Cities Index.
9. Addendum to FEIR No. 331

Anaheim City Council
July 23, 2024

Document
9. Addendum to FEIR No. 331
Meeting
July 23, 2024
Body
Anaheim City Council
Pages
43
Original file
22.2 MB
Text extracted from the city's file for reading and search. Open the original on local.anaheim.net. That file is the official record.

May 2024

A D D E N D U M
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GYPSUM CANYON CEMETERY PROJECT
2BANAHEIM , CALIFORNIA

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GYPSUM CANYON CEMETERY PROJECT
2BANAHEIM, CALIFORNIA

Submitted to:

City of Anaheim
200 South Anaheim Boulevard
Anaheim, California 92805

Prepared by:

LSA Associates, Inc.
3210 El Camino Real, Suite 100
Irvine, California 92602
(949) 553-0666

Project No. OCC1901

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TABLE OF CONTENTS
TABLE OF CONTENTS ............................................................................................................................... i FIGURES AND TABLES ............................................................................................................................ iv LIST OF ABBREVIATIONS AND ACRONYMS ............................................................................................. v

1.0 INTRODUCTION ................................................................................................ 1-1

1.1 Purpose and Scope ............................................................................................................ 1-1

1.2 Evaluation of Environmental Impacts ............................................................................... 1-3

1.2.1 Approved Project ................................................................................................................ 1-3

1.2.2 Proposed Project and Addendum ....................................................................................... 1-4

1.3 Findings of this Addendum ............................................................................................... 1-5

1.4 Format of Addendum ........................................................................................................ 1-6

1.4.1 Chapter 1.0: Introduction ................................................................................................... 1-6

1.4.2 Chapter 2.0: Project Description ........................................................................................ 1-6

1.4.3 Chapter 3.0: Comparative Evaluation of Environmental Impacts ...................................... 1-6

1.5 Existing Documents to be Incorporated by Reference ..................................................... 1-6

1.6 Contact Persons ................................................................................................................ 1-7

2.0 PROJECT DESCRIPTION ..................................................................................... 2-1

2.1 Background ....................................................................................................................... 2-1

2.2 Approved Project .............................................................................................................. 2-1

2.2.1 City of Anaheim and Setting ............................................................................................... 2-1

2.2.2 Mountain Park Specific Plan and Setting ............................................................................ 2-1

2.2.3 Approved Project Characteristics ....................................................................................... 2-5

2.3 Proposed Project ............................................................................................................. 2-32

2.3.1 OCCD Cemetery ................................................................................................................ 2-32

2.3.2 CalVet Veterans Cemetery ............................................................................................... 2-40

2.4 Project Objectives ........................................................................................................... 2-40

3.0 COMPARATIVE EVALUATION OF ENVIRONMENTAL IMPACTS ........................... 3-1

3.1 Land Use and Planning ...................................................................................................... 3-3

3.1.1 Existing Environmental Setting ........................................................................................... 3-3

3.1.2 Comparison of Impacts for the Approved Project and the Proposed Project .................... 3-3

3.1.3 Cumulative Land Use and Planning Impacts ..................................................................... 3-10

3.1.4 Findings Related to Land Use and Planning ...................................................................... 3-11

3.1.5 Standard Conditions and Mitigation Measures ................................................................ 3-11

3.2 Landform and Aesthetics ................................................................................................ 3-12

3.2.1 Existing Environmental Setting ......................................................................................... 3-12

3.2.2 Comparison of Impacts for the Approved Project and the Proposed Project .................. 3-13

3.2.3 Cumulative Landform and Aesthetics Impacts ................................................................. 3-24

3.2.4 Findings Related to Landform and Aesthetics .................................................................. 3-25

3.2.5 Standard Conditions and Mitigation Measures ................................................................ 3-25

3.3 Geology and Soils ............................................................................................................ 3-26

3.3.1 Existing Environmental Setting ......................................................................................... 3-26

3.3.2 Comparison of Impacts for the Approved Project and the Proposed Project .................. 3-29

3.3.3 Cumulative Geology and Soils Impacts ............................................................................. 3-35

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3.3.4 Findings Related to Geology and Soils ............................................................................. 3-36

3.3.5 Standard Conditions and Mitigation Measures ............................................................... 3-36

3.4 Hydrology ........................................................................................................................ 3-39

3.4.1 Existing Environmental Setting ........................................................................................ 3-39

3.4.2 Comparison of Impacts for the Approved Project and the Proposed Project ................. 3-40

3.4.3 Cumulative Hydrology Impacts ........................................................................................ 3-53

3.4.4 Findings Related to Hydrology ......................................................................................... 3-54

3.4.5 Standard Conditions and Mitigation Measures ............................................................... 3-54

3.5 Water Quality ................................................................................................................. 3-54

3.5.1 Existing Environmental Setting ........................................................................................ 3-54

3.5.2 Comparison of Impacts for the Approved Project and the Proposed Project ................. 3-56

3.5.3 Cumulative Water Quality Impacts .................................................................................. 3-66

3.5.4 Findings Related to Water Quality ................................................................................... 3-67

3.5.5 Standard Conditions and Mitigation Measures ............................................................... 3-68

3.6 Biological Resources ....................................................................................................... 3-69

3.6.1 Existing Environmental Setting ........................................................................................ 3-69

3.6.2 Comparison of Impacts for the Approved Project and the Proposed Project ................. 3-70

3.6.3 Cumulative Biological Resources Impacts........................................................................ 3-88

3.6.4 Findings Related to Biological Resources ......................................................................... 3-89

3.6.5 Standard Conditions and Mitigation Measures ............................................................... 3-90

3.7 Traffic and Circulation..................................................................................................... 3-96

3.7.1 Existing Environmental Setting ........................................................................................ 3-96

3.7.2 Comparison of Impacts for the Approved Project and the Proposed Project ................. 3-99

3.7.3 Cumulative Traffic and Circulation Impacts ................................................................... 3-106

3.7.4 Findings Related to Traffic and Circulation .................................................................... 3-107

3.7.5 Standard Conditions and Mitigation Measures ............................................................. 3-108

3.8 Air Quality ..................................................................................................................... 3-109

3.8.1 Existing Environmental Setting ...................................................................................... 3-109

3.8.2 Comparison of Impacts for the Approved Project and the Proposed Project ............... 3-109

3.8.3 Cumulative Air Quality Impacts ..................................................................................... 3-115

3.8.4 Findings Related to Air Quality ...................................................................................... 3-116

3.8.5 Standard Conditions and Mitigation Measures ............................................................. 3-117

3.9 Noise ............................................................................................................................. 3-120

3.9.1 Existing Environmental Setting ...................................................................................... 3-120

3.9.2 Comparison of Impacts for the Approved Project and the Proposed Project ............... 3-121

3.9.3 Cumulative Noise Impacts ............................................................................................. 3-125

3.9.4 Findings Related to Noise .............................................................................................. 3-126

3.9.5 Standard Conditions and Mitigation Measures ............................................................. 3-126

3.10 Hazards and Hazardous Materials ................................................................................ 3-127

3.10.1 Existing Environmental Setting ...................................................................................... 3-127

3.10.2 Comparison of Impacts for the Approved Project and the Proposed Project ............... 3-128

3.10.3 Cumulative Hazards and Hazardous Materials Impacts ................................................ 3-132

3.10.4 Findings Related to Hazards and Hazardous Materials ................................................. 3-133

3.10.5 Standard Conditions and Mitigation Measures ............................................................. 3-134

3.11 Population and Housing................................................................................................ 3-135

3.11.1 Existing Environmental Setting ...................................................................................... 3-135

3.11.2 Comparison of Impacts for the Approved Project and the Proposed Project ............... 3-136

3.11.3 Cumulative Population and Housing Impacts ................................................................ 3-138 iii
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3.11.4 Findings Related to Population and Housing .................................................................. 3-138

3.11.5 Standard Conditions and Mitigation Measures .............................................................. 3-139

3.12 Public Services and Utilities........................................................................................... 3-139

3.12.1 Existing Environmental Setting ....................................................................................... 3-139

3.12.2 Comparison of Impacts for the Approved Project and the Proposed Project ................ 3-141

3.12.3 Cumulative Public Services and Utilities Impact ............................................................. 3-155

3.12.4 Findings Related to Public Services and Utilities ............................................................ 3-155

3.12.5 Standard Conditions and Mitigation Measures .............................................................. 3-156

3.13 Recreation ..................................................................................................................... 3-159

3.13.1 Existing Environmental Setting ....................................................................................... 3-159

3.13.2 Comparison of Impacts for the Approved Project and the Proposed Project ................ 3-159

3.13.3 Cumulative Recreation Impacts ...................................................................................... 3-162

3.13.4 Findings Related to Recreation ....................................................................................... 3-165

3.13.5 Standard Conditions and Mitigation Measures .............................................................. 3-165

3.14 Cultural Resources ........................................................................................................ 3-166

3.14.1 Existing Environmental Setting ....................................................................................... 3-166

3.14.2 Comparison of Impacts for the Approved Project and the Proposed Project. ............... 3-166

3.14.3 Cumulative Cultural Resources Impacts ......................................................................... 3-170

3.14.4 Findings Related to Cultural Resources .......................................................................... 3-170

3.14.5 Standard Conditions and Mitigation Measures .............................................................. 3-171

4.0 REFERENCES ..................................................................................................... 4-1

APPENDICES
A: MITIGATION MONITORING AND REPORTING PROGRAM NO. 137
B: APPLICABILITY OF MITIGATION MONITORING PROGRAM NO. 137 TO THE GYPSUM CANYON

CEMETERY PROJECT

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FIGURES AND TABLES

FIGURES
Figure 2-1: Regional and Project Location .......................................................................................... 2-3 Figure 2-2: Mountain Park Specific Plan Development Areas ............................................................ 2-7 Figure 2-3: Conceptual Site Plan ....................................................................................................... 2-33 Figure 3-1: General Plan Land Use Designations ................................................................................ 3-5 Figure 3-2: Existing Zoning Designations ............................................................................................ 3-7 Figure 3-3: Visual Simulation: EIR No. 331 View N-9 ........................................................................ 3-15 Figure 3-4: Conceptual Grading Plan ................................................................................................ 3-19 Figure 3-5: Relationship of Conservation Easement to Project Site ................................................. 3-71

TABLES
Table 2.A: Permitted Residential Development Under Approved Project ......................................... 2-5 Table 2.B: EIR No. 331 Project Design Features ................................................................................ 2-11 Table 3.A: Beneficial Uses of Receiving Waters ................................................................................ 3-55 Table 3.B: Mapped Vegetation/Land Cover Classifications .............................................................. 3-80 Table 3.C: Summary of Jurisdictional/Nonjurisdictional Features .................................................... 3-82 Table 3.D: Jurisdictional Impacts ...................................................................................................... 3-83 Table 3.E: Comparison of Future Land Use ..................................................................................... 3-102 Table 3.F: Project-Generated VMT ................................................................................................. 3-102 Table 3.G: Citywide VMT per Service Population ........................................................................... 3-103 Table 3.H: Project Parking Demand ................................................................................................ 3-105 Table 3.I: Approved Project Daily Maximum Emissions (lbs/day) .................................................. 3-111 Table 3.J: Approved Project Annual GHG Emissions (MT/Year) ..................................................... 3-111 Table 3.K: Proposed Project Daily Maximum Emissions (lbs/day) .................................................. 3-112 Table 3.L: Proposed Project Annual GHG Emissions (MT/Year) ..................................................... 3-112 Table 3.M: City of Anaheim General Plan and SCAG Regional Comprehensive Plan Consistency Analysis .............................................................................................................. 3-163

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LIST OF ACRONYMS AND ABBREVIATIONS
ACOE United States Army Corps of Engineers
Act Natural Community Conservation Act
ADL aerially deposited lead
ADT average daily trips
amsl above mean sea level
AQMP Air Quality Management Plan
Basin Plan Water Quality Control Plan for the Santa Ana River Basin bgs below ground surface
BMP Best Management Practices
CAAQS California Ambient Air Quality Standards
CalRecycle California Department of Resources Recycling and Recovery Caltrans California Department of Transportation
CalVet California Department of Veterans Affairs
CARB California Air Resources Board
CBC 2022 California Building Code as Adopted by the Anaheim City Council CCRPA California Cultural Resource Preservation Alliance CDFW California Department of Fish and Wildlife
CEQA California Environmental Quality Act
cf cubic feet
cfs cubic feet per second
CIMIS California Irrigation Management System
City City of Anaheim
CMP Congestion Management Plan
CNEL Community Noise Equivalent Level
CNPS California Native Plant Society
CO carbon monoxide
County County of Orange
CPUC California Public Utilities Commission
CSS coastal sage scrub

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CWA Clean Water Act
DA Development Area
DAMP Drainage Area Management Plan
dB decibels
dBA A-weighted decibels
DCV design storm capture volume
DEDB dry extended detention basin
EB eastbound
EIR Environmental Impact Report
ESA Environmental Site Assessment
g acceleration of gravity (equal to 32 feet/second)
GHG greenhouse gas
HCP Habitat Conservation Plan
HEC RAS Hydrologic Engineering Center-River Analysis System HHWE Household Hazardous Waste Element
I- Interstate
IA Implementation Agreement
ICU intersection capacity utilization
IS/MND Initial Study/Mitigated Negative Declaration
ITE Institute of Transportation Engineers
IWMD Integrated Waste Management Department
kV kilovolts
kWh kilowatt-hours
LIP Local Implementation Plan
LOS level(s) of service
MCL maximum contaminant level
MG million gallons
MGD million gallons per day
MMRP Mitigation Monitoring and Reporting Program
MND Mitigated Negative Declaration
MPAH Master Plan of Arterial Highways
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MPSP Mountain Park Specific Plan
MS4 Municipal Separate Storm Sewer System
MUTCD Manual of Uniform Traffic Control Devices
Mw moment magnitude
NAAQS National Ambient Air Quality Standards
NCCP Natural Communities Conservation Plan
NO2 nitrogen dioxide
NOP Notice of Preparation
NOX nitrogen oxides
NPDES National Pollution Discharge Elimination System
NRPPA North Ranch Policy Plan Area
O3 ozone
OCCD Orange County Cemetery District
OCHCA OC Healthcare Agency
OCHM Orange County Hydrology Manual
OCIWMD Orange County Integrated Waste Management District OCSD Orange County Sanitation District
OCTA Orange County Transportation Authority
OCTAM Orange County Transportation Analysis Model
OCWD Orange County Water District
PAHs polycyclic aromatic hydrocarbons
PDF project design feature
PM10 particulate matter less than 10 microns in diameter PM2.5 particulate matter less than 2.5 microns in diameter PWQMP Preliminary Water Quality Management Plan
PRC Public Resources Code
Proposed Project Gypsum Canyon Cemetery Project
RCPG Regional Comprehensive Plan and Guide
REC recognized environmental condition
RHNA Regional Housing Needs Allocation
RMP Runoff Management Plan

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ROG reactive organic gases
RTP/SCS Regional Transportation Plan/Sustainable Communities Strategy RWQCB Regional Water Quality Control Board
SAF Saint Anthony Falls
SARI Santa Ana Regional Interceptor
SB Senate Bill
SC Standard Condition
SCAB South Coast Air Basin
SCAG Southern California Association of Governments
SCAQMD South Coast Air Quality Management District
SCE Southern California Edison
SCH State Clearinghouse
SoCalGas Southern California Gas Company
SR State Route
SRRE Source Reduction and Recycling Element
SWPPP Storm Water Pollution Prevention Plan
SWRCB State Water Resources Control Board
TACs Toxic Air Contaminants
TAZ traffic analysis zone
TDS total dissolved solids
TNC ACE The Nature Conservancy Anaheim Conservation Easement TSS total suspended sediment
UDS underground detention systems
USEPA United States Environmental Protection Agency
USFWS United States Fish and Wildlife Service
UWMP Urban Water Management Plan
v/c volume-to-capacity
UST underground storage tank
VHFHSZ Very High Fire Hazard Severity Zone
VMT vehicle miles traveled
VOC volatile organic compounds
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WB westbound
WDR waste discharge requirement
WQMP Water Quality Management Plan
WSA Water Supply Assessment
WV Water Verification

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1.0 INTRODUCTION

1.1 PURPOSE AND SCOPE
On August 23, 2005, the City of Anaheim (City) Council certified Environmental Impact Report (EIR) No. 331 (referred to as the “Certified EIR” or “EIR No. 331” in this Addendum) in conjunction with its adoption of an amendment to the Mountain Park Specific Plan (MPSP), initially adopted by the City in 1991. EIR No. 331 addressed the City’s General Plan Update (GPA No. 2004-00419), which amended the land uses in the approximately 3,001-acre area comprising the MPSP (Specific Plan Area).

Changes to the MPSP analyzed within EIR No. 331 included decreasing the intensity of development from 7,966 residential units to 2,500 units; eliminating proposed commercial and mineral extraction uses, four school sites, and a City maintenance yard; and reducing the number of park sites. As part of the General Plan Update, the City Council also updated the Zoning Code, terminated an existing Development Agreement with the Irvine Company, and entered into a new Development Agreement with the Irvine Company. This document refers to the MPSP, as last amended, as the “Approved Project.”
EIR No. 331 serves as the programmatic environmental document for which future projects may tier off. This Addendum to EIR No. 331 has been prepared to evaluate the environmental impacts of the proposed amendments to the MPSP, Zoning Code, and General Plan Land Use Element, including changes to conditionally permitted land uses within Development Area (DA) 5 of the MPSP as detailed in the Project Description found in Chapter 2.0 (Proposed Project).

Under Section 15162 of the State California Environmental Quality Act (CEQA) Guidelines (State CEQA Guidelines), a subsequent EIR is not required for the proposed changes unless the City determines on the basis of substantial evidence that one or more of the following conditions are met:

1. Substantial changes are proposed in the project which will require major revisions of the previous EIR or Negative Declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects;

2. Substantial changes occur with respect to the circumstances under which the project is undertaken which will require major revisions of the previous EIR or Negative Declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects; or

3. New information of substantial importance, which was not known and could not have been known with the exercise of reasonable diligence at the time the previous EIR was certified as complete or the Negative Declaration was adopted, shows any of the following:

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a. The project will have one or more significant effects not discussed in the previous EIR; b. Significant effects previously examined will be substantially more severe than shown in the previous EIR;
c. Mitigation measures or alternatives previously found not to be feasible would in fact be feasible, and would substantially reduce one or more significant effects of the project, but the project proponents decline to adopt the mitigation measure or alternative; or d. Mitigation measures or alternatives which are considerably different from those analyzed in the previous EIR would substantially reduce one or more significant effects on the environment, but the project proponents decline to adopt the mitigation measure or alternative.

Section 15164 of the State CEQA Guidelines states that an Addendum to an EIR shall be prepared “if some changes or additions are necessary, but none of the conditions described in Section 15162 calling for preparation of a subsequent EIR have occurred.” Thus, if none of the above conditions are met, the City may not require preparation of a subsequent or supplemental EIR. Rather, the City can decide that no further environmental documentation is necessary or can require that an Addendum be prepared.

This Addendum reviews changes to the Approved Project and to existing conditions that have occurred since EIR No. 331 was approved and compares environmental effects of the Proposed Project with those analyzed and previously disclosed under the Approved Project. This Addendum also considers new information of substantial importance that was not known and could not have been known with exercise of reasonable diligence at the time EIR No. 331 was certified and evaluates whether there are new or more severe significant environmental effects associated with changes in circumstances under which project development is being undertaken. It further examines whether, as a result of any changes or any new information, a subsequent or supplemental EIR may be required. This examination includes an analysis of provisions of Public Resources Code (PRC) Section 21166 and Section 15162 of the State CEQA Guidelines and their applicability to the project.

On August 23, 2005, a Final EIR (MPSP Amendment Final EIR No. 331 [State Clearinghouse (SCH) No. 2004071098]) was certified by the Anaheim City Council along with the adoption of a Mitigation Monitoring and Reporting Program (MMRP). In addition, a Statement of Findings of Fact for EIR No. 331 noted significant unavoidable adverse impacts related to aesthetics, air quality, and traffic and circulation. Therefore, a Statement of Overriding Considerations was also adopted.

Pursuant to the provisions of CEQA and the State CEQA Guidelines, the City is the Lead Agency charged with the responsibility of deciding whether to approve the Proposed Project, in consideration of the potential environmental effects that could result from project implementation compared to the environmental effects previously analyzed for the Approved Project.

The City’s review of the Proposed Project is limited to examining environmental effects associated with differences between the Proposed Project and the Approved Project. Pursuant to CEQA and the State CEQA Guidelines, the City has prepared this Addendum to EIR No. 331 to provide decision- 1-3
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makers with a factual basis for evaluating the specific environmental impacts associated with the Proposed Project and to determine whether there are changes in circumstances or new information of substantial importance that would require preparation of a subsequent or supplemental EIR.

EIR No. 331 remains valid and constitutes the certified CEQA documentation for future planning actions associated with implementation of the Mountain Park Specific Plan. As such, EIR No. 331, along with this Addendum, will be used to determine whether the Proposed Project falls within the scope of the Approved Project as analyzed in EIR No. 331.

Based upon review of the facts as presented in the analysis contained in this document, the City finds that an Addendum to the previous Certified EIR is the appropriate documentation to comply with CEQA. The rationale and the facts for this finding are provided in the body of this Addendum.

1.2 EVALUATION OF ENVIRONMENTAL IMPACTS

1.2.1 Approved Project

1.2.1.1 EIR Process for EIR No. 331
Consistent with Section 15063 of the State CEQA Guidelines, City staff determined that a Program EIR was the appropriate environmental document to be prepared for the Approved Project (refer to Section 1.2.1.2, Type of EIR, below, for more information regarding the decision to prepare a Program EIR). The State Clearinghouse (SCH) issued a project number for EIR No. 331 (SCH No. 2004071098). In accordance with the State CEQA Guidelines, Section 15082, the Notice of Preparation (NOP) was circulated in July 2004 to responsible agencies and individuals for a period of 30 days, during which time written comments were solicited pertaining to environmental issues and topics that the EIR should evaluate.

The Draft EIR was circulated for public review for the required 45‐day public review period, from April 4, 2005, to May 19, 2005. The City Council certified the Final EIR in on August 23, 2005, and approved the project.

1.2.1.2 Type of EIR (2005 Certified EIR No. 331)
EIR No. 331 serves as a Program EIR pursuant to State CEQA Guidelines, Section 15168. The use of a Program EIR provides an occasion for a more exhaustive consideration of effects and alternatives than otherwise would be practical under a Project EIR. However, subsequent activities occurring as a result of program/project approval and certification of a Program EIR must be further evaluated in light of the Program EIR to determine whether or not an additional environmental document must be prepared. If an agency finds that no new effects could occur and that no new mitigation would be required, then the agency can determine that subsequent activities are covered under the Program EIR and no further environmental documentation would be required. Conversely, an agency may determine that future projects could require the preparation of a new Initial Study, a Mitigated Negative Declaration (MND), or a new EIR. If new environmental documentation is required, a Program EIR can be used to focus the scope of the subsequent environmental document (State CEQA Guidelines, Section 15168).

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EIR No. 331 identified the vision for residential development within DAs 1, 2, 3, 4, 5, and 7, as well as other community facilities and amenities, including a fire station, interpretive center, school site, and store. The Approved Project included an amendment to the City of Anaheim Zoning Code to incorporate the zoning standards for the site and an amendment to the City of Anaheim General Plan to remove the Very High Fire Hazard Severity Zone (VHFHSZ) designation from the MPSP, as illustrated in Exhibit S-5 (Fire Protection Areas).

As mentioned above, EIR No. 331 involved a comprehensive update to Title 18 of the Anaheim Municipal Code, which contains the City’s zoning regulations. Title 18, specifically Chapter 18.112, was amended to implement the updated zoning standards for development within the MPSP enabled under the Proposed Project.

Subsequent activities associated with implementation of the Approved Project that would require approval of a discretionary action would require a project‐specific analysis of environmental impacts associated with implementing maps, plans, permits, and approvals. When reviewing future projects, the City would utilize the tiering provisions in CEQA to determine whether, in the light of project- specific circumstances, EIR No. 331 prepared for the Approved Project would still provide an adequate description of the broad effects of future projects as they are considered.

1.2.2 Proposed Project and Addendum
This Addendum compares anticipated environmental effects of the Proposed Project with those disclosed in EIR No. 331 to review whether any conditions set forth in Section 15162 of the State CEQA Guidelines requiring preparation of a subsequent or supplemental EIR are met. The description of the Proposed Project contained in Section 2.3, in Chapter 2.0, Project Description, below, establishes the basis for analyzing the Proposed Project’s potential environmental impacts compared to the Approved Project. Potential environmental effects of the Proposed Project are addressed for each of the following areas in the order that they appeared in EIR No. 331:
• Land Use and Planning
• Landform and Aesthetics
• Geology and Soils
• Hydrology
• Water Quality
• Biological Resources
• Traffic and Circulation
• Air Quality
• Noise
• Hazards and Hazardous Materials
• Population and Housing
• Public Services and Utilities
• Recreation
• Cultural Resources

The City had determined in the Notice of Preparation/Initial Study prepared for the Approved Project that the following issues would have no impacts and would not be evaluated in EIR No. 331:
agricultural resources and mineral resources. The Proposed Project does not necessitate a change in these determinations, as the existing site conditions and nature of the project have not substantially changed from those identified for EIR No. 331. Although no land use and planning impacts were identified, consistency with applicable land use policies was still evaluated in EIR No. 331. Therefore, environmental analysis provided in EIR No. 331 remains relevant and applicable to the Proposed Project for the areas unaffected by changes for these topic areas. A brief description of these topics areas is provided in Chapter 3.0 of this Addendum, below. 1-5
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Environmental topic areas that were evaluated in detail in EIR No. 331 and found to have no impacts, less than significant impacts, or less than significant impacts with mitigation incorporated include: land use and planning, geology and soils, hydrology, water quality, biological resources, noise, hazards and hazardous materials, population and housing, public services and utilities, recreation, and cultural resources. As previously discussed, environmental topic areas found to have significant and unavoidable impacts include landform and aesthetics, traffic and circulation, and air quality. All of these topic areas, as analyzed in detail in EIR No. 331, are analyzed in detail in Sections

3.1 through 3.14, below.

1.3 FINDINGS OF THIS ADDENDUM
The City of Anaheim is the Lead Agency for the Proposed Project. The City has determined that analyses of project environmental effects are best provided through the use of an Addendum and that none of the conditions set forth in PRC Section 21166, Section 15162 or Section 15163 of the State CEQA Guidelines requiring preparation of a subsequent or supplemental EIR have been met.

1. There are no substantial changes to the project that would require major revisions of the Certified EIR due to new significant environmental effects or a substantial increase in severity of impacts identified in the Certified EIR;

2. Substantial changes have not occurred in the circumstances under which the project is being undertaken that will require major revisions to the Certified EIR to disclose new significant environmental effects or that would result in a substantial increase in severity of impacts identified in the Certified EIR; and

3. There is no new information of substantial importance that was not known at the time the Certified EIR was certified, indicating any of the following:
a. The project will have one or more new significant effects not discussed in the Certified EIR; b. There are impacts determined to be significant in the Certified EIR that would be substantially more severe;
c. Mitigation measures or alternatives previously found not to be feasible would in fact be feasible and would substantially reduce one or more significant effects of the project, but the project proponents decline to adopt the mitigation measure or alternative; or d. Mitigation measures or alternatives which are considerably different from those analyzed in the previous EIR would substantially reduce one or more significant effects on the environment, but the project proponents decline to adopt the mitigation measure or alternative.

The complete evaluation of potential environmental effects of the project, including rationale and facts supporting the City’s findings, is contained in Chapter 3.0 of this Addendum.

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1.4 FORMAT OF ADDENDUM
This Addendum has been organized into three chapters, as described in the sections below.

1.4.1 Chapter 1.0: Introduction
Chapter 1.0 includes a description of the purpose and scope of the Addendum, previous environmental documentation, project approvals, findings of the Addendum, and existing documents to be incorporated by reference.

1.4.2 Chapter 2.0: Project Description
Chapter 2.0 describes the MPSP Area, the necessary City discretionary actions to implement the Proposed Project, and an overview of the Proposed Project.

1.4.3 Chapter 3.0: Comparative Evaluation of Environmental Impacts Chapter 3.0 contains the environmental analyses of the Proposed Project’s impacts compared to the impacts of the Approved Project analyzed in EIR No. 331. This comparative analysis has been undertaken pursuant to the provisions of CEQA to provide the City of Anaheim decision-makers with a factual basis for determining whether the Proposed Project, changes in circumstances, or new information since EIR No. 330 and SEIR No. 346 were certified require additional environmental review or preparation of a subsequent or supplemental EIR. Chapter 3.0 also contains findings for each environmental topic to determine whether conditions set forth in PRC Section 21166 or Section 15162 of the State CEQA Guidelines requiring preparation of a subsequent or supplemental EIR have been met.

1.5 EXISTING DOCUMENTS TO BE INCORPORATED BY REFERENCE
As permitted in Section 15150 of the State CEQA Guidelines, this Addendum references several technical studies, analyses, and reports. Information from the documents that have been incorporated by reference has been briefly summarized in the appropriate section(s) of this Addendum. Documents incorporated by reference are available for review at the City of Anaheim Planning Division, at 200 South Anaheim Boulevard, Suite 162, Anaheim, CA 92805. Please contact Jose Barriga, Associate Planner, at (714) 765-5380 or at [email protected] for additional information.

Documents incorporated by reference include, but are not limited to:
• City of Anaheim; Certified Final Environmental Impact Report No. 331, July 2005; • City of Anaheim; Mountain Park Specific Plan, as amended; • City of Anaheim; General Plan, as amended; and
• City of Anaheim Municipal Code.
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1.6 CONTACT PERSONS
The Lead Agency for the Addendum for the Proposed Project is the City of Anaheim. Questions regarding preparation of this Addendum, its assumptions, or its conclusions should be referred to the following:

Jose Barriga, Associate Planner
City of Anaheim
Planning & Building Department
Planning Services Division
200 South Anaheim Boulevard, Suite 162
Anaheim, CA 92805
Phone: (714) 765-5380
Email: [email protected]

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2.0 PROJECT DESCRIPTION

2.1 BACKGROUND
The Orange County Cemetery District (OCCD) is proposing to construct a public cemetery on 283 acres of property within DA 5 (project site) of the MPSP Area. A State veterans cemetery is also being considered within a portion of the 283-acre project site in a collaborative effort among the California Department of Veterans Affairs (CalVet), the County of Orange (County), and the OCCD.

To facilitate this proposed development, amendments to the City’s General Plan Land Use Element, Zoning Code, and MPSP are proposed. Specifically, Table LU-4, General Plan Density Provisions for Specific Areas of the City, of the General Plan Land Use Element would be amended to include a note explaining the addition of cemeteries as a conditionally permitted use within DA 5. No other text or figure revisions would occur. Similarly, proposed amendments to the MPSP, as codified in Chapter 18.112 of the Anaheim Municipal Code, would add cemeteries as a conditionally permitted use within DA 5 of the Specific Plan Area and include other minor amendments to establish consistency with this addition throughout the document.

2.2 APPROVED PROJECT

2.2.1 City of Anaheim and Setting
Anaheim is located in the northern portion of Orange County, California. Anaheim and its sphere of influence include approximately 50 square miles within Orange County. Anaheim is bordered on the west by Buena Park, Cypress, and Stanton; on the east by unincorporated Orange County; on the south by Orange, Villa Park, and Garden Grove; and on the north by Fullerton, Placentia, and Yorba Linda.

Regional access to Anaheim is provided by State Route (SR-) 91, which traverses the northern portion of the city from east to west; SR-57, which traverses the center of the city from north to south; and Interstate 5, which traverses the western portion of the city diagonally from north to south. In addition, the northern portions of SR-241 and SR-55, which connect to SR-91, run within Anaheim.

2.2.2 Mountain Park Specific Plan and Setting
Specific plans are customized regulatory documents that provide more focused guidance and regulation for identified areas. The City has 11 specific plans in effect, which each including land use, circulation, and infrastructure plans, as well as zoning requirements and design guidelines.

The MPSP, which was initially approved by the City Council in 1991, encompasses approximately 3,001 acres of land and is situated mostly within City boundaries, while its southernmost and easternmost portions are located within unincorporated Orange County. All unincorporated portions of the MPSP fall within the City’s sphere of influence. As shown on Figure 2-1, Regional and Project Location, the area encompassed by the MPSP (the “Specific Plan Area”) is located generally in Gypsum Canyon, south of SR-91, and bisected into two segments, eastern and western, by SR-241. Approximately 22.8 acres of off-site project features are also associated with the MPSP.

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SOURCE: USGS 7.5' Quad - Black Star Canyon (1988), Prado Dam (1981); CA I:\OCC1901\GIS\Pro\Mountain Park Memorial Park\Mountain Park Memorial Park.aprx (12/19/2023) FIGURE 2-1
Gypsum Canyon Cemetery Project
Regional and Project LocaƟon
0 1000 2000
FEET
Project Site
City Boundary
Mountain Park Specific Plan Boundary
San Bernardino
County
Los Angeles
County
Riverside
County
Orange
County
••••142
••••261
••••133
••••22
••••39
••••55
••••241
••••71
••••60
••••57
• •• •91
••••••210
••••••405
••••••5
••••••15
••••••10
Project
LocaƟon
Project Vicinity
SR 91
SR 241

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The Specific Plan Area is bound on the west by The Summit of Anaheim Hills Specific Plan Community (residential) and the Sycamore Canyon Specific Plan Community (residential), on the south by unincorporated Orange County (open space), on the east by the Coal Canyon Biological Corridors (open space), and to the north by SR-91. Further north of the Specific Plan Area beyond SR-91 are Featherly Regional Park and residential communities within Yorba Linda.

Access to the Specific Plan Area is provided from Gypsum Canyon Road via Santa Ana Canyon Road and the Gypsum Canyon Road interchange with SR-91. The Specific Plan Area has not been developed with an internal circulation system aside from various unimproved dirt roads that were used for previous on-site operations and emergency access.

The Specific Plan Area is generally undeveloped in its current condition and is characterized by steep canyons and uneven topography as well as scrub and chaparral vegetation.

The MPSP, as amended, allows for the development of up to 2,500 dwelling units across seven unique DAs (DAs 1–7). Although the MPSP includes provisions that would enable future development within the Specific Plan Area, it also provides for the preservation of open space/natural habitat areas in DAs 8–11A. Visual representation of each DA within the Specific Plan Area is provided on Figure 2-2, Mountain Park Specific Plan Development Areas. The project site is located in DA 5.

2.2.3 Approved Project Characteristics
The Approved Project is the existing MPSP, as last amended in 2005. Under the Approved Project, the MPSP was planned to include 2,163 acres of open space and trails in addition to residential neighborhoods, a vehicular circulation system, and public facilities, including parks and a school.

Specifically, the MPSP allowed for the development of up to 2,500 dwelling units across DAs 1–7, with the exception of DA 6. DA 6 was instead planned for Institutional uses. The breakdown of residential units across each DA is provided in Table 2.A, below.

Table 2.A: Permitted Residential Development Under Approved Project DA DA 1 DA 2 DA 3 DA 4 DA 5 DA 7 Total
Maximum Units Permitted
(Single-Family Attached)
- - - - 825 - 825
Maximum Units Permitted
(Single-Family Detached)
210 130 50 420 770 95 1,675
Maximum Permitted Units per
DA
210 130 50 420 1,595 95 2,500
Source: Mountain Park Specific Plan (2005).

DA = Development Area

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DA 5
DA 9
DA 10
DA 3
DA 4
DA 7
DA 11
DA 2
DA 1
DA 8
County of Orange
(City of Anaheim
Sphere-of-Influence)
SOURCE: Google Maps (2023)
I:\OCC1901\GIS\Pro\Mountain Park Memorial Park\Mountain Park Memorial Park.aprx (12/19/2023) FIGURE 2-2
Gypsum Canyon Cemetery Project
Mountain Park Specific Plan Development Areas
0 1000 2000
FEET
Project Site
Sphere-of-Influence
Water Line Extension
(City Right of Way)
Toll Road Interchange
Toll Road Overcrossing
Development Area 1
Development Area 2
Development Area 3
Development Area 4
Development Area 5
Development Area 7
Development Area 8
Development Area 9
Development Area 10
Development Area 11

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In addition to residential communities, each DA was also planned to include unique community- serving features and conceptual characteristics. The following list provides a brief overview of each DA’s character:
• DA 1 is the southernmost DA in the eastern portion of the project site and encompasses approximately 161 acres. As stated in Table 2.A, a maximum of 210 single-family detached dwelling units are allowed within DA 1, with lot sizes ranging from 5,000 to 7,000 square feet. A water reservoir is planned south of this DA.
• DA 2 is located between DAs 1 and 5 in the eastern portion of the project site and encompasses approximately 87 acres. A maximum of 130 single-family detached dwelling units are planned within this area, with lot sizes ranging from 4,000 to 5,000 square feet. • DA 3 encompasses approximately 88 acres and is located west of SR-241, north of the proposed extension of Weir Canyon Road. DA 3 is planned to include a maximum of 50 single-family detached dwelling units, with lot sizes ranging from 3,375 to 4,000 square feet. A 15-acre public community park and a minimum 10-acre school site with the capacity to serve 800 students are planned within this area.
• DA 4 is located in the northern portion of the site, adjacent to and east of SR-241 and encompasses approximately 163 acres. This DA is planned to include a maximum of 420 single- family detached dwelling units; access would be provided from Mountain Park Drive. The size of the lots is estimated to range from approximately 1,600 to 3,375 square feet. • DA 5 (approximately 291 acres) is located in the northeast portion of the project site and is planned to include a maximum of 770 single-family detached residential units and 825 single- family attached units with lot sizes ranging from 1,600 to 3,375 square feet. DA 5 was the site of a former surface mining and concrete production facility that ceased operations in 2004 and its surface is disturbed as a result. A private recreation center is planned southwest of the intersection of Gypsum Canyon Road/Mountain Park Drive, adjacent to Gypsum Creek.

Additionally, a water reservoir is planned in the eastern portion of this DA. Other planned development within DA 5 includes on-site roadways (including a roundabout at Gypsum Creek), utility infrastructure, manufactured slopes with landscaping, a trailhead/staging area, relocation of the Questar pipeline, and fuel modification areas.
• DA 6 is located at the northwest corner of Santa Ana Canyon Road and Gypsum Canyon Road and is the smallest of the DAs at approximately 5 acres. It is planned for institutional land uses, including a fire station, a trail staging area, and a convenience store of approximately 3,000 square feet.
• DA 7 is located southwest of the proposed Weir Canyon Road extension, west of SR-241, and is approximately 36 acres. This area is planned to include a maximum of 95 single-family detached dwelling units with a lot sizes ranging from 3,375 to 4,000 square feet. A water reservoir is proposed southeast of this DA.

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• DAs 8–11 encompass 2,163 acres and are set aside for the conservation of open space. No development is approved within these areas.

Other general features of the Approved Project include a landscape concept, a lighting concept, a Fire Master Plan, a grading concept, and biological resource protection features. As previously mentioned, the Approved Project also included the following project features over 22.8 acres of off- site land:
• Featherly Regional Park Drainage Improvements;
• Santa Ana Canyon Road Improvements;
• Gypsum Canyon Road/SR-91 Box Culvert Modification and Interchange Improvements; • Weir Canyon Road Improvements;
• Oak Canyon Drive Improvements;
• Sanitary Sewer Facility Connections; and
• Connections to Other Existing Off-site Utilities.

The Approved Project also included the construction of a planned interchange within the California Department of Transportation (Caltrans) right-of-way at SR-241/Weir Canyon Road and a Mountain Park Drive bridge overcrossing at SR-241 to provide access between DAs east and west of SR-241, which traverses the Specific Plan Area. The implementation of this project feature had already been evaluated in the MPSP (SP 90-4) Final EIR No. 302, but the Approved Project addressed the environmental impacts of these facilities. Other Caltrans-related features of the Approved Project include:
• SR-91 Remedial Fill Slopes
• Slope and Drainage Facility Modifications along SR-241

2.2.3.1 Project Design Features
EIR No. 331 included a discussion of a variety of project design features (PDFs) intended to avoid or minimize the potential environmental impacts of the Mountain Park Specific Plan in the project design stage.

Please refer to Table 2.B below for a list of the PDFs included in the Approved Project and an explanation of whether they would be applicable to the Proposed Project.

While many PDFs would not be specifically applicable to the Proposed Project, they would remain applicable to the Mountain Park Specific Plan as a whole. Because the PDFs are already incorporated into the Proposed Project’s design rather than as mitigation measures, these PDFs are not included in the MMRP and are not listed again under the Mitigation section of each topic. However, a brief discussion of applicable Project Design Features, if any, has been included in each topic’s Comparison of Impacts section.
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Table 2.B: EIR No. 331 Project Design Features
EIR No. 331 Project Design Feature Applicable to Proposed Project? Reasoning
Section 4.2, Aesthetics
PDF 2-1 The Mountain Park Specific Plan provides for replacement of oak, sycamore, willow and other native trees removed as a result of the project at a ratio of 20:1. In conjunction with the submittal of each tentative tract or parcel map, the property owner/developer shall submit a Detailed Landscape Plan to the Planning Department demonstrating that trees removed from the site will be replaced at a total ratio of 20:1. The 20:1 ratio is achieved using a combination of the Scenic Corridor Overlay tree list (Anaheim Zoning Code Chapter 18.18, Table 18-B), and the Mountain Park Specific Plan Tree List.

