lead agencies must evaluate historical resources against the CRHR criteria before making a finding as to a proposed project’s impacts to historical resources. Mitigation of adverse impacts is required if the proposed project would cause substantial adverse change to a historical resource. Substantial adverse change includes demolition, destruction, relocation, or alteration such that the significance of a historical re source would be impaired. While demolition and destruction are fairly obvious significant impacts , it is more difficult to assess when change, alteration, or relocation crosses the threshold of substantial adverse change. The CEQA Guidelines provide that a project that demolishes or alters those physical characteristics of a historical resource that convey its historical significance (i.e., its character-defining features) can be considered to materially impair the resource’s significance. The CRHR is used in the consideration of historical resources relative to significance for purposes of CEQA. The CRHR includes resources listed in, or formally determined eligible for listing in, the NRHP, as well as some California State Landmarks and Points of Historical Interest. Properties of local significance that have been designated under a local preser vation ordinance (local landmarks or landmark districts) or that have been identified in a local historical resources inventory may be eligible for listing in the CRHR and are presumed to be significant resources for purposes of CEQA unless a preponderance of evidence indicates otherwise.

Generally, a resource shall be considered by the lead agency to be a “historical resource” if it:

1. Is listed in or determined to be eligible by the State Historical Resources Commission for listing in the California Register of Historical Resources (California Public Resources Code Section 5024.1, Title 14 California Code of Regulations, Section 4850, et seq.).

2. Is included in a local register of historical resources or is identified as significant in a historical resource survey meeting the requirements of Section 5024.1(g) of the Public Resources Code.

3. Is a building or structure determined to be historically significant or significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, military, or cultural annals of California.

Tribal Cultural Resources/Assembly Bill 52
In September 2014, Governor Brown signed AB 52 (Chapter 532, Statutes of 2014), which creates a new category of environmental resources that must be considered under CEQA: “tribal cultural resources.” The legislation imposes new requirements for offering to consult with California Native American tribes regarding projects that may affect a tribal cultural resource, emphasizes a broad definition of what may be cons idered to be a tribal cultural resource, and includes a list of recommended mitigation measures (MMs).

Recognizing that tribes may have expertise regarding their tribal history and practices, AB 52 requires lead agencies to provide notice to tribes that are traditionally and culturally affiliated with the geographic area of a proposed project if they have requested notice of projects proposed within that area. MMs agreed upon during consultation must be recommended for inclusion in the environmental document.

AB 52, which became effective on July 1, 2015, requires lead agencies to provide notice to tribes that are traditionally and culturally affiliated with the geographic area of a proposed project, if they have requested such notice in writing. Once Native American tribes receive a project notification, they have 30 days to respond and identify if they wish to initiate consultation regarding the project DisneylandForward
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on subjects such as mitigation for any potential project impacts to tribal cultural resources. A tribal cultural resource is defined as either a site, feature, place, or cultural landscape that is geographically defined in terms of size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is eligible for the CRHR or a local historic register. If a tribe requests consultation and the lead agency and the tribe ultimately agree on mitigation to address any potentially significant impacts to tribal cultural resources, the mitigation measures agreed upon during consultation must be recommended for inclusion in the environmental document.

Native American Historic Resource Protection Act
Established in 2002, the Native American Historic Resource Protection Act, establishes a misdemeanor for unlawfully and maliciously excavating upon, removing, destroying, injuring, or defacing a Native American historic, cultural, or sacred site that is listed or may be eligible for listing in the CRHR. The focus of this legislatio n was to provide additional legal protection for Native American historical and cultural sites, art, and other cultural artifacts found at those sites.

The Act also encourages collaborative relationships for the protection of Native American cultural resources between Native Americans and landowners. Funding and other state assistance should be encouraged for support of voluntary agreements to conserve, maintain, and provide physical access for Native Americans to these cultural resources.

California Health and Safety Code (Sections 7050.5, 7051, and 7054) These sections of the California Health and Safety Code collectively address the illegality of interference with human burial remains (except as allowed under applicable sections of the [California Public Resources Code]. These sections also address the disposition of Native American burials found in archaeological sites and protect such remains from disturbance, vandalism, or inadvertent destruction. Procedures to be implemented are established for (1) the discovery of Native American skeletal remains during construction of a project; (2) the treatment of the remains prior to, during, and after evaluation; and (3) reburial.

Section 7050.5 of the California Health and Safety Code specifically provides for the disposition of accidentally discovered human remains. Section 7050.5 states that if human remains are found, no further excavation or disturbance of the site or any nearby area reasonably suspected to overlie adjacent remains shall occur until the County Coroner has determined whether the human remains are likely of Native American origin, and, if so, the most likely descendant is given the opportunity to suggest appropriate treatment and disposition of the human remains pursuant to California Public Resources Code Section 5097.98, discussed below.

California Public Resources Code (Section 5097.98)
Section 5097.98 of the Public Resources Code states that, if remains are determined by the Coroner to be of Native American origin, the Coroner must notify the NAHC within 24 hours. When the NAHC receives this notification from a County Coroner, it shall immediately notify those persons it believes to be most likely descended from the deceased Native American. The descendants may, with the permission of the owner of the land or his or her authorized representative, inspect the site of the remains and may recommend to the owner or the person responsible for the excavation work means for treatment or disposition, with appropriate dignity, of the human remains and any associated grave goods. The descendants shall complete their inspection and make recommendations or preferences for treatment within 48 hours of being granted access to the site. This regulation also requires that, upon the discovery of Native American remains, the landowner shall ensure that the immediate vicinity, according to generally accepted cultural or archaeological standards or practices, where the Native American human DisneylandForward
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remains are located, is not damaged or disturbed by further development activity until the landowner has discussed and conferred with the most likely descendants regarding their recommendations and all reasonable options regarding their preferences for treatment. This section of the Public Resources Code has been incorporated into Section 15064.5(e) of the State CEQA Guidelines.

5.15.3 PROJECT IMPACT ANALYSIS
A. Methodology
Native American Consultation
Although cultural and historic resources were analyzed in the Prior EIRs, these exact thresholds relating to tribal cultural resources were not. Therefore, the significance of impacts under these thresholds are analyzed in this Draft Subsequent EIR rather than in comparison to conclusions in the Prior EIRs under CEQA supplemental review standards.

As stated previously, EIR No. 311 concluded that no impacts to cultural resources were expected to occur from development of The Disneyland Resort Project, however, the City required the implementation of mitigation regarding archaeological resources in case of an unforeseen discovery of archaeological materials, which would mitigate potential impacts to archaeological resources to less than significant. SEIR No. 340 did not directly address impacts to the specific tribal cultural resources thresholds that were adopted as additions to CEQA Guidelines Appendix G in 2016; however, Section 5.4, Cultural Resources, of SEIR No. 340 concluded that there is no evidence of Native American human remains in the ARSP area and that adherence to Section 5097.98 of the California Public Resources Code and Section 7050.5 of the California Health and Safety Code would ensure that a significant impact would not occur. In compliance with the standard requirements, the City of Anaheim contacted known Native American groups to solicit consultation requests, pursuant to SB 18, in October 2009. No concerns were raised during this process.

Native American coordination efforts were conducted for this Project in 2021 and 2022. Psomas submitted a request to the NAHC to review the Sacred Lands File (SLF) database regarding the possibility of Native American cultural resources and/or sacred places in the Project Site. The results from the NAHC were received on June 25, 2021. The SLF search did not identify any known resources or sacred lands within the Project Site. However, the NAHC recommended that the lead agency (City of Anaheim) contact tribes that are traditionally and culturally affiliated with the geographic area. The City contacted the tribes listed on their consultation list on December 10, 2021.

Additionally, because the Project requires a General Plan Amendment, it is subject to the statutory requirements of SB 18 Tribal Consultation Guidelines (California Government Code Section 65352.3), which require the offer of government-to-government consultation with interested local Native American tribes identified by the NAHC. Native American groups may have knowledge about cultural resources in the area and may have concerns about adverse effects from development on cultural resources. These resour ces may be sacred lands, traditional cultural places and resources, and archaeological sites.

Informational letters were sent to the following tribes identified on the NAHC’s list:
 Ralph Goff, Chairperson, Campo Band of Diegueno Mission Indians; DisneylandForward
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 Christina Conley, Tribal Consultant and Administrator, Gabrielino Tongva Indians of California Tribal Council;
 Michael Garcia, Vice Chairperson, Ewiiaapaayp Band of Kumeyaay Indians;  Robert Dorame, Chairperson, Gabrielino Tongva Indians of California Tribal Council;  Robert Pinto, Chairperson, Ewiiaapaayp Band of Kumeyaay Indians;  Charles Alvarez, Gabrielino/Tongva Tribe;
 Andrew Salas, Chairperson, Gabrieleno Band of Mission Indians;  Matias Belardes, Chairperson, Juaneno Band of Mission Indians Acjachemen Nation – Belardes;
 Anthony Morales, Chairperson, Gabrielino/Tongva San Gabriel Band of Mission Indians;  Gwendolyn Parada, Chairperson, La Posta Band of Diegueno Mission Indians;  Sandonne Goad, Chairperson, Gabrielino /Tongva Nation;  Javaughn Miller, Tribal, La Posta Band of Diegueno Mission Indians;  Isaiah Vivanco, Chairperson, Soboba Band of LuisenoIndians;  Angela Elliott Santos, Chairperson, Manzanita Band of Kumeyaay Nation;  Michael Linton, Chairperson, Mesa Grande Band of Diegueno Mission Indians;  Shasta Gaughen, Tribal Historic, Pala Band of Mission Indians; and  Lovina Redner, Tribal Chair, Santa Rosa Band of Cahuilla Indians.

As part of the AB 52 process, the City sent a project notification letter to the Gabrieleño Band of Mission Indians – Kizh Nation, which was the tribe that had previously requested to be part of any consultation regarding tribal cultural resources. On December 13, 2021, the Gabrieleño Band of Mission Indians – Kizh Nation requested consultation with the City of Anaheim regarding the Project. The following is a chronology of the consultation between the City and the Gabrieleño Band of Mission Indians – Kizh Nation:
 February 8, 2022 – The City and Gabrieleño Band of Mission Indians – Kizh Nation consultation was held;
 February 18, 2022 – Gabrieleño Band of Mission Indians – Kizh Nation provided the City with documentation in addition to proposed mitigation measures, including a measure for the retention of a Native American Monitor from or approved by the Gabrieleño Band of Mission Indians – Kizh Nation for any “ground disturbing activity”, where “ground- disturbing activity” includes, but is not limited to, demolition, pavement removal, potholing, auguring, grubbing, tree removal, boring, grading, excavation, drilling, and trenching;  May 5, 2023 – The City provided the following proposed mitigation measure:
“Prior to the issuance of any grading permit in which native soil, as identified by the geotechnical report prepared for the project, is disturbed, the property owner/developer or contractor as designee shall provide evidence in the form of an executed Agreement to the City of Anaheim Planning and Building department that they have retained a qualified Native American tribal monitor to provide third-party monitoring during excavation and grading activities in native sediment and to recover and catalogue tribal resources as necessary. The tribal monitor shall be from or approved by the Gabrieleño Band of Mission Indians – Kizh Nation. The agreement shall include (i) professional qualifications DisneylandForward
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of Native American monitor; (ii) detailed scope of services to be provided including but not limited to pre-construction education, observation, evaluation, protection, salvage, notification, and/or curation requirements, as applicable, with final documentation/report to Public Works Inspector; (iii) contact information; (iv) communication protocols between Contractor and Monitor for scheduling to facilitate timely performance; (v) acknowledgment that if the tribal monitor is unavailable or unresponsive based on terms stipulated in the agreement, property ow ner/developer or contractor as designee may contract with another qualified tribal monitor acceptable to the City. The selection of the qualified professional(s) shall be subject to City acceptance based on generally accepted professional qualifications and certifications, as applicable. The cover sheet of the grading plans shall include a note to identify that third party tribal monitoring is required during excavation and grading activities in accordance the with City-approved Agreement.

Contact information for approved tribal monitor shall be provided by the contractor to the City inspector at the pre-construction meeting.”;
 May 9, 2023 - Gabrieleño Band of Mission Indians – Kizh Nation requested a follow-up meeting;
 May 9, 2023 – The City requested specific edits to the mitigation measure provided and reiterated this request on May 11 when discussing scheduling the follow-up meeting;  May 18, 2023 – The City again requested specific edits on the mitigation measure, having received no response or meeting scheduled;
 May 19, 2023 - Gabrieleño Band of Mission Indians – Kizh Nation responded to set a follow-up call for June 1 meeting;
 May 19, 2023 – The City confirmed June 1 meeting, but again requested specific edits to the mitigation measure in advance of the meeting to make sure to have information available to facilitate the consultation;
 May 19, 2023 - Gabrieleño Band of Mission Indians – Kizh Nation provided a dial-in number for June 1 meeting and replied “We will make edits on the mitigations.” No edits were provided in advance on the June 1 meeting;
 June 1, 2023 – At the meeting, the Gabrieleño Band of Mission Indians – Kizh Nation reiterated the original information and mitigation measures they provided and expressed the position that monitoring only in native soil would not protect tribal cultural resources.

The tribe requested any information available from Disney regarding the history of the subsurface soils that will be impacted by the project, specifically information about whether the “original” soils of the project location have been “removed” and “replaced” by new soils (e.g., engineered, cleaned, imported) or have the original soils just been excavated, placed onsite and then “backfilled” into the same location;  June 26, 2023 - Gabrieleño Band of Mission Indians – Kizh Nation followed up with the City on the availability of information on the subsurface soils;  June 30, 2023 – The City advised the Gabrieleño Band of Mission Indians – Kizh Nation that the City did not have the requested information and proposed the following revised mitigation measure based on the consultation:
“Prior to the issuance of any permits allowing ground-disturbing activities that cause excavation to depths greater than current foundations, grading permit in which native soil, as identified by the geotechnical report prepared for the project, is disturbed, the property owner/developer or contractor as designee shall provide evidence in the form of an executed Agreement to the City of Anaheim Planning and Building department that they have retained a qualified Native American tribal monitor to provide third-party monitoring DisneylandForward
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during construction-related ground disturbance actives excavation and grading activities in native sediment and to recover and catalogue tribal resources as necessary. The tribal monitor shall be from or approved by the Gabrieleño Band of Mission Indians – Kizh Nation. The agreement shall include (i) professional qualifications of Native American monitor; (ii) detailed scope of services to be provided including but not limited to pre- construction education, observation, evaluation, protection, salvage, notification, and/or curation requirements, as applicable, with final documentation/report to Public Works Inspector; (iii) contact information; (iv) communication protocols between Contractor and Monitor for scheduling to facilitate timely performance; (v) acknowledgment that if the tribal monitor is unavailable or unresponsive based on terms stipulated in the agreement, property owner/developer or contractor as designee may contract with another qualified tribal monitor acceptable to the City. The selection of the qualified professional(s) shall be subject to City acceptance based on generally accepted professional qualifications and certifications, as applicable. The cover sheet of the grading plans shall include a note to identify that third party tribal monitoring is required during excavation and grading activities in accordance the with City-approved Agreement. Contact information for approved tribal monitor shall be provided by the contractor to the City inspector at the pre-construction meeting.”
 June 30, 2023 - Gabrieleño Band of Mission Indians – Kizh Nation advised that they would review the revised mitigation.

As of September 6, 2023, no further response has been received.

B. Thresholds of Significance
The following significance criteria are derived from the City of Anaheim Environmental Checklist.

Threshold 5.15a 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 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)?
Threshold 5.15b Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is a 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?
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C. Standard Requirements
The following standard requirement is applicable to the Project. As appropriate, the measure number and section from SEIR No. 340 is listed in parentheses. Modifications to the original measure are shown as strikethrough for deleted text and bold for new, inserted text.

SR CUL-1 Before and during construction, if human remains are discovered on-site, no further disturbance shall occur until the County Coroner has made a determination of origin, and disposition pursuant to California Public Resources Code Section 5097.98 and California Health and Safety Code Section 7050.5 has occurred. (SEIR No 340, SR 5.4-1)
SR TCR-1 Prior to approval of any amendment to the ARSP or the City of Anaheim General Plan, the project property owner/developer shall coordinate with the City Planning Department to undergo a solicitation of Native American consultation pursuant to Senate Bill (SB) 18 ( California Government Code, Section 65352.3). (SEIR No 340, SR 5.4-2)
D. Impact Analysis
Threshold 5.15a 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 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)?
New Impact from EIR No. 311; New Impact from SEIR No. 340 – No Project Impact. As previously discussed, neither EIR No. 311 nor SEIR No. 340 directly addressed impacts related to tribal cultural resources.

For purposes of impact analysis, a tribal cultural re source is considered a site, feature, place, cultural landscape, sacred place, or object which is of cultural value to a California Native American Tribe and is either eligible for the CRHR or a local register of historical resources, as defined in subdivision (k) of Public Resources Code Section 5020.1 or determined to be significant pursuant to criteria set forth in Public Resources Code Section 5024.1. As indicated in Section

5.4, Cultural Resources, of this Draft Subsequent EIR, no designated or eligible tribal cultural resources, as defined in Section 15064.5 of the CEQA Guidelines, have been identified on the Project Site. Additionally, based on the SCCIC record search and results from the NAHC SLF database, there are no tribal cultural resources on the Project Site that are currently listed on the CRHR. Further, as indicated in the South Environmental report and the HRG report, detailed in Section 5.4, Cultural Resources, the entire Project Site has been significantly disturbed over the last fifty years. Therefore, the Project would not have an impact on tribal cultural resources associated with an impact to a resource that is listed or eligible for listing on the CRHR or a local register.

The project would result in no impact. This impact would be new when compared with the impact analyses in EIR No. 311 and SEIR No. 340, neither of which addressed tribal cultural resources.

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Threshold 5.15b Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is a 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?
New Impact from EIR No. 311; New Impact from SEIR No. 340 – Project Impact Less Than Significant With Mitigation. As previously discussed, neither EIR No. 311 nor SEIR No. 340 directly addressed impacts related to tribal cultural resources.

The second component of this threshold is if the Project would impact “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 Resource Code Section 5024.1.” In making this determination, the lead agency shall consider the significance of the resource to a California Native American tribe.” Subdivision (c) of Public Resource Code Section 5024.1 states:

A resource may be listed as an historical resource in the California Register if it meets any of the following CRHR criteria:
(1) Is associated with events that have made a significant contribution to the broad patterns of California’s history and cultural heritage; (2) Is associated with the lives of persons important in our past; (3) Embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual, or possesses high artistic values; or
(4) Has yielded, or may be likely to yield, information important in prehistory or history.

Based on the South Environmental Development History Report for DisneylandForward, the HRG Report, the information available through the record searches at the SCCIC and the NAHC, and the long-term past development and use of the Project Site for visitor-serving uses, there is no information available that indicates there are significant tribal resources on the Project Site that would be significant pursuant to criteria set forth in subdivision (c) of Public Resource Code Section 5024.1. However, pursuant to state law and SR TCR-1, the City of Anaheim notified the tribes that previously notified the City of a desire to be consulted with regarding projects on the campus.

As stated previously, the City and Gabrieleño Band of Mission Indians – Kizh Nation conducted a consultation regarding tribal cultural resources, exchanging proposed mitigation measures. As of September 6, 2023, no further response regarding the City’s proposed mitigation measure has been received.

