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

Waste
 Zero waste to landfill for wholly owned and operated parks and resorts Materials
 Use recycled, certified, or verified sustainable paper  At least 30 percent recycled plastic in products and packaging  Design packaging for reuse, recycling, or composting
 Use of recycled content or sustainable textiles for apparel  Sustainable production processes for products
Sustainable Design
 New projects achieve near net zero, maximize water efficiencies and are designed to support zero waste operations
 90 percent diversion for construction waste for domestic and European Union projects DisneylandForward
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The Project would also incorporate the following key features:
 Use of recycled paper products for stationery, letterhead, and packaging;  Recovery of materials such as: food scraps, cardboard, recyclables, landscape material, kitchen grease, scrap metal and many other recoverable materials that align with our zero- waste goal; and
 Continued participation in the City of Anaheim’s voluntary “Recycle Anaheim” program or other substitute program as may be developed by the City.

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 this Project. Because no additional development is proposed and with implementation of the initiatives and commitment to reaching the goals identified above, no new change to the expected solid waste generation is anticipated.

The Orange County solid waste landfill system would have the ability to serve the Project with solid waste landfill capacity. The County of Orange maintains 15-years of countywide solid waste landfill capacity, as required by AB 939. According to OC Waste and Recycling, the Project would primarily be served by the Olinda-Alpha Landfill in Brea, which has a remaining capacity of 14.47 million cubic yards (mcy). Depending on the location, solid waste may also be disposed of at the Frank R. Bowerman Landfill in Irvine. which has a remaining capacity of 161.88 mcy. Additionally, the Olinda-Alpha Landfill has an estimated closure date of 2036 and Frank R. Bowerman Landfill has an estimated closure date of 2053 (Halligan 2022). Buildout of the Project could be accommodated within the permitted capacity of the County’s landfill capacity; therefore, the Project would not generate solid waste in excess of the capacity of local infrastructure or otherwise impair the attainment of solid waste reduction goals. The Project would implement mitigation measures to reduce potential impacts on solid waste, including: MM UTIL-17 (implementation of a solid waste management plan), MM UTIL-18 (implementation of solid waste minimization measures), MM UTIL-19 (showing trash and recyclable receptacles on plans), MM UTIL-20 (installing trash and recyclable receptacles), and MM UTIL-21 (annual reports to the City). As a result, with implementation of mitigation, the Project would have a less than significant impact.

The Project would result in a less than significant impact 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.

Threshold 5.16-5 Would the project comply with Federal, State, and local management and reduction statutes and regulations related to solid waste? Reduced Impact from EIR No. 311; No New Impact from SEIR No. 340 - Project Impact Less Than Significant Impact With Mitigation. According to EIR No. 311, The Disneyland Resort would implement strategies to comply with management and reduction statutes and regulations; however, because of limited landfill capacity the impact 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 of the proposed mitigation would further ensure that adequate solid waste services were provided and that solid waste generation would be minimized.

Based on coordination with OC Waste & Recycling, the OC Landfill System would be able to accommodate solid waste generation related to Project buildout. The Project would be required DisneylandForward
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to comply with all federal, state, and local agency regulations regarding solid waste. Under AB 939, the Integrated Waste Management Act of 1989, the City is required to develop source reduction, reuse, recycling, and composting programs to reduce the amount of solid waste entering landfills. Local jurisdictions are mandated to divert at least 50 percent of their solid waste generation to recycling. Additionally, under SB 1838, the State Organics Law, includes targets for a 75 percent reduction in compost materials disposed in landfills by 2025 and reduction of at least 20 percent of edible food currently disposed for human consumption by 2025. The City implements municipal codes and ordinances that help to reduce the waste source and increase the diversion rate. The City program, Recycle Anaheim, consists of an automated trash collection program and a recycling and yard waste collection system. In collaboration with Republic Services, the City’s franchise contractor, the City provides an automated curbside recycling program for solid waste disposal, which uses the three-can automated collection system for trash, commingled recyclable materials, and yard waste. Additionally, the City of Anaheim requires that all materials generated from construction activities be recycled to meet the 65 percent diversion rate from the landfill system. The Project would implement mitigation measures to reduce potential impacts on solid waste, including: MM UTIL-17 (implementation of a solid waste management plan), MM UTIL-18 (implementation of solid waste minimization measures), MM UTIL-19 (showing trash and recyclable receptacles on plans), MM UTIL-20 (installing trash and recyclable receptacles), and MM UTIL-21 (annual reports to the City). As a result, with implementation of mitigation, the Project would have a less than significant impact.

5.16.4 CUMULATIVE IMPACTS
The cumulative impact area to determine cumulative impacts on utility services considers the service area of the respective providers.

Water
According to EIR No. 311, with implementation of required mitigation, The Disneyland Resort Project would not contribute to a significant and unavoidable cumulative impact related to water supply or water service with implementation of mitigation. According to SEIR No. 340, buildout of the ARSP would result in less than significant cumulative impacts to water supply and infrastructure with adherence to the proposed mitigation measures.

As discussed above, water service is provided by the City of Anaheim. The estimated buildout water supply requirement for the Project is projected to be 4,012 AFY. This is approximately

6.0 percent of the total City supply requirement estimated for 2045 in the City’s 2020 UWMP. The WSA indicates that the City would have adequate water supplies to meet demands during normal, single-dry, and multiple-dry years to 2045 (Psomas 2023a). Because the WSA included a review of known projects served by the City the Project would not contribute considerably to a significant cumulative impact on water supplies.

Additionally, the Project would be served by existing water infrastructure and would not contribute considerably to a significant cumulative impact on water facilities.

The Project would result in a less than significant cumulative 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, development of The Disneyland Resort would increase sewer flows however, with construction of improvements identified in EIR No. 311 and implementation of mitigation by developers in the area on a fair share basis, a significant cumulative impact would not occur. According to SEIR No. 340, cumulative impacts on sewer services associated with buildout of the ARSP and potential future projects would be less than significant.

As discussed above in Section 5.16.3, under Threshold 5.16-1, a Sewer Study was prepared to analyze adequacy of the sewer system. For the buildout alternatives, potential future capacity constraints may exist in certain areas based on specific location and timing of Project flows and other future flows. As discussed previously, these impacts would be reduced to less than significant levels with implementation of MMs UTIL-8, UTIL-9, UTIL-10 , and UTIL-11 and compliance with the terms identified in the Development Agreement related to cost sharing for future improvements.

Storm Drain
According to EIR No. 311, implementation of improvements recommended in the EIR No. 311 and in the City’s Master Plan of Drainage for the South Central Area would reduce potential cumulative impacts to less than significant levels. According to SEIR No. 340, all new growth within the ARSP area would occur in compliance with mitigation measures; however, the City has no control over the growth and storm water contributions of areas outside of its jurisdiction. 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.

Therefore, mitigation of these impacts would be outside of the City’s jurisdiction, and the potential cumulative impact would be significant and unavoidable.

The cumulative study area for storm drains includes the public storm drain system within the City of Anaheim as well as tributary systems beyond the City’s limits. The Project and other new development anticipated would result in changes to on-site land uses, including development of surface parking areas with hotel and theme park uses. Although development within the DRSP and ARSP properties would include landscaped areas consistent with the Design Plans in both the DRSP and ARSP, such land conversion may result in increased impervious surfaces and may increase the amount and velocity of surface runoff entering the storm drain system, which was already fully evaluated in EIR No. 311 and SEIR No. 340. 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. However, Disney has paid all required fees associated with funding utility improvements, including fees related to the construction of improvements to the storm drainage system, theref ore, impacts would be less than significant assuming compliance with standard requirements. All other future development in the cumulative study area would also be responsible to convey, retain, and treat storm water as well as ensure payment of storm drain impact fees to fund the construction of improvements to the storm drainage system within cumulative study area.

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

Electricity
According to EIR No. 311, with implementation of required mitigation The Disneyland Resort Project would not contribute to a significant and unavoidable cumulative impact related to electricity. According to SEIR No. 340, the City would be able to serve the ARSP at full buildout while maintaining existing and planned services within its respective service areas, and all projects would be required to comply with State and local regulations related to energy conservation. Therefore, buildout of the ARSP would not have a cumulative impact related to electricity.

Electricity would be provided by the City on demand, consistent with the City’s Electric Rates, Rules, and Regulations. The Project and other new development in the service area would result in increased demand for electricity and an increased demand on the existing distribution system.

Future development of the Project would be required to coordinate with the City to implement necessary upgrades to existing facilities or construction of new facilities to accommodate the anticipated demand, including the construction of up to 12 new switch stations within the Project Site. Additionally, on-site energy use would be reduced through compliance with Title 24, the CalGreen Code, and other energy conservation programs and policies. Cumulative projects in the County would also comply with the same regulations.

Natural Gas
According to EIR No. 311, with implementation of required mitigation, The Disneyland Resort Project would not contribute to a significant and unavoidable cumulative impact related to natural gas. According to SEIR No. 340, ad equate capacity was identified to serve buildout of the ARSP and additional development within the SCG service area would comply with Title 24; therefore, it was concluded that the ARSP contribution to cumulative natural gas impacts would be considered less than significant.

Natural gas service would be provided by SCG on demand, consistent with CPUC requirements.

The Project and other new development in the service area would result in increased demand for natural gas and an increased demand on the existing distribution system. Future development of the Project would be required to coordinate with SCG to implement necessary upgrades to existing facilities or construction of new facilities to accommodate the anticipated demand.

Additionally, on-site energy use would be reduced through compliance with Title 24, the CalGreen Code, and other energy conservation programs and policies. Cumulative projects in the County would also comply with the same regulations.

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Solid Waste
According to EIR No. 311, The Disneyland Resort Project would contribute to a significant and unavoidable cumulative impact related to solid waste. According to SEIR No. 340, buildout of the ARSP would not create demands for solid waste services that exceed the capabilities of the County’s waste management system. Consequently , buildout of the ARSP would not have a significant cumulative contribution to solid waste impacts.

Solid waste collection services are provided on demand by private haulers, and cumulative impacts on their services would occur from future development in their service area. Available landfill capacity is expected to decrease over time with future growth and development in Orange County. Waste reduction and recycling programs and regulations are expected to reduce this demand and extend the life of existing landfills. Also, CalRecycle is responsible for administering and monitoring State solid waste reduction initiatives, and individual jurisdiction’s ability to meet these requirements. It is assumed that the role of CalRecycle would continue in the future. Based on the available capacity of landfills in the r egion and the fact that no new demand beyond what was previously evaluated as part of The Disneyland Resort Project and the ARSP Project, the Project would not contribute considerably to a significant cumulative impact to landfill capacity or solid waste regulations.

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

Telecommunications
According to EIR No. 311, with implementation of required mitigation, The Disneyland Resort project would not contribute to a significant and unavoidable cumulative impact related to telecommunications. According to SEIR No. 340, the ARSP and surrounding areas, including future development, would continue to be served by existing infrastructure; buildout of the ARSP would not result in a significant contribution to cumulative impacts; and mitigation measures were not required.

The cumulative study area for telecommunications is inclusive of numerous telecommunications providers’ service areas. Future growth and development in the region would generate additional demand for telecommunication services. As with the Project, all future projects in the area would be responsible for connection to existing facilities and would be required to comply with all applicable regulations related to telecommunications.

5.16.5 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.

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Public Services and Utilities – Water
MM UTIL-1 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. (EIR No. 311, MM 3.10.6-2; SEIR No. 340, MM 5.15-1)
MM UTIL-2 Prior to each final building and 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. (EIR No. 311, MM 3.10.6-3) 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)
MM UTIL-4 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. (SEIR No. 340, MM 5.15-3)
MM UTIL-5 Prior to issuance of 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 DisneylandForward
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to the satisfaction of the Public Utilities Department, Water Engineering Division, in accordance with the building permit plans. (SEIR No. 340, MM 5.15-5) MM UTIL-6 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 1,000 square feet for non-residential uses 2,500 square feet in accordance with Ordinance No. 6160. (SEIR No. 340, MM 5.15-7)
MM UTIL-7 Ongoing during project developm ent and operations, the property owner/developer shall implement the following required improvements to the water supply system, in accordance with Anaheim’s Water Rates, Rules and Regulations, Water Services Administrative Procedures and Design Guidelines (APDG), and Water Services Standard Specifications (WSSS), within the timeframes described below or as further determined by the Public Utilities Department, Water Engineering Division. The cost of all Main Extensions, Main Enlargements, abandonments, relocations, and easements documents shall be paid for by the property owner/developer of the properties served by these mains in accordance with Rule 15A.
 In the Theme Park District, west of Disneyland Drive, all new fire water connections, including but not limited to, those that would serve, private fire hydrants, in The Disneyland Resort shall be made to water mains served by the 335 Pressure Zone. Specifically, no new fire water connections are permissible on existing water mains in Walnut Street or Magic Way. Any new fire connections for buildings adjacent to these mains shall connect to the 20- inch water main in Disneyland Drive.
 The Southeast District shall be served by at least two points of connection with internal looping.
o Any new water service connections along Harbor Boulevard shall require the construction of a 12-inch water main from Convention Way intersection to a point approximately 400-ft north of the intersection. o Any new connection to the existing water main in Clementine Street, north of Orangewood Avenue, shall require replacement of the existing 8-inch water main with a new 12-inch water main.
 Abandon the existing 12-inch water main within the Esplanade between Harbor Boulevard and Disneyland Drive. This work shall be completed concurrently with any proposed improvements along Disneyland Drive or Harbor Boulevard.  New easements may be required where public water infrastructure are located within private property through abandonment(s) of a public right-of-way. Such easements shall limit improvements that impact access for operation and maintenance of existing facilities. Alternatively, the property owner/developer may abandon and/or relocate existing public water infrastructure provided the property owner/developer prepares an analysis to determine any associated and appropriate improvements due to the work. The property owner/developer shall submit the analysis and any associated improvement plans to the Public Utilities Department, Water Engineering Division for review and approval.  Prior to issuance of building permits, the property owner/developer shall submit hydraulic analyses to determine the adequacy of existing and proposed facilities if required by the Public Utilities Department, Water Engineering Division.

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MM HWQ-2 Exclusive of the Theme Parks including the retail/entertainment component, prior to issuance of each building permit (for non Setback Realm Areas); prior to approval of Final Site Plan (for Setback Realm Areas); for the West Parking facility: 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 Areas (for the final landscape plans for West Street/Disneyland Drive setback landscape, Cerritos Ave. setback landscape, landscaping at entrance to hotels and landscaping interior to hotel and RD&E parking), Prior to issuance of each building permit, the property owner/developer shall submit landscaping and irrigation plans and an Irrigation Management Program. This landscape plan shall include a maintenance program to control the use of fertilizers and pesticides, and an irrigation system designed to minimize surface runoff and overwatering. Additionally:
a. The landscape plans shall be prepared and certified by a licensed landscape architect. The landscape architect shall submit plans in accordance with Anaheim’s Landscape Water Efficiency Ordinance and Guidelines including:

1. Project Information

2. Maximum Applied Water Use expresses as annual totals.

3. Soil management report or specifications.

4. Landscape design plan.

5. Irrigation design plan.

6. Grading design plan.
b. The Irrigation Management Program shall specify methods for monitoring the irrigation system and shall be designed by an irrigation engineer (plans to be submitted in accordance with the Specific Plan). The system shall ensure that irrigation rates do not exceed the infiltration of local soils and that the application of fertilizers and pesticides do not exceed appropriate levels of frequencies.
c. The landscape and irrigation plans shall be developed to be consistent with the provisions of the Specific Plan, which require that the Estimated Applied Water Use (EAWU) to be less than the Maximum Applied Water Allowance (MAWA) or that the landscape irrigation system 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. In addition, all irrigation systems shall be designed so that they will function properly with reclaimed water, if it should become available. (EIR No. 311, MM 3.7-3; SEIR No. 340, MM 5.15-4) Public Services and Utilities – Wastewater/Sewer
MM UTIL-8 Prior to issuance of any Building Permit for any new hotel development within the Theme Park District that proposes a portion or the entirety of the hotel project’s sewer flow to discharge to the City sewer system on Harbor Boulevard, north of Katella Avenue, the property owner/developer shall prepare a Sewer Study for review and approval by the City Engineer, funded by the property owner/developer.

Said Sewer Study shall evaluate whether there is adequate capacity in the Harbor Boulevard sewer system to accept the flow from the proposed new hotel use. The DisneylandForward
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Sewer Study shall determine whether the proposed hotel project would create a deficiency in the Harbor Boulevard sewer system or the downstream City sewer system. If the Sewer Study shows there would be deficiency in the Harbor Boulevard sewer system or the downstream sewer system, the Sewer Study shall identify the required sewer system upgrades. If a sewer system upgrade is required, the property owner/developer shall be responsible for the design and construction of the upgrade to the sewer system and all associated improvements [collectively, “Sewer Improvements”]. The City-identified and approved cost of the Sewer Improvements may be credited toward the applicable sewer impact fees for the hotel project upon completion of the Sewer Improvements and acceptance by the City. The design of the Sewer Improvements and the related sewer improvement plans shall be completed prior to issuance of any Building Permit for the hotel project and the sewer improvement plans shall identify all associated improvements required for the required Sewer Improvements. Construction of Sewer Improvements shall be completed prior to final building and zoning inspections for the hotel. If no sewer system upgrade is required, the developer shall be required to pay the applicable sewer impact fees, pursuant to A.M.C.

10.12.085, with applicable credits applied for sewer flows from existing uses to be removed.

MM UTIL-9 Prior to issuance of a plumbing permit resulting in a cumulative flow of more than 50 gpm peak in the Theme Park District resulting in redirected existing sewer flows that currently do not flow to Harbor Boulevard to instead flow to Harbor Boulevard via non-gravity flow (e.g. lift station, force main, ejector pump, etc.), the property owner/developer shall prepare a Sewer Study for review and approval by the City Engineer, funded by the property owner/developer. Said Sewer Study shall evaluate whether there is adequate capacity in the Harbor Boulevard sewer system to accept the proposed redirected flow. The Sewer Study shall determine whether the proposed redirected flow would create a deficiency in the Harbor Boulevard sewer system or the downstream City sewer system. If the Sewer Study shows there would be deficiency in the Harbor Boulevard sewer system or the downstream sewer system, the Sewer Study shall identify the required sewer system upgrades. If a sewer system upgrade is required, the property owner/developer shall be responsible for the design and construction of the upgrade to the sewer system and all associated improvements [collectively, “Sewer Improvements”]. The City-identified and approved cost of the Sewer Improvements may be credited toward the applicable sewer impact fees for the hotel project upon completion of the Sewer Improvements and acceptance by the City. The design of the Sewer Improvements and the related sewer improvement plans shall be completed prior to issuance of any Building Permit for the hotel project and the sewer improvement plans shall identify all associated improvements required for the required Sewer Improvements. Construction of Sewer Improvements shall be completed prior to final building and zoning inspections for the hotel. If no sewer system upgrade is required, the developer shall be required to pay the applicable sewer impact fees, pursuant to A.M.C.