Yes The Proposed Project would involve the removal and
replacement of native trees; therefore, PDF 2-1 would
be applicable to the Proposed Project and would be
incorporated.

PDF 2-2 Prior to approval of the Park Master Plan for the sports park within Development Area 3, the property owner/developer shall submit lighting plans for review and approval by the Community Services Department that incorporate the
following design specifications:
• Sports field luminaries shall have mounting hardware
approved by the City, which cannot be inadvertently or
intentionally adjusted to cause spillover impacts. Instead, luminaries shall be professionally and permanently installed to direct light only onto the sports fields/courts and away from residential areas and other development.
• Luminaries lamps shall provide good color rendering and natural light qualities.
• Luminaries shall be restricted to no more than 500 lux (1 lumen per square meter) or 50 foot-candles per fixture. • Luminaries shall be placed at the appropriate, engineered height to reduce potential for glare and incidental spillover into adjacent properties and open space.
• Luminaries mountings, poles, and fixtures shall have matted finishes.

No This PDF pertains to Development Area 3 of the
Mountain Park Specific Plan. Because the Proposed
Project is limited to Development Area 5, PDF 2-2
would not be applicable to the Proposed Project and
would not be incorporated.

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Table 2.B: EIR No. 331 Project Design Features
EIR No. 331 Project Design Feature Applicable to Proposed Project? Reasoning
Section 4.4, Hydrology
PDF 4-1 The Mountain Park Specific Plan includes a Proposed Drainage System Plan (refer to Exhibit 3-9 of the Draft EIR included in Attachment A). Prior to approval of the first mass grading plan, the property owner/developer shall submit a Drainage and Runoff Management Plan (RMP) to the Department of Public Works for review and approval. The RMP shall demonstrate substantial conformance with the Proposed Drainage System included in the Mountain Park Specific Plan. The Drainage and Runoff Management Plan shall include the approximate timing for construction of the following drainage facilities:

Gypsum Canyon Road/SR-91 Box Culvert Modification: A
1,500 linear foot culvert modification will be constructed at the downstream end of Gypsum Canyon to address existing
deficiencies and accommodate proposed peak flows from the project site. The proposed storm drain improvement plan will extend the Gypsum Canyon Road/SR-91 box culvert inlet
structure approximately 1,500 feet upstream following the existing alignment of the Gypsum Creek. At this location, the proposed Gypsum Canyon Road will be designed to serve as an impoundment to retain storm water runoff up to
approximately 17 feet, which produces sufficient hydraulic head to convey 5,500 cfs through the culvert into Featherly Park. The elevation difference between the flow line of the culvert inlet and the top of the road is expected to be approximately 20 feet, allowing for a freeboard of three feet.

The extension of the culvert upstream, with the described design modifications to the inlet control, will prevent flooding onto Gypsum Canyon Road during large storm events. The
proposed modification of the culvert will improve the flood control design capacity of the culvert from a 10-year storm event to a 100-year storm event. A confirmation of the
structural integrity and design calculations of the existing Yes* This PDF requires the preparation and submittal of an RMP to the Department of Public Works for review
and approval prior to approval of the first mass
grading plan. While the Proposed Project would also
be required to prepare and submit an RMP to the
Department of Public Works, the specific drainage
facilities included in the Proposed Project’s RMP would differ from the Approved Project’s RMP, as detailed in
this PDF, as the development of the Proposed Project
would result in different post-constriction hydrologic
conditions and drainage patterns due to a propose
change in land use and impervious surface area.

However, the specific drainage facilities detailed in the Proposed Project’s RMP would accomplish the same
purpose of managing and treating stormwater flows
on the project site prior to discharge into the Santa
Ana River as the Approved Project’s RMP.
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Table 2.B: EIR No. 331 Project Design Features
EIR No. 331 Project Design Feature Applicable to Proposed Project? Reasoning
culvert structure shall be completed prior to final design of the new box culvert extension.
a. West Drainage Area Storm Drain Improvement: Minor
storm drain improvements to an existing undersized 36-inch reinforced concrete pipe (RCP) that collects off-site runoff from the undisturbed slopes draining into The Summit will be upsized to the capacity of a 54-inch RCP for proper
conveyance of the project flows into the existing 66-inch RCP.
b. SR-91/Gypsum Canyon Road Storm Drain Improvement: A
minor storm drain improvement will be implemented for
the 4-acre sub-area that used to drain into the existing culvert inlet but will not adequately drain after the culvert extension. The improvement will consist of a riser tower and a RCP (size to be determined) to collect the flows and
connect directly into the triple box culvert at the
approximate location of the existing culvert inlet.
c. Featherly Regional Park Channel Improvements: The
improvements to the box culvert outlet for energy
dissipation of flood flows will include a concrete apron followed by riprap to reduce velocities down to the 10 to 12 feet per second (fps) range. Riprap will also be added to the embankments beyond the concrete apron. To provide
additional stabilization of the channel downstream, flow velocities will be decreased to the range of 10 to 12 fps where turf-reinforced mesh blankets will be used, and
vegetation re-established along the channel bottom and
embankments. Turf-reinforced blankets (or equivalent
alternatives) will continue along the embankment up to a maximum of 340 feet beyond the riprap leading up to the existing road crossing. Prior to approval of a grading permit, the property owner/developer shall provide evidence to the Department of Public Works that the design and
construction of these improvements have been approved by

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the County of Orange Harbors, Beaches and Parks
Department.
d. Outlet Points to Natural Channels: Energy
dissipation/velocity reduction devices will be employed to ensure flows are released at nonerosive velocities. Such devices may include: riprap, geotextiles, granule filters, fills, grade control structures and/or check dams, or equivalent measures.
e. Vegetated floodwall for Community Center: As part of final design, a vegetated floodwall would be incorporated into the portion of the slope downstream of the community
center as necessary to satisfy flood control requirements.

PDF 4-2 The Mountain Park Specific Plan includes a Proposed Drainage System Plan (refer to Exhibit 3-9 of the Draft EIR included in Attachment A), which includes drainage improvements within Caltrans right-of-way. Prior to issuance of an and
Encroachment Permit, the property owner/developer shall submit a Drainage Plan to Caltrans for review and approval.

The Drainage Plan shall demonstrate substantial conformance with the Proposed Drainage System included in the Mountain Park Specific Plan. The Drainage Plan shall include the approximate timing for construction of the following drainage facilities:
• SR-241 Drainage Improvements: The improvements along
the SR-241 include the abandonment of the existing 72-inch corrugated steel pipe (CSP) in lieu of a 54-inch RCP, the modification of the 42- inch CSP outlet structure, the
modification of several smaller drainage systems draining into the proposed 54-inch RCP and 42-inch CSP and the
implementation of five Caltrans swales within the Caltrans right-of-way.

No This PDF pertains to drainage improvements within
Caltrans right-of way, specifically along SR-241. As the Proposed Project would not require nor result in
drainage improvement within any Caltrans rights-of-
way, this PDF would not be applicable to the Proposed
Project.

Section 4.5, Water Quality
PDF 5-1 In furtherance of the Orange County Drainage Area Management Plan/City of Anaheim Local Implementation Plan (DAMP/LIP) requirements, the Mountain Park Specific Plan Yes* This PDF requires compliance with the Orange County DAMP and City of Anaheim LIP through the
incorporation of water quality BMPs, including site
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EIR No. 331 Project Design Feature Applicable to Proposed Project? Reasoning
includes the following project design features that shall be incorporated into the final project Water Quality Management Plan (WQMP). These design features meet or exceed the
requirements of the DAMP/LIP. Prior to approval of each mass or rough grading plan, the property owner/developer shall submit the Final WQMP to the Department of Public Works incorporating the following measures:
• Site Design BMPs: The following site design BMPs are
practices designed to minimize runoff and the introduction of pollutants in storm water runoff.
o Minimize Impervious Area and Impervious Areas Directly Connected to Storm Drains
▪ Minimize impervious areas by incorporating
landscaped areas over substantial portions of the
project area consistent with the Development Plan
and Concept Landscape Plans. Single family residential
landscape areas shall be determined by zoning
development standards, including setbacks, lot
coverage, street parkway standards, and design
objectives;
▪ Minimize directly connected impervious area by
draining parking lots to landscaped areas or
bioretention facilities to promote filtration and
infiltration of storm water, if landscaping slopes are
less than 2 percent and the project is not adjacent to
steep slopes;
▪ Utilize vegetated areas, e.g., setbacks, swales, end
islands, and median strips, for biofiltration and
bioretention of nuisance and storm runoff flows from
parking lots and other impervious areas; and
▪ Design sidewalks to drain into landscaping and swales prior to discharging to the storm water conveyance
system.
design, source control, and treatment control BMPs, in
the Final WQMP. Although the Proposed Project
would prepare a Final WQMP that would incorporate
site design, source control, and treatment control
BMPs in compliance with the DAMP/LIP, the specific
BMPs may differ from those detailed in this PDF. Some
BMPs specified in this PDF may remain applicable to
the Proposed Project and be incorporated into the
Final WQMP, some measures that are specific to the
residential development proposed under the
Approved Project would not be applicable to the
Proposed Project. However, the specific BMPs detailed
in the Proposed Project’s Final WQMP would
accomplish the same purpose of managing and
treating stormwater flows on the project site prior to
discharge into the Santa Ana River, as the BMPs
detailed in this PDF.

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o Selection of Construction Materials and Design Practices ▪ Select building material for roof gutters and
downspouts that do not include copper or zinc; and
▪ Construct streets, sidewalks, and parking lot aisles to the minimum widths specified in the Anaheim
Municipal Code or adopted Specific Plan and in
compliance with the Development Plan and
regulations for the Americans with Disabilities Act and safety requirements for fire and emergency vehicle
access. Incorporate landscaped buffer areas between
sidewalks and streets in compliance with the
Development Plan and Anaheim Municipal Code.
o Conserve Natural Areas
▪ Preserve existing riparian areas along Gypsum Creek
and protect with buffer zones per the Development
Plan;
▪ Preserve 2,163 acres of open space within the project boundary outside of the development area, including
NCCP open space areas, open space devoted to
conservation easements, and other open space;
▪ Concentrate or cluster development on the least
environmentally sensitive portions of the project site
(e.g., the quarry site) while leaving the remaining land in a natural, undisturbed condition;
o Non-Structural Source Control BMPs
▪ N1 Education for property owners, tenants and
occupants – practical information materials shall be
provided to the first residents/occupants/tenants on
general housekeeping practices that contribute to the
protection of storm water quality. The Homeowner's
Association (HOA) shall have an ongoing educational
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EIR No. 331 Project Design Feature Applicable to Proposed Project? Reasoning
material distribution program. At a minimum, these
materials shall cover the following topics:
 The use of chemicals (including household type)
that should be limited to the property, and
avoidance of discharge of specified wastes via
hosing or other means to gutters, catch basins, and
storm drains.
 The proper importance of appropriate irrigation
techniques and proper handling/application of
material such as fertilizers, herbicides, pesticides,
cleaning solutions, paint products, automotive
products, and swimming pool chemicals, and
swimming pool drainage.
▪ Use natural drainage systems to the maximum extent
practicable or create drainages (e.g., vegetated
swales) that mimic natural conveyances and allow for
storm water infiltration as well as pollutant removal;
and
▪ Maximize canopy interception and water conservation
by preserving existing native trees and shrubs in
natural open space areas outside of the development
area, incorporating new trees into project design
pursuant to landscape and reforestation plan, and
including native or drought resistant plants in
development plant palettes.
o Protect Slopes and Channels
▪ Protect slopes: minimize erosion potential with
vegetative cover, route flows safely away from steep
and/or sensitive slopes, stabilize disturbed slopes; and ▪ Protect channels: control and treat flows in
landscaping and/or other controls prior to reaching
existing natural drainage systems, stabilize channel
crossings, ensure that increases in runoff velocity and

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frequency caused by the project do not erode the
channel, install energy dissipaters, such as riprap, at the outlets of storm drains or conveyances.
• Source Control BMPs: The following source control BMPs shall be implemented in order to minimize the amount of pollutants in dry weather (nuisance) flows and in storm water runoff from the project.
o The environmental and legal impacts of illegal dumping of harmful substances into storm drains and sewers.
o Alternative household products that are safer to the
environment.
o Household hazardous waste collection programs.
o Used oil-recycling programs.
o Proper procedures for spill prevention and clean up.
o Proper storage of materials that pose pollution risks to local waters.
o Carpooling programs and public transportation
alternatives to driving.

N2 Activity Restrictions (Conditions, Covenants, and
Restrictions) - Conditions, Covenants, and Restrictions (CC&Rs) shall be prepared as necessary and shall address surface water quality protection, or, alternatively, use restrictions shall be developed through lease terms.

N3 Common Area Landscape Management - ongoing
maintenance shall be consistent with City of Anaheim
Landscape Water Efficiency (Chapter 10.19 of the Anaheim Municipal Code), plus fertilizer and/or pesticide usage shall be consistent with County Management Guidelines for Use of Fertilizers {DAMP Section 5.5). See also, efficient
irrigation systems under structural controls.

N4 BMP Maintenance - Homeowners Associations·(HOAs)
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EIR No. 331 Project Design Feature Applicable to Proposed Project? Reasoning
structural BMPs {including treatment controls) located
within the HOA boundaries. These BMPs are outlined below.

N11 Common Area Litter Control - HOA shall conduct litter patrol; provide for covered trash receptacles, trashcans with lids, and emptying of trash receptacles in common areas; note trash disposal violations by tenants/homeowners or businesses and report the violations to the owner/HOA for investigation shall be conducted.

N14 Common Area Drainage Facility Inspection - Privately- owned drainage facilities shall be inspected each year and, if necessary, cleaned and maintained prior to the storm
season, no later than October 1st each year. Drainage
facilities include catch basins and inlets, catch basin inserts, water quality basins, detention basins, other treatment facilities, and open drainage channels.

N 15 Street Sweeping Private Streets and Parking Lots - Streets shall be, swept prior to the storm season in late summer/early fall, no later than October 1st of each year.

Parking lots at the private community center shall be swept weekly at a minimum, weather permitting.
o Structural Source Control BMPs
▪ Provide Storm Drain Stenciling and Signage - all storm drain inlets and catch basins, constructed or modified, within the project area shall be stenciled or labeled.

Signs, which prohibit illegal dumping, shall be posted
at public access points along channels and creeks
within the project area. Legibility of stencils and signs shall be maintained.
▪ Trash Area Design - trash areas shall be paved,
designed not to allow run-on, screened or walled to
prevent off-site transport of trash; and covered to
minimize direct precipitation. Common area litter

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control shall include a litter patrol, covered trash
receptacles, emptying of trash receptacles in a timely
fashion, and noting trash violations by
tenants/homeowners and reporting the violations to
the owner/HOA for investigation. Connection of trash
area drains to the municipal storm drain system shall
be prohibited.
▪ Efficient Irrigation - the timing and application
methods of irrigation water in common areas shall
minimize the runoff of excess irrigation water into the storm water conveyance system.
▪ Protect Slopes and Channels - Storm water BMPs shall
be included to decrease the potential for erosion of
slopes and/or channels, and may include appropriate
conveyance structures, landscaping, etc.
▪ Hillside Landscaping - Hillside areas that are disturbed by project development shall be landscaped with
deep-rooted, drought tolerant plant species selected
for erosion control.
▪ Fire Station - Catch basin inserts with hydrocarbon
absorption mats shall be provided for the fire station
and vehicle maintenance shall be performed indoors
and shall therefore not enter into the storm drain
system because indoor drains flow to the sanitary
sewer system.
• Treatment Control BMPs: The following treatment control BMPs are a part of the conceptual water quality treatment program included in the Mountain Park Specific Plan (refer to Exhibit 3-10). Prior to the issuance of grading permits, the property owner/developer shall include the following
features in the final WQMP submitted to the Department of Public Works for review and approval.
o Storm water runoff from the disturbance area shall be routed to nine water quality basins. Collectively, the
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EIR No. 331 Project Design Feature Applicable to Proposed Project? Reasoning
water quality basins shall treat runoff from
approximately 488 acres within the disturbance area. The water quality basins shall incorporate dry extended
detention to provide water quality treatment for storm
flows. Dry extended detention basins are designed with
outlets that detain the runoff volume from the water
quality design storm (e.g., the 85th percentile 24-hour event) for some minimum time (36 hours) to allow
particles and associated pollutants to settle out.
o The water quality basins shall incorporate wetland
vegetation along the low flow channel in the bottom of
the basin for the treatment of dry weather flows and
small storm events. These basins shall not contain
ponded or standing water for periods in excess of 48
hours.
o The park and school site shall have a water quality basin or BMP with equivalent treatment effectiveness with the sizing of the treatment based on the DAMP/LIP
requirements.
o Per the MS4 permit, the water quality basins within the proposed project shall be designed to contain a "water
quality pool" sized to meet the maximized storm water
capture volume for the area, from the formula
recommended in Urban Runoff Quality Management,
WEF Manual of Practice No. 23/ASCE Manual of Practice
No. 87 (1998). The water quality pool is designed to drain in 36 hours.
o Approximately 4.1 acres of roadway that does not drain to the basins shall be treated with filter strips (a type of biofilter) designed per the MS4 permit and DAMP/LIP
requirements treating a flow rate two times the 85th
percentile hourly rainfall as determined by historical
rainfall. The water tank located in Development Area 7
shall also be treated using a filter strip or a bioswale, designed per DAMP/LIP requirements.

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o Offsite roadway improvements shall be treated by BMPs providing treatment equivalent to that provided by
biofiltration (bioswales or filter strips) sized pursuant to the criteria in the MS4 permit.

Section 4.6, Biological Resources
PDF 6-1 Prior to approval of tentative tract or parcel maps, the project biologist shall submit written verification in the form of a note on the tentative tract or parcel maps, that the project development boundaries are consistent with the Open Space, Trail and Bikeway Plan identified in Exhibit 3-8 of the Draft EIR (included in Attachment A). The proposed project includes 2,163 acres of preserved open space: NCCP/HCP Reserve (940 acres), The Nature Conservancy Anaheim Conservation
Easement (TNC ACE) (913 acres) and 310 acres of additional open space throughout the project site not related to the NCCP/HCP Reserve or TNC ACE.

No Construction of the project site is limited to the
boundaries of the parcel conveyed to the County by
The Irvine Company. Access to the adjacent NCCP/HCP
reserve and other conservation lands is not allowed
during construction or operation of the cemetery
These conserved lands are open to the public only on
designated dates and times and public access to these
resources via the proposed project’s on-site roadways
would not be allowed.

Section 4.7, Traffic and Circulation
PDF 7-1 The Mountain Park Specific Plan includes a circulation system consisting of on-site roadways (refer to Exhibit 4.7-5 of the Draft EIR included in Attachment A). The tentative tract or parcel maps submitted for review and approval, will
incorporate preliminary street design features (i.e., cross- sections, alignment and grades) demonstrating consistency with the proposed circulation system. Prior to approval of each tentative tract or parcel map, the subdivision map shall be prepared consistent with the Mountain Park Specific Plan Circulation System Plan (Exhibit 4. 7-5 of the Draft EIR) to the satisfaction of the City Engineer. All street improvements within the subdivision map shall be completed prior to the final building and zoning inspection for units served by said improvement.

Yes* The Proposed Project would include circulation and street design features as part of the Proposed
Project’s development; therefore, PDF 7-1 would be
applicable to the Proposed Project and would be
incorporated where feasible to ensure consistency
with the MPSP proposed circulation system.

PDF 7-2 The Mountain Park Specific Plan includes a circulation system including the following off-site roadway improvements (refer to Exhibit 4.7-5 of the Draft EIR included in Attachment A) identified in the Mountain Park Specific Plan, the City of Yes* The Proposed Project includes only DA 5. The Gypsum Canyon Road and Santa Ana Canyon Road, La Palma
Avenue and State Route 91 are the key roadways that
were studied in the Traffic Impact Analysis for the
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EIR No. 331 Project Design Feature Applicable to Proposed Project? Reasoning
Anaheim General Plan and Orange County Master Plan of
Arterial Highways. The development area plans and tentative tract or parcel maps, submitted for review and approval, shall incorporate preliminary street design features (i.e., cross- sections, alignment and grades) demonstrating that the
proposed circulation system is consistent with that defined in the Mountain Park Specific Plan, the City of Anaheim General Plan and the Orange County Master Plan of Arterial Highways. • Gypsum Canyon Road - Improved from a two-lane undivided roadway to a four-lane divided roadway from the SR-91
westbound off-ramp to the proposed Santa Ana Canyon
Road realignment. A construction contract for
improvements to this portion of Gypsum Canyon Road shall be awarded prior to issuance of the first building permit in development areas east of SR-241. The improvements shall be substantially completed prior to the first final building and zoning inspection for the first phase of development for areas east of SR-241.
• Santa Ana Canyon Road - Realign and improve from a two- lane undivided roadway to a four-lane divided roadway
from SR-241 to Gypsum Canyon Road. A construction
contract for improvements to this portion of Santa Ana
Canyon Road shall be awarded prior to issuance of the first building permit in development areas east of SR-241. The improvements shall be substantially completed prior to the first final building and zoning inspection for the first phase of development for areas east of SR-241.
• Weir Canyon Road (Oak Canyon Drive to Blue Sky Way) – Restripe approximately 600-feet to transition from a six-lane roadway at Oak Canyon Drive to a four-lane roadway at Blue Sky Way prior to issuance of the first building permit for Development Areas 3 or 7, whichever occurs first.
• Weir Canyon Road (Blue Sky Way to SR-241) - Construct as a four-lane divided roadway from Blue Sky Way to SR-241
(includes elimination of the northbound left-turn lane at the Proposed Project. PDF 7-2 would be applicable where
feasible for the Proposed Project; however, some of
these other roadways listed in the PDF 7-2 pertain to
the other development areas in the Approved Project.

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Weir Canyon Road/Blue Sky Road intersection).

Improvements to this portion of Weir Canyon Road shall be completed prior to the first final building and zoning
inspection for Development Areas 3 or 7, whichever occurs first.
• Gypsum Canyon Road and SR-91 Westbound Ramp
intersection – Add second northbound through lane. A
construction contract for improvements to this portion of intersection shall be awarded prior to issuance of the first building permit for development areas east of SR-241. The improvements shall be substantially completed prior to the first final building and zoning inspection for the first phase of development for areas east of SR-241.
• Gypsum Canyon Road and SR-91 Eastbound Ramp
intersection - Add second northbound and southbound
through lanes. A construction contract for improvements to this portion of intersection shall be awarded prior to
issuance of the first building permit in development areas east of SR-241. The improvements shall be substantially completed prior to the first final building and zoning
inspection for the first phase of development areas for east of SR-241.
• Gypsum Canyon Road/Santa Ana Canyon Road intersection – Improve to provide two southbound through lanes and a southbound right-turn lane, two northbound through lanes and a northbound left-turn lane, and two eastbound left- turn lanes and an eastbound right-turn lane. A construction contract for improvements to this intersection shall be awarded prior to the issuance of the first building permit in development areas east of SR-241. The improvements shall be substantially completed prior to the first final building and zoning inspection for the first phase of development for areas east of SR-241.Oak Canyon Drive, east of Running
Springs Road - This portion of Oak Canyon Drive within City right-of-way will be abandoned by the City of Anaheim and 2-25
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EIR No. 331 Project Design Feature Applicable to Proposed Project? Reasoning
improved with a vehicle maintenance road and landscaping (see Exhibit 3-17). The maintenance road will be gated to the satisfaction of the City Engineer. Improvements
associated with this portion of Oak Canyon Drive within City right-of-way shall be substantially completed prior to
issuance of the first building permit in development areas west of SR-241.

PDF 7-3 The proposed project includes the construction of the SR- 241/Weir Canyon Road interchange with ramps to and from the south on SR-241 and construction of a bridge over SR-241 for Mountain Park Drive. Prior to completion of the Mountain Park Drive bridge over-crossing, the design for the construction of the SR-241/Weir Canyon Road interchange shall be awarded.

Construction of the SR-241/Weir Canyon Road interchange shall be completed prior to issuance of the 421st building permit on the east side of SR-241.

No The Proposed Project would be developed without
constructing Mountain Park Drive or extending Weir
Canyon Road, which are planned under the existing
MPSP and would pertain to the improvements
discussed in this PDF. The Traffic Impact Analysis (TIA) prepared for the Proposed Project indicates that the
Proposed Project would use Gypsum Canyon Road for
entry into the cemetery and that the General Plan
Buildout circulation network would have enough
capacity to serve the Proposed Project without the
construction of Mountain Park Drive and the extension
of Weir Canyon Road connection to Mountain Park
Drive. Therefore, as indicated in the TIA, the Proposed Project can be developed without the construction of
Mountain Park Drive and the extension of Weir
Canyon Road connection to Mountain Park Drive, and
would not create a new significant transportation
impact. This PDF would therefore not be applicable to
the Proposed Project, though it is possible to defer the extension of Weir Canyon Road and construction of
Mountain Park Drive to the future development of
other Mountain Park Specific Plan Development Areas.

Development Areas 3, 4, or 7 may require these
infrastructure improvements for access to planned
land uses. In such cases, PDF 7-3 may apply to these
future developments.

PDF 7-4 The proposed project includes the construction of a bridge over SR-241 for Mountain Park Drive. Prior to opening of No As mentioned above, the Proposed Project would be
developed without constructing Mountain Park Drive

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models for development areas east of SR-241, the Mountain Park Drive over-crossing construction shall be completed. or extending Weir Canyon Road, and would not create
a new significant transportation impact. Therefore, the Mountain Park Drive over-crossing would not be
necessary, and this PDF would not be applicable to the
Proposed Project. However, it is possible to defer the
extension of Weir Canyon Road and construction of
Mountain Park Drive to the future development of
other Mountain Park Specific Plan Development Areas,
as discussed above.

Section 4.9, Noise
PDF 9-1 The Mountain Park Specific Plan includes a conceptual grading plan. The conceptual grading plan includes berms in the following locations as shown on Exhibit 4.9-7 of the Draft EIR (included in Attachment A) that would reduce exterior noise levels in areas behind the berms to less than 65 CNEL. Prior to the approval of grading plans for development areas that require sound attenuation measures, the property
owner/developer shall submit grading plans to the Department of Public Works that demonstrate conformance with the
conceptual grading plan included in the Specific Plan, including the following:
• Ten to 40 foot high berms (above pad elevation) along SR- 241 in Development Area 4.
• Intermittent berms with heights 10 to 20 feet above pad elevations are also included along SR-91 in Development Area 5. Final berm design shall be shown on precise grade permits for specific builder projects.

No Traffic noise contours along SR-91, SR-241, and
Gypsum Canyon Road have the potential to exceed 70
dBA CNEL at the northernmost portions of DA 5, but it
is not expected that noise levels would exceed 75 dBA
CNEL where people would congregate within the
proposed cemetery facilities; therefore, no exterior
noise impacts would occur. As such, under the
Proposed Project, DA 5 would not require sound
attenuation measures, and therefore PDF 9-1 would
not be applicable to the Proposed Project and would
not be incorporated.

Section 4.10, Hazards and Hazardous Materials
PDF 10-1 Prior to the approval of the first tentative tract or parcel map, the property owner/developer shall enter into an agreement (Fire Protection Agreement) with the City of Anaheim. This agreement shall specify the property owner/developer's pro- rata fair share funding of capital improvements necessary to establish adequate fire protection facilities and equipment to Yes* The Proposed Project would be subject to a Fire
Protection Agreement with the City of Anaheim. An
administration building and a building associated with
the maintenance yard are proposed but would not
require additional fire protection services beyond
what the City currently provides for the area, as
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Table 2.B: EIR No. 331 Project Design Features
EIR No. 331 Project Design Feature Applicable to Proposed Project? Reasoning
service the proposed development. The property
owner/developer shall be responsible for paying fees or otherwise providing for the design, construction and furnishing of the fire station, including all fire apparatus necessary to fully equip the fire station per the City's specifications, to adequately serve the project. The property owner/developer shall also be responsible for dedicating a parcel for
development of the fire station in the location specified in Exhibit 3-4 of the Draft EIR (Development Plan) included in Attachment A. The fire station facility shall be constructed and operational prior to the issuance of the first building permit for any development area east of the SR-241, or as otherwise required by the Fire Department in the Fire Protection
Agreement.
development of the two buildings would not induce a
substantial population increase at the site. However,
the Proposed Project would not preclude development
of the planned fire station within DA 6. Construction of the fire station could be pursued in the future if
determined to be necessary. As such, PDF 10-1 would
be generally applicable to the Proposed Project and
would be incorporated to some extent.

PDF 10-2 Prior to submittal of the first tentative tract or parcel map or approval of the first grading plan, whichever occurs first, the property owner/developer shall submit a final Fire Master Plan (FMP) to the Fire Department for review and approval to ensure that fire protection for each Development Area is in accordance with Fire Department requirements. The final FMP shall be in substantial conformance with the preliminary FMP (Appendix R of the EIR). A copy of the approved Fire Master Plan shall be submitted to the following City Departments:

Planning, Police and Public Works.

Yes A Fire Master Plan was prepared for the Mountain
Park Specific Plan and was included in EIR No. 331. The Proposed Project would adhere to the Fire Master
Plan; therefore, PDF 10-2 would be applicable to the
Proposed Project and would be incorporated.

PDF 10-3 The Mountain Park Specific Plan includes conceptual fuel modification strategies. Prior to submittal of each tentative tract or parcel map or grading plan, whichever occurs first, fuel modification plans shall be submitted to the Fire Department for review and approval. The fuel modification plan shall be prepared in accordance with the provisions of the California Fire Code in effect at the time of submittal of the tentative tract or parcel map and be based upon the criteria set forth in the City of Anaheim Fire Department Fuel Modification Plan Guidelines. Prior to final Certificate of Occupancy for the first building in each Development Area fuel modification zones Yes* Because the Proposed Project would include the
development of two cemetery pads mostly composed
of irrigated lawns, the Proposed Project would serve
as a form of fuel modification. As such, the Proposed
Project contains fuel modification strategies and PDF
10-3 would remain applicable to the Proposed Project,
with the consideration that the Proposed Project
would not necessitate any Certificates of Occupancy.

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Table 2.B: EIR No. 331 Project Design Features
EIR No. 331 Project Design Feature Applicable to Proposed Project? Reasoning
shall be installed and inspected in substantial conformance with the approved plans to the satisfaction of the Fire Department.

Section 4.12, Public Services & Utilities
PDF 12-1 Prior to the approval of the first tentative tract or parcel map in Development Area 3, the map shall provide for a minimum 10- acre site reserved for the purchase and construction of an elementary school by the Orange Unified School District. The property owner/developer shall provide the Planning
Department with adequate proof that, in defining the
boundaries of the school site area, the property
owner/developer has complied with the provisions of the School Impact Mitigation Agreement (Appendix K of the Draft EIR) dated December 16, 2004 between Irvine Community
Development Company and the Orange Unified School District, or any subsequent agreement entered into between the
property owner/developer and the Orange Unified School
District.

No The Proposed Project does not include the
development of any residential units and would not
introduce any new school-age residents. Therefore,
while PDF 12-1 remains applicable to the MPSP, it
would not apply to the Proposed Project.

PDF 12-2 The Mountain Park Specific Plan includes a Water System Sub Area Master Plan (SAMP) (refer to Exhibit 3-11 of the Draft EIR included in Attachment A). Prior to approval of each tentative tract or parcel map, the property owner/developer shall submit water improvement plans prepared in conformance with the SAMP to the Public Utilities Department for review and
approval. The property owner/developer shall extend and construct the necessary water lines, pump stations, and reservoirs to serve development phases prior to connecting to the City's water system.

Yes The Proposed Project would be required to submit a
water improvement plan to the Public Utilities
Department for review and approval.

PDF 12-3 Irrigation systems within the Mountain Park Specific Plan area shall be controlled by automatic programmable irrigation controllers that utilize California Irrigation Management System (CIMS) Data to adjust water times and durations based on daily evapotranspiration) data. Prior to approval of landscape plans, the property owner/developer shall provide verification in the form of notes on the plans to the Public Yes The cemetery uses proposed under the Proposed
Project would consist largely of irrigated burial lawns that would require consistent irrigation. As such, PDF
12-3 would be applicable to the Proposed Project and
would be incorporated.
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Table 2.B: EIR No. 331 Project Design Features
EIR No. 331 Project Design Feature Applicable to Proposed Project? Reasoning
Utilities Department, Water Engineering Division, that the irrigation system is in conformance with the system identified in the SAMP. Public Utilities Department shall confirm that it is in conformance with the irrigation system identified in the SAMP. Community wide irrigation control shall be provided by a centralized irrigation control system designed to separately valve hydrozones based on plant water requirements,
exposure and terrain characteristics. All systems shall utilize matched precipitation rate nozzles and emitters for precise water application, adjustable low angle nozzles to reduce overspray, check valves to reduce low head drainage, and master valves to minimize water loss in the event of a line break or valve malfunction.

PDF 12-4 The Public Facilities Plan provided in the Mountain Park Specific Plan includes a Project Sewer Study that identifies the sanitary sewer facilities to be constructed with the project. The project sanitary sewer system is shown on Exhibit 3-12 of the Draft EIR included in Attachment A. The property
owner/developer shall conduct sewer monitoring at two
similar developments within the City to collect 14 days of data during dry weather conditions to verify the sewage generation rates. The property owner/developer shall then prepare a report based on the City approved sewer modeling software to verify that the sewer sizes conform to those proposed in the project sewer study. Prior to approval of the sewer
improvement plans, the property owner/developer shall
submit plans to the Department of Public Works,
demonstrating that the sanitary sewer system is in
conformance with the alternatives described in the Project Sewer Study included in the Mountain Park Specific Plan. The property owner/developer shall extend and construct the necessary facilities, including sanitary sewer lines to serve the project development phases.

No Because the Proposed Project would not connect to
local sewer lines for transport to a local treatment
plant, PDF 12-4 would not be applicable to the
Proposed Project and would not be incorporated.

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Table 2.B: EIR No. 331 Project Design Features
EIR No. 331 Project Design Feature Applicable to Proposed Project? Reasoning
PDF 12-5 The Public Facilities Plan provided in the Mountain Park Specific Plan identifies the electrical facilities to be constructed with the project. The project electric system is shown on Exhibit 3-13 of the Draft EIR included in Attachment A. Prior to approval of permits for improvement plans, the property owner/developer shall submit electric system plans to the Public Utilities Department, Electrical Engineering Division, demonstrating that the electric system is in conformance with the Public Facilities Plan included in the Mountain Park Specific Plan. The property owner/developer shall extend and construct the necessary facilities, including electric lines identified in Exhibit 3-13 of the Draft EIR (included in Attachment A), to serve development phases.

Yes The Proposed Project would involve an electrical
component; therefore, PDF 12-5 would be applicable
to the Proposed Project and would be incorporated.

PDF 12-6 The Public Facilities Plan provided in the Mountain Park Specific Plan identifies the natural gas facilities to be constructed with the project. The project natural gas system is shown on Exhibit 3-13 of the Draft EIR (included in Attachment A). Prior to approval of grading plans, final tract or parcel maps, or street improvement plans, whichever occurs first, the property owner/developer shall submit plans to the Public Utilities Department demonstrating that the natural gas system is in conformance with the Public Facilities Plan included in the Mountain Park Specific Plan. The property owner/developer shall extend and construct the necessary facilities, including natural gas lines to serve development phases.

No Because the Proposed Project is not expected to use
natural gas, PDF 12-6 and SC 1-12 would not apply to
the Proposed Project and would not be incorporated.

Section 4.13, Recreation
PDF 13-1 The Mountain Park Specific Plan includes the implementation of the public Gypsum Creek Regional Riding and Hiking Trail (refer to Exhibit 3-8 of the Draft EIR, Open Space, Trail and Bikeway Plan). Prior to approval of each tentative tract or parcel map that the trail is located within, the final alignment and final design for the Gypsum Creek Regional Riding and Hiking Trail shall be reviewed and approved by the Community Services Department and County of Orange Harbors, Beaches and Parks Department and shown on the tract or parcel map.

Yes* The Proposed Project includes a 24-foot-wide OC Parks Trailhead access road and an entry gate to be
constructed to provide continued access to the
existing OC Parks Gypsum Canyon Wilderness
trailhead. As such, PDF 13-1 would remain applicable
where feasible to ensure that these project elements
would not affect the existing OC Parks Gypsum Canyon
Wilderness trailhead (referred to in the Approved
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EIR No. 331 Project Design Feature Applicable to Proposed Project? Reasoning
An offer of dedication of trail easements to the County of Orange shall occur concurrently with recordation of final tract or parcel maps. Trail improvements shall be completed prior to final building and zoning inspections for the first building within said tracts.

Project as Gypsum Creek Regional Riding and Hiking
Trail).

PDF 13-2 The Mountain Park Specific Plan includes the implementation of Class II bikeways (on-street, striped) along the following roadways: proposed Mountain Park Drive; extension of Weir Canyon Road within the project site; Gypsum Canyon Road from off-site Featherly Regional Park to on-site Mountain Park Drive; and Santa Ana Canyon Road within the project site (refer to Exhibit 3-8 of the Draft EIR, Open Space, Trail and Bikeway Plan). Prior to approval of each tentative tract or parcel map that includes these bikeways; the property owner/developer shall include provisions for these bikeways on the tract or parcel map. The final alignment and final design of each bikeway shall be shown on the street improvement plans and shall be reviewed and approved by the Department of Public Works.

No The only roadway discussed in PDF 13-2 that would be relevant to the Proposed Project would be Gypsum
Canyon Road and Santa Ana Canyon Road, as the
Proposed Project includes development of Gypsum
Canyon Road as the entrance road serving the
proposed cemetery uses. Because the Proposed
Project does not include bicycle lanes along Gypsum
Canyon Road at this time, PDF 13-2 would not be
applicable to the Proposed Project. However, the
Proposed Project does not preclude future
development of these bicycle lanes along Gypsum
Canyon Road.

Source: Mountain Park Specific Plan Amendment, EIR No. 331 (2005). * = The overall purpose of the PDF would remain applicable to the Proposed Project, while the specifics detailed in the PDF may pertain to specific Approved Project characteristics and would not necessarily apply to the Proposed Project.

BMP = best management practice
CNEL = community noise equivalent level
DAMP = Drainage Area Management Plan
dBA = a-weighted decibels
LIP = Local Implementation Plan
MPSP = Mountain Park Specific Plan
PDF = Project Design Feature
RMP = Runoff Management Plan
SR- = State Route
TIA = Traffic Impact Analysis

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2.3 PROPOSED PROJECT
As discussed above, the OCCD is proposing to construct both a public cemetery and a State veterans cemetery (“Proposed Project”) on 283 acres of property within DA 5 (project site) of the Specific Plan Area.

The project site comprises 283.28 acres. Development of the Proposed Project would be accomplished through subdivision of the property into two parcels, as illustrated in Figure 2-3, Conceptual Site Plan. Parcel 1 would be 126.13 acres and Parcel 2 would be 157.15 acres. Within these two parcels, two cemetery areas would be constructed, a lower pad and an upper pad, separated by a keyway1 buttressed slope. The lower pad on Parcel 1 would be developed as a public cemetery to be owned/operated by the OCCD. The upper pad on Parcel 2 is currently being considered as a State veterans cemetery to be owned and operated by CalVet.

The project site would be developed in approximately 10- to 20-acre increments on an as-needed basis for the OCCD public cemetery or CalVet, if CalVet moves forward with constructing a State veterans cemetery. Initially, an overall site mass and rough grading operation may be conducted to balance site earthwork for the upper and lower pads and build the keyway buttress slope.

2.3.1 OCCD Cemetery
An approximately 80-acre developable pad would be developed for the OCCD cemetery within the project site that would provide up to approximately 50 acres of interment areas; an approximately 7,700-square-foot administration building; an approximately 30,150-square-foot maintenance yard and building; approximately 9,800 square feet of committal shelters; approximately 15 acres of roads, walkways, parking, hardscape, and plaza niche areas; and approximately 15 acres of landscaped area. Build-out of the OCCD cemetery would take place in phases as demand warrants and could include up to 150,000 interment spaces. The final number of interment spaces would be determined by OCCD during the final design of each phase.

The first phase of development for the public cemetery would include development of utility infrastructure, bridge crossings and vehicular site circulation, administrative buildings, a maintenance building/area, and first-phase interment areas. The remainder of the in-ground interment and aboveground committal structures and niche areas would be implemented as demand warrants. Up to 10 acres of the public cemetery may be set aside for use by local police, fire, and first responders and their spouses, and up to 10 percent of the developable acreage of the public cemetery would be set aside for Allied Veterans and Government Officials of the Korean and Vietnam Wars.