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resources on the Project Site, this portion of Orange County was inhabited by Native American tribes. Although there is no documentation fr om the SCCIC or the NAHC of archaeological resources important to Native Americans having been identified near the Project Site, there is always the possibility that undiscovered intact cultural resources, including tribal cultural resources, may be present below the surface in native sediments. To minimize the potential direct impacts, a mitigation measure has been included requiring Native American monitoring during earth-moving and grading activities at depths greater than current foundations. Implementation of Mitigation Measure MM CUL-1 would address unanticipated discovery of archaeological resources, and MM TCR-1 would provide for appropriate protection of tribal cultural resources that may be discovered during construction. Additionally, the Project would comply with SR CUL- 1 regarding discovery of any human remains. Therefore, this impact would be less than significant with mitigation.

5.15.4 CUMULATIVE IMPACTS
As previously discussed, neither EIR No. 311 nor SEIR No. 340 directly addressed impacts related to tribal cultural resources.

Although tribal cultural resources are site-specific with regard to any given resource (e.g., resources of important cultural value to Native Americans), impacts may be considered cumulative simply because they relate to the loss of tribal cultural resources in general over time throughout the region. There are no tribal cultural resources listed or determined eligible for listing, on the national, State, or local register of historical resources on the Project Site. However, should buried resources be identified, ground disturbance within native sediment could lead to the accelerated degradation of previously unknown tribal cultural resources. Mitigation can reduce potential impacts to a less than significant level. As with the Project, testing and data recovery is standard practice in the City and is routinely required of projects prior to and during grading activities. Despite the site-specific nature of cultural resources, the mitigation identified for tribal cultural resources monitoring, standard mitigation measures and adherence to State requirements would reduce the potential for cumulative impacts. As a result, with implementation of MM TCR-1 and MM CUL-1, the Project would not have a cumulatively considerable contribution to a significant cumulative impact related to tribal cultural resources.

The Project would result in a less than significant cumulative impact with mitigation. This impact would be new when compared with the impact analyses in EIR No. 311 and SEIR No. 340, neither of which addressed tribal cultural resources.

5.15.5 MITIGATION PROGRAM
EIR No. 311 and SEIR No. 340 presented mitigation measures (MM), Project Design Features (PDF), and standard requirements (SR) to reduce potential impacts associated with The Disneyland Resort Project and the ARSP Project, respectively. As appropriate, the measure number and section from EIR No. 311 and/or SEIR No. 340 are listed in parentheses.

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Modifications to the original measure are shown as strikethrough for deleted text and bold for new, inserted text.

Mitigation Measures
MM TCR-1 Tribal Cultural Resources Monitoring. Prior to the issuance of any permits allowing ground-disturbing activities that cause excavation to depths greater than current foundations, the property owner/developer or contractor as designee shall provide evidence in the form of an executed Agreement to the City of Anaheim Planning and Building Department that they have retained a qualified Native American tribal monitor to provide third-party monitoring during construction- related ground disturbance activities and to recover and catalogue tribal resources as necessary. The tribal monitor shall be from or approved by the Gabrieleño Band of Mission Indians – Kizh Nation. The agreement shall include (i) professional qualifications of Native American monitor; (ii) detailed scope of services to be provided including but not limited to pre-construction education, observation, evaluation, protection, salvage, notification, and/or curation requirements, as applicable, with final documentation/report to Public Works Inspector; (iii) contact information; (iv) communication protocols between Contractor and Monitor for scheduling to facilitate timely performance; (v) acknowledgment that if the tribal monitor is unavailable or unresponsive based on terms stipulated in the agreement, property owner/developer or contractor as designee may contract with another qualified tribal monitor acceptable to the City. The selection of the qualified professional(s) shall be subject to City acceptance based on generally accepted professional qualifications and certifications, as applicable. The cover sheet of the grading plans shall include a note to identify that third party tribal monitoring is required during excavation and grading activities in accordance with the City- approved Agreement. Contact information for approved tribal monitor shall be provided by the contractor to the City inspector at the pre-construction meeting.

MM CUL-1 Prior to issuance of each grading permit, the property owner/developer shall submit a letter identifying the certified archaeologist that has been hired to ensure that the following actions are implemented:
a. The archaeologist must be present at the pre-grading conference in order to establish procedures for archaeological monitoring, as well as for temporarily halting or redirecting work to permit the sampling, identification, and evaluation of artifacts if potentially significant artifacts are uncovered. Specific monitoring procedures will be established based on review of site specific conditions, including presence of native soils, anticipated construction activities, and nature of ground disturbance including depth of excavation. If artifacts are uncovered and determined to be significant, the archaeological observer shall determine appropriate actions in cooperation with the property owner/developer for exploration and/or salvage.
b. Specimens that are collected prior to or during the grading process shall be donated to an appropriate educational or research institution. c. Any archaeological work at the site shall be conducted under the direction of the certified archaeologist. If any artifacts are discovered during grading operations when the archaeological monitor is not present, grading shall be diverted around the area until the monitor can survey the area.

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d. A final report detailing the findings and disposition of the specimens shall be submitted to the City Engineer. Upon completion of the grading, the archaeologist shall notify the City as to when the final report will be submitted Planning and Building Department within ninety days . (EIR No. 311, MM

3.13-1; SEIR No. 340, MM 5.4-1)

5.15.6 IMPACT SUMMARY
Threshold 5.15a 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 listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k)?
Impact Summary: The project would result in no impact. This impact would be new when compared with the impact analyses in EIR No. 311 and SEIR No. 340, neither of which addressed tribal cultural resources.

Threshold 5.15b Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is a 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 Summary: The Project would result in a less than significant impact with mitigation. This impact would be new when compared with the impact analyses in EIR No. 311 and SEIR No. 340, neither of which addressed tribal cultural resources.

Cumulative Impacts
Impact Summary: The Project would result in a less than significant cumulative impact with mitigation. This impact would be new when compared with the impact analyses in EIR No. 311 and SEIR No. 340, neither of which addressed tribal cultural resources.

5.15.7 REFERENCES
Anaheim, City of. 2012 (last accessed January 4, 2022). Final Environmental Impact Report 340 Amendment No. 14 to the Anaheim Resort Specific Plan and Mitigation Monitoring Program No. 85C. Anaheim, CA: Anaheim. http://anaheim.net/1009/Anaheim-Resort. ———.2010 (May). Citywide Historic Preservation Plan . Anaheim, CA: Anaheim. https://www.anaheim.net/DocumentCenter/View/1485/Citywide-Historic-Preservation- DisneylandForward
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5.15-20 Section 5.15 – Tribal Cultural Resources
Plan-
?bidId=#:~:text=The%20Plan%20is%20intended%20to%20assist%20the%20City%20an d%20its,formal%20designation%2C%20of%20those%20resources. ———. 1996 (last accessed September 14, 2022). The Disneyland Resort Specific Plan Final Environmental Impact Report No. 311 with Addendum and Modified Mitigation Monitoring Program 0067. Anaheim, CA: Anaheim. http://anaheim.net/1017/Disneyland- Resort.
———. 1994 (August). The Anaheim Resort Specific Plan Draft EIR No. 313 with Addendum.

Anaheim, City of: Anaheim, CA. https://anaheim.net/DocumentCenter/View/2494/Master- Environmental -Impact-Report-Number-313-?bidld=
California State Parks, Office of Historic Preservation. 2022. California Register of Historical Resources. Sacramento, CA:
https://ohp.parks.ca.gov/?page_id=21238#:~:text=The%20California%20Register%20pr ogram%20encourages,grant%20funding%20and%20affords%20certain.

Historic Resources Group. 2023 (May). Historic Resources Technical Report, Disneyland Forward. Pasadena, CA: HRG. (Appendix E-2)
South Central Coastal Information Center (SCCIC). 2021 (July 2). Email Correspondence Regarding: Records Search Results for the 3WDI000400 Project. Fullerton, CA: SCCIC. (Appendix E-3)
South Environmental. 2023 (August). Development History Report for the DisneylandForward Project. City of Anaheim, California. Pasadena, CA: South Environmental. (Appendix E-1)

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5.16 UTILITIES AND SERVICE SYSTEMS
This section discusses the existing setting of the Project Site related to utilities and assesses the Project’s potential impacts related to water supply and distribution systems, wastewater collection systems, stormwater collection, electric power, natural gas, solid waste, and telecommunications.

5.16.1 SUMMARY OF PREVIOUS ENVIRONMENTAL DOCUMENTATION
The Disneyland Resort Specific Plan EIR No. 311
Water
The analysis of water service impacts in EIR No. 311 concluded the capacity of the existing water supply system would be exceeded, resulting in a significant impact. However, with implementation of MMs 3.10.6-1 through 3.10.6-9 and PDFs 3.10.6-1 and 3.10.6-2, this impact would be reduced to a level considered less than significant.

Sewer/Wastewater
EIR No. 311 reported that the existing sewer facilities in the area were at capacity and local improvements would be required to accommodate project-related volume increases.

Implementation of the recommended improvements in the City’s South Central Area Sewer Deficiency Study also would be required to accommodate the development of The Disneyland Resort Project in the future. However, the County Sanitation District of Orange County was determined to have adequate treatment plant capacity to serve the project. Implementation of MMs 3.10.7-1 through MM 3.10.7-3 and PDF 3.10.7-1 outlined in EIR No. 311 would reduce all impacts to a level considered less than significant. This mitigation has been implemented.

Stormwater
EIR No. 311 concluded storm drain facilities within the project site would not be sufficient to handle increased storm drain runoff flows. Implementation of MMs 3.10.8-1 through 3.10.8-3 and PDFs 3.10.8-1 through 3.10.8-4 outlined in EIR No. 311 would reduce impacts to storm drain facilities to a level considered less than significant.

Electricity
EIR No. 311 determined that existing electrical facilities were inadequate to accommodate the increased demand for electricity that development of The Disneyland Resort Project would generate. In addition to implementation of MMs 3.10.9-1 through 3.10.9-4 and MMs 3.8-12, a new substation would be required to reduce impacts to a level considered less than significant. 1 Additionally, EIR No. 311 determined the project would contribute to a cumulative impact related to electricity consumption. The Anaheim City Council adopted a Statement of Overriding Considerations with regard to this potential impact.

1 (Note: Environmental equivalency approved on 4/28/98 to reference the approved agreement between the City and the Walt Disney World Company. The 3/18/97 City Council staff report indicated that MMP No. 0067 identified the need to construct a 69kV electric substation on Disney’s property as a mitigation measure to address the impact of the Project on the City’s electric system. Staff determined that service can be provided through the City’s 12kV system, thereby, eliminating the need for the substation.) DisneylandForward
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Natural Gas Service
According to EIR No. 311, Southern California Gas would be able to meet the demand for natural gas created by The Disneyland Resort Project. Implementation of MMs 3.10.10-1 through

3.10.10-2 would reduce impacts to less than significant levels. Additionally, EIR No. 311 determined the project would contribute to a cumulative impact related to natural gas consumption. The Anaheim City Council adopted a Statement of Overriding Considerations with regard to this potential impact.

Solid Waste
In the analysis of impacts related to solid waste, EIR No. 311 identified that the Olinda-Alpha landfill had limited available capacity. For this reason, development of The Disneyland Resort Project would create a significant, unavoidable project and cumulative impact, even with implementation of MMs 3.10.3-1 through 3.10.3-3. The Anaheim City Council adopted a Statement of Overriding Considerations with regard to this potential impact.

Telephone and Cable Television
EIR No. 311 indicated that Pacific Bell would accommodate all increased demand for telephone services associated with development of The Disneyland Resort Project without disrupting existing service. Implementation of MM 3.10.11-1 would reduce impacts to less than significant levels.

EIR No. 311 indicated cable television service would be accommodated without creating a significant impact. Television reception of residents and businesses without cable television might be impacted by construction of projects within the DRSP. However, implementation of MMs 3.10.12-1 would reduce potential impacts to less than significant levels.

EIR No. 311 Mitigation Measures and Project Design Features EIR No. 311 and Modified MMP No. 0067
2 required the following mitigation measures and project design features to reduce potential impacts associated with The Disneyland Resort Project to less than significant levels.

Public Services and Utilities – Water
MM 3.10.6-1 The applicant shall implement all project design features or their environmental equivalent. The City of Anaheim Planning Department will ensure compliance through the mitigation monitoring process.

MM 3.10.6-2 With the exception of the West Parking Area, prior to issuance of each building permit (for non-Setback Realm Areas); prior to approval of Final Site Plan (for Setback Realm Areas); to be implemented prior to final zoning and building inspections (for non-Setback Realm Areas) and prior to acceptance by the City Engineer (for Setback Realm Areas); and continuing on an ongoing basis during project operation; For the West Parking Area: prior to approval of initial building permits for interim condition of a portion of the West Parking Area (for the final landscape plans for the Walnut Street Setback area and for the area adjacent to the Walnut Street soundwall in the private realm); and prior to approval of building permits for the ultimate condition of the West Parking Area (for the final landscape

2 Addendum No. 1 to EIR No. 311, which t he City approved in 1996, modified MMP No. 0067.

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plans for West Street/Disneyland Drive setback landscape, Cerritos Ave. setback landscape, landscaping of entrance to hotels and landscaping interior to hotel and RD&E parking), among the water conservation measures to be shown on plans and implemented by the property owner/developer within the Specific Plan area include the following:
 Use of low-flow sprinkler heads in irrigation system.  Use of waterway re-circulation systems.
 Low-flow fittings, fixtures, and equipment, including low flush toilets and urinals.
 Use of self-closing valves on drinking fountains.
 Use of reclaimed water for irrigation and washdown when it becomes available.  Continuation of the existing cooling tower recirculation system.  Use of efficient irrigation systems such as drip irrigation and automatic systems which use moisture sensors.
 Low-flow shower heads in hotels.
 Water-efficient ice machines, dishwashers, clothes washers, and other water- using appliances.
 Use of irrigation systems primarily at night when evaporation rates are lowest.  Provide information to the public in conspicuous places regarding water conservation.
 Use of water-conserving landscape plant materials wherever feasible.  Use of vacuum and other equipment to reduce the use of water for washdown of exterior areas.
(Note: Environmental equivalents were approved for this measure as follows:

Prior to 10/8/97, environmental equivalent approved to clarify the timing relative to the Setback Realm Areas and non-Setback Realm Areas. It should be noted that this measure will apply to and be monitored with the ultimate landscaping only and not with any interim landscaping condition.

On 10/8/97, environmental equivalent approved to change the timing for the West Parking Area as the SP-4 portion of the West Parking Area will first be developed to accommodate surface parking in an interim condition only. Implementation of this measure for all of the West Parking Area would require substantial portions of the landscaping to be removed in order to implement plans for the ultimate condition of the West Parking Area.

On 7/26/18, environmental equivalent approved which, with the exception of the Planning Department, removed other departments from the “Responsible for Monitoring” Section of this measure as they are not required to review/monitor. It also removed the following language: “(to the extent feasible within the Theme Park District)”.)
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MM 3.10.6-3 Prior to each final zoning and building inspection, the property owner/developer shall submit a certified water audit for landscape irrigation systems except for areas within the Theme Parks.

MM 3.10.6-4 Prior to issuance of the first building permit for the Disneyland Administration Building; to be implemented prior to final building and zoning inspections for the Disneyland Administration Building, the existing 12-inch water main between Ball Road and the southeast corner of the Disneyland Administration Building site will be replaced by the applicant with a new 16-inch diameter main to the satisfaction of the Public Utilities Department.

MM 3.10.6-5 Prior to issuance of the first building permit for Phase II, excluding permits for the demolition or relocation of the existing SCE transmission lines, for construction in the back-of-house area, excluding the Disneyland Administration Building, the existing 12 and 10-inch water mains located between the southeast corner of the Disneyland Administration Building site and Harbor Boulevard north of Manchester Avenue will be replaced with a new 16-inch water main to the satisfaction of the Public Utilities Department.

Note: Implementation of the water improvement required in Condition of Approval #72, which requires a new 16” water main to be constructed in Manchester Avenue/Midway Drive between the Harbor/Manchester intersection and the Anaheim Boulevard/Midway Drive intersection, has been determined as environmentally equivalent to the adopted mitigation measure. (Note: On 2/27/97, environmental equivalent approved to add a note to clarify this measure.)
MM 3.10.6-6 Prior to Issuance of the first building permit for Phase II, excluding permits for demolition or the relocation of the existing SCE transmission lines; to be implemented in accordance with the approved phasing plan, the applicant shall construct or cause to be constructed the following improvements:
a. The existing 8-inch water main in Clementine Street from Katella Avenue to Freedman Way shall be replaced by a 20-inch water main. b. The existing 10-inch water main in Freedman Way from Clementine Street to Harbor Boulevard shall be replaced by a 20-inch water main. c. The existing 10-inch water main in Harbor Boulevard from Katella Avenue to Freedman Way shall be replaced by a 20-inch water main. d. The 12-inch water main in Katella Avenue from Harbor Boulevard to Clementine Street shall be replaced by a 20-inch water main. e. The existing 10-inch water main in Harbor Boulevard from Freedman Way to Harbor Boulevard north of Manchester Avenue shall be replaced by a 16-inch water main.

The City recognizes that these improvements will serve not only the applicant but also other property owners/developers in the Specific Plan area, the, Anaheim Resort and the service area, each of which should contribute its allocable share of the cost of these improvements. To implem ent this requirement as it applies to other property owners/developers in the Specific Plan area, the Anaheim Resort, and the service area, the City shall, and shall make appropriate arrangements with DisneylandForward
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other public agencies, if any, to reimburse the applicant to the extent that its contributions for these improvements exceed the applicant's allocable share of the cost. Such arrangements shall include one or more of the following: (1) creation of integrated financing districts; (2) entry into a reimbursement agreement with the applicant; (3) creation of appropriate community facilities districts, assessment districts, and/or use of similar public financing districts and/or mechanisms; and (4) creation of other such mechanisms or districts as may be appropriate to provide for the reimbursement of these costs. The determination of the allocable share of improvement costs attributable to the applicant and other property owners/developers, and reimbursement amounts, shall be based on an apportionment of the costs of su ch improvements among property owners/developers, including the applicant, in the Specific Plan area, the Anaheim Resort, or otherwise defined service area, as applicable, depending on the area served.

To implement this mitigation measure, the City has adopted the Anaheim Resort Water Facilities Fee Program (Rule 15E of the Water Rates, Rules and Regulations). Compliance with this Fee Program by the property owner/developer (per Resolution No. 95R-140, effective September 1, 1995) shall satisfy the requirements of this Mitigation Measure, or the City may enter into alternative financing arrangements with the applicant.

MM 3.10.6-7 Prior to issuance of the first building permit for Phase II, excluding permits for demolition or the relocation of the existing SCE Transmission lines, the applicant shall submit for review and approval an Engineering Report and Phasing Plan demonstrating the incorporation of a new water supply well in the vicinity of Clementine Street and Freedman Way.

MM 3.10.6-8 Prior to final building and zoning inspections for Phase II, the applicant shall fund or cause to be funded the drilling of a new water supply well in the vicinity of Clementine Street and Freedman Way.

MM 3.10.6-9 Prior to final building and zoning inspections for the Second Theme Park, the applicant shall cause to be constructed the site improvements for the well in the vicinity of Clementine Street and Freedman Way.