10.12.085, with applicable credits applied for sewer flows from existing uses to be removed.

MM UTIL-10 Prior to issuance of the first building permit for development of over 10,000 sf in the Southeast District or Theme Park East Overlay, the property owner/developer shall prepare a Sewer Study for review and approval by the City Engineer, funded by the property owner/developer. Said Sewer Study shall evaluate whether the total sewer flow proposed to the Katella Avenue sewer system, east of Harbor DisneylandForward
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Boulevard, for development authorized by the DisneylandForward project for the Theme Park East Overlay/Southeast District does not exceed a peak flow of 285 gpm. And that the total sewer flow proposed to be directed to the Harbor Boulevard sewer system, south of Katella Avenue, for development authorized by the DisneylandForward project for the Theme Park East Overlay/Southeast District does not exceed a peak flow of 2,000 gpm (total allowable development within Theme Park East Overlay/Southeast District). If the projected sewer effluent flow exceeds these stipulated amounts for either the Katella Avenue or Harbor Boulevard sewer system, the Sewer Study shall determine whether the development project creates a deficiency in the Katella Avenue sewer system, east of Harbor Boulevard, or the Harbor Boulevard sewer system, south of Katella Avenue, sewer collections systems and the downstream City sewer system.

Should a deficiency be created, the Sewer Study shall identify the required sewer system upgrades and improvements (“Sew er Improvements”). If Sewer Improvements are required, the property owner/developer shall be responsible for the design and construction of the Sewer Improvements. The City-identified and approved cost of the sewer improvements may be credited toward the applicable sewer impact fees for the development project upon completion of the Sewer Improvements and acceptance by the City. The design of the Sewer Improvements and the sewer improvement plans shall be completed prior to issuance of any Building Permit for development in the Theme Park East Overlay/Southeast District and shall identify all associated improvements required for the required Sewer Improvements. Construction of Sewer Improvements shall be completed prior to the first final building and zoning inspection for development within the Theme Park East Overlay/Southeast District. If no improvement is required, the developer shall be required to pay the applicable sewer impact fees, pursuant to A.M.C. 10.12.085.

MM UTIL-11 Prior to issuance of any Building Permit for any new hotel development within the Parking Overlay (between Harbor Boulevard and Manchester Avenue), the property owner/developer shall prepare a Sewer Study for review and approval by the City Engineer, funded by the property owner/developer. Said Sewer Study shall evaluate the sewer flow from the hotel(s) directed to Clementine Street and ultimately Katella Avenue. Sewer improvements required to address deficiencies in the sewer systems in Clementine Street and/or Katella Avenue, east of Harbor Boulevard, shall be the sole responsibility of the property owner/developer (“Clementine and Katella Sewer Improvements”). Should a deficiency be created, the Sewer Study shall identify the required sewer system upgrades and improvements. If a sewer system upgrade is required, the property owner/developer shall be responsible for the design and construction of the Clementine and Katella Sewer Improvement s and all associated improvements.

The City-identified cost of the Clementine and Katella Sewer Improvements may be credited toward the applicable sewer impact fees for the hotel project(s) upon completion of the Sewer Improvements and acceptance by the City. The design of the Clementine and Katella Sewer Improvements and the sewer improvement plans shall be completed prior to issuance of any Building Permit for the hotel project(s) and identify all associated improvements required for the required for the Sewer Improvements. Construction of sewer improvements shall be completed prior to issuance of the first certificate of occupancy for the first hotel development.

If no improvement is required, the developer shall be required to pay the applicable sewer impact fees, pursuant to A.M.C. 10.12.085.

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Public Service and Utilities – Storm Drains
MM UTIL-12 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:
c. 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.
d. 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 3.11.8-2 and PDF 3.10.8-1; SEIR No. 340, MM 5.18-1)
MM UTIL-13 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. (SEIR No. 340, MM 5.18-3) DisneylandForward
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Public Services and Utilities – Electricity
MM UTIL-14 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 comply with the California Energy Code ( Title 10), which may include the following:
• Consultation with the City energy-conservation experts at the Anaheim Public Utilities Community and Sustainability Division for assistance with energy- conservation design features.
• Use of high-efficiency air conditioning systems , connected if feasible to a computerized central energy management system, and meeting all control, scheduling and load efficiency requirements of the California Energy Code (Title 24, Building Efficiency Standards).
• Use of electric high-efficiency (NEMA) motors intended to conserve energy. • While recognizing the unique lighting apparatus required for some theme park uses, uUse of motion sensing lightswitch devices and light-emitting diode (LED) energy-efficiency lighting fixtures for indoor and outdoor lighting when feasible, T8 lamps, metal hallide and/or high-pressure sodium (HID) lamps.
 Incorporation of electric vehicle chargers into parking structures . (EIR No. 311, PDF 3.10.9-2; SEIR No. 340, MM 5.17-1)
MM UTIL-15 Prior to issuance of a building permit, if the property owner/developer incorporates grid-tied renewable energy generation systems into the project , they shall comply with the Anaheim Public Utilities Department’s most recent Interconnection Guidelines. (SEIR No. 340, MM 5.17-4) MM UTIL-16 The property owner/developer shall provide Anaheim Public Utilities Department electrical engineering staff with its forecasted electric demand and schedules to allow for sufficient lead time for planning, design, engineering, materials procurement, and construction of new electrical facilities, if required, to accommodate the Project’s additional or modified electrical demand. Forecasts must be at least two to five years: e.g., two years for the construction of up to two line extensions and five years for the construction of three line extensions or a new substation.

MM ENE-2 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 ResortAny new system improvements (e.g., substation, line connections), if required, shall be constructed in accordance with the City’s Electric Rates, Rules and Regulations and Electrical Specifications. Electrical Service Fees and other applicable fees will be assessed in accordance with the then current Electric Rates, Rules and Regulations and Electrical Specifications. (EIR No. 311, MM 3.10.9-3; SEIR No. 340, MM 5.17-2)
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Public Services and Utilities – Natural Gas
MM ENE-3 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. (EIR No. 311, MM 3.10.10-2) Public Services and Utilities – Solid Waste
MM UTIL-17 Ongoing during theme park operations and prior to final building and zoning inspections of new theme park development, the property owner/developer shall implement a solid waste management plan which has been reviewed and approved by the Public Works Department to ensure that the project plans comply with AB 939, SB 1383 related to reducing organic waste in landfill, the Solid Waste Reduction Act of 1989, as administered by the City of Anaheim, and the County’s and City’s Integrated Waste Management Plans. Implementation of said plan shall commence upon occupancy and shall remain in full effect as required by the Street and Sanitation Division and may include the following plan components:
a. Detailing the locations and design of on-site recycling facilities. b. Providing on-site recycling receptacles to encourage recycling. c. Complying with all Federal, State, and City regulations for hazardous material disposal.
d. 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 property owner/developer 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.
 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 The Disneyland Resort. (EIR No. 311, MM 3.10.3-2 and MM 3.10.3-3; SEIR No. 340, MM 5.19-1)
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MM UTIL-18 Oongoing during project operation, the existing solid waste recycling and waste minimization practices at The Disneyland Resort shall be expanded as feasible to serve new development in 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. (EIR No. 311, PDF 3.10.3-1; SEIR No. 340, MM 5.19-2)
MM UTIL-19 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. (SEIR No. 340, MM 5.19-3) MM UTIL-20 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. (SEIR No. 340, MM 5.19-4) MM UTIL-21 Ongoing during project operation, upon City request and no less than annually or more than semi-annually, the property owner/developer shall prepare and submit to the Planning Director or Planning Services Manager a consolidated Construction Waste Management Report for all development projects on Disney Properties demonstrating that at least 75 percent of non-hazardous construction and demolition debris has been recycled or salvaged, or has otherwise complied with the City’s waste diversion program, which Report shall identify the materials diverted from disposal and whether the materials have been sorted on site or co- mingled.
(SEIR No. 340, MM 5.19-5)
Public Service and Utilities – Television
MM UTIL-22 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 warranted based on the analysis, new or relocated equipment would be required. If the City of Anaheim determines that the proposed project creates a significant impact on broadcast television reception at local residences, the property owner/developer shall install 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. (EIR No. 311, MM 3.10.12-1)
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The following mitigation measures are either are not applicable to the Project, covered by other mitigation measures or completed:
 The following mitigation measures and project design features were satisfied by the approval of the 1996 Infrastructure and Parking Finance Agreement, issuance of bonds and construction of improvements: EIR No. 311 MM 3.10.6-5, MM 3.10.6-6, MM 3.10.6-8, MM 3.10.6-9, MM 3.10.7-3, MM 3.10.8-2, PDF 3.10.8-3, PDF 3.10.8-4.  The following measures and project design features were completed with the installation of improvements or completion of activities described in the measure: EIR No. 311 MM

3.10.6-4, 3,10.6-7, PDF 3.10.6-2, MM 3.10.7-2, PDF 3.10.7-1, MM 3.10.8-3, PDF 3.10.8-2, PDF 3.10.9-1, PDF 3.10.9-1a, PDF 3.10.9-3, and SEIR No. 340 MM 5.15-8.  SEIR No. 340 MM 5.15-9 and MM 5.18-2 are not applicable as they are obligations of the City.
 SEIR No. 340 5.15-6 has been replaced by MM UTIL-7.

5.16.6 IMPACT SUMMARY
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?
Impact Summary:

Water: 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.

Wastewater: 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.

Stormwater: 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.

Electricity: 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.

Natural Gas: 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: 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.

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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)?
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 analyses in EIR No. 311 and SEIR No. 340.

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?
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 5.16-4 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? Impact Summary: The Project would result in a less than significant impact 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.

Threshold 5.16-5 Would the project comply with Federal, State, and local management and reduction statutes and regulations related to solid waste? Impact Summary: The Project would result in a less than significant impact 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.

Cumulative Impacts
Impact Summary:

Water: The Project would result in a less than significant cumulative 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.

Wastewater: The Project would result in a less than significant cumulative 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.

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

Electricity: The Project would result in a less than significant cumulative 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.

Natural Gas: The Project would result in a less than significant cumulative 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.

Solid Waste: The Project would result in a less than significant cumulative impact 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.

Telecommunications: The Project would result in a less than significant cumulative 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.

5.16.7 REFERENCES
Anaheim, City of. 2017 (January). Anaheim Public Utilities Electric Utility Rules. Anaheim, CA: the City. https://www.anaheim.net/883/Electric-Utility-Rules. ———. 2004a (May). General Plan for the City of Anaheim (City Council Resolution No. 2004- 94). Anaheim, CA: the City. https://anaheim.net/712/General-Plan ———. 2004b (May). Final Anaheim General Plan and Zoning Code Update EIR No . 330 (Prepared by The Planning Center). Anaheim, CA: the City. https://www.anaheim.net/932/EIR-No-330-Volume-I-FEIR
———. 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=
Ardurra. 2023 (June). Hydraulic Analysis for DisneylandForward. Newport Beach, CA: Ardurra. (Appendix H-2)
California Air Pollution Control Officers Association (CAPCOA). 2022 California Emission Estimator Model (CalEEMod)
TM Version 2022.1.1.0, Developed by Trinity Consultants in Collaboration with SCAQMD and other California Air Districts. Sacramento, CA: CAPCOA.

California Department of Resources Recycling and Recovery (CalRecycle). 2023. History of California Solid Waste Law, 1985-1989. Sacramento, CA: CalRecycle. https://calrecycle.ca.gov/laws/legislation/calhist/1985to1989/ ———.2019a. SWIS Facility/Site Activity Details: Olinda Alpha Landfill (30-AB-0035).

Sacramento, CA: CalRecycle.
https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/2757?siteID=2093.

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———.2019b. SWIS Facility/Site Activity Details: Frank R. Bowerman Sanitary LF (30-AB-0360).

Sacramento, CA: CalRecycle.
https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/2767?siteID=2103.

CH2MHill. 2006 (January). Master Plan of Storm Drainage for East Garden Grove Wintersburg Channel Tributary Area. Anaheim, CA: the City. https:
//www.anaheim.net/DocumentCenter/View/9163/East-GG-Wintersburg?bidId= CNC Engineering. 2009 (June). Master Plan of Storm Drainage for Anaheim Barber City Channel Tributary Area . Anaheim, CA: the City. https
://www.anaheim.net/DocumentCenter/View/9161/Barber-Channel?bidId= Halligan, Aimee 2022 (December 2). Personal communication. Email communication between A.

Halligan (OC Waste & Recycling) and M. Larum (Psomas).

Psomas. 2023a (July). DisneylandForward Water Supply Assessment. Santa Ana, CA: Psomas. (Appendix L-1)
———.2023b (August). City of Anaheim DisneylandForward Sewer Study. Santa Ana, CA:

Psomas. (Appendix L-2)
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6-1 Section 6.0 – Alternatives to the Proposed Project
SECTION 6.0

ALTERNATIVES TO THE PROPOSED PROJECT

6.1 INTRODUCTION
In compliance with CEQA Guidelines Section 15126.6(a), an EIR must “describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but wo uld avoid or substantially lessen any significant effects of the project, and evaluate the comparative merits of the alternatives”. The City of Anaheim, as the CEQA Lead Agency, is responsible for selecting a range of proposed Project alternatives. This section identifies potential alternatives to the Project and evaluates them, as required by CEQA.

Key provisions of the CEQA Guidelines on alternatives (Sections 15126.6[b], 15126.6(e) and15126.6[f]) are summarized below to explain the foundation and legal requirements for the alternatives analysis in this Draft Subsequent EIR.
 The discussion of alternatives shall focus on alternatives to the proposed project or its location which are capable of avoiding or substantially lessening any significant effects of the proposed project, even if these alternatives would impede to some degree the attainment of the proposed project objective, or would be more costly (Section 15126.6[b]);
 The specific alternative of “no project” shall also be evaluated along with its impact (Section 15126.6[e][1]);
 The “no project” analysis shall discuss t he existing conditions at the time the Notice of Preparation is published, and at the time the environmental analysis is commenced, as well as what would reasonably be expected to occur in the foreseeable future if the proposed project were not approved, based on current plans and consistent with available infr astructure and community services. If the environmentally superior alternative is the “no project” alternative, the Draft EIR shall also identify an environmentally superior alternative among the other alternatives (Section 15126.6[e][2]);
 The range of alternatives required in a Draft EIR is governed by the “rule of reason” that requires the Draft EIR to set forth only those alternatives necessary to permit a reasoned choice. The alternatives shall be limited to ones that would avoid or substantially lessen any of the significant effects of the proposed project. Of those alternatives, the Draft EIR need examine in detail only the ones that the Lead Agency determines could feasibly attain most of the basic objectives of the proposed project. The range of feasible alternatives shall be selected and discussed in a manner to foster meaningful public participation and informed decision making. Among the factors that may be taken into account when addressing the feasibility of alternatives are site suitability, economic viability, availability of infrastructure, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries, and whether the proponent can reasonably acquire, control or otherwise have access to the alternative site (or the site is already owned by the proponent) (Section 15126.6[f]);
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 [For alternative locations,] only locations that would avoid or substantially lessen any of the significant effects of the proposed project need be considered for inclusion in the Draft EIR (Section 15126.6[f][2][A]);  If the Lead Agency concludes that no feasible alternative locations exist, it must disclose the reasons for this conclusion, and should include the reasons in the Draft EIR. For example, in some cases there may be no feasible alternative locations for a geothermal plant or mining project which must be in close proximity to natural resources at a given locations (Section 15126.6[f][2][B]); and
 A Draft EIR need not consider an alternative whose effect cannot be reasonably ascertained and whose implementation is remote and speculative (Section 15126.6[f][3]).

Since this Draft Subsequent EIR analyzes the impacts of the Project that are new or substantially more severe than those previously disclosed in EIR No. 311 and SEIR No. 340, this alternatives analysis focuses on these new significant impacts. Alternatives to The Disneyland Resort Project and the ARSP Project were analyzed in EIR No. 311 and SEIR No. 340, respectively, and are not required to be re-analyzed here under CEQA supplemental review standards. The City previously considered and rejected these alternatives to The Disneyland Resort Project and the ARSP Project and adopted findings regarding the alternatives as part of the approvals of those projects.

Pursuant to the guidelines stated above, a range of alternatives to the Project is considered and evaluated in this Draft Subsequent EIR. These alternatives were developed during project planning and environmental review. The discussion in this section provides the following:
 A description of alternatives considered;
 A comparative analysis of the alternatives under consideration and the DisneylandForward Project. The focus of this analysis is to determine if alternatives are capable of eliminating or reducing the significant environmental effects of the Project to a less than significant level; and
 An analysis of whether the alternatives meet most of the objectives of the Project (as presented in Section 3.4 of this Draft Subsequent EIR and restated below).

6.2 SUMMARY OF PREVIOUS ENVIRONMENTAL DOCUMENTATION
The Disneyland Resort EIR No. 311
EIR No. 311 included an analysis of seven alternatives:
 No Project/No Development Alternative;
 No Project/Continuing Development Alternative;
 Design Alternative;
 Land Use Alternative;
 Reduced Project Scale Alternative;
 Increased Project Scale Alternative; and
 Alternative Site.

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EIR No. 311 provided a full analysis for each alternative, including a comparison to the proposed project. EIR No. 311 determined that the No Project/No Development Alternative would be the environmentally superior alternative. In accordance with CEQA requirements requiring selection of another alternative if the No Project alternative is the environmentally superior alternative, EIR No. 311 found that the Design Alternative would be the most environmentally superior of the development alternatives. The Design Alternative would involve development of the same project site; however, proposed land uses would be reconfigured. Specifically, frontage of the public parking facility along Walnut Street would be reduced by roughly one quarter; the East Parking Area would be reconfigured to 44 acres with a parking structure and surface parking; the Future Expansion District would include 56 acres of land that would not be developed; parking facilities would be reconfigured; the Hotel District would be decreased in acreage to retain an existing agricultural field; and the maximum density of the Hotel District would be reduced by 1,300 hotel rooms and 3,330 parking spaces. EIR No. 311 concluded that the Design Alternative would reduce impacts to land use; transportation; air quality; noise; population, housing and employment; public services and utilities; visu al resources; aesthetics; and energy. Significant and unavoidable impacts related to land use (loss of prime farmland) and solid waste would still occur. The Design Alternative was found to fully implement the objectives of the proposed project.

Anaheim Resort Specific Plan SEIR No. 340
SEIR No. 340 identified the alternatives analyzed in MEIR No. 313 and provided a comparison for the project evaluated in SEIR No. 340:
 No Project/Continuing Development
 Modified Land Use Alternative: Inclusive of Hote l Circle Specific Plan area into the Project Area
 Lower Intensity Land Use Alternative A (Year 2000)
 Lower Intensity Land Use Alternative B (Year 2008)
Due to changed conditions, a full alternatives analysis was not prepared for either the No Project/Continuing Development or Modified Land Use Alternative.