2.3.1.1 Architectural Design
The administration building, committal shelters, and maintenance building would all be one story and reflect cohesive Spanish Colonial architectural design, including light-colored stucco façades and brick-colored clay roof tiles, built with noncombustible materials. 1 A keyway refers to a groove or recess that is intentionally created to enhance the connection point between both sides of a slope.
12/15/2023 OCCD PUBLIC CEME

OCCD CEMETERY OCCD CEMETERY

ADMINISTRATION BUILDINGADMINISTRATION BUILDING

KEYWAY BUTTRESS SLOPEKEYWAY BUTTRESS SLOPE

SECONDARY ACCESS ROADSECONDARY ACCESS ROAD
APPROXIMATELY 80 ACRE APPROXIMATEL Y 80 ACRE

OCCD DEVELOPABLE PADOCCD DEVELOPABLE PAD

FUTURE CALVET FUTURE CALVET

CEMETERY PADCEMETERY PAD

OCCD PUBLIC OCCD PUBLIC

CEMETERY CEMETERY

APPROXIMATELY APPROXIMATEL Y
100 ACRE VETERANS 100 ACRE VETERANS

DEVELOPABLE PADDEVELOPABLE PAD
91 EAST FREEW
AY
91 EAST FREEWAY
TOTAL SITE ACREAGE: 283 ACRESTOTAL SITE A
PLPL
PLPL

PLPL PLPL
PLPL

OCCD CEMETERY MAINTENANCE OCCD CEMETERY MAINTENANCE

BUILDING AND YARDBUILDING AND Y ARD

FUTURE LOOP ROAD TO CAL FUTURE LOOP ROAD TO CAL

VET CEMETERY PADVET CEMETERY PAD

ENTRY AND EXIT BRIDGES WITH ENTRY AND EXIT BRIDGES WITH

ONE LANE TRAFFIC EACH DIRECTIONONE LANE TRAFFIC EACH DIRECTION

E SANTA ANA

E SANTA ANA CANYON ROAD

CANYON ROAD
GYPSUM
GYPSUM

CANYON ROAD

CANYON ROAD

ENTRY PLAZA / CONTROLLED ENTRY PLAZA / CONTROLLED

ACCESSACCESS

EXISTING OC PARKS OUTDOOR EXISTING OC PARKS OUTDOOR

EDUCATION AREAEDUCATION AREA

FUTURE INTERSECTION FUTURE INTERSECTION

IMPROVEMENTS / TRAFFIC SIGNAL IMPROVEMENTS / TRAFFIC SIGNAL

BASED ON FINAL PROJECT NEEDSBASED ON FINAL PROJECT NEEDS

OC PARKS ENTRYOC PARKS ENTRY

OCCD CEMETERY ENTRYOCCD CEMETERY ENTRY

EXTERIOR CEMETERY LOOP ROADEXTERIOR CEMETERY LOOP ROAD
PLPL
SOURCE: RJM Design Group
FEET
8004000
FIGURE 2-3
I:\OCC1901\G\Site_Plan.ai (12/15/2023)
LEGEND
Project Site
Conceptual Site Plan
Gypsum Canyon Cemetery Project

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2.3.1.2 Landscaping
Native and drought-tolerant trees and vegetation would be utilized in the landscape design and palette for the OCCD cemetery, in addition to warm-season Bermuda turf interment areas, in keeping with the natural open space character of the surrounding property to the east, south, and west of the project site. Special edge treatment adjacent to SR-91 would be incorporated into the landscape design given the area’s increased level of visibility from the roadway, which is designated as an Eligible State Scenic Highway according to the City’s General Plan Circulation Element.2 All landscaping would comply with Chapter 18.46 of the Anaheim Municipal Code regarding landscaping and water efficiency.

The Proposed Project would protect existing trees in place, where feasible. If necessary, a tree replacement survey would be conducted and an application to cut down, destroy, or remove specimen trees would be filed with the Planning & Building Department in accordance with Chapter

18.112.070 of the Anaheim Municipal Code.

2.3.1.3 Lighting
Aboveground lighting fixtures would be provided along the exterior entry road at the gated entry, the main entrance to the OCCD cemetery, and maintenance facility. Lighting fixtures would not be placed near Gypsum Creek to limit direct lighting onto the drainage. Lighting has been located to provide safety and security while minimizing impacts to Gypsum Creek. Fixtures would be fitted with appropriate shields to limit overspill onto the natural channel.

A 100-foot lighted flagpole is near the northwest corner of the project site. The flag would be illuminated from dusk to dawn with focused lighting fixtures.

2.3.1.4 Buttress Slope
Dividing the upper and lower pads would be an approximately 40-acre keyway buttressed slope. The slope would be designed to provide an undulating slope character that is compatible with the natural topography within the canyon. The slope would also be landscaped with native and drought- resistant plant materials to minimize the visual intrusion of the slope when viewed from off site. The slope would include terrace drains and benches to minimize erosion. The slope would incorporate a slope ratio of 2:1 and undulating horizontal radii to blend the slope into the natural terrain of the project site.

2.3.1.5 Circulation/Roadways
Primary access to the proposed cemetery would be from Santa Ana Canyon Road and Gypsum Canyon Road through a security-gated entry plaza. The improvements have been incorporated into the project design at the intersection of Gypsum Canyon Road/Santa Ana Canyon Road at the time the northbound leg is modified to permit through traffic:
2 City of Anaheim. 2004. City of Anaheim General Plan Circulation Element. May. Website:
https://www.anaheim.net/DocumentCenter/View/9520/D-0-Circulation-Element?bidId= (accessed April 3, 2024).

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• Southbound Gypsum Canyon Road
○ Retain retroreflect strip (consistent with Section 2A.21 of MUTCD) already mounted to sign support.
○ Install R3-18 sign below existing stop sign indicating no left or U-turns. • Eastbound Santa Ana Canyon Road
○ Retain retroreflect strip (consistent with Section 2A.21 of the MUTCD) already mounted to sign support.
○ Replace existing 30 by 30-inch stop sign to 36 by 36 inch stop sign (R1-1) and (for a temporary period of six months consistent with Section 2A.15 of the MUTCD) add two red flags above the stop sign for enhanced conspicuity.
○ Add R10-7 Do Not Block Intersection sign below the stop sign. ○ Place an additional R10-7 Do Not Block Intersection sign on east side of Gypsum Canyon Road directly opposite eastbound leg.
○ Add 30 by 30-inch warning sign W23-2 New Traffic Pattern Ahead 250 feet in advance of intersection on a temporary basis for six months (consistent with Section 2C.52 of the MUTCD) to alert drivers to the addition of north-south traffic.

The entry plaza would be located south of the existing Santa Ana Canyon Road/Gypsum Canyon Road intersection. From the entry plaza, the exterior entry or loop road would be divided into a 46- foot access road (one southbound lane with a median and two northbound lanes) that would utilize two bridges to cross over Gypsum Creek (one bridge for ingress and one bridge for egress from the cemetery) and join into one 36-foot access road that provides single-lane inbound and outbound access to both the OCCD cemetery and the future CalVet cemetery. The bridges would be 14 feet wide, 100- to 120-feet long steel bridges with a Corten finish. There would be two access points to the OCCD cemetery on the lower pad: (1) the primary cemetery entrance built during the first phase of construction, and (2) secondary access to the exterior loop road for additional site circulation.

An internal loop road system is proposed within the OCCD cemetery to provide access from the exterior entry road to interment areas, a committal shelter, niches, and an administrative building.

Similarly, an internal loop road system would be provided in the veterans cemetery and would connect to the external loop road.

2.3.1.6 Parking
The proposed OCCD cemetery (80 acres) on the lower pad would provide approximately 44 surface parking spaces within a parking lot located adjacent to the administrative building. In addition, parking for viewing and services of interments, niches, etc., would be provided within the internal roadways circulating throughout the cemetery. These roadways are designed as 32 feet wide, including two 12-foot travel lanes and an 8-foot single-sided parallel parking area. Based on Anaheim Standard Detail 470 (i.e., parallel parking stalls shall be a minimum of 8 feet by 22 feet), there would be approximately 361 parallel parking spaces located along the internal roadways.

Therefore, a total of approximately 405 parking spaces would be provided This design and operation 2-37
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is consistent with similar cemeteries and would accommodate the peak parking demand on site.

Required parking spaces would be confirmed based on the results of the parking demand study.

2.3.1.7 Open Space/Trail Access
At the entry plaza, a 24-foot-wide OC Parks trailhead access road and an entry gate would be constructed to provide continued access to the existing OC Parks Gypsum Canyon Interpretive Center and trailhead.

2.3.1.8 Domestic, Fire, and Irrigation Water/Sewer
Three separate on-site services for fire, domestic, and irrigation would be provided to both the upper and lower pads and would be conveyed within a single 20-inch water line point of service provided by Anaheim Public Utilities on Santa Ana Canyon Road. The three separate services would be connected at the project entry and located within the typical easement section of the exterior access road. The 20-inch main water line would connect to the existing 30-inch line located in Santa Ana Canyon Road, near Woodcreek Road. Submeters would be provided for the fire, domestic, and irrigation lines between the parcels/cemeteries. Two irrigation booster pump stations would be constructed on site to assist in conveying water on site. Alternatively, a groundwater well may be constructed on site to provide potable water and irrigation services to both cemeteries. The location and depth of the well is currently being evaluated. On-site water pipelines would be connected to the groundwater well within the property following approval by the State Water Resources Control Board (SWRCB). There currently are no reclaimed water lines in this portion of Anaheim, and all activities on site would use potable water or well water as an alternative.

A water tank reservoir maybe be required in the northeast corner of the project site to meet project demand for landscape irrigation and potable water at the administrative building, committal shelter, and maintenance facility on the lower pad and similar facilities on the upper pad. The proposed tank could be up to 75 feet in diameter and 40 feet high, providing a minimum of 672,000 gallons of storage capacity. The reservoir would be located at the 680-foot elevation (680-foot-zone reservoir) and designed in a manner that screens it from public view pursuant to community design guidelines specified in the City’s MPSP. The need for and sizing of any reservoir would be subject to additional analysis of water demand associated with maximum day irrigation, on-site buildings, and fire flow requirements.

On-site sewage would be collected via pipelines and conveyed to on-site holding tanks with the upper and lower pads. These holding tanks would be regularly monitored and cleaned out, as needed, with a vacuum truck.

2.3.1.9 Drainage/Storm Drain Features
The drainage system for the proposed OCCD cemetery has been designed to maintain existing drainage patterns in the proposed condition. Accordingly, all lots would be graded to allow runoff to drain toward a designated private street or area drain, leading to the proposed storm drain infrastructure and flowing to the south or southwest general direction. All on-site storm drain infrastructure (including, but not limited to, grate inlets, curb and gutters, and storm drain pipes) would be sized per City of Anaheim Drainage Manual and Orange County Hydrology Manual (OCHM) standards.

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On-site storm drain lines would collect on-site runoff and direct it to one of two underground detention systems (UDS). Each UDS is designed with a lining as well as outlet orifices that drain to the Gypsum Creek. The UDS would reduce runoff from the proposed development to lower than the existing runoff level. Finally, outflow from the site would be discharged into unlined Gypsum Creek as it is in the existing condition. A Saint Anthony Falls dissipator has been incorporated into the design to reduce the flow velocity and avoid erosion of the creek banks and channel. Two detention basins are also incorporated into the on-site storm drain system as described below in Section

2.3.1.10, Water Quality Features.

The on-site storm drain system is designed to prevent off-site low flows from entering the system.

Off-site flow from the southeast would be conveyed to the Gypsum Creek via a trapezoidal channel along the southern border while maintaining existing flow pattern as well as preventing off-site flow from comingling with on-site runoff.

2.3.1.10 Water Quality Features
Two aboveground and lined dry extended detention basins (DEDBs) for stormwater treatment benefits have been incorporated into the project design, with one located in each pad. These DEDBs would serve as the primary best management practice (BMP) addressing the quality of stormwater runoff from the Proposed Project. The DEDB is designed for biofiltration of design storm capture volume (DCV) from a 24-hour, 85th percentile storm event and discharge of the same volume over 48 to 72 hours. Peak flow rates for the post-development condition would be lower than those of the 110 percent of pre-development condition; therefore, peak flow mitigation would be achieved by the incorporation of DEDBs. During heavy storm events, an emergency spillway would allow overflow of the DEDBs. The DEDBs and associated Connector Pipe Screen would be regularly maintained.

Additional Non-Structural and Structural Source Control BMPs included as part of the Water Quality Management Plan (WQMP) for the Proposed Project include, but are not limited to:
• Apply and maintain storm drain system stenciling and signage; • Design trash enclosures to reduce pollutant introduction; • Implement activity restrictions, such as no dumping of oil or chemicals into inlets, no washing of vehicles on site, and no washing of the maintenance yard pavement; • Perform landscape maintenance and litter control on a monthly basis; • Implement cleaning of all structural and nonstructural BMPs on a monthly basis; • Conduct employee training on an annual basis;
• Inspect and clean out the common-area catch basin on a monthly basis; • Conduct street sweeping of private streets and parking lots on a monthly basis; • Sweep trash and storage areas on a weekly basis;
• Conduct routine maintenance of the irrigation system to identify leaks/overspray and adjust due to seasonal fluctuations;
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• Inspect the energy dissipator annually; and
• Use drought-tolerant/non-invasive plants species in landscaping to minimize water consumption and protect against slope erosion.

2.3.1.11 Electrical Facilities
Electricity would be provided to the project site via existing overhead facilities located at the Santa Ana Canyon Road/Gypsum Canyon Road intersection. Three existing overhead poles would be undergrounded within the project site, and two existing power poles off site would be undergrounded at the southwest corner of the Santa Ana Canyon Road/Gypsum Canyon Road intersection. Additionally, two existing power poles at the SR-91 on-ramp on Gypsum Canyon Road would be undergrounded by Caltrans and Southern California Edison (SCE) as part of their improvement project. All electrical transmission facilities entering the project off site would be provided in underground conduit to both the upper and lower pads within the exterior entry road cross section in a manner consistent with the City’s 2023 Wildfire Mitigation Plan. As such, the Wildfire Mitigation Plan requirements would be addressed as part of the electrical service plan and proposed line extension work.

2.3.1.12 Natural Gas
There is an existing Southern California Gas Company easement that crosses the project site from east to west. This easement would be protected in place under the Proposed Project.

2.3.1.13 Questar Fuel Pipeline Realignment
There is an existing Questar fuel pipeline and easement located on site. The pipeline is inactive and would be capped and removed. The easement would be realigned to provide for the on-site roadway to the upper pad. The OCCD is coordinating with Questar regarding this realignment of the easement and capping of any pipeline facilities located within the existing easement.

2.3.1.14 Operational Characteristics
Operations and maintenance of the proposed OCCD cemetery would consist of similar activities as those currently conducted at OCCD’s other cemeteries. Maintenance activities would include landscaping activities such as trimming/or planting of trees, shrubs, groundcover, or perennials, as needed; trimming around memorial markers and mowing curb borders and lawns; trash and debris removal; cleaning and repainting buildings and structures as needed; irrigation repair, cleaning, and repairing of storm drainage and water quality features (described above); and maintenance and cleaning of roads, parking lots, lighting, and fencing. On a designated day of the week, staff would remove flowers placed on the space. It is anticipated that up to 12 staff members would be employed at the proposed OCCD cemetery once it is fully operational.

Typical operational activities include preparation for the burial or interment of caskets or urns. This would include the removal of lawn, excavation and removal of soil, preparation of the lowering device for the casket into the vault and then lowering of the vault into the space. The crew would then replace and compact the soil and prepare the surface for grass sod and/or seed. Once the flat memorial marker is received, staff would prepare the space for the placement of the memorial markers. Placement in a niche, which is an aboveground receptacle for an urn, would involve the

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removal of the granite shutter and interior polypropylene cover, placement of the urn, and securing of the cover and shutter. Upon receipt, a niche plate or engraving of the stone would take place to mark the placement of the urn. The OCCD cemetery would operate Monday through Friday from 7:00 a.m. to 5:00 p.m. Visitation hours would be daily from 8:00 a.m. to 5:00 p.m. The cemetery office would be open 7:00 a.m. to 5:00 p.m., Monday through Friday, and closed on Saturdays, Sundays, and holidays. The number of burial services may fluctuate throughout the week; however, the number of burial services would not exceed four services per day from Monday to Friday between the hours of 8:30 a.m. and 1:30 p.m. In addition, each burial service would occur during a specific time slot and would not overlap with another burial service. Burial services on Saturdays, Sundays, or certain holidays (Martin Luther King Day, Lincoln’s Birthday, Presidents’ Day, or the day after Thanksgiving) would require advance approval of the cemetery manager. The number of services on Saturdays would be limited to three and conduction of services on Sunday would be avoided, unless determined essential. For the holidays listed above, the number of services would be limited to two. No burial services would be conducted on New Year’s Day, Memorial Day, Independence Day, Labor Day, Veterans Day, Thanksgiving Day, or Christmas Day.

2.3.2 CalVet Veterans Cemetery
An approximately 100-acre developable upper pad would be developed for the State veterans cemetery. CalVet would determine the ultimate design of the State veterans cemetery; however, the exterior loop roadway and utility infrastructure have been designed to accommodate future development of the State veterans cemetery. Accessed via the main entry roadway, the State veterans cemetery would include an administrative building (approximately 2,000 square feet), an assembly area, restrooms, a maintenance/operations building (approximately 3,000 square feet), and a committal structure (approximately 600 square feet) in addition to interment spaces.

Interment spaces would include in-ground burials, in-ground cremains, and columbaria niches. It is anticipated that the architectural design of the buildings and other features, landscaping, and lighting within the veterans cemetery would complement the public cemetery design. Build out of the State veterans cemetery would take place in phases as demand warrants and could include up to 200,000 interment spaces.

Potential operational activities would be similar to activities at the public cemetery, with operating hours being 8:00 a.m. to 5:00 p.m. every day of the year. Cemetery operations include the care of burial and interment sites, on-site structures, and grounds and burial events. It is estimated that the State veterans cemetery would employ approximately 20 employees. The number of burial services may fluctuate throughout the week; however, the number of burials would not exceed four services per day. In addition, each burial service would occur during a specific time slot and would not overlap with another burial service. There would potentially be activities held during holidays, such as Memorial Day and Veterans Day, and other special military events. Interments or events could include the performance of the three-volley salute using rifles. These events would be of short duration (i.e., seconds or minutes) and would be limited to the daytime hours of operation.

2.4 PROJECT OBJECTIVES
The Proposed Project would require minor amendments to the City’s General Plan Land Use Element, Municipal Code, and MPSP, which would be generally consistent with the goals and objectives established for the Approved Project. Further, the Proposed Project would not 2-41
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substantially interfere with the achievement of these objectives because the proposed changes would be isolated within just one of the seven DAs established by the MPSP. Under the Approved Project, the City established the following intended project objectives for the MPSP Amendment and General Plan Amendment in 2005:
• Implement the goals and policies of the City of Anaheim General Plan. The objective is to ensure that development of the site is accomplished consistent with applicable goals and objectives of the City of Anaheim as set forth in the City’s recently updated General Plan; • Further regional transportation and air quality goals by creating housing near concentrated employment centers and major transportation corridors. The Proposed Project would provide various housing opportunities and would support commercial and public facilities in proximity to existing employment areas;
• Provide a broad mix of housing opportunities. The Proposed Project provides a range of single- family attached and single-family detached residential units on lots ranging from 1,600 to over 7,000 square feet;
• Develop a land use plan that responds to the site characteristics, including topography, biological resources, and visually significant ridgelines. The Proposed Project would utilize canyon bottoms and adjacent areas for development and would preserve important ridgelines and high canyon walls;
• Provide regional open space/habitat preservation areas. The Proposed Project would confirm the preservation of 2,163 acres of contiguous natural open space (72 percent of the project site);
• Maintain Consistency with the Implementation Agreement for the Central Coastal NCCP/HCP.

The NCCP/HCP Reserve is discussed in Section 3.6, Biological Resources. Following approval of the NCCP/HCP, the participating agencies (including the City of Anaheim) and participating landowners (including the Irvine Company), United States Fish and Wildlife Service (USFWS), California Department of Fish and Wildlife (CDFW), and the County of Orange, signed an Implementation Agreement (IA). The IA sets forth the implementation requirements for the NCCP/HCP, including requirements related to dedication, creation, and management of the Reserve, interim management of the Reserve, funding for Reserve management, and procedures and minimization measures related to development impacts to and “take” of Identified Species and modification of habitat in those areas designated for development under the NCCP/HCP;
• Provide new homes for sale to address Orange County’s housing shortage. Orange County, like southern California generally, has seen a dramatic increase in the demand for new housing. The Proposed Project would provide a supply of 2,500 new homes for purchase to assist in alleviating this important public need; and
• Implement components of the Orange County Master Plan of Arterial Highways (MPAH) within and in the vicinity of the project site. The Proposed Project involves improvements to

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Weir Canyon Road and an extension of the roadway to its ultimate terminus at SR-241, consistent with the MPAH. The Proposed Project also involves improvements to Santa Ana Canyon Road consistent with the MPAH. The SR-241/Weir Canyon Road interchange, which is assumed in the MPAH, would also be implemented with the Proposed Project.

Furthermore, the following project objectives have been identified for the Proposed Project:
• Provide an affordable public cemetery and veterans cemetery to the citizens of Anaheim and Orange County;
• Address an identified need for full-casket interments, since at the current rate of sale, full-casket interments may be exhausted at El Toro Memorial Park by 2025/2026; and • Provide veterans who reside in Anaheim and Orange County with a convenient and local option as an alternative to Riverside National Cemetery, Los Angeles National Cemetery, or the California Central Coast Veterans Cemetery located in Seaside.

Discretionary approvals required for the Proposed Project include:

1. Approval of a General Plan Amendment to amend the Table LU-4 in the Land Use Element indicating the conditionally permitted cemetery use within DA 5;

2. Approval of an MPSP Amendment identifying a cemetery use as a conditionally permitted use within DA 5 and removing the retail uses within the Institutional designation (within DA 6);

3. Approval of a Zoning Code Amendment to incorporate zoning standards for DA 5 as amended in the MPSP;

4. Approval of a Conditional Use Permit to allow for operation of the cemeteries within DA 5

5. Approval of a Tentative Parcel Map; and

6. Determination that the Program Environmental Impact Report No. 331 (EIR No. 331) adequately analyzed the Proposed Project pursuant to the requirements of CEQA. 3-1
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3.0 COMPARATIVE EVALUATION OF ENVIRONMENTAL IMPACTS
The following discussion contains an analysis of the potential impacts of the changes to the Approved Project relative to the Proposed Project. The potential impacts of the Proposed Project are compared to impacts identified for the Approved Project analyzed in EIR No. 331. As previously explained in Chapter 1.0, Introduction, this comparative analysis has been undertaken pursuant to CEQA and to provide City decision-makers with a factual basis for determining whether the proposed changes to the Approved Project, changes in circumstances, or new information since the certification of EIR No. 331 require additional environmental review. Potential impacts associated with the Proposed Project are evaluated using the same thresholds applied in EIR No. 331. The basis for each finding is explained in the analysis that follows.

IMPACTS IDENTIFIED IN THE CERTIFIED EIR
As discussed in Chapter 2.0, Project Description, the Proposed Project would result in minor amendments to the City’s MPSP, General Plan Land Use Element, and Zoning Code. Although impacts would be similar to or less than those previously covered by EIR No. 331, a new analysis for impacts is provided in this Addendum as required by CEQA. The environmental analysis provided in EIR No. 331 remains relevant and applicable to the Proposed Project in areas unaffected by changes in existing conditions and changes in the Proposed Project for the environmental topics as listed below.

The City had determined in the Initial Study prepared for the Approved Project that the following issues would have no impacts and would not be evaluated in EIR No. 331: agricultural resources and mineral resources. The Proposed Project does not necessitate a change in these determinations, as the existing site conditions and nature of the project have not substantially changed from those identified for EIR No. 331. Therefore, the environmental analysis provided in EIR No. 331 remains relevant and applicable to the Proposed Project for the areas unaffected by changes for these topic areas. Refer to Sections 3.1 through 3.14, below, for in-depth analysis of the environmental topic areas that included potentially significant impacts in EIR No. 331.

IMPACTS NOT IDENTIFIED IN THE CERTIFIED EIR
Impacts related to energy, greenhouse gas (GHG) emissions, wildfire, and tribal cultural resources were not evaluated as individual resource topics in EIR No. 331 because, at the time of preparation, these topics were not considered individual resource sections under State CEQA Guidelines Appendix G. GHG Emissions was added as a resource category in State CEQA Guidelines Appendix G in 2010. Tribal Cultural Resources was added as a resource category in State CEQA Guidelines Appendix G in 2015. The Energy and Wildfire resource categories were added to State CEQA Guidelines Appendix G in 2019. As these four resource categories were only included in the State CEQA Guidelines after the 2005 Certified EIR was approved, they were not evaluated as separate resource sections in EIR No. 331. Prior to the updates made to these topics in 2015 and 2019, impacts from wildfire were briefly discussed within the Hazards and Hazardous Materials section, and impacts to tribal cultural resources were briefly discussed within the Cultural Resources section.

Please refer to the discussion below to determine where each resource category is discussed in this Addendum.

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• Energy: The Proposed Project would allow for the development of cemetery uses in DA 5 of the MPSP, where residential development of up to 1,595 units was previously environmentally cleared. This shift in projected land use and the lesser degree of development would result in decreased energy demand as opposed to the Approved Project. As such, there would be no significant impacts related to energy resources as a result of the Proposed Project, and this topic will not be discussed further in this Addendum.
• Greenhouse Gas Emissions: EIR No. 331 did not discuss the Approved Project’s potential impacts related to GHG emissions and therefore did not draw any conclusions for the Proposed Project for comparison. However, the potential daily maximum and annual GHG emissions from the Approved Project were re-modeled using the current version of CalEEMod, version 2022.1.1.21, for the purposes of comparison to potential GHG emissions from the Proposed Project. The comparative potential GHG emissions for the Approved Project versus the Proposed Project are addressed further in Section 3.8, Air Quality, of this Addendum. • Wildfire: Per discussion in the Hazards and Hazardous Materials section of the 2004 EIR No. 330, it was concluded that wildland fires would pose a significant threat to people and structures, as the Specific Plan Area is susceptible as a result of its larger proportion of vegetation and open space. However, the Approved Project included a detailed Fire Master Plan, fuel modification plan, and other fire protection measures. Further, a fire station was planned for DA 6, and it was stated that the MPSP roadway system would improve emergency access to and within the Specific Plan Area. As such, the Approved Project includes goals and policies that address the threat of wildland fires within Anaheim, and impacts were found to be less than significant. The Proposed Project does alter the anticipated development analyzed under the Approved Project by permitting landscaped cemetery uses within DA 5 where residential uses were previously environmentally cleared. Analysis of how the Proposed Project would affect wildfire risks will be addressed further in Section 3.10, Hazards and Hazardous Materials, of this Addendum. • Tribal Cultural Resources: As discussed in Section 3.14, Cultural Resources, because the Proposed Project includes an update to the City’s General Plan, the requirements of Senate Bill (SB) 18 for Native American consultation apply. The SB 18 Consultation is ongoing. The results of these consultation efforts and the implications of these results as they pertain to tribal cultural resources will be incorporated into Section 3.14, Cultural Resources, of this Addendum.

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3.1 LAND USE AND PLANNING

3.1.1 Existing Environmental Setting
Since the preparation of EIR No. 331, there have been no major changes to the existing setting surrounding the Specific Plan Area with respect to land use and planning. Slight changes to the existing setting within the Specific Plan Area have occurred pertaining to conservation easements.

When EIR No. 331 was certified in 2005, existing open space within the Specific Plan Area was governed by the Natural Communities Conservation Plan/Habitat (NCCP/HCP) and The Nature Conservancy Anaheim Conservation Easement (TNC ACE). However, in 2014, the MPSP property owner (the Irvine Company) donated land to Orange County for preservation as a conservation easement (“2014 easement”). When this occurred, jurisdiction over the affected portion of the Specific Plan Area was transferred to OC Parks. The land is now subject to the conservation easement conditions established by OC Parks Foundation when the land was donated in 2014.

However, this change does not affect DA 5, which is referred to as the “Unencumbered Parcel” in the deed associated with the 2014 easement. As previously discussed, DA 5 contains a former surface mining site and is highly disturbed as a result. Though directly adjacent to the 2014 easement, the project site has not undergone any changes with respect to land use and planning since the certification of EIR No. 331.

As noted in Section 2.0, Project Description, the Specific Plan Area encompasses approximately 3,023.8 acres, including 3,001 acres on site and 22.8 acres off site (for infrastructure, roadway, and drainage improvements). DA 5 consists of approximately 291 acres, or 9.7 percent, of the total on-site MPSP acreage. Land use documents deemed applicable to the MPSP in EIR No. 331 include the City of Anaheim General Plan, the City of Anaheim Zoning Code, the County of Orange General Plan, NCCP/HCP Reserve, the TNC ACE, and the Southern California Association of Governments (SCAG) Regional Comprehensive Plan and Guide (RCPG). According to the City’s General Plan Land Use Element, the MPSP, including the project site, is located within the City’s Hill and Canyon Community Policy Area. General Plan Land Use Designations within the MPSP include Low-Medium Density Residential, Low-Medium Hillside Residential, Institutional, and Open Space, as shown on Figure 3-1, General Plan Land Use Designations. According to the figure, the entirety of DA 5 is classified for the Low-Medium Density land uses. According to the MPSP, DA 5 consists of the “RMP- 4” Single Family Detached Residential Zone and the “RMP-5” and “RMP-6” Single-Family Cluster Residential Zones. Please refer to Figure 3-2, Existing Zoning Designations, for a breakdown of zoning designations by DA. These zones implement the Low-Medium Hillside and Low-Medium Density Residential land use designations pertaining to DA 5 in the General Plan.

3.1.2 Comparison of Impacts for the Approved Project and the Proposed Project It should be noted that the Approved Project was found to have no impacts pertaining to the physical division of an established community and that this threshold was therefore not analyzed in EIR No. 331. Because the project site and the MPSP are generally undeveloped and do not contain any residential communities, this conclusion remains valid for the Proposed Project, and this threshold will not be discussed further in this Addendum.

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City of Yorba Linda
SOURCE: Google Maps (2023)
I:\OCC1901\GIS\Pro\Mountain Park Memorial Park\Mountain Park Memorial Park.aprx (12/19/2023) FIGURE 3-1
Gypsum Canyon Cemetery Project
General Plan Land Use Designations
0 1000 2000
FEET
Project Site
City Boundary
Mountain Park
Specific Plan Boundary
Land Use Designations
Low Medium Density
Low Medium Hillside Density
Open Space
Parks
Public-Institutional
Residential-Low
Residential-Low Medium
Residential-Low Medium Hillside
School

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City of Yorba Linda
SOURCE: Google Maps (2023)
I:\OCC1901\GIS\Pro\Mountain Park Memorial Park\Mountain Park Memorial Park.aprx (12/19/2023) FIGURE 3-2
Gypsum Canyon Cemetery Project
Existing Zoning Designations
0 1000 2000
FEET
Project Site
Mountain Park
Specific Plan Boundary
Zoning Designations
Mountain Park Specific Plan
Multiple-Family Residential (Up to 18 units/acre)
Open Space
Public Recreational
Sycamore Canyon Specific Plan
The Summit of Anaheim Hills Specific Plan
Transition

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Would the project conflict with any applicable land use plan, policy, or regulation of any agency with jurisdiction over the project (including, but not limited to the general plan, specific plan, local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect?
Approved Project
No Impact. EIR No. 331 found that the Approved Project would have no impact related to conflicts with applicable land use plans, policies, or regulations. The approved land uses in the Specific Plan, including DA 5, were determined to be consistent/compatible with City, County, regional, and resource protection plans/programs in Table 4.1-1, Consistency of the Proposed Project with Land Use-Related Goals and Policies, in EIR No. 331. Some general themes within Table 4.1-1 included land use compatibility, quality housing in strategic locations, and the preservation of open space and natural resources. The Approved Project was found to be consistent with all applicable policies because it allowed for the development of a variety of housing units in a strategic location while ensuring the preservation of approximately 2,163 acres of open space and utilizing landscaping to ensure smooth transitions between adjacent land uses. Due to its planned open space preservation, the Approved Project was also found to be consistent with the NCCP/HCP and TNC ACE. Potential inconsistencies arising from the new zoning and development standards set forth in the Specific Plan Amendment were eliminated through an amendment to the City’s Zoning Code to incorporate these standards. As such, no impacts were identified in EIR No. 331 pertaining to conflict with applicable land use plans, policies, or regulations.

Proposed Project
Less Than Significant Impact. The Proposed Project would involve the development of cemetery uses within DA 5 of the Specific Plan Area, which is currently planned for the development of up to 1,595 residential units, a private recreation facility, and other infrastructure. This change in land use would only occur within DA 5, which consists of approximately 9.7 percent of the on-site MPSP acreage. As such, approximately 92.3 percent of the Specific Plan Area would remain unchanged with regard to land use and plans, policies, and regulations. DA 5, which is also considered the project site, is currently designated for Low-Medium Density Residential in the City’s General Plan Land Use Element and zoned as the “RMP-4” Single Family Detached Residential Zone as well as the “RMP-5” and “RMP-6” Single-Family Cluster Residential Zones. As currently written, these land use and zoning designations, as well as the DA 5 development standards set forth in the MPSP, do not allow cemeteries as a permitted use, creating a potential land use conflict. However, the proposed amendments to the City of Anaheim General Plan and Zoning Code, as well as the Specific Plan Amendment, would identify cemeteries as a conditionally permitted use within DA 5 of the MPSP, which would resolve this potential conflict across each document.

In addition, the Proposed Project does not include a realignment of Santa Ana Canyon Road, as planned in the existing MPSP. Given that the realignment would no longer take place under the Proposed Project, the available development areas within DA 6 would be reduced. Given the reduction in developable area within DA 6, the removal of the planned 3,000 square feet of convenience store uses in DA6 would take place under the Proposed Project. However, this removal would not preclude the development of the planned fire station and trail staging area within DA 6.

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However, the proposed Specific Plan Amendment would remove the retail uses within the Institutional designation of DA 6.

With approval of these amendments, all potential land use inconsistencies would be eliminated.

As previously discussed, in 2014, the MPSP property owner (Irvine Company) donated approximately 1,040 acres of the Specific Plan Area to Orange County for preservation as a conservation easement (“2014 easement”). When this occurred, new conservation easement conditions established by OC Parks Foundation became applicable to the 2014 easement. DA 5 does not fall within the 2014 easement, meaning these conditions are generally not applicable to the project site. The Proposed Project within DA 5 would not create a land use conflict with the 2014 easement or any other conservation easements within the Specific Plan Area because the MPSP Design Guidelines would ensure the Proposed Project’s consistency with the City’s Community Design Element and Green Element, as well as other applicable documents. Relevant project design features that would contribute to land use compatibility by providing appropriate interface between the cemetery and adjacent conserved lands include, but are not limited to, transitional grading and landscaping. The Proposed Project would not otherwise interfere with any conservation easements within the MPSP and, as such, would be compatible with adjacent land uses consistent with all applicable goals and policies outlined in Table 4.1-1 of EIR No. 331. Based on this and the other factors discussed above, the Proposed Project would result in less than significant impacts related to conflict with land use plans and would therefore not result in new significant environmental impacts compared to the analysis presented in EIR No. 331.

3.1.3 Cumulative Land Use and Planning Impacts
Approved Project
Less Than Cumulatively Considerable Impact. EIR No. 331 analyzed jurisdictions within the Specific Plan Area’s vicinity, including the Hill and Canyon Area on either side of SR-91 within the cities of Anaheim and Yorba Linda, as the cumulative study area for potential land use and planning impacts.

EIR No. 331 stated that both areas have been developed with hillside communities and have generally been built out given the dedication of the Chino Hills State Park and TNC ACE open space areas. As such, the MPSP was one of the last potential sites for residential development within this portion of Orange County, and other large-scale developments were not anticipated within the vicinity. Because other communities within Yorba Linda and Anaheim within the Specific Plan Area’s vicinity were generally characterized by low-density residential communities, the proposed Low- Medium Hillside Density residential development within the MPSP DAs would be consistent with surrounding land uses. Further, the use of transitional grading and landscaping would ensure gradual transitions between new land uses and open space areas. As such, cumulative land use and planning impacts under the Approved Project were found to be less than considerable.

Proposed Project
Less Than Cumulatively Considerable Impact. As previously discussed, neighborhoods within the existing setting surrounding the Specific Plan Area, including within the neighboring city of Yorba Linda, have generally been built out to their full potential and limited land use changes are anticipated within these neighborhoods in the present or future. In 2022, the City of Anaheim 3-11
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approved minor building reconfigurations and other improvements to the Kindred Community Church, located approximately 0.7-mile west of the project site at 8712 East Santa Ana Canyon Road. However, these improvements supported a continuation of the existing religious land use and therefore would not result in cumulatively considerable land use conflicts. Further, the Proposed Project affects only a small portion (DA 5) of the MPSP and would not affect planned land uses throughout the remaining DAs or outside of the MPSP. With regard to compatibility with adjacent land uses, the proposed cemeteries would include the appropriate design features to blend in with surrounding land uses, including transitional grading and landscaping near open space or easement interfaces. Any potential land use and planning policy conflicts would be eliminated through the approval of the proposed amendments to the General Plan Land Use Element, Zoning Code, and MPSP. As such, the Proposed Project would not result in any individually significant impacts to land use and planning that could contribute to cumulatively considerable land use and planning conflicts.

As a result, no significant adverse cumulative impacts to land use and planning would occur under the Proposed Project.

3.1.4 Findings Related to Land Use and Planning

3.1.4.1 No New Significant Effects Requiring Major Revisions to the Certified EIR Based on the foregoing analysis and information, there is no evidence that the Proposed Project requires a major change to EIR No. 331. The Proposed Project would not result in new significant environmental impacts related to land use and planning, and there would not be an increase in the severity of impacts described in EIR No. 331.

3.1.4.2 No Substantial Change in Circumstances Requiring Major Revisions to the Certified EIR No major changes to the Specific Plan Area have taken place since preparation of EIR No. 331 that would require revisions to the analysis in EIR No. 331. There is no information in the record or otherwise available that indicates that there are substantial changes in circumstances pertaining to land use and planning that would require major changes to EIR No. 331.

3.1.4.3 No New Information Showing Greater Significant Effects than the Certified EIR This Addendum has analyzed all available relevant information to determine whether there is new information that was not available at the time of EIR No. 331, indicating that a new significant effect not reported in that document may occur. Based on the information and analyses above, there is no substantial new information indicating that there would be a new significant impact related to land use and planning requiring major revisions to EIR No. 331.

3.1.4.4 No New Information Showing the Ability to Reduce Significant Effects in the Certified EIR There is no new information, mitigation, or alternatives to the Proposed Project that would substantially reduce one or more significant impacts pertaining to air quality identified and considered in EIR No. 331.

3.1.5 Standard Conditions and Mitigation Measures
No Standard Conditions or mitigation measures were identified in EIR No. 331 pertaining to land use and planning because no impacts from implementation of the Approved Project were identified. As

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the Proposed Project would not result in any potentially significant impacts pertaining to land use and planning, no additional Mitigation Measures or Standard Conditions are required.

3.2 LANDFORM AND AESTHETICS

3.2.1 Existing Environmental Setting

3.2.1.1 Landform/Topography
The project site is located generally in Gypsum Canyon. Existing elevations range from approximately 340 feet above mean sea level (amsl) in the northern portion to approximately 2,200 feet amsl in the southern portion of the project site.

The project site consists of a large open canyon feature located within a perimeter of ridges. The ridges on site, for the most part, are elongated with moderate to very steep side slopes ranging from 3:1 to 1:1 (horizontal to vertical). The sides of the ridges are often incised by swales and re- entrants from the canyons, which are generally narrow and V-shaped, with the exception of the main canyons, which are fairly wide and flat-bottomed. EIR No. 331 considered the existing landform/topography as a scenic resource. EIR No. 331 identified specific landform features such as on-site rock outcroppings within many of the DAs of the MPSP (DA 1, DA 2, DA 3, DA 4, and DA 7); however, they were not identified within DA 5 or DA 6. DA 5 is at a disturbed former quarry site that is no longer operational. Due to the extensive mining activities that have occurred in this area, the majority of this DA does not have natural topographic features. EIR No. 331 described the proposed conceptual grading plan for DA 5 as generally consisting of lowering the grades in the southern and eastern portions of the DA and raising the grades in the northern and western portions of the DA.

The grading in DA 5 would have accommodated residential pads for a maximum of 770 single-family detached and 825 single-family attached dwelling units.

Proposed development within DA 5 would be visible from SR-241 from the west and the alterations to the northern slopes adjacent to SR-91 would be visible from SR-91. The grading proposed to accommodate development within DA 5 would not significantly alter the existing landform/ topography because the majority of DA 5 is highly disturbed and natural landforms have been altered by mining activities.

3.2.1.2 Aesthetics
The areas surrounding the project site to the north are developed with residential uses in the city of Yorba Linda, SR-91, and the Santa Ana River. Land uses to the west include residential in the city of Anaheim, while land uses east and south of the project site consist of permanent open space associated with the NCCP, TNC ACE, or Chino Hills State Park. Due to the project’s location on the north and northwestern hillsides of Anaheim, which are at higher elevations and visible from surrounding areas, much of the project site is visible from a number of vantage points, including distant areas. EIR No. 331 provided numerous images to indicate the potential of the view with the Proposed Project in place.