The City recognizes that these improvements will serve not only the applicant but also other property owners/developers in the Specific Plan area, the Anaheim Resort, and the service area, each of which should contribute its allocable share of the cost of these improvements. To implement this requirement as it applies to other property owners/developers in the Specific Plan area, the Anaheim Resort, and the service area, the City shall, and shall make appropriate arrangements with other public agencies, if any, to reimburse the applicant to the extent that its contributions for these improvements exceed the applicant's allocable share of the cost. Such arrangements shall include one or more of the following: (1) creation of integrated financing districts; (2) entry into a reimbursement agreement with the applicant; 3) creation or appropriate community facilities districts, assessment districts, and/or use of similar public financing districts and/or mechanisms; and (4) creation of other such mechanisms or districts as may be appropriate to provide for the reimbursement of these costs. The determination of the allocable share of improvement costs attributable to the applicant and other property owners/developers, and reimbursement amounts, shall be based on an apportionment of the costs of su ch improvements among property DisneylandForward
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owners/developers, including the applicant, in the Specific Plan Area, the Anaheim Resort or otherwise defined service area, as applicable, depending on the area served.

The City has adopted the Anaheim Resort Water Facilities Fee Program (Rule 15E of the Water Rates, Rules and Regulations). Compliance with this Fee Program by the property owner/developer (per Resolution No. 95R-140, effective September 1, 1995) shall satisfy the requirements of this mitigation measure. It is noted that the City may require the applicant to provide an advance in accordance with Rule 15E of the Water Rates, Rules and Regulations to complete the site improvements for the new water supply well for which the drilling phase was previously completed under Mitigation Measure No. 3.10.6-8. The City may also enter into alternative financing arrangements with the applicant to ensure that this mitigation measure is implemented.

PDF 3.10.6-2 To be shown on street improvement plans; to be implemented prior to street relocation or final building and zoning inspections for the second theme park, whichever occurs first, with development of the Disneyland Resort, some street rights of way will be relocated, therefore requiring relocation of the utilities. The following improvements are included in the development of the Disneyland Resort:
 The existing 10-inch water main in Cerritos Avenue between Walnut Street and West Street/Disneyland Drive will be abandoned with the proposed realignment of this portion of Cerritos Avenue, and a new 12-inch water main will be installed in the new Cerritos Avenue right-of-way.  The existing 12-inch and 14-inch water mains in West Street/Disneyland Drive will be replaced with a 20-inch water main and relocated with the realignment of the West Street/Disneyland Drive right-of-way.
 An onsite 12-inch dual-feed water main through the proposed Disneyland Resort from the proposed water line in West Street/Disneyland Drive to the proposed water line in Harbor Boulevard will be constructed. The dual-feed system will create two means of water supply to any point fed from this line and will ensure good fire flow protection.

Public Services and Utilities – Wastewater/Sewer
MM 3.10.7-1 The applicant shall implement all project design features or their environmental equivalent. The City of Anaheim Planning Department will ensure compliance through the mitigation monitoring process.

MM 3.10.7-2 Prior to issuance of the first building permit for the Disneyland Administration Building; to be implemented prior to final building and zoning inspection for the Disneyland Administration Building, the applicant shall submit a report indicating that the Administration Building will not increase the sewage flows to Ball Road beyond historic levels. The applicant will upgrade or parallel the existing 10-inch diameter pipe in Winston Road from the Disneyland property line to West Street/Disneyland Drive with an approximate 12-inch diameter pipe. Additionally, an upgrade or parallel pipe to the existing 10-inch diameter pipe in West Street between Winston Road and Cerritos Avenue will be provided.

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MM 3.10.7-3 Prior to the first final building and zoning inspection for Phase II, excluding permits for demolition or the relocation of the existing SCE Transmission Lines, the applicant shall construct or cause to be constructed the following improvements:
 A City' sewer main upgrade line or parallel sewer line to the existing 24-inch sewer main in Katella Avenue, from the existing 27-inch District sewer line at Walnut Street or Ninth Street to Harbor Boulevard.
 A City sewer main upgrade line or parallel sewer line to the existing 15-inch sewer main in Harbor Boulevard from Katella Avenue to Manchester Avenue.

The City recognizes that these improvements will serve not only the applicant but also other property owners/developers in the Specific Plan area, the Anaheim Resort, and the service area, each of which should contribute its allocable share of the cost of these improvements. To implement this requirement as it applies to other property owners/developers in the Specific Plan area, the Anaheim Resort, and the service area, the City shall, and shall make appropriate arrangements with other public agencies, if any, to reimburse the applicant to the extent that its contributions for these improvements exceed the applicant's allocable share of the cost. Such arrangements shall include one or more of the following: (1) creation of integrated financing districts; (2) entry into a reimbursement agreement with the applicant; (3) creation of appropriate community facilities districts, assessment districts, and/or use of similar public financing districts and/or mechanisms; and (4) creation of other such mechanisms or districts as may be appropriate to provide for the reimbursement of these costs. The determination of the allocable share of improvement costs attributable to the applicant and other property owners/developers, and reimbursement amounts, shall be based on an apportionment of the costs of su ch improvements among property owners/developers, including the applicant, in the Specific Plan area, the Anaheim Resort, or otherwise defined service area, as applicable, depending on the area served.

To implement this mitigation measure, the City has adopted the Sewer Impact and Improvement Fee Program for the South Central City Area. Compliance with this Fee Program by the property owner/developer (per Ordinance No. 5490 and Resolution No. 95R-60 dated April 18, 1995) shall satisfy the requirements of this Mitigation Measure, or the City may enter into alternative financing arrangements with the applicant.

PDF 3.10.7-1 To be shown on street improvements plans; to be implemented prior to final building and zoning inspection for the second theme park, with development of the Disneyland Resort, some street rights-of-way will be realigned, therefore requiring concurrent relocation of the sewer line to the proposed rights-of-way as follows:
 Reconstruction of the existing pipeline in West Street/Disneyland Drive when the street alignment is implemented.
 Construction of a 15-inch to 21-inch pipeline in Cerritos Avenue between West Street/Disneyland Drive and Walnut Street when the existing street is abandoned and relocated.
 Construction of a 12-inch pipeline in West Street/Disneyland Drive from Winston Road to Cerritos Avenue.

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Public Service and Utilities – Storm Drains
MM 3.10.8-1 The applicant shall implement all project design features or their environmental equivalent. The City of Anaheim Planning Department will ensure compliance through the mitigation monitoring process.

MM 3.10.8-2 Excluding the relocation of the SCE transmission lines or demolition, a detailed drainage study and plan that identifies either no increase in area historic drainage flows and no changes in area historic drainage patterns, except as already addressed through Project Design Features; or, that identifies additional drainage improvements to meet multi-year storm design frequency discharges for Phase II and Phase III improvements and to protect property in the event of a 100 year storm design frequency shall be submitted for review and approval.

It is noted that the City has adopted the Storm Drain Impact and Improvement Fee Program for the South Central City Area. Compliance with this Fee Program by the property owner/developer (per Ordinance No. 5491 and Resolution No. 95R-61 dated April 18, 1995) shall satisfy the requirements of this Mitigation Measure, or the City may enter into alternative financing arrangements with the applicant.

MM 3.10.8-3 Prior to approval of a grading plan for the South Parking Area; to be implemented prior to the first final building and zoning inspection for the South Parking Area, the applicant shall construct or cause to be constructed detention/retention facilities in the South Parking Area to ensure that the storm water runoff from the Future Expansion District does not increase area historic drainage flows and does not alter historic drainage patterns.
(Note: Environmental equivalent approved prior to 3/98 which changed timing to reflect that the grading plan was the appropriate plan with which to first monitor this measure).

PDF 3.10.8-1 To be shown on street improvement plans; to be implemented prior to final building and zoning inspections for the second theme park, if the proposed runoff will be discharging at or below area historic levels, and consistent with area historic patterns, The Disneyland Resort tributary to the Katella Avenue drainage basin will not be required to implement drainage main line infrastructure improvements.

Detention/retention facilities of storm runoff may be considered in the final design phase of the overall public system; however, such proposed detention/retention facilities must have maintenance guarantees and would be required to meet strict design criteria so that they may function properly in multi-year storm design frequencies.

PDF 3.10.8-2 To be shown on street improvement plans; to be implemented prior to final building and zoning inspection for the second theme park, due to the proposed relocation of the portion of Cerritos Avenue between Walnut Street and West Street/Disneyland Drive, the existing storm drain lines in this part of Cerritos Avenue will be abandoned. As part of the reconstruction of Cerritos Avenue, a new storm drain line will be installed from West Street/Disneyland Drive within the new right-of-way to Walnut Street, and then in existing right-of-way along Walnut Street and Cerritos Avenue to the ABC Channel.

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PDF 3.10.8-3 To be shown on street improvement pl ans; to be implemented prior to final building and zoning inspection for the second theme park, due to the lowering of a portion of West Street/ Disneyland Drive, a new storm drain line with a pump system shall be constructed to pump water from the sump area to the proposed Cerritos Avenue storm drain line.

PDF 3.10.8-4 To be shown on street improvement plans ; to be implemented prior to final building and zoning inspection for the second theme park, storm drain laterals are required as part of normal street construction and are listed as follows: New storm drain laterals will be constructed in West Street/Disneyland Drive north of Katella Avenue to drain runoff to Katella Avenue; in West Street/Disneyland Drive north of the realigned Cerritos Avenue to drain runoff to Cerritos Avenue; and, in Walnut Street north of existing Cerritos Avenue; and in Walnut Street north of Katella Avenue to drain runoff to Katella Avenue. All will be designed in compliance with the Master Plan of Drainage for the South Central City Area.

Public Services and Utilities – Electricity
MM 3.10.9-1 The applicant shall implement all project design features or their environmental equivalent. The City of Anaheim Planning Department will ensure compliance through the mitigation monitoring process.

MM 3.10.9-2 Prior to issuance of each building permit, t he property owner/developer shall submit plans showing that each of the project's buildings will comply with the State Energy Conservation Standards for New Residential and Nonresidential Buildings (Title 24, Part 6, Article 2, California Code of Regulations).

MM 3.10.9-3 Prior to issuance of the first building permit for Phases II and III, the applicant shall enter into the agreement with the City (dated March 18, 1997) to meet the increased electrical demands for opening day (June 30, 2001) of The Disneyland Resort.
(Note: Environmental equivalency approved on 4/28/98 to reference the approved agreement between the City and the Walt Disney World Company. The 3/18/97 City Council staff report indicated that MMP No. 0067 identified the need to construct a 69kV electric substation on Disney’s property as a mitigation measure to address the impact of the Project on the City’s electric system. Staff determined that service can be provided through the City’s 12kV system, thereby, eliminating the need for the substation. The City subsequently amended its Electric Rates, Rules and Regulations to allow the City to recover electric upgrade costs without the need for a service agreement which superseded the need for this equivalency.) MM 3.10.9-4 Prior to Issuance of Building Permit for the undergrounding of the SCE 220kV Electrical Lines, if the SCE 220kV electrical lines are to be undergrounded, then a leak response/safety plan shall be submitted for review and approval and will include, at a minimum, the following information:
a. Leak and spill procedure
b. Location of absorbent materials and containers
c. Storage and handling procedures
d. First aid measures
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The plan shall outline the procedures for responding to a leak or other events identified by the Fire Department.

PDF 3.10.9-1 Prior to final building and zoning inspection for the second theme park, the Southern California Edison transmission lines that cross the existing Disneyland South Parking Lot will be relocated, with the 66kV lines undergrounded and the 220KV lines in an aerial configuration.

PDF 3.10.9-1aPrior to final building and zoning inspection for the second theme park, coordinate with the Southern California Edison Company for the relocation of the 220 kV lines and 66kV lines presently crossing the existing Disneyland theme park parking lot.

PDF 3.10.9-2 Prior to issuance of each building permit; to be implemented prior to each final building and zoning inspection, in order to conserve energy, the Disneyland Resort shall implement numerous energy saving practices in compliance with Title 10, which may include the following:
 Consultation with the City energy-conservation experts for assistance with energy-conservation design features.
 Use of high-efficiency air conditioning systems controlled by a computerized management system including features such as a variable air volume system, a 100-percent outdoor air economizer cycle, sequential operation of air conditioning equipment in accordance with building demands, isolation of air conditioning to any selected floor or floors.
 Use of electric motors designed to conserve energy.
 Use of special lighting fixtures such as motion sensing lightswitch devices and compact fluorescent fixtures in place of incandescent lights.  Use of T8 lamps and electronic ballasts. Metal hallide or high-pressure sodium for outdoor lighting and parking lots.

PDF 3.10.9-3 At time that relocated 220 kV transmission lines are placed in service, the 220KV transmission lines will use cross-phasing and/or use other reasonable methods agreed to by SCE in the aerial alignment to minimize EMF levels.

Public Services and Utilities – Natural Gas
MM 3.10.10-1 Prior to issuance of each building permit, the property owner/developer shall submit plans which shall ensure that buildings are in conformance with the State Energy Conservation Standards for nonresidential building (Title 24, Part 6, Article 2, California Administrative Code).

MM 3.10.10-2 Prior to approval of each final building and zoning inspection, the Southern California Gas Company has developed several programs which are intended to assist in the selection of most energy-efficient water heaters and furnaces. The property owner/developer shall implement a program, as required, to reduce the demand on natural gas supplies.

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Public Services and Utilities – Solid Waste
MM 3.10.3-1 The applicant shall implement all project design features or their environmental equivalent. The City of Anaheim Planning Department will ensure compliance through the mitigation monitoring process.

MM 3.10.3-2 For the second theme park, prior to opening day, except where solid waste recycling facilities are required for operation of facility prior to opening day (in which case solid waste recycling facilities will be provided prior to final building and zoning inspections); and for the remainder of the Disneyland Resort, prior to final zoning and building inspections; Excluding the relocation of SCE transmission lines, the Disneyland Administration Building and demolition, the property owner/developer shall submit project plans to the Director of Maintenance for review and approval to ensure that the plans comply with AB 939, the Solid Waste Reduction Act of 1989, as implemented by the City of Anaheim, the County of Orange Integrated Waste Management Plan, and the City of Anaheim Integrated Waste Management Plan, administered by the Department of Maintenance. (Note: Environmental equivalent approved on 12/7/99 to change the timing for this mitigation measure as the majority of Disney’s California Adventure will not be open to the public nor occupied by employees of Disneyland prior to Opening Day, and therefore, will not be generating solid waste. With respect to the remainder of The Disneyland Resort, solid waste management facilities will be provided as part of the Certificate of Occupancy process, after which time facilities will be occupied and therefore generating solid waste.

Mitigation measure also references “Director of Maintenance”. This has been changed to Director of Public Works, inasmuch as City Maintenance functions are now overseen by the Public Works Department. Additionally, the Department of Maintenance reference in the mitigation measure has been changed to Department of Public Works, Streets and Sanitation Division).

MM 3.10.3-3 Prior to final zoning and building inspection; to be implemented during operation of the theme parks, a solid waste management plan shall be submitted for review and approval by the applicant for the Disneyland Resort theme parks to ensure that the project plans comply with AB 939, as administered by the City of Anaheim, and the County’s and City’s Integrated Waste Management Plans. Waste management mitigation measures that s hall be taken to reduce solid waste generation shall include:
a. Detailing the locations and design of back-of-house recycling facilities. b. Complying with all Federal, State, and City regulations for hazardous material disposal.
c. Continuing participation in the City’ of Anaheim’s voluntary “Recycle Anaheim,” program or other substitute program as may be developed by the City.

In order to meet the requirements of the Solid Waste Reduction Act of 1989 (AB 939), the applicant shall implement numerous solid waste reduction programs at the Disneyland Resort, including:
 Facilitating paper recycling by providing chutes or convenient locations for sorting and recycling bins.

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 Facilitating cardboard recycling (especially from retail areas) by providing adequate space and centralized locations for collections and baling.  Facilitating glass recycling (especially from restaurants) by providing adequate space for sorting and storing.
 Providing trash compactors for nonrecyclable materials whenever feasible to reduce the total volume of solid waste and the number of trips required for collection.
 Prohibition of curbside pick-up within Disneyland Resort.

PDF 3.10.3-1 Prior to final building and zoning inspections for the second theme park; and continuing on an ongoing basis during project operation, the existing solid waste recycling and waste minimization practices at the Disneyland theme park shall be expanded as feasible to serve the Disneyland Resort. Existing practices include:
 Usage of recycled paper products for stationary, letterhead, and packaging.  Recovery of materials such as aluminum and cardboard.  Collection of office paper for recycling.
 Collection of polystyrene (foam) cups for recycling.
 Collection of glass, plastic, kitchen grease, laser printer, toner, cartridges, oil, batteries, and scrap metal for recycling or recovery.

Public Service and Utilities – Television
MM 3.10.12-1 Prior to issuance of first building permit; and six months after topping out for Phase II and Phase III of the Disneyland Resort, excluding the Disneyland Administration Building, a pre-project study of area television reception shall be undertaken by the applicant to determine baseline conditions. After topping out for Phase II and Phase III of the Disneyland Resort, a follow up study of area television reception shall be undertaken immediately by the applicant. If the City of Anaheim determines that the proposed project creates a significant impact on broadcast television reception at local residences, a signal booster or relay system shall be installed on the roof of the tallest project building to restore broadcast television reception to its original condition as soon as practicable.

Anaheim Resort Specific Plan Subsequent EIR No. 340
Water
SEIR No. 340 identified that buildout of the ARSP would exceed capacities of existing water facilities; however, this impact would be mitigated to a less than significant level. Further, the projected water demand associated with buildout of the ARSP would be accommodated through existing and projected supplies. Implementation of MMs 5.15-1 through 5.15-9 would ensure water conservation measures would be incorporated into future development to ensure that water supplies remain reliable into the future.

Sewer/Wastewater
According to SEIR No. 340, the sewer treatment requirements of the Santa Ana Regional Water Quality Control Board (RWQCB) would not be exceeded by buildout of the ARSP. SEIR No. 340 DisneylandForward
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identified that buildout of the ARSP would increase sewage flows in existing sewer lines and trunks serving the area, resulting in several sewer lines becoming deficient; however, this impact would be mitigated to a less than significant level through implementation of MM 5.16-1.

Additionally, it was determined that buildout of the ARSP evaluated in SEIR No. 340 would increase sewage flows by approximately 323,656 gallons per day (gpd) in the PR District and

2.1 million gallons per day (mgd) in the C-R District and that these increases in sewage flow would be accommodated by available capacity at Orange County Sanitation District (OCSD) Treatment Plant No. 1.

Electricity
According to SEIR No. 340, buildout of the ARSP area would result in an increased demand for electricity. Compliance with the standard requirements and implementation of MMs 5.17-1 through 5.17-4 would reduce anticipated demand through conservation efforts. It is expected that the existing electrical distribution system and future planned improvements would adequately accommodate the anticipated demand, thus resulting in a less than significant impact with mitigation.

Stormwater
According to SEIR No. 340, buildout of the ARSP has the potential to worsen several existing deficiencies in the City’s storm drain system. However, participation in the City’s Master Plan of Storm Drains and related Infrastructure Improvement (Fee) Program would assist in mitigating existing and future storm drainage system deficiencies. Additionally, implementation of the MMs

5.18-1 through 5.18-3 would ensure that impacts to regional flood control facilities associated with buildout of the ARSP would be reduced to less than significant levels.

As discussed in SEIR No. 340, although all new growth within the ARSP area would occur in compliance with identified mitigation, the City has no control over the growth and storm water contributions of areas outside of its jurisdiction. It was determined that any addition of storm water to the regional storm water system may be cumulatively considerable when combined with potential storm water flow increases from surrounding jurisdictions and the potential cumulative impact could be significant and unavoidable if development in the surrounding jurisdictions occurs without upgrades to the storm water infrastructure. The Anaheim City Council adopted a Statement of Overriding Considerations with regard to this potential impact.