The Lower Intensity Land Use Alternative A assumed that development would be limited to implementation of the first stage of ARSP development (Year 2000). Specifically, the alternative assumed that all approved hotel/motel development within the ARSP would be constructed by Year 2000, which would include approximately 1,000 hotel rooms. Total build out of the ARSP under this alternative would result in approximately 12,190 hotel rooms by Year 2000 (11,190 existing rooms [i.e., at the time MEIR No. 313 was prepared] plus approximately 1,000 approved hotel rooms). All impacts identified in SEIR No. 340 would be avoided; however, this alternative would fail to achieve 12 of the project’s 16 objectives.

Implementation of the Lower Intensity Land Use Alternative B would allow for development of up to 16,200 hotel rooms within the ARSP by Year 2008. As described in SEIR No. 340, this alternative would allow for development of up to 16,200 hotel rooms within the ARSP over a 14- year period, with the build out year changing to Year 2024, which represents a net increase of 4,613 hotel rooms or hotel room equivalents over existing development. This alternative would reduce the employment impact from significant and unavoidable to less than significant; however, this alternative would not support all of the identified project objectives.

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The Lower Intensity Land Use Alternative A: Year 2000 Scenario Alternative, as modified for SEIR No. 340, was identified as the environmentally superior alternative.

6.3 PROJECT SUMMARY
As detailed in Section 3.0, Project Description, to allow continued, long-term growth of The Disneyland® Resort, Walt Disney Parks and Resorts U.S., Inc. (Disney) proposes the DisneylandForward (Project), which would allow the transfer of uses permitted under The Disneyland Resort Project to other areas of the Disneyland Resort Specific Plan No. 92-1 (DRSP) and properties within the Anaheim Resort Specific Plan No. 92-2 (ARSP) owned or leased by Disney or other subsidiaries of The Walt Disney Company (Disney ARSP Properties, and, collectively with Disney’s properties in the DRSP, Disney Property or Disney Properties). These areas are or will be considered to be part of The Disneyland Resort Project as modified by the DisneylandForward Project.

The Project would not increase the amount of development square footage or hotel rooms currently allowed in the DRSP and analyzed in Environmental Impact Report (EIR) No. 311, which the City of Anaheim (City) certified in 1993, or the number of hotel rooms currently allowed in the ARSP and analyzed in Supplemental Environmental Impact Report No. 340, which the City certified in 2012. However, the Project would permit an increase of 4,376 theme park-related parking spaces in the ARSP. The Project also would provide for future administrative review by the City of Disney’s development projects on Disney Property, which would rely on this Subsequent Environmental Impact Report in accordance with CEQA standards.

The Project Site is located entirely within the City in Orange County, California, within an area known as The Anaheim Resort®, a 1,078-acre portion of the City especially designated by the City's General Plan for Commercial Recreation land uses and which is intended to provide for tourist and entertainment-related industries, such as theme parks, hotels, tourist-oriented retail, movie theaters, and other visitor-serving facilities. The Anaheim Resort includes the following three specific plan areas: DRSP (489.7 acres), ARSP (581.3 acres) and Hotel Circle Specific Plan No. 93-1 (HCSP) (6.8 acres). The Project Site is located within areas regulated by the DRSP and the ARSP.

The Project Site encompasses The Disneyland Resort, including the existing Theme Park, Hotel, Parking and Future Expansion Districts, and the Disney ARSP Properties.

The Disneyland Resort Project
The City analyzed the environmental impacts of The Disneyland Resort Project, including the adoption of the DRSP, in EIR No. 311, which the City certified in 1993 along with the adoption of Mitigation Monitoring Program No. 0067. In 1996, in conjunction with an amendment to The Disneyland Resort Project, the City Council approved an Addendum to EIR No. 311, including a Modified Mitigation Monitoring Plan No. 0067. Table 6-1, Uses Currently Allowed Under DRSP/ARSP For Disney Properties, details allowable development.

As of the date of the Notice of Preparation of this Subsequent EIR, October 21, 2021, Disney has developed approximately 45 percent of the approved square footage for theme park uses.

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The Anaheim Resort Specific Plan Project
The City analyzed the environmental impacts of the ARSP in Master EIR No. 313, which the City certified in 1994, along with the adoption of Mitigation Monitoring Program No. 85C. In December 2012, the City certified Supplemental EIR (SEIR) No. 340 in support of the approval of Amendment No. 14 to the ARSP Project. SEIR No. 340 reevaluated the environmental changes in and around the ARSP area since certification of Master EIR No. 313 in September 1994 and incorporated the relevant findings from Master EIR No. 313. As detailed in Table 6-1, Uses Currently Allowed Under DRSP/ARSP For Disney Properties, the ARSP, as previously amended, allows development on Disney ARSP Properties of up to 75 or 50 hotel rooms per gross acre with approval of a Final Site Plan. Section 18.116.070 of the City of Anaheim Municipal Code also allows the development of theme parks, entertainment venues, and transportation facilities on these properties with approval of a conditional use permit.

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TABLE 6-1

USES CURRENTLY ALLOWED UNDER DRSP/ARSP

FOR DISNEY PROPERTIES
Disney DRSP
Property
Maximum Allowable
Development Under
DRSP Existing Development1 Remaining Entitlement 1
Hotel District Uses (97 acres)
Hotel Rooms 5,600 hotel rooms 2,342 hotel rooms 2 3,258 hotel rooms Hotel Retail/Restaurant 300,0 00 sf 159,549 sf 140,451 sf Hotel Meeting Space 200,000 sf 161,220 sf 38,780 sf
Parking Spaces 9,930 spaces 5,885 spaces 4,045 spaces
Theme Park District (292 acres)
Theme Park 6,850,000 sf 3,192,885 sf3 3,657,115 sf
Administration Building 475,000 sf 305,430 sf 169,570 sf Administration Building
Parking 2,300 spaces 1,545 spaces 755 spaces
Parking District (57.1 acres)
East Parking Area 17,600 spaces 2,179 spaces4 15,421 spaces West Parking Area 16,700 spaces 16,298 spaces 402 spaces Future Expansion District (24.7 acres)
Parking Area 5,100 spaces 2,529 spaces 2,571 spaces
Disney ARSP
Properties
Maximum Allowable
Development Under
ARSP Existing Development1 Remaining Entitlement1
C-R District Uses (75.4 acres)
1515 S. Manchester
Ave
1585 S. Manchester
Ave
1530 S. Harbor Blvd
(14.88 acres)
1,116 hotel rooms (75
rooms per gross acre or 75
rooms per lot or parcel,
whichever is greater)
Cast Member parking
(1,261 spaces – temporary
parking lot initially approved
on May 8, 2019, and an
approximately 67,424-
square foot office building
1,116 hotel rooms
1900 S. Harbor Blvd
(44.66 acres)
3,348 hotel rooms (75
rooms per gross acre or 75
rooms per lot or parcel,
whichever is greater)5
Toy Story Parking Lot
(4,635 spaces-temporary
parking lot approved
through June 26, 2024)
3,348 hotel rooms
333 W. Ball Road
(10.69 acres)
534 hotel rooms (50 rooms
per gross acre or 75 rooms
per lot or parcel, whichever
is greater)
Cast Member parking
(1,324 spaces) 534 hotel rooms
1717 S. Disneyland
Drive
(5.15 acres)
564 hotel rooms (50 rooms
per gross acre or 75 rooms
per lot or parcel, whichever
is greater)6
Paradise Pier Hotel (489
rooms and approximately
17,619 square feet in
ancillary commercial uses)
45 hotel rooms
1 These numbers are as of the date of the Notice of Preparation, October 21, 2021; over the course of this environmental review process, these numbers may change due to ongoing development efforts based on current entitlements. 2 Hotel rooms include existing Vacation Ownership Resort (VOR) units at the Grand Californian Hotel and VOR units at the Disneyland Hotel under construction as of NOP.
3 This amount includes the existing 246,702 sf of retail, dining and entertainment in Downtown Disney as of the NOP. The DRSP allows up to 350,000 sf of retail, dining and entertainment sf in either the Theme Park or Hotel District. 4 This amount includes the existing 842 spac es in the Ball Cast Member Lot. The DRSP allows up to 5,000 parking spaces identified for the East Parking Area to be located in the Theme Park District. 5 Acreage for density excludes ulti mate public right-of-way for Clementine Street and Gene Autry Way. 6 The Paradise Pier Hotel property is co mprised of two parcels: a 4.48-acre parce l that includes 489 hotel rooms and a 0.67- acre property that is allowed 75 hotel rooms.

Source: City of Anaheim 2021.

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6-7 Section 6.0 – Alternatives to the Proposed Project
Non-Disney Properties
For non-Disney properties located in the DRSP or the ARSP, EIR No. 311 and SEIR No. 340, including the associated Mitigation Monitoring Plans, would continue to apply to future development. Specifically, development in District A, the Anaheim GardenWalk Overlay and the CR-Overlay would not be regulated by the mitigation measures associated with this Subsequent EIR.
1 6.3.1 PROJECT CHARACTERISTICS
The Project Site is located primarily within areas of The Anaheim Resort and in areas governed by the DRSP and ARSP. The Project Site also includes areas identified in the General Plan as planned extensions of Gene Autry Way between Harbor Boulevard and Haster Street and of Clementine Street between Katella Avenue and Orangewood Avenue, portions of which are outside The Anaheim Resort.

Within the DRSP, areas are currently divided into the following five Districts: Theme Park, Hotel, Parking, Future Expansion Districts, and District A. The DRSP, particularly the DRSP Zoning and Development Standards in Chapter 18.114 of the Anaheim Municipal Code, specifies the land uses allowed for each District. While no changes to overall boundaries of the DRSP are proposed, the Project would allow the transfer of theme park, hotel and other retail, dining and entertainment uses, and parking permitted under The Disneyland Resort Project among the Theme Park, Hotel, Parking, and Future Expansion Districts and divide the DRSP into the following four Districts:

Theme Park, Parking, Southeast District, and District A as summarized in Table 6-2, Proposed Development Summary for Disney Properties, and shown on Exhibit 1, Proposed DRSP and ARSP Development Districts and Overlays.

Within the ARSP, Disney ARSP Properties are within the Commercial Recreation (C-R) District (Development Area 1) of the ARSP. The ARSP, particularly the ARSP Zoning and Development Standards in Chapter 18.116 of the Anaheim Municipal Code, specifies the land uses allowed for this area. The Project would provide Overlays for Disney ARSP Properties to allow certain DRSP uses on Disney ARSP Properties as summarized in Table 6-2 and shown on Exhibit 1, Proposed DRSP and ARSP Development Districts and Overlays.

TABLE 6-2

PROPOSED DEVELOPMENT SUMMARY FOR DISNEY PROPERTIES

Disney DRSP Property Maximum Allowable Development Under DRSP Theme Park District – 389 acres
Hotel Rooms Up to 5,600 hotel rooms3
Hotel Retail/Restaurant Up to 300,000 sf
Hotel Meeting Space Up to 200,000 sf
Parking for Hotel Uses Up to 9,930 spaces
Theme Park District Retail Entertainment Up to 350,000 sf1 Theme Park and Back-of-house Uses Up to 6,850,000 sf1,5 Administration Building 475,000 sf
Administration Building Parking 2,300 spaces

1 Project-related actions that may impact non-Disney prop erties in the Project Site include proposed amendments to The Anaheim Resort Identity Program and The Anaheim Resort Public Realm Landscape Program, the removal of Gene Autry Way from the General Plan Circulation Element, and the construction of proposed pedestrian bridges.

DisneylandForward
Draft Subsequent EIR No. 352

6-8 Section 6.0 – Alternatives to the Proposed Project
TABLE 6-2

PROPOSED DEVELOPMENT SUMMARY FOR DISNEY PROPERTIES
Disney DRSP Property Maximum Allowable Development Under DRSP Theme Park Parking 5,000 spaces2
Parking District – 57.1 acres
East Parking Area (30.1 acres) Up to 17,600 spaces2
West Parking Area (27 acres) Up to 16,700 spaces
Southeast District – 24.7 acres
Theme Park Up to 390,000 sf5
Hotel Rooms Up to 1,852 hotel rooms3
Parking 5,100 spaces
Total Maximum Allowable Development
7,825,000 sf
5,600 rooms
51,630 spaces
Disney ARSP Properties8 Maximum Allowable Development Under ARSP Parking Overlay4 – 25.57 acres
1515 S. Manchester Ave
1585 S. Manchester Ave
1530 S. Harbor Blvd
A portion of the parking spaces allocated to the East Parking Area of the DRSP and up to 1,116 hotel rooms
333 W. Ball Road Up to 5,700 parking spaces and up to 534 hotel rooms6 Theme Park East Overlay – 52.6 acres7
1900 S. Harbor Blvd Up to 840,000 sf of theme park uses and up to 3,348 hotel rooms5 Theme Park West Overlay – 5.15 acres
1717 S. Disneyland Drive Up to 80,000 sf of theme park uses and up 564 hotel rooms5 Notes:
1 Up to 350,000 sf of the theme park and back-of-house sf may be developed as Retail, Dining and Entertainment sf. 2 Up to 5,000 parking spaces may be constructed within the Theme Park District; however, an equivalent number of potential parking spaces would be removed from the allotment for the East Parking Area. 3 Up to 1,852 hotel rooms may be constructed in the Southeast District; however, an equivalent number of potential hotel rooms would be removed from the allotment for the Theme Park District, such that the maximum number of hotel rooms would not exceed 5,600.
4 For any square footage for back-of-house uses or limited retail, dining and entertainment uses, the traffic generation characteristics of said uses shall not exceed those associated with the otherwise permitted hotel/motel (including accessory uses) density as determined by the City Traffic and Transportation Manager prior to approval of building plans. Further, the proposed development shall not result in infrastructure impacts greater than those associated with the property's permitted hotel/motel density, unless such impacts are duly analyzed and mitigated pursuant to subsequent environmental review (such impacts shall be determined through a sewer and transportation impact analysis to be submitted to the City Engineer).

Additional infrastructure studies may be required as determined by the Planning Director. 5 Theme park sf may be constructed in the Southeast Distri ct, the Theme Park East Overlay and the Theme Park West Overlay; however, an equivalent number of potential theme park sf would be removed from the allotment for the Theme Park District, such that the maximum theme park sf would not exceed 6,850,000 sf. The amount of restaurant sf in the Southeast District and the Theme Park East Overlay shall be further limited to up to 20 percent of the allotted theme park square footage in the District/Overlay.
6 Up to 5,700 parking spaces includes the number of existing spaces (1,324 spaces) plus additional spaces (4,376 spaces). 7 The planned extensions of Clementine St reet and Gene Autry Way are proposed to be removed as part of the Project; therefore, the total acreage for the Theme Park East Overlay has been adjusted to include the acreages associated with these street rights-of-way; however, the maximum intensity of up to 3,348 hotel rooms would not change. 8 Actual acres for hotel density to be determined by a licensed Civil Engineer/Land Surveyor.

Source: WDI 2021.

DisneylandForward
Draft Subsequent EIR No. 352

6-9 Section 6.0 – Alternatives to the Proposed Project
Proposed Modifications to The Disneyland Resort Project The Project proposes to reallocate allowable land uses within the Theme Park District (389 acres), the Parking District (57.1 acres), and the Southeast District (24.7 acres).2 The former Hotel District would become part of the Theme Park District and the Future Expansion District would become the Southeast District. The C-R Overlay and District A would continue to allow specific parcels in the DRSP to become part of The Disneyland Resort or be developed with the uses established by the ARSP. The Anaheim GardenWalk Overlay would continue to apply to specific parcels within the DRSP area and would provide for the development of the Anaheim GardenWalk lifestyle retail and entertainment complex.

The Project would allow Disney to move a portion of the unused approved theme park square footage to the existing Hotel District, which would become part of the new expanded Theme Park District of the DRSP. The Project also would allow Disney to move a portion of the unused approved theme park square footage to the existing Future Expansion District, which would become the Southeast District of the DRSP, and to the proposed Theme Park East and West Overlays of the ARSP.

Under the Project, Disney could develop cumulatively up to 6,850,000 previously approved square feet of theme park uses in the DRSP, including up to 6,850,000 previously approved square feet in the expanded Theme Park District if all theme park square footage were developed in the expanded Theme Park District. Disney coul d also develop a portion of this previously approved theme park square footage in the newly renamed Southeast District (up to 390,000 square feet), in the proposed Theme Park East Overlay (up to 840,000 square feet), and in the proposed Theme Park West Overlay (up to 80,000 square feet). If theme park square footage is developed in the Southeast District and Theme Park East and West Overlays, an equivalent amount of theme park square footage would be removed from the allotment for the Theme Park District, such that the maximum theme park square footage would not exceed 6,850,000 square feet.

Similarly, the Project would allow Disney to move the unused portion of the hotel room approvals from the existing Hotel District to the existing Theme Park District or the existing Future Expansion District, the newly renamed Southeast District. Under the Project, Disney could develop cumulatively up to 5,600 previously approved hotel rooms in the DRSP, including a combination of up to 5,600 previously approved hotel rooms in the expanded Theme Park District if all hotel rooms were developed in the expanded Theme Park District and up to 1,852 previously approved hotel rooms in the newly renamed Southeast District.

Disney is not seeking additional square footage for theme park uses or retail entertainment uses or additional hotel rooms within The Disneyland Resort as part of this Project. Instead, the Project would allow Disney to move the existing approvals to other areas governed by the DRSP and ARSP.

Proposed Modifications to the Anaheim Resort Specific Plan The Project would create a Theme Park East Overlay within the ARSP for the existing Toy Story Parking Lot and a Theme Park West Overlay within the ARSP for the existing Paradise Pier Hotel.

The Theme Park Overlay would allow Disney to develop theme park uses on these properties concurrently with the development of theme park uses on the expanded Theme Park District or

2 The total DRSP developable acreage would be increas ed with the proposed abandonm ent of public right-of-way in Magic Way, previously dedicated by Disney to the City.

DisneylandForward
Draft Subsequent EIR No. 352

6-10 Section 6.0 – Alternatives to the Proposed Project the Southeast District of the DRSP. With the Project, Disney could develop up to 840,000 square feet of previously approved theme park uses wi thin the Theme Park East Overlay and up to 80,000 square feet of previously approved theme park uses within the Theme Park West Overlay for a cumulative total of up to 920,000 square feet of previously approved theme park uses in these Overlays. The Anaheim Municipal Code currently allows theme park uses in these Overlay areas with approval of a conditional use permit.