A flagpole has been constructed on the project site and is currently lit during nighttime hours. 3-13
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3.2.2 Comparison of Impacts for the Approved Project and the Proposed Project EIR No. 331 combined the evaluation of the following two impact areas together. Therefore, to maintain consistency between EIR No. 331 and this Addendum, the two impact areas are combined here as well.

Would the project have a substantial adverse effect on a scenic vista? Would the project substantially degrade the existing visual character or quality of the site and its surroundings?
Approved Project
Significant and Unavoidable Impact. The visual impacts of the Approved Project include both the objective visual resource change created by the project and the subjective viewer response to that change. View perception is subjective. The perception of different viewer groups to the visual environment and its elements varies based on viewer activity and awareness. Activities such as commuting in heavy traffic can distract an observer from many aspects of the visual environment.

Conversely, pleasure driving or relaxing in a scenic environment can encourage an observer to look at the view more closely and at a greater length, thereby increasing the observer’s attention to detail.

Sensitivity is also determined by how much the viewer has at stake in the viewshed. Typically, people who own property in the area are more sensitive to change than those passing through the area.

Because of the Specific Plan Area’s location within a Scenic Overlay Corridor and the designation of this stretch of SR-91 as an Eligible State Scenic Highway, the project is subject to additional requirements related to preserving scenic resources and scenic vistas. EIR No. 331 identified that a landscape plan would be implemented that would emphasize the natural environment by restoring disturbed riparian slopes and using a plant palette that would transition from ornamental landscape to the existing functional landscape. As a requirement of Section 18.18.040 of the Anaheim Municipal Code, any specimen trees removed as part of project implementation would be replaced at a ratio ranging from 2:1 to 4:1 depending on the size of the tree removed.

EIR No. 331 identified Chino Hills State Park being located east of the project site. Views of the project site from vantage points within the park are generally limited to a public ridgeline trail in the western portion of the State Park. From this area, the quarry (DA 5) is the prominent visual feature in the foreground. The approved landscape plan would create a landscape program that would emphasize the natural environment by restoring disturbed riparian and slope areas and using a plant palette that would smoothly transition from an ornamental development landscape to the existing natural landscape. Background views would not be altered or obstructed.

EIR No. 331 provided a comparison of existing views with prepared visual simulations for all DAs.

The entire MPSP area was evaluated from various viewpoints and it was determined that there were sensitive views, particularly of rock outcrops, in DA 1, DA 2, DA 3, DA 4, and DA 7. These sensitive views would be impacted, and EIR No. 331 identified the visual impacts to these DAs as significant and unavoidable. However, because of location and previous use as a quarry, DA 5 and DA 6 do not have natural landforms associated with them and impacts to these DAs were therefore found to be less than significant.

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Proposed Project
Significant and Unavoidable Impact. EIR No. 331 evaluated DA 5 for residential development within a larger project area; however, this Addendum evaluates DA 5 for as a cemetery for the general public and veterans. As mentioned previously, a former quarry is within DA 5. The quarry greatly altered the existing landforms but did not change the surrounding ridgelines that contribute to the scenic vistas in the area. The replacement of the residential area with a cemetery would result in development to a lesser scale but would still be visible from SR-91 and the State Park. DA 5 would require implementation of a landscape plan that would transition the plant palette from the cemetery land use to the surrounding natural areas. The proposed development of a cemetery use would result in a landscaped area comprising the majority of DA 5 as opposed to the current plan for the development of a neighborhood containing up to 1,595 single-family dwelling units. While the proposed cemetery uses would include small structures associated with administration, interment, and ceremonial uses, the Proposed Project would ultimately result in a less developed landscape than under the Approved Project. However, landscaping of the northern slope of the project site would mark a change from existing conditions as seen from SR-91, as highlighted on Figure 3-3, Visual Simulation: EIR No. 331 View N-9. Figure 3-3 showcases the landscaping techniques to be utilized along the slope to screen the development on the higher elevations within DA 5. Because this marks a substantial difference from current views, impacts would be significant and unavoidable and the Proposed Project would not affect the visual resource conclusions reached in EIR No. 331 regarding DAs outside of DA 5. Because the baseline appearance of DA 5 and DA 6 remain disturbed due to former quarry operations as stated in EIR No. 331, and because a lesser degree of development is proposed within DA 5, impacts to these DAs would remain less than significant. As such, the Proposed Project would not result in increased visual resource impacts than those identified in EIR No. 331.

Would the project substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a State scenic highway or local scenic roadway? Approved Project
Significant and Unavoidable Impact. With respect to State scenic highways and local scenic roadways, the on-site scenic resources (topographic features and rock outcrops) are visible primarily from SR-241, which is not designated as State scenic highway or a scenic roadway by the City of Anaheim or Caltrans. However, the County of Orange Scenic Highways Plan designates SR-241 as a Type II Landscape Corridor. Views from the western side of SR-241 are of the rock outcroppings.

SR-91 between SR-55 and Weir Canyon Road is categorized as a Type 1 Scenic Highway (Viewscape Corridor) in the County Scenic Highways Plan, a State Scenic Highway by the State of California, and within the Scenic Corridor Overlay Zone by the City of Anaheim. The views from SR-91 toward the MPSP area are limited due to the difference in elevation between the roadway and the project site.

It was determined that the Specific Plan Area would not be visible from the portions of Weir Canyon Road and Santa Ana Canyon Road that are designated by the City of Anaheim as scenic expressways.

FIGURE 3-3
I:\OCC1901\G\View Simulation\View_Sim_1.ai (12/19/2023) Gypsum Canyon Cemetery Project
Visual Simulation: EIR No. 331 View N-9
Existing View 1 - View from the south side of SR-91 looking east towards the project site.

Proposed View 1 - View from the south side of SR-91 looking east towards the project site.

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The Approved Project would comply with all requirements of the Anaheim Municipal Code relative to grading, as feasible. In certain instances, the MPSP includes grading design standards that deviate from the City’s grading policy; however, the MPSP ultimately still achieves the intent of the grading policy with regard to the natural appearance of manufactured slopes through use of grading and landscaping techniques. Please refer to Figure 3-4, Conceptual Grading Plan, for an illustration of proposed grading within the project site. In general, as shown in the cross-sections for each of the DAs, the cuts and fills planned as part of the project were designed to follow the natural topography to the extent feasible.

As noted previously, the southern portion of the Specific Plan Area that includes more prominent landform features would remain as permanent open space. The ridgelines in this area, as well as more substantial ridgelines surrounding the project site, such as Windy Ridge, were determined to not be significantly impacted with implementation of the Proposed Project as described in EIR No. 331.

Proposed Project
Significant and Unavoidable Impact. The visual impact analysis provided in EIR No. 331 regarding the Approved Project remains valid for all DAs aside from DA 5. Because the Proposed Project is subject to the MPSP, the Proposed Project is still required to comply with specific plan grading requirements and all applicable grading and landscaping provisions concerned with the natural appearance of manufactured slopes and the interface between development and open space outlined in the MPSP.

As stated above, due to DA 5’s location along the northernmost boundary of the Specific Plan Area, views of DA 5 are available from SR-91, which is designated as an eligible State scenic highway. The grading and landscaping techniques proposed are anticipated to create a natural appearance, to the extent possible, of the manufactured slopes. The closest portion of SR-91 to the Specific Plan Area would be the south side of SR-91 looking southeast toward the project site. A visual simulation of the Approved Project was provided as Exhibit 4.2-15 (View N-9) in EIR No. 331. In order to compare the potential visual impacts associated with SR-91 from the Proposed Project to the Approved Project, a view simulation was prepared for the Proposed Project from the same viewpoint. This simulation, illustrated on Figure 3-3, Visual Simulation: EIR No. 331 View N-9, showcases a similar visual effect of development as the Approved Project. In both cases, landscaping techniques are utilized along the slope in order to screen the development on the higher elevations within DA 5.

Exhibit 4.2-15 appears to show distant rooftops of the planned homes within DA 5 as designated under the Approved Project, which would no longer be developed under the Proposed Project.

Upon comparison of the figures, the proposed development would result in less visible development from the selected viewpoint, and impacts would be reduced. The Proposed Project would generally reduce the scale of development by providing two cemeteries consisting mostly of landscaped grassy areas and manufactured slopes, as opposed to the 1,595 residential structures under the Approved Project. As such, visual impacts of the Proposed Project would be substantially reduced from those of the Approved Project.

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FIGURE 3-4
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SOURCE: RJM Design Group

NOT TO SCALE
LEGEND
Project Site
Conceptual Grading Plan
Gypsum Canyon Cemetery Project

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SR-241 also provides limited views toward DA 5 in certain locations. View simulations included in EIR No. 331 showed that the planned residential development within DA 5 would have been visible beyond intervening land uses such as the planned SR-241/Weir Canyon Road interchange as well as landscaping and grading of other DAs. However, given the significantly reduced scale of development and general natural appearance under the Proposed Project, DA 5 is not anticipated to be visible from SR-241 under the Proposed Project. Therefore, views of the project site from SR-91 and SR-241 would either be obstructed by intervening land uses or would demonstrate a decrease in visual impacts as compared to the Approved Project given the lesser scale of development under the proposed cemetery uses as opposed to the planned residential uses. Further, the proposed cemetery land use would be less obtrusive than a residential neighborhood. Although substantially reduced, the impacts would remain significant and unavoidable and the findings of EIR No. 331 remain valid.

Would the project create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?
Approved Project
Less Than Significant Impact. EIR No. 331 indicated that the Approved Project would generate light sources that are typical of the uses proposed: streetlights, residential lighting, and lighting for the proposed sports park in DA 3. EIR No. 331 identified PDF 2-2, which pertained to submittal of lighting plans for review and approval by the Community Services Department and the inclusion of lighting-related design specifications for the sports park within DA 3.

All planned lighting would be shielded or directed downward to minimize light and glare spillover.

Planned street lighting would consist of downcast luminaries, shielded and oriented in a manner that would minimize light spillage or glare from the project site. Based on the conceptual lighting plan for the Approved Project, the following types of lighting would be provided: signalized intersections; theme streetlights at intersections; accent lighting at entry gates; streetlights within DAs and where necessary for traffic safety purposes along collector roads; and low-level security lighting at parks and schools. Based on conceptual plans, streetlights at major private streets and intersections, local streets, interior streets, and park areas would be a maximum of 14 feet high.

Sports field lighting at the community park proposed in DA 3 would also be provided with a state-of- the-art technology lighting system to minimize light and glare and reduce night sky glow, and spillover to adjacent existing and proposed residences. The lights would be directed inward and screened with vegetation. Park site designs had not been developed at the time of preparation of EIR No. 331; however, it was determined to be possible that lights would be visible from existing residents west of the project site as well as future residents of the Approved Project at night.

The Approved Project was found to result in an increase in nighttime lighting, thereby creating an indirect impact on common wildlife species in the area. Because these common wildlife species using habitats on site would avoid habitats affected by the nighttime light spillover effects, the wildlife species diversity would decrease beyond the actual DA. However, this was found to not reduce general wildlife populations below self-sustaining levels in the region and was considered less than significant, as discussed in Section 3.6.2, Biological Resources, of this Addendum.

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Proposed Project
Less Than Significant Impact. Because the Proposed Project would be limited to DA 5 and would not affect DA 3 or the planned sports park, PDF 2-2 would not be applicable and is not discussed further.

The Proposed Project would be the development of cemetery uses on the DA 5 property. The MPSP identified this area (DA 5) for residential development, which would have lighting from individual residences but also local roadways. The cemeteries would not be open 24 hours per day but would require lighting for security and safe travel on the internal roadways after dark. The lighting from the Proposed Project is not anticipated to be as bright or as widespread as the Approved Project.

However, the existing flagpole does serve as a source of night lighting. The lighting is focused on the flag and does not result in off-site light spillage. Therefore, the impact from on-site lighting would be less than that from the Approved Project and the conclusions of EIR No. 331 remain valid.

Would the project conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project (including, but not limited to the general plan, specific plan, local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect?
Approved Project
Less Than Significant Impact. EIR No. 331 indicated that the Approved Project would be consistent with the relevant goals and policies related to aesthetics and visual resources. Some City of Anaheim General Plan elements identified as applicable to the Approved Project included the Circulation Element, Green Element, and Community Design Element. The Anaheim Municipal Code, Caltrans State Scenic Highway Program, and County of Orange Scenic Highways Plan were also identified as documents applicable to the Approved Project. The MPSP includes specific development standards that govern implementation of the Approved Project, which avoid or minimize environmental impacts.

Proposed Project
Less Than Significant Impact. EIR No. 331 identified that the Approved Project would be consistent with the relevant goals and policies. The Proposed Project would continue to implement the applicable design standards set forth in the MPSP and would be consistent with relevant Anaheim Municipal Code and 2022 California Building Code as adopted by the Anaheim City Council (CBC) provisions. Therefore, there would be no change in significance for this issue area because both the Approved Project and Proposed Project would comply with the local codes and regulations through compliance with the applicable provisions of the Specific Plan. The findings of EIR No. 331 remain valid.

Would the project conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
Approved Project
Less Than Significant with Mitigation Incorporated. EIR No. 331 indicated that the Approved Project is located within the City of Anaheim Scenic Corridor Zone Overlay (Chapter 18.18, Anaheim Municipal Code), which contains a section on tree preservation (Section 18.18.040, Tree 3-23
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Preservation). Development of the Approved Project would require destruction and/or removal of Specimen Trees as defined in Section 18.18.040, Tree Preservation.

With the concern regarding Specimen Trees, the Approved Project applicant planned to replace removed specimen trees at a 20:1 ratio. EIR No. 331 included PDF 2-1, which required a detailed Landscape Plan to demonstrate adherence to the 20:1 ratio. This would substantially exceed the requirements of Section 18.18.040, Tree Preservation (required replacement at a ratio ranging from 2:1 to 4:1 depending on the size of the tree removed). The trees’ replacement pursuant to the City’s tree preservation requirements would be consistent with the City’s tree list and provisions outlined in the Anaheim Municipal Code Section 18.18.040. Generally, replacement trees would consist of oaks, sycamores, willows, toyon, and other native trees present within the Specific Plan Area.

The percentage of the different types of replacement trees would be representative of the trees existing on the site and would be planted in varying sizes to promote age and size diversity and create a more biologically sound replanting program. The impact associated with the removal of specimen trees as a result of the Approved Project were determined to be less than significant with implementation of PDFs and Standard Conditions that address tree replacement.

Proposed Project
Less Than Significant Impact. The Proposed Project is focused on DA 5, which was previously a working quarry. Since closing, the quarry went through stabilization as required by the Surface Mining and Reclamation Act of 1975 requirements. Therefore, the existing land within DA 5 is highly disturbed. However, according to the Biological Resources Assessment (LSA 2023) prepared for the proposed project, the project site contains oak trees designated as Specimen Trees under Section

18.112.070 of the City’s Municipal Code. It should be noted that, while EIR No. 331 discussed Section

18.18.040 of the City’s Municipal Code, since the adoption of the Mountain Park Specific Plan, the Municipal Code section applicable to the Proposed Project is now Section 18.112.070. Section

18.112.070 considers oak trees with a trunk diameter of 8 inches or greater to be a Specimen Tree.

Pursuant to Section 18.112.070, A Specimen Tree Removal Permit application shall be required and submitted to the Planning and Building Department on forms provided for such purposes together with a filing fee as established by resolution of the City Council. All final landscape plans shall be consistent with the Specimen Tree Removal Permit, including replacing each specimen tree removed by grading by trees from the City’s Tree Replacement List until an overall replacement ratio of 20:1 is reached.

The Proposed Project would adhere to PDF 2-1 as identified in EIR No. 331, as well as all tree removal and replacement requirements set forth in Section 18.112.070 of the City’s Municipal Code.

Therefore, the Proposed Project would not conflict with the tree preservation policy, and the findings of EIR No. 331 remain valid.

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3.2.3 Cumulative Landform and Aesthetics Impacts
Approved Project
Less Than Cumulatively Considerable Impact. EIR No. 331 analyzed jurisdictions within the Specific Plan Area’s vicinity, including the Hill and Canyon Area on either side of SR-91 within Anaheim and Yorba Linda, as the cumulative study area for potential aesthetic impacts. EIR No. 331 identified that over the two preceding decades, the Hill and Canyon Area on both sides of SR-91 has been developed into attractive and highly desirable hillside residential communities. Well-designed commercial and institutional uses have also been introduced to the area. With the recent dedication of Chino Hills State Park and TNC ACE as open space, the area was considered essentially built out.

Consequently, the MPSP project site was considered one of the last developable areas in this portion of Anaheim and the County.

From the standpoint of aesthetic impacts, EIR No. 331 described that the Approved Project would result in a new community that fits well within the existing setting in that the land uses proposed are consistent and compatible with surrounding land uses. Specifically, the DAs nearest existing neighborhoods would be developed into attractive, low- to low/medium-density residential communities; areas nearest existing parks and open spaces would be preserved as open space. This natural progression from developed to undeveloped land use is consistent with the surrounding areas and the preservation of the major landforms within the Hill and Canyon Area as part of the project design. The Irvine Ranch Land Reserve and Coal Canyon addition of the Chino Hills State Park would result in substantial open space preservation. This conclusion is consistent with the impact analysis presented in the City of Anaheim General Plan Update Final EIR No. 330. The Approved Project was determined to not result in significant cumulative aesthetic impacts.

Proposed Project
Less Than Cumulatively Considerable Impact. To maintain consistency with EIR No. 331, the cumulative study area for potential aesthetic impacts of the Proposed Project includes jurisdictions within the Specific Plan Area’s vicinity, including the Hill and Canyon Area on either side of SR-91 within Anaheim and Yorba Linda. As previously stated, this land has generally been built out with hillside residential communities or set aside for preservation.

The Proposed Project is within DA 5 of the MPSP. The Approved Project had identified this area for residential development; however, the Proposed Project would involve the development of a cemetery use within DA 5. The change of land use to a cemetery would allow for a visual transition from residential development to the adjacent open space. This improved natural progression from developed to undeveloped land use remains consistent with the surrounding areas and the preservation of the major landforms within the Hill and Canyon Area. In 2022, the City of Anaheim approved minor building reconfigurations and other improvements to the Kindred Community Church, 0.7-mile west of the project site at 8712 East Santa Ana Canyon Road. However, these improvements would not substantially alter the existing aesthetic character of the property and therefore would not result in cumulatively considerable aesthetic impacts. No other projects are proposed or currently approved within the geographic region that would result in aesthetic changes to undeveloped land. Therefore, the Proposed Project would not result in significant cumulative 3-25
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aesthetic impacts and the conclusions of EIR No. 331 regarding cumulative visual impacts remain valid.

3.2.4 Findings Related to Landform and Aesthetics

3.2.4.1 No New Significant Effects Requiring Major Revisions to the Certified EIR The planned land use change from residential development within DA 5 to use as a cemetery is a change but major revisions are not anticipated. DA 5 was previously a quarry, which dramatically changed the character of the existing landforms in this area, so the change from residential use to a cemetery would not result in new significant effects requiring revisions to EIR No. 331.

3.2.4.2 No Substantial Change in Circumstances Requiring Major Revisions to the Certified EIR No major changes to the Specific Plan Area have taken place since preparation of EIR No. 331 that would require revisions to the analysis in EIR No. 331. There is no information in the record or otherwise available that indicates that there are substantial changes in circumstances pertaining to landform and aesthetics that would require major changes to EIR No. 331.

3.2.4.3 No New Information Showing Greater Significant Effects than the Certified EIR As previously stated, the planned land use change from residential development within DA 5 to use as a cemetery is a change but greater significant effects are not anticipated. DA 5 was previously a quarry, which dramatically changed the character of the existing landforms in this area, but the change from planned residential use to a cemetery would not result in new significant effects requiring revisions to EIR No. 331.

3.2.4.4 No New Information Showing the Ability to Reduce Significant Effects in the Certified EIR Since DA 5 was previously a quarry, EIR No. 331 did not identify significant visual effects from this previous land use. However, converting the proposed residential development to a cemetery would not reduce the previously identified significant effects. Therefore, there is no change in significance for this issue area.

3.2.5 Standard Conditions and Mitigation Measures
Although no mitigation measures were identified pertaining to landform and aesthetics in EIR No. 331, Standard Conditions (SC) 2-1 through SC 2-6 were identified as applicable to the Approved Project. SC 2-1 through 2-4 are also applicable to the Proposed Project as they pertain to activities that would occur within the project site such as grading, tree replacement, and street improvements. However, SC 2-5 and 2-6 were prescribed for aspects of the Approved Project affecting Caltrans right-of-way, which is beyond the boundaries of the project site and would therefore not apply to the Proposed Project. SC 2-1 through 2-4, as follows, would remain applicable to the Proposed Project:

SC 2-1 Prior to approval of grading plans, the property owner/developer shall provide grading plans to the Department of Public Works demonstrating that graded areas will be compatible with natural landform characteristics in conformance with the Anaheim Municipal Code, Title 17 Land Development and Resources, the City of

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Anaheim Grading Design Manual and Hillside Grading Procedures, the Mountain Park Specific Plan Grading Concept and Hillside Grading and Landscape Policies, and the most recent version of the Anaheim Building Code (ABCCalifornia Building Code (CBC).

SC 2-2 Prior to approval of precise grading plans, the property owner/developer shall prepare a detailed slope landscape plan, which shall be approved by the Department of Public Works. The plan shall be certified by a licensed landscape architect, and be prepared in compliance with Section 17.06 of the City of Anaheim Municipal Code and the Mountain Park Specific Plan Grading Concept and Hillside Grading and Landscape Policies to blend landscape features with the existing environment. In addition, the landscape plan shall conform to the preliminary landscape plan approved in conjunction with the development area plans.

SC 2-3 Tree replacement shall be conducted consistent with Section 18.112.07018.040.

Prior to approval of grading plans, the property owner/developer shall provide a Specimen Tree Removal Plan to the Planning Department demonstrating that the proposed project has been designed in accordance with the provisions of Chapter

18.112.07018.040 and required tree replacement. The Specimen Tree Removal Plan will include an inventory of directly and indirectly affected trees that shall be determined either by referencing existing tree inventory data collected on the subject property or having a qualified arborist conduct an assessment based on the final, approved limits of development. The tree inventory will determine the species, number, sizes, and health of all trees to be impacted by the approved project and will be used to determine compensation ratios based on City of Anaheim (City) requirements. Protected trees shall not be removed or trimmed without proper City permits. All Specimen Trees shall be replaced by four trees from the City’s Replacement Tree List (Table 18-B) in Section 18.18.040. In addition, per Municipal Code 18.112.070, each specimen tree removed will be replaced by additional trees chosen from Table 1 Mountain Park Tree List, up to an overall replacement ratio of 20 to 1. Compensatory planting should be conducted within the portion of the project area that would remain undeveloped under the approved plans, or at an off-site location as approved by the City.

SC 2-4 Prior to approval of street improvement plans for a development area; the property owner/developer shall submit a detailed lighting plan for review and approval by the Public Utilities Department. The plan shall be reviewed for compliance with adopted City standards.

3.3 GEOLOGY AND SOILS

3.3.1 Existing Environmental Setting
The project site is located in the northern foothills of the Santa Ana Mountains, which are included within the Peninsular Ranges geomorphic province of coastal southern California and form the southeastern margin of the Los Angeles Basin. The bedrock units within the project site represent 3-27
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marine and nonmarine sedimentary strata of upper Cretaceous, Paleocene, Eocene, and Miocene ages. In order of oldest to youngest, these include the Ladd, Williams, Silverado, Santiago, Vaqueros- Sespe, and Topanga formations.

The main portion of the project site consists of the major north-trending Gypsum Canyon drainage, with numerous smaller northeasterly and westerly trending ridges and canyons. The northern and western boundaries are adjacent to SR-91 and existing residential development within Anaheim, respectively. The southern and eastern boundaries of the overall project site are adjacent to undeveloped land approaching Windy Ridge and the drainage divide between Coal Canyon and Gypsum Canyon, respectively. Windy Ridge is not located within the project site.

The ridges adjacent to DA 5, for the most part, are elongated with moderate to very steep side slopes ranging from 3:1 to 1:1 (horizontal to vertical). The sides of the ridges are often incised by swales and re-entrants from the canyons, which are generally narrow and V-shaped, with the exception of the main canyons, which are fairly wide and flat-bottomed. Existing elevations range from approximately 340 feet to 2,200 feet above mean sea level.

The majority of the site consists of vacant undeveloped land; however, there are existing improvements located within the project limits. A segment of the Questar natural gas pipeline transects the southern region of the site. The pipeline is 16 inches in diameter and has a general east to west alignment. The current easement for the pipeline is 50 feet wide. This segment of the Questar pipeline would need to be relocated prior to grading in the southern portion of the site.

The topography in the central to northeast region of the site is bowl-shaped, and site observations indicate that this area was graded to be a desilting basin. The northern region of the bowl-shaped topography contains an embankment that separates a larger basin upgradient from a smaller basin downgradient. Surface observations indicate that a corrugated riser and storm drain may connect these two basins.

3.3.1.1 Geologic Units
Geologic structures at the overall project site consist of bedrock formations of Tertiary and Cretaceous age (i.e., Vaqueros-Sespe Formation, Ladd). Alluvial materials, ranging in depth from 5 to greater than 50 feet in depth, are present in the main drainage channels across the project site. The potential for liquefaction exists within the project site due to the nature of the alluvial materials (i.e., relatively sandy) and the presence of groundwater.

The hillside areas near DA 5 are generally underlain by bedrock of numerous formations consisting of upper Cretaceous to late Quaternary-age bedrock. The bedrock units have been faulted and uplifted during regional mountain building processes. The structure generally consists of homoclinal3 blocks transected by north-northwest-trending bedrock faults.

3 In structural geology, a homocline or homoclinal structure is a geologic structure in which the layers of a sequence or rock strata dip uniformly in a single direction having the same general inclination in term of direction and angle.

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Surficial geologic units consist of relatively recent alluvium, slopewash, landslides, and manmade fills.

3.3.1.2 Artificial Fill
Major fill deposits within DA 5 are associated with the now-closed Robertson’s Ready-Mix sand and gravel quarry. They are predominantly silts and clays derived from the quarry operations. Major fill deposits are also located in DA 3 and DA 7. These deposits are associated with the off-site grading of the adjacent development to the west. Minor fill is associated with access road construction, as well as existing and previously existing structures located within all development sites.

3.3.1.3 Topsoil
A mantle of sandy topsoil covers much of the project site. The topsoil is approximately 1 to 2 feet thick, with thicker accumulations in swales. The nature of the topsoil varies depending on the parent material from which it was derived.

3.3.1.4 Soil Creep
Soil creep material consists of thin to thick sandy soil material (slopewash, topsoil and weathered bedrock) that moved slowly downslope due to saturation during heavy rains. Soil creep material exists in the canyon side slopes.

3.3.1.5 Slopewash
The occurrence of slopewash and thick soil cover is generally found throughout the project site in canyons, swales, side slopes, and saddles. The term slopewash is synonymous with colluvium and may include alluvium. The composition of slopewash or colluvial materials is highly variable and controlled mainly by the composition of the underlying bedrock source. In general, these deposits consist of thick sandy soil accumulations generally transported only short distances from their source.

3.3.1.6 Alluvium-Young Axial Channel Deposits
Alluvium represents an accumulation of sandy, coarse materials within canyons resulting from periodic stream transportation and deposition. As a result of transport, the alluvium generally tends to be thinner in the narrow canyons and thicker within the broader canyons and valley areas.

3.3.1.7 Landslides
The landslide materials are derived from slopewash and underlying bedrock as a result of translational or bedding plane failures and/or rotational failure and slumps. Landslide material exists in canyon side slopes adjacent to DA 5.

3.3.1.8 Regional Faults/Seismicity
The Alquist-Priolo Earthquake Fault Zoning Act was adopted by the State of California in 1972 to mitigate the hazard of surface fault rupture along active faults. For the purpose of this act, the State has defined an “active” fault as having “had surface displacement during Holocene time” (i.e., during the previous 11,000 years). In accordance with the Act, the State has delineated “Earthquake Fault 3-29
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Zones” along “active” faults throughout the State. The designated zone closest to the project site appears to be roughly 1 to 2 miles to the north along the Whittier-Elsinore Fault Zone. The subject project site is not within a designated “Earthquake Fault Zone.”

3.3.2 Comparison of Impacts for the Approved Project and the Proposed Project The Approved Project was found to have no impacts pertaining to the rupture of a known earthquake fault because, according to the most recent Alquist-Priolo Earthquake Fault Zoning Map at the time, there are no known earthquake faults on or near the Specific Plan Area. In addition, no impacts were identified regarding soils incapable of supporting septic tanks or alternative wastewater systems because such systems were not proposed under the Approved Project. As such, these thresholds were not analyzed in EIR No. 331. Because these conditions have not changed since the certification of EIR No. 331, the conclusions remain valid for the Proposed Project, and these thresholds will not be discussed further in this Addendum.

Would the project expose people or structures to potential or substantial adverse effects, including risk of loss, injury, or death involving: i) rupture of a known earthquake fault, ii) strong seismic ground shaking; iii) seismic-related ground failure, including liquefaction; or iv) landslides? Approved Project
Less Than Significant with Mitigation Incorporated. EIR No. 331 indicated that there are no known active or potentially active faults on or crossing the project site; therefore, the possibility of surface fault rupture is considered remote. However, as with all of southern California, the Approved Project site is located within a seismically active region, and ground shaking from seismic activity can cause damage to buildings and infrastructure.

Seismic parameters for the Approved Project site were analyzed using a deterministic seismic hazard analysis. In a deterministic analysis, one does not consider how likely or unlikely an earthquake on a specific fault would be. It simply involves computing the maximum ground acceleration that could be expected if the most severe earthquake actually occurred along each of the known fault systems in the area. The closest fault to the project site is the Whittier-Elsinore Fault Zone, located 1 to 2 miles north of the project site. Based on this analysis, the Whittier-Elsinore fault is potentially capable of producing the most intense ground acceleration at the site due to its proximity and maximum credible earthquake magnitude of 6.8 (Mw). Such an earthquake near the site could produce seismic shaking with peak horizontal ground acceleration estimated at 0.9941g (g is the acceleration of gravity, equal to 32 feet/second).

Ground motion can also result in secondary impacts, such as liquefaction, ground failure, and seismic settlement. A probabilistic seismic hazard analysis was also performed and indicates a ground acceleration of 0.675g for a 10 percent probability of occurrence within the next 50 years.

The possibility of ground acceleration or shaking at the Approved Project site is considered similar to that for all of southern California and is considered a potentially significant impact. All applicable guidelines, including compliance with the CBC, accepted industry standards, and other regional and local regulations that address seismic hazards, would be incorporated into project design. In addition, EIR No. 331 prescribed Standard Conditions (SC) 3-1, requiring structures to be designed in

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accordance with the most recent seismic standards in the Anaheim Building Code; SC 3-2, requiring grading activities in conformance with the Anaheim Municipal Code, City Grading Design Manual, and Grading Plan Procedures; SC 3-3, requiring a preliminary geotechnical report; and Mitigation Measure (MM) 3-1, requiring incorporation of recommendations of the preliminary geotechnical reports into final grading plans. With implementation of SCs 3-1 through SC 3-3 and MM 3-1, potentially significant seismic-related hazards were considered to be reduced to less than significant levels.

Liquefaction commonly occurs when three conditions are simultaneously present: (1) high groundwater, (2) relatively loose, cohesionless (sandy) soil, and (3) earthquake-generated seismic waves.

EIR No. 331 identified that elevated groundwater conditions exist in DA 5. This, together with the sandy, cohesionless nature of alluvium encountered in borings and the close proximity to the Whittier-Elsinore Fault (which is approximately 1 to 2 miles north of the site), could present the potential for liquefaction.

The potential adverse effects of the groundwater conditions on site are considered low for the following reasons. The lateral extent of the artesian zone previously described is located south of proposed DAs and would not affect development of the site. In areas where proposed design does encroach into the main canyon, recent subsurface investigations did not encounter groundwater.

Possible remedial measures would include the complete or partial removal of liquefiable soils in conjunction with increased (i.e., deeper and/or stiffer) foundation recommendations. Subdrains would be installed where groundwater is encountered near the ground surface as necessary. If artesian conditions are encountered within the proposed DAs, each situation would be evaluated separately.

During rough grading operations, and where feasible, complete removal of all potentially liquefiable alluvium would be accomplished. Where groundwater is present or encountered within alluvial areas, removals would extend down to saturated alluvium. Following alluvial removals, engineered fill would be placed at a minimum of 90 percent relative compaction. The proposed grading concept for the project includes alluvial removals, engineered fill in the canyons, and installation of a subdrain system to reduce potential impacts associated with liquefaction.

Potential impacts associated with elevated groundwater conditions that could cause liquefaction were identified as are potentially significant. However, EIR No. 331 determined that with application of SCs 3-1, 3-2, and 3-3, and MM 3-1, impacts would be reduced to level less than significant.

EIR No. 331 indicated that there were three large landslide complexes within or adjacent to the Specific Plan Area grading limits, including one landslide complex within the grading limits of DA 5.

EIR No. 331 determined that the two on-site landslides within grading limits, including DA 5, would require mitigation, such as complete removal of the landslide if feasible, in areas where the Approved Project design does not entirely remove mapped landslides. The feasibility of landslide removal is determined by several factors including, but not limited to location of the landslide with respect to the limits of grading, size and depth of landslide, whether removal of the slide would cause additional slope instability within the project or to adjacent existing structures, access to the 3-31
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landslide, and the presence of groundwater. EIR No. 331 indicated that, if complete removal is not possible, landslides may be stabilized and/or buttressed. This typically involves partial removal of the landslide and stabilizing potential future movement with earthen fill or reinforced material(s) such as geogrid reinforced soil or walls. Potential impacts associated with landslides were identified as potentially significant. However, EIR No. 331 determined that with application of SCs 3-1, 3-2, and 3-3, and MM 3-1, as described above, and MM 3-2, which required that all grading and earthwork activities shall be performed under the observation of a registered geotechnical engineer in order to achieve proper sub-grade preparation, selection of satisfactory materials, and placement and compaction of all structure fill, impacts would be reduced to level less than significant.

Overall, EIR No. 331 determined that with implementation of SCs 3-1, 3-2, and 3-3, MM 3-1, and MM 3-2, potential impacts associated with exposing people or structures to substantial adverse effects, including risk of loss, injury, or death involving rupture of a known earthquake fault, strong seismic ground shaking, and seismic-related ground failure, including liquefaction or landslides would be less than significant.

Proposed Project
Less Than Significant Impact with Mitigation. The Proposed Project would be developed within DA-5, which has been extensively graded and includes areas reclaimed after the closure of mining operations. The current site conditions and planned grading are documented in the Final Preliminary Report of Geotechnical Studies and Review of Preliminary Grading Plan for Tentative Parcel Map 2022-160, Gypsum Canyon Cemetery Site, City of Anaheim (GMU 2023). Grading for the development of DA 5 is anticipated to include mass grading the existing vacant parcel of land to create two large, contoured pad areas for cemetery development. The lower pad would be for a public cemetery for Orange County, while the upper pad would serve as the State veterans cemetery site. In general, the preliminary grading creates the following:
• Two large contour pads (i.e., lower and upper sites) separated by a 2:1 (horizontal:vertical) north-northeasterly trending slope with a maximum height of 175 feet. The majority of the upper pad would be divided into two levels by a 2:1 north to northeasterly trending slope with a maximum height of 19 feet. The mass-graded pads surface drain from 1 percent to 7 percent, with all pads ultimately draining to the south toward the perimeter access road, where future storm drain improvements would be located;
• A site access road along the southwesterly and southerly perimeters of the site adjacent to the Gypsum Canyon drainage; and
• A secondary access road in the south-central portion of the project site.

The maximum depths of design cut and fill are about 147 feet and 102 feet, respectively.

As the Proposed Project would be on the same site as analyzed in EIR No. 331, the geologic conditions relating to rupture of a known earthquake fault, strong seismic ground shaking, and seismic-related ground failure, including liquefaction or landslides would be the same as discussion in EIR No. 331. As such, the relevant goals, policies, standard conditions, and mitigation measures

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identified in EIR No. 331 are applicable to the development of the Proposed Project within DA 5.

With implementation of SC 3-1, requiring structures to be designed in accordance with the most recent seismic standards in the Anaheim Building Code; SC 3-2, requiring grading activities in conformance with the Anaheim Municipal Code, City Grading Design Manual, and Grading Plan Procedures; SC 3-3, requiring a preliminary geotechnical report; MM 3-1, requiring incorporation of recommendations of the preliminary geotechnical reports into final grading plans; and MM 3-2, requiring grading observation by a geotechnical professional, potential impacts associated with exposing people or structures to substantial adverse effects, including risk of loss, injury, or death involving rupture of a known earthquake fault, strong seismic ground shaking, and seismic-related ground failure, including liquefaction or landslides would be less than significant, and similar to the Approved Project.

Would the project result in substantial soil erosion or the loss of topsoil? Approved Project
Less Than Significant with Mitigation Incorporated. EIR No. 331 identified that during construction activities of the Approved Project (including on-site and off-site project features, the SR-241/Weir Canyon Road interchange, the bridge overcrossing, and SR-91 slope improvements), soil would be exposed and there would be an increased potential for soil erosion compared to existing conditions.

Additionally, during a storm event, soil erosion could occur at an accelerated rate. The increased erosion potential could result in short-term water quality impacts. These impacts would be reduced to a level considered less than significant through implementation PDF 5-1, which detailed BMPs to be included in the Final WQMP in accordance with the Orange County Drainage Area Management Plan/City of Anaheim Local Implementation Plan (DAMP/LIP), and SC 5-1, 5-2, and 5-3, which require a WQMP, coverage under the Construction General Permit, and compliance with the General Waste Discharge Requirements for construction dewatering, as described in Section 4.5, Water Quality of EIR No. 331.

The potential for erosion following completion of project development would be negligible with implementation of erosion control BMPs required in the Stormwater Pollution Prevention Plan (SWPPP) for the Approved Project. The requirement to prepare a SWPPP is identified in SC 5-2 as part of the Construction General Permit. Erosion control BMPs are designed to prevent erosion and include, but are not limited to slope stabilization using rock or revegetation, revegetation, and hydroseeding.

Therefore, EIR No. 331 determined potential erosion impacts would be less than significant with implementation of PDF 5-1, existing regulations, and SC 5-1, 5-2, and 5-3.

Proposed Project
Less Than Significant with Mitigation Incorporated. EIR No. 331 identified the potential for significant impacts, particularly during construction. Similar impacts are anticipated for the Proposed Project, including the potential for surface runoff from the Proposed Project area resulting in soil erosion, particularly during the soil-disturbing activities during construction. The Proposed Project is focused on DA 5. A WQMP has been prepared for the Proposed Project to address post- construction soil erosion. With implementation PDF 5-1 (as modified for the Proposed Project), and 3-33
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SCs 5-1, 5-2, and 5-3, as discussed in Section 3.5 Water Quality of this Addendum, potential impacts within DA 5 associated with soil erosion would be less than significant, similar to the Approved Project.

Would the project be located on a geologic unit or soil that is unstable or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse?
Approved Project
Less Than Significant with Mitigation Incorporated. EIR No. 331 described unsuitable materials as including soils/materials that are compressible and/or collapsible, such as topsoils, alluvium, colluvium, landslides, and fill materials. Following is a discussion of unsuitable soils related to the Proposed Project:
• Compressible/Collapsible Material: Potentially compressible and/or collapsible materials include topsoil, alluvium, colluvium, highly weathered bedrock, landslides, and undocumented fill. Consolidation tests on alluvial materials indicate potential for collapse under load and increase in moisture content. Removal of collapsible/compressible material would be required in areas where structural fill is required. Estimated depths of removal would be determined prior to approval of each grading plan.
• Fill Materials: In areas of deep fills, design options include the potential for increased compaction (above the current industry standard of 90 percent) and/or settlement monitoring (for the duration necessary to ensure that both the projected total and differential settlement estimates for a given area are within the limits at which structural improvement construction is conservatively acceptable) along with increased foundation recommendations (possibly including post-tensioned and/or deepened foundation systems). Prior to fill placement, loose and compressible materials would be removed where feasible. Removal bottoms would also be scarified and moisture conditioned, as necessary.
• Expansive Soils: Although the potential for expansive soils on the project site is considered “very low,” the potential exists and is considered a potentially significant impact. • Slope Stability/Cuts/Fills: EIR No. 331 identified the need to require remedial measures and/or stabilization measures throughout the project site. Cut and fill depths, as well as cut slope and fill slope heights, were described. EIR No. 331 also indicated the areas within each DA that would require remedial and stabilization measures as well as areas requiring structural setbacks.

All cut and fill slopes shall be planned at angles of 2:1 (horizontal to vertical) or less and are required to have a calculated factor of safety of 1.5 and 1.1 for static and pseudo-static conditions, respectively. Per the City of Anaheim Council Policy No. 5.3 regarding Hillside Grading/Contour Grading, some of the DA slopes may need to be redesigned at a steeper ratio than 2:1. Site specific recommendations for areas where steepened slopes may be planned include, but are not limited to, possible slope reinforcement. The Approved Project includes cut and fill slopes and EIR No. 331 identified a potential for slope failure if these slopes are not

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properly designed and constructed. As such, EIR No. 331 prescribed SCs 3-1, 3-2, 3-3, and MMs 3-1 and 3-2, as described above.