Natural Gas
According to SEIR No. 340, Southern California Gas Company (SCGC) indicated that natural gas service to the ARSP can be provided from an existing gas main that is accessible from various locations in the ARSP area. The service would be provided in accordance with the SCGC’s policies and extension rules on file with the California Public Utilities Commission. Therefore, the ARSP would be served by existing facilities, and no new systems or substantial alterations would be required.

Solid Waste
Buildout of the ARSP would generate an estimated 109,514 pounds of solid waste per day or approximately 19,986 tons of solid waste annually. Buildout of the ARSP would add approximately 19,986 tons of solid waste annually to existing solid waste facilities and capacity, which would impact the landfill system. However, the buildout of the ARSP could be accommodated within the permitted capacity of the County’s landfill capacity. In addition, once the Alpha Olinda Landfill closes in 2021, capacity would exist for buildout of the ARSP in the Frank R. Bowerman Landfill.

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No significant impacts would occur, and no mitigation would be required; however, implementation of MM 5.19-1 through 5.19-5 would further ensure that adequate solid waste services would be provided and that solid waste generation would be minimized.

Telephone and Cable Television
AT&T would serve the ARSP area. According to SEIR No. 340, it was determined that AT&T can provide telephone, digital cable, and high-speed internet services and that the ARSP area can be served by Time Warner Cable with the existi ng cable resources available to the site. The infrastructure capacity for telephone service ty pically expands with new development. Facilities needed to connect the ARSP area to the existing telephone system may include new conduit, fiber and copper facilities. These improvements would be implemented in accordance with applicable State and local regulations. According to SEIR No. 340, the impact related to additional demand for telephone service would be less than significant.

SEIR No. 340 Mitigation Measures and Standard Requirements SEIR No. 340 required implementation of the following mitigation measures and compliance with standard requirements regarding utilities and service systems to reduce potential impacts associated with full buildout of the ARSP to less than significant levels.

Water Supply and Infrastructure
MM 5.15-1 Prior to issuance of each building permit (to be implemented prior to final building and zoning inspections, and continuing on an on-going basis during project operation), the property owner/ developer shall submit to the Planning and Building Department plans for review and approval which shall ensure that water conservation measures are incorporated. The water conservation measures to be shown on the plans and implemented by the property owner/developer, to the extent applicable include, but are not limited to, the following:
a. Use of low-flow sprinkler heads in irrigation systems. b. Use of waterway recirculation systems.
c. Low-flow fittings, fixtures, and equipment, including low flush toilets and urinals.
d. Use of self-closing valves on drinking valves.
e. Use of efficient irrigation systems such as drip irrigation and automatic systems which use moisture sensors.
f. Use of low-flow shower heads in hotels.
g. Water efficient ice-machines, dishwashers, clothes washers and other water- using appliances.
h. Use of irrigation systems primarily at night when evaporation rates are lowest. i. Provide information to the public in conspicuous places regarding water conservation.
j. Use of water conserving landscape plant materials wherever.

MM 5.15-2 Prior to issuance of each building permit, all water supply planning for the project will be closely coordinated with, and be subject to the review and final approval of, the Utilities Department, Water Engineering Division and Fire Department.

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MM 5.15-3 Prior to issuance of each building permit, water pressure greater than 80 pounds per square inch (psi) shall be reduced to 80 psi or less by means of pressure reducing valves installed at the property owner/developer’s service.

MM 5.15-4 Prior to the issuance of each building permit, the property owner/developer shall submit a landscape and irrigation plan which shall be prepared and certified by a licensed landscape architect. The irrigation plan shall specify methods for monitoring the irrigation system. The system shall ensure that irrigation rates do not exceed the infiltration of local soils, that the application of fertilizers and pesticides do not exceed appropriate levels of frequencies, and that surface runoff and overwatering is minimized. The landscaping and irrigation plans shall include water-conserving features such as low flow irrigation heads, automatic irrigation scheduling equipment, flow sensing controls, rain sensors, soil moisture sensors, and other water-conserving equipment. The landscaping and irrigation plans shall indicate that separate irrigation lines for recycled water shall be constructed and recycled water will be used when it becomes available. All irrigation systems shall be designed so that they will function properly with recycled water.

MM 5.15-5 Prior to approval of the Final Site Plan and building permits, plans shall specifically show that the water meter and backflow equipment and any other large water system equipment will be installed to the satisfaction of the Public Utilities Department, Water Engineering Division, aboveground and behind the building setback line in a manner fully screened from all public streets and alleys and in accordance with Ordinance No. 4156. Prior to the final building and zoning inspections, the water meter and backflow equipment and any other large water system equipment shall be installed to the satisfaction of the Public Utilities Department, Water Engineering Division, in accordance with the Final Site Plan and the building permit plans.

MM 5.15-6 Prior to issuance of each building permit, unless records indicate previous payment, the appropriate fees for Primary Mains, Secondary Mains and Fire Protection Service shall be paid to the Public Utilities Department, Water Engineering Division in accordance with Rule 15A, and Rule 20 of the Public Utilities Department Water Rates, Rules and Regulations.

MM 5.15-7 Prior to final building and zoning inspections, a separate water meter shall be installed for landscape water on all projects where the landscape area exceeds 2,500 square feet in accordance with Ordinance No. 6160.

MM 5.15-8 Prior to the issuance of the first building permit or grading permit, whichever occurs first, the property owner/developer shall comply with Rule 15E of the Public Utilities Department Water Rates, Rules, and Regulations. Rule 15E shall be amended to include:
a. Construction of a new well with a minimum 1,500 GPM capacity to serve The Anaheim Resort Area (tentative location near Ponderosa Park and Orangewood Avenue); and
b. Construction of a new 16-inch water main along Harbor Boulevard from Orangewood to Chapman Avenue.)
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MM 5.15-9 Ongoing, the City shall continue to collaborate with the Metropolitan Water District of Southern California (MWD), its member agencies, and the Orange County Water District (OCWD) to ensure that available water supplies meet anticipated demand. If it is forecasted that water demand exceeds available supplies, staff shall recommend to City Council to trigger application of the Water Conservation Ordinance (Anaheim Municipal Code, §10.18), as prescribed, to require mandatory conservation measures as authorized by Sections 10.18.070 through

10.18.090, as appropriate.

SR 5.15-1 Prior to the issue of each building permit, the property owner/developer shall be required to prepare and submit to the City for review and approval (1) a Landscape Documentation Package and (2) landscape and irrigation plans with appropriate water use calculations in accordance with the requirements of Anaheim Municipal Code Chapter 10.19, Landscape Water Efficiency.

Sewer
MM 5.16-1 Prior to approval of a final subdivision map or issuance of a grading or building permit, whichever occurs first, the property owner/developer shall participate in the City’s Master Plan of Sewers and related Infrastructure Improvement (Fee) Program to assist in mitigating existing and future sanitary sewer system deficiencies as follows:

The property owner/developer shall submit a report for review and approval of the City Engineer to assist in determining the following:
a. If the development/redevelopment (1) does not discharge into a sewer system that is currently deficient or will become deficient because of that discharge and/or (2) does not increase flows or change points of discharge, then the property owner’s/developer’s responsibility shall be limited to participation in the Infrastructure Improvement (Fee) Program.
b. If the development/redevelopment (1) disc harges into a sewer system that is currently deficient or will become deficient because of that discharge and/or (2) increases flows or changes points of discharge, then the property owner/developer shall be required to guarantee mitigation to the satisfaction of the City Engineer and the City Attorney of the impact prior to approval of a final subdivision map or issuance of a grading or building permit whichever occurs first, pursuant to the improvements identified in the South Central Area Sewer Deficiency Study. The property owner/developer shall be required to install the sanitary sewer facilities, as recommended by the South Central Area Sewer Deficiency Study, prior to acceptance for maintenance of public improvements by the City or final building and zoning inspections for the building/structure, whichever comes first. Additionally, the property owner/developer shall participate in the Infrastructure Improvement (Fee) Program, as determined by the City Engineer, which may include fees, credits, reimbursements, or a combination thereof. As part of guaranteeing the mitigation of impacts for the sanitary sewer system, the property owner/developer shall submit a sanitary sewer system improvement phasing plan for the project to the City Engineer for review and approval which shall contain, at a minimum, (1) a layout of the complete system, (2) all facility sizes, including support calculations, (3) construction phasing, and (4) construction estimates.

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The study shall determine the impact of the project sewer flows for total build out of the project and identify local deficiencies for each project component (i.e., each hotel).

SR 5.16-1 Prior to issuance of building permits, the property owner/developer shall provide evidence to the Planning Director/Planning Services Manager that all sewage and wastewater disposal into the sewer system shall comply with OCSD’s Wastewater Discharge Regulations, including the procurement of the necessary permits by food service establishments that would be developed in the ARSP area.

SR 5.16-2 Prior to issuance of building permits, the property owner/developer shall provide proof of payment to the Planning Director/Planning Services Manager for a sanitary sewer service charge to OCSD.

SR 5.16-3 Prior to issuance of building permits, the property owner/developer shall provide proof of payment to the Planning Director/Planning Services Manager for a capital facilities connection charge to OCSD.

Electricity
MM 5.17-1 Prior to issuance of each building permit, the property owner/developer shall consult with the City of Anaheim Public Utilities Department, Business and Community Programs Division in order to review energy efficient measures to incorporate into the project design. Prior to the final building and zoning inspection, the property owner developer shall implement these energy efficient measures which may include the following:
a. High-efficiency air-conditioning systems with EMS (computer) control b. Variable air volume (VAV) distribution
c. Outside air (100%) economizer cycle
d. Staged compressors or variable speed drives to flow varying thermal loads e. Isolated HVAC zone control by floors/separable activity areas f. Specification of premium-efficiency electric motors (i.e., compressor motors, air-handling units, and fan-coil units)
g. Use of occupancy sensors in appropriate spaces
h. Use of compact fluorescent lamps
i. Use of cold cathode fluorescent lamps
j. Use of light emitting diode (LED) or equivalent energy-efficient lighting for outdoor lighting
k. Use of Energy Star® exit lighting or exit signage.
l. Use of T-8 lamps and electronic ballasts where applications of standard fluorescent fixtures are identified
m. Use of lighting power controllers in association with metal-halide or high pressure sodium (high intensity discharge) lamps for outdoor lighting and parking lots
n. Consideration of thermal energy storage air-conditioning for spaces or facilities that may require air-conditioning during summer, day-peak periods.

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o. For swimming pools and spas, incorporate solar heating, automatic covers, and efficient pumps and motors, as feasible.
p. Consideration for participation in Advantage Services Programs such as:
i. New construction design review, in which the City cost-shares engineering for up to $10,000 for design of energy efficient buildings and systems
ii. New Construction – cash incentives ($300 to $400 per kW reduction in load) for efficiency that exceeds Title 24 requirements iii. Green Building Program – offers accelerated plan approval, financial incentives, waived plan check fees and free technical assistance.

MM 5.17-2 Prior to final building and zoning inspection, the property owner/developer shall install an underground electrical service from the Public Utilities Distribution System. The Underground Service will be installed in accordance with the Electric Rules, Rates, Regulations and Electrical Specifications for Underground Systems.

Electrical Service Fees and other applicable fees will be assessed in accordance with the Electric Rules, Rates, Regulations and Electrical Specifications for Underground Systems.

MM 5.17-3 Prior to issuance of each building permit, the property owner/developer shall submit plans and calculations to the City of Anaheim Planning and Building Department, Building Division, to demonstrate that the energy efficiency of each building will exceed the Title 24 Energy Efficiency Standards for Residential and Non-residential Buildings current at the time of application by at least 10 percent.

MM 5.17-4 Prior to approval of a Final Site Plan, the property owner/developer shall coordinate with the Public Utilities Department to incorporate feasible renewable energy generation measures into the project. These measures may include but not be limited to use of solar and small wind turbine sources on new and existing facilities and the use of solar powered lighting in parking areas.

SR 5.17-1 Prior to issuance of building permits, the property owner/developer shall be required to demonstrate to the Planning Department, Building Division that building plans meet the applicable Title 24 Energy Efficiency Standards for Residential and Nonresidential Buildings (24 CCR 6). These standards are updated, nominally every three years, to incorporate improved energy efficiency technologies and methods. The 2008 standards, which were applicable January 1, 2010, are approximately 15 percent more energy efficient than the 2005 Building and Energy Efficiency Standards.

SR 5.17-2 Prior to issuance of building permits, the property owner/developer shall be required to demonstrate to the Planning Department, Building Division that building plans meet the applicable California Green Building Standards (24 CCR 11).

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Stormwater
MM 5.18-1 Prior to approval of a final subdivision map, or issuance of a grading or building permit, whichever occurs first, the property owner/developer shall participate in the City’s Master Plan of Storm Drains and related Infrastructure Improvement (Fee) Program to assist in mitigating existing and future storm drainage system deficiencies as follows:

The property owner/developer shall submit a report for review and approval by the City Engineer to assist with determining the following:
a. If the specific development/redevelopment does not increase or redirect current or historic storm water quantities/flows, then the property owner/developer’s responsibility shall be limited to participation in the Infrastructure Improvement (Fee) Program to provide storm drainage facilities in 10- and 25-year storm frequencies and to protect properties/structures for a 100-year storm frequency.
b. If the specific development/redevelopment increases or redirects the current or historic storm water quantity/flow, then the property owner/developer shall be required to guarantee mitigation to the satisfaction of the City Engineer and City Attorney’s office of the impact prior to approval of a final subdivision map or issuance of a grading or building permit, whichever occurs first, pursuant to the improvements identified in the Master Plan of Drainage for the South Central Area. The property owner/developer shall be required to install the storm drainage facilities as recommended by the Master Plan of Drainage for the South Central Area to provide storm drainage facilities for 10- and 25-year storm frequencies and to protect properties/structures for a 100-year storm frequency prior to acceptance for maintenance of public improvements by the City or final building and zoning inspection for the building/structure, whichever occurs first. Additionally, the property owner/developer shall participate in the Infrastructure Improvement (Fee) Program as determined by the City Engineer which could include fees, credits, reimbursements, or a combination thereof.

As part of guaranteeing the mitigation of impacts on the storm drainage system, a storm drainage system improvement phas ing plan for the project shall be submitted by the property owner/developer to the City Engineer for review and approval and shall contain, at a minimum, (1) a layout of the complete system; (2) all facility sizes, including support calculations; (3) construction phasing; and, (4) construction estimates.

MM 5.18-2 Ongoing, the City shall work with the Orange County Flood Control District (OCFCD) to ensure that flood control facilities are well maintained and capable of accommodating, at a minimum, future 25-year storm flows for City-owned and maintained facilities, and 100-year storm flows for County facilities. Where improvements to local drainage facilities have the potential to increase discharges to County facilities, the City shall analyze potential impacts to County facilities in consultation with the Manager, County of Orange Flood Control Division.

Encroachment Permits shall be obtai ned from the County’s Public Property Permits Section for any activity performed within OCFCD’s right of way.

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MM 5.18-3 Prior to the issuance of building permits, t he City shall require that building plans indicate that new developments will minimize stormwater and urban runoff into drainage facilities by incorporating design features such as detention basins, on- site water features, and other strategies.

OC Waste & Recycling
MM 5.19-1 Prior to issuance of each building permit; to be implemented prior to final building and zoning Inspection, the property owner/developer shall submit project plans to the Public Works Department for review and approval to ensure that the plans comply with AB 939, the Solid Waste Reduction Act of 1989, as administered by the City of Anaheim and the County of Orange and City of Anaheim Integrated Waste Management Plans. Prior to final building and zoning inspection, implementation of said plan shall commence and shall remain in full effect. Waste management mitigation measures that s hall be taken to reduce solid waste generation include, but are not limited to:
a. Detailing the location and design of on-site recycling facilities. b. Providing on-site recycling receptacles to encourage recycling. c. Complying with all Federal, State and City regulation for hazardous material disposal.
d. Participating in the City of Anaheim’s “Recycle Anaheim” program or other substitute program as may be developed by the City.

In order to meet the requirements of the Solid Waste Reduction Act of 1989 (AB 939), the property owner/developer shall implement numerous solid waste reduction programs, as required by the Public Works Department, including, but not limited to:
a. Facilitating recycling by providing chutes or convenient locations for sorting and recycling bins.
b. Facilitating cardboard recycling (especially in retail areas) by providing adequate space and centralized locations for collection and storing. c. Facilitating glass recycling (especially from restaurants) by providing adequate space for sorting and storing.
d. Providing trash compactors for non-recyclable materials whenever feasible to reduce the total volume of solid waste and the number of trips required for collection.
e. Prohibiting curbside pick-up.

MM 5.19-2 Ongoing during project operation, the following practices shall be implemented, as feasible by the property owner/developer:
a. Usage of recycled paper products for stationary, letterhead, and packaging. b. Recovery of materials such as aluminum and cardboard. c. Collection of office paper for recycling.
d. Collection of polystyrene (foam) cups for recycling.

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e. Collection of glass, plastics, kitchen grease, laser printer toner cartridges, oil, batteries, and scrap metal for recycling or recovery.

MM 5.19-3 Prior to issuance of building permits, plans shall show that trash storage areas shall be provided and maintained in a location acceptable to the City of Anaheim Department of Public Works, Operations Division. On an ongoing basis, trash storage areas shall be provided and maintained in accordance with approved plans on file with said Department.

MM 5.19-4 Prior to issuance of each building permit, the Property Owner/Developer shall demonstrate that the plans include provisions for the installation of trash and recycle receptacles near all benches and near high traffic areas such as plazas, transit stops and retail and dining establishments.

MM 5.19-5 Prior to issuance of each grading and building permit, the Property Owner/Developer shall submit to the Planning Director or Planning Services Manager for approval a Construction Waste Management Plan that, at a minimum, specifies that at least 75 percent of non-hazardous construction and demolition debris shall be recycled or salvaged and identifies the materials to be diverted from disposal and whether the materials will be sorted on site or co-mingled.

5.16.2 ENVIRONMENTAL SETTING
The following discussion details the existing conditions at the time the City published the NOP for Subsequent EIR No. 352; however, consistent with CEQA’s subsequent review standards, the previously approved projects serve as the baseline for the CEQA analysis, and Draft Subsequent EIR No. 352 compares the effects of the Project changes on the previously approved projects with the effects of the previously analyzed and approved projects, as detailed in EIR No. 311 and SEIR No. 340.

A. Existing Conditions
Water
The City relies on a combination of imported water, local groundwater, and recycled water to meet its water needs. The City works together with two primary agencies, Metropolitan Water District of Southern California (Metropolitan or MWD) and Orange County Water District (OCWD) to ensure a safe and reliable water supply that would continue to serve the community in periods of drought and shortage. The sources of imported water supplies include the Colorado River and the State Water Project (SWP) provided by Metropolitan (Psomas 2023a).

The City’s main source of water supply is groundwater from the Orange County Groundwater Basin (OC Basin). The City has historically relied on approximately 70 percent groundwater (previous 10-year average) and 30 percent imported water under normal conditions. Over the 25--year planning period of the 2020 Urban Water Management Plan (UWMP), groundwater supplies are anticipated to increase to between 80 and 85 percent of total water use. The construction of a Groundwater Treatment Project is underway and all groundwater wells in the City are scheduled to be back online by the end of 2023. Recycled water represents less than 0.2 percent of the City’s total water supply (Psomas 2023a).