The Project would create a Parking Overlay within the ARSP for the Disney ARSP Properties located at 1515 S. Manchester Avenue, 1585 S. Manchester Avenue, 1530 S. Harbor Boulevard, and 333 W. Ball Road. The Project would increase the number of permitted theme park parking spaces in the Parking Overlay at 333 W. Ball Road, permitting up to 5,700 parking spaces (this includes 1,324 existing spaces plus 4,376 additional spaces). The Parking Overlay would permit development of the same type of parking and transportation facilities allowed under Anaheim Municipal Code Section 18.114.080 for the East Parking Area of the Parking District of the DRSP, and the same type of back-of-house uses, limited retail, and dining and entertainment uses allowed under Anaheim Municipal Code Section 18.114.060 for the Theme Park District of the DRSP. Parking facilities in the Parking Overlay would be architecturally treated through use of terraced structures; landscaped buffers and berms; noise attenuation louvers along the openings on the lower levels and solid walls with landscaped planters on the upper levels; and additional landscaping in the setbacks.

6.3.2 PROJECT OBJECTIVES
Section 15124 of the CEQA Guidelines (14 California Code of Regulations (CCR), § 15124) requires an EIR to include a statement of objectives sought by a proposed project. This disclosure assists with the development of a reasonable range of proposed project alternatives to be evaluated in the EIR and provides a rationale for adoption of a Statement of Overriding Considerations if one is necessary. The statem ent of objectives should include the underlying purpose of the proposed project and may discuss project benefits.

The City of Anaheim established objectives relative to The Disneyland Resort Project analyzed in EIR No. 311. The objectives were intended to set the framework and criteria in which the pattern and intensity of growth for the DRSP area was envisioned. Many of these objectives remain applicable to the Project evaluated in this Subsequent EIR No. 352, which would amend The Disneyland Resort Project, analyzed in EIR No. 311, and the Anaheim Resort Specific Plan Project, analyzed in Master EIR No. 313 and SEIR No. 340.

The underlying purpose of the Project is to allow continued, long-term growth of The Disneyland Resort Project, approved by the City in 1993, by allowing the transfer of previously approved theme park, hotel, and other retail, dining and entertainment uses permitted under The Disneyland Resort Project to Disney Properties to support a fully integrated, multi-day vacation destination.

Another underlying purpose of the Project is to allow the City to perform administrative reviews of Disney’s development projects on Disney Properties.

The objectives of the Project are the ongoing implementation of the following Disneyland Resort Project and ARSP Project objectives which were in place when the City approved The Disneyland Resort Project and the ARSP Project:

The Disneyland Resort Project (from EIR No. 311) objectives:
 To reconfirm and enhance Southern California as one of the world’s greatest tourist destinations;

DisneylandForward
Draft Subsequent EIR No. 352

6-11 Section 6.0 – Alternatives to the Proposed Project  To support the ongoing transformation of The Anaheim Resort into a multi-day destination resort for use by Southern California metropolitan area residents, as well as visitors from around the world;

 To promote the goals of the Anaheim General Plan by enhancing visitor-serving commercial uses in the City and to provide a catalyst for the economic and physical enhancement of Anaheim;
 To support the buildout of a fully integrated resort that increases visitation levels and generates an economic base capable of supporting project components consistent with the objectives of the City;
 To maintain and enhance the economic vitality of the City of Anaheim and Orange County by providing business and job opportunities associated with the construction and operation of The Disneyland Resort;
 To enhance The Anaheim Resort by providing a wider range of attractions, hotel accommodations, restaurants, shopping opportunities, and public parking;  To accommodate existing and anticipated traffic through implementation of an innovative transportation and parking plan, including convenient access to parking facilities from freeways, use of conveyance systems to shuttle visitors from parking facilities and hotels to area attractions, and provision of pedestrian walkways throughout The Disneyland Resort;
 To lay a foundation for future economic expansion and minimize environmental impacts through comprehensive site development guidelines; and
 To develop public/private cooperation and partnership which utilize the private sector to fund vitally needed improvements in The Anaheim Resort to benefit the public.

The ARSP Project (from SEIR No. 340) objectives:
 To maintain and encourage Anaheim’s position as a nationally recognized tourist, convention and recreation center:
 To increase sales tax yields and further enhance the economic base of the community, thereby lessening the tax burden on real property;
 To encourage the development of quality facilities that complement conventions, family entertainment, and recreation within appropriate areas of the community; and  To maintain the integrity of the Commercial Recreation Area (now referred to as The Anaheim Resort) by permitting only compatible land uses within this designated area.

Additional objectives of the DisneylandForward Project include:
 To support the continued reimagination of The Disneyland Resort to meet and exceed evolving guest expectations for immersive entertainment and technological advances in theme park and other resort experiences.
 To continue to fulfill the following vision of Walt Disney: “Disneyland will never be completed…It will continue to grow as long as there is imagination left in the world.”  To allow the expansion of theme park and parking uses to Disney ARSP Properties to support the continued success and vitality of The Anaheim Resort, including The Disneyland Resort.

DisneylandForward
Draft Subsequent EIR No. 352

6-12 Section 6.0 – Alternatives to the Proposed Project In 2004, the Anaheim City Council adopted a comprehensive update of its General Plan, including some updates to the goals, policies and objectives applicable to The Anaheim Resort. The DRSP and ARSP would continue to implement goals and policies of the General Plan of the City of Anaheim and, specifically, the goal of the City of Anaheim to enhance the attraction of tourists and visitors to The Anaheim Resort. A complete discussion of the relationship between the DRSP, ARSP and the General Plan is found in Section 5.10, Land Use and Planning.

The Project also would generate substantial public revenues and employment opportunities.

Benefits to the local economy would include the creation of direct part-time and full-time employment positions associated with The Disneyland Resort, creation of indirect part-time and full-time employment positions associated with The Disneyland Resort’s supply chains, the labor income associated with these employment positions, additional economic output in the form of goods and services produced by The Disneyland Resort, and State and local tax revenue.

6.3.3 SIGNIFICANT AND UNAVOIDABLE IMPACTS
The Disneyland Resort EIR No. 311
The topics below were identified in EIR No. 311 as significant and unavoidable adverse impacts:
 Land Use-Related Plans and Policies. Loss of designated prime agricultural land;  Land Use Compatibility. Loss of designated prime agricultural land and the juxtaposition of commercial and residential uses;
 Transportation and Circulation. Short-term, construction-related significant and unavoidable impacts related to transportation associated with site preparation and construction; significant deficiencies in levels of service; and transportation disruption;  Air Quality. Construction- and operational-related emissions;  Aesthetics. Construction- and operational-related visual impacts;  Solid Waste. Limited landfill capacity;
 Public Services – Schools. School enrollment due to over-capacity situations; and  Utilities. Cumulative consumption of electricity and natural gas.

Anaheim Resort Specific Plan SEIR No. 340
SEIR No. 340 identified the following potential impacts as significant and unavoidable adverse impacts:
 Aesthetics. Significant shade and shadow impact on surrounding properties;  Air Quality. Regional construction and operational emissions; local PM10 and PM2.5 emissions;
 Greenhouse Gas Emissions. Direct and indirect cumulative GHG emissions;  Noise. Construction noise impacts;
 Transportation and Traffic . Intersections, arterial segments, freeway ramp termini intersections, freeway ramps, freeway mainlines, and freeway weaving areas would operate at unacceptable levels of service (LOS); the contribution to traffic volumes and levels of service at intersections in the City of Orange and at freeway ramps and mainlines; and DisneylandForward
Draft Subsequent EIR No. 352

6-13 Section 6.0 – Alternatives to the Proposed Project  Storm Water. Addition of storm water to the regional storm water system.

DisneylandForward Project
As previously mentioned, an EIR should consider a range of feasible alternatives that would attain most of the Project objectives, listed above, while reducing one or more of the significant and unavoidable impacts of the Project. The significant impacts associated with the DisneylandForward Project are summarized below:
 Air Quality
o The Project would result in a significant and unavoidable impact regarding regional construction emissions. This impact would not be new or substantially more severe when compared with the impact analyses in EIR No. 311 and SEIR No. 340. o The Project would result in a significant and unavoidable impact related to operational emissions of VOC, NOx, CO, PM10, and PM2.5. This impact would be new for PM10 and PM 2.5 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.
 Cultural Resources
o The Project would result in a significant and unavoidable impact on historical resources. This impact is new when compared with the impact analyses in EIR No. 311 and SEIR No. 340.
 Greenhouse Gas Emissions
o The Project would result in a significant and unavoidable impact related to generation of greenhouse gas emissions. This impact would be new when compared with the analysis in EIR No. 311, which did not address GHG Emissions.

This impact would not be new or substantially more severe when compared with the impact analysis in SEIR No. 340.
 Noise
o The Project may result in a temporary potentially significant and unavoidable construction noise impact even with the implementation of mitigation measures.

This impact would be new when compared with the impact analysis in EIR No. 311, but not new or substantially more severe when compared with the impact analysis in SEIR No. 340.
 Cumulative Impacts
o Air Quality: The Project would result in a significant and unavoidable cumulative impact related to air pollutant concentrations during construction and operations.

This impact would not be new or substantially more severe when compared with the impact analyses in EIR No. 311 and SEIR No. 340.
o Cultural Resources: The Project would result in a significant and unavoidable cumulative impact related to historic resources, which would be new when compared with the impact analyses in EIR No. 311 and SEIR No. 340. o Greenhouse Gas Emissions: While the development of the Project would be consistent with the GHG reduction goals, the Project would result in a significant and unavoidable cumulative impact related to greenhouse gas emissions. This DisneylandForward
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6-14 Section 6.0 – Alternatives to the Proposed Project impact would be new when compared with the impact analysis in EIR No. 311, which did not address GHG emissions . This impact would not be new or substantially more severe when compared with the impact analysis in SEIR No. 340.
o Noise: The Project could result in a temporary significant and unavoidable cumulative impact related to construction noise. This impact would be increased when compared with the impact analysis in EIR No. 311, but would not be new or substantially more severe when compared with the impact analysis in SEIR No. 340.

6.4 ALTERNATIVES CONSIDERED BUT NOT CARRIED FORWARD FOR DETAILED

ANALYSIS
Section 15126.6(c) of the CEQA Guidelines specifies that a Draft EIR should (1) identify alternatives that were considered by the Lead Agency but were eliminated from detailed consideration because they were determined to be infeasible during the scoping process and (2) briefly explain the reasons underlying the Lead Agency’s determination. This section of the CEQA Guidelines states: “Among the factors that may be used to eliminate alternatives from detailed consideration in an [Draft] EIR are: (i) failure to meet most of the basic project objectives, (ii) infeasibility, or (iii) inability to avoid significant environmental impacts”.

The following alternatives were considered during the scoping and planning process but were not selected for detailed analysis in this Draft Subsequent EIR.

6.4.1 NO PROJECT/NO FURTHER DEVELOPMENT
The No Project/No Further Development Alternative would involve retention of The Disneyland Resort and Disney ARSP Properties as currently developed and would not allow further development pursuant to existing entitlement s and approvals. Although no new impacts would occur with this alternative due to the lack of future development, this alternative would be inconsistent with the rights of Disney, as the property owner, for future continued development in accordance with previously certified EIR No. 311 and SEIR No. 340 and previously approved DRSP and ARSP along with Disney’s rights under the existing Development Agreement between the City and Disney, which was approved in 1996. Therefore, the No Project/No Further Development Alternative is not feasible.

Additionally, objectives of the Project involve the increase in visitation levels which would thereby support the City’s economic growth and the continued development of new experiences to meet evolving guest expectations. The lack of future development and opportunity for redevelopment would not support these objectives. Specifically, the No Project/No Further Development Alternative would not support the following objectives to the same degree as the DisneylandForward Project:
 To reconfirm and enhance Southern California as one of the world’s greatest tourist destinations;

 To support the ongoing transformation of The Anaheim Resort into a multi-day destination resort for use by Southern California metropolitan area residents, as well as visitors from around the world;

6-15 Section 6.0 – Alternatives to the Proposed Project  To maintain and enhance the economic vitality of the City of Anaheim and Orange County by providing business and job opportunities associated with the construction and operation of The Disneyland Resort;
 To enhance The Anaheim Resort by providing a wider range of attractions, hotel accommodations, restaurants, shopping opportunities, and public parking;  To accommodate existing and anticipated traffic through implementation of an innovative transportation and parking plan, including convenient access to parking facilities from freeways, use of conveyance systems to shuttle visitors from parking facilities and hotels to area attractions, and provision of pedestrian walkways throughout The Disneyland Resort;
 To lay a foundation for future economic expansion and minimize environmental impacts through comprehensive site development guidelines;
 To maintain and encourage Anaheim’s position as a nationally recognized tourist, convention and recreation center;
 To increase sales tax yields and further enhance the economic base of the community, thereby lessening the tax burden on real property;
 To encourage the development of quality facilities that complement conventions, family entertainment, and recreation within appropriate areas of the community;  To maintain the integrity of the Commercial Recreation Area (now referred to as The Anaheim Resort) by permitting only compatible land uses within this designated area;  To support the continued reimagination of The Disneyland Resort to meet and exceed evolving guest expectations for immersive entertainment and technological advances in theme park and other resort experiences;
 To continue to fulfill the following vision of Walt Disney: “Disneyland will never be completed…It will continue to grow as long as there is imagination left in the world”; and  To allow the expansion of theme park and parking uses to Disney ARSP Properties to support the continued success and vitality of The Anaheim Resort, including The Disneyland Resort.

In summary, the No Project/No Further Development Alternative is inconsistent with the right to develop according to existing entitlements and would also not meet most of the basic Project Objectives. Therefore, further analysis of the No Project/No Further Development Alternative is not provided in this Draft Subsequent EIR.

6.4.2 ALTERNATIVE SITE
CEQA requires the discussion of alternatives focus on alternatives to the Project or its location, which are capable of avoiding or substantially lessening any significant effects of the Project while feasibly attaining most of the project’s basic objectives. The key parts of the alternative location analysis are (1) the availability of alternative locations that are of necessary size and location that are available or owned by the applicant and (2) the consistency of the selected alternative location(s) with Project objectives and City adopted plans.

Further, the analysis focuses on
whether any of the significant effects of the DisneylandFoward Project would be avoided or substantially lessened by developing the Project at another location. Only locations that would avoid or substantially lessen any of the significant effects of the Project need be considered for inclusion in the Draft Subsequent EIR (CEQA Guidelines, Section 15126.6[f][2][A]).

DisneylandForward
Draft Subsequent EIR No. 352

6-16 Section 6.0 – Alternatives to the Proposed Project As detailed in Section 6.2.1, Project Characteristics, the Project Site is located within areas that are owned or leased by Disney or other subsidiaries of The Walt Disney Company and is currently developed with uses associated with The Disneyland Resort Project and the ARSP Project, including hotel, theme park, parking, and associated commercial recreation uses. The Project Site covers approximately 554 acres and includes all properties owned by Disney in The Anaheim Resort in order to provide a comprehensive, long-term development plan for all Disney Properties.

All existing and future development plans for the Project would occur within these areas which are located near each other and are able to be connected easily via pedestrian access.

In order to achieve a single, integrated project, the Alternative Site must be comprised of parcels or areas that are contiguous or immediately proximate to each other, are zoned for visitor-serving uses, of adequate size, and owned by Disney. Due to the lack of available land that meets these requirements, an Alternative Site is not considered to be a feasible alternative for the DisneylandForward Project. Additionally, the Project proposes to include existing development which could not be accomplished through an Alternative Site.

As identified in Section 6.2.2 above, the DisneylandForward objectives focus on maintaining and enhancing Disney’s presence in and economic support of the City while providing an optimal guest experience. Construction of the Project at any other location in the City would not meet these key Project objectives and would not maximize functional space, allow for greater interaction between uses, or improve the efficiency of space within the Project Site. It would also decrease pedestrian and vehicular connectivity and accessibility, by decentralizing the guest experience through the introduction of new off-site locations. Further, this alternative would not maintain or enhance the synergy that comes from providing complementary uses in a single Project Site. Thus, implementing the Project through development at another site would not accomplish the objectives of the Project. Specifically, the Alternative Site would not support the following objectives to the same degree as the DisneylandForward Project:
 To reconfirm and enhance Southern California as one of the world’s greatest tourist destinations;

 To support the buildout of a fully integrated resort that increases visitation levels and generates an economic base capable of supporting project components consistent with the objectives of the City;
 To enhance The Anaheim Resort by providing a wider range of attractions, hotel accommodations, restaurants, shopping opportunities, and public parking;  To accommodate existing and anticipated traffic through implementation of an innovative transportation and parking plan, including convenient access to parking facilities from freeways, use of conveyance systems to shuttle visitors from parking facilities and hotels to area attractions, and provision of pedestrian walkways throughout The Disneyland Resort;
 To lay a foundation for future economic expansion and minimize environmental impacts through comprehensive site development guidelines;
 To maintain and encourage Anaheim’s position as a nationally recognized tourist, convention and recreation center;
 To encourage the development of quality facilities that complement conventions, family entertainment, and recreation within appropriate areas of the community; DisneylandForward
Draft Subsequent EIR No. 352

6-17 Section 6.0 – Alternatives to the Proposed Project  To maintain the integrity of the Commercial Recreation Area (now referred to as The Anaheim Resort) by permitting only compatible land uses within this designated area;  To support the continued reimagination of The Disneyland Resort to meet and exceed evolving guest expectations for immersive entertainment and technological advances in theme park and other resort experiences;
 To continue to fulfill the following vision of Walt Disney: “Disneyland will never be completed…It will continue to grow as long as there is imagination left in the world”; and  To allow the expansion of theme park and parking uses to Disney ARSP Properties to support the continued success and vitality of The Anaheim Resort, including The Disneyland Resort.

In order to achieve the Project Objectives noted above, a large area of contiguous property that is available for development, that is located within an area that is zoned for visitor-serving uses, and that includes existing development associated with The Disneyland Resort would be required.

As discussed above, other than the Project Site, there are no areas owned by Disney that meet these criteria; therefore, there is not Alternative Site that would meet these Project objectives, Therefore, further analysis of an alternative site(s) is not provided in this Draft Subsequent EIR.

6.5 ALTERNATIVES TO THE PROPOSED PROJECT
In accordance with CEQA Guidelines Section 15126.6(a) and CEQA supplemental review principles discussed previously in Section 6.1, this section addresses a reasonable range of alternatives considered in the Draft Subsequent EIR. The range of potential alternatives include those that could feasibly accomplish most of the basic objectives of the Project and could avoid or substantially lessen one or more of the significant effects.

Based on the criteria listed previously and the fact that the Project would result in significant and unavoidable impacts related to Air Quality, Cultural Resources, Greenhouse Gas Emissions, and Noise, the alternatives described below have been determined to represent a reasonable range of alternatives.

The alternatives considered in this Draft Subsequent EIR include the following alternatives to the Project, which are further described in this section:
 No-Project/Continuing Development;
 Restrict Removal or Substantial Changes to Listed Historic Features; and  Development With No Theme Park East Overlay.

Each of these alternatives is summarized below and, as appropriate, compared with the impacts of the Project and the Project’s attainment of Project Objectives.