Proposed Project
Less Than Significant With Mitigation Incorporated. The current Final Preliminary Report of Geotechnical Studies and Review of Preliminary Grading Plan for Tentative Parcel Map 2022-160, Gypsum Canyon Cemetery Site City of Anaheim, prepared by GMU (June 2023), documents similar site soil conditions to those identified in EIR No. 331. The Proposed Project is focused on DA 5, and although there are no steep slopes, there is a need to address fill materials and the appropriate compaction requirements for the project area. The appropriate compaction would allow for development of DA 5 according to applicable building codes for structures and overall site grading.

With implementation of SC 3-1 through SC 3-3 and MM 3-1 and 3-2, potential impacts related to unstable geologic units or soils would be less than significant, and similar to the Approved Project.

Would the project be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial risk to life or property? Approved Project
Less Than Significant With Mitigation Incorporated. During the preparation of EIR No. 331, Table

4.3-2 was created to indicate the expansive potential of soils within each DA. In general, soils derived from surficial and bedrock materials are for the most part “very low” in expansion potential.

Isolated areas may produce more expansive materials; however, minimal amounts may be anticipated.

At the completion of rough grading, the soils engineer would collect representative samples of near- surface soil material and test it for expansion potential. Recommendations to compensate for the potential adverse effects of expansive soils would be provided for each area based on the results of this testing. Construction techniques that are employed to address potential adverse effects of expansive soils include (but are not limited to) deepened foundations, post-tension foundations and moisture conditioning. Potential impacts associated with expansive soils would be less than significant implementation of SCS 3-1, 3-2, and 3-3, and MMs 3-1 and 3-2 identified in EIR No. 331.

Proposed Project
Less Than Significant with Mitigation. The Proposed Project would require additional grading of the DA 5 area. As identified with the Approved Project, there is a “very low” potential for encountering expansive soils. With implementation of SCs 3-1 through SC 3-3 and MMs 3-1 and 3-2, potential impacts related to expansive soils would be less than significant, similar to the Approved Project.

Would the project conflict with any applicable plan, policy or regulation of an agency with jurisdiction over the project adopted for the purpose of avoiding or mitigating an environmental effect?
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Approved Project
Less Than Significant with Mitigation Incorporated. During the preparation of EIR No. 331, Table

4.3-4 was created to address the consistency of the Approved Project with the relevant goals and policies outlined in the City of Anaheim General Plan and SCAG’s RCPG. As identified in Table 4.3-4 of EIR No. 331, the Approved Project would be consistent with the relevant goals and policies of the Anaheim General Plan related to geology and soils, and to SCAG’s policies related to potential seismic hazards. With implementation of SC 3-1, 3-2, and 3-3, and MMs 3-1 and 3-2 outlined in EIR No. 311, potential geotechnical impacts associated with compliance with plans, policies, and regulations were determined to be less than significant.

Proposed Project
Less Than Significant with Mitigation Incorporated. The Proposed Project is focused on DA 5, but the relevant goals and policies identified in EIR No. 331 are appropriate for the cemetery development as well. The Proposed Project would continue to be consistent the relevant goals and policies similar to the Approved Project. With implementation of SCs 3-1 through SC 3-3 and MMs 3-1 and 3-2, potential geotechnical impacts related to compliance with plans, policies, and regulations related to would be less than significant, similar to the Approved Project

3.3.3 Cumulative Geology and Soils Impacts
Approved Project
Less Than Cumulatively Considerable Impact. EIR No. 331 found that potential cumulative impacts related to geology and soils are site-specific and cannot be comprehensively assessed on a cumulative basis. While geotechnical impacts may be associated with the foreseeable projects, by the very nature of the impacts (i.e., landslides and expansive and compressible soils) the constraints are site-specific. EIR No. 331 noted that the Approved Project, as well as the foreseeable projects, would be required to comply with the applicable State and local requirements, including, but not limited to, the CBC and the Grading Code (City of Anaheim Title 17–Land Development and Resources). As such, impacts specific to the Approved Project, as well as the impacts associated with other projects, would be reduced to a less than significant level. Because seismic impacts would be considered a regional issue and are also addressed through compliance with applicable codes and design standards, the project’s contribution to cumulative geotechnical and soils impacts was considered less than significant.

Proposed Project
Less Than Cumulatively Considerable Impact. As stated above for the Approved Project, the potential cumulative impacts related to geology and soils are site-specific and cannot be comprehensively assessed on a cumulative basis. The explanation of why cumulative impacts for the Approved Project cannot be assessed would be appropriate for the Proposed Project as well.

Through compliance with applicable codes and design standards, the Proposed Project would result in a less than cumulatively considerable impact to geology and soils, similar to the Approved Project.

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3.3.4 Findings Related to Geology and Soils

3.3.4.1 No New Significant Effects Requiring Major Revisions to the Certified EIR Based on the foregoing analysis and information, there is no evidence that the Proposed Project requires a major change to EIR No. 331. The Proposed Project would not result in new significant environmental impacts related to geology and soils, and there would not be a substantial increase in the severity of impacts described in EIR No. 331.

3.3.4.2 No Substantial Change in Circumstances Requiring Major Revisions to the Certified EIR No major changes to the Specific Plan Area have taken place since preparation of EIR No. 331 that would require revisions to the analysis in EIR No. 331. There is no information in the record or otherwise available that indicates that there are substantial changes in circumstances pertaining to geology and soils that would require major changes to EIR No. 331.

3.3.4.3 No New Information Showing Greater Significant Effects than the Certified EIR This Addendum has analyzed available relevant information to determine whether there is new information that was not available at the time of EIR No. 331, indicating that a new significant effect not reported in that document may occur. Based on the information and analyses above, there is no substantial new information indicating that there would be a new significant impact related to geology and soils requiring major revisions to EIR No. 331.

3.3.4.4 No New Information Showing the Ability to Reduce Significant Effects in the Certified EIR There is no new information, mitigation, or alternatives to the Proposed Project that would substantially reduce one or more significant impacts pertaining to geology and soils identified and considered in EIR No. 331.

3.3.5 Standard Conditions and Mitigation Measures
Standard Conditions (SC) 3-1 through SC 3-3 were prescribed to the Approved Project and would remain applicable to the Proposed Project as they would pertain to features or activities of the Proposed Project, including seismic standards and grading.

SC 3-1 Prior to issuance of each building permit, the property owner/developer shall demonstrate that each structure has been designed in accordance with the most recent seismic standards in the CBC (California Building Code)ABC (Anaheim Building Code) and approved by the Chief Building Official. The CABC contains provisions that regulate the design and construction of excavations, foundations, retaining walls and other building elements to control the effects of seismic ground shaking and adverse soil conditions.

SC 3-2 Prior to issuance of building permits, the property owner/developer shall submit building pad certifications to the Department of Public Works, as required in Code Section 17.06, documenting that grading has been completed in conformance with the Anaheim Municipal Code, Title 17-Land Development and Resources, the City of 3-37
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Anaheim Grading Design Manual and Grading Plan Procedures, and the Mountain Park Specific Plan Grading Concept and Hillside Grading and Landscape Policies.

SC 3-3 In compliance with the Anaheim Municipal Code, prior to approval of each mass grading plan, the property owner/developer shall submit a preliminary geotechnical report prepared by an engineering geologist and geotechnical engineer to the Department of Public Works for review and approval. This report shall be prepared to the satisfaction of the City Engineer and shall address soil and geology related constraints and hazards identified in EIR No. 331 such as slope stability, settlement, liquefaction, and related secondary seismic hazards. For grading within Caltrans right-of-way, a preliminary geotechnical report shall be submitted and approved by Caltrans. Specifically, the report shall:
• Include an assessment of potential soil related constraints such as stability of proposed cut, fill and natural slopes. Conduct further subsurface exploration to refine geologic structure for cut slope stability. If the report finds stabilization necessary, grading plans shall require corrective measures to address the need for stabilization;
• Include an assessment of on-site landslides and appropriate corrective measures, such as further subsurface exploration of landslide areas beneath planned fills and development areas. Corrective measures would include complete removal, if feasible or stabilization or buttressing of the landslide. This would involve partial removal of the landslide and stabilizing potential future movement with earthen fill or reinforced materials;
• Include subsurface exploration of alluvial and canyon drainage areas beneath planned fills or development areas;
• Evaluate excavation characteristics of on-site earth materials; • Include subsurface exploration to refine geologic structure for cut slope stability;
• Establish specific remedial grading requirements, including but not limited to establishing parameters for stabilization/ buttressing of slopes, removal of unstable soil materials;
• Provide grading, foundation, and structural design recommendations based on findings of future geotechnical investigations;
• Address settlement, liquefaction, and structural design recommendations.

Grading plans shall incorporate removal, where feasible, of all potentially liquefiable alluvium. The grading plans shall also incorporate placement of engineered fill in the canyons and installation of a subdrain system;

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• Address the potential for expansive soils. Representative soil samples of near surface soil material shall be collected and tested for expansion potential after the completion of rough grading on site. Expansive soils that are detrimental to the project shall be subject to special building/foundation design, deepened foundations, post-tension foundations, soil removal, selective grading to blend highly expansive soils with soils of low expansivity, moisture conditioning, or other corrective measures as recommended by a licensed soils/geotechnical engineer and approved by the City Engineer prior to approval of each grading plan;
• Include an evaluation of potentially corrosive soils and recommend appropriate corrective measures. If corrosive soils are found, corrective measures shall be incorporated into the grading plans;
• Address collapsible/compressible material. This material shall be subject to removal or other corrective measures in all areas planned for structural fill.

Topsoil, colluvium, alluvium, highly weathered bedrock, and landslide materials with settlement potential shall be subject to corrective measures such as removal and recompaction, surcharging, settlement monitoring, and/or other measures deemed appropriate by the geotechnical engineer of record and approved by the City Engineer prior to approval of each grading plan; • Include appropriate laboratory testing to define soil engineering parameters; • Include additional refraction lines to better ascertain rock hardness and rippability for specific planned cut areas;
• Include a review of seismic and faulting conditions on site. Seismic design parameters identified for the project shall be incorporated into project design as applicable. Caltrans seismic design criteria for the proposed overcrossings shall be incorporated into overcrossing design and implementation; and, • Corrective work within Caltrans right-of-way shall be done in accordance with Caltrans standard specifications.

EIR No. 331 prescribed Mitigation Measures (MM) 3-1, 3-2, and 3-3 pertaining to geology and soils.

MMs 3-1 and 3-2 would remain applicable to the Proposed Project; however, MM 3-3, which requires the submittal of a blasting plan prior to commencement of any blasting activities, would no longer apply as no blasting is proposed during construction of the Proposed Project.

MM 3-1 Prior to the approval of each rough grading plan, the property owner/developer shall submit a site specific geotechnical report prepared by a civil engineer based on recommendations of the preliminary geotechnical reports required under SC 3-3 to the Department of Public Works for review and approval. Site-specific geotechnical studies shall provide specific feasible recommendations for soils engineering, appropriate drains and subdrains in each Development Area, and address the 3-39
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potential for artesian conditions in Development Areas 1 and 2. As part of addressing the potential effects of groundwater on slope stability during future site specific investigations, the property owner/developer shall obtain and provide data from piezometers installed through the alluvium of Gypsum Canyon into the underlying bedrock, near proposed toe of slopes. The piezometers should be monitored for a period of one year to evaluate the potential artesian conditions with consideration for seasonal fluctuations in groundwater elevations.

MM 3-2 Prior to the approval of each grading plan, a note shall be added to the grading plan requiring that during grading operations, all grading and earthwork shall be performed under the observation of a registered geotechnical engineer in order to achieve proper sub-grade preparation, selection of satisfactory materials, and placement and compaction of all structural fill. An engineering geologist shall map cut slopes during grading to identify any laterally continuous, adversely oriented, broken, or fractured zones that may reduce slope stability. The note shall be prepared to the satisfaction of the Department of Public Works.

3.4 HYDROLOGY

3.4.1 Existing Environmental Setting
The City lies within Region 8 (Santa Ana) of the California Regional Water Quality Control Board’s (RWQCB) jurisdiction. The Santa Ana River is the main surface watercourse within Anaheim and provides roughly 70 percent of the total groundwater recharge for the Santa Ana River basin. Water flow is regulated by the Prado Dam, Seven Oaks Dam, and other flood-control facilities. The river’s unlined channel bottom consists of permeable sandy material and is directly connected to pervious alluvial materials that allow for the transfer of water into the underlying aquifers.

According to EIR No. 331, the Specific Plan Area is located within the Santa Ana River Basin and within the Santa Ana River regional watershed. The Specific Plan Area incorporates a majority of the Gypsum Creek local watershed, as well as a West drainage area, East drainage area, and several freeway drainage areas, including the SR-91 drainage area, the SR-91/SR-241 drainage area, and the SR-91/Gypsum Canyon Road drainage area.

The project site, which represents DA 5 of the Specific Plan Area, is located in the northwest corner of the Specific Plan Area and incorporates a portion of the Gypsum Canyon watershed and East drainage area, which influences the SR-91 and SR-91/Gypsum Canyon Road drainage areas. The Gypsum Canyon watershed is approximately 3,379 acres and is primarily natural, with the exception of some modifications made by the sand and gravel extraction operations in the northeast corner of the Specific Plan Area and the construction of SR-241. Elevations in Gypsum Canyon range from approximately 340 feet amsl to 2,200 feet amsl with steep slopes ranging from 30 to 75 percent.

The East drainage area is approximately 155 acres and comprises two sub-drainage areas, East A and East B. East A is approximately 37 acres and drains toward SR-91 via natural drainage courses, including a portion of the existing quarry operations associated with Robertson’s Ready Mix. The remaining area (East B) of approximately 118 acres drains northeast via natural drainage courses toward SR-91 and the Coal Canyon Biological Corridor and also contains a minor portion of the

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quarry operations. The existing quarry operation extends approximately 6 acres into the East drainage area divided among the two sub-drainage areas.

The SR-91 and SR-91/Gypsum Canyon Road drainage areas collect flows within the project boundary and adjacent off-site areas and direct them north to the Santa Ana River.

According to the Preliminary Drainage Report for Public and Proposed Veterans Cemetery at Gypsum Canyon (Preliminary Drainage Report) prepared by Huit Zollars and dated October 6, 2023, and the County of Orange/Santa Ana Region Priority Project Preliminary Water Quality Management Plan (PWQMP) prepared by Huit Zollars and dated October 9, 2023, under existing conditions, the project site comprises two watershed conditions, the Upper and Lower Pads, and contains eight site outlets, a natural channel in the south, and Gypsum Creek. The Upper Pad comprises the eastern half of the project site and the Lower Pad comprises the western half. Under existing conditions, runoff from the Lower Pad either flows west to one of two site outlets that flow to the unlined Gypsum Creek, or north to three site outlets that flow to the Santa Ana River. Run off from the Upper Pad in the east either flows west to one of two site outlets that flow to Gypsum Creek, or north to one outlet that flows to the Santa Ana River. The natural channel in the south conveys off- site flows on site and eventually discharges into Gypsum Creek. Gypsum Creek flows across the western edge of the project site from south to north and discharges into the Santa Ana River (Reach 2). Gypsum Creek is an earthen channel that is subject to both upstream flows from Gypsum Canyon and the influence of the floodplain from the Santa Ana River. During large storm events, flow depths exceed the channel capacity from Gypsum Canyon due to the backwater effect of the Santa Ana River floodplain.

3.4.2 Comparison of Impacts for the Approved Project and the Proposed Project The Proposed Project would develop the 283.28-acre project site, which represents DA 5 of the Specific Plan Area, with a public cemetery and a State veterans cemetery instead of 1,595 dwelling units, including 770 single-family detached residential units and 825 single-family attached residential units, a private recreation center, a water reservoir, on-site roadways (including roundabout at Gypsum Creek), utility infrastructure, manufactured slopes with landscaping, a trailhead/staging area, relocation of the Questar pipeline, and fuel modification areas. All other elements of the Approved Project would remain as described in EIR No. 331 and would result in the same impacts analyzed and disclosed in EIR No. 331. As such, this analysis focuses on the potential hydrological impacts of the Proposed Project on the project site (i.e., DA 5).

As previously discussed, during preparation of the Mountain Park Initial Study, the City determined that implementation of the Approved Project would not result in significant impacts related to exposing people or structures to a significant risk of loss, injury, or death involving flooding, including flooding as a result of a dam or levee failure, or inundation by seiche or mudflow. As such, no further analysis is presented in EIR No. 331 relating to those issue areas. As implementation of the Proposed Project would occur on a portion of the same site analyzed in EIR No. 331 (DA 5), impacts related to flooding as a result of a dam or levee failure, or inundation by seiche or mudflow are expected to be similar to the Approved Project. Impacts would be less than significant, similar to the Approved Project.
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Would the project create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff.

Approved Project
Less Than Significant Impact. According to EIR No. 331, implementation of the Approved Project would result in approximately 76 percent of DA 5 being impervious, including roofs, concrete walkways, and roads, while 24 percent of the site would remain pervious, including lawns and landscaped areas. EIR No. 331 analyzed the capacity of the existing drainage system to determine the peak discharge for a 100-year design storm event to ensure all existing and proposed storm drain facilities are sufficiently sized to meet the flood protection goals of the OCHM and the City of Anaheim’s Drainage Design Manual (CADDM). As detailed in EIR No. 331, the comparative analysis performed for the pre- and post-development runoff indicated that the flow rate from Gypsum Canyon would increase from 1,030 cubic feet per second (cfs) to 1,100 cfs under a 2-year storm event, 1,640 cfs to 1,760 cfs under a 5-year storm event, 2,520 cfs to 2,680 cfs under a 10-year storm event, 3,230 cfs to 3,430 under a 25-year storm event, 3,480 cfs to 3,700 cfs under a 50 year storm event, and 3,990 cfs to 4,240 cfs under a 100-year storm event with implementation of the Approved Project.

Based on this analysis, EIR No. 331 determined that development of the Approved Project within DA 5 would contribute to the exceedance of the capacity of the inlet of the existing Gypsum Canyon Road/SR-91 box culvert within the SR-91/Gypsum Canyon Road drainage area. However, the Approved Project included a Runoff Management Plan (RMP), as detailed in PDF 4-1, which included improvements to this box culvert improvements to this box culvert, including the extension of the culvert upstream to the inlet control, that would alleviate current flooding onto Gypsum Canyon Road during large storm events and accommodate the increase of storm flows from the Approved Project.

EIR No. 331 also determined that although flows to Gypsum Creek would increase with development within DA-5, the increase would be less than significant from a hydrologic and flood control standpoint as there are no structures, homes, or facilities that would be impacted by the overbank flows in the existing or post-development conditions. Further, the Approved Project included measures, detailed in PDF 4-1 to minimize scour and erosion for post-development flows of smaller storm events that remain within the channel and are not impacted by the backwater effect of the Santa Ana River.

EIR No. 331 also indicated that although 10 acres of the East drainage area would be incorporated into DA 5, no development would occur within post-condition East A and East B sub-drainage areas, and the reduction of drainage area and peak flows would not result in any hydrologic impacts to the existing drainage facilities. In addition, no runoff from the DAs would drain toward the East drainage area drainage facilities.

EIR No. 331 indicated that the Approved Project would also implement an RMP (PDF 4-1), including a three-component storm flow drainage system consisting of: (1) a high-flow bypass line for collecting off-site drainage from undisturbed areas within the project boundary and routing around the DAs, (2) an on-site storm drain system to collect high flows from the DAs, and (3) a low-flow

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water quality system to divert initial storm flows and dry-weather flows from the DAs to a series of water quality basins and/or other structural water quality BMPs without increasing flooding or capacity hazards to the downstream receiving waterbody. In the eastern portion of the Specific Plan Area, including DA 5, the flows would be delivered to Gypsum Creek and other tributary areas dependent upon the locations of the water quality basins and the storm drain outlets, then to the Santa Ana River. At each discharge point, measures would be implemented to reduce the velocity of flow (i.e., riprap, check dams), extend the drain to a stabilized outlet, and provide a flow path barrier to minimize scour and erosion of these outlets. Further, the majority of flows from the eastern DA would ultimately end up at the previously discussed SR-91/Gypsum Canyon Road culvert extension, adjacent to DA 5, before discharging through the culvert into the Santa Ana River. The culvert modification detailed in PDF 4-1 of the Approved Project would allow for the proper hydraulic head to convey flows from storm events, including the 100-year storm and alleviate existing flooding.

Overall, EIR No. 331 determined that peak flows would not exceed the capacity of the existing or planned stormwater drainage system improvements.

The high-flow bypass system described in EIR No. 331 included a series of storm drain pipes that would collect runoff from the undeveloped portions of the site and route flows around the developed areas. This system would serve to maintain existing drainage patterns and would also avoid interference with the runoff from the DAs. EIR No. 331 indicated that the high-flow bypass system and on-site storm drain system (described below) would combine to result in eight primary discharge points within the Specific Plan Area that would drain into natural drainage courses within Gypsum Canyon. EIR No. 331 stated that these primary discharge points would undergo changes to pre-development run-off quantities and would be subject to the confluence of storm flows, increases in velocity and scour potential, and potential habitat conversion. However, in conjunction with the preparation of final storm drain improvement plans, countermeasures for the potential environmental impacts to the natural drainage courses for each primary discharge point would be accomplished by the design of the outlet structures to transition high-velocity piped flows into non- erosive open channel flows for the protection of downstream habitats and channel stability. Further, the length and width of the outlet countermeasures would vary dependent upon the natural characteristics of the downstream channel. Overall, EIR No. 331 concluded that all facilities would be designed to assure the post-development runoff condition would be transitioned into the natural environment in a manner that ensures less than significant impacts to the natural drainage courses and habitat.

As detailed in EIR No. 331, the on-site storm drain system, including a series of catch basins and laterals, would strategically collect and deliver runoff from the graded DAs and roadways to the main storm drain lines to minimize the threat of on-site flooding. Within DA 5, EIR No. 331 indicated that flows would travel through the on-site storm drain system to a main storm drain line that would connect directly to Gypsum Creek, as discussed above. Where flows are discharged to Gypsum Creek or other natural areas, the Approved Project included design features to diffuse the flows, reduce velocity, and deliver the storm flows in a manner that avoids environmental harm to the existing habitat and maintains the stability of the creek. Therefore, EIR No. 331 determined that the design of the on-site storm drain system would prevent on-site flooding and reduce potential impacts to less than significant levels.
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Further, EIR No. 331 indicated that implementation of the approved water quality treatment system would result in controlled discharges of storm flows from the water quality basins into natural drainage courses through the use of energy diffusers and scour protection, or through direct connections back to the main storm drain lines after treatment.

Overall, EIR No. 331 concluded that with implementation of the PDFs discussed above, development of the Approved Project, including development within DA 5, would not result in a significant impact on existing or planned drainage facilities within the Specific Plan Area or downstream of the site.

These PDFs were determined based on the Approved Project specific hydrology/drainage report and WQMP to manage post-development stormwater flows in order to ensure that flows would not exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff. Therefore, EIR No. 331 determined that impacts would be less than significant.

Proposed Project
Less Than Significant Impact. Implementation of the Proposed Project would develop the project site (DA 5) with a public cemetery and a State veterans cemetery. The Proposed Project would result in approximately 10 percent of the site being impervious, including roofs, concrete walkways, and roads, while 90 percent of the site would remain pervious, including open space, landscaped areas, and burial areas. This represents a significant reduction in impervious surface area within DA 5 as compared to the Approved Project, which would result in approximately 76 percent of impervious surface area. As such, implementation of the Proposed Project is expected to result in less stormwater runoff compared to the Approved Project due to the significant decrease in impervious surface area. Development of the Proposed Project would maintain the existing drainage pattern of the site, and all areas would be graded to allow runoff to drain toward a designed private road or area drain, leading to the proposed storm drain infrastructure.

The Preliminary Drainage Report prepared for the Proposed Project analyzed the hydrology of the project site with implementation of the Proposed Project, analyzed the capacity of the existing drainage system, and discussed the proposed improvements for on-site drainage to convey flow effectively and prevent flooding of downstream facilities. According to the hydrologic analysis performed, implementation of the Proposed Project would increase flow rate and decrease time of concentration compared to existing conditions. As discussed in the PWQMP, the comparative analysis performed for the pre- and post-development runoff volumes resulting from a 2-year 24-hour storm event indicated that the runoff volumes from the project site would decrease from 1,161,745 cubic feet (cf) to 788,436 cf with implementation of the Proposed Project. Further, the Preliminary Drainage Report indicated that the flow rate of runoff from the project site would increase from 292.34 cfs to 345.75 cfs under a 2-year storm event, 616.78 cfs to 695.56 cfs under a 10-year storm event, 764.15 cfs to 850.37 cfs under a 25-year storm event, and 1,020.40 cfs to 1,116.23 cfs under a 100-year storm event with implementation of the Proposed Project. This change in flow characteristics is a result of the changes in acreage, flow length, slope, land use, and flow type between the existing and proposed conditions.

Similar to the Approved Project, the Proposed Project would also implement an RMP pursuant to PDF 4-1; however, the RMP would be modified to address the specific runoff conditions of DA 5. The

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proposed RMP includes a three-component storm flow drainage system consisting of: (1) a high- flow bypass line for collecting off-site drainage from undisturbed areas within the project boundary and routing around the DA, (2) an on-site storm drain system to collect high flows from the project site, and (3) a low-flow water quality system to divert initial storm flows and dry-weather flows from the project site to a series of water quality basins and other structural water quality BMPs without increasing flooding or capacity hazards to the downstream receiving water body. These components are discussed in greater detail below. Similar to the Approved Project, all proposed storm drain infrastructure such as grate inlets, curb and gutters, and storm drain pipes would be sized per CADDM and OCHM standards.

The on-site storm drain system would collect on-site runoff and direct it to one of two UDSs, which would mitigate flow rate from the proposed development to lower than the existing runoff level.

Before draining to the Gypsum Creek, flows would then pass through the Saint Anthony Falls (SAF) Energy Dissipator, which is designed to reduce the flow velocity and avoid erosion of the creek banks and channel. Further, the Preliminary Drainage Report indicated that the existing trapezoidal channel along the north edge of the project site, which would collect flows from the easternmost slope of the Upper Pad, would have sufficient capacity to convey those flows to Gypsum Creek.

Overall, the Preliminary Drainage Report determined that with implementation of the UDS and SAF Energy Dissipater, flows from the proposed development would be sufficiently mitigated.

In addition, two aboveground and lined DEDBs, which would be located upstream of the two UDSs, and three Modular Wetland Systems are proposed for stormwater treatment benefits and would strategically collect and deliver runoff from the project site to the main storm drain lines to minimize the threat of on-site flooding, similar to the Approved Project. The DCV would be diverted from each pad to a DEDB using a flow splitter, which is designed for biofiltration of the DCV from a 24-hour, 85th percentile storm event and discharge of the same volume over 48 to 72 hours. During heavy storm events, an emergency spillway would allow overflow of the DEDB. The three Modular Wetland Systems are placed along the approach road to collect and treat runoff from the road as well as the bridge.

Further, the storm drain system would be designed to prevent off-site low flows from entering the system. Off-site flows from the southeast would be conveyed to Gypsum Creek via a series of storm drain inlets and pipes and would confluence with treated on-site flows and discharge into an energy dissipater before discharging into Gypsum Creek.

Overall, with implementation of PDF 4-1 discussed above, development of the Proposed Project would not result in a substantial impact on existing or planned drainage facilities within the project site or downstream of the site. Although the proposed PDF 4-1, which requires implementation of an RMP, included in the Proposed Project would PDF 4-1 of the Approved Project, the measures contained within the PDF would accomplish the same purpose of managing post-development stormwater flows in order to ensure that flows would not exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff.

Therefore, the proposed PDF 4-1 would replace the Approved Project PDF 4-1.Similar to the Approved Project, the measures contained in PDF 4-1 were determined based on a project-specific Preliminary Drainage Report and PWQMP. Impacts would be less than significant, similar to the Approved Project.
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Would the project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, in a manner which would result in substantial erosion or siltation on-site or off-site?
Approved Project
Less Than Significant Impact. EIR No. 331 indicated that implementation of the Approved Project would change the topography and land cover of the Specific Plan Area and would introduce new impervious surfaces as well as result in grading impacts, which would affect existing erosion conditions. EIR No. 331 identified three major changes with implementation of the Approved Project that would influence soil movement, including decreased erodible area due to the addition of impervious areas, overall decrease in slopes due to grading activities, and increased peak flow rate and runoff volume.

Because implementation of the Approved Project would significantly increase the impervious surface area of the Specific Plan Area, including within DA 5, sheet erosion would decrease in developed areas. Sheet erosion is commonly linked to downstream water quality impacts and causes increased turbidity. EIR No. 331 also indicated that the most significant factor leading to the substantial reduction in sheet erosion is the prior development of the quarry site located in the northeast portion of the Specific Plan Area, within DA 5, which accounts for roughly one-third of the estimated sheet erosion in the existing condition. EIR No. 331 indicated that upon termination of the quarry operations, the approved reclamation plan would result in the improvement of erosion control measures to reduce the impacts of the quarry on the existing erosion rate. Because implementation of the Approved Project would decrease sheet erosion at the site, EIR No. 331 determined that implementation of the Approved Project would significantly reduce siltation both on and off site.

EIR No. 331 also indicated that the total debris and sediment yields from the Gypsum Canyon watershed would decrease with implementation of the Approved Project. Because the Approved Project would introduce landscaping and new impervious surfaces, debris and sediment would mostly be attributed to fine materials like silt and clay that primarily come from overland flow and erosion. This reduction in debris and sediment yield would result in less deposition downstream and could adversely impact downstream waterbodies if the Specific Plan Area represents a significant source of sediment to the downstream waterbody. However, EIR No. 331 indicated that Gypsum Canyon represents less than 1 percent of the total drainage area contributing runoff and sediment to Reach 2 of the Santa Ana River and the existing annual sediment yield for Gypsum Canyon in comparison to the annual sediment yield of the Santa Ana River represents less than 1 percent of the total sediment contributions. As such, EIR No. 331 determined that the reduced sediment and debris yield with implementation of the Approved Project accounts for a negligible fraction of the total sediment inputs to the river. Overall, EIR No. 331 concluded that implementation of the Approved Project would not substantially alter the existing drainage pattern of the site or area in a manner that would result in substantial erosion or siltation on-site or off-site, and impacts would be less than significant.

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Proposed Project
Less Than Significant Impact. Implementation of the Proposed Project would develop the project site (DA 5) with a public cemetery and State veterans cemetery. The Proposed Project would result in approximately 10 percent of the site being impervious, including concrete walkways and roads, while 90 percent of the site would remain pervious, including open space, landscaped areas, and burial areas. This represents a significant reduction in impervious surface area within DA 5 as compared to the Approved Project. Development of the Proposed Project would maintain the existing drainage pattern of the site, and all areas would be graded to allow runoff to drain toward a designed private road or area drain, leading to the proposed storm drain infrastructure.

As previously discussed, the Proposed Project would include an RMP (PDF 4-1) and measures to ensure that downstream impacts due to erosion or siltation would be less than significant, including two UDSs, SAF Energy Dissipator, two DEDBs, and three Modular Wetland Systems. The on-site storm drain system would collect on-site runoff and direct it to one of two UDSs, which would mitigate flow rate from the proposed development to lower than the existing runoff level. Before draining to the Gypsum Creek, flows would then pass through the SAF Energy Dissipator, which is designed to reduce the flow velocity and avoid erosion of the creek banks and channel. In addition, two above-ground and lined DEDB and three Modular Wetland Systems are proposed for stormwater treatment benefits and would strategically collect and deliver runoff from the project site to the main storm drain lines to minimize the threat of on-site flooding and reduce water quality impacts associated with erosion and siltation, similar to the Approved Project. The three Modular Wetland Systems are placed along the approach road to collect and treat runoff from the road as well as the bridge.

Since the certification of EIR No. 331, quarry operations within the project have ceased and the BMPs, including erosion control measures, detailed in the approved reclamation plan have been implemented at the quarry site. As such, sheet erosion at the project site has reduced since certification of EIR No. 331. Although implementation of the Proposed Project would result in less impervious surface area within DA 5 as compared to the Approved Project, the majority of the project site would be landscaped, which would reduce the amount of sheet erosion and siltation that occurs on the project site. This additional landscaping would also result in a decrease of total debris and sediment yields from the Gypsum Canyon watershed, although to a lesser extent than the Approved Project. Nevertheless, because the Proposed Project would occur on the same site analyzed in EIR No. 331 and Gypsum Canyon represents less than 1 percent of the total drainage area contributing runoff and sediment to Reach 2 of the Santa Ana River, the reduced sediment and debris yield with implementation of the Proposed Project would account for a negligible fraction of the total sediment inputs to the river, similar to the Approved Project.

Overall, because implementation of the Proposed Project would provide landscaping across the majority of the project site and the Proposed Project includes design features and measures to address erosion and siltation impacts, implementation of the Proposed Project would not substantially alter the existing drainage pattern of the site or area in a manner that would result in substantial erosion or siltation on-site or off-site. Impacts would be less than significant, similar to the Approved Project.
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Would the project create the potential for significant changes in the flow velocity or volume of stormwater runoff to cause environmental harm?
Approved Project
Less Than Significant Impact. EIR No. 331 analyzed the potential for significant changes in the flow velocity and volume of stormwater runoff to cause environmental harm using the United States Army Corps of Engineers (ACOE) Hydrologic Engineering Center-River Analysis System (HEC-RAS).

The results of the analysis indicated that the 100-year storm event would cause the greatest increase in water surface elevation and channel velocities for Gypsum Creek. Therefore, EIR No. 331 indicated that PDFs 4-1 and 4-2 would be implemented to address changes in the flow velocity and volume of stormwater runoff and would be designed to meet a 100-year storm event.

EIR No. 331 also included a sediment and scour analysis for Gypsum Creek to determine sediment transport impacts on the creek. The analysis found that sediment would still accrete and deplete within the influence of the extended culvert depending on the size of the storm event similar to existing conditions, because Gypsum Creek would be subject to increased discharges due to increases in impervious surface area with implementation of the Approved Project and scour and deposition would occur at a slightly high rate. However, EIR No. 331 determined that this anticipated increase would not result in any additional impacts such as required maintenance of the culvert inlet or reduction of sediment delivery downstream.

Overall, EIR No. 331 determined that changes in the flow velocity or volume of stormwater runoff with implementation of the Approved Project would not result in substantial soil erosion or any other adverse environmental effect with implementation of PDFs 4-1 and 4-2 intended to address changes in the flow velocity or volume of stormwater runoff. As previously discussed, these PDFs were determined based on the Approved Project-specific hydrology/drainage report and WQMP to manage post-development stormwater flows. Impacts would be less than significant.

Proposed Project
Less Than Significant Impact. As previously discussed, the Proposed Project would include an RMP (PDF 4-1) and measures intended to address changes in the flow velocity and volume of stormwater runoff due to implementation of the Proposed Project, similar to the Approved Project. The on-site storm drain system would collect on-site runoff and direct it to one of two UDSs, which would mitigate flow rate from the proposed development to lower than the existing runoff level. Before draining to the Gypsum Creek, flows would then pass through the SAF Energy Dissipator, which is designed to reduce the flow velocity and avoid erosion of the creek banks and channel. In addition, two above-ground and lined DEDBs and three Modular Wetland Systems are proposed for stormwater treatment benefits and would strategically collect and deliver runoff from the graded DAs and roadways to the main storm drain lines to minimize the threat of on-site flooding and reduce water quality impacts associated with erosion and siltation, similar to the Approved Project.

Further, the hydrologic analysis performed as part of the Preliminary Drainage Report prepared for the Proposed Project determined that the UDSs would successfully mitigate increased flow from the proposed development.

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In addition, because implementation of the Proposed Project would result in the development of substantially less impervious surface area within the project site (DA 5) as compared to the Approved Project, peak flows from Gypsum Canyon and the project site are anticipated to be less than with implementation of the Approved Project. As such, changes in the flow velocity or volume of stormwater runoff from the project site with implementation of the Proposed Project is expected to be less than with implementation of the Approved Project and would be expected to result in decreased impacts associated with changes in the flow velocity or volume of stormwater runoff.

As the Proposed Project would implement an RMP (PDF 4-1) and measures to address changes in the flow velocity or volume of stormwater runoff with implementation of the Proposed Project, impacts would be less than significant, similar to the Approved Project. As previously discussed, although the proposed PDF 4-1, which requires implementation of an RMP, included in the Proposed Project would be different than PDF 4-1 of the Approved Project, the measures contained in the RMP would accomplish the same purpose of managing post-development stormwater flows.

Therefore, the proposed PDF 4-1 would replace the Approved Project PDF 4-1. In addition, similar to the Approved Project, these PDFs were determined based on a project-specific Preliminary Drainage Report and PWQMP. PDF 4-2 detailed in EIR No. 331 addressed construction activities within Caltrans rights-of-way and were not prescribed to Approved Project components within DA 5.

Therefore, PDF 4-2 is not applicable to the Proposed Project. Impacts would be less than significant, similar to the Approved Project.

Would the project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, or substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site? Approved Project
Less Than Significant Impact. As previously discussed, EIR No. 331 indicated that implementation of the Approved Project would not result in a substantial increase in the rate or amount of surface runoff in a manner that would exceed the capacity surrounding drainage facilities with incorporation of PDFs and measures. In addition, EIR No. 331 stated that the results of the HEC-RAS analysis indicated that the average pad elevation for each DA exceeded the 100-year flood elevation by at least 13 feet, thereby meeting the main drainage goal for the Approved Project and ensuring homes would not be impacted by the 100-year flood conditions. Further, the approved development plan and impact area largely avoided encroachment upon the mainstem of Gypsum Creek, thereby eliminating the threat of potential flooding to all structures.

In addition, although peak flows would increase in the 100-year storm event due to increases in impervious surface area, the HEC-RAS results showed that with the improvements to the Gypsum Canyon Road/SR-91 Culvert, as previously discussed, the drainage infrastructure could accommodate the developed condition storm flows without presenting a flood hazard. EIR No. 331 also indicated that implementation of the RMP, including a three-component storm flow drainage system, as previously described, would ensure that development of the Approved Project would not result in on-site flooding.
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EIR No. 331 also indicated that the flood control infrastructure of the Santa Ana River has been designed to accommodate peak flows from Gypsum Canyon in excess of what would be generated by the Approved Project. Therefore, EIR No. 331 concluded that the Santa Ana River would not be adversely impacted by increases in peak flow and would not result in off-site or downstream flooding.

Overall, EIR No. 331 concluded that with implementation of PDF 4-1 previously discussed, including improvements to the Gypsum Canyon Road/SR-91 box culvert, and other design features to minimize scour and erosion for post-development flows, diffuse the flows, and reduce velocity of the storm flows,, development of the Approved Project, including development within DA 5, would not result in substantial on- or off-site flooding. As previously discussed, these PDFs were determined based on the Approved Project-specific hydrology/drainage report and WQMP to manage post-development stormwater flows.

Proposed Project
Less Than Significant Impact. Similar to the Approved Project, implementation of the Proposed Project would not result in a substantial increase in the rate or amount of surface runoff in a manner that would exceed the capacity of surrounding drainage facilities with implementation of an RMP (PDF 4-1). In addition, as the Proposed Project would develop a public cemetery and State veterans cemetery on the project site, implementation of the Proposed Project would not result in the construction of homes or other habitable structures within the project site that could be adversely impacted by flood conditions.

Similar to the Approved Project, the Proposed Project would also implement an RMP including a three-component storm flow drainage system, as previously described, that would ensure development of the Proposed Project would not result in on-site flooding.

Because implementation of the Proposed Project would result in the development of less impervious surface area within the project site (DA 5) as compared to the Approved Project, peak flows from Gypsum Canyon and the project site are anticipated to be less than with implementation of the Approved Project. Since EIR No. 331 indicated that flood control infrastructure of the Santa Ana River has been designed to accommodate peak flows from Gypsum Canyon in excess of what would be generated by the Approved Project, and implementation of the Proposed Project would result in less peak-flow runoff, the Santa Ana River would not be adversely impacted by the Proposed Project’s increases in peak flow and would not result in off-site or downstream flooding.

Overall, with implementation of the proposed Project-specific RMP (PDF 4-1), development of the Proposed Project would not result in substantial on- or off-site flooding. Impacts would be less than significant, similar to the Approved Project. Similar to the Approved Project, the measures contained in PDF 4-1 were determined based on a project-specific Preliminary Drainage Report and PWQMP.

As previously discussed, although the proposed PDF 4-1 included in the Proposed Project would be different than PDF 4-1 of the Approved Project, the measures contained in the PDF would accomplish the same purpose of managing post-development stormwater flows to ensure that flows would not result in on- or off-site flooding. Therefore, the proposed PDF 4-1 would replace the Approved Project PDF 4-1.