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Groundwater Supply
Local groundwater from the OC Basin has been the least costly and most reliable source of water supply for the City. The City has historically relied on the OC Basin for approximately 70 percent of its water supply over the previous 10 years. The City operates 18 active groundwater wells to supply potable water to its customers. Recently, the City has taken 14 wells out of service due to water quality concerns related to contaminants known as p er- and polyfluoroalkyl substances (PFAS). The City is implementing a new Groundwater Treatment Program that would allow the City to remove PFAS to acceptable State mandated levels. This program will keep long-term costs low for customers while also providing high quality drinking water and maintaining a high degree of water supply reliability (Psomas 2023a).

The OC Basin is managed by the OCWD. Pumping from the Basin is managed through a process that uses financial incentives to encourage groundwater producers to pump a sustainable amount of water. The framework for the financial incentives is based on establishing the Basin Production Percentage (BPP), the percentage of each Producer’s total water supply that comes from groundwater pumped from the Basin. Groundwater production at or below the BPP is assessed a Replenishment Assessment (RA), while pumpi ng above the BPP is assessed a Basin Equity Assessment (BEA) in addition to the RA, which is calculated based on Metropolitan's (imported water) rates (Psomas 2023a).

Resolution No. 13-1-6, adopted on January 16, 2013, by the OCWD Board of Directors, stated the District’s goal to develop the necessary supplies and facilities to achieve and maintain a 75 percent BPP, long-term. OCWD’s transition to the 75 percent BPP was due to construction of the Groundwater Replenishment System (GWRS) Initial Expansion Project, which was completed in 2015. This expansion provided an additional 31,000 AFY of water for recharging the groundwater basin. OCWD is in the final stages of constructing a final expansion to increase GWRS treatment capacity to 130 MGD. Currently the BPP is set at 77 percent and with the final expansion of the GWRS to be completed by 2023. It is anticipated that the BPP will increase to as much as 85 percent, with 82 percent assumed in the 2020 UWMP for the planning period from 2025 through 2045 (Psomas 2023a).

Imported Water Supply
The City of Anaheim is one of only three retail member agencies of Metropolitan in Orange County. As a member agency, pursuant to the Metropolitan Act, the City has preferential rights to a certain percentage of water delivered to Metropolitan each year primarily from the State Water Project and/or the Colorado River Aqueduct as well as other Metropolitan supply/storage programs. Being a member agency of Metropolitan puts the City in a better position relative to receiving water directly from Metropolitan, as opposed to other agencies in Orange County which obtain their imported Metropolitan water through MWDOC (Psomas 2023a).

Metropolitan’s 2020 UWMP was developed as part of the 2020 Integrated Water Resources Plan (IRP) planning process. The IRP represents Metropolitan’s comprehensive blueprint for long-term water reliability, including key supply development and water use efficiency goals. The planning and agency coordination for both the UWMP and IRP are carried out concurrently. The 2020 IRP update describes the core water resources that would be used to meet full-service demands at the retail level under foreseeable hydrologic conditions from 2020 through 2045. The foundation of Metropolitan’s resource strategy for achieving regional water supply reliability has been to develop and implement water resources programs and activities through its IRP preferred resource mix. This preferred resource mix includes conservation, local resources such as water recycling and groundwater recovery, Colorado River supplies and transfers, SWP supplies and DisneylandForward
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transfers, in region surface reservoir storage, in-region groundwater storage, out-of-region banking, treatment, conveyance, and infrastructure improvements (Psomas 2023a).

Projected Water Demand
Metered water consumption (demand) was provided by the City for fiscal years (FY) 2018 and 2019. These years were used to evaluate existing demand prior to the pandemic when The Disneyland Resort was in full operation. FY 2019 had the highest demand and was selected to represent existing demand and used to project future demands related to Project buildout. The metered data was separated by major Disneyland Resort property areas: Disneyland Park, Disney’s California Adventure Park, Downtown Disney, Disneyland Hotel, Grand Californian Hotel, Paradise Pier Hotel, and other “Shared” uses located outside of these areas which include surface lots, fire water meters, and irrigation of street medians and parkways. Metered water consumption for FY 2019 is summarized in Table 5.16-1, Existing Water Demand. The water demand for existing land uses within the Project Site was accounted for in the existing demand reported in the City’s 2020 UWMP, along with future demand projected through FY 2045. The existing demand presented in Table 5.16-1 of 2.37 million gallons per day (MGD) equates to an existing annual use of 2,656 acre-feet per year (AFY) (Psomas 2023a).

TABLE 5.16-1

EXISTING WATER DEMAND
Use
FY 2019
Demand (gpd)
Existing
Quantity Units
Factor
(gpd/unit)
Theme Parka 1,567,851 3,193 ksf 491
Downtown Disneyb 90,420 247 ksf
Hotel 552,024 2,825 rooms 195
Shared 160,898 7.3% %
Total 2,371,193
a Estimated 121,500 gpd for TDA subtracted from Theme Park demand data. TDA demand taken from EIR No. 311 based on 270 gpd/ksf for office, cafeteria, and health club.
b Existing square-footage is only partially occupied and included in Theme Park District Retail/Entertainment land use.

Source: Psomas 2023a.

Infrastructure
The Project Site is served by local water lines owned and maintained by the City of Anaheim. As detailed previously, EIR No. 311 and SEIR No. 340 identified certain improvements to the water system that were required to accommodate buildout of The Disneyland Resort and the Disney ARSP Properties. As of November 2022, all re quired improvements have been fully constructed and are operational. These improvements are detailed in Table 5.16-2, Constructed Water System Improvements.

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TABLE 5.16-2

CONSTRUCTED WATER SYSTEM IMPROVEMENTS
Location Improvementa
On-site
930 LF of 16-inch water main from Ball R oad to Southeast corner of Team Disney Administration Building
2,990LF of 12-inch water main from Disneyland Drive to Harbor Boulevard Disneyland Resort to develop piping on-site to use reclaimed water when available Clementine Street 1,280 LF of 20-inch water main from Katella Avenue to Disney Way Disney Way 1,600 LF of 20-inch water main from Harbor Boulevard to Clementine Street Harbor Boulevard 1,300 LF of 20-inch water main from Katella Avenue to Disney Way 2,110 LF of 16-inch water main from Disney Way to Manchester Avenue Katella Avenue 1 580 LF of 20-inch water main from Harbor Boulevard to Clementine Street Well 55 Engineering Report, funding, drilling and equipping of Well at 1713 South Clementine Street Magic Way 1,340 LF of 12-inch water main from Walnut Street to Disneyland Drive Disneyland Drive 3,400 LF of 20-inch water main from Katella Avenue to Magic Way 2,350 LF of 20-inch water main from Magic Way to Ball Road ROW: right-of-way; LF: linear feet
a Plans were approved by the City between 1996 an d 2001, and improvements were constructed by 2001.

Source: Psomas 2023a

Sewer
The Project Site is served by local sewer lines owned and maintained by the City of Anaheim. As detailed previously, EIR No. 311 and SEIR No. 340 identified certain improvements to the sewer system that were required to accommodate buildout of The Disneyland Resort and the Disney ARSP Properties. As of November 2022, all re quired improvements have been fully constructed and are operational. These improvements are detailed in Table 5.16-3, Constructed Sewer System Improvements.

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TABLE 5.16-3

CONSTRUCTED SEWER SYSTEM IMPROVEMENTS
Location Improvementa
Katella Avenue 3,320 LF of 24-inch and 21-inch from 735 feet west of Harbor Boulevard to Walnut Street 679 LF of 21-inch pipe from Harbor Boulevard to west of Harbor Boulevard Harbor Boulevard 706 LF of 18-inch pipe from Katella to the north 2,225 LF of 18-inch pipe from north of Katella to 420 feet south of Manchester 276 LF of 10-inch pipe from Katella to the south to existing pipe West Street/DL Drive 305 LF of 18-inch pipe from Katella to the north 594 LF of 15-inch pipe from 18-inch pipe to the north
Downtown Drive 717 LF of 12-inch pipe north to Ce rritos to tie into existing 18-inch in Cerritos Disneyland Drive 902 LF of 15-inch pipe from Old Cerritos north to Magic Way 808 LF of 10-inch pipe and 12-inch pipe from Ball Road to the north 725 LF of 12-inch pipe from Magic Way to the north
Magic Way 1,210 LF of 18-inch pipe from Disneyland Drive to Walnut Steet ROW: right-of-way; LF: linear feet
a Plans were approved by the City between 1996 and 2001, and improvements were constructed by 2001.

Source: Psomas 2023b

Wastewater from the Project Site is conveyed through sewer trunks and interceptors to two OCSD treatment plants that treat residential, commercial, and industrial wastewater - Plant No. 1 in Fountain Valley and Plant No. 2 in Huntington Beach.

Stormwater
In 1973, the City of Anaheim published a Master Plan of Drainage that divided the City into 43 drainage areas. The Master Plan of Flood Control & Drainage Facilities in Orange County, last revised by Orange County Flood Control District in February 1999, identifies the Anaheim Barber City (ABC) Channel as Facility C03. According to the City of Anaheim Master Plan of Storm Drainage for East Garden Grove Wintersburg Channel Tributary Area (CNC 2006) and City of Anaheim Master Plan of Storm Drainage for Anaheim Barber City Channel Tributary Area (CH2MHill 2009), the Project Site is located within numerous designated drainage areas.

Specifically, the Project Site is located within Drainage Areas 20, 21, 22, and 25. These reports, prepared by the City of Anaheim, evaluate the storm drainage system within the Anaheim Barber City Channel Tributary Area (ABCCTA) and the East Garden Grove Wintersburg Channel Tributary Area (EGGWCTA) in the City of Anaheim in order to identify storm drainage system needs to reduce street flooding within the study area. Runoff from Drainage Areas 20, 21, and 22 discharge into the ABC Channel via inlets and storm drain pipes within the City limits (CNC 2006).

According to the Master Water Quality Management Plan (MWQMP) prepared for The Disneyland Resort, included as Appendix H-1 of this Draft Subsequent EIR, and which addresses the majority of the Project Site, including Disney ARSP Properties, the Project Site primarily drains to the ABC Channel.

Anaheim Barber City Channel Tributary Area
Drainage Area 20
Drainage Area 20 drains approximately 815 acres. A large portion of the Drainage Area is on the eastern side of the I-5 and is generally bound by State College Road on the east, Ball Road on the south, and Vermont Avenue on the east and north. Flow from the east side of the I-5 is carried DisneylandForward
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across the I-5 through two underground conduits al ong Ball Road. The flow is then augmented by the runoff from the portion of Drainage Area 20 west of the I-5. The portion of the Drainage Area west of the I-5 is generally bound by the I-5 on the east, Disneyland Theme Park on the south, Union Pacific Railroad track on the west, and Ball Road on the north. Generally, water flows over land and then through pipes from east to west and discharges directly into the ABC Channel (CNC 2006).

The capacity of the existing facilities ranges from 17 percent to 100 percent of a 10-year storm, which means that at certain locations, the City’s flooded width criteria during 10-, 25-, and 100-year storm events are not met. Improvements to the existing facilities were recommended in order to satisfy the City’s requirement of conveying the 10-year storm event and the flooded width criteria. The improvements consist of parallel stor m drains, relief drains, extensions of existing systems, and replacement of existing facilities (CNC 2006).

Existing Improvements
The major storm drain in Drainage Area 20 runs along Ball Road and discharges directly into the ABC Channel. The storm drain varies from a 36-inch reinforced concrete pipe (RCP) east of East Street to a double 7-foot by 7-foot reinforced concrete box (RCB) at the ABC Channel. Seven storm drain laterals feed into this storm drain within Drainage Area 20. The largest of these laterals is along Harbor Boulevard, which consists of a 90-inch RCP and turns westerly at Ball Road, continues parallel to the storm drain in Ball Road until it crosses the I-5, and then confluences with the storm drain mainline (CNC 2006).

The City’s flooded width criteria are not satisfied along Ball Road, Harbor Boulevard, Turin Avenue, Avocado Street, and Norman Avenue (CNC 2006).

Drainage Area 21
Drainage Area 21 drains approximately 305 acres and is generally bounded by Ball Road on the north, Harbor Blvd and Walnut Street on the east, Katella Avenue on the south and ABC Channel on the west. Generally, water flows over land and then through pipes from east to west and discharges directly into the ABC Channel (CNC 2006).

Existing Improvements
The major storm drain in Drainage Area 21 is a 72-inch RCP and a 48-inch RCP along Cerritos Avenue that both discharge directly into the ABC Channel. The main tributary lateral to this line is a 72-inch RCP in Walnut Avenue. A 42-inch RCP in Magic Way discharges into the Walnut Ave storm drain. The City’s flooded width criteria is not satisfied along Cerritos Avenue between the ABC Channel and Walnut Avenue, along Walnut Avenue between Cerritos Avenue and Magic Way, along Magic Way between Walnut Avenue and Disneyland Drive and along Calle De Las Estrellas between Ninth Street and Hampstead Street (CNC 2006).

Drainage Area 22
Drainage Area 22 drains approximately 940 acres and is generally bound by Lewis Street and the Union Pacific Railroad easement on the east, Katella Avenue on the south, Ninth Street and Walnut Street on the west, and Ball Road on the north. Generally, water flows over land and then through pipes from east to west and drains into the double 8-foot by 8.5-foot RCB storm drain in Katella Avenue (CNC 2006).

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The capacity of the existing facilities ranges from 16 percent to 100 percent of a 10-year storm, which means that at certain locations, the City’s flooded width criteria during a 10-, 25- and 100-year storm event are not met. Improvements to the existing facilities were recommended in order to satisfy the City’s requirement of conveying the 10-year storm event and the flooded width criteria. The improvements consist of parallel stor m drains, relief drains, extensions of existing systems, and replacement of existing facilities (CNC 2006).

Existing Improvements
Presently, the major storm drain system in Drainage Area 22 consists of a 51-inch RCP that originates at Allec Street on Cerritos Avenue and runs west to Anaheim Boulevard, where it turns south in a 60-inch RCP line to Katella Avenue. The line crosses under the I-5 as a private California Department of Transportation (Caltrans) line for this portion of the run. The drain turns west and runs along the northerly side of Katella Avenue to Harbor Boulevard where two parallel 63-inch RCP and 72-inch RCP lines confluence with the main storm drain line on northerly side of Katella Avenue. The main line becomes a 12-foot by 7-foot RCP continuing to the west. Along the way, a 66-inch RCP cross-connector diverts some of the flow from the northerly line to a line running along the southerly side of Katella Avenue; two laterals from Disneyland (66-inch RCP and a 36-inch RCP) join the main northerly line; and another two parallel lines (48-inch RCP and 42-inch RCP) transition together just before confluencing with the main northerly line at Disneyland Drive. The main line continues past Disneyland Drive to the west in a 12.5-foot by

7.5-foot RCB to a point just east of Walnut Street, where it confluences with the southerly Katella Avenue storm drain line (CNC 2006).

The City’s flooded width criteria are not satisfied along Allec Street from Cerritos Avenue to approximately 2,100 feet upstream; Palais Road and Claudina Street; Guinida Lane; Winston Road; Palm Street; Anaheim Boulevard at the I-5; Manchester Avenue between Harbor Boulevard and the I-5; Katella Avenue between Harbor Boulevard and Ninth Street; and Walnut Street (CNC 2006).

East Garden Grove Wintersburg Channel Tributary Area
Drainage Area 25
Drainage Area 25 drains approximately 450 acres and is generally bound by Katella Avenue on the north, the I-5 and Spinnaker Street on the east, Chapman Avenue on the south, and Harbor Boulevard on the west. Generally, water flows over land to streets and then through pipes from northeast to southwest to Chapman Avenue at the Anaheim city limits. The capacity of the existing facilities ranges from 50 percent to 100 percent of a 10-year storm. Also, the City’s flooded width criteria during a 10-, 25-, and 100-year storm event is not satisfied in certain locations.

Improvements to the existing facilities were recommended in order to satisfy the City’s requirement of conveying the 10-year storm event the flooded width criteria. The improvements consist of parallel storm drains, extensions of existing systems, and replacement of existing facilities (CH2MHill 2006).

Existing Improvements
One major storm drain drains Area 25, with six laterals contributing to the flow along the way. This major storm drain begins in Haster Street, just north of Leatrice Lane. The drain runs south, then turns west in Orangewood Avenue, where it continues to Harbor Boulevard. The drain turns south again, and follows Harbor Boulevard to Chapman Avenue. At this point, the drain enters the City of Garden Grove, and turns east on Chapman Avenue, where it eventually outlets into the Oertley storm drain. This drain varies in size from 60-inch to 84-inch RCP, and has a maximum capacity DisneylandForward
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of 280 cfs, which is 66 percent of a 10-year storm. The City’s flooded width criteria during a 25- and 100-year storm event is not satisfied on Harbor Boulevard or on Orangewood Avenue from Clementine Street to Harbor Boulevard (CH2MHill 2006).

Electric Power
The City of Anaheim Public Utilities Department provi des electrical services to the Project Site.

The Public Utilities Board advises the City Council on public utility matters. Primary power supply comes from the Intermountain power plant in Utah and other entitlements in California via the state-regulated transmission network. A combustion turbine generator located at Dowling substation supplies an additional 50 megawatts for peaking requirements. The City’s main receiving substation is located on Lewis Street east of Interstate 5. The existing facilities currently provide adequate service to the Project Site, which is currently served by the Katella, Lewis, and the Southwest substations through 12-kilovolt (kV) distribution circuits and 69-kV transmission lines.

According to Disney, the electricity usage for theme park uses (Disneyland and Disney California Adventure) as of 2019, which is the most current information available pre-COVID-19 pandemic, totaled 184,202,000 kilowatt hours per year (kWh/yr), the electricity usage for hotel uses (the Disneyland Hotel, the Grand Californian, and the Paradise Pier Hotel) totaled 41,068,586 kWh/yr, and the remaining uses (Parking, Downtown Disney, and administration offices) totaled 31,620,627 kWh/yr.

Natural Gas
The Southern California Gas Company (SCGC) is the natural gas provider for the City of Anaheim and has facilities throughout the City and near the Project Site. The availability of natural gas service is based upon present conditions of gas supply and regulatory policies. As a public utility, the SCGC is under the jurisdiction of the California Public Utilities Commission and Federal regulatory agencies (Anaheim 2004b). The Project area is located within an urban area where natural gas service and facilities currently exist.

Solid Waste
The City of Anaheim maintains an exclusive contract with Republic Waste Services of Southern California LLC (Anaheim Disposal) to provide waste hauling services. OC Waste & Recycling provides the landfill resource for Orange County. Solid waste generated from the Project would be disposed of at the Olinda Alpha Landfill, which is part of the Orange County landfill system operated by OC Waste & Recycling. The landfill is located at 1942 North Valencia Avenue in the City of Brea and is permitted to accept up to 8,000 tons of solid waste per day. The landfill currently accepts 7,000 tons per day on average, with a remaining airspace capacity estimated at

17.5 million cubic yards as of October 1, 2020. The Olinda Alpha Landfill is approximately 565 acres with about 453 acres permitted for refuse disposal (CalRecycle 2019a). Opened in 1960, the landfill is scheduled to close in approximately December 2036 and is proposed to be used as a County regional park after landfill closure.

Once the Olinda Alpha Landfill is closed, solid waste from the Project would be directed to the Frank R. Bowerman Landfill (FRB Landfill). The FRB Landfill is located at 11002 Bee Canyon Access Road in Irvine and is approximately 725 acres, of which 534 acres are permitted for disposal. The FRB Landfill can accept 11,500 tons per day with an estimated remaining air space capacity of 205 million cubic yards as of February 29, 2008 (CalRecycle 2019b). The closure date for the FRB Landfill is anticipated in the year 2053.