6.5.1 NO PROJECT/CONTINUING DEVELOPMENT
According the Section 15156.6(e) of the CEQA Guidelines, a “no project” alternative shall be evaluated to allow decisionmakers to compare the impacts of approving the proposed project with the impacts of not approving the proposed project. Additionally, the no project alternative may represent the continuation of an existing land use or ongoing operation into the future. Thus, the following analysis focuses on the impacts of the Project in comparison to the impacts that would DisneylandForward
Draft Subsequent EIR No. 352

6-18 Section 6.0 – Alternatives to the Proposed Project occur under the existing plans, in this case continued development of The Disneyland Resort Project and the ARSP, analyzed in EIR No. 311 and SEIR No. 340, respectively.

The No Project/Continuing Development Alternative assumes that the General Plan land use designations, DRSP Development Districts, and DRSP and ARSP development standards and regulations would remain as they currently pertain to the Project Site. Assumptions include that the 489.7-acre Disneyland Resort Project would proceed as approved, but that the benefits associated with coordinating infrastructure, design, and streetscape improvements between the DRSP and the ARSP as detailed for the DisneylandForward Project would not be realized.

Additionally, future development and redevelopment would be subject to existing entitlements and would be specifically limited to the Districts and Overlays as defined by the existing DRSP and ARSP.

The No Project/Continuing Development Alternative would assume that current land use designations, development standards and regulations would remain as they do today, pursuant to the DRSP and ARSP. The DRSP and ARSP areas would continue to be developed in accordance with the current DRSP and ARSP, respectively, and all approved amendments.

Under current conditions, development has occurred pursuant to the DRSP and the ARSP; therefore, much of the coordination related to infrastructure, design, and streetscape improvements has already occurred, creating three distinct but complimentary specific plan areas.

Comparative Analysis of Environmental Impacts
Aesthetics
The No Project/Continuing Development Alternative would result in the same impacts identified in EIR No. 311 and SEIR No. 340, including significant and unavoidable construction-related visual impacts and potential shade and shadow impacts. The No Project/Continuing Development Alternative would not implement Project modifications to the Structural Height Map, which would reduce slightly potential impacts related shade and shadow to less than significant levels for the DisneylandForward Project. Therefore, the aesthetic impacts resulting from No Project/Continuing Development Alternative would be greater than those of the DisneylandForward Project.

This impact would be greater than the DisneylandForward Project.

Air Quality
The No Project/Continuing Development Alternative would involve construction and operations consistent with what was identified in EIR No. 311 and SEIR No. 340. EIR No. 311 and SEIR No. 340 identified significant and unavoidable direct and cumulative construction impacts and direct and cumulative operational impacts which would continue with the No Project/Continuing Development Alternative. As with the DisneylandForward Project, development under the No Project/Continuing Development Alternative would be required to comply with current regulations and requirements and implementation of mitigation identified in EIR No. 311 and SEIR No. 340.

As discussed in Section 5.2, Air Quality, the DisneylandForward Project would result in a reduced impact associated with conflicting or obstructing implementation of the applicable air quality plan; however, all other impacts would remain consistent with the No Project/Continuing Development Alternative as evaluated in EIR. No. 311 and SEIR No. 340. Therefore, impacts related to conflicting or obstructing implementation of the applicable air quality plan would be greater under this alternative than those of the DisneylandForward Project and all other impacts would be consistent with the DisneylandFoward Project. Both the alternative and the Project would result DisneylandForward
Draft Subsequent EIR No. 352

6-19 Section 6.0 – Alternatives to the Proposed Project in significant and unavoidable impacts related to cumulatively considerable net increases of a criteria pollutant for which the region is in non-attainment.

This impact would be greater than the DisneylandFoward Project.

Biological Resources
Under the No Project/Continuing Development Alternative, future development pursuant to existing entitlements would occur on the Project Site. Due to the previously developed condition of the Project Site, this alternative would not impact any areas occupied by biological resources.

Similar to the DisneylandForward Project, the No Project/Continuing Development Alternative would potentially impact nesting birds and would be subject to existing regulations. Therefore, the biological resources impacts resulting from No Project/Continuing Development Alternative would be less than significant with mitigation as identified in EIR No. 311 and SEIR No. 340, which would be consistent with the DisneylandFoward Project.

This impact would be similar to the DisneylandFoward Project.

Cultural Resources
Under the No Project/Continuing Development Alternative, future development pursuant to existing entitlements would occur on the Project Site. Similar to the DisneylandFoward Project, no new or previously undisturbed areas would be developed, and similar mitigation would be required to reduce potential impacts to archaeological resources to less than significant. Due to the passage of time since certification of EIR No. 311, the DisneylandForward Project identified significant and unavoidable impacts related to t he potentially removal of potentially significant historical structures located within the potential Disneyland Theme Park Historic District, the Pope House and the three individually designated structures (the Hungry Bear Restaurant, Pirates of the Caribbean and the Main Street Railroad Depot). EIR No. 311 did not identify these impacts; therefore, the No Project/Continuing Development Alternative would not result in a significant and unavoidable impact as detailed in this Subsequent Draft EIR for the DisneylandForward Project.

However, any removal of the potentially significant historic structures would require supplemental environmental review. Therefore, this alternative would result in a less than significant impact related to historic resources, which would be less than with the DisneylandFoward Project.

This impact would be less than the DisneylandFoward Project.

Energy
Under the No Project/Continuing Development Alternative, future development pursuant to existing entitlements would occur on the Project Site which would introduce new land uses, employees and population and subsequently incr ease demand for energy. Increased demand under this alternative would be similar to the increased energy demands that were identified in EIR No. 311 and SEIR No. 340. Further, all mitigation noted in EIR No. 311 and SEIR No. 340 would also apply to this alternative, which would reduce impacts to less than significant levels, which would be consistent with the Project.

This impact would be similar to the DisneylandFoward Project.

DisneylandForward
Draft Subsequent EIR No. 352

6-20 Section 6.0 – Alternatives to the Proposed Project Geology and Soils
Under the No Project/Continuing Development Alternative, future development pursuant to existing entitlements would occur on the Project Site. The entire site has been subject to previous disturbance and development. Similar to the DisneylandForward Project, the No Project/Continuing Development Alternative would be subject to standard engineering practices and existing regulations. Therefore, the geology and soils impacts resulting from No Project/Continuing Development Alternative would be less than significant with mitigation identified in EIR No. 311 and SEIR No. 340, which would be consistent with the DisneylandForward Project.

This impact would be similar to the DisneylandForward Project.

Greenhouse Gas Emissions
The No Project/Continuing Development Alternative would result in the same impacts identified in SEIR No. 340, including significant and unavoidable impacts related to the magnitude of the increase in GHG emissions. As discussed above, EIR No. 311 did not analyze GHG emissions.

The No Project/Continuing Development Alternative would be required to comply with current regulations and requirements; however, due to existing development that has occurred to date in The Disneyland Resort and the ARSP, GHG emissions associated with the No Project/Continuing Development Alternative would result in a significant and unavoidable GHG emission impacts, which would be consistent with the Disneyland Forward Project. Therefore, the GHG impacts resulting from No Project/Continuing Development Alternative would be similar to those of the DisneylandForward Project.

This impact would be similar to the DisneylandForward Project.

Hazards and Hazardous Materials
The No Project/Continuing Development Alternative would involve continued construction and operation of generally similar uses on the same site as the DisneylandForward Project. This alternative would also be required to comply with current regulations and requirements as would the Project. Therefore, the hazards and hazardous materials impacts resulting from No Project/Continuing Development Alternative would be less than significant with mitigation identified in EIR No. 311 and SEIR No. 340, which would be similar to the DisneylandForward Project.

This impact would be similar to the DisneylandForward Project.

Hydrology and Water Quality
Under the No Project/Continuing Development Alternative, future development pursuant to existing entitlements would occur on the Project Site. The entire site has been subject to previous disturbance and development and, similar to the Project, the No Project/Continuing Development Alternative would be subject to standard engineering practices and existing State and local regulations related to water quality and hydrology. Therefore, the hydrology and water quality impacts resulting from No Project/Continuing Development Alternative would be less than significant with mitigation identified in EIR No. 311 and SEIR No. 340, which would be consistent with the DisneylandForward Project.

This impact would be similar to the DisneylandForward Project.

DisneylandForward
Draft Subsequent EIR No. 352

6-21 Section 6.0 – Alternatives to the Proposed Project Land Use and Planning
The No Project/Continuing Development Alternative would introduce the same type and intensity of uses as previously analyzed; therefore, this alternative would result in the same impacts identified in EIR No. 311 and SEIR No. 340. Although this alternative would comply with all of the zoning requirements and design guidelines set fo rth in the DRSP and ARSP, where applicable, this alternative would not integrate the DisneylandForward Project-related updates to the DRSP and ARSP that would promote a more walkable and connected Project Site. Further, as discussed in EIR No. 311, a significant and unavoidable impact related to land use incompatibilities was identified. As discussed in Section 5.10, Land Use and Planning, the DisneylandForward Project would avoid this potential impact through im plementation of development standards and design guidelines. Because the No Project/Continuing Development Alternative would not incorporate the modified development standards and design guidelines associated with the DisneylandForward Project, potential impacts would occur related to land use compatibility that would be avoided with the DisneylandForward Project. Therefore, land use compatibility impacts resulting from No Project/Continuing Development Alternative would be greater than those of the DisneylandForward Project.

This impact would be greater than the DisneylandForward Project.

Noise
The No Project/Continuing Development Alternative would introduce the same type and intensity of uses as previously analyzed; therefore, this alternative would result in the same impacts identified in EIR No. 311 and SEIR No. 340, including a significant and unavoidable impact related to construction noise as detailed in SEIR No. 340. Additional mitigation measures that would be required by the DisneylandForward Project would not apply to this alternative. This alternative would continue to result in significant and unavoidable impacts related to noise. Therefore, noise impacts resulting from No Project/Continuing De velopment Alternative would be consistent with the DisneylandForward Project.

This impact would be similar to the DisneylandForward Project.

Population and Housing
Under the No Project/Continuing Development Alternative, future development pursuant to existing entitlements would occur on the Project Site which would generate additional employment and population within the City and County and subsequently increase the demand for housing.

Similar to the DisneylandForward Project, no additional entitlement would be requested and the maximum amount of employment-generating development would not change from current entitlements; therefore, the amount of anticipated employment would be slightly less than with the Project. Because The Disneyland Resort and Disney ARSP Properties have undergone substantial development since EIR No. 311 and SEIR No. 340 were certified and employment has increased since certification of these two EIRs, a portion of this increased employment already has occurred. Therefore, the continued development pursuant to the No Project/Continuing Development Alternative would result in slightly less employment growth than with the DisneylandForward Project, which is increased from what was identified in EIR No. 311 and SEIR No. 340. Consistent with EIR No. 311 and SEIR No. 340, the No Project/Continuing Development Alternative would result in less t han significant impacts, which is also consistent with the DisneylandForward Project.

This impact would be similar to the DisneylandForward Project.

DisneylandForward
Draft Subsequent EIR No. 352

6-22 Section 6.0 – Alternatives to the Proposed Project Public Services
Under the No Project/Continuing Development Alternative, future development pursuant to existing entitlements analyzed in EIR No. 311 and SEIR No. 340 would occur on the Project Site, which would introduce new land uses, employees and population and subsequently increase demands for public services and recreation. Increased demands for this alternative would be similar to the increased demands for public services and recreation that were identified in EIR No. 311 and SEIR No. 340. Further, all mitigation noted in EIR No. 311 and SEIR No. 340 would also apply to the No Project/Continuing Development Alternative. As detailed in Section 5.13, Public Services, EIR No. 311 found that school impacts would be significant and unavoidable due to overcrowding at local districts; however, based on changing conditions since certification of EIR No. 311, this impact would no longer be considered significant and unavoidable with the No Project/Continuing Development Alternative. A dditionally, EIR No. 311 did not specifically address library impacts, but the No Project/Continuing Development Alternative would be subject to library fees consistent with the DisneylandForward Project. Therefore, the No Project/Continuing Development Alternative would re sult in less than significant impacts, which would be consistent with the DisneylandForward Project.

This impact would be similar to the DisneylandForward Project.

Transportation
The No Project/Continuing Development Alternative would introduce the same type and intensity of uses as previously analyzed in EIR No. 311 and SEIR No. 340; however, several of the required improvements identified in EIR No. 311 and SEIR No. 340 have been implemented which were intended to mitigate specific impacts. As detailed in Section 5.14, Transportation, EIR No. 311 and SEIR No. 340 each focused its transportation impact analyses on an examination of whether the project was likely to cause automobile delay at intersections and congestion on nearby individual highway segments, traditionally known as LOS analysis, while the currently mandated analysis focuses on vehicle miles traveled. Similarly, EIR No. 311 did not specifically address impacts related to hazards or emergency access. Thus, new impacts were identified for the DisneylandForward Project and each of these new impacts were found to be less than significant with mitigation. Because the No Project/Continuing Development Alternative involves development under existing entitlements, and because existing mitigation (specifically related to the Transportation Demand Management Program) identified in EIR No. 311 and SEIR No. 340 would continue to be required, similar less than significant impacts with mitigation would occur under the No Project/Continuing Development Alternative. Therefore, the No Project/Continuing Development Alternative would be consistent with the DisneylandForward Project.

This impact would be similar to the DisneylandForward Project.

Tribal Cultural Resources
Under the No Project/Continuing Development Alternative, future development and disturbance pursuant to existing entitlements would occur on the Project Site. Similar to the Project, no new or previously undisturbed areas would be developed. As detailed in Section 5.15, Tribal Cultural Resources, neither EIR No. 311 nor SEIR No. 340 specifically analyzed tribal cultural resources; therefore, the impact was identified as a new impact and a new mitigation measure was developed that would not apply to the No Project/Continuing Development Alternative. Therefore, tribal cultural resources impacts resulting from No Project/Continuing Development Alternative would be potentially significant and unavoidable without the implementation of new mitigation developed as part of the DisneylandForward Project. This impact would be greater than the DisneylandForward Project.

DisneylandForward
Draft Subsequent EIR No. 352

6-23 Section 6.0 – Alternatives to the Proposed Project This impact would be greater than the DisneylandFoward Project.

Utilities and Service Systems
Under the No Project/Continuing Development Alternative, future development pursuant to existing entitlements would occur on the Project Site, which would introduce new land uses, employees and population and subsequently increase demands for utilities. Increased demands for this alternative would be similar to the increased demands for utilities that were identified in EIR No. 311 and SEIR No. 340. However, as discussed in Section 5.16, Utilities, EIR No. 311 identified a significant and unavoidable impact related to solid waste due to the lack of adequate landfill capacity. Since that time, the Orange County landfill system has improved and opened or expanded facilities to increase capacity. Consistent with the analysis associated with the DisneylandForward Project, impacts associated with the No Project/Continuing Development Alternative would now be considered less than significant with mitigation, which would be a reduced impact when compared with the impacts previously identified in EIR No. 311 and SEIR No. 340. Therefore, impacts related to utilities for the No Project/Continuing Development Alternative would be reduced to less than significant levels, which would be consistent with the Project.

This impact would be similar to the DisneylandForward Project.

Conclusions
Avoid or Substantially Lessen the Significant Impacts of the Project The No Project/Continuing Development Alternative, when compared to the DisneylandForward Project, would result in reduced impacts related to Cultural Resources and greater impacts related to Aesthetics, Air Quality, Land Use and Planning, and Tribal Cultural Resources.

Attainment of Project Objectives
The No Project/Continuing Development Alternative would allow for continued development of The Disneyland Resort according to current entitlements which would achieve the Project objectives. Under the current DRSP development structure, theme park uses are only allowed in the Theme Park District. As of the date of the Notice of Preparation of this Draft Subsequent EIR, October 21, 2021, Disney has developed approximately 45 percent of the approved square footage for theme park uses, even though most of the Theme Park District is built out. Future development, including additional theme park square footage, would require expansion into new areas or replacement of existing uses in the existing Theme Park District with more dense development. Accordingly, because expansion of theme park uses into new areas would not occur under the No Project/Continuing Development Al ternative, this alternative would limit the ability to develop new immersive theme park experiences that would meet and exceed guest expectations. Without allowing for flexibility to meet guest expectations, the Disneyland Resort would attract fewer theme park guests, resulting in decreased economic benefits when compared with the DisneylandForward Project. Therefore, this alternative would not support any of the identified Project objectives to the same degree as the Project. Specifically, the No Project/Continuing Development Alternative would not support the following objectives to the same degree as the DisneylandForward Project:
 To reconfirm and enhance Southern California as one of the world’s greatest tourist destinations;

DisneylandForward
Draft Subsequent EIR No. 352

6-24 Section 6.0 – Alternatives to the Proposed Project  To support the ongoing transformation of The Anaheim Resort into a multi-day destination resort for use by Southern California metropolitan area residents, as well as visitors from around the world;
 To promote the goals of the Anaheim General Plan by enhancing visitor-serving commercial uses in the City and to provide a catalyst for the economic and physical enhancement of Anaheim;
 To support the buildout of a fully integrated resort that increases visitation levels and generates an economic base capable of supporting project components consistent with the objectives of the City;
 To maintain and enhance the economic vitality of the City of Anaheim and Orange County by providing business and job opportunities associated with the construction and operation of The Disneyland Resort;
 To enhance The Anaheim Resort by providing a wider range of attractions, hotel accommodations, restaurants, shopping opportunities, and public parking;  To accommodate existing and anticipated traffi c through implementation of an innovative transportation and parking plan, including convenient access to parking facilities from freeways, use of conveyance systems to shuttle visitors from parking facilities and hotels to area attractions, and provision of pedestrian walkways throughout The Disneyland Resort;
 To lay a foundation for future economic expansion and minimize environmental impacts through comprehensive site development guidelines;
 To develop public/private cooperation and partnership which utilize the private sector to fund vitally needed improvements in The Anaheim Resort to benefit the public.  To maintain and encourage Anaheim’s position as a nationally recognized tourist, convention and recreation center;
 To increase sales tax yields and further enhance the economic base of the community, thereby lessening the tax burden on real property;
 To encourage the development of quality facilities that complement conventions, family entertainment, and recreation within appropriate areas of the community;  To maintain the integrity of the Commercial Recreation Area (now referred to as The Anaheim Resort) by permitting only compatible land uses within this designated area;  To support the continued reimagination of The Disneyland Resort to meet and exceed evolving guest expectations for immersive entertainment and technological advances in theme park and other resort experiences;
 To continue to fulfill the following vision of Walt Disney: “Disneyland will never be completed…It will continue to grow as long as there is imagination left in the world”; and  To allow the expansion of theme park and parking uses to Disney ARSP Properties to support the continued success and vitality of The Anaheim Resort, including The Disneyland Resort.