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Would the project place housing within a 100-year flood hazard as mapped on a federal Flood Hazard Boundary or Flood Insurance Rate Map or other flood hazard delineation map? Would the project place within a 100-year flood hazard area structures which would impede or redirect flood flows?
Approved Project
Less Than Significant Impact. EIR No. 331 indicated that the Approved Project would not place any housing within a 100-year flood hazard area as mapped on a federal Flood Hazard Boundary or Flood Insurance Rate map or other flood hazard delineation map. As discussed above, EIR No. 331 also stated that the results of the HEC-RAS analysis indicated that the average pad elevation for each DA exceeded the 100-year flood elevation by at least 13 feet, thereby meeting the main drainage goal for the Approved Project and ensuring homes would not be impacted by the 100-year flood conditions. Further, the approved development plan and impact area largely avoided encroachment upon the mainstem of Gypsum Creek, thereby eliminating the threat of potential flooding to all structures. Therefore, the flood hazard potential for all structures, including housing, was considered less than significant due to the relatively large difference in the elevation of the DAs and the water surface elevation of a 100-year flood, and implementation of the Approved Project would not expose people or structures to a significant risk of loss, injury, or death involving flooding.

Overall, EIR No. 331 concluded that implementation of the Approved Project would result in less than significant impacts relating to flooding and would not impede or redirect flood flows.

Proposed Project
Less Than Significant Impact. Implementation of the Proposed Project would develop the project site with a public cemetery and State veterans cemetery and would not include any housing. As such, implementation of the Proposed Project would not place any housing within a 100-year flood hazard area as mapped on a federal Flood Hazard Boundary or Flood Insurance Rate map or other flood hazard delineation map.

In addition, as previously discussed, the Proposed Project would implement an RMP, including a three-component storm flow drainage system, as previously described, that would ensure development of the Proposed Project would not result in on-site flooding. Further, implementation of the Proposed Project would result in decreased runoff from the project site as compared to the Approved Project, thereby reducing flooding risk, as the Proposed Project would result in less impervious surface area on the project site than with implementation of the Approved Project.

Overall, implementation of the Proposed Project would develop fewer structures on the project site and generate less runoff compared to the Approved Project, resulting in a decreased flooding risk.

Therefore, the potential exposure of people or structures to a significant risk of loss, injury, or death involving flooding would be less than significant.

Overall, implementation of the Proposed Project would result in less than significant impacts relating to flooding and would not impede or redirect flood flows, similar to the Approved Project. 3-51
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Would the project substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level (e.g., the production rate or pre-existing nearby wells would drop to a level which would not support existing land uses or planned uses for which permits have been granted)?
Approved Project
Less Than Significant Impact. EIR No. 331 determined that because groundwater underlying the project site is not used for drinking water or irrigation and would not be used as a water supply for the Approved Project, implementation of the Approved Project would not significantly deplete groundwater supplies. Further, EIR No. 331 indicated that groundwater supplies would potentially increase due to the cessation of groundwater pumping by quarry operations.

EIR No. 331 also indicated that implementation of the Approved Project would result in changes to groundwater recharge within the Specific Plan Area due to the increase in impervious surface area with the construction of houses, buildings, and roads. However, some recharge could occur within landscaped area such as lawns and gardens. According to EIR No. 331, implementation of the Approved Project would result in approximately 76 percent of DA 5 being impervious, including roofs, concrete walkways, and roads, while 24 percent of the site would remain pervious, including lawns and landscaped areas. Because only a small portion of the approved development was planned over the alluvial aquifer portion of the Specific Plan Area, where a majority of the groundwater recharge within the Specific Plan Area occurs, EIR No. 331 determined that the impacts to groundwater recharge from the approved development are likely to be minor.

In addition, as detailed in EIR No. 331, recharge to groundwater in the alluvial sediments of the Santa Ana River primarily comes from surface flow and underflow from the Chino Basin, with only minor amounts coming from the aquifers of adjacent canyons, including Gypsum Canyon. As such, any reduction in ground water recharge to the aquifers of Gypsum Canyon, such as with implementation of the Approved Project, would have only minor impacts on aquifers associated with the Santa Ana River.

Therefore, EIR No. 331 concluded that potential impacts relating to groundwater recharge with implementation of the Approved Project would be less than significant.

Proposed Project
Less Than Significant Impact. The project site represents DA 5 of the Specific Plan Area, which was analyzed in EIR No. 331. As the Proposed Project would be within the same area as the Approved Project, the shallow bedrock and thin alluvial aquifers in the project area do not yield appreciable amounts of water to wells and, accordingly, are not considered a major source of groundwater supply. However, the proposed project may include a groundwater well on site to provide potable water and irrigation services to both cemeteries. As discussed in more detail in Section 3.12, Public Services and Utilities, of this Addendum, the City anticipates adequate water supply for the Proposed Project. In addition, the Proposed Project would be required to prepare and submit a Water Supply Assessment prior to Final Map recordation and would be required to implement SC 12-4, requiring water verification studies from the Public Utilities Department to confirm sufficient

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water supply in accordance with SB 221. With preparation of a Water Supply Assessment and implementation of SC 12-4, no new impact to water supply would occur. Therefore, the Proposed Project could rely on existing groundwater entitlements to serve the Proposed Project’s water needs and would not contribute to a substantial depletion of groundwater supplies.

Although the Proposed Project would also result in changes to groundwater at the project site due to the increase in impervious surface areas with the construction of roofs, concrete walkways, and roads, the Proposed Project would result in substantially less impervious surface area as compared to the Approved Project. The Proposed Project would result in approximately 10 percent of the site being impervious, while 90 percent of the site would remain pervious, including open space, landscaped areas, and burial areas. Compared to implementation of the Approved Project, which would result in approximately 76 percent of DA 5 being impervious while 24 percent of the site would remain pervious, this represents a substantial reduction in impervious surface area. As such, more groundwater recharge could occur at the project site with implementation of the Proposed Project as compared to the Approved Project. Because EIR No. 331 concluded that potential impacts relating to groundwater recharge with implementation of the Approved Project would be less than significant and implementation of the Proposed Project would facilitate increased groundwater recharge at the project site, potential impacts relating to groundwater recharge with implementation of the Proposed Project would be less than significant, similar to the Approved Project.

Would the project conflict with any applicable plan, policy, or regulation of an agency with jurisdiction over the project adopted for the purpose of avoiding or mitigation an environmental effect?
Approved Project
Less Than Significant Impact. EIR No. 331 included a consistency analysis for the Approved Project on hydrology-related goals and policies outlined in the City’s General Plan. EIR No. 331 identified goals related to reducing urban runoff from new development, reducing the risk to life, property, public investment, and social order created by flood hazards, and maintain a storm drain system that would adequately protect and enhance the wealth, safety, and general welfare of Anaheim.

With the implementation of the previously discussed PDFs, including the three-component storm flow drainage system detailed in the RMP, and adherence to all required federal, State, and local regulations relating to water quality, as discussed in Section 4.5, Water Quality, of EIR No. 331, EIR No. 331 determined that the Approved Project would be considered consistent with the relevant goals and policies related to hydrology. Therefore, impacts related to conflict with any applicable plan, policy, or regulation of an agency with jurisdiction over the Approved Project adopted for the purpose of avoiding or mitigating a potential environmental effect would be less than significant.

Proposed Project
Less Than Significant Impact. Similar to the Approved Project, the Proposed Project would implement an RMP (PDF 4-1), including the three-component storm flow drainage system, and would adhere to all required federal, State, and local regulations relating to water quality, as discussed in Section 3.5, Water Quality, of this Addendum. As such, the Proposed Project would be consistent with the identified goals related to reducing urban runoff from new development, 3-53
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reducing the risk to life, property, public investment, and social order created by flood hazards, and maintain a storm drain system that would adequately protect and enhance the wealth, safety, and general welfare of Anaheim. Impacts related to conflict with any applicable plan, policy, or regulation of an agency with jurisdiction over the project adopted for the purpose of avoiding or mitigating an environmental effect would be less than significant, similar to the Approved Project.

3.4.3 Cumulative Hydrology Impacts
Approved Project
Less Than Cumulatively Considerable Impact. EIR No. 331 analyzed the Gypsum Canyon and West watershed areas as the cumulative study area for potential hydrologic impacts. The qualitative and quantitative impact analysis for the Approved Project contained in EIR No. 331 demonstrated that there would be no significant adverse hydrology impacts associated with the Approved Project, inclusive of surface drainage, flooding, erosion and sedimentation, and groundwater hydrology issues. Further, EIR No. 331 indicated that the Approved Project would not contribute considerably to impacts within the Gypsum Canyon or surrounding watersheds because all impacts would be less than significant with incorporation of PDFs (refer to Section 2.2.3, Approved Project Characteristics, of this Addendum). In addition, because the Approved Project represents substantial build out of the Gypsum Canyon, past projects were considered in the existing conditions and there would be no substantial future development in the area that would add to the less than significant impacts associated with the Approved Project. Therefore, EIR No. 331 concluded that hydrologic impacts associated with the Approved Project would not be cumulatively considerable.

Proposed Project
Less Than Cumulatively Considerable Impact. To maintain consistency with EIR No. 331, the geographic area under consideration for cumulative hydrology impacts for the Proposed Project would be Gypsum Canyon and West watershed areas. A cumulatively considerable impact related to hydrology would occur if further development, in addition to development of the Proposed Project, would substantially impact the hydrologic conditions of Gypsum Canyon and West watershed areas.

Similar to the Approved Project, the analysis presented in this section of the Addendum demonstrates that there would be no significant adverse hydrology impacts associated with the Proposed Project, inclusive of surface drainage, flooding, erosion and sedimentation, and groundwater hydrology issues. Further, as discussed above, the Proposed Project would not contribute considerably to impacts within the Gypsum Canyon or surrounding watersheds because all impacts would be less than significant with incorporation of applicable PDFs. In addition, because the Proposed Project represents substantial build out of Gypsum Canyon, similar to the Approved Project, past projects were considered in the existing conditions and there would no substantial future development in the area that would add to the less than significant impacts associated with the Proposed Project. In 2022, the City of Anaheim approved minor building reconfigurations and other improvements to the Kindred Community Church, 0.7-mile west of the project site at 8712 East Santa Ana Canyon Road. However, these improvements would not substantially alter the existing hydrologic characteristics of the property and therefore would not result in cumulatively considerable hydrologic impacts, and no other projects with the potential to alter the hydrology of the cumulative study are currently proposed or approved. Therefore, hydrologic impacts associated with the Proposed Project would not be cumulatively considerable, similar to the Approved Project.

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3.4.4 Findings Related to Hydrology

3.4.4.1 No New Significant Effects Requiring Major Revisions to the Certified EIR Based on the foregoing analysis and information, there is no evidence that the Proposed Project requires a major change to EIR No. 331. The Proposed Project would not result in new significant environmental impacts related to hydrology, and there would not be a substantial increase in the severity of impacts described in EIR No. 331.

3.4.4.2 No Substantial Change in Circumstances Requiring Major Revisions to the Certified EIR No major changes to the project site have taken place since preparation of EIR No. 331 that would require revisions to the analysis in EIR No. 331. There is no information in the record or otherwise available that indicates that there are substantial changes in circumstances pertaining to hydrology that would require major changes to EIR No. 331.

3.4.4.3 No New Information Showing Greater Significant Effects than the Certified EIR This Addendum has analyzed all available relevant information to determine whether there is new information that was not available at the time EIR No. 331 was certified, indicating that a new significant effect not reported in that document may occur. Based on the information and analyses above, there is no substantial new information indicating that there would be a new significant impact related to hydrology requiring major revisions to EIR No. 331.

3.4.4.4 No New Information Showing the Ability to Reduce Significant Effects in the Certified EIR There is no new information, mitigation, or alternatives to the Proposed Project that would substantially reduce one or more significant impacts pertaining to hydrology identified and considered in EIR No. 331.

3.4.5 Standard Conditions and Mitigation Measures
EIR No. 331 did not prescribe any Standard Conditions or mitigation measures pertaining to hydrology, and no new mitigation is required.

3.5 WATER QUALITY

3.5.1 Existing Environmental Setting
The City lies within Region 8 (Santa Ana) of the California RWQCB’s jurisdiction. The Santa Ana River is the main surface watercourse within Anaheim and provides roughly 70 percent of the total groundwater recharge for the Santa Ana River basin. Water flow is regulated by the Prado Dam, the Seven Oaks Dam, and other flood-control facilities. The river’s unlined channel bottom consists of permeable sandy material and is directly connected to pervious alluvial materials that allow for the transfer of water into the underlying aquifers.

According to EIR No. 331, the approximately 3,001-acre MPSP Area is located within the Santa Ana River Basin and within the Santa Ana River regional watershed. The Specific Plan Area incorporates a majority of the Gypsum Creek local watershed, as well as a West drainage area, an East drainage 3-55
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area, and several freeway drainage areas, including the SR-91 drainage area, the SR-91/SR-241 drainage area, and the SR-91/Gypsum Canyon Road drainage area.

The project site, which represents DA 5 of the Specific Plan Area, is located in the northwest corner of the Specific Plan Area. It incorporates a portion of the Gypsum Canyon watershed and East drainage area, and influences the SR-91 and SR-91/Gypsum Canyon Road drainage areas.

Receiving waters for the project site include Gypsum Creek and the Santa Ana River (Reaches 1 and 2). Gypsum Creek, Santa Ana River Reach 1, and Santa Ana River Reach 2 are not listed on the most recent United States Environmental Protection Agency (USEPA) approved 303(d) list (2020–2022) as impaired for any pollutant of concern.4 Although the Water Quality Control Plan for the Santa Ana River Basin (Basin Plan) does not designate Gypsum Creek with beneficial uses, the Santa Ana River is listed as having designated beneficial uses. Table 3.A provides the beneficial uses for Santa Ana River Reaches 1 and 2.

Table 3.A: Beneficial Uses of Receiving Waters
Waterbody MUN AGR GWR REC1 REC2 WARM WILD RARE SPAWN
Santa Ana River Reach 1 + X2 X I I
Santa Ana River Reach 2 + X X X X X X X X*
Source: Santa Ana RWQCB. 1995. Santa Ana River Basin Plan, Chapter 3 – Beneficial Uses, Table 3-1. January 24. + = Excepted from municipal drinking water source (MUN) designation X = Existing or Potential Beneficial Use
I = Intermittent Beneficial Use
2 Access prohibited in all or part per agency with jurisdiction * SPAWN only from Prado Dam to 0.6 mile downstream of the State Route 90 (Imperial Highway) Bridge

As identified in Table 3-A, the beneficial uses of Reach 1 of the Santa Ana River include water contact recreation involving body contact with water, noncontact water recreation, warm freshwater habitat, and wildlife habitat waters. The beneficial uses of Reach 2 of the Santa Ana River include agricultural supply water used for farming, horticulture, or ranching; groundwater recharge for natural or artificial recharge of groundwater; water contact recreation involving body contact with water; noncontact water recreation; warm freshwater habitat; wildlife habitat waters; and waters that support rare, threatened, or endangered species and associated habitats. Surface water quality in the project area is under the jurisdiction of the Santa Ana RWQCB. and specific surface water quality objectives have been established by the Santa Ana RWQCB and are summarized in the Basin Plan.

Gypsum Canyon is located east of the Orange County Ground Water Basin and southwest of the Chino-Riverside Ground Water Basin, in the Gypsum Creek local watershed of the Santa Ana River regional watershed. The shallow bedrock and thin alluvial aquifers in the project area do not yield appreciable amounts of water to wells and, accordingly, are not considered a major source of groundwater supply. Historical land uses within Gypsum Canyon have been limited to cattle grazing, rocket testing, and clay, sand, and gravel mining. Mining operations have included Robertson’s

4 Santa Ana Regional Water Quality Control Board (RWQCB). California 2020-2022 Integrated Report (303(d) List/305(b) Report), Appendix A; Proposed Final 2020-2022 303(d) List.

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Ready Mix Sand and Gravel surface mine and several individual clay mining operations associated with Pacific Clay Products. Water supply to the Robertson’s Ready Mix sand and gravel mining operation has come from a well located near the Santa Ana River, to the north of Gypsum Canyon.

Groundwater underlying the project site is not currently used for drinking water or irrigation.

Ground water quality in the project area is under the jurisdiction of the Santa Ana RWQCB and specific ground water quality objectives have been established by the Santa Ana RWQCB and are summarized in the Basin Plan. Basin-specific objectives have been established for constituents such as total dissolved solids (TDS) and nitrate. Water quality constituents for which basin plan objectives are not specifically identified in this plan are regulated according to their respective maximum contaminant levels (MCLs) or State of California Department of Health Services Action Levels. For water quality standards in the Basin Plan, such as the toxicity standard, MCLs may be used as an alternative numeric benchmark in this chapter in the absence of a numeric standard.

Several underground storage tanks (USTs) have been associated with the Robertson’s Ready Mix site, including USTs for the storage of gasoline, waste oil, and diesel fuel. At the time EIR No. 331 was prepared, the majority of the USTs had been removed under oversight by the City of Anaheim, the OC Healthcare Agency (OCHCA), and/or the Santa Ana RWQCB. EIR No. 331 indicated that trace concentrations of hydrocarbons have been observed in groundwater near the UST sites, but no constituents have been detected above their MCLs in groundwater. As discussed in the site-specific Phase I Environmental Site Assessment (ESA) prepared for the Proposed Project, this quarry area underwent “cleanup activities” in 2005, including the removal of all remaining USTs and the excavation, off-site treatment, and recycling of 84 tons of hydrocarbon-affected soil. A “no further action” letter was published by the City of Anaheim Public Utilities Department, and the case was closed in 2013.

Groundwater quality impacts related to the McDonnell Douglas rocket fuel test site, which occupied the central portion of Gypsum Canyon approximately 0.75-mile upgradient (to the south) of the project site, have also been detected. The rocket fuel test site operated from 1966 to 1979 and tested various types of hydrazine, pentaborane, and fluorine fuels at several test pads throughout the site. Activities included melting and forming solid propellants, testing solid propellants, and cleaning parts with chlorinated solvents. No USTs or pipelines were located at the facility, with the exception of three septic tanks and leach lines. According to the Phase I ESA prepared for the Proposed Project by Ninyo and Moore and dated December 20, 2023, the McDonnell Douglas rocket fuel test site is not a Recognized Environmental Condition (REC) associated with the project site.

3.5.2 Comparison of Impacts for the Approved Project and the Proposed Project The Proposed Project would develop the 283.28-acre project site, which represents DA 5 of the Specific Plan Area, with a public cemetery and a State veterans cemetery instead of 1,595 dwelling units, including 770 single-family detached residential units and 825 single-family attached residential units, a private recreation center, a water reservoir, on-site roadways (including a roundabout at Gypsum Creek), utility infrastructure, manufactured slopes with landscaping, a trailhead/staging area, relocation of the Questar pipeline, and fuel modification areas. All other elements of the Approved Project would remain as described in EIR No. 331 and would result in the 3-57
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same impacts as analyzed and disclosed in EIR No. 331. As such, this analysis focuses on the potential water quality impacts of the Proposed Project on the project site (i.e., DA 5).

Would the project violate any water quality standards or waste discharge requirements? Would the project result in the potential for discharge which affects the beneficial uses (i.e., swimming, fishing, etc.) of the receiving waters?
Approved Project
Less Than Significant Impact. As detailed in EIR No. 331, anticipated pollutants of concern associated with operation of the Approved Project include sediments (total suspended sediment [TSS] and turbidity), nutrients (nitrogen and phosphorus), trace metals (copper, lead, and zinc), pathogens (bacteria, viruses, and protozoa), petroleum hydrocarbons (oil, grease, and polycyclic aromatic hydrocarbons [PAHs]), pesticides, trash and debris, organic compounds, and oxygen- demanding compounds.

EIR No. 331 discussed implementation of PDF 5-1, including site design, source control, and treatment control BMPs, that would be implemented as part of the Approved Project in compliance with the requirements of the then adopted Orange County National Pollution Discharge Elimination System (NPDES) Permit (Order No. R8-2002-0010) (Prior Orange County Municipal Separate Storm Sewer System [MS4] Permit). The Prior Orange County MS4 Permit specified requirements for managing runoff water quality from new development and significant development projects, including specific sizing criteria for treatment BMPs. To implement the requirements of the Prior Orange County MS4 Permit, the Co-Permittees developed the 2003 Drainage Area Management Plan (2003 DAMP) that included stormwater discharge requirements and BMPs to manage urban runoff pollution. In order to meet the 2003 DAMP requirements and characterize and manage pollutant sources on a local level, local jurisdictions, including the City of Anaheim, developed and adopted a Local Implementation Plan (LIP) that contains policies for compliance with the Prior Orange County MS4 Permit and 2003 DAMP. As required by the Prior Orange County MS4 Permit, 2003 DAMP, and LIP, EIR No. 331 indicated that the Approved Project would be required to prepare a Final WQMP. The Final WQMP would specify the site design, source control, and treatment BMPs that would be implemented to capture, treat, and reduce pollutants of concern in stormwater runoff.

Site design BMPs included minimizing impervious areas, conserving natural areas, protecting slopes and channels, and other practices designed to minimize runoff and the introduction of pollutants in stormwater runoff. Structural source control BMPs included education for property owners, tenants, and occupants; activity restrictions; common-area landscape management; BMP maintenance; common-area litter control; common-area drainage facility inspection; and street sweeping for private streets and parking lots. Nonstructure source control BMPs included storm drain stenciling and signage, trash area design, efficient irrigation, protecting slopes and channels, hillside landscaping, and the Fire Station catch basin protection. In addition, treatment control BMPs to manage and treat runoff from 488 acres within the Specific Plan Area, including the entirety of DA 5, consisted of nine water quality basins. Sizing criteria contained in the Prior Orange County MS4 Permit would be met for all treatment control BMPs, including biofiltration measures. According to

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EIR No. 331, all of DA 5 would be treated by one water quality basin (WQ Basin #5b) located on the east side of the DA. The water quality basins would incorporate dry extended detention basins to provide water quality treatment for storm flows and trash racks would be installed on the inlets into the basin to aid in capturing trash and debris. The water quality basin would also incorporate wetland vegetation in a low flow channel at the bottom of the basins for treatment of dry weather flows and small storm events.

In order to analyze the Approved Project’s potential impacts on water quality, EIR No. 331 modeled predicted pollutant loads for TSS, nutrients, trace metals, pathogens, petroleum hydrocarbons, pesticides, and trash and debris. The results found that, which the exception of TSS, loads of modeled constituents are anticipated to increase with implementation of the Approved Project as compared to the existing conditions. The increase in pollutant loads is primarily the result of anticipated increases in stormwater runoff volumes resulting from increases in impervious surface area with development of the Approved Project. However, EIR No. 331 indicated that the modeled concentrations in runoff from developed areas with implementation of PDFs (including site design, source control, and treatment control BMPs, in compliance with the Prior Orange County MS4 Permit) would be below all applicable benchmark water quality objectives and criteria for the receiving waters.

Although not modeled, EIR No. 331 also analyzed potential impacts on water quality related to turbidity, pathogens, hydrocarbons, pesticides, and trash and debris. According to EIR No. 331, concentrations of hydrocarbons and pesticides are expected to increase, concentrations of trash and debris may increase, and concentrations of pathogens are not anticipated to significantly change in the receiving waters with implementation of the Approved Project. However, EIR No. 331 determined that none of these qualitatively assessed constituents are expected to impact receiving waters with implementation of the PDFs in compliance with the Prior Orange County MS4 Permit.

EIR No. 331 also analyzed potential water quality effects during dry-weather conditions and indicated that appreciable dry-weather flows out of the water quality basins are not anticipated due to infiltration and evapotranspiration within the basins, which would adequately reduce the potential for dry-weather flow discharges. Further, EIR No. 331 indicated that landscaping in public and common areas would utilize drought-tolerant vegetation that requires little watering and chemical application to minimize the potential generation and transport of dissolved constituents.

Landscape irrigation in common areas would also be controlled utilizing evapotranspiration sensors to minimize excess watering, and educational programs and materials would emphasize the best practices to minimize the potential generation and transport of dissolved constituents. In addition, as previously discussed, the water quality basins would also incorporate wetland vegetation in a low-flow channel at the bottom of the basins for treatment of dry-weather flows and small storm events.

Overall, EIR No. 331 determined that the site design, source control, and treatment control BMPs implemented as part pf PDF 5-1 in compliance with the Prior Orange County MS4 Permit and implementation plans would manage and treat runoff from the Specific Plan Area to ensure all potential impacts from pollutants of concern on downstream water quality would be less than significant. Therefore, EIR No. 331 determined that potential impacts on water quality with implementation of the Approved Project would be less than significant. 3-59
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Because potential impacts on water quality with implementation of the Approved Project would be less than significant with compliance with water quality standards and applicable permits and implementation plans, EIR No. 331 also determined the Approved Project would not exceed water quality objectives established to protect beneficial uses of receiving waters. Therefore, beneficial uses of receiving waters would be protected and impacts would be less than significant.

Proposed Project
Less Than Significant Impact. As previously discussed, the Proposed Project would develop the 283.28-acre project site with a public cemetery and a State veterans cemetery. Similar to the Approved Project, anticipated pollutants of concern associated with operation of the Proposed Project include suspended solids and sediment, nutrients, heavy metals, pathogens, pesticides, oil and grease, toxic organic compounds, and trash and debris. As previously discussed, there are no current impairments for receiving waters (i.e., Gypsum Creek and Santa Ana River Reaches 1 and 2).

The City of Anaheim is a Co-Permittee of the Waste Discharge Requirements (WDRs) for the County of Orange, Orange County Flood Control District, and the Incorporated Cities of Orange County within the Santa Ana Region Areawide Urban Storm Water Runoff, Orange County (Order No. R-8- 2009-0030, NPDES No. CAS618030, as amended by Order No. R8-2010-0062) (Current Orange County MS4 Permit). The Current Orange County MS4 Permit specifies requirements for managing runoff water quality from new development and significant development projects, including specific sizing criteria for treatment BMPs. To implement the requirements of the Current Orange County MS4 Permit, the Co-Permittees developed the 2007 Drainage Area Management Plan (2007 DAMP) that includes stormwater discharge requirements and BMPs to manage urban runoff pollution. In order to meet the 2007 DAMP requirements and to characterize and manage pollutant sources on a local level, local jurisdictions, including the City of Anaheim, have developed and adopted a LIP that contains policies for compliance with the Current Orange County MS4 Permit and 2007 DAMP. As required by the Current Orange County MS4 Permit, 2007 DAMP, and LIP, the Proposed Project would prepare a Final WQMP (PDF 5-1). The Final WQMP would specify the site design, source control, and treatment BMPs that would be implemented to capture, treat, and reduce pollutants of concern in stormwater runoff.

A Preliminary WQMP has been prepared for the Proposed Project, in compliance with the Current Orange County MS4 Permit, that details the source control and treatment BMPs that would be implemented to reduce impacts to water quality from operation of the Proposed Project. Similar to the Approved Project, nonstructure source control BMPs would include education for property owners, tenants, and occupants; activity restrictions; common-area landscape management; BMP maintenance; common-area littler control; common-area catch basin inspection; and street sweeping for private streets and parking lots. Also, similar to the Approved Project, structural source control BMPs would include providing storm drain system stenciling and signage, designing and constructing trash and waste storage areas to reduce pollution introduction, efficient landscape irrigation systems, protecting slopes and channels, and hillside landscaping.

As previously described in Section 3.4, Hydrology, of this Addendum, the Proposed Project would also implement an RMP, similar to the Approved Project, including a three-component storm flow drainage system consisting of: (1) a high-flow bypass line for collecting off-site drainage from

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undisturbed areas within the project boundary and routing it around the project site, (2) an on-site storm drain system to collect high flows from the project site, and (3) a low-flow water quality system to divert initial storm flows and dry-weather flows from the project site to a series of water quality basins and other structural water quality BMPs without increasing flooding or capacity hazards to the downstream receiving waterbody.

Two aboveground and lined DEDBs, one associated with each pad, would be used to treat the DCV for the project site. The DEDBs would be located upstream of the two UDSs, which would mitigate flow rate from the proposed development to lower than the existing runoff level. The UDSs would be sized for hydromodification (100-year peak flow mitigation) and flood control in compliance with the Current Orange County MS4 Permit. Before draining to the Gypsum Creek, flows would then pass through the SAF Energy Dissipator, which is designed to reduce the flow velocity and avoid erosion of the creek banks and channel.

In addition, three Modular Wetland Systems are proposed for stormwater treatment benefits and would strategically collect and deliver runoff from the project site to the main storm drain lines to minimize the threat of on-site flooding, similar to the Approved Project. The three Modular Wetland Systems are placed along the approach road to collect and treat runoff from the road located south of the project site as well as the bridge.

Further, the storm drain system would be designed to prevent off-site low flows from entering the system. Off-site flows from the southeast would be conveyed to Gypsum Creek via a series of storm drain inlets and pipes and would confluence with treated on-site flows and discharge into an energy dissipater before discharging into Gypsum Creek.

Overall, with compliance with the Current Orange County MS4 Permit and implementation plans (2007 DAMP and LIP), including preparation of a Final WQMP to address pollutants of concern in storm water runoff as detailed in PDF 5-1, the Proposed Project’s impacts associated with the violation of water quality standards or WDRs or degradation of surface or groundwater water quality during project operation would be less than significant, similar to the Approved Project.

Would the project otherwise substantially degrade water quality? Approved Project
Less Than Significant Impact. EIR No. 331 indicated that the potential impacts on water quality associated with constriction activities, construction materials, and nonstormwater runoff are primarily related to sediment (TSS and turbidity). Construction activities primarily responsible for sediment releases are related to exposing soils to potential mobilization by rainfall/runoff and wind.

Such activities include vegetation removal, grading, and trenching for infrastructure improvements.

Other pollutants of concern during construction discussed in EIR No. 331 relate to construction materials and nonstormwater flows, including waste construction materials, chemicals, liquid products, and petroleum products used in building construction or the maintenance of heavy equipment and concrete-related waste streams. These nonsediment-related pollutants have the potential to be released during various construction activities, including materials storage, vehicle or 3-61
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equipment fueling, vehicle or equipment maintenance (including washing), waste handling, hazardous materials handling or storage, delivery areas, loading docks, or other outdoor work areas.

However, EIR No. 331 also indicated that potential construction impacts on water quality would be minimized through implementation of Standard Condition (SC) 5-2 detailed in EIR No. 331, which required compliance with the SWRCB then adopted Construction General Permit (Prior Constriction General Permit). As required by the Prior Construction General Permit and the 2003 DAMP/LIP, the Construction Contractor would be required to prepare a SWPPP and implement construction BMPs detailed in the SWPPP during construction activities. Construction BMPs would include, but not be limited to, erosion and sediment control (designed to minimize erosion and retain sediment on site) and good housekeeping practices to prevent spills, leaks, and discharge of construction debris and waste into receiving waters. BMPs listed in EIR No. 331 also included slope stabilization using rock or vegetation, revegetation, hydro-seeding or using tackifiers on exposed areas, installation of energy dissipators, drop structures, catch basin inlet protection, construction materials management, and cover and containment of construction materials and wastes.

EIR No. 331 determined that construction of the Approved Project may require groundwater dewatering if groundwater is encountered during grading, or to allow discharges associated with testing of water lines, sprinkler systems, and other facilities. Given the relatively shallow groundwater conditions in some portions of the proposed DA, EIR No. 331 included an evaluation of the relationship of excavation activities to the groundwater table. EIR No. 331 indicated that groundwater encounters and associated dewatering are expected during construction in three areas, two of which are within DA 5.

As such, EIR No. 331 indicated that groundwater dewatering activities associated with construction of the Approved Project would comply with the SWRCB’s then-adopted Dewatering General Permit, which regulates construction dewatering activities and requires notification, testing, and reporting of construction-related nonstormwater discharges associated with dewatering and other construction activities. In addition, the Approved Project included PDFs to protect receiving waters from dewatering and construction related nonstormwater discharges. Overall, EIR No. 331 determined that compliance with the Dewatering General Permit, as required by SC 5-3 detailed in EIR No. 331, would ensure that construction impacts related to water quality standards, WDRs, and degradation of groundwater quality would be less than significant.

EIR No. 331 also discussed potential water quality impacts to groundwater during operation of the Approved Project and indicated that chemical constituents associated with urban development that impact groundwater quality are typically compounds that leach through permeable portions of the development (i.e., lawns) as a result of natural recharge or irrigation return flow. The primary constituents of concern for groundwater related to residential development are pesticides, herbicides, and nitrate (via fertilizer) that are typically applied to maintain lawns and gardens.

Although fertilizers, pesticides, and herbicides could reach the shallow groundwater, EIR No. 331 indicated that concentrations would not be likely to exceed Basin Plan objectives for nitrate or MCLs for pesticides and herbicides as studies have shown that while pesticides and herbicides are commonly detected in shallow groundwater beneath urban areas, they are not typically detected at concentrations exceeding their MCLs. Therefore, EIR No. 331 determined that anticipated

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pesticide/herbicide impacts to groundwater related to the approved development would be less than significant. Further, pesticide, herbicide, and nitrate impacts would be minimized through PDFs and implementation of BMPs, including encouraging landscape practices that minimize irrigation, implementation of BMPs for the storage and application of fertilizers and pesticides, and education programs.

In addition, EIR No. 331 indicated that ongoing operation and maintenance activities of treatment control measures and BMPs detailed in PDF 5-1 during project operation in accordance with the requirements of the then adopted MS4 Permit, specifically the DAMP/LIP, as required by SC 5-1 detailed in EIR No. 331. These treatment control PDFs and BMPs, including site inspections, trash and debris removal, irrigation system inspection and adjustment, major and minor vegetation removal, snag removal, integrated pest management, structural repairs, and sediment removal, would ensure that the BMPs detailed in PDF 5-1 operate at their maximum efficiency and treatment capacity.

Further, as prescribed through SCs 5-1 detailed in EIR No. 331, a WQMP demonstrating compliance with the implementation plans under the then adopted MS4 Permit, specifically the DAMP/LIP, would be developed prior to approval of each mass or rough grading plan.

Overall, EIR No. 331 determined that with compliance with the Prior Construction General Permit and Dewatering General Permit, as well as ongoing operation and maintenance activities of treatment control BMPs detailed in PDF 5-1 during project operation, and compliance with the DAMP/LIP, Construction General Permit, and General Waste Discharge Permit as prescribed by SCs 5-1 through 5-3, potential water quality impacts would be less than significant.

Proposed Project
Less Than Significant Impact. Pollutants of concern during construction of the Proposed Project include sediment, trash, petroleum products, concrete waste (dry and wet), sanitary waste, and chemicals. Each of these pollutants on its own or in combination with other pollutants can have a detrimental effect on water quality. During construction activities, excavated soil would be exposed, and there would be an increased potential for soil erosion and sedimentation compared to existing conditions. In addition, chemicals, liquid products, petroleum products (e.g., paints, solvents, and fuels), and concrete-related waste may be spilled or leaked during construction. Sediment from increased soil erosion and chemicals from spills and leaks have the potential to be transported via storm water runoff into receiving waters (i.e., Gypsum Creek and Santa Ana River Reaches 1 and 2).

Construction of the Proposed Project would disturb the entire project site. Because project construction would disturb greater than 1 acre of soil, the proposed Project would be subject to the requirements of the SWRCB’s currently adopted NPDES Permit and Waste Discharge Requirements for Discharges of Stormwater Runoff Associated with Construction and Land Disturbance Activities Order No. 2022-0057-DWQ, NPDES No. CAS000002 (Current Construction General Permit), similar to the Approved Project. As required by the Current Construction General Permit, the Construction Contractor would be required to prepare a SWPPP and implement construction BMPs detailed in the SWPPP during construction activities. Construction BMPs would include, but not be limited to, erosion and sediment control (designed to minimize erosion and retain sediment on site) and good 3-63
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housekeeping practices to prevent spills, leaks, and discharge of construction debris and waste into receiving waters. Compliance with the Current Construction General Permit would be implemented through adherence with SC 5-2.

According to the Final Preliminary Report of Geotechnical Studies and Review of Preliminary Grading Plan prepared for the Proposed Project by GMU Engineers and Geologists and dated June 12, 2023, groundwater was encountered at 44 feet below existing ground surface (bgs) at the proposed bridge’s eastern abutment, and the historic high groundwater within Gypsum Canyon is at 40 feet bgs. In addition, variations in perched groundwater and groundwater depths between previous and recent investigations indicate that groundwater elevation is seasonally controlled and highly variable. Further, groundwater within the project site may be higher during wetter than normal winters as controlled by the Gypsum Canyon watershed. Similar to the Approved Project, because perched groundwater and groundwater depths at the project site vary seasonally and groundwater within the project site may be higher during wetter than normal winters, groundwater could have the potential to impact grading or construction. As such, groundwater dewatering may be required during Proposed Project construction. Groundwater dewatering activities could affect surface water quality through the discharge of polluted groundwater to surface waterbodies. Groundwater dewatering activities would comply with the WDR Permit for Discharges to Surface Waters That Pose an Insignificant (De Minimis) Threat to Water Quality (Groundwater Discharge Permit) (Order No. R8-2020-0006, NPDES No. CAG998001). In compliance with the requirements of the Groundwater Discharge Permit, groundwater would be tested and treated (if necessary) prior to discharge to surface water. Compliance with the Groundwater Discharge Permit would ensure that construction impacts related to water quality standards, WDRs, and degradation of groundwater quality would be less than significant, similar to the Approved Project. Compliance with the Groundwater Discharge Permit would be implemented through adherence with SC 5-3.

Similar to the Approved Project, potential water quality impacts to groundwater during operation of the Proposed Project could occur. However, similar to the Approved Project, concentrations would not likely exceed Basin Plan objectives for nitrate or MCLs for pesticides and herbicides. Therefore, anticipated pesticide/herbicide impacts to groundwater related to the proposed development would be less than significant. Further, similar to the Approved Project, pesticide, herbicide, and nitrate impacts would be minimized through PDFs and implementation of BMPs, including encouraging landscape practices that minimize irrigation, implementation of BMPs for the storage and application of fertilizers and pesticides, and education programs.

In addition, the Proposed Project would implement ongoing operation and maintenance activities of treatment control BMPs detailed in PDF 5-1 during project operation, including site inspections, trash and debris removal, irrigation system inspection and adjustment, major and minor vegetation removal, snag removal, integrated pest management, structural repairs, and sediment removal, to ensure that BMPs operate at their maximum efficiency and treatment capacity, similar to the Approved Project.

Overall, with compliance with the Current Construction General Permit, including preparation and implementation of a SWPPP and construction BMPs, and the Groundwater Discharge Permit, as well as ongoing operation and maintenance activities of treatment control BMPs detailed in PDF 5-1 during project operation, and compliance with the DAMP/LIP, Construction General Permit, and

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General Waste Discharge Permit as prescribed by SC 5-1 through 5-3, potential water quality impacts would be less than significant, similar to the Approved Project.

Would the project result in a potential for discharge of pollutants from areas of material storage, vehicle or equipment fueling, vehicle or equipment maintenance (including washing), waste handling, hazardous materials handling, or storage, delivery areas, loading docks or other outdoor work areas?
Approved Project
Less Than Significant Impact. EIR No. 331 indicated that on-site material storage, vehicle or equipment fueling, vehicle or equipment maintenance (including washing), waste handling, and hazardous materials handling during construction activities would be required to comply with the Prior Construction General Permit, including the completion of a SWPPP, as discussed above.

Therefore, EIR No. 331 determined that compliance with these regulations would ensure that potential on-site construction impacts from these activities would be less than significant.

EIR No. 331 also indicated that the Approved Project’s on-site land uses do not include equipment fueling, outdoor hazardous materials handling or storage, or delivery areas/storage docks. Further, operational activities would not include any industrial or heavy commercial uses that could result in pollutant discharge such as material storage, vehicle or equipment fueling, vehicle or equipment maintenance, waste handling, hazardous materials handling, or storage, delivery areas, loading docks, or other outdoor work areas. Therefore, EIR No. 331 determined there would be no potential impacts associated with these activities during operation of the Approved Project.

Overall, EIR No. 331 concluded that construction and operation of the Approved Project would not result in a potential for discharge of pollutants from areas of material storage, vehicle or equipment fueling, vehicle or equipment maintenance (including washing), waste handling, hazardous materials handling, or storage, delivery areas, loading docks, or other outdoor work areas with compliance with the Prior Construction General Permit. Impacts would be less than significant.

Proposed Project
Less Than Significant Impact. Similar to the Approved Project, on-site material storage, vehicle or equipment fueling, vehicle or equipment maintenance (including washing), waste handling, and hazardous materials handling during construction activities would be required to comply with the Construction Stormwater General Permit, including the completion of a SWPPP, as discussed above.

Therefore, compliance with the Construction General Permit would ensure that potential on-site construction impacts from these activities would be less than significant, similar to the Approved Project.

In addition, the Proposed Project’s on-site land uses do not include equipment fueling, outdoor hazardous materials handling or storage, or delivery areas/storage docks, and operational activities would not include any industrial or heavy commercial uses that could result in pollutant discharge such as material storage, vehicle or equipment fueling, vehicle or equipment maintenance, waste handling, hazardous materials handling, or storage, delivery areas, loading docks, or other outdoor 3-65
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work areas, similar to the Approved Project. Therefore, no potential impacts associated with these activities during operation of the Proposed Project would occur, similar to the Approved Project.

Overall, construction and operation of the Proposed Project would not result in significant impact associated with discharge of pollutants from areas of material storage, vehicle or equipment fueling, vehicle or equipment maintenance (including washing), waste handling, hazardous materials handling, or storage, delivery areas, loading docks, or other outdoor work areas with compliance with the Construction General Permit. Impacts would be less than significant, similar to the Approved Project.