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The City of Anaheim maintains a comprehensive recycling program with the goal of reducing solid waste by 50 percent (City of Anaheim 2004a). Anaheim Disposal provides all recyclable residential and commercial waste recovery to a Material Recovery Facility (MRF) where recyclable materials are sorted from construction debris.

Telecommunications
Telephone Services in the vicinity of the Project are provided by AT&T. Existing facilities are located in the developed areas surrounding the Project Site.

Spectrum currently provides fiber and coaxial feeds in the Project Site for a variety of services including but not limited to standard and high-definition cable television service, PRI T1 telephony circuit(s), cable television service, high speed internet, and digital telephone service to the Project Site.

B. Regulatory Framework
Water
State
Urban Water Management Planning Act
The Urban Water Management Planning Act (UWMP Act) (California Water Code Sections10610, et. seq.) was enacted in 1983. The UWMP Act applies to municipal water suppliers, such as the City of Anaheim, that serve more than 3,000 customers or that provide more than 3,000 acre feet per year (afy) of water. The UWMP Act requires these suppliers to update their Urban Water Management Plan (UWMP) every five years to demonstrate an appropriate level of reliability in supplying anticipated short-term and long-term water demands during normal, dry, and multiple dry years.

Senate Bill 610 and Senate Bill 221
Senate Bill (SB) 610 amended State law to improve the link between information on water supply availability and certain land use decisions made by cities and counties. 3 Specifically, it requires land use planning entities (in this case, the City of Anaheim), when evaluating certain large development projects, to request an assessment of water supply availability from the water supply entity that would provide water to a project. A water supply assessment (WSA) must be prepared in conjunction with the land use approval process associated with a project and must include an evaluation of the sufficiency of the water supplies available to the water supplier to meet existing and anticipated future demands, including the demand associated with the project in question, over a 20-year horizon that includes normal, single-dry, and multiple dry-years. An SB 610 WSA is required for any “project” that is subject to CEQA and that proposes, among other things, residential development of more than 500 dwelling units.

In addition, SB 221 requires land use planning agencies, such as the City, to include (as a condition in any tentative map that includes a subdivision involving more than 500 dwelling units) a requirement to obtain a written verification from the applicable public water system or, where there is no existing water supplier from a consultant directed by the City, that sufficient water supplies are available for the subdivision. SB 221 also addresses the issue of land use and water

3 SB 610 amended section 21151.9 of the California Public Resources Code , and amended sections 10631, 10656, 10910, 10911, 10912, and 10915 of, repealed section 10 913 of, and added and amended section 10657 of, the California Water Code.

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supply, but at a different point in the planning process than does SB 610. SB 221 requires a City or County to deny approval of a tentative or parcel map if the City or County finds that the project does not have a sufficient, reliable water supply as defined in the bill.

Due to the size of the Project Site, the State of California, through SB 610, requires that a WSA be completed to evaluate the potential effect of the proposed development on current and future water supplies. While the Project would be implemented by numerous individual development projects that may have fewer than the threshold of 500 units (or a water use equivalent of commercial or office square footage) that triggers the preparation of a WSA, collectively the total Project exceeds the threshold. Therefore, a Water Supply Assessment has been prepared to evaluate the impacts of the Project.

SB 1262 – Sustainable Groundwater Management Act
Senate Bill 1262 adopted in September 2016 amends Section 66473.7 of the Government Code to require WSAs to address certain elements regarding groundwater sustainability if the project relies in whole or in part on groundwater as a source of supply.

For a WSA, the portions of SB 1262 that are applicable are as follows:
 For a basin that has not been adjudicated that is a basin designated as high- or medium- priority pursuant to California Water Code Section 10722.4, information regarding the following should be provided:
o Whether the California Department of Water Resources (DWR) has identified the basin as being subject to critical conditions of overdraft pursuant to California Water Code Section 12924.
o If a groundwater sustainability agency has adopted a groundwater sustainability plan or has an approved alternative, a copy of that alternative or plan.

Local
City of Anaheim General Plan, Public Services and Facilities Element The Public Services and Facilities Element of the City of Anaheim General Plan addresses public services and infrastructure, such as fire protection, law enforcement, parks, schools, water, sewer, and storm drain systems. The Element summarizes current and projected water supplies; identifies the City’s water distribution system; and provides goals and policies related to water resources and conservation. Applicable goals and policies from the Public Services and Facilities Element that are related to water and that are applicable to the Project are provided in Table 5.10-1 in Section 5.10, Land Use and Planning, with a project consistency analysis.

City of Anaheim Municipal Code
Water Conservation Ordinance
Chapter 10.18 of the Anaheim Municipal Code provides voluntary and mandatory water restrictions for the City to respond to different degrees of water shortages. Four Water Reduction Plans are defined in Chapter 10.18. Plan I is intended for mild water shortages and encourages voluntary reduction in outdoor irrigation. Plans II through IV include mandatory restrictions for significant to extreme water shortages. Restri ctions include no irrigation runoff, required shutoff nozzles on hoses, no water driveways or sidewalks, prohibit non-circulation fountains, only nighttime irrigation, water service upon request in restaurants, launder linens upon request in hotels, and limited to restricted irrigation days. This ordinance implements and enforces water DisneylandForward
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shortage contingency rules and regulations during periods of water supply shortages and water shortage emergencies to ensure that there is sufficient water for human consumption, sanitation, and fire protection.

Landscape Water Efficiency Ordinance
This ordinance establishes an alternative ordinance acceptable under Executive Order B-29-15 as being at least as effective as the State Model Water Efficient Landscape Ordinance and is to promote the design, installation, and maintenance of landscaping in a manner that conserves regional water resources by ensuring that landscaping projects are not unduly water-needy and that irrigation systems are appropriately designed and installed to minimize water waste.

Sewer/Wastewater
Regional
County Sanitation District Act
Section 4700, et seq . of the California Health and Safety Code is also known as the County Sanitation District Act. This act regulates the formation, operation, and governance of County Sanitation Districts, including the construction, maintenance, and operation of a sewerage system and sewage disposal or treatment plant, a refuse transfer or disposal system, or both. It also authorizes the districts to charge a fee for connection to the sewer system or increases in the strength or quantity of wastewater from a specific parcel or operation. The capital facilities fee shall be sufficient to construct the incremental expansion of the sewer system in order to accommodate the development.

Orange County Sanitation District Wastewater Discharge Regulations In accordance with the Clean Water Act, the General Pretreatment Regulations, and the Porter-Cologne Water Quality Control Act, the Orange County Sanitation District (OCSD) has adopted Wastewater Discharge Regulations to address the types of discharges that may enter into the sewer system. The OCSD requires permits or waivers for specific discharges such as groundwater, surface runoff, or subsurface drainage; industrial wastewater; toxic materials in wastewater; fats, oil, and grease from food service establishments; medical wastes; and sludge subject to prohibitions, on-site treatment, self-monitoring, and reporting requirements.

Liquid waste pumpers must also register with the Orange County Health Care Agency and obtain a Waste Hauler Permit from OCSD for the disposal of septage, chemical toilet, and grease trap wastes at Treatment Plant No. 1.

The regulations include fees and charges for service, connection, permits, violations, and penalties to fund operation and maintenance of the regional sewer system.

Local
City of Anaheim General Plan, Public Services and Facilities Element The Public Services and Facilities Element of the City of Anaheim General Plan addresses public services and infrastructure, such as fire protection, law enforcement, parks, schools, water, sewer, and storm drain systems. The Element shows the sanitary sewer system map and identifies deficiencies in the City’s sewer system. Applicable goals and policies from the Public Services and Facilities Element that are related to sewer services and that are applicable to the DisneylandForward
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Project are provided in Table 5.10-1 in Section 5.10, Land Use and Planning, with a project consistency analysis.

Stormwater
Local
City of Anaheim General Plan, Public Services and Facilities Element The Public Services and Facilities Element of the City of Anaheim General Plan addresses the presence and effectiveness of community resources including public services and infrastructure.

Applicable goals and policies from the Public Services and Facilities Element that are related to storm drain systems and that are applicable to the Project are provided in Table 5.10-1 in Section

5.10, Land Use and Planning, with a project consistency analysis.

Electricity
State
Title 24 Energy Efficiency Standards
The Energy Efficiency Standards for Residential and Nonresidential Buildings (Title 24, Part 6 of the California Code of Regulations [CCR]) were established in 1978 in response to a legislative mandate to reduce California’s energy consumption. Since that time, the energy efficiency standards have undergone several revisions. Effective January 1, 2010, the adopted 2008 Title 24 standards replaced the 2005 Title 24 standards. The California Energy Commission (CEC) adopted the 2008 standards in order to (1) “Provide California with an adequate, reasonably- priced, and environmentally-sound supply of energy” and (2) “Respond to Assembly Bill 32, the Global Warming Solutions Act of 2006, which mandates that California must reduce its greenhouse gas emissions to 1990 levels by 2020” (CEC 2009).

Local
City of Anaheim General Plan, Public Services and Facilities Element The Public Services and Facilities Element of the City of Anaheim General Plan addresses electric utilities (service and facilities) throughout the City. Applicable goals and policies from the Public Services and Facilities Element that are related to electric utilities and that are applicable to the Project are provided in Table 5.10-1 in Section 5.10, Land Use and Planning, with a project consistency analysis.

Natural Gas
Local
City of Anaheim General Plan, Public Services and Facilities Element The Public Services and Facilities Element of the City of Anaheim General Plan addresses private utilities, including natural gas. Applicable goals and policies from the Public Services and Facilities Element that are related to natural gas and that are applicable to the Project are provided in Table 5.10-1 in Section 5.10, Land Use and Planning, with a project consistency analysis.

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Solid Waste
State
California Integrated Waste Management Act (AB 939)
The California Integrated Waste Management Act of 1989 (AB 939) requires all counties to prepare an Integrated Waste Management Plan. The County of Orange has an adopted plan that includes the following mandated components: a Source Reduction and Recycling Element; a Household Hazardous Waste Element; a countywide Siting Element that identifies 15 years of available disposal capacity; and a statement of si gnificant solid waste disposal problems facing the jurisdiction.

The Source Reduction and Recycling Element (SRRE) of the Integrated Waste Management Plan is required by AB 939 to identify how each jurisdiction would meet the mandatory State waste diversion goals of 25 percent by the year 1995 and 50 percent by the year 2000. The purpose of AB 939 was to “reduce, recycle, and re-use solid waste generated in the state to the maximum extent feasible”. Noncompliance with the goals and timelines set forth within AB 939 can be severe, as the bill imposes fines of up to $10,000 per day on jurisdictions (cities and counties) not meeting these recycling and planning goals.

The term “integrated waste management” refers to the use of a variety of waste management practices to safely and effectively handle the municipal solid waste stream with the lowest adverse impact on human health and the environment. AB 939 has established a waste management hierarchy as follows:
 Source Reduction;
 Recycling;
 Composting;
 Transformation; and
 Disposal.

Mandatory Commercial Organics Recycling Bill (SB 1383)
In September 2016, Governor Brown signed SB 1383, establishing methane emissions reduction targets in a Statewide effort to reduce emissions of short-lived climate pollutants (SLCP) in various sectors of California’s economy. Decomposition of organic waste in landfills is a significant source of greenhouse gas (GHG) emissions, particularly methane emissions, contributing to global climate change; and organic waste is the largest waste stream in California. Organic waste includes food, green material, landscape and pruning waste, organic textiles and carpets, lumber, wood, paper products, printing and writing paper, manure, biosolids, digestate, and sludges.

SB 1383 established the following organic waste reduction targets: 75 percent reduction of organic waste disposal in landfills and 20 percent recovery of currently wasted edible food by 2025. This law complements and expands upon the goals of AB 341 (Mandatory Commercial Recycling) and AB 1826 (Mandatory Commercial Organics Recycling).

On January 1, 2022, SB 1383 regulations took effect and State enforcement of numerous responsibilities established for all California jurisdictions began. SB 1383 requires jurisdictions to (1) provide organics collection services to all residents and businesses, (2) establish an edible food recovery program, (3) conduct education and outreach, (4) procure recyclable and recovered organic products, (5) secure access to recycling and edible food recovery capacity, and DisneylandForward
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(6) monitor compliance. Collection requirements are defined for residential and non-residential land uses, dependent on type, size, and other factors. Residents, employees, tenants, and customers are required to properly sort organic materials into the correct containers. Jurisdictions can select from a variety of organic waste collection services to match their unique communities and local infrastructure, while producing clean streams of organic feedstock that can be recycled into recycled products.

Local
City of Anaheim General Plan, Public Services and Facilities Element The Public Services and Facilities Element of the City of Anaheim General Plan addresses solid waste services. Applicable goals and policies from the Public Services and Facilities Element that are related to solid waste and that are applicable to the Project are provided in Table 5.10-1 in Section 5.10, Land Use and Planning, with a project consistency analysis.

Telephone and Cable Television
Local
City of Anaheim General Plan, Public Services and Facilities Element The Public Services and Facilities Element of the City of Anaheim General Plan addresses telephone and television/cable services and facilities. Applicable goals and policies from the Public Services and Facilities Element that are related to telephone service and facilities and that are applicable to the Project are provided in Table 5.10-1 in Section 5.10, Land Use and Planning, with a project consistency analysis.

5.16.3 PROJECT IMPACT ANALYSIS
A. Methodology
Water
The analysis in this section is based on DisneylandForward Subsequent EIR Water Supply Assessment (WSA), prepared by Psomas for the Project and included as Appendix L-1 of this Draft Subsequent EIR (Psomas 2023a). Additional information and analysis is based on the Hydraulic Analysis, prepared by Ardurra for the Project and included as Appendix H-2 of this Draft Subsequent EIR (Ardurra 2023). This modeling was conducted to analyze the effect the Project’s increased water demand would have on the water distribution system with the existing and planned near term improvements in Anaheim Public Utilities’ Capital Improvement Program.

Sewer/Wastewater
The analysis in this section is based on City of Anaheim DisneylandForward Sewer Study (Psomas 2023b) prepared for the Project and included as Appendix L-2 of this Draft Subsequent EIR. The sewer study provides sewer capacity analysis for the existing condition and The Disneyland Resort Project buildout flows for both existing allowed land uses and proposed Project uses. The analysis includes Project development flows for various loading scenarios along with sewer flows for existing and other reasonably anticipated proposed development from the upstream tributary areas.

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Stormwater
The analysis in this section is based on review of the following documents:
• Master Plan of Storm Drainage for Anaheim Barber City Channel Tributary Area, 2009 (June), City of Anaheim.
• Master Plan of Storm Drainage for East Garden Grove Wintersburg Channel Tributary Area, 2006 (January), City of Anaheim.

Electricity
As indicated below, the City of Anaheim Public Utilities Department provides electrical services to the Project Site.

Natural Gas
The following information is summarized from the City of Anaheim General Plan and the General Plan EIR No. 330. In addition, the natural gas provider was contacted to determine if the Project would significantly impact the natural gas provider’s abilities to provide natural gas service.

Solid Waste
Information concerning solid waste services is based on correspondence from OC Waste & Recycling
4 and the City of Anaheim General Plan (City of Anaheim 2004a).

Telephone and Cable Television
The following information is summarized from the City of Anaheim General Plan (City of Anaheim 2004a).

B. Thresholds of Significance
The following significance criteria are derived from the City of Anaheim Environmental Checklist.

The Project would result in a significant impact related to utilities and service systems if it would:

Threshold 5.16-1 Would the project require or result in the construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?
Threshold 5.16-2 Would the project have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years (including large-scale developments as defined by Public Resources Code Section 21151.9 and described in Question No. 20 of the Environmental Information Form)?
Threshold 5.16-3 Would the project result in a determination by the wastewater treatment provider which serves or may serve the project that it has

4 OC Waste & Recycling is formerly known as the Orange County Integrated Waste Management Department.

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adequate capacity to serve the project's projected demand in addition to the provider's existing commitments?
Threshold 5.16-4 Would the project 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? Threshold 5.16-5 Would the project comply with Federal, State, and local management and reduction statutes and regulations related to solid waste? C. Standard Requirements
The following standard requirements are applicable to the Project. As appropriate, the measure number and section from EIR No. 311 and/or SEIR No. 340 are listed in parentheses.

Modifications to the original measure are shown as strikethrough for deleted text and bold for new, inserted text.

SR UTIL-1 Prior to the issue of each building permit, the property owner/developer shall be required to prepare and submit to the City for review and approval (1) a Landscape Documentation Package and (2) landscape and irrigation plans with appropriate water use calculations in accordance with the requirements of Anaheim Municipal Code Chapter 10.19, Landscape Water Efficiency. (SEIR No. 340, SR 5.15-1) SR UTIL-2 Prior to issuance of building permits, the property owner/developer shall provide evidence to the Planning Director/Planning Services Manager that all sewage and wastewater disposal into the sewer system shall comply with OCSD’s Wastewater Discharge Regulations, including the procurement of the necessary permits by food service establishments that would be developed in the ARSP area. (SEIR No. 340, SR 5.16-1)
SR UTIL-3 Prior to issuance of building permits, the property owner/developer shall provide proof of payment to the Planning Director/Planning Services Manager for a sanitary sewer service charge to OCSD. (SEIR No. 340, SR 5.16-2) SR UTIL-4 Prior to issuance of building permits, the property owner/developer shall provide proof of payment to the Planning Director/Planning Services Manager for a capital facilities connection charge to OCSD. (SEIR No. 340, SR 5.16-3) SR UTIL-5 Prior to issuance of building permits, the property owner/developer shall be required to demonstrate to the Planning Department, Building Division that building plans meet the applicable Title 24 Energy Efficiency Standards for Residential and Nonresidential Buildings (24 CCR 6). These standards are updated, nominally every three years, to incorporate improved energy efficiency technologies and methods. The 2008 standards, which were applicable January 1, 2010, are approximately 15 percent more energy efficient than the 2005 Building and Energy Efficiency Standards. (EIR No. 311, MM 3.10.9-2; SEIR No. 340, SR 5.17-1) SR UTIL-6 Prior to issuance of building permits, the property owner/developer shall be required to demonstrate to the Planning Department, Building Division that building plans meet the applicable California Green Building Standards (24 CCR 11). (SEIR No. 340, SR 5.17-2)
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SR HWQ -1 Development projects that will result in soil disturbance of one (1) or more acres of land shall comply with the State’s Construction General Permit by filing a Notice of Intent (NOI) with the State Water Resources Control Board (SWRCB) and implementing a Storm Water Pollution Prevention Plan (SWPPP). Prior to the issuance of preliminary or precise grading permits, the property owner/developer shall provide the City Engineer with evidence that an NOI has been filed with the SWRCB by providing a copy of the NOI invoice and the assigned Waste Discharger Identification (WDID) No. for the project. The SWPPP shall include Best Management Practices (BMPs) designed with a goal of preventing a net sediment load increase in storm water discharges relative to preconstruction levels and shall prohibit during the construction period discharges of storm water or non- storm water at levels which would cause or contribute to an exceedance of applicable water quality standards contained in the Basin Plan. The BMPs shall address erosion control, sediment control, wind erosion control, tracking control, non-storm water management and waste management and materials pollution control during all phases of construction, including a sampling and analysis plan for sediment and non-visible storm water pollutants. The property owner/developer shall be responsible for proper implementation of the SWPPP. (SEIR No. 340, SR 5.8-1)
SR HWQ -2 Prior to issuance of the precise grading permit, the property owner/developer shall prepare Water Quality Management Plans (WQMPs) for review and approval by the Public Works, Development Services. The WQMP shall identify permanent site design, source control and treatment control Best Management Practices (BMPs) that will be used on the site to control predictable pollutant runoff. The WQMP shall also describe the long-term operation and maintenance requirements for the treatment control BMPs and the mechanism for funding the BMPs. The WQMP shall be recorded against the property to ensure long-term compliance. (SEIR No. 340, SR 5.8-2)
SR HWQ-3 Prior to issuance of the first building permit for Disney ARSP Properties , the property owner/developer shall pay the Storm Drain Impact Fees which would go toward future storm drain improvements within The Anaheim Resort area and South Central City area. (SEIR No. 340, SR 5.8-3)
SR HWQ -4 Chapter 10.09 of the Anaheim Municipal Code is the City’s NPDES Ordinance, which provides regulations to comply with the CWA, the California Porter-Cologne Water Quality Control Act, and the City’s NPDES permit. This ordinance prohibits the discharge of specific pollutants into the storm water; regulates illicit connections to the storm drain system; requires development projects to implement permanent BMPs on individual sites to reduce pollutants in the storm water; and requires local discharge permits for non-storm water discharges into the storm drain system. (SEIR No. 340, SR 5.8-4)
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D. Impact Analysis
Threshold 5.16-1 Would the project require or result in the construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?
No New Impact from EIR No. 311; No New Impact from SEIR No. 340 - Project Impact Less Than Significant With Mitigation.