DisneylandForward
Draft Subsequent EIR No. 352

6-25 Section 6.0 – Alternatives to the Proposed Project

6.5.2 RESTRICT REMOVAL OR SUBSTANTIAL CHANGES TO HISTORIC FEATURES The Alternative to Restrict Removal or Substantial Changes to Listed Historic Features would not allow any future modifications to, or removal of, the structures determined to be historic resources as defined by CEQA. This alternative would continue to allow the transfer of uses permitted under The Disneyland Resort Project to other areas of the DRSP and Disney ARSP Properties, as proposed by the Project, however, any future modifications could not substantially impact the potential Disneyland Theme Park Historic District, the three individually eligible structures (the Hungry Bear Restaurant, Pirates of the Caribbean and the Main Street Railroad Depot), or the Pope House. Substantial changes include changes or alterations that result in a material change such that the resources no longer convey historic significance. As detailed in Section 5.4, Cultural Resources, the majority of modifications anticipated for the potential Disneyland Theme Parks Historic District would not result in a material change that would affect this potential district. This Draft Subsequent EIR analyzes the potential for demolition or substantial changes and finds a significant and unavoidable impact. However, because these four features are limited to currently developed areas within Disneyland and its back-of-house area, most of the DisneylandForward Project would continue to be implemented as proposed, especially within areas outside of the potential Disneyland Theme Parks Historic District.

Comparative Analysis of Environmental Impacts
Aesthetics
Implementation of the Alternative to Restrict Removal or Substantial Changes to Listed Historic Features would restrict future changes to four specific features within Disneyland and its back of house area and the remainder of the Project Site would be subject to future development as detailed throughout this Draft Subsequent EIR. Because each of the uses to be retained is located within fully developed areas (i.e., not along the site’s perimeter) that are not visible from off-site vantage points, they would not have an effect on the site’s aesthetics or visual appearance. This alternative would involve the continued development of the DRSP and Disney ARSP Properties as detailed throughout this Draft Subsequent EIR and would result in similar aesthetic impacts related to visual intrusion and shade and shadow. Consistent with the DisneylandForward Project, application of mitigation would reduce potential impacts to less than significant levels.

This impact would be similar to the DisneylandForward Project.

Air Quality
The duration of construction activities associated with the Alternative to Restrict Removal or Substantial Changes to Listed Historic Features would be consistent with the assumptions identified throughout this Draft Subsequent EIR. Retention of the four specific features would not significantly modify air emissions in comparis on to the Project due to their limited size and operations. None of the features identified involve high air emissions operations; therefore, the difference in air emissions would be nominal when compared to the DisneylandForward Project.

Additionally, the same mitigation measures identified throughout this Draft Subsequent EIR would be required, and, when considered with the underlying Disneyland Resort Project and the ARSP Project, this alternative would continue to result in significant and unavoidable regional construction and operational emissions. These impacts would be consistent with the DisneylandForward Project and would not be new when compared with EIR No. 311 and SEIR No. 340.

This impact would be similar to the DisneylandForward Project.

DisneylandForward
Draft Subsequent EIR No. 352

6-26 Section 6.0 – Alternatives to the Proposed Project Biological Resources
Due to the nature of biological resources as physical resources that are tied to the land, impacts associated with the Alternative to Restrict Removal or Substantial Changes to Listed Historic Features would be consistent with those identified for the DisneylandForward Project. Retention of the four specific features would not change the area considered for continued development under the DisneylandForward Project. Mitigation measures similar to those identified in this Draft Subsequent EIR would be required; it is expected that all impacts related biological resources would be reduced to less than significant levels, which is consistent with the DisneylandForward Project.

This impact would be similar to the DisneylandForward Project.

Cultural Resources
Implementation of the Alternative to Restrict Removal or Substantial Changes to Listed Historic Features would restrict future changes to historic features within the proposed Disneyland Theme Park Historic District, the three individually eligible structures (the Hungry Bear Restaurant, Pirates of the Caribbean and the Main Street Railroad Depot), and the Pope House. The retention of these features would avoid the significant impact identified for the DisneylandForward Project related to potential loss of historic resources. The remainder of the DisneylandForward Project Site would be subject to development as detailed throughout this Draft Subsequent EIR and mitigation measures similar to those identified in this Draft Subsequent EIR would be required. It is expected that all impacts related archeological resources would be reduced to less than significant levels, which is consistent with the DisneylandForward Project.

Impacts would be less when compared to the DisneylandForward Project as the Alternative would avoid a significant and unavoidable impact of the Project.

Energy
Short- and long-term energy demand and consumption associated with the Alternative to Restrict Removal or Substantial Changes to Listed Historic Features would be consistent with the DisneylandForward Project. Retention of the four specific features would not modify anticipated energy demand or consumption in comparison to the Project due to their limited size and operations. None of the features identified involve inefficient or abnormally high energy demand; therefore, the difference in energy efficiency would be nominal when compared to the DisneylandForward Project. Therefore, impacts associated with energy under this alternative would be consistent with the DisneylandForward Project. Mitigation measures consistent with those identified in this Draft Subsequent EIR would be required and, consistent with the Project, impacts would be reduced to less than significant levels.

This impact would be similar to the DisneylandForward Project.

Geology and Soils
Due to the nature of geology and soils resources as physical resources that are tied to the land, impacts under the Alternative to Restrict Removal or Substantial Changes to Listed Historic Features would be similar to those identified for the DisneylandForward Project. Retention of the four specific features would not change the area considered for continued development under the Project. Mitigation measures similar to those identified in this Draft Subsequent EIR would be required; it is expected that all impacts related geology and soils would be reduced to less than significant levels, which would be consistent with the DisneylandForward Project.

DisneylandForward
Draft Subsequent EIR No. 352

6-27 Section 6.0 – Alternatives to the Proposed Project This impact would be similar to the DisneylandForward Project.

Greenhouse Gas Emissions
Implementation of the Alternative to Restrict Removal or Substantial Changes to Listed Historic Features would result in development of the same types of potential land uses as with the Project and the overall maximum allowable density of development associated with the Project would be unchanged. Retention of the four specific features would not significantly decrease GHG emissions in comparison to the DisneylandForward Project due to their limited size and operations. None of the features identified involve high GHG emitting operations; therefore, the difference in GHG emissions would be nomi nal when compared to the DisneylandForward Project. Therefore, impacts associated with Greenhouse Gas Emissions under this alternative would be consistent with the DisneylandForward Project, which are identified as significant and unavoidable. Mitigation measures consistent with those identified in this Draft Subsequent EIR would be required and, consistent with the DisneylandForward Project, with impacts would remain significant and unavoidable.

This impact would be similar to the DisneylandForward Project.

Hazardous Materials
Although the Alternative to Restrict Removal or Substantial Changes to Listed Historic Features would not allow for modification of certain on-site features, retention of the four specific features would not have a notable effect on potential hazardous materials impacts. None of the features identified include specific hazardous material use, storage, or disposal that is not typical of other uses throughout The Disneyland Resort; therefore, there would be no notable difference related to hazardous materials impacts when compar ed to the DisneylandForward Project. This alternative would involve the continued development of the DRSP and Disney ARSP Properties as detailed in this Draft Subsequent EIR and would result in similar impacts related to hazards and hazardous materials. Consistent with the DisneylandForward Project, application of mitigation would reduce potential impacts to less than significant levels.

This impact would be similar to the DisneylandForward Project.

Hydrology and Water Quality
Implementation of the Alternative to Restrict Removal or Substantial Changes to Listed Historic Features would result in development of the same types of uses as would the Project with the exception of four specific features to be retained. Future development associated with this alternative would create similar hydrology and water quality issues as new or redeveloped theme park, hotel, and parking uses are introduced to the area. Due to their limited size and location within fully developed areas of The Disneyland Resort, retention of the four specific features would not change the area considered for continued development under the Project. Mitigation measures similar to those identified in this Draft Subsequent EIR would be required and it is expected that all impacts related hydrology and water quality would be reduced to less than significant levels, which would be consistent with the DisneylandForward Project.

This impact would be similar to the DisneylandForward Project.

Land Use and Planning
Implementation of the Alternative to Restrict Removal or Substantial Changes to Listed Historic Features would result in development of the same types of uses as would the DisneylandForward DisneylandForward
Draft Subsequent EIR No. 352

6-28 Section 6.0 – Alternatives to the Proposed Project Project and within a similar physical development area with the exception of four specific features to be retained. Consistent with the DisneylandForward Project, development would be generally consistent with the current general plan and would involve the same amendments as detailed in this Draft Subsequent EIR. All mitigation measures identified in this Draft Subsequent EIR and development standards and design guidelines ident ified in the DRSP and ARSP would be implemented under this alternative; therefore, land use impacts associated with future development would be consistent with those identified for the DisneylandForward Project.

Consistent with the DisneylandForward Project, this alternative would result in less than significant impacts related to land use and planning with implementation of mitigation measures.

This impact would be similar to the DisneylandForward Project.

Noise
Implementation of the Alternative to Restrict Removal or Substantial Changes to Listed Historic Features would result in development of the same types of uses as the DisneylandForward Project with the exception of potential modification of four specific features which would be retained in their current use. Retention and continued operation of these four features would neither increase nor decrease anticipated noise impacts. Mitigation measures consistent with those identified in this Draft Subsequent EIR would be required, which would reduce impacts related to long-term operations to less than si gnificant levels, however, impacts related to construction noise and vibration would remain significant and unavoidable. Therefore, noise impacts would be consistent with the DisneylandForward Project.

This impact would be similar to the DisneylandForward Project.

Population and Housing
Implementation of the Alternative to Restrict Removal or Substantial Changes to Listed Historic Features would restrict future changes to four specific features within the Disneyland theme park and its back of house area and the remainder of the site would be developed consistent with the DisneylandForward Project. Retention of the four features would have no notable effect related to employment; therefore, this alternative would generate the same number of jobs as the DisneylandForward Project, and this job creation would result in a similar housing demand and population growth when compared to the DisneylandForward Project. The housing and population impacts of this alternative would be less than significant, consistent with the DisneylandForward Project.

This impact would be similar to the DisneylandForward Project.

Public Services
Implementation of the Alternative to Restrict Removal or Substantial Changes to Listed Historic Features would result in development of the same types of uses as the Project and within the same physical development area. As discussed above, this alternative would be consistent with the population generation associated with the Project; therefore, the demand for public services would also be similar to the DisneylandForward Project. Further, retention of the four features would not have a notable effect on public services. Mitigation measures similar to those identified in this Draft Subsequent EIR would be required; therefore, public service impacts associated with future development would be consistent with those identified for the DisneylandForward Project.

Consistent with the Project, this alternative would result in less than significant impacts related to public services with implementation of mitigation measures.

DisneylandForward
Draft Subsequent EIR No. 352

6-29 Section 6.0 – Alternatives to the Proposed Project This impact would be similar to the DisneylandForward Project.

Transportation and Traffic
Development of the Alternative to Restrict Removal or Substantial Changes to Listed Historic Features would retain four specific features within the Disneyland theme park and its back-of- house area. Retention and continued operation of these features would not result in a notable effect on traffic. Therefore, the anticipated distribution and volume of vehicular traffic would be consistent with the DisneylandForward Project. Mitigation measures similar to those identified in this Draft Subsequent EIR would be required and it is expected that all impacts related transportation and traffic would be reduced to less than significant levels, which would be consistent with the DisneylandForward Project.

This impact would be similar to the DisneylandForward Project.

Tribal Cultural Resources
Due to the nature of tribal cultural resources as resources that are tied to the land, impacts associated with the Alternative to Restrict Removal or Substantial Changes to Listed Historic Features would be consistent with those identified for the DisneylandForward Project. Retention of the four specific features would not change the area considered for continued development under the DisneylandForward Project. Mitigation measures similar to those identified in this Draft Subsequent EIR would be required; it is expected that all impacts related tribal cultural resources would be reduced to less than significant levels, which would be consistent with the DisneylandForward Project.

This impact would be similar to the DisneylandForward Project.

Utilities
Implementation of the Alternative to Restrict Removal or Substantial Changes to Listed Historic Features would result in development of the same types of uses as the DisneylandForward Project, with a similar demand for utilities, and within the same physical development area; therefore, the demand for utilities would also be similar to the DisneylandForward Project. As discussed in this Draft Subsequent EIR, impacts on utilities would be less than significant with mitigation.

This impact would be similar to the DisneylandForward Project.

Conclusions
Avoid or Substantially Lessen the Significant Impacts of the Project This alternative would avoid or substantially lessen the Project’s significant impact on cultural resources; however, the remaining impacts would be similar to those of the Project. As detailed above, retention of the four features would eliminate the potentially significant and unavoidable impact related to the loss of historic resources, thus reducing the impacts of the Project.

Attainment of Project Objectives
The Alternative to Restrict Removal or Substantial Changes to Listed Historic Features would not meet the underlying purpose of the Project and would totally prevent most updates and changes to Disneyland. Implementation of the Alternative to Restrict Removal or Substantial Changes to DisneylandForward
Draft Subsequent EIR No. 352

6-30 Section 6.0 – Alternatives to the Proposed Project Listed Historic Features would restrict substantial modification or removal of potential historic resources, including the potential Disneyland Them e Park Historic District, the three historic resources within Disneyland (the Hungry Bear Restaurant, Pirates of the Caribbean and the Main Street Railroad Depot), and the potentially individually eligible Pope House; therefore, this alternative would frustrate Disney’s objective of being able to change the resort as Disney imagines new and more exciting entertainment for guests. This Alternative would not meet the following Project objectives:
 To support the continued reimagination of The Disneyland Resort to meet and exceed evolving guest expectations for immersive entertainment and technological advances in theme park and other resort experiences; and
 To continue to fulfill the following vision of Walt Disney: “Disneyland will never be completed…It will continue to grow as long as there is imagination left in the world.” Additionally, this Alternative would not meet other Project objectives listed below to the same degree as the DisneylandForward Project in that limiting the flexibility of future redevelopment of specific elements would limit Disney’s ability to maximize future guest experiences, potentially limit the volume of visitors seeking new and ever-changing experiences, and limit the ability to more meaningfully contribute to the economic growth of the City:
 To reconfirm and enhance Southern California as one of the world’s greatest tourist destinations;

 To support the ongoing transformation of The Anaheim Resort into a multi-day destination resort for use by Southern California metropolitan area residents, as well as visitors from around the world;
 To promote the goals of the Anaheim General Plan by enhancing visitor-serving commercial uses in the City and to provide a catalyst for the economic and physical enhancement of Anaheim;
 To support the buildout of a fully integrated resort that increases visitation levels and generates an economic base capable of supporting project components consistent with the objectives of the City;
 To maintain and enhance the economic vitality of the City of Anaheim and Orange County by providing business and job opportunities associated with the construction and operation of The Disneyland Resort;
 To enhance The Anaheim Resort by providing a wider range of attractions, hotel accommodations, restaurants, shopping opportunities, and public parking;  To maintain and encourage Anaheim’s position as a nationally recognized tourist, convention and recreation center;
 To increase sales tax yields and further enhance the economic base of the community, thereby lessening the tax burden on real property; and
 To encourage the development of quality facilities that complement conventions, family entertainment, and recreation within appropriate areas of the community.

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6.5.3 DEVELOPMENT WITH NO THEME PARK EAST OVERLAY
The Development With No Theme Park East Overlay Alternative would restrict future development of the 52.6-acre parcel located at 1900 South Harbor Boulevard, identified as the ARSP Theme Park East Overlay in the Project, to current uses allowed under the ARSP. As shown in Table 3-2, maximum allowable development for this property under the ARSP would be 3,348 hotel rooms, or the property could remain as the Toy Story Parking Lot through June 26, 2024 under Conditional Use Permit No. 2006-05103C, which has a maximum of 4,635-surface parking spaces. The parcel would remain within the ARSP C-R District in the Low-Medium Density, which allows for development of up to 75 hotel rooms per acre. Although the parcel would be developed and included as part of this alternative, no theme park uses would be permitted on this parcel under this alternative. As detailed in Section 3.0, Project Description, Section

18.116.070 of the City of Anaheim Municipal Code would allow the development of theme parks, entertainment venues, and transportation facilities on this property with approval of a conditional use permit (CUP); however, no CUP would be requested with this alternative. Future development of the remainder of the Project Site would be pursuant to the DisneylandForward Project. This alternative also assumes the planned extensions of Clementine Street and Gene Autry Way would be removed as part of this alternative, thus adjusting the current acreage associated with the parcel to include these street rights-of-way. This alternative would not modify the development potential associated with the DisneylandForward Project; instead, it would restrict development of theme park uses to specific areas. With the removal of the parcel at 1900 South Harbor Boulevard, the remainder of the maximum theme park square footage would be developed elsewhere within the DisneylandForward site, as shown in Table 3-2, Uses Currently Allowed Under DRSP/ARSP For Disney Properties, with the exception of theme park uses on the Theme Park East Overlay.

As discussed in Section 3.0, Project Description, the DisneylandForward Project would not increase the amount of development square footage or hotel rooms currently allowed in the DRSP and analyzed in Environmental Impact Report No. 311, which the City certified in 1993, or the number of hotel rooms currently allowed in the ARSP and analyzed in Supplemental Environmental Impact Report No. 340, which the City certified in 2012. Similarly, this alternative would neither increase nor reduce the amount of hotel rooms currently allowed in the ARSP for the parcel at 1900 South Harbor Boulevard.

The purpose of this alternative, as detailed below, is to try to reduce or avoid potential noise impacts on adjacent residential uses associated with developing theme park uses on the parcel located at 1900 South Harbor Boulevard.

Comparative Analysis of Environmental Impacts
Aesthetics
Implementation of the Development With No Theme Park East Overlay Alternative would avoid development of theme park uses on the parcel located at 1900 South Harbor Boulevard. However, development of hotel uses at this location would continue to be permitted according to existing zoning requirements and design guidelines set forth in the ARSP and Chapter 18.116 of the Anaheim Municipal Code for the Commercial-Recreation (C-R) District. Specifically, future hotel uses would be developed to:
 Create a coherent, unique resort identity that reinforces the image of the Anaheim Resort as a high-quality destination resort; and
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6-32 Section 6.0 – Alternatives to the Proposed Project  Improve the aesthetic character of The Anaheim Resort by visually defining the boundaries with appropriate landscape treatments.

Further, development would be subject to existing maximum permitted structural heights ranging from 140 feet in the northwest corner to 200 feet in the southeast corner, as determined by the Anaheim Commercial Recreation Area Maximum Permitted Structural Height Map, which is consistent with the existing conditions analyzed in Section 5.1, Aesthetics. Development of this alternative represents a change in the maximum structural heights that would be allowable under the DisneylandForward Project, which proposes to allow maximum permitted structure height of 170 feet with one structural thematic element up to 200 feet. As discussed in Section 5.1, Aesthetics, and illustrated on Exhibits 5.1-27 through 5.1-30, certain potential shade and shadow- related impacts associated with the DisneylandF orward Project under various future conditions may be avoided through development of this alternative, while other shade and shadow-related impacts to surrounding land uses would be greater than with the DisneylandForward Project.