Would the project conflict with any applicable plan, policy or regulation of an agency with jurisdiction over the project adopted for the purpose of avoiding or mitigating an environmental effect?
Approved Project
Less Than Significant Impact. EIR No. 331 included a consistency analysis for the Approved Project on related goals and policies outlined in the City’s General Plan and SCAG’s RCPG related to water quality. EIR No. 331 identified goals related to reducing urban runoff from new development and encouraging water reclamation throughout the region to reduce wastewater discharges and reliance on imported water. With the implementation of the previously discussed PDFs, including water quality basins that would act as a source of reclamation for the groundwater table, and adherence to all required federal, State, and local regulations relating to water quality, including the Prior Orange County MS4 Permit, 2003 DAMP/LIP, Prior General Construction Permit, and Dewatering General Permit, EIR No. 331 determined that the Approved Project would be considered consistent with the relevant goals and policies related to water quality. Therefore, impacts related to conflict with any applicable plan, policy, or regulation of an agency with jurisdiction over the project adopted for the purpose of avoiding or mitigating an environmental effect would be less than significant.

Proposed Project
Less Than Significant Impact. Similar to the Approved Project, the Proposed Project would implement similar measures detailed in PDF 5-1, including water quality basins, that would act as a source of reclamation for the groundwater table, and adherence to all required federal, State, and local regulations relating to water quality, including the Current Orange County MS4 Permit, 2007 DAMP/LIP, Current Construction Stormwater General Permit, and the Groundwater Discharge Permit. Although the proposed PDF 5-1 included in the Proposed Project would differ from PDF 5-1 of the Approved Project, the BMPs detailed in the PDF would accomplish the same purpose of managing post-development stormwater flows. Therefore, the proposed PDF 5-1 would replace the Approved Project PDF 5-1.

As such, the Proposed Project would be consistent with the identified goals related to reducing urban runoff from new development and encouraging water reclamation throughout the region to reduce wastewater discharges and reliance on imported water. Impacts related to conflict with any applicable plan, policy, or regulation of an agency with jurisdiction over the Proposed Project

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adopted for the purpose of avoiding or mitigating an environmental effect would be less than significant, similar to the Approved Project.

3.5.3 Cumulative Water Quality Impacts
Approved Project
Less Than Cumulatively Considerable. EIR No. 331 analyzed the Gypsum Canyon and West watershed areas as the cumulative study area for potential water quality impacts. The qualitative and quantitative impact analysis for the Approved Project contained in EIR No. 331 demonstrated that there would be no significant adverse water quality impacts associated with the Approved Project, inclusive of surface and groundwater water quality issues. Further, EIR No. 331 indicated that the Approved Project would not contribute considerably to impacts within Gypsum Canyon or surrounding watersheds because all impacts would be less than significant with the incorporation of PDFs (refer to Section 2.2.3, Approved Project Characteristics, of this Addendum). In addition, because the Approved Project represents substantial build out of the Gypsum Canyon, past projects were considered in the existing conditions and there would no substantial future development in the area that would add to the less than significant impacts associated with the Approved Project.

In addition, implementation of the Approved Project would comply with all requirements of the Prior General Construction Permit, Dewatering General Permit, and the Prior Orange County MS4 Permit and its implementation plans, the 2003 DAMP and LIP. The 2003 DAMP/LIP constituted a watershed-wide program to address cumulative impacts of development in the watershed.

Stormwater discharges would not increase any pollutants exceeding receiving water quality standards. In addition, all new developments within the Santa Ana River watershed and communities surrounding the Specific Plan Area would be required to implement BMPs to satisfy these same regulatory requirements, which are designed to address cumulative water quality impacts within the overall watershed, and Approved Project stormwater discharge compliance with these receiving water standards further ensures no significant cumulative impact. Since the Approved Project would not adversely impact water quality and other projects would also need to comply with all requirements of the Prior Construction General Permit, the Dewatering General Permit, and the Prior Orange County MS4 Permit and its implementing programs, EIR No. 331 determined that no cumulative impacts were anticipated.

Proposed Project
Less Than Cumulatively Considerable. To maintain consistency with EIR No. 331, the geographic area under consideration for cumulative water quality impacts for the Proposed Project would be the Gypsum Canyon and West watershed areas. A cumulatively considerable impact related to water quality would occur if further development, in addition to development of the Proposed Project, would substantially impact the water quality conditions of Gypsum Canyon and the surrounding watersheds. Similar to the Approved Project, the analysis presented in this section of the Addendum demonstrates that there would be no significant adverse water quality impacts associated with the Approved Project, inclusive of surface and groundwater water quality issues.

Further, as discussed above, the Proposed Project would not contribute considerably to impacts within the Gypsum Canyon or surrounding watersheds because all impacts would be less than significant with the incorporation of PDFs. In addition, because the Proposed Project represents 3-67
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substantial build out of Gypsum Canyon, similar to the Approved Project, past projects were considered in the existing conditions and there would no substantial future development in the area that would add to the less than significant impacts associated with the Proposed Project. In 2022, the City of Anaheim approved minor building reconfigurations and other improvements to the Kindred Community Church, 0.7-mile west of the project site at 8712 East Santa Ana Canyon Road.

However, these improvements would not substantially alter the existing water quality characteristics of the property and therefore would not result in cumulatively considerable water quality impacts, and no other projects with the potential to alter the water quality of the cumulative study are currently proposed or approved.

In addition, similar to the Approved Project, implementation of the Proposed Project would comply with all requirements of the Current Construction General Permit, the Groundwater Discharge Permit, and the Current Orange County MS4 Permit and its implementation plans, the 2007 DAMP and LIP. In addition, all new developments within the Santa Ana River watershed and communities surrounding the Specific Plan Area would be required to implement BMPs in order to satisfy these same regulatory requirements, which are designed to address cumulative water quality impacts within the overall watershed, and Proposed Project stormwater discharge compliance with these receiving water standards further ensures no significant cumulative impact. Since the Proposed Project would not adversely impact water quality and other projects would also need to comply with all requirements of the Current Construction General Permit, Groundwater Discharge Permit, and the Current Orange County MS4 Permit and its implementing programs, no cumulative impacts are anticipated, similar to the Approved Project.

3.5.4 Findings Related to Water Quality

3.5.4.1 No New Significant Effects Requiring Major Revisions to the Certified EIR Based on the foregoing analysis and information, there is no evidence that the Proposed Project requires a major change to EIR No. 331. The Proposed Project would not result in new significant environmental impacts related to water quality, and there would not be a substantial increase in the severity of impacts described in EIR No. 331.

3.5.4.2 No Substantial Change in Circumstances Requiring Major Revisions to the Certified EIR No major changes to the project site have taken place since preparation of EIR No. 331 that would require revisions to the analysis in EIR No. 331. There is no information in the record or otherwise available that indicates that there are substantial changes in circumstances pertaining to water quality that would require major changes to EIR No. 331.

3.5.4.3 No New Information Showing Greater Significant Effects than the Certified EIR This Addendum has analyzed all available relevant information to determine whether there is new information that was not available at the time EIR No. 331 was certified, indicating that a new significant effect not reported in that document may occur. Based on the information and analyses above, there is no substantial new information indicating that there would be a new significant impact related to water quality requiring major revisions to EIR No. 331.

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3.5.4.4 No New Information Showing the Ability to Reduce Significant Effects in the Certified EIR There is no new information, mitigation, or alternatives to the Proposed Project that would substantially reduce one or more significant impacts pertaining to water quality identified and considered in EIR No. 331.

3.5.5 Standard Conditions and Mitigation Measures
EIR No. 331 did not prescribe any mitigation measures pertaining to water quality, and no new mitigation is required.

Although no mitigation measures pertaining to water quality were prescribed in EIR No. 331, Standard Conditions (SC) 5-1 through 5-5 were identified to be applicable to the Approved Project, with SCs 5-1 through 5-3 applicable to Approved Project components within DA 5. SCs 5-4 and 5-5 were prescribed for construction activities within Caltrans rights-of-way and were not prescribed to Approved Project components within DA 5. SCs 5-1 through 5-3 would remain applicable to the Proposed Project, as modified below.

SC 5-1 Prior to approval of each mass or rough grading plan, the property owner/developer shall submit a project water quality management plan (WQMP) to the Department of Public Works for review and approval. The WQMP shall demonstrate compliance with the implementation plans under the Orange County MS4 Permit, namely the Drainage Area Management Plan/Local Implementation Plan (DAMP/LIP).

SC 5-2 Prior to the approval of grading plans, the property owner/developer shall provide written evidence to the Department of Public Works that it has filed a Notice of Intent with the Regional Water Quality Control Board in order to obtain coverage under the National Pollutant Discharge Elimination System (NPDES) Permit and Waste Discharge Requirements for Discharges of Stormwater Runoff Associated with Construction and Land Disturbance Activities Order No. 2022-0057-DWQ, NPDES No. CAS000002 (Construction Stormwater General Permit) (CGP) (NPDES No.

CAS000002, Resolution No. 2001-046, or the latest approved CGP. Pursuant to the permit requirements, the property owner/developer shall develop a Stormwater Pollution Prevention Plan (SWPPP) that incorporates Best Management Practices for reducing or eliminating construction related pollutants in the site runoff.

SC 5-3 Prior to approval of a grading plan, the Department of Public Works shall verify that the project complies with the Waste Discharge Requirements (WDR) Permit for Discharges to Surface Waters That Pose an Insignificant (De Minimis) Threat to Water Quality (Groundwater Discharge Permit) (Order No. R8-2020-0006, NPDES No. CAG998001) General Waste Discharge Requirements issued by the Santa Ana Regional Water Quality Control Board (RWQCB) Order No. R8-2003-0061, and NPDES No. CAG998001 (or latest approved equivalent) are in effect and shall govern discharges from construction dewatering and water line/sprinkler line testing should they occur during construction. The property owner/developer shall comply with these regulations including provisions requiring notification, testing and reporting of 3-69
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dewatering and testing-related discharges, which shall mitigate any impacts of such discharges.

3.6 BIOLOGICAL RESOURCES
For the purposes of this Addendum, a Biological Resources Assessment (BRA) (LSA 2024) was prepared for the Proposed Project area. The BRA assessed the current biological conditions on the project site, identified the impacts to biological resources and assessed the impacts of the Proposed Project relative to the findings of FEIR No. 331. The results of the BRA have been incorporated into the discussion below.

3.6.1 Existing Environmental Setting
The City of Anaheim is largely urbanized and surrounded by other developed cities, with few remaining areas of natural habitat. Developed areas of Anaheim contain nonnative species of plants and animals, while the eastern Hill and Canyon Area contains the majority of the city’s remaining significant biological resources. A State-owned 1,400-acre wildlife corridor is present within Coal Canyon, east of the MPSP. Vegetation within the project study area is predominantly composed of a wide variety of scrub and chaparral communities. Additionally, several grassland, woodland, and riparian habitats exist within Gypsum Creek and many tributaries that drain into it. As discussed in EIR No. 331, several plant communities and sensitive plant and wildlife species are covered under the NCCP/HCP, which is further discussed below.

3.6.1.1 Natural Community Conservation Plan and Habitat Conservation Plan Reserve The Natural Community Conservation Act (the Act), codified at Fish and Game Code Sections 2800- 2840, authorizes the preparation of NCCPs to protect natural communities and species while allowing a reasonable amount of economic development. The Mountain Park project site is within the NCCP/HCP – County of Orange Central & Coastal Subregion. The NCCP/HCP was reviewed and approved by the California Department of Fish and Wildlife (CDFW) and USFWS in 1996, to address protection and management of coastal sage scrub (CSS) habitat and CSS-obligate species, and other covered habitats and species, and mitigate anticipated impacts to those habitats and species on a programmatic, subregional level rather than on a project-by-project, single-species basis. EIR No. 331 lists the following plant communities within the project area that are covered by the NCCP HCP:

CSS, Oak Woodlands, Tecate Cypress Forest, and Cliff and Rock.

Please note that EIR No. 331 mentions the Mountain Park project site is within an approved development area by the NCCP/HCP and its impact to covered species does not require further mitigation beyond compliance with the NCCP/HCP.

3.6.1.2 The Nature Conservancy Anaheim Conservation Easement In November 2001, The Irvine Company dedicated 11,000 acres to The Nature Conservancy in the form of conservation easements, including the TNC ACE. The TNC ACE is within the MPSP area and includes 911 acres within three parcels. When the conservation easements were dedicated, agreements were made between The Irvine Company and The Nature Conservancy regarding permitted and prohibited uses. Any activities within the TNC ACE area must be coordinated with The Nature Conservancy. Uses permitted in the conservation easement areas that are relevant to the

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Proposed Project include: existing roads and trails; environmental enhancement activities; passive recreational activities; and limited slope stabilization and infrastructure activities needed to support development. These permitted uses are subject to specific provisions outlined in the TNC ACE and approval of The Nature Conservancy.

3.6.1.3 2014 Irvine Company Donation & Irvine Ranch Conservancy In 2014, the MPSP property owner (the Irvine Company) donated land to Orange County for preservation as a conservation easement (“2014 easement”). When this occurred, jurisdiction over the affected portion of the Specific Plan Area was transferred to OC Parks. The land is now subject to the conservation easement conditions established by OC Parks Foundation when the land was donated in 2014, and is part of the larger Irvine Ranch Conservatory open space classification. This change does not affect DA 5, which is referred to as the “Unencumbered Parcel” in the 2019 IS/MND prepared for the Interim Recreation and Resource Management Plan associated with the 2014 easement. As previously discussed, DA 5 contains a former surface mining site and is highly disturbed as a result. Please refer to Figure 3-5, Relationship of Conservation Easement to Project Site, for an illustration of the project site’s proximity to the 2014 easement/Irvine Ranch Conservatory. Though the project site does not overlap with this easement or the TNC ACE, it is directly adjacent to both.

3.6.2 Comparison of Impacts for the Approved Project and the Proposed Project Would the project have a substantial or adverse effect, either indirectly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S.

Fish and Wildlife Service?
Approved Project
Less Than Significant with Mitigation Incorporated. EIR No. 331 identified federally and State listed plant and wildlife species and other sensitive plant and wildlife species that could be affected by the Approved Project and identified coverage under the NCCP/HCP or additional measures to mitigate impacts to these species.

Listed Plant and Wildlife Species Covered by the NCCP/HCP EIR No. 331 found that the following plant and wildlife species listed by federal or State Agencies were observed on-site or have the potential to occur: Santa Monica Mountains dudley, coastal California gnatcatcher, American peregrine falcon and southwestern willow flycatcher. Santa Monica Mountains was not observed on-site but there remained a low potential for this species occur due to the presence of suitable habitat. Coastal California gnatcatcher was present on within the development areas of the Approved Project. American peregrine falcon was not observed but has the potential to occur. As Covered Species under the NCCP/HCP potential impacts to these species are fully mitigated by compliance with the NCCP/HCP. Therefore, no additional mitigation is required.

SOURCE: Google Maps (2023)
I:\OCC1901\GIS\Pro\Mountain Park Memorial Park\Mountain Park Memorial Park.aprx (12/19/2023) FIGURE 3-5
Gypsum Canyon Cemetery Project
Relationship of Conservation Easement to Project Site
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FEET
Project Site
Conservation Easements
Irvine Ranch Conservancy
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Southwestern willow flycatcher was observed on-site, however based on the focused surveys, the habitat on-site appears to support migrating willow flycatcher but does not appear suitable for breeding. As a Conditionally Covered Species, the long term conservation value of the NCCP/HCP coverage, and implementation of Mitigation Measures 6-2 and 6-2 was identified to mitigate the impacts to southwestern willow flycatcher by Approved Project to less than significant.

Listed Plant and Wildlife Species Not Covered by the NCCP/HCP The potential to encounter Braunton’s milkvetch, federally listed as endangered, was identified but was not observed and was not expected to be occur within the development of the Approved Project and this species would not be impacted. The Santa Ana sucker, a federally threatened species, was not expected to occur on site; however, it is known to occur in the Santa Ana River, which receives stormwater from the Approved Project. EIR No. 331 determined that the Approved Project would have little effect on the Santa Ana sucker.

Sensitive Plant Species Covered by the NCCP/HCP
Three nonlisted sensitive plant species Covered under the NCCP/HCP, were observed on site, and two others have the potential to occur. NCCP/HCP Covered species observed on site include Tecate cypress, Coulter’s matilija poppy, and Catalina mariposa lily. The foothill mariposa lily, which is Conditionally Covered under the NCCP/HCP, was also observed on site. NCCP/HCP Covered species not observed, but with the potential to occur within the project site, include Nuttall’s scrub oak and heart-leaved pitcher sage. Potential impacts to these species are fully mitigated by compliance with the NCCP/HCP. Therefore, no additional mitigation is required.

Sensitive Plant Species Not Covered by the NCCP/HCP
Nonlisted, sensitive plant species observed on site or with the potential to occur on site that are Not Covered by the NCCP/HCP were previously listed in the EIR. Palmer’s grapplinghook was not located within the proposed development areas and would not be impacted by the Approved Project. No mitigation for this species was required.

The following sensitive plant species observed on site or with the potential to occur are or could be within the proposed development areas: many-stemmed dudleya, longspined spineflower, chaparral nolina, Robinson’s pepper-grass, and Hall’s monardella. Potentially significant impacts to many-stemmed dudleya would be reduced to less than significant with implementation of current restoration programs and survey efforts. Impacts to longspined spineflower, chaparral nolina, Robinson’s pepper-grass, and Hall’s monardella were considered less than significant.

Wildlife Species Covered and Conditionally Covered by the NCCP/HCP Several nonlisted wildlife species Covered under the NCCP/HCP were observed on-site, and several others have the potential to occur. NCCP/HCP Covered wildlife species observed on site include:
coast horned lizard, orange-throated whiptail, coastal whiptail, northern red-diamond rattlesnake, sharp-shinned hawk, red-shouldered hawk, cactus wren, southern California rufous-crowned sparrow, coyote, and gray fox. These species are “Identified Species” within the NCCP/HCP and are considered Covered species, and their loss has been mitigated within the NCCP/HCP. Therefore, impacts are considered less than significant.

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Several nonlisted wildlife species Covered under the NCCP were not observed on site; however, they have the potential to occur. These include arboreal salamander, black-bellied slender salamander, Coronado skink, coastal rosy boa, ring-necked snake, northern harrier, rough-legged hawk, and San Diego desert woodrat. Due to their coverage under the NCCP/HCP, potential impacts have been mitigated within the NCCP/HCP. Therefore, impacts are considered less than significant.

The golden eagle and prairie falcon are Conditionally Covered species. Both species were observed on the project site. Pursuant to NCCP/HCP guidelines, activities that are more than 0.5 mile from an active or historically active nesting site may proceed without minimization or mitigation requirements. Direct impacts to nesting sites for both species were not expected to occur, and the edge of the proposed development area was more than 0.5 mile from the potential nesting areas.

Therefore, the Approved Project met the conditions of and is consistent with the NCCP/HCP. As such, potential impacts to the golden eagle and prairie falcon are considered adequately mitigated under the NCCP/HCP and are considered less than significant.

Wildlife Species Not Covered by the NCCP/HCP
Cooper’s hawk, willow flycatcher, black-chinned sparrow, Bell’s sage sparrow, tricolored blackbird, and western mastiff bat were all observed within the Mountain Park project site. With the exception of the willow flycatcher, these species are not federally or State-listed, and considerable habitat for these species was preserved on site. Willow flycatchers were observed on site during focused surveys; however, it has been determined that this species is utilizing the project site during migration only. Potential impacts of the Approved Project were not expected to threaten regional populations of these species and are thereby considered less than significant. It should also be noted that although no significant impact would result from the Approved Project to these species, MM 6-6 protecting nesting birds would further ensure that impacts to birds remain less than significant. Additionally, the preservation of open space on site provides nesting and foraging habitat that is used by these species.

Several additional sensitive wildlife species were not observed on site but have the potential to occur, including: coast range newt, silvery legless lizard, San Diego mountain kingsnake, coast patch- nosed snake, ferruginous hawk, merlin, white-tailed kite, long-eared owl, olivesided flycatcher, loggerhead shrike, pallid bat, Townsend’s western big-eared bat, spotted bat, pocketed free-tailed bat, big free-tailed bat, San Diego black-tailed jackrabbit, northwestern San Diego pocket mouse, and southern grasshopper mouse. Similar to the discussion in the previous paragraph, these species are not federally or State-listed, and considerable habitat for these species is preserved on site. In addition, potential impacts were not expected to threaten regional populations of these species and are thereby considered less than significant. Although the impacts are considered to be less than significant, compliance with MM 6-6 ensured the protection of active nests protected by the federal Migratory Bird Treaty Act and nests and eggs protected by California Fish and Game Code Section 3503. As stated in MM 6-6, the vegetation removal would occur outside of the nesting season. If vegetation removal activities must occur during the nesting season, provisions would be made to ensure the protection of nesting birds.
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Proposed Project
Less than Significant with Mitigation Incorporated. The Proposed Project encompasses approximately 283 acres of primarily lower-quality habitat within the DA 5 of the MPSP The BRA conducted a literature review and biological database record search that resulted in the identification of 17 special-status plant species occurrences within a 9-mile radius of the project site.

Of the 17 special-status plant species, none are anticipated to occur within the project site due to the lack of suitable habitat. Further, special-status plant surveys were conducted during all seasons through 2023 when regional special-status plant species would have been observable. No species identified in the literature search or biological databases were observed during field surveys and they are not anticipated to occur within the project site because of the site’s existing conditions.

The BRA literature review of the biological database records also resulted in the identification of 38 special-status animal species in the vicinity of the project site. Of the 38 special-status animal species, 17 are not anticipated to occur within the project site due to lack of suitable habitat. CNDDB and IPaC records search identified the following 11 special-status animal species to potentially occur within the project: Crotch bumble bee, Southern California legless lizard, coastal whiptail, San Diego banded gecko, red-diamond rattlesnake, coast patched nose snake, burrowing owl, golden eagle, white-tailed kite and pallid bat. Special status animal species observed within the project during field surveys include western spadefoot, yellow warbler, coastal California gnatcatcher, southwestern willow flycatcher, western mastiff bat, pocketed free-tailed bat, and big free-tailed bat.

Focused surveys were conducted for three “Identified species ” in the NCCP/HCP: coastal California gnatcatcher and western spadefoot (Covered Species); and San Diego fairy shrimp (conditionally covered). Both California gnatcatcher and western spadefoot were identified on the project site during focused surveys. San Diego Fairy Shrimp were not identified on the project site during focused surveys.

Listed Plant and Wildlife Species Covered by the NCCP/HCP The NCCP/HCP is implemented to allow for direct, indirect, and cumulative impacts to “identified species” regardless of the number or distribution of the species within the NCCP development area.

Therefore, compliance with the conditions of the NCCP/HCP, all direct, indirect, and cumulative impacts under CEQA and NEPA to covered habitats and identified species resulting from development within designated development areas owned by NCCP/HCP participating landowners are considered fully mitigated.

Because the potential cemetery site supports the proposed threatened western spadefoot and federally listed as threatened coastal California gnatcatcher, authorization of take of these species would be required. Such authorization is provided pursuant to the NCCP/HCP for the portion of the site that was formerly owned by the Irvine Company. The USFWS will require verification that the Irvine Company authorizes utilization of its take authorization by the Orange County Cemetery District for the coastal California gnatcatcher and western spadefoot. Beyond the County of Orange’s verification of take authorization, the requirements of the NCCP/HCP and involve notification to the USFWS and the CDFW, and implementation of a number of construction

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minimization measures—principally monitoring—during vegetation clearing and grading, as outlined in SC 6-4.

Listed Plant and Wildlife Species Not Covered by the NCCP/HCP Suitable habitat for Braunton’s milkvetch or Santa Ana Sucker was not identified during recent surveys and no impacts to these species are expected. This conclusion is the same as FEIR No. 331.

The crotch bumble bee is a California candidate endangered species. This species inhabits open scrub (including chaparral) and grassland from coastal California to the crest of the Sierra-Cascade and in desert edge areas, south into Mexico. It primarily nests underground. Suitable bumble bee habitat requires the continuous availability of flowers on which to forage throughout the duration of the colony (spring through fall), colony nest sites, and overwintering sites for the queens.

Suitable habitat is present within the project site throughout the scrub habitat present on site.

Although this species was not observed since the beginning of the 2019 surveys, the species has a low to moderate potential to forage within the project site.

During construction activities, the project (i.e., grading and vegetation clearing) could directly affect habitat used for foraging and potential nesting by the Crotch bumble bee. Construction activities, including grading and vegetation clearing, will affect special-status amphibian and reptile species.

These species include red diamond rattlesnake, Southern California legless lizard, and western spadefoot. These amphibian and reptile species live or estivate underground and surface to reproduce, sun, or forage. SC 6-4 from EIR No. 331 identifies compliance with the NCCP/HCP and has been refined to reflect the presence of western spadefoot and the presence of potential foraging and ground nesting habitat for Crotch bumble bee. With implementation of SC 6-4 which requires compliance with the NCCP/HCP, potential impacts to covered species under the NCCP/HCP and potential Crotch bumblebee habitat are considered less than significant.

Sensitive Plant Species Covered by the NCCP/HCP
Several nonlisted plant species Covered under the NCCP/HCP were observed on-site during field surveys for the proposed project, Coulter’s Matilija poppy. This species are “Identified Species” within the NCCP/HCP and are considered Covered species, and their loss has been mitigated within the NCCP/HCP. Therefore, impacts are considered less than significant.

Sensitive Plant Species Not Covered by the NCCP/HCP
No sensitive plant species not covered by the NCCP/HCP were identified during field surveys for the proposed project.

Wildlife Species Covered and Conditionally Covered by the NCCP/HCP Several nonlisted wildlife species Covered under the NCCP/HCP were observed on-site, and several others have the potential to occur. NCCP/HCP Covered wildlife species observed on site include:

Coastal Cactus Wren, Red Shouldered Hawk, Northern Harrier and Coyote. These species are “Identified Species” within the NCCP/HCP and are considered Covered species, and their loss has been mitigated within the NCCP/HCP. Therefore, impacts are considered less than significant. 3-77
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Several nonlisted wildlife species Covered under the NCCP were not observed on site; however, they have the potential to occur. These include coastal whiptail and red diamond rattlesnake. These species are “Identified Species” within the NCCP/HCP and are considered Covered species, and their loss has been mitigated within the NCCP/HCP. Therefore, impacts are considered less than significant.

Wildlife Species Not Covered by the NCCP/HCP
Several special-status animal species (and nesting birds) have the potential to be directly impacted during vegetation removal and mass grading activities. In addition, several special-status animal species have the potential to be indirectly affected during construction activities through increased noise, vibration, lighting, and dust. Such indirect disturbance has the potential to affect foraging patterns and disorient special-status bird species that have the potential of occurring in adjacent habitat areas. Increased anthropogenic disturbance and waste (e.g., litter) during and following project construction could also attract predators of special-status species to the project vicinity.

Given that (1) the project is situated at a higher grade, (2) there is spatial separation between proposed project infrastructure and Gypsum Canyon to the west of the project site, (3) the project is sited near SR-91, and (4) operational lighting would have minimal spill into adjacent habitats, long- term significant indirect effects to special-status species are not anticipated.

Indirect temporary effects on hydrology and water quality could occur during construction. Such effects include a potential increase in erosion and sediment transport into adjacent or downstream aquatic areas. Chemical spills or leaks of fuel, transmission fluid, lubricating oil, or motor oil from construction equipment could also contaminate waters and degrade their quality. These potential indirect effects to hydrology and water quality would be avoided or substantially minimized through the implementation of best management practices (BMPs), project design features, and a Water Quality Management Plan and/or a Stormwater Pollution Prevention Plan (if required). As such, significant indirect impacts to water quality—and any aquatic species occurring in adjacent aquatic habitats—are not anticipated.

The project site contains suitable nesting habitat for ground-nesting birds and for other birds that are protected while nesting. Riparian woodland adjacent to the project site serves as suitable nesting habitat for various common and special-status bird species. Construction activities that occur during the nesting bird season (February 1 through September 15) have potential to result in the direct or indirect take of nesting birds.

As outlined in EIR No. 331, potential direct and indirect impacts on special-status wildlife species would be reduce to a less than significant level with implementation of SC-4, and MM 6-3 and MM 6-6, and would effectively avoid or minimize any impacts on special-status wildlife species and nesting birds.

With the implementation of the outlined standard conditions and mitigation measures from EIR No. 331 and the authorization of the take of covered species under the NCCP/HCP, impacts will would be to special-status biological resources anticipated to occur from the Proposed Project would be reduced to less than significant. Therefore, the conclusions of the Certified EIR remain valid.

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Would the project have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Wildlife or the U.S. Fish and Wildlife Service? Approved Project
Less Than Significant with Mitigation Incorporated. EIR No. 331 identified that project implementation would remove 221.8 acres of plant communities considered sensitive by the resource agencies (namely CDFW), including 213.5 acres of CSS (200.1 acres of primary impacts and

13.4 acres of secondary impacts) and 8.3 acres of coast live oak woodland (7.6 acres of primary impacts and 0.7 acre of secondary impacts). EIR No. 331 also identified the amount of these communities preserved on site. Due to the sensitivity of these communities, their support of several sensitive species, and the fact that impacts to these communities would substantially reduce their regional distribution, impacts in most circumstances would be considered potentially significant.

However, as assessed under the NCCP/HCP, impacts to these plant communities would not have a substantial adverse effect on the habitat types or species using them, and NCCP/HCP mitigation (i.e., the Reserve) assures full mitigation of development impacts. The project would also impact 3.4 acres of cliff and rock communities; however, impacts to these communities are covered and fully mitigated under the NCCP/HCP. Within the NCCP/HCP Reserve, there is approximately 18,740 acres of CSS, 963 acres of woodlands, and 74 acres of cliff and rock protected. Additional habitat would also be preserved within the TNC ACE.

The Approved Project would not impact any of the 43 acres of Tecate Cypress Forest on site. The on- site areas with this habitat are within preserved open space.

Project implementation would remove approximately 2.1 acres of needlegrass grassland.

Needlegrass grassland is considered a CNDDB high-priority inventory community due to its limited distribution in the region. Impacts to 2.1 acres of needlegrass grassland amounts to approximately 18 percent of the total 11.7 acres mapped within the study area. This loss is not expected to substantially reduce the distribution of this community in the region, and considering the preservation of 9.6 acres of needlegrass in open space areas, the impact is considered less than significant. It should also be noted that although it is not a protected species, the NCCP/HCP Reserve protects 5,877 acres of grassland.

A total of 2.1 acres of cottonwood-willow riparian woodland would be impacted by the Approved Project on site. Additionally, 0.2 acre of sycamore riparian woodland would be impacted by off-site project features. These communities are Not Covered under the NCCP/HCP but are considered high- priority inventory communities by the CDFW. Due to their sensitivity, limited distribution within the region, and potential to support sensitive species (i.e., migratory willow flycatchers), impacts to these habitats are considered potentially significant prior to mitigation. It should be noted that the project would not impact willow scrub or mixed riparian habitat.

Approved Project implementation would also result in the direct removal of 339.4 acres of several nonsensitive plant communities, including 296.0 acres of chaparral communities (264.3 acres of primary impacts; 31.7 acres of secondary impacts), 16.5 acres of annual grassland communities (14.5 acres of primary impacts; 2.0 acres of secondary impacts), 2.0 acres of sumac savannah (1.0 3-79
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acre of primary impacts; 1.0 acre of secondary impacts), 14.2 acres of oak savannah (13.7 acres of primary impacts; 0.5 acre of secondary impacts), 2.7 acres of mule fat scrub2 (2.6 acres of primary impacts; 0.1 acre of secondary impacts), 4.4 acres of mule fat scrub/coast live oak woodland (4.3 acres of primary impacts; 0.1 acre of secondary impacts), 0.2 acre of Mexican elderberry woodland (0.2 acre of primary impacts), and 3.4 acres of cliff and rock communities (3.1 acres of primary impacts; 0.3 acre of secondary impacts). These communities are not considered sensitive by resource agencies, and impacts to them would not reduce these communities below self- perpetuating levels throughout the region. In addition, substantial amounts of each community are preserved in open space. Therefore, their removal was considered less than significant. In addition, cliff and rock communities and coast live oak woodland are covered habitats under the NCCP/HCP, and mitigation provided in the NCCP/HCP adequately mitigates development impacts.

Fire-Dependent Vegetation
The implications of the Approved Project on fire frequency are complex, but the potential exists for the project to change the natural fire cycle of the area. Of particular concern is the impact of a change in fire frequency to the Tecate cypress. The Tecate cypress is a fire-dependent species, requiring the heat of a fire to open its cones for seed dispersal. However, Tecate cypress cone production is low until the trees are about 30 years old; therefore, too frequent of fires may eliminate trees by burning them before they have produced enough cones/seed to successfully reproduce.

The Approved Project, including associated firebreaks and fuel modification zones, would reduce fire frequency by minimizing the chance of naturally set fires (i.e., lightning) by eliminating the amount of vegetation available as a source to spark and fuel a wildfire. Based on the historical data reviewed for this assessment, fires that have affected the Tecate cypress stands in Coal and Gypsum canyons have been occurring at less than 20-year intervals (1948, 1967, 1982, and 2002) and have contributed to the decline of the northernmost population of the species. The potential for the project to suppress fire frequency would not affect Tecate cypress. In fact, suppressing fire frequency in the area may allow the remaining population of Tecate cypress to mature.

Conversely, the presence of development and urban encroachment may increase the potential for more frequent human-induced fires. As mentioned above, an increase in fire frequency has caused the decline of the Tecate cypress from much of its historic distribution in Coal and Gypsum canyons.

Consequently, any unnatural increases in fire frequency in scrub and chaparral habitats could potentially threaten the continued existence of sensitive communities and species. Again, based on the historical data of fires occurring in the area, the Approved Project would not increase the fire frequency to a point that it would threaten the Tecate cypress stands more than they already are. It should also be mentioned that a high percentage of unnatural fires in settings similar to Mountain Park are caused by off-road vehicle use by residents. Since such a use of NCCP/HCP and other open space lands around the project would be strictly prohibited, this is not expected to be a factor.

Therefore, impacts of the Approved Project were considered less than significant.

Proposed Project
Less Than Significant With Mitigation. Vegetation communities were mapped using classifications defined by the Orange County Habitat Classification System as articulated by Jones & Stokes

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Associates, Inc., for the Orange County Central-Coastal NCCP/HCP (1993). This classification system is the same as used in EIR No. 331 to identify vegetation on the project site. The dominant vegetation community within the project site is ruderal, which primarily consists of nonnative annual grassland species (see Table 3.B for more details regarding the vegetation within the project site).

Table 3.B: Mapped Vegetation/Land Cover Classifications Vegetation/Land Cover Project Acres Impacts (Acres)
Permanent Temporary
Scrub Habitats
Remnant Coastal Sage Scrub 1.91 1.79 -
Buckwheat Scrub 8.5 8.5 -
Buckwheat/Encelia Scrub 12.96 4.47 -
Cactus Scrub 7.22 7.2 -
Deerweed scrub 1.71 1.64 -
Brittlebush 1.52 1.52 -
Subtotal 33.82 25.12 0
Chaparral Habitat
Toyon-Sumac Savannah 3.85 0.73 0.01
Oak/Mexican Elderberry 7.03 2.61 -
Subtotal 10.88 3.34 0.01
Riparian Habitats
Mule Fat Scrub 0.78 0.73 -
Riparian (Mule Fat) 1.72 1.71 -
Subtotal 2.5 2.44 0
Disturbed Areas
Disturbed 31.15 26.52 0.99
Tarweed Population 22.16 22.16 -
Ruderal 181.88 160 1.42
Subtotal 235.19 208.68 2.41
Other Land Cover Type
Ephemeral Drainage (Gypsum Creek) 0.89 - 0.55
Total 283.28 240.31 3.06
Source: Biological Resource Assessment (LSA 2024)

Special-Status Natural Communities
As outlined in EIR No 331, impacts to NCCP/HCP covered plant communities, coastal sage scrub is considered sensitive by the resource agencies. Due to the sensitivity of the communities, their support of several sensitive species and the fact that the impacts to these communities would substantially reduce their regional distribution, impacts in most circumstances would be considered potentially significant. However, as assessed under the NCCP/HCP, impacts to these plant communities will not have a substantial adverse effect on the habitat types or species using them, and NCCP/HCP mitigation (i.e., the Reserve) assures full mitigation of development impacts. EIR No. 331 notes that there will be 200.1 acres of primary impacts to this vegetation community; however, the impacts within the project area are 25.12 acres (Table 3.B).

As demonstrated in Table 3.B above, the proposed project would permanently remove up to 2.61 acres of coast live oak/Mexican elderberry woodland, which is considered a sensitive natural 3-81
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community. If unmitigated, these impacts on sensitive natural communities and protected trees would be considered potentially significant. Therefore, SC 2-3 is recommended to compensate for the loss of coast live oak trees. Impacts to coast live oak/Mexican elderberry woodland associated with the proposed project would be mitigated through compliance with Section 18.112.070 of the City Municipal Code, which required replacement of Specimen Trees and through the establishment of the NCCP/HCP Reserve and the Conservation Easement established in 2014. As outlined in EIR No. 331, the full development impacts to coast live oak/Mexican elderberry woodland were provided by the NCCP/HCP Reserve. With implementation of SC 2-3 and through the establishment of the NCCP/HCP Reserve, Anaheim Conservation Easement and 2014 Conservation Easement, potential impacts to coast live oak/Mexican elderberry woodland are considered less than significant.

The BRA identifies 2.44 acres of riparian vegetation present in varying densities within and adjacent to Gypsum Creek and considered a sensitive natural community by CDFW would be temporarily impacted by the Proposed Project. Any impacts to riparian habitat shall be avoided to the maximum extent possible during construction activities. With implementation of the augmented Standard Condition 6-1 (involving grading plans to identify ESA areas) and MM 6-1 (involving construction site housekeeping practices), and MM 6-2 (requiring construction fencing, buffers from Gypsum Canyon Channel, and controlled vehicle traffic routes) impacts associated with the loss of riparian habitat or any existing special status communities in the project site are considered reduced to a less than significant level.

With the implementation of SC’s 2-3 and 6-1 and MM’s 6-1 through 6-2, impacts to existing special status natural communities in the project site would be mitigated to less than significant levels.

Therefore, the impacts of the Proposed Project are considered less than significant with mitigation incorporated, and the findings of the EIR No. 331 remain valid.

Would the project have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means? Approved Project
Less Than Significant with Mitigation Incorporated. EIR No. 331 identified approximately 28.48 acres of waters of the United States, including approximately 0.28 acre of wetlands, mapped in the study area. The Approved Project would impact approximately 6.25 acres of waters of the United States, including 0.23 acre of wetlands, subject to the jurisdiction of the ACOE. Of the 6.25 acres of impacts to ACOE jurisdiction, 5.40 acres occur within the primary impact area (which includes 0.23 acre of wetlands), and 0.49 acre of waters of the United States occurs within the secondary impact area.

Approximately 45.44 acres of CDFW jurisdictional streambed and associated riparian habitat were mapped within the study area. The Approved Project would impact approximately 10.22 acres of CDFW jurisdiction, 8.27 acres within the primary impact area and 1.1 acres within the secondary impact area (refer to Exhibit 4.6-4, Impacts to CDFW Jurisdictional Areas). Impacts on ACOE and CDFW jurisdictions in most cases would be considered potentially significant. However, with

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incorporation of the identified mitigation program, this impact would be reduced to a level considered less than significant.

Proposed Project
Less Than Significant With Mitigation Incorporated. The ACOE issued an Approved Jurisdictional Determination for the project site in July 2022 that has been included in the 2024 BRA. It should also be noted that this determination is consistent and applicable to the ACOE published September 2023 rule (see LSA 2024 for more info).

The CDFW, under Sections 1600 through 1616 of the California Fish and Game Code, regulates alterations to lakes, rivers, and streams (defined by the presence of a channel bed and banks, and at least an intermittent flow of water) where fish or wildlife resources may be adversely affected.

The Regional Water Quality Control Board (RWQCB) is responsible for the administration of Section 401 of the CWA. Typically, the areas subject to jurisdiction of the RWQCB coincide with those of the USACE (i.e., waters of the United States, including any wetlands). The RWQCB may also assert authority over “waters of the State” under waste discharge requirements pursuant to the Porter- Cologne Water Quality Control Act.

Gypsum Creek and two unnamed tributaries to Gypsum Creek were identified within the delineation and were determined to be jurisdictional. Additionally, two other drainage features on the east side of the project were also determined to be jurisdictional. One roadside ditch and six basins were determined to be nonjurisdictional. Gypsum Creek was determined to be a nonwetland waters of the United States/waters of the State and CDFW riparian. The two unnamed drainage features were also determined to be nonwetland waters of the United States/waters of the State and CDFW streambed. Both temporary and permanent impacts are summarized (see Table 3.C).

Table 3.C: Summary of Jurisdictional/Nonjurisdictional Features Feature ACOE Waters of the
United Sates (acres)
RWQCB Waters of
the State (acres)
CDFW Streambeds/
Riparian (acres)
Drainage 1 Gypsum Creek 1.94 4.31 4.31
Drainage 1 A 0.02 0.03 0.03
Drainage 1 B 0.33 1.04 1.04
Drainage 2 0.12 0.12 0.12
Drainage 3 0.08 0.08 0.08
Roadside Ditch (Nonjurisdictional) (Nonjurisdictional) (Nonjurisdictional) Basin 1 (Nonjurisdictional) (Nonjurisdictional) (Nonjurisdictional) Basin 2 (Nonjurisdictional) (Nonjurisdictional) (Nonjurisdictional) Basin 3 (Nonjurisdictional) (Nonjurisdictional) (Nonjurisdictional) Basin 4 (Nonjurisdictional) (Nonjurisdictional) (Nonjurisdictional) Basin 5 (Nonjurisdictional) (Nonjurisdictional) (Nonjurisdictional) Basin 6 (Nonjurisdictional) (Nonjurisdictional) (Nonjurisdictional) Total 2.49 5.58 5.58
Source: Biological Resource Assessment (LSA 2024).

CDFW = California Department of Fisha and Wildlife
RWQCB = Regional Water Quality Control Board
USACE = United States Army Corps of Engineers

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According to the Biological Resources Assessment (LSA 2024) most of the project site does not support streams or other waters subject to the jurisdiction of the ACOE (CWA Section 404), CDFW (Fish and Game Code Section 1600), or RWQCB (CWA Section 401 or the Porter-Cologne Water Quality Control Act). However, there are some drainage courses/riparian areas in the bottom of Gypsum Canyon along the western and southern edges of the site, as well as some ephemeral drainage courses in the northeastern and eastern portions of the site that are jurisdictional of all three agencies. Road access to the site would likely require some modification to Gypsum Creek.

Direct impacts to Gypsum Creek caused by the construction of the bridge and grading of the property are outlined in Table 3.D, below.

Table 3.D: Jurisdictional Impacts
Feature
ACOE Impacts (Acres) RWQCB/CDFW Impacts (Acres)
Permanent Temporary Permanent Temporary
Drainage 1 Gypsum Creek – 0.36 – 0.69
Drainage 1 A – – – –
Drainage 1 B – – – –
Drainage 2 0.01 – 0.01 –
Drainage 3 – – – –
Source: Biological Resource Assessment (LSA 2024).

ACOE= United States Army Corps of Engineers
CDFW= California Department of Fish and Wildlife
RWQCB = Regional Water Quality Control Board

As shown in Table 3.D, grading from the Proposed Project would result in permanent impacts to ACOE and CDFW jurisdictional waters to drainage two (0.01 acre). Construction of bridges used to access the site near Gypsum Creek would result in temporary 0.36 acre of temporary impacts to ACOE jurisdictional waters and 0.69 acre pf CDFW jurisdictional waters to Gypsum Creek (drainage one). The total impacts to ACOE (0.37 acre) non-wetland waters will be less than what is proposed in EIR No. 331, which was6.25 acres. The RWQCB and CDFW impacts to jurisdictional streambeds will total 0.70 acres and is less than what was proposed in EIR No. 331 for the primary impact area (8.27 acres). The impacts to the drainage features within the project area will be less than the impacts identified in EIR No. 331.

These impacts would be limited with the implementation of EIR No. 331’s SC 6-1, requiring disclosure of any jurisdictional impacts to the Department of Public Works in compliance with the provisions of the 1602 California Fish and Game Code. Additionally, EIR No. 331’s SC 6-2, requiring a section 404 permit from ACOE and SC 6-3 requiring section 401 from the RWQCB, would be implemented to limit impacts to jurisdictional waters. As mentioned earlier, MM 6-2 would include additional provisions to ensure that address construction related impacts to Gypsum Creek are reduced to a level less than significant. The limited impacts from the Proposed Project are less than the Approved Project and with the incorporated SCs and MMs, therefore. would be less than significant with the approved mitigation. The findings of the EIR No. 331 remain valid.

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Would the project interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites?
Approved Project
Less Than Significant with Mitigation Incorporated.

Wildlife Movement
EIR No. 331 presented data gathered during the literature review and during 2001 and 2002 surveys that indicated use of the Mountain Park project site by a variety of wildlife both for local and regional movement. Local movement of resident wildlife within the project site and immediate vicinity would be affected by the development. East-west regional movement is hindered only by SR-241; however, provisions such as fencing and undercrossings have been constructed to facilitate this movement. North-south movement is unimpeded in the southern portion of the site but the point of access to the Chino Hills for larger mammals such as mountain lion is severely hindered at the mouth of Gypsum Canyon due to the significant historical and recent disturbance (i.e., mining operations, Santa Ana Canyon Road, Gypsum Canyon Road, SR-91). Studies of mountain lion movement substantiate that the Gypsum Canyon undercrossing and/or culverts are not utilized by this species and that mountain lion are more likely to utilize Coal Canyon to the east. More ubiquitous species such as coyote, raccoon, opossum, and skunk currently utilize the Gypsum Canyon undercrossing and culverts in spite of the disturbance and development and would be expected to continue their use after Approved Project implementation.

In summary, the proposed Mountain Park development may interfere with the local movement of resident wildlife. However, the Approved Project provides additional buffer areas in the form of the TNC ACE and other open space beyond the NCCP/HCP Reserve boundary, and avoids the ridge separating Mountain Park from Coal Canyon. In addition, wildlife movement studies conducted in this area have found the Gypsum Canyon underpass unused and inappropriate for use by mountain lion. Furthermore, the NCCP/HCP program places a focus on conservation of habitat on an ecosystem level to promote wildlife diversity. Accordingly, the NCCP/HCP Reserve design established corridors and special linkages to accommodate wildlife movement. Under the NCCP/HCP, it was determined that the Reserve design incorporated sufficient connectivity for purposes of wildlife movement so that impacts of development within DAs designated by the NCCP/HCP do not require further mitigation. Likewise, given the ecosystem-based approach to reserve design, it was determined that the reserve design adequately addressed buffer and edge considerations to fulfill the NCCP/HCP reserve design tenets and that, accordingly, impacts of development within designated DAs outside the NCCP/HCP Reserve do not require further mitigation. As such, impacts to wildlife movement from the Approved Project were determined to be less than significant.

Habitat Loss and Fragmentation
The primary impacts of the project on wildlife resources are the removal and disruption of habitat and the loss and displacement of wildlife, resulting in a less diverse and less abundant local faunal population. Adverse impacts to wildlife are generally associated with the degree of habitat loss and fragmentation from the standpoint of physical character, quality, diversity, and abundance of 3-85
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vegetation. Although a few species of wildlife are entirely dependent on a single vegetation community, it is important to recognize that the entire mosaic of vegetation communities within the project site and adjoining areas constitutes a functional ecosystem for wildlife species both within the immediate project site and as part of the regional ecosystem. The NCCP/HCP recognized the necessity for conservation at an ecosystem level to promote wildlife diversity, and the Reserve design that was established adequately addressed habitat linkages, habitat buffers, and edge considerations to fulfill the NCCP/HCP Reserve design tenets and ensure wildlife diversity within the region. Implementation of the Approved Project would result in the loss of relatively large areas of CSS, chaparral, and grassland habitats. The removal of these habitats could cause the direct mortality of numerous common wildlife species. In addition, potential adverse indirect impacts to vegetation and wildlife include increased vehicular traffic and a corresponding increase in road kill and noise; an increase in human intrusion, including hikers and bicyclists; an increase in predatory and feral pets; an increase in litter, pollutants, dust, oil, and other human debris; and an increase in nighttime lighting. Common wildlife species using habitats on site would avoid habitats affected by these “spillover” impacts, thereby decreasing diversity beyond the actual development envelope.

These impacts by themselves would not be expected to reduce general wildlife populations below self-sustaining levels within the region; therefore, elimination or disruption of habitat for these species is less than significant. Furthermore, as stated previously, the NCCP Reserve design incorporates several features to ensure habitat connectivity and addresses buffer and edge considerations.

The Yuma myotis summer roost within the SR-91 culverts may be impacted by the Approved Project during modification of the culverts. Although the Yuma myotis is not a sensitive species and impacts to this small roosting population would not be considered significant, a mitigation measure has been established to ensure the protection of the colony (MM 6-5).

Proposed Project
Less Than Significant. According to the Biological Resources Assessment (LSA 2024), there are wildlife species that occur in the project vicinity would be introduced to new effects to the area. The noise, vibration, light, dust, or human disturbance within construction areas would only temporarily deter wildlife from using areas in the immediate vicinity of construction activities. These indirect effects could temporarily alter migration behaviors, territories, or foraging habitats in select areas.

The construction activities would likely have a temporary effect to wildlife. However, because of the footprint of the proposed project adjacent to Gypsum Creek and the increased traffic use of the area, daily site visits, and grounds maintenance activities, these would not be temporary effects and would alter their normal functions for the duration of the Project construction and during operation of the proposed project. The Proposed Project would not place permanent barriers within Gypsum Creek that would impede wildlife movement. This assessment is consistent with that of EIR No. 331 Wildlife Movement Within the Study Area. It is noted that the Gypsum Canyon underpass and culverts are not likely to be utilized as a “wildlife crossing by more selective animals: deer, bobcat, gray fox, or mountain lion” (Draft EIR No. 331 2005). Given the reduced intensity of development associated with operation of the Proposed Project compared to the approved development in EIR No. 331, potential impacts to wildlife movement by the Proposed Project would be substantially less than identified in EIR No. 331 and are considered less than significant. Implementation of measures

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SC 2-3, SC 6-1, SC 6-2, SC-6-3, MM 6-1, 6-5 would further avoid and or minimize impacts to wildlife movement within the project site during construction or operation of the Proposed Project.

Would the project conflict with the provisions of an adopted habitat conservation plan, natural community conservation plan, or other approved local, regional, or state habitat conservation plan? Approved Project
Less Than Significant Impact. As outlined in EIR No. 331, the Approved Project has been designed to be consistent with the Central/Coastal NCCP/HCP. Development has been limited to areas identified in the plan as approved development areas. Additionally, the area that would be impacted by the Approved Project is substantially reduced from the approved development area identified in the NCCP/HCP. This was demonstrated by comparing the project impact area to the Non-Reserve NCCP development. As such, no impacts were identified in the NCCP/HCP Reserve areas. SC-6 was included in EIR No. 331 and incorporates the conservation measures set forth in the NCCP/HCP which were applicable to the Approved Project. Therefore, the Approved Project was determined to be consistent with the NCCP/HCP and the IA, and impacts were not considered significant.

Proposed Project
Less Than Significant Impact. Although several conservation easements under different jurisdictions (OC Parks, The Nature Conservancy, NCCP/HCP) exist within the Specific Plan Area, the project site does not encroach upon any protected lands or easements. DA 5, in which the Proposed Project is located, has been referred to in previous conservation documents as the “unencumbered parcel” and is not subject to the regulations of these easements. However, due to its close proximity to these conservation areas, the Proposed Project would ensure compatibility of the proposed uses with the easements. The proposed cemetery used would not create a land use conflict with the NCCP/HCP, the 2014 Conservation Easement or the TNC ACE because the proposed project would be designed consistent with design standards set forth in MPSP and the conservation measures set forth in the NCCP/HCP have been incorporated as SC-6.. Further, the proposed cemetery uses would generally be less intrusive than the approved residential community and would introduce less land disturbance and human occupancy into the project site. The Proposed Project would not conflict with the provisions of the NCCP/HCP, 2014 Conservation Easement or the TNC ACE ; as such, impacts to these conservation plans/programs would be less than significant and the findings of EIR No. 331 remain valid.

Would the project conflict with any applicable plan, policy or regulation of an agency with jurisdiction over the project adopted for the purpose of avoiding or mitigating an environmental effect?
Approved Project
Less Than Significant Impact. EIR No. 331 identified that there was consistency with Goals 14.1,

14.2, and 14.3 of the City of Anaheim’s General Plan Green Element, and this is ensured by the fact that the Proposed Project has been designed to be supportive of and consistent with the NCCP/HCP and associated IA. It would not conflict with any approved or adopted local policies or ordinances protecting biological resources.
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Additionally, the project was consistent with SCAG’s policies outlined in the Growth Management and Open Space chapters of the Regional Comprehensive Plan and Guide. Consistent with Policy

3.20, the Approved Project protects the majority of resources on site through the preservation of approximately 2,163 acres of open space (72 percent). Consistent with Policy 3.23, potential impacts to biological resources are mitigated to a level considered less than significant through implementation of PDFs, existing regulations, and standard conditions. As noted above, the project is supportive and consistent with the NCCP/HCP and IA, which were developed to address protection and management of CSS habitat and CSS-obligate species, and other covered habitats and species, and to mitigate anticipated impacts to those habitats and species on a programmatic, subregional level rather than on a project-by-project, single-species basis. This managed approach to resource protection is consistent with Ancillary Goal 9.08 of the Open Space Chapter. Wetland resources are not protected under the NCCP/HCP; however, a mitigation plan has been developed for wetland resources to reduce impacts to a level considered less than significant. Approval of this mitigation plan by the CDFW and ACOE would be required.

As described in Section 3.1 above, EIR No. 331 identified impacts to specimen trees that are protected under Section 18.112.070 of the City’s Municipal Code. As noted in Section 3.1 with implementation of PDF 2-1 and Standard Condition 2-3 impacts associated with removal of specimen trees as a result of the Approved Project would be less than significant.

Proposed Project
Less Than Significant Impact. EIR No. 331 identified that there was consistency with Goals 14.1,

14.2, and 14.3 of the City of Anaheim’s General Plan Green Element. This is ensured by the fact that the Proposed Project has been designed to be supportive of and consistent with the NCCP/HCP and associated IA, but as with the approved project a mitigation plan for impacts to wetland/ jurisdictional resources to reduce impacts to a level considered less than significant. Approval of the mitigation plan by the CDFW and ACOE would be required, like the Approved Project. The Proposed Project would not conflict with any approved or adopted local policies or ordinances protecting biological resources.

As discussed above, the proposed project would potentially impact riparian vegetation within Gypsum Creek. These impacts would be addressed through implementation of Standard Conditions SC 6-2 and SC 6-3 which will include approval of compensatory mitigation by CDFW and USACE and impacts are considered less than significant.

The Proposed Project is anticipated to potentially impact specimen trees protected by Section

18.112.070 of the City’s Municipal Code. Therefore, these impacts would be addressed through compliance with SC 2-3, which requires that, prior to issuance of the grading permit, a qualified arborist would conduct an inventory of trees on the project site and determine which City permits are needed for tree removal and require compliance with the City’s Replacement Tree List according to the Anaheim Municipal Code (Section 18.112.070). Any trees impacted and removed would require compensatory planting within the Proposed Project area that is compliant with Section

18.112.070 of the City’s Municipal Code and impacts to protected specimen trees would be less than significant.

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Therefore, there would be no greater impacts than identified with the Approved Project and the findings of EIR No. 331 remain valid.

3.6.3 Cumulative Biological Resources Impacts
Approved Project
Less Than Cumulatively Considerable. EIR No. 331 identified the Mountain Park property as being within the Central Subregion of the Central/Coastal NCCP/HCP. The NCCP Reserve System design has set aside approximately 37,000 acres for long-term management. By preserving large habitat blocks and maintaining connectivity, the NCCP Reserve System has minimized the cumulative impacts of proposed projects within authorized take lands. In view of the NCCP Reserve System design and monitoring and management guidelines, cumulative impacts to the following biological resources were considered to have been fully mitigated:
• Covered sensitive plant communities (e.g., CSS and coast live oak woodlands); • Wildlife movement;
• Covered sensitive wildlife species (e.g., coastal California gnatcatcher, coastal cactus wren); and • Covered sensitive plant species (e.g., foothill mariposa lily and Coulter’s matilija poppy).

Several criteria were used to analyze the cumulative impacts to biological resources not covered under the NCCP/HCP. The study area was established to encompass the open space bounded by the Puente Hills and Chino Hills to the north, the Peralta Hills to the west, the San Joaquin Hills to the south, and the Santa Ana Mountains to the east and south. This area contains a regional complex of relevant habitats, species’ populations, and biological systems. As a whole, this area provides a meaningful, regional ecological unit upon which to base the cumulative impacts analysis. The cumulative impacts analysis to species Not Covered under the NCCP/HCP considered past, present, and reasonably foreseeable projects to the extent that information was available and deemed to be reliable and accurate. Specific and general plans for the County and cities were reviewed and compiled information was collected during previous project public review processes. Potentially affected resources were categorized based on their sensitivity, significance, and role in ecosystem sustainability. Based upon the parameters established, cumulative impacts to biological resources are less than significant, and the findings of EIR No. 331 remain valid.

The Proposed Project preserved approximately two-thirds of the project site as open space precluding future development within open space areas. This preservation ensures that there would be no unanticipated future cumulative impacts that may have occurred otherwise. The Mountain Park project would contribute to the loss of raptor foraging habitat. The cumulative loss of raptor foraging habitat is within “authorized take lands” under the NCCP/HCP. The loss of raptor foraging habitat within the region is not expected to substantially affect raptor species or threaten their survival in the region. In addition, the preservation of 37,000 acres within the NCCP Reserve and the more than 900 acres of open space area within the TNC ACE alleviates these impacts as well as impacts to species Not Covered under the NCCP/HCP. Therefore, this loss is not considered cumulatively significant.
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An assessment of the cumulative impacts to many-stemmed dudleya included surveys conducted in May and June 2004 by PCR Services Corporation (PCR) and GLA within unsurveyed and undersurveyed areas of the NRPPA and NCCP Reserve. These surveys found approximately 41 new colonies of many-stemmed dudleya totaling approximately 11,700 individual plants. These results found that regional population numbers of many-stemmed dudleya are greater than previously known. The addition of this new data to the existing LSA NCCP Dudleya Study brings the total known colonies within the NCCP Reserve and the Irvine Company conservation areas to 180 colonies within conservation areas. The adjusted total of known many-stemmed dudleya colonies within the entire NCCP Central Subregion (conservation areas and proposed DAs) is 307 colonies. The proposed Mountain Park project, inclusive of all known projects, would impact approximately 23 percent of the known colonies in the NCCP Central Subregion. Due to the low cumulative percentage of impacts, the implementation of the pilot mitigation program, and the static nature of the impacts (i.e., no additional impacts from unforeseeable Irvine Company projects in the Central Subregion in the future), cumulative impacts are considered less than significant.

Proposed Project
Less Than Cumulatively Considerable Impact. The EIR No. 331 identified the MPSP as being within the Central Subregion of the Central/Coastal NCCP/HCP. The NCCP Reserve System design has set aside approximately 37,000 acres for long-term management. By preserving large habitat blocks and maintaining connectivity, the NCCP Reserve System has minimized the cumulative impacts of proposed projects impacts associated with Covered Species, sensitive habitats and listed and sensitive species within authorized take. With the NCCP/HCP in place for the Approved Project, the same conditions would apply to the Proposed Project. As noted above, subsequent to the establishment of the NCCP Reserve, over 900 acres in the TNC ACE and over 2,500 acres have been preserved in perpetuity providing for additional conservation for sensitive and non-sensitive habitat and species. Additionally, the potential cumulative impacts to other sensitive species and habitats, jurisdictional waters and protected trees are substantially less than the Approved Project given the reduced intensity of development associated with the Proposed Project. With implementation of the applicable SCs, MMs and appropriate PDFs, the Proposed Project would likely result in a less than cumulatively considerable impact compared to the Approved Project. Therefore, the Proposed Project would have less than cumulatively considerable impacts, and the findings of EIR No. 331 remain valid.

3.6.4 Findings Related to Biological Resources

3.6.4.1 No New Significant Effects Requiring Major Revisions to the Certified EIR Based on the foregoing analysis and information, there is no evidence that the Proposed Project requires a major change to the EIR No. 331. The Proposed Project would not result in new significant environmental impacts related to biological resources, and there would not be a substantial increase in the severity of impacts described in the EIR. No. 331

3.6.4.2 No Substantial Change in Circumstances Requiring Major Revisions to the Certified EIR No major changes to the Specific Plan Area have taken place since preparation of the EIR No. 331 that would require revisions to the analysis in the EIR No. 331. There is no information in the record

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or otherwise available that indicates there are substantial changes in circumstances pertaining to biological resources that would require major changes to the EIR No. 331.

3.6.4.3 No New Information Showing Greater Significant Effects than the Certified EIR This Addendum has analyzed available relevant information to determine whether there is new information that was not available at the time the EIR No. 331 was certified, indicating that a new significant effect not reported in that document may occur. Based on the information and analysis above, there is no substantial new information indicating that there would be a new significant impact related to biological resources requiring major revisions to the EIR No. 331.

3.6.4.4 No New Information Showing the Ability to Reduce Significant Effects in the Certified EIR There are no new information, mitigation, or alternatives to the Proposed Project that would substantially reduce one or more significant impacts pertaining to biological resources identified and considered in the EIR No. 331.

3.6.5 Standard Conditions and Mitigation Measures
The Standard Conditions and mitigation measures from EIR No. 331 pertaining to biological resources remain applicable to the Proposed Project, as they include requirements for future development projects. Applicable standard conditions and mitigation measures from EIR No. 331 have included below, and augmented to reflect current regulations and additional provisions that would be applicable to Proposed Project. With implementation of the standard conditions and mitigation measures identified below potential impacts to biological impacts associated with the Proposed Project to less than significant levels.

SC 6-1 Prior to approval of mass or rough grading plans impacting jurisdictional areas, the property owner/developer shall provide written evidence to the Department of Public Works/Planning & Building Department of compliance with the provisions of Section 1602 of the California Fish and Game Code. This shall be accomplished by providing a copy of the executed Streambed Alteration Agreement. Mass or rough grading plans shall include identification of Environmentally Sensitive Areas (ESA) and shall show placement of orange fencing or similar material to delineate and avoid jurisdictional features adjacent to the construction area.

SC 6-2 Prior to approval of mass or rough grading plans impacting jurisdictional areas, the property owner/developer shall provide the Department of Public Works/Planning & Building Department with a copy of the executed Section 404 permit obtained from the Army Corp of Engineers (ACOE). Mass or rough grading plans shall include identification of Environmentally Sensitive Areas (ESA) and shall show placement of orange fencing or similar material to delineate and avoid jurisdictional features adjacent to the construction area.

SC 6-3 Prior to approval of mass or rough grading plans, the property owner/developer shall provide the Department of Public Works/Planning & Building Department with a copy of the Section 401 water quality certification obtained from the Regional 3-91
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Water Quality Control Board (RWQCB). Mass or rough grading plans shall include identification of Environmentally Sensitive Areas (ESA) and shall show placement of orange fencing or similar material to delineate and avoid jurisdictional features adjacent to the construction area.

SC 6-4 Prior to approval of mass or rough any grading plans, the project biologist shall review the following contract specifications to verify that the following measures to minimize impacts to the coastal California gnatcatcher, western spadefoot and other coastal sage scrub (CSS) species or species covered by the Central/Coastal NCCP/HCP have been included on the specifications. The project biologist shall provide written evidence to the Department of Public Works in the form of a note on the grading plans that this condition has been completed. • To the maximum extent practicable, no grading of coastal sage scrub (CSS) habitat that is occupied by nesting gnatcatchers will occur during the breeding season (February 15 through July September 15). It is expressly understood that this provision and the remaining provisions of these “construction-related minimization measures” are subject to public health and safety considerations.

These considerations include unexpected slope stabilization, erosion control measures and emergency facility repairs. In the event of such public health and safety circumstances, landowners or public agencies/utilities will provide United State Fish and Wildlife Service/California Department of Fish and Wildlife (USFWS/CDFWG) with the maximum practicable notice (or such notice as is specified in the Natural Communities Conservation Program/Habitat Conservation Plan (NCCP/HCP) to allow for capture of gnatcatchers, cactus wrens, and any other CSS Identified Species that are not otherwise flushed, and will carry out the following measures only to the extent as practicable in the context of the public health and safety considerations. • Prior to commencement of grading operations or other activities involving significant soil disturbance, all areas of CSS habitat to be avoided under the provisions of the NCCP/HCP, shall be identified with temporary fencing or other markers clearly visible to construction personnel. Additionally, prior to the commencement of grading operations or other activities involving disturbance of CSS, a survey will be conducted to locate gnatcatchers and cactus wrens within 100 feet of the outer extent of projected soil disturbance activities and the locations of any such species shall be clearly marked and identified on the construction/grading plans.
• A monitoring biologist, acceptable to USFWS/CDFWG will be on site during any clearing of CSS. The landowner or relevant public agency/utility will advise USFWS/CDFWG at least seven (7) calendar days [and preferably fourteen (14) calendar days] prior to the clearing of any habitat occupied by Identified Species to allow USFWS/CDFWG to work with the monitoring biologist in connection with bird flushing/capture activities. The monitoring biologist will flush Identified Species (avian or other mobile Identified Species) from occupied

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habitat areas immediately prior to brush-clearing and earth-moving activities. If birds cannot be flushed, they will be captured in mist nets, if feasible, and relocated to areas of the site to be protected or to the NCCP/HCP Reserve System. It will be the responsibility of the monitoring biologist to assure that Identified bird or other mobile species will not be directly impacted by brush clearing and earth-moving equipment in a manner that also allows for construction activities on a timely basis.
• Following the completion of initial grading/earth movement activities, all areas of CSS habitat to be avoided by construction equipment and personnel will be marked with temporary fencing and other appropriate markers clearly visible to construction personnel. No construction access, parking, or storage of equipment or materials will be permitted within such marked areas. • In areas bordering the NCCP Reserve System or Special Linkage/Special Management areas containing significant CSS identified in the NCCP/HCP for protection, vehicle transportation routes between cut-and-fill locations will be restricted to a minimum number during construction consistent with project construction requirements. Waste dirt or rubble will not be deposited on adjacent CSS identified in the NCCP/HCP for protection. Pre-construction meetings involving the monitoring biologist, construction supervisors, and equipment operators will be conducted and documented to ensure maximum practicable adherence to these measures.
• CSS identified in the NCCP/HCP for protection and located within the likely dust drift radius of construction areas shall be periodically sprayed with water to reduce accumulated dust on the leaves as recommended by the monitoring biologist.
• If western spadefoot is not found in suitable habitat areas during initial ground disturbance, the monitoring biologist will spot-check grading activities (on an as- needed basis, as determined by the monitoring biologist) until grading is completed for those areas. If western spadefoot is brought to the surface during grading/excavation, individuals will be collected and relocated following pre- approved methods by the California Department of Fish and Wildlife (CDFW) or an approved Western Spadefoot Management Plan
• Conduct focused surveys, by a quailed biologist, in suitable habitat for Crotch bumblebee within the project area and submit a survey report to the Public Works Department/Department of Planning & Building, prior to issuance of a grading permit. The surveys shall be conducted during the months of April through June, consisting of three site visit typically 2 to 4 weeks apart. The survey report shall document the presence or absence of Crotch bumble within the project area. If the survey results are negative, the qualified biologist will submit a summary of findings, and a survey report prepared and submitted to CDFW. If survey results are positive, the applicant will consult with CDFW to 3-93
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determine appropriate measures needed to address potential impacts to the species, prior to the issuance of a grading permit.

SC 6-5 Prior to approval of mass or rough grading plans, the property owner/developer shall report the amount of coastal sage scrub that would be impacted by proposed grading activities. The amount of coastal sage scrub impacts shall be noted on plans submitted for grading permits and submitted to the Planning Department and to the Nature Reserve of Orange County (NROC) to ensure that a proper accounting of coastal sage scrub impacts is recorded for purposes of the NCCP/HCP.

SC 6-6 On an annual basis until grading activities are complete, the property owner/developer shall provide the Planning & Building Department and Nature Reserve of Orange County (NROC) with a calculation of the total amount of coastal sage scrub that has been removed during the calendar year.

MM 6-1 Prior to issuance of grading or building permits initiation of construction activities, the property owner/developer shall retain a project biological monitor approved by both the United States Fish and Wildlife Services and California Department of Fish and Game. The project biological monitor shall ensure that all permit conditions are met, all Mitigation Measures are properly implemented, and that the project complies with all Standard Conditions and project design features. The project biological monitor shall also be present during any pre-grade meetings, mass grading operations, and periodically during construction to ensure that sensitive resources designated for preservation are properly protected. Beginning with the initiation of construction or grading activities, the project biological monitor shall submit monthly status reports to the Planning Department to demonstrate compliance with this measure. Additionally, the following construction site housekeeping measures shall be incorporated into all conditions of approval for grading and building permits and compliance verified during construction by the biological monitor.
• To prevent inadvertent entrapment of animals during the construction phase of a project, all excavated, steep-walled holes or trenches more than 2 ft deep shall be covered at the close of each working day by plywood or similar materials. If the trenches cannot be closed, one or more escape ramps constructed of earthen-fill or wooden planks shall be installed. Before such holes or trenches are filled, they shall be thoroughly inspected for trapped animals. In the case of trapped animals, escape ramps or structures shall be installed immediately to allow the animal(s) to escape. • For the duration of construction activities, all food-related trash items such as wrappers, cans, bottles, and food scraps shall be disposed of in securely closed containers and removed at least daily from the construction site.

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• Pets, such as dogs or cats, shall not be permitted on the project site during construction to prevent harassment, injury, or death of wildlife in the project vicinity.
• Use of rodenticides and herbicides in project sites shall be restricted. This is necessary to prevent primary or secondary poisoning of predators and the depletion of prey populations on which they depend. All uses of such compounds shall observe label and other restrictions mandated by the United States Environmental Protection Agency, the California Department of Food and Agriculture, and other State and federal legislation.

MM 6-2 Prior to the approval of mass or rough grading plans issuance of grading permits impacting jurisdictional areas, the property owner/developer shall provide a wetland mitigation plan approved by the ACOE (for Section 404 areas) and CDFWG (for the Section 1602 areas) to the Department of Public Works. A total of 14.1 acres of riparian mitigation are necessary to offset the loss of ACOE and CDFWG jurisdictional areas as a result of the Proposed Project. A Conceptual Wetland and Riparian Habitat Mitigation Plan has been prepared by LSA (February 2005). The purpose of the mitigation plan is to:
• Create (establish), restore, or enhance wetland/riparian habitats on site to the maximum extent practicable to minimize the on-site loss of ACOE and CDFWG jurisdictional acreage and function, and provide off-site mitigation for the remainder of the impacts;
• To implement, to the extent practicable, off-site mitigation in the Santa Ana River watershed, as close to the study area as possible or otherwise at a key ecological site;
• To return jurisdictional habitats that are temporarily disturbed during construction to pre-construction conditions; and,
• To ensure that adjacent non-jurisdictional habitats are protected. • The project disturbance limits shall be clearly marked with construction fencing (or other highly visible material), and construction/materials staging and vehicle/equipment maintenance and fueling areas shall be located at least 100 ft away from Gypsum Canyon Channel, where feasible.
• To minimize temporary disturbances, all project-related vehicle traffic shall be restricted to established roads, construction areas, and other designated areas.

The preferred on-site mitigation approach shall be approved by the ACOE, CDFWG and RWQCB during the permitting process. One possible component of the on-site mitigation, to address the impacts of the box extension on the already disturbed Gypsum Canyon Creek channel, could include a rebuilt creek as a low-flow riparian 3-95
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corridor through the canyon mouth area. Conceptually, the box extension shall act as a high-flow by-pass that efficiently conveys the more intense and destructive flood flows. The riparian corridor shall extend upstream to the road crossing of Gypsum Canyon Creek. The riparian corridor shall consist of a riverine channel flanked by planted embankments. The riverine channel would be soft bottom and the riparian vegetated floor would be nurtured by low and seasonal run-off diverted into it from a channel split from the new box culvert opening. This "splitter" shall consist of a junction opening that becomes a tunnel that would accommodate storm flows as well as wildlife movement under the road crossing to the riparian corridor.

MM 6-3 Prior to approval of mass or rough grading plans a grading permit, the property owner/developer shall submit copies of contractor specifications to the Department of Public Works/Planning & Building Department that include the following note:
“Initial clearing of vegetation that has been identified as being used by the southwestern willow flycatcher shall be conducted outside of the breeding season or with the presence of a biological monitor during the breeding season to ensure that no individuals of this species are directly impacted. The breeding season for the southwestern willow flycatcher is between May 15 and July 31.” Following completion of initial clearing of vegetation, the project biological monitor shall provide written evidence to the Planning & Building Department that this measure has been completed.

MM 6-5 Prior to approval of street improvement plans for Gypsum Canyon Road, the property owner/developer shall submit copies of contractor specifications to the Department of Public Works/Planning and Building Department that include the following requirements to protect the summer roost of Yuma myotis within the Gypsum Canyon culverts under the 91 Freeway and within Gypsum Creek: (1) construction activities to lengthen the culverts shall be scheduled outside of the critical breeding time (April May 1 through August 1531) to avoid direct impacts; (2) if construction must occur between May April 1 and August 1531,, all construction activities shall occur outside the current culverts and no deeper than 25 feet inside the culverts to avoid a negative effect on the colony, (3) no night work shall occur around the culvert openings and only construction lighting necessary for safety purposes shall be used near the culvert openings and (4) design lighting such that it minimizes light trespass into adjacent habitat. All lighting fixtures will have light shields or similar devices (e.g., Dark Sky-compliant lighting) installed to minimize illuminance above the site and avoid light trespass into Gypsum Creek and other adjacent open space areas. The color temperature of the light emitted by the luminaires should be less than 2700 Kelvin to minimize adverse effects to wildlife, including bats. The specifications shall be prepared by a CDFW approved bat biologist. Following completion of construction activities associated with the culverts, the project biological monitor shall provide written notification to the Planning Department that the contractor specifications have been complied with.

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The specifications shall also include the conduction of a bat habitat assessment of suitable roosting trees prior to construction. If trimming or removal of suitable roosting trees are identified within the project work area, a CDFW approved bat biologist will work with the construction contractor during the trimming and removal process. Trees and snags that have been identified as confirmed or potential roost sites require a two-step removal process and the involvement of the bat biologist to ensure that no roosting bats are killed during this activity. This two- step removal shall occur over 2 consecutive days as follows. On Day 1, branches and limbs not containing cavities, as identified by a qualified bat biologist, will be removed. On Day 2, the remainder of the tree may be removed without supervision by a bat biologist. The disturbance caused by limb or frond removal, followed by an interval of 1 evening, will allow bats to safely abandon the roost.

MM 6-6 Prior to approval of mass or rough grading plans issuance of a grading permit, the property owner/developer shall submit copies of contractor specifications to the Department of Public Works/Planning & Building Department that include the following requirements to protect nesting birds regulated by the Migratory Bird Treaty Act: “When feasible, vegetation removal activities shall be scheduled between July 16 and February 14 to avoid the nesting season. This would ensure that no active nests would be disturbed and that removal could proceed rapidly. If vegetation removal activities shall occur during the nesting season (February 15 to July 15), all suitable habitat shall be thoroughly surveyed for the presence of nesting birds by a qualified biologist prior to removal. If any active nests are detected, the area shall be flagged, along with a minimum 50-foot buffer (buffer may range between 50 and 300 feet as determined by the monitoring biologist) and shall be avoided until the nesting cycle is complete or it is determined by the monitoring biologist that the nest has failed.” In addition, a biologist shall be present on the site to monitor the vegetation removal to ensure that nests not detected during the initial survey are not disturbed. The project biological monitor shall provide written notification to the Planning & Building Department that these requirements have been accomplished following completion of grading activities associated with each grading permit.

3.7 TRAFFIC AND CIRCULATION

3.7.1 Existing Environmental Setting
The key roadways that are within the Proposed Project’s vicinity are SR-91, SR-241, La Palma Avenue, Gypsum Canyon Road, and Santa Ana Canyon Road. SR-91 is north of the project site and is expected to facilitate the majority of the regional travel to and from the site. SR-91 begins in the Inland Empire to the east, traverses all of northern Orange County, and terminates at I-110 in Los Angeles County. SR-241 is west of the project site, although no connection exists between SR-241 and the project site. La Palma Avenue is an east-west roadway located north of the project site and is designated as a Secondary Arterial. Within the vicinity of the project site, La Palma Avenue has four lanes and a center median, with no sidewalks or bike lanes and no on-street parking. Gypsum Canyon Road is a north-south roadway accessing the project site and is classified as a Hillside 3-97
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Primary Arterial by the City’s General Plan Circulation Element. Hillside Primary Arterials can be constrained by terrain and may provide four lanes divided with left-turn pockets. Gypsum Canyon Road is currently four divided lanes between La Palma Avenue and the SR-91 Westbound (WB) Ramps. Bike lanes and a horse trail are proposed along Gypsum Canyon Road in the Anaheim General Plan. Santa Ana Canyon Road is an east-west Hillside Secondary Arterial. The purpose of these roadways is to provide for circulation within Anaheim. In the current condition, however, a large quantity of regional traffic uses Santa Ana Canyon Road in the peak commute hours to bypass SR-91.

Transportation System Performance Criteria for the Approved Project To measure Transportation System Performance Criteria, EIR No. 331 utilized traffic level of service (LOS). LOS was analyzed in the document as it was the relevant performance criteria to be used when the document was prepared. Traffic LOS is a widely used indicator of system performance.

LOS values range from “A” to “F,” with LOS A representing free-flow traffic conditions and LOS F representing severe traffic congestion. LOS values are based on volume/capacity (v/c) and intersection capacity utilization (ICU) ranges. The v/c and ICU ranges applied to roadways are designated in the Orange County Congestion Management Plan (CMP) and/or the City of Anaheim and City of Yorba Linda General Plans. LOS “D” (ICU not to exceed 0.90) is the traffic performance standard that has been adopted by the cities of Anaheim, Orange, and Yorba Linda. The results of the LOS analysis from the Traffic Impact Study and EIR No. 331 will be mentioned in the impacts discussed below.

Studies Prepared for the Proposed Project
A Traffic Impact Analysis, a Vehicle Miles Traveled (VMT) Analysis, and a Parking Demand Study have been prepared to assess the potential for traffic, circulation, and parking impacts for the Proposed Project.

Traffic Impact Analysis for the Proposed Project
The Traffic Impact Analysis (LSA 2024) analyzed the LOS for the Proposed Project and Approved Project scenarios at the project site area, which includes the four intersections and four roadway segments mentioned below.

Intersections:
a. Gypsum Canyon Road/La Palma Avenue
b. Gypsum Canyon Road/SR-91 WB Ramps
c. Gypsum Canyon Road/SR 91 Eastbound (EB) Ramps (Unsignalized) d. Gypsum Canyon Road (Unsignalized)
Roadway Segments:
a. Gypsum Canyon Road (La Palma Avenue to SR-91 WB Ramps) b. Gypsum Canyon Road (SR-91 WB Ramps to SR-91 EB Ramps) c. Gypsum Canyon Road (SR-91 EB Ramps to Santa Ana Canyon Road) d. Santa Ana Canyon Road (West of Gypsum Canyon Road)

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The Traffic Impact Analysis conducted several traffic scenarios, which will be further discussed below in the comparison analysis of the approved and Proposed Project.

Vehicle Miles Traveled Analysis for the Proposed Project A VMT Analysis (LSA 2024) was prepared to address the potential VMT impacts of the Proposed Project. The City of Anaheim Traffic Impact Analysis Guidelines for California Environmental Quality Act Analysis (June 2020) establish methodology for transportation analysis consistent with SB 743, which eliminates consideration of vehicle LOS for the purposes of CEQA. Rather than consider a project’s effect on vehicle LOS, CEQA now considers a project’s effect on VMT. The VMT generated by a project is a function of total trips and the length of those trips.

The City’s guidelines establish three screening criteria for projects that are not anticipated to result in significant increases in VMT and could be presumed to have a less than significant impact absent substantial evidence to the contrary. Among the Type 3 project screening criteria, projects that are public services are anticipated to have a less than significant impact on VMT. While the Proposed Project is a public service, a VMT assessment was nonetheless prepared.

The City’s guidelines establish VMT per service population (e.g., population plus employment) as the metric of analysis and Orange County as the regional average. The City’s guidelines further establish that VMT analysis and forecasting is to use the Orange County Transportation Analysis Model (OCTAM) to calculate project‐generated VMT and project effect on VMT for the project traffic analysis zone (TAZ) under four scenarios:
• Baseline conditions (i.e., OCTAM baseline conditions) • Baseline plus project (i.e., including the project land use in OCTAM base year model runs) • Cumulative no project (i.e., OCTAM future model conditions) • Cumulative plus project (i.e., including the project land use in OCTAM future‐year model runs) This results in the summary of two metrics, project-generated VMT per service population compared to the regional average threshold of significance and the project’s effect on citywide VMT per service population compared to the no project condition. The result of the LSA VMT Analysis for the Proposed Project is further discussed below.

Parking Demand Study for the Proposed Project
A Parking Demand Study (LSA 2024) was prepared to the assess consistency of the project design with the Anaheim Municipal Code. Anaheim Municipal Code Section 18.42.040 establishes required off-street parking for nonresidential projects. Due to the unique nature of the Proposed Project being a cemetery land use, the Municipal Code requires preparation of a parking demand study per paragraph 18.42.040.010.0108. The results of the Parking Demand Study concluded that the Proposed Project provides adequate parking supply with regard to demand and are further discussed below.
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3.7.2 Comparison of Impacts for the Approved Project and the Proposed Project EIR