Water
EIR No. 311 determined that water demand associated with The Disneyland Resort would exceed the capacity of the existing water system; implementation of identified project design features and mitigation measures related to improvement s to the water system and water conservation measures would reduce impacts on the water supply system to less than significant. According to SEIR No. 340, water demand associated with buildout of the ARSP would exceed capacities of existing water facilities, but implementation of proposed mitigation measures would reduce impacts to less than significant.

The Project Site, including The Disneyland Resort and Disney ARSP Properties, is currently served by an existing water system that is owned and maintained by the City of Anaheim. As previously discussed, Disney has constructed all requested improvements related to development of The Disneyland Resort, and this infrastructure would be protected in place during future development associated with the Project. As detailed in Section 3.0, Project Description, the Project would allow Disney to move previous ly approved uses to other Disney Properties governed by the DRSP and ARSP; no additional square footage for theme park uses or retail entertainment uses or additional hotel rooms are proposed within the Project Site as part of this Project. Because no additional development is proposed, no new demand is anticipated. Future development related to the Project would require on-site construction of new, relocated, or expanded water mains to serve development. All proposed water mains would be sized to accommodate anticipated demand. These improvements would be located entirely within the Project Site. Because all required off-site improvements have been constructed to serve The Disneyland Resort as analyzed in EIR No. 311 and the Disney ARSP Properties as analyzed in SEIR No. 340, upgrades to the existing infrastructure system are not anticipated, and would not be required to implement the Project (Psomas 2023a). The Project would implement mitigation measures to reduce impacts on water facilities, including the following: MM UTIL- 1 (implementation of water conservation measures), MM UTIL-2 (water audit for landscape irrigation systems), MM UTIL-3 (water supply planning coordination with the Public Utilities Department), MM UTIL-4 (use of pressure reducing valves), MM UTIL-5 (installation of water meter and backflow equipment), MM UTIL-6 (installation of separate landscape water meters), MM UTIL-7 (installation of water supply system improvements), and MM HWQ-2 (landscape irrigation systems designed to minimize surface runoff and overwatering).

The Project would result in a less than significant impact with mitigation. This impact would not be new or substantially more severe when compared with the impact analyses in EIR No. 311 and SEIR No. 340.

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Wastewater
According to EIR No. 311, projected wastewater (also referred to as sewer) flows from The Disneyland Resort would exceed available capacity; however, the proposed improvements to the system would accommodate the project and a significant impact would not occur. According to SEIR No. 340, build out of the ARSP would increase sewage flows in existing sewer lines and trunks serving the area, resulting in several sewer lines becoming deficient. Implementation of mitigation would reduce potential impacts to less than significant levels.

The Project Site, including The Disneyland Resort and Disney ARSP Properties, is currently served by an existing sewer system that is owned and maintained by the City of Anaheim. As previously discussed and detailed in Table 5.16-3, Disney has constructed all requested improvements related to development of The Disneyland Resort, and this infrastructure would be protected in place during future development associated with the Project. As detailed in Section 3.0, Project Description, the Project would allow Disney to move previously approved uses to other Disney Properties governed by the DRSP and ARSP.

Project Development Flows
With the exception of the property located at 333 W. Ball Road which is tributary to the Ball Road sewer system, The Disneyland Resort and Disney AR SP Properties are tributary to the Katella sewer system. As part of the Sewer Study, sewer flow factors were derived from typical flow factors for hotel and restaurant uses and monitored theme park flow data, collected in April 2022.

These flow factors were then adjusted to account for a factor of safety. As detailed in the Sewer Study, included as Appendix L-2 to the Draft Subsequent EIR, these derived flow factors differ from those identified previously in EIR No. 311 for various reasons, including adjustments for consistency with recent sewer studies and more current industry standards and adjustments based on actual theme park density. Overall, the adjusted flow factors are 25.5 percent higher than those identified in EIR No. 311 as shown in Table 5.16-4, Sewer Flow Factors.

TABLE 5.16-4

SEWER FLOW FACTORS
Land Use Units
EIR No. 311
Flow Factor
(gpd/unit)
EIR No. 311
Flow (mgd)
Adjusted Flow
Factor
(gpd/unit)
Adjusted Flow
(mgd)
Restaurant/Retail ksf 2,000 0.60 800 0.24
Hotel Rooms Rooms 150 0.84 150 0.84
Theme Park ksf 234 1.60 400 2.74
Total 3.04 3.82
Adjusted Flow Higher than EIR No. 311 25.5%
gpd: gallons per day
mgd: million gallons per day
kdf: thousand square feet
Source: Psomas 2023b.

In addition to determining adjusted flow factors, flow monitoring results from both The Disneyland Resort, collected in April 2022, and key areas in the City’s pipelines along Harbor Boulevard, Walnut Street, and Katella Avenue which were collected in November 2022, were used to review and adjust the City’s sewer model to better simulate observed data while also maintaining conservatively higher flows to account for potential seasonal variability in flows and peaking.

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Capacity Analysis and Pipeline Deficiencies
Katella Sewer System
The Sewer Study analyzed sewer capacity for expected buildout sewer flows associated with the Disneyland Resort, including the DisneylandFoward Project and other reasonably anticipated proposed development.

The maximum depth-to-diameter (d/D) ratio for pipelines within the sewer collection system is used to identify pipeline capacity deficiencies. For peak dry weather flow conditions, the maximum d/D ratio for identifying an existing pipeline as deficient is 0.67 for pipelines smaller than 12-inch and 0.75 for pipelines 12-inch and larger.

In order to provide a full analysis of the DisneylandForward Project and capture the Project’s proposed flexibility in future development, the Sewer Study analyzed two potential development scenarios both tributary to the Katella sewer system.

Scenario 1, Current Approved Disney Full Buildout, represents development of uses under current entitlements, which can also be considered a No Project scenario. This scenario represents the worst case for the Katella North pipeline. Using the adjusted flow factors, Scenario 1 identified a sewer flow increase of 2.69 mgd or 1,865 gallons per minute (gpm), as illustrated in Table 5.16-5, Sewer Flows for Remaining Approved Disneyland Resort Development – Scenario 1.

TABLE 5.16-5

SEWER FLOWS FOR REMAINING APPROVED DISNEYLAND
RESORT DEVELOPMENT SCENARIO 1
Disney DRSP/ARSP Property
Remaining
Entitlement Units
Factor(3)
(gpd/unit)
Sewer Flow Increase
mgd gpm
DRSP Theme Park District(1) 3,554 ksf 400 1.42 987
DRSP Retail/Entertainment(2) 103 ksf 800 0.08 57
DRSP Administration Building 170 ksf 100 0.02 12
DRSP Hotel District 3,258 rooms 150 0.49 339
ARSP Paradise Pier 45 rooms 150 0.01 5
ARSP East Parking 1,116 rooms 150 0.17 116
ARSP Toy Story/Theme Park East 3,348 rooms 150 0.50 349 Total 2.69 1,865
1 Allowed theme park area (3,657 ksf) minus area that may be used as retail, dining, and entertainment (103 ksf). 2 Allowed theme park area that may be used as retail, dining, and entertainment. 3 Hotel flow factor of 150 gpd/rom includes hotel rooms and a ll auxiliary uses, consistent with the City's master plan.

Source: Psomas 2023b

Scenario 2, DisneylandForward Full Buildout, represents DisneylandForward buildout in which maximum development is placed in the Southeast District and Theme Park East Overlay. This scenario represents the worst case for the Katella South pipeline. Using the adjusted flow factors, Scenario 2 identified a sewer flow increase of 2.784 mgd or 1,934 gpm as illustrated in Table 5.16-6, Sewer Flows for Future Project Development – Scenario 2.

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TABLE 5.16-6

SEWER FLOWS FOR FUTURE PROJECT
DEVELOPMENT SCENARIO 2
Project Districts
Remaining
Entitlement Units
Factor(3)
(gpd/unit)
Sewer Flow Increase
mgd gpm
Theme Park District & Theme Park West Overlay
Theme Park(1) 2,324 ksf 400 0.930 646
Retail Entertainment 103 ksf 800 0.082 57
Administration Building 170 ksf 100 0.017 12
Hotel(2) 1,451 rooms 150 0.218 151
Southeast District
Theme Park 312 ksf 400 0.125 87
Restaurant (4) 78 ksf 800 0.062 43
Hotel 1,852 rooms 150 0.278 193
Theme Park East Overlay
Theme Park 672 ksf 400 0.269 187
Restaurant (4) 168 ksf 800 0.134 93
Hotel 3,348 rooms 150 0.502 349
Parking Overlay 1,116 rooms 150 0.167 116
Total 2.784 1,934
1 Theme park area (2,324 ksf) = Total remaining (3,657 ksf) - Retail Entertainment (103 ksf) - Southeast (390 ksf) - Theme Park East (840 ksf)
2 Hotel rooms (1,451 rooms) = Total remaining (3,258 room s) - Southeast Overly (1,852) + ARSP (45 remaining PPH) 3 Hotel flow factor of 150 gpd/room includes hotel rooms and all auxiliary uses, consistent wi th the City’s master plan. 4 Restaurant use equal to a maximum of 20% of the allowed Theme Park square footage Source: Psomas 2023b

For either Scenario, the Sewer Study identified segments along Katella Avenue west of Harbor Boulevard to 9th Street with a greater than 0.75 d/D ratio and necessitating sewer improvements to accommodate the increase in flow for buildout of the Project.

The Sewer Study also evaluated build out alternatives relative to pipeline capacities on Harbor Boulevard, Clementine Street, Disneyland Drive, Walnut Street, and Magic Way. Potential future capacity constraints may exist in certain areas based on specific location and timing of Project flows and other future flows.

Ball Road Sewer System
The maximum buildout for the Disney ARSP located on the northeast corner of Ball Road and Harbor Boulevard, at 333 W. Ball Road identified a sewer flow increase of 0.08 mgd or 55.6 gpm.

Accordingly, there are no resulting pipeline deficiencies within the Ball Road sewer system.

Pursuant to Development Agreement terms, the City of Anaheim will advance, and Disney will participate in cost sharing for, improvements to address the future build out deficiency on Katella Avenue west of Harbor Boulevard to 9 th Street. These improvements are within the Project Site and would be reviewed and approved through the City’s Capital Improvement Program.

Additionally, MM UTIL-8 through MM UTIL-11 establish requirements for project-specific sewer study preparation and construction of upgrades or payment of applicable sewer impact fees, pursuant to A.M.C. 10.12.085. Implementation of these mitigation measures in addition to DisneylandForward
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compliance with the terms identified in the Development Agreement related to cost sharing for future improvements would reduce impacts to sewer system capacity to less than significant.

Stormwater
According to EIR No. 311, The Disneyland Resort would result in an increase in storm water runoff due to an increase in impervious surface area, which would exceed available storm drain capacities. However, the proposed improvements to the system would accommodate the project and a significant impact would not occur. According to SEIR No. 340, buildout of the ARSP may worsen several existing deficiencies within the City’s storm drain system, resulting in significant impacts. However, the property owner/developer for each future development project woud be required to participate in the City’s Master Plan of Storm Drains and related Infrastructure Improvement (Fee) Program to assist in mitigating existing and future storm drainage system deficiencies. Additionally, implementation of t he proposed mitigation would ensure that impacts to regional flood control facilities would be reduced to less than significant levels.

The Project Site, including The Disneyland Resort and Disney ARSP Properties, is currently served by an existing storm drain system that is owned and maintained by the City of Anaheim.

As previously discussed, Disney has constructed all requested improvements related to development of The Disneyland Resort, and this infrastructure would be protected in place during future development associated with the Project.

As discussed in Section 3.0, Project Description, The Disneyland Resort has successfully implemented various initiatives that go beyond compliance with federal, State and local environmental rules and regulations. Specifically, Disney worked with the Orange County Water District (OCWD) to develop a process for storing water instead of releasing it to the ocean through storm drains. When large bodies of water or water attractions are drained at The Disneyland Resort, the water is sent to the OCWD’s Groundwater Replenishment System, where it is purified and added to Orange County’s groundwater supply. As also detailed in Section 3.0, Project Description, the Project would allow Disney to move previously approved uses to other Disney Properties governed by the DRSP and ARSP; no additional square footage for theme park uses or retail entertainment uses or additional hotel rooms are proposed as part of the Project. Because no additional development is proposed, and with implementation of the identified initiative, increased stormwater flows are not anticipated. Additionally, because all required improvements have been constructed to serve The Disneyland Resort as analyzed in EIR No. 311 and the Disney ARSP Properties as analyzed in SEIR No. 340, upgrades to the existing infrastructure system are not anticipated, and would not be required to implement the Project.

However, although the overall amount of future development associated with the Project would remain unchanged, the Project has the potential to increase impervious surfaces within different areas of the Project Site, which could increase runoff volumes and rates to certain facilities. As detailed in Section 5.9, Hydrology and Water Quality, the City requires that individual developments provide engineering plans as well as drainage studies and Preliminary Water Quality Management Plans, as required by SR HWQ-1, SR HWQ-2 and SR HWQ-4 , specifying methods to convey, retain, and treat storm water, which would ensure that storm water runoff from the Project Site would not exceed the capacity of downstream drainage systems. As required by SR HWQ-3, Disney is responsible for payment of all required fees associated with funding of storm drain improvements including construction of necessary improvements to the off-site storm drain system. Therefore, with implementation of site-specific storm drain improvements the DisneylandForward
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Project would not result in impacts related to deficiencies in the off-site storm drainage system serving the Project Site and preventing localized flooding. Any on-site storm drain would be designed and constructed to the satisfaction of the City Engineer). The Project would implement mitigation measures to reduce impacts on storm water facilities, including the following:

MM UTIL-12 (payment of the City’s Master Plan of Storm Drains and related Infrastructure Improvement Fee) and MM UTIL-13 (incorporating stormwater runoff mitigation measures in building plans).

Construction activities associated with the proposed on-site storm drain facilities would be within the physical impact area identified for the Project, as evaluated throughout this Draft Subsequent EIR. No additional impacts associated with construction of on-site storm drains or connections to existing facilities would occur. Impacts would be less than significant, and no mitigation would be required.

Electricity
According to EIR No. 311, The Disneyland Resort Project would increase demand for electricity, requiring improvements to existing electrical facilities, including a new electrical substation.

Additionally, the project required relocation of transmission lines. EIR No. 311 found that implementation of project design features and mitigation measures would result in a less than significant impact. According to SEIR No. 340, build out of the ARSP and expansion of the Convention Center would result in increased demand for electricity. Compliance with the standard requirements and implementation of the proposed mitigation measures would reduce anticipated demand through conservation efforts. It was expected that the existing electrical distribution system and future planned improvements w ould adequately accommodate the anticipated demand, thus resulting in a less than significant impact with mitigation.

As detailed in Section 3.0, Project Description, the Project would allow Disney to move previously approved theme park, hotel, parking and other uses to other Disney Properties governed by the DRSP and ARSP; no additional square footage for theme park uses or retail entertainment uses or additional hotel rooms are proposed as part of this Project. Because no additional development is proposed and with implementation of the initiatives and commitment to reaching the sustainability and energy efficiency goals discussed below, no new change to the overall expected electricity demand is anticipated. However, the Project would result in increased electricity demand on several Disney Properties that are currently operated as surface parking lots. The Project would increase electricity demand in the Theme Park District west of Disneyland Drive, the Southeast District, the Theme Park West Overlay, the Theme Park East Overlay, and the Parking Overlays if developed with Project uses.

The Project Site, including The Disneyland Resort and Disney ARSP Properties, is currently served by existing electrical infrastructure that is owned and maintained by the City of Anaheim.

Based on information provided by Disney for the total electricity demand in 2019 for the Disneyland and California Adventure theme parks and projected electricity demand for future parking structures, which is included in Appendix E of this Draft Subsequent EIR, and default calculations for hotels derived from the California Emissions Estimator Model (CalEEMod) version 2022.1.1.0 (CAPCOA 2022), Project demand for electricity for operation of the remaining entitlements under The Disneyland Resort Project and the ARSP Project for the Disney Properties would be 402,005,865 kWh/yr, as detailed in Section 5.5, Energy. The information provided by Disney reflects the increased demand for electricity for theme park attractions, which today DisneylandForward
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include more computerized animation than in 1993, when the City certified EIR No. 311, as well as the increased electric energy efficiency incorporated into theme park and Resort operations since 1993.

The Project also is expected to require new electrical switching stations, including in the Theme Park District west of Disneyland Drive, in the Southeast District/Theme Park East Overlay, in the Theme Park District along Harbor Boulevard, and in the East Parking Area of the DRSP Parking District.

Construction activities associated with these facilities would be within the physical impact area identified for the Project and evaluated throughout this Draft Subsequent EIR. All required switching stations, line extensions and service connections would be conducted in compliance with the City’s Electric Rates, Rules and Regulations. No additional impacts associated with construction of on-site transmission lines or connections to existing facilities would occur.

As discussed in Section 3.0, Project Description, The Disneyland Resort has successfully implemented various initiatives that go beyond compliance with federal, State and local environmental rules and regulations. During Project operations, the Project would continue to implement sustainability strategies, further reducing Project electricity consumption, including:
 An early focus of The Disneyland Resort’s environmentally-focused culture, Disneyland Railroad steam trains and the Mark Twain Riverboat were converted in 2009 to be fueled with 99.9 percent biodiesel made from used kitchen cooking oil, replacing the 200,000+ gallons of petroleum diesel fuel previously used every year to fuel those attractions;  In 2016, Cars Land received a 40,000-square-foot photovoltaic system (solar array) atop the Radiator Springs Racers attraction;
 In 2016, The Disneyland Resort successfully completed a ten-year diesel minimization plan through which Disneyland Finding Nemo submarines were re-powered with zero emission technology, diesel-fueled construction light towers were replaced with solar light towers, and diesel-fueled pressure washers were replaced with propane or electric units.