However, mitigation measures and compliance with the sky exposure plane identified in this Draft Subsequent EIR as well as compliance with development standards and design guidelines set forth in the ARSP would be required which would reduce potential impacts to less than significant levels.

This impact would be similar to the DisneylandForward Project.

Air Quality
The duration of construction activities associated with the Development With No Theme Park East Overlay Alternative would be consistent with the assumptions identified in this Draft Subsequent EIR and SEIR No. 340 for the parcel located at 1900 South Harbor Boulevard. Although this alternative would not allow for development of theme park uses on the parcel located at 1900 South Harbor Boulevard, the parcel could be fully developed with hotel uses which would result in similar construction and operational emissi ons when compared to the DisneylandForward Project, which modeled air emissions based on development of this parcel with maximum allowable hotel uses. Additionally, mitigation measures similar to those identified in this Draft Subsequent EIR would be required; however, potential air quality impacts would be significant and unavoidable, similar to the Project.

This impact would be similar to the DisneylandForward Project.

Biological Resources
Due to the nature of biological resources as physical resources that are tied to the land, impacts associated with the Development With No Theme Park East Overlay Alternative would be similar to those identified for the Project. Although this alternative would not allow for development of theme park uses on the parcel located at 1900 South Harbor Boulevard, it is assumed that the parcel would be fully developed with hotel uses, thus resulting in a similar impact area when compared to the DisneylandForward Project. Mitigation measures similar to those identified in this Draft Subsequent EIR would be required; it is expected that all impacts related biological resources would be reduced to less than significant levels, which would be consistent with the DisneylandForward Project.

This impact would be similar to the DisneylandForward Project.

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6-33 Section 6.0 – Alternatives to the Proposed Project Cultural Resources
Due to the nature of cultural resources as physical resources that are tied to the land, impacts related to the Development With No Theme Park East Overlay Alternative would be similar to those identified for the Project. Although this alternative would not allow for development of theme park uses on the parcel located at 1900 South Harbor Boulevard, the parcel could be fully developed with hotel uses, thus resulting in a similar impact area when compared to the DisneylandForward Project. Mitigation measures similar to those identified in this Draft Subsequent EIR would be required; it is expected that all impacts related cultural resources would be reduced to less than significant levels with the exception of the potential significant and unavoidable loss of historic resources, which would continue with this alternative and would be consistent with the DisneylandForward Project.

This impact would be similar to the DisneylandForward Project.

Energy
Short- and long-term energy demand and consumption associated with the Development With No Theme Park East Overlay Alternative would be similar to the DisneylandForward Project, primarily because the Project evaluated development of the parcel at 1900 South Harbor Boulevard (Theme Park East Overlay District) with the maximum development potential of hotel uses to represent a worst-case air emissions. Mitigation measures similar to those identified in this Draft Subsequent EIR would be required; however, it is expected that impacts would be mitigated to less than significant, which would be consistent with the DisneylandForward Project.

This impact would be similar to the DisneylandForward Project.

Geology and Soils
Due to the nature of geology and soils resources as physical resources that are tied to the land, impacts associated with the Development With No Theme Park East Overlay Alternative would be similar to those identified for the DisneylandForward Project. Although this alternative would not allow for development of theme park uses on the parcel located at 1900 South Harbor Boulevard, the parcel could be fully developed with hotel uses, thus resulting in a similar impact area when compared to the DisneylandForward Project. Mitigation measures similar to those identified in this Draft Subsequent EIR would be required; it is expected that all impacts related geology and soils would be reduced to less than significant levels, which would be consistent with the Project.

This impact would be similar to the DisneylandForward Project.

Greenhouse Gas Emissions
Implementation of the Development With No Theme Park East Overlay Alternative would result in full development of the parcel with hotel uses, which is an option under the DisneylandForward Project and the remaining theme park square footage would be reallocated elsewhere within the Project Site. The overall maximum allowable density of development associated with the Project would be unchanged. This alternative assumes full development of 1900 South Harbor Boulevard with hotel uses (up to 3,348 hotel rooms), consistent with the analysis presented for the DisneylandForward Project, which proposes a combination of hotels and theme park uses on this property. Additionally, the remainder of the site (consistent with the Project Site as defined for the DisneylandForward Project) would be developed with uses detailed in this Draft Subsequent EIR.

Therefore, impacts associated with GHG emissions under this alternative would be consistent DisneylandForward
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6-34 Section 6.0 – Alternatives to the Proposed Project with the Project, primarily because the Project evaluated development of the parcel as the Theme Park East Overlay District with hotel uses to represent a worst-case air emissions scenario.

Additionally, since a large amount of GHG emissions are due to vehicular emissions, the assumption that the amount of daily traffic would be substantially similar to the Project under this alternative (refer to Transportation/Traffic discussion, below) means that vehicular emissions would be similar to the Project. Mitigation measur es similar to those identified in this Draft Subsequent EIR would be required, however impacts would remain significant and unavoidable, which would be consistent with the Project.

This impact would be similar to the DisneylandForward Project.

Hazardous Materials
Although the Development With No Theme Park East Overlay Alternative would not allow for development of theme park uses on the parcel located at 1900 South Harbor Boulevard, the parcel could be fully developed with hotel uses (up to 3,348 hotel rooms), thus resulting in a similar impact area when compared to the DisneylandForward Project. As discussed in Section 5.7, Hazards and Hazardous Materials, there are a number of hazardous materials sites that have been identified throughout the Project Site. Because the development area pursuant to this alternative would be the same as the DisneylandForward Project, this alternative would result in similar impacts related to known and unknown hazardous material locations. Mitigation measures similar to those identified in this Draft Subsequent EIR would be required; it is expected that all impacts related hazardous materials would be reduced to less than significant levels, which would be consistent with the Project.

This impact would be similar to the DisneylandForward Project.

Hydrology and Water Quality
Implementation of associated with the Development With No Theme Park East Overlay Alternative would result in development of the same types of uses as the Project. Future development associated with this alternative would create similar hydrology and water quality issues as new or redeveloped theme park, hotel, and parking uses are introduced to the area.

Although this alternative would not allow for development of theme park uses on the parcel located at 1900 South Harbor Boulevard, the parcel could be fully developed with hotel uses, thus resulting in a similar impact area when compared to the DisneylandForward Project. Because the area assumed for development would be the same as with the DisneylandForward Project, it is assumed that similar measures would be required to accommodate runoff and pollutants potentially leaving the site. Mitigation measures similar to those identified in this Draft Subsequent EIR would be required and it is expected that all impacts related hydrology and water quality would be reduced to less than significant levels, which would be consistent with the DisneylandForward Project.

This impact would be similar to the DisneylandForward Project.

Land Use and Planning
Implementation of the Development With No Theme Park East Overlay Alternative would result in development of the same types of uses as the Project and within a similar physical development area. Although this alternative would not allow for development of theme park uses on the parcel located at 1900 South Harbor Boulevard, the parcel could be fully developed with hotel uses, which is a potential development scenario of the DisneylandForward Project. As discussed above under Aesthetics, it is assumed that future development on the parcel under this alternative would DisneylandForward
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6-35 Section 6.0 – Alternatives to the Proposed Project comply with existing zoning requirements and design guidelines set forth in the ARSP and Chapter 18.116 of the Anaheim Municipal Code for the Commercial-Recreation (C-R) District, thus resulting in development that is compatible from a land use perspective with surrounding land uses. Comparable zoning requirements and design guidelines related to setbacks and aesthetic treatments for visible features would also be applicable to development under the DisneylandForward Project if theme park uses were allowed. This alternative would not involve approval of a Theme Park East Overlay and would also not create potential land use compatibility issues associated with developing theme park uses on the 1900 South Harbor Boulevard parcel; however, this alternative assumes that development of hotels would occur which would introduce uses similar to the Project. Mitigation measures similar to those identified in this Draft Subsequent EIR would be required; therefore, land use impacts associated with future development would be similar to those identified for the Project. Therefore, this alternative would result in less than significant impacts related to land use and planning with implementation of mitigation measures, which would be consistent with the DisneylandForward Project.

This impact would be similar to the DisneylandForward Project.

Noise
With the exception of theme park uses, implementation of the Development With No Theme Park East Overlay Alternative would result in development of the same types of uses as the Project.

Although theme park uses would not be allowed on the 1900 South Harbor Boulevard parcel, the entire parcel could be developed with hotel uses. Development of this parcel would require a similar type and quantity of construction equipment for either hotel (this alternative) or theme park (Project) uses. Mitigation measures similar to those identified in this Draft Subsequent EIR would be required, which would reduce impacts related to construction; however, temporary impacts during construction would remain significant. Therefore, short-term construction impacts would be similar when compared to the DisneylandForward Project.

As detailed in Section 5.11, Noise, the Project analyzed development of the 1900 South Harbor Boulevard parcel with theme park uses to represent a worst-case noise impact scenario for the operational scenario. Therefore, it is assumed that development of hotel uses under this alternative would result in similar or slightly reduced operational noise impacts when compared to the Project. It is also assumed that mitigation would continue to be required to achieve a finding of less than significant, including use of sound barriers similar to the Project. Therefore, long-term operational impacts would be slightly reduced when compared to the DisneylandForward Project.

Impacts would be slightly less than the DisneylandForward Project.

Population and Housing
Consistent with the Project, the Development With No Theme Park East Overlay Alternative would not increase the amount of development square footage or hotel rooms currently allowed in the DRSP, or the number of hotel rooms currently allowed in the ARSP. Under this alternative, theme park development would not be permitted on the parcel located at 1900 South Harbor Boulevard, however, this parcel could still be developed with hotel uses. The rest of the Project Site would be developed consistent with the DisneylandForward Project and the elimination of theme park uses in this area would not change the overall maximum allowable density across the Project Site. Therefore, this alternative would generate a similar number of jobs as the Project, and this job creation would result in a similar housing demand and population growth when compared to the Project. The housing and population impacts of this alternative and the DisneylandForward Project would be less than significant.

DisneylandForward
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6-36 Section 6.0 – Alternatives to the Proposed Project This impact would be similar to the DisneylandForward Project.

Public Services
Implementation of the Development With No Theme Park East Overlay Alternative would result in development of the same types of uses as the DisneylandFoward Project and within the same physical development area. Although theme park uses would not be allowed on the 1900 South Harbor Boulevard parcel, the entire parcel could be developed with hotel uses. As discussed above, this alternative would be consistent with the population generation associated with the DisneylandForward Project; therefore, the demand for public services would also be similar to the Project. Similar to the DisneylandForward Project, no significant impacts on recreation would occur assuming adherence to the standard requirements, which requires provision of parkland to the City of Anaheim and/or the payment of fees, consistent with the Anaheim Municipal Code, Section 17.08.250.

This impact would be similar to the DisneylandForward Project.

Transportation
Development of the Development With No Theme Park East Overlay Alternative would result in similar impacts related to traffic because the DisneylandForward Project traffic analysis analyzed a worst-case condition of development of hotel rooms without any theme park uses on the parcel located at 1900 South Harbor Boulevard, which is consistent with this alternative. Therefore, the anticipated distribution and volume of vehicular traffic would be similar to the DisneylandForward Project. Mitigation measures similar to those identified in this Draft Subsequent EIR would be required and it is expected that all impacts related transportation and traffic would be reduced to less than significant levels, which would be consistent with the Project.

This impact would be similar to the DisneylandForward Project.

Tribal Cultural Resources
Due to the nature of tribal cultural resources as physical resources that are tied to the land, impacts related to the Development With No Theme Park East Overlay Alternative would be similar to those identified for the Project. Although this alternative would not allow for development of theme park uses on the parcel located at 1900 South Harbor Boulevard, the parcel could be fully developed with hotel uses, thus resulting in a similar impact area when compared to the DisneylandForward Project. Mitigation measures similar to those identified in this Draft Subsequent EIR would be required; it is expected that all impacts related tribal cultural resources would be reduced to less than significant levels, which would be consistent with the DisneylandForward Project.

This impact would be similar to the DisneylandForward Project.

Utilities
Implementation of the Development With No Theme Park East Overlay Alternative would result in development of the same types and amount of uses as the Project and within the same physical development area with the exception that theme park uses would not be allowed on 1900 South Harbor Boulevard. Even though theme park would not be allowed on this property, it could potentially be reallocated elsewhere within the Project Site, thus allowing for full buildout of the maximum allowable square footage. Because theme park uses have a higher energy demand than hotels, energy demands under the Development With No Theme Park East Overlay DisneylandForward
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6-37 Section 6.0 – Alternatives to the Proposed Project Alternative may be reduced at 1900 South Harbor Boulevard; however, the overall utility demands spread across the entire Project Site would be similar to the DisneylandForward Project. Further, the wastewater analysis for the DisneylandForward Project as summarized in Section 5.16, Utilities, accounts for multiple development scenarios on this parcel and presents mitigation that would be triggered by any type of development (hotel, theme park, retail/restaurant) that exceeds 10,000 square feet. This mitigation would continue to apply to this alternative and would reduce potential impacts to less than significant levels. Therefore, utility impacts associated with the Development With No Theme Park East Overlay Alternative would be less than significant, which would be consistent with the DisneylandForward Project.

This impact would be similar to the DisneylandForward Project.

Conclusions
Avoid or Substantially Lessen the Significant Impacts of the Project As detailed above, implementation of the Development With No Theme Park East Overlay Alternative would result in substantially similar impacts when compared with the Project. Although impact conclusions would be consistent with the Project, this alternative would create minor differences in the severity of impacts related to Noise. Specifically, according to the Noise Study summarized in Section 5.11, Noise, theme park operations represent a worst case scenario when compared to hotel uses; however, impacts would be reduced to less than significant levels under either scenario. Therefore, this alternative would not avoid or decrease the significant and unavoidable impacts related to Air Quality, Cultural Resources, GHG Emissions, or Noise associated with the DisneylandForward Project.

Attainment of Project Objectives
The Development With No Theme Park East Overlay Alternative would not support the identified Project objectives to the same degree as the DisneylandForward Project, primarily because limiting the potential expansion of theme park uses into new areas limits the potential to attract the same volume of new visitors to the area as would the DisneylandForward Project, which would support a more immersive theme park and hotel experience. Implementation of this alternative would not allow for the potential for development of theme park uses at 1900 South Harbor Boulevard (known as the proposed Theme Park East Overlay), thus limiting the potential for meeting the changing demands of future tourism in Southern California and the City of Anaheim.

This alternative also likely would limit the introduction of theme park uses into the DRSP Southeast District given its smaller size relative to the Theme Park East Overlay. As discussed in the Section 3.0, Project Description, the S outheast District is 24.7 acres and allocated up to 390,000 square feet of theme park uses while the Theme Park East Overlay is 52.6 acres (more than twice the size of the Southeast District) and allocated up to 840,000 square feet of theme park uses. Without development of theme park uses in the Theme Park East Overlay, the Project would lack the synergy important to develop both properties with theme park uses.

Specifically, the Development With No Theme Park East Overlay Alternative would not support the following objectives to the same degree as the DisneylandForward Project:
 To reconfirm and enhance Southern California as one of the world’s greatest tourist destinations;
 To support the ongoing transformation of The Anaheim Resort into a multi-day destination resort for use by Southern California metropolitan area residents, as well as visitors from around the world;
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6-38 Section 6.0 – Alternatives to the Proposed Project  To promote the goals of the Anaheim General Plan by enhancing visitor-serving commercial uses in the City and to provide a catalyst for the economic and physical enhancement of Anaheim;
 To support the buildout of a fully integrated resort that increases visitation levels and generates an economic base capable of supporting project components consistent with the objectives of the City;
 To enhance The Anaheim Resort by providing a wider range of attractions, hotel accommodations, restaurants, shopping opportunities, and public parking;  To lay a foundation for future economic expansion and minimize environmental impacts through comprehensive site development guidelines;
 To maintain and encourage Anaheim’s position as a nationally recognized tourist, convention and recreation center;
 To increase sales tax yields and further enhance the economic base of the community, thereby lessening the tax burden on real property;
 To encourage the development of quality facilities that complement conventions, family entertainment, and recreation within appropriate areas of the community;  To support the continued reimagination of The Disneyland Resort to meet and exceed evolving guest expectations for immersive entertainment and technological advances in theme park and other resort experiences;
 To continue to fulfill the following vision of Walt Disney: “Disneyland will never be completed…It will continue to grow as long as there is imagination left in the world.”; and  To allow the expansion of theme park and parking uses to Disney ARSP Properties to support the continued success and vitality of The Anaheim Resort, including The Disneyland Resort.

6.6 ENVIRONMENTALLY SUPERIOR ALTERNATIVE
CEQA requires the identification of an environmentally superior alternative. CEQA Guidelines Section 15126.6(e)(2) states that if the No Project Alternative is the environmentally superior alternative, then the Draft EIR shall also identify an environmentally superior alternative among the other alternatives. Table 6-3 provides, in summary format, a comparison of the impacts for each alternative to the Project. Table 6-3 identifies whether the respective alternatives would have similar, less, or greater impacts compared to the impacts of the DisneylandForward Project.

The Restrict Removal or Substantial Changes to Listed Historic Features Alternative has the least impact to the environment because it would eliminate a potential significant and unavoidable impact by retaining the potential Disneyland Theme Park Historic District, the three individually eligible features within the potential Disneyland Theme Park Historic District (the Hungry Bear Restaurant, Pirates of the Caribbean and the Main Street Railroad Depot), and the potentially individually eligible Pope House. While this alternative would be environmentally superior to the DisneylandForward Project, it would not meet most of the Project Objectives, particularly the following:
 To support the continued reimagination of The Disneyland Resort to meet and exceed evolving guest expectations for immersive entertainment and technological advances in theme park and other resort experiences.

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6-39 Section 6.0 – Alternatives to the Proposed Project  To continue to fulfill the following vision of Walt Disney: “Disneyland will never be completed…It will continue to grow as long as there is imagination left in the world.” Additionally, this Alternative would not meet other Project objectives listed below to the same degree as the DisneylandForward Project in that limiting the flexibility of future redevelopment of specific elements would limit Disney’s ability to maximize future guest experiences and more meaningfully contribute to the economic growth of the City.  To reconfirm and enhance Southern California as one of the world’s greatest tourist destinations;

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6-40 Section 6.0 – Alternatives to the Proposed Project TABLE 6-3

COMPARISON OF THE ALTERNATIVES TO THE PROPOSED PROJECT
Environmental Issue
Proposed
Project
No Project/Continued
Development
Restrict Removal or
Substantial Changes to
Listed Historic Features No Theme Park East Overlay
Impact Level Comparison to Project Comparison to Project Comparison to Project Aesthetics LSM Greate r Simila r Simila r
Air Quality SU Greater Simila r Simila r
Biological Resources LSM Similar Similar Similar
Cultural Resources SU Less Less Similar
Energy LSM Similar Similar Similar
Geology and Soils LSM Similar Simila r Simila r
Greenhouse Gas Emissions SU Similar Simila r Simila r
Hazards and Hazardous
Materials and Wildfire LSM Similar Similar Similar
Hydrology and Water Quality LSM Similar Simila r Simila r Land Use and Planning LSM Greater Simila r Simila r
Noise SU Simila r Simila r Less
Population and Housing LS Similar Simila r Simila r
Public Services and
Recreation LSM Similar Similar Similar
Transportation/Traffic LSM Similar Similar Similar
Tribal Cultural Resources LSM Greater Similar Similar
Utilities and Service Systems LSM Similar Simila r Simila r LS: Less Than Significant, LSM: Less Than Significant After Mitigation, SU: Significant and Unavoidable.

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6.7 REFERENCES
Anaheim, City of. 2023a (January 10). General Plan Safety Element. Anaheim, CA: City of Anaheim. https://www.anaheim.net/DocumentCenter/View/47834/Safety- Element_01102023.
———.2023b (January 1). Anaheim Municipal Code. Anaheim, CA: City of Anaheim. https://codelibrary.amlegal.com/codes/anaheim/latest/anaheim_ca/0-0-0-51668. ———.2022b. 2021-2029 Draft Housing Element Update. Anaheim, CA: City of Anaheim. https://www.anaheim.net/5998/2021-2029-Draft-Housing-Element. ———.2020 (July 17, date amended). Bicycle Master Plan. Anaheim, CA: Anaheim. https://www.anaheim.net/3398/Bicycle-Master-Plan.
———. 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 Office of Administrative Law. 2010. California Code of Regulations (Title 14, Natural Resources; Division 6, Resources Agency; Chapter 3, Guidelines for Implementation of the California Environmental Quality Act). Eagen, MN: Westlaw for the State. http://government.westlaw.com/linkedslice/default.asp?Action=TOC&RS=GVT1.0& VR=2.0&SP=CCR-1000.

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7-1 Section 7.0 – Other CEQA Considerations
SECTION 7.0

OTHER CEQA CONSIDERATIONS
CEQA Guidelines Section 15126 requires all aspec ts of a proposed project (including planning, acquisition, development, and operation) be considered when evaluating the proposed project’s impact on the environment. Section 15126 also sets forth general content requirements for EIRs.

The significant environmental effects of the DisneylandForward Project are discussed in Sections 5.1 through 5.16 of this Draft Subsequent EIR, and summarized in Section 1.0, Executive Summary. As addressed through the analysis presented in this Draft Subsequent EIR, with implementation of project-specific mi tigation measures, there remain significant environmental effects related to Air Quality (regional construction emissions), Cultural Resources (historic resources), Greenhouse Gas Emissions (GHG emissions), and Noise (temporary construction noise), which cannot be avoided if the DisneylandForward Project is implemented.

With the exception of Cultural Resources, each of the significant and unavoidable findings are consistent with previous findings in the Prior EIRs.

This section identifies (1) effects determined not to be significant; (2) significant irreversible environmental changes that would result from implementing the Project; and (3) growth-inducing impacts of the Project.

7.1 EFFECTS DETERMINED NOT TO BE SIGNIFICANT
CEQA Guidelines Section 15128 states “an EIR shall contain a statement briefly indicating the reasons that various possible significant effects of a project were determined not to be significant and were therefore not discussed in detail in the EIR”. Through review of the Project and the Project Site, the City has determined detailed discussions for agricultural and forestland resources, mineral resources, and wildfire are not required because the Project would result in no impacts due to the lack of these resources on the Project Site.

7.2 SIGNIFICANT IRREVERSIBLE ENVIRONMENTAL CHANGES WHICH WOULD BE

CAUSED BY THE PROJECT SHOULD IT BE IMPLEMENTED
CEQA Guidelines Section 15126(d) requires a Draft EIR to describe any significant irreversible environmental changes which would occur as a result of the proposed action should it be implemented. The Project Site in the City is curr ently developed with various uses. Existing land uses within the area governed by the DRSP consist of Disneyland, Downtown Disney, Disney California Adventure Park, Disney’s Grand Californian Hotel & Spa, Disneyland Hotel, Disney administration offices, back-of-house uses, and parking lots/structures owned or controlled by Disney as well as hotels, motels, retail centers, rental car offices, and convenience stores owned by third parties. Existing land uses within the Disney ARSP Properties are surface parking lots, an office building, and the Paradise Pier Hotel and associated parking structure. Existing land uses in the ARSP include the Anaheim Convention Center, as well as hotels, motels, retail, restaurant, service station, office, parking lot/structures, single-family residential uses, rental car offices, event center/banquet halls, vacant lands, RV park uses, and mobile home sites. The ARSP also includes a post office, Orange Grove Elementary, and a vocational school. As noted above, the Project Site does not contain any natural resources and, under existing conditions, has a high demand for non-renewable resources related to energy demand and transportation.

Construction and long-term operation of the Project would require the commitment and reduction of nonrenewable and/or slowly renewable resources, including petroleum fuels and natural gas (for vehicle emissions, construction, lighting, heating, and cooling of structures) and lumber, sand/gravel, steel, copper, lead, and other metals (for use in building construction, piping, and DisneylandForward
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7-2 Section 7.0 – Other CEQA Considerations
roadway infrastructure). Other resources that are slow to renew and/or recover from environmental stresses would also be impacted by Project implementation, such as air quality through the combustion of fossil fuels and production of greenhouse gases and water supply through the increased potable water demands for drinking, cooking, cleaning, landscaping, and general maintenance needs. An increased commitment of public services (e.g., police, fire, and sewer and water services) would also be required. Therefore, implementation of the Project would result in an irreversible commitment of land, energy resources, and public services. Restoration of the Project Site to pre-developed conditions would not be feasible given the degree of disturbance, the urbanization of the area, and the level of capital investment.

As described in Section 3.0, Project Description, of this Draft Subsequent EIR, the Project Site is currently entitled for additional development associated with buildout of The Disneyland Resort and the ARSP, which would increase the demand for nonrenewable resources as detailed above.

Because the only increase to development square footage associated with the DisneylandForward Project includes an increase of 4,376 theme park-related parking spaces in the ARSP at the 333 West Ball Road site (ARSP Parking Overlay), there would be no net increase in hotel or theme park development compared to existing entitled conditions. The DisneylandForward Project would also introduce a greater level of efficiency through the mitigation measures and project design features discussed throughout this Draft Subsequent EIR.

While many of these efficiencies would be implemented or achieved with or without the DisneylandForward Project, the anticipated demand for nonrenewable resources would be no greater than what would occur without the DisneylandForward Project through continued development of The Disneyland Resort and the ARSP.

7.3 GROWTH-INDUCING IMPACTS OF THE PROPOSED ACTION
Pursuant to CEQA Guidelines Sections 15126(d) and 15126.2(e), this section is provided to examine ways in which the Project could foster economic or population growth, or the construction of additional housing, either directly or indirectly, in the surrounding environment. To address this issue, potential growth-inducing effects are examined through analysis of the following questions:

2. Would this proposed project result in the need to expand one or more public services to maintain desired levels of service?

3. Would this proposed project encourage or facilitate economic effects that could result in other activities that could significantly affect the environment?

4. Would approval of this proposed project involve some precedent-setting action that could encourage and facilitate other activities that could significantly affect the environment? Growth-inducing effects are not necessarily beneficial, detrimental, or of little significance to the environment (CEQA Guidelines, Section 15126.2(e)). This issue is presented to provide additional information on ways in which the Project could contribute to significant changes in the environment, beyond the direct consequences of implementing the Project examined in the preceding sections of this Draft Subsequent EIR. It should also be noted that while implementation of the Project would result in new development on the Project Site, the associated increases in population are not considered to be the result of growth inducement, but rather reflects the accommodation of growth already anticipated by current entitlements and the previously certified EIR No. 311 and SEIR No. 340. Section 5.12, Population and Housing, provides additional discussion regarding such growth.

DisneylandForward
Draft Subsequent EIR No. 352

7-3 Section 7.0 – Other CEQA Considerations

1. Would this proposed project remove obstacles to growth (e.g., through the construction or extension of major infrastructure facilities that do not presently exist in the project area, or through changes in existing regulations pertaining to land development)? As discussed in Section 3.0, Project Description, new and modified infrastructure facilities are required to accommodate the Project. Specifically, Project development would require improvements to on and off-site sewer, water, and electrical facilities. Additionally, vehicular circulation improvements are proposed on and near the Project Site. These improvements are recommended as part of the Project to address future impacts, including addressing increased traffic volumes, modified traffic distribution, and increased demand for utilities that would be generated by the Project. However, the proposed improvements would accommodate Pr oject conditions and anticipated growth associated with related projects and the ARSP. The Project would not introduce increased roadway capacity in areas that are not already fully developed or planned for development and redevelopment with urban uses, and therefore would not induce unplanned growth.

Existing backbone wet and dry utility infrastructure is currently installed within or in the vicinity of the Project Site. The backbone infrastructure would be protected in place during construction and operation. However, implementation of the Project would involve improvements to existing utility infrastructure and construction of new utility infrastructure, as necessary to serve the proposed development. The utility infrastructure installed as part of the Project would be sized and located expressly to serve the Project Site (existing and proposed uses), entitled uses, and anticipated growth associated with related projects buildout of the ARSP, and would not, therefore, induce growth in the immediate vicinity.

Approval of the Project and associated discretionary actions would accommodate growth, including economic growth, associated with existing entitlements associated with the The Disneyland Resort and the ARSP but would not remove an existing regulatory obstacle to growth, but rather, would allow for flexibilit y in the continued development of the Project Site with entitled uses. Consistent with the findings of EIR No. 311, the induced growth from the Project would be focused on the immediate area within The Anaheim Resort, inclusive of the ARSP and The Disneyland Resort. The continued development of the Project Site pursuant to existing entitlements would not encourage growth through the provision of new and essential public services or access opportunities, nor would it result in urbanization of land in a remote location. The Project is not, therefore, considered to be growth-inducing with respect to removal of obstacles to growth. Additionally, as discussed in Section 5.10, Land Use and Planning, the Project would be generally consistent with the goals/policies of the Anaheim General Plan and other relevant planning documents that address development of the Project Site.

2. Would this proposed project result in the need to expand one or more public services to maintain desired levels of service? As discussed in Section 5.13, Public Services, the Project would potentially increase the demand for public services (police and fire), however all expanded facilities would be located within the development footprint of the DisneylandForward Project. Therefore, the Project would not necessitate the expansion of existing public service facilities outside the limits of the Project Site in order to maintain desired levels of service. In the event that these facilities or associated resources do need to be expanded in off-site areas, funding mechanisms are in place through existing regulations and standard practices to accommodate such growth. The Project would not, therefore, have significant growth-inducing consequences with respect to public services. This would be consistent with the findings of EIR No. 311 and SEIR No. 340.

DisneylandForward
Draft Subsequent EIR No. 352

7-4 Section 7.0 – Other CEQA Considerations

3. Would this proposed project encourage or facilitate economic effects that could result in other activities that could significantly affect the environment? During project-specific construction associated with the Project, a number of design, engineering, and construction-related jobs would be created, which would last until project-specific construction was completed. This would provide economic stimulus in the area; however, these jobs typically would be filled by existing residents of the region and would not be substantial enough to foster other activities that would have significant effects on the environment.

In addition, the Project would result in the addition of employees. However, as discussed in Section 5.12, Population and Housing, this proposed increase in employees, population, and housing is within the forecasts for the City and the County. Additionally, the majority of the anticipated employment positions are typical of the existing employment on the Project Site and within the City associated with visitor-serving uses and may not offer a unique enough opportunity to induce job seekers to relocate to the area for the sole purpose of filling these positions. While some future employees may transfer into the area to fill these positions, it is expected that qualified area residents would fill the vast majority of additional employment positions. Similarly, it is anticipated that either local worker would fill the positions or construction employees would commute from elsewhere in the region, rather than relocate to the Anaheim area for a temporary construction job. Nonetheless, implementation of the Project may result in the creation of indirect and induced jobs.

Indirect jobs are those that would be created when goods and services are purchased from businesses in the region, and induced jobs are those that are created when wage incomes of those employed in direct and indirect jobs are spent on the purchase of goods and services in the region. This would be consistent with the findings of EIR No. 311 and SEIR No. 340.

4. Would approval of this project involve some precedent-setting action that could encourage and facilitate other activities that could significantly affect the environment? As discussed previously, the Project involves continued development of entitled uses. The Project does not involve any changes in the type or amount of allowed development on the Project Site or in the City, with the exception of an increase of 4,376 theme park-related parking spaces in the ARSP. Additionally, these actions, which include flexibility for future development, are Project-specific and would not encourage and facilitate other activities. The Project would continue to function as a visitor-serving use and would be generally consistent with existing land use and planning policies.

No changes to any of the City’s building safety standards (i.e., building, grading, plumbing, mechanical, electrical, fire codes) are proposed or required to implement the Project.

Regulatory requirements, and Project-specific mitigation measures have been identified in Sections 5.1 through 5.16 to ensure that implementation of the Project complies with all applicable City plans, policies, and ordinances, as applicable, to ensure that there are no conflicts with adopted land development regulations and that environmental impacts are minimized. The Project does not propose any precedent-setting actions that, if approved, would specifically allow or encourage other projects and resultant growth to occur. This would be consistent with the findings of EIR No. 311 and SEIR No. 340.

DisneylandForward
Draft Subsequent EIR No. 352

8-1 Section 8.0 – List of EIR Preparers and Contributors SECTION 8.0

LIST OF EIR PREPARERS AND PERSONS CONSULTED

8.1 EIR PREPARERS

8.1.1 CITY OF ANAHEIM (LEAD AGENCY)
Planning & Building
Elaine Thienprasiddhi, Senior Planner
Ted White, Director of Planning & Building
Heather Allen, Principal Planner
Linda Johnson, Principal Planner
Judy Dadant, Senior Planner
Christine Nguyen, Senior Planner
Amanda Lauffer, Associate Planner
Terry Alford, Building Official
Sylvia Frias, Code Enforcement Supervisor
Public Works
Rudy Emami, Director of Public Works
Carlos Castellanos, City Engineer
Public Works – Traffic
Rafael Cobian, City Traffic Engineer
David Kennedy, Associate Transportation Planner
Joe Alcock, Principal Transportation Planner
Public Works – Development Services
Shawn Azarhoosh, Principal Civil Engineer
Mike Eskander, Development Services Manager
Keith Linker, Principal Civil Engineer
Randy Saldana, Real Property Specialist II
Gabreelle Gonzalez, Associate Engineer
Public Works – Design
Bill Grigsby, Principal Civil Engineer
Public Works – Operations & ARMD
Eddie de la Torre, Streets & Sanitation Administrator
Mark McGee, Operations Contract Specialist
Dan DeBassio, Deputy Public Works Director
Ayumi Takayasu, Public Works Operations Manager
Dianne Rasmussen, Operations Supervisor
DisneylandForward
Draft Subsequent EIR No. 352

8-2 Section 8.0 – List of EIR Preparers and Contributors City Attorney
Leonie Mulvihill, Assistant City Attorney
Bryn Morley, Deputy City Attorney III
Public Utilities – Electrical
Janet Lonneker, Assistant General Manager
Nam Nguyen, Principal Power Systems Planning Engineer
Vinh Tran, Principal Electrical Engineer
Fred Barvarz, Transmission & Distribution Manager
Tony Mai, Electrical Capital Projects Manager
Joseph Wei, Electrical Systems Planning Manager
Hieu Lam, Senior Power Systems Planning Engineer
Jeremy Greaney, Senior Electrical Engineer
Public Utilities – Water
David Kim, Principal Civil Engineer
Gidti Ludesirishoti, Principal Civil Engineer
Philip Bogdanoff, Engineering Manager
Public Utilities – Environmental Compliance
Jonathan Sanks, Environmental & Safety Services Manager Police
Rick Armendariz, Deputy Chief
Eric Trapp, Police Captain
Jon Yepes, Police Lieutenant
Tony Lee, Police Sergeant
Mark Berger, Police Officer Planning & Research
James Griswold, Sergeant
John Carter, Dispatch Supervisor
Fire
Patrick Russell, Fire Chief
David Rodriguez, Assistant Fire Marshal
Lindsey Young, Fire Marshal
Gary Blevins, Deputy Fire Marshal
Economic Development
Sergio Ramirez, Director of Economic Development
Housing
Andy Nogal, Deputy Director of Housing and Community Development Kevin Clausen, Senior Project Manager
DisneylandForward
Draft Subsequent EIR No. 352

8-3 Section 8.0 – List of EIR Preparers and Contributors Comm Services – Parks
Jose Jimenez, Parks Manager
Comm Services – Library
Thomas Edelblute, Senior Library Services Manager
City Peer Reviewer
Dudek

8.1.2 PSOMAS (EIR CONSULTANT)
Jennifer Marks, Principal in Charge/Senior Project Manager Sean Noonan, Project Manager
Jessica Hitchcock, Project Manager
Megan Larum, Assistant Project Manager
Tin Cheung, Air Quality and Greenhouse Gas Manager
Jordan Werkmeister, Environmental Planner
Charles Cisneros, Cultural Resources Manager
Amber Heredia, Senior Biologist
Sheryl Kristal, Senior Word Processor
Danaé Overman, Technical Editor
Jim McPherson, GIS Manager
Jennie Ramirez, GIS Specialist
Paul O’Brien, GIS Technician
Mike Swan, Sewer and Water Senior Engineer
Kim Alexander, Sewer and Water Senior Engineer
Matthew Heideman, Hydrology and Water Quality Senior Engineer Steven Zehner, Hydrology and Water Quality Senior Engineer Alex Evett, Senior GIS Analyst

8.2 EIR CONTRIBUTORS

8.2.1 RRM DESIGN GROUP (Shade and Shadow/Visual, Specific Plan)

8.2.2 HISTORIC RESOURCES GROUP (Historic Resources)

8.2.3 SOUTH ENVIRONMENTAL (Historic Resources)

8.2.4 ARDURRA (Hydraulic Analysis)

8.2.5 VENEKLASEN (Noise)

8.2.6 GIBSON TRANSPORTATION CONSULTING (Transportation)

8.3 ORGANIZATIONS AND PERSONS CONSULTED

8.3.1 NATIVE AMERICAN TRIBE
Andrew Salas, Chairman, Gabrieleño Band of Mission Indians – Kizh Nation DisneylandForward
Draft Subsequent EIR No. 352

8-4 Section 8.0 – List of EIR Preparers and Contributors

8.4 APPLICANT

8.4.1 WALT DISNEY COMPANY

Anaheim City CouncilApril 16, 2024

Anaheim City Council
April 16, 2024