This initiative reduced The Disneyland Resort’s diesel fuel consumption by nearly 90 percent; and
 Since 2014, The Disneyland Resort has deployed over 400 electric vehicle charging ports for guests and cast members, and intends to continue growing its EV-charging infrastructure.

With compliance with the standard requirements SR UTIL-2 and SR UTIL-3 requiring compliance with Title 24 standards and California Green Building Standards, it is expected that the existing electrical distribution system and future planned improvements would adequately accommodate the anticipated demand. The Project also would implement mitigation measures to reduce impacts on electricity, including the following: MM UTIL-14 (implementation of energy-saving measures), MM UTIL-15 (grid-tied renewable energy generation measures), MM UTIL-26 (providing forecasted electricity demand to City); and ENE-2 (payment of City fees). With compliance with the standard requirements and mitigation measures, the Project’s impact would be less than significant.

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Natural Gas
According to EIR No. 311, The Disneyland Resort would increase demand for natural gas, requiring improvements to existing SCG system and no significant impacts were identified.

According to SEIR No. 340, no impact would occur related to provision of natural gas service to future projects within the ARSP area.

The Project Site, including The Disneyland Resort and Disney ARSP Properties, are currently served by existing natural gas infrastructure that is owned and maintained by Southern California Gas Company (SCGC), and this infrastructure would be protected in place during future development associated with the Project. As detailed in Section 3.0, Project Description, the Project would allow Disney to move previously approved uses to other areas governed by the DRSP and ARSP; no additional square footage for theme park uses or retail entertainment uses or additional hotel rooms are proposed as part of this Project. Because no additional development is proposed, no new demand is anticipated. Additionally, because all required improvements have been constructed to serve The Disneyland Resort as analyzed in EIR No. 311 and the Disney ARSP Properties as analyzed in SEIR No. 340, upgrades to the existing infrastructure system are not anticipated, and would not be required to implement the Project. The service would be provided in accordance with the SCGC’s policies and extension rules on file with the California Public Utilities Commission. The Project also w ould implement mitigation measures to reduce impacts on electricity, including MM ENE-3 (implementation of natural gas demand reduction measures) and MM ENE-1 (compliance with State Energy Conservation standards). Therefore, the Project would have a less than significant impact with mitigation.

The Project would result in a less than significant impact with mitigation. This impact would not be new or substantially more severe when compared with the impact analysis in EIR No. 311. This impact would be new when compared with the impact analysis in SEIR No. 340.

Telecommunications Facilities
According to EIR No. 311, The Disneyland Resort would increase demand for telephone and fiber optics service; however, any upgrading would be provided by the service providers; no significant impacts were identified. According to SEIR No. 340, no impact would occur related to provision of telephone service to future projects within the ARSP area.

The Project Site, including The Disneyland Resort and Disney ARSP Properties, is currently served by existing telephone, digital cable, and high-speed internet infrastructure, and this infrastructure would be protected in place during future development associated with the Project.

As detailed in Section 3.0, Project Description, the Project would allow Disney to move previously approved uses to other Disney Properties governed by the DRSP and ARSP; no additional square footage for theme park uses or retail entertainment uses or additional hotel rooms are proposed as part of this Project. No additional development is proposed beyond what was evaluated in EIR No. 311 for The Disneyland Resort and SEIR No. 340 for the Disney ARSP Properties. Facilities needed to connect the Project to the existing telecommunications systems may include new conduit, fiber and copper facilities. Anaheim Fire uses the Emergency Radio Response Communication (ERRC) System throughout the Project Site to establish and enhance radio communications for emergency communication. As future development associated with the DisneylandForward Project occurs, new buildings and structures may shadow existing ERRC structures, potentially disrupting the ERRC system. Implementation of MM UTIL-22 installation of a signal booster or relay system on the roof of the tallest project building to restore broadcast television reception to its original condition if the City of Anaheim determines that the proposed project would create a significant impact on broadcast television reception at local residences.

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These improvements would be implemented in accordance with applicable State and local regulations. Therefore, the impact related to additional demand for telecommunications facilities would be reduced to less than significant with mitigation.

The Project would result in a less than significant impact with mitigation. This impact would not be new or substantially more severe when compared with the impact analysis in EIR No. 311. This impact would be new when compared with the impact analysis in SEIR No. 340.

Threshold 5.16-2 Would the project have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years (including large-scale developments as defined by Public Resources Code Section 21151.9 and described in Question No. 20 of the Environmental Information Form)?
No New Impact from EIR No. 311; No New Impact from SEIR No. 340 - Project Impact Less Than Significant With Mitigation. According to EIR No. 311, it was determined that water demand associated with The Disneyland Resort would increase and require improvements to the existing water system, resulting in a significant impact. Implementation of identified project design features and mitigation measures related to improvements to the water system, including new wells and/or additional MWD connections, and water conservation measures would reduce impacts on the water supply system to levels not considered significant. According to SEIR No. 340, water demand associated with buildout of the ARSP would be accommodated through existing and projected supplies. Impacts would be less than significant; however, implementation of the proposed mitigation measures would ensure water conservation measures are incorporated into the design and into each phase of the proposed development to ensure that water supplies remain reliable into the future.

Estimated Project Water Demand
Unit water use factors were developed to estimate water demand for future Project development based on the FY 2019 consumption by use type and existing development shown in Table 5.16-7, Estimated Project Water Demands. Factors were calculated for theme park uses, a portion of which may be used for retail and entertainment, and hotel uses, which includes associated retail, restaurant, and meeting spaces. These uses were grouped based on the meter data available.

The resulting demand factors are included in Table 5.16-7 and projected water demand for Project’s remaining entitled uses are shown in Table 5.16-7 (Psomas 2023a).

TABLE 5.16-7

ESTIMATED PROJECT WATER DEMANDS
Remaining Entitlement
Remaining
Entitlement Units
Factor
(gpd/unit)
Demand
gpd AFY
Theme Park 3,657 ksf 491 1,795,809 2,012
Retail/Entertainmenta 103 ksf 0
DRSP Hotel 3,264 rooms 195 636,480 713
ARSP Hotel 5,043 rooms 195 983,385 1,102
Total 3,415,674 3,826
a Acreage included in Theme Park. Allowed theme park area that may be used as retail, dining, and entertainment.

Source: Psomas 2023a

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Based on the estimated development phasing, demand phasing is shown in Table 5.16-8, Estimated Project Phasing of Water Demand. The Project would be implemented in multiple phases over the next 30 years or more. The time frame for future development of the Project Site would be controlled by market forces and determined by Disney within the Project Site. Despite the anticipated 30-year or more buildout, it is conservatively assumed that Project buildout would occur by 2045. Project phasing would begin after 2025 with the initial phase assumed to be completed by 2030, consisting of all hotel uses and 40 acres of theme park uses. The initial phase estimate is made to be consistent with assumptions for air quality and construction phasing. The remaining theme park uses are then phased equally at 5-year increments out to 2045 (Psomas 2023a).

TABLE 5.16-8

ESTIMATED PROJECT PHASING OF WATER DEMAND
Phasing 2025 2030 2035 2040 2045
Land Use
Theme Park (ksf)a 0 646 1,650 2,653 3,657
Hotel (rooms)b 0 8,307 8,307 8,307 8,307
Water Demand (AFY)
Theme Park 0 355 907 1,459 2,012
Hotel 0 1,814 1,814 1,814 1,814
Total (without losses) 0 2,170 2,722 3,274 3,826
Total (with 4.85% water loss) 0 2,275 2,854 3,433 4,012 a Initial Park use phase of 40 acres (at 16,155 sf/a c) by 2030 with remainder spread equally to 2045. b All hotel use assumed complet ed by 2030. No development by 2025.

Source: Psomas 2023a.

City Water Demand
City water demands were developed and projected in the City’s 2020 UWMP. The City’s total water use in FY 2020 was 56,912 AF, an 8.3 percent decrease from FY 2015 water use reported in the previous 2015 UWMP. The water demand forecast was carried out in coordination with Municipal Water District of Orange County (MWDOC) and Orange County Water District (OCWD) as a regional effort and calculated by CDM Smith (2020). Demand projections were based on existing use data as well as projected land use, population, economic growth, and future passive and active conservation measures (baseline c onservation). FY 2020 and projected City water demands are shown in Table 5.16-9, 2020 UWMP Projected City Water Demand. All projected demands include an estimated 4.85 percent in water loss or non-revenue water consistent with the 2020 UWMP (Psomas 2023a).

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TABLE 5.16-9
2020 UWMP PROJECTED CITY WATER DEMAND
2020 2025 2030 2035 2040 2045
UWMP Water Demand Projections (AFY)
SF Housing 20,098 20,374 20,012 19,664 19,303 19,229
MF Housing 11,374 12,523 12,545 12,963 13,437 14,051
Other Potable (CII) 20,912 22, 794 26,778 28,117 29,523 29,523 Large Landscape (Golf Course) 349 350 350 350 350 350
Total Potable Demand 52,733 56, 041 59,685 61,094 62,613 63,153 Losses 3,282 2,717 2,895 2,964 3,038 3,064
Fire/Temp 796

4.85% 4.85% 4.85% 4.85% 4.85%
Recycled Water 101 120 120 120 120 120
Total Demand 56,912 58,878 62,700 64,178 65,771 66,337
Source: Psomas 2023a

Southern California’s urban water demand has been largely shaped by the efforts to comply with The Water Conservation Act of 2009, also known as Senate Bill (SB)x7-7. SB-7x7, signed into law on February 3, 2010, required the State of California to reduce urban water use by 20 percent by the year 2020. The City has been actively engaged in efforts to reduce water use in its service area and has met the final 2020 water use target as documented in the 2020 UWMP. This was critical to ensure the City’s eligibility to receive future state water grants and loans. In April 2015, Governor Brown issued an Executive Order as a result of one of the most severe droughts in California’s history, requiring a collective reduction in statewide urban water use of 25 percent by February 2016, with each agency in the state given a specific reduction target by DWR. In response to the Governor’s mandate, the City adopted Ordinance No. 6332, on May 19, 2015, establishing provisions against water waste and implementing higher (more restrictive) stages of water conservation to achieve its demand reduction target of 20 percent. The City was able to meet the mandated water use reduction from June 2015 through February 2016 (Psomas 2023a).

In 2018, Governor Brown signed into law the water conservation bills AB 1668 and SB 606. These bills were a result of an Executive Order from the Governor during the recent drought which required State agencies to develop and recommend a long-term water conservation framework to ensure adequate water supplies for the State now and in the future. The two bills establish guidelines for efficient water use and a framework for implementation and oversight of the new standards, which must be in place by 2022 (Psomas 2023a).

In response to the current drought, Governor Newsom signed Executive Order N-7-22 on March 28, 2022, after declaring states of emergency in April, May, July, and October of 2021 due to prolonged drought conditions. The purpose of the order is to help the State achieve conservation goals by implanting various water use reduction measures including the requirement that each water supplier implement shortage response actions for a shortage level of twenty percent (a Level 2 shortage under Section 10632 of the Water Code) (Psomas 2023a).

Given these long-term water conservation goals, the current level of City conservation is expected to be maintained or exceeded. Projections use baseline conservation which assume the implementation of future passive measures a ffecting new developments, including the Model Water Efficient Landscape, plumbing code efficiencies for toilets, and expected plumbing code for high-efficiency clothes washers. It also assumes the implementation of future active measures DisneylandForward
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for existing customers and the implementation of Metropolitan incentive programs at historical annual levels seen in Orange County (Psomas 2023a).

The demand for the Project area existing land use (2,656 AFY), as detailed above, was included in the 2020 UWMP reported and projected water demand estimates. The net new water demand for the Project of 3,826 AFY was also assumed to be included in the 2020 UWMP demand forecast as previously approved development as part of the DRSP and ARSP. Other proposed development within the City was evaluated in the WSA to confirm that sufficient growth was accounted for in the UWMP for the combined development. Based on this analysis, the City water demand as estimated in the 2020 UWMP included sufficient increased demand to account for the combined proposed development in the Project area and other areas within the City. The demand increase from the Project in FY 2045 is projected to be 6.0 percent of the total demand estimated for the City (Psomas 2023a).

Projected normal year City water demand through FY 2045 is shown in Table 5.16-10, Estimated Project Phasing of Water Demand, as reported in the 2020 UWMP, with Project water demand shown separately. All demands include an estimated 4.85 percent in water loss or non-revenue water consistent with the 2020 UWMP (Psomas 2023a).

TABLE 5.16-10

ESTIMATED PROJECT PHASING OF WATER DEMAND
Demanda 2025 2030 2035 2040 2045
Total City Demand without Projectb 58,878 60,425 61,324 62,338 62,325 Project Demandc 0 2,275 2,854 3,433 4,012
Total Demand 58,878 62,700 64,178 65,771 66,337
a All normal-year demands include 4.85% non-revenue wa ter (water loss) consistent with City's 2020 UWMP. b Normal year demand based on the City's 2020 UWMP excluding new Projec t demand resulting from remaining DLR entitled uses.
c Projected Project demand resulting from remaining DLR entitled uses including 4.85% projected water loss Source: Psomas 2023a

As stated above, estimated buildout water supply r equirement for the Project is projected to be 4,012 AFY. This is approximately 6.0 percent of the total City supply requirement estimated for FY 2045 in the City’s 2020 UWMP. Additionally, the Project would comply with SR UTIL-1 requiring water conservation measures to be incorporated into future landscape plans to help conserve the water supply. As discussed in Section 3.0, Project Description, The Disneyland Resort has also successfully implemented various initiatives that go beyond compliance with federal, State and local environmental rules and regulations, including:
 Over the years, The Disneyland Resort has placed considerable emphasis on reducing water consumption through various conservation measures, efficiency and reuse. In 2019, The Disneyland Resort used less potable water than in 2009, all while serving many more guests; and
 The Disneyland Resort manages its irrigation based on changing weather conditions using an on-site weather system comprised of satellite irrigation controllers around the resort.

The weather system’s features include drip irrigation, flow sensors and cut off valves, soil moisture sensors and water-friendly planting, among other features.

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The Project would also incorporate the following key features:
 Use of water-efficient landscaping, with no turf;
 Use of low-flow sprinkler heads in irrigation system;  Use of waterways re-circulation systems;
 Use of low-flow fittings, fixtures, and equipment, including low flush toilets and urinals;  Use of self-closing valves on drinking fountains;
 Use of reclaimed water for irrigation and washdown when it becomes available;  Continuation of the existing cooling tower recirculation system;  Use of efficient irrigation systems such as drip irrigation and automatic systems which use moisture sensors;
 Use of low-flow shower heads in hotels;
 Use of water-efficient ice machines, dishwashers, clothes washers, and other water-using appliances;
 Use of irrigation systems primarily at night when evaporation rates are lowest;  Display of water conservation information to the public in conspicuous places;  Use of water-conserving landscape plant materials wherever feasible;  Use of vacuum and other equipment to reduce the use of water for washdown of exterior areas; and
 Consultation with the City energy-conservation experts for assistance with energy- conservation design features.

Based on the findings of the WSA and with Project compliance with SR UTIL-1 and continued implementation of these initiatives, the Project would comply the City’s Water Conservation Ordinance and impacts related to water supply would be less than significant (Psomas 2023a).

The City is projected to have sufficient imported and groundwater supplies to meet normal year, single-dry year, and multiple-dry year conditions. Over the 20-year planning period, groundwater supplies are anticipated to increase from 77 percent to between 80 and 85 percent of total water use due to the expansion of OCWD’s Groundwater Replenishment System (GWRS) which recharges recycled water into the OC Basin. With the expansion of the GWRS to be completed by 2023, an estimated BPP of 82 percent is assumed in the 2020 UWMP for the period from 2025 through 2045 (Psomas 2023a).

Therefore, the City is projected to have sufficient imported and groundwater supplies to meet normal year, single-dry year, and multiple-dry year conditions including new Project demands and new demands from other planned development within the planning period because:
(1) Metropolitan has projected supply surpluses for each of these conditions and (2) the City can increase groundwater production consistent with their available well capacity, if needed.

The Project would implement mitigation measures to reduce potential impacts on water supply, including: MM UTIL-1 (implementation of water conservation measures), MM UTIL-2 (water audit for landscape irrigation systems), MM UTIL-3 (water supply planning coordination with the Public Utilities Department), MM UTIL-4 (use of pressure reducing valves), MM UTIL-5 (installation of water meter and backflow equipment), and MM UTIL-6 (installation of separate landscape water DisneylandForward
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meters). As a result, impacts related to water facilities would be less than significant with mitigation.

Threshold 5.16-3 Would the project 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?
New Impact from EIR No. 311; No New Impact from SEIR No. 340 - Project Impact Less Than Significant With Mitigation. According to EIR No. 311 and SEIR No. 340, although the project would increase wastewater (sewer) flows, it was determined that County Sanitation Districts of Orange County would have adequate treatment plant capacity to serve The Disneyland Resort Project as well as development of the Disney-owned properties in the ARSP.

EIR No. 311 identified a less than significant impact. According to SEIR No. 340, adherence to standard requirements would ensure payment of required fees. SEIR No. 340 identified a less than significant impact with mitigation.

Therefore, Disney would be responsible for payment of all required fees associated with funding utility improvements, including fees related to the construction of improvements to the wastewater treatment facilities. The Project would also be required to implement MM UTIL-8 through MM UTIL-11 to ensure adequate capacity in sewer pipelines serving the Project Site. Therefore, with payment of all required fees and implementation of mitigation, impacts related to wastewater treatment facilities would be reduced to less than significant.

Threshold 5.16-4 Would the project 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? Reduced Impact from EIR No. 311; No New Impact from SEIR No. 340 - Project Impact Less Than Significant With Mitigation. According to EIR No. 311, The Disneyland Resort would increase the amount of solid waste generated and, because of limited landfill capacity, the impact related to solid waste generation in excess of standards and capacity was identified as significant and unavoidable. According to SEIR No. 340, no significant impact would occur related to provision of solid waste service to future projects within the ARSP area; however, implementation DisneylandForward
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of the proposed mitigation would further ensure that adequate solid waste services are provided and that solid waste generation would be minimized.

The Project Site, including The Disneyland Resort and Disney ARSP Properties, is currently served by landfill facilities that are owned and maintained by OC Waste and Recycling. As discussed in Section 3.0, Project Description, The Disneyland Resort has successfully implemented various initiatives that go beyond compliance with federal, State and local environmental rules and regulations, including:
 Each year, The Disneyland Resort’s Property Control department collects and repurposes over one million pounds of company assets that the company no longer needs. These include theme park props, décor, furniture, and appliances removed during refurbishments. The assets are reused internally, offered to cast members and/or donated to local charities;
 The Disneyland Resort maintains a recycling program that has grown into a comprehensive resort-wide effort, both onstage and backstage. Over 25 different commodities are collected at the resort for recycling, including cardboard, paper, plastics, glass, metal, food waste, green waste and construction debris. With these efforts, The Disneyland Resort diverts more than 30 million pounds of materials from landfill annually; and
 Since launching a food scraps program in 2013, the Disneyland Resort continues to make great strides in reducing and recovering food waste. Today, this program diverts over five million pounds of food waste from landfills annually. In 2019, participation expanded throughout the resort to include locations in food and beverage service areas, storefronts, and office buildings. This program has been recognized by external groups multiple times, including most recently by the U.S. EPA Food Recovery Challenge in 2020; and The Walt Disney Company has also identified the following goals related to sustainability:

Anaheim City CouncilApril 16, 2024

Anaheim City Council
April 16, 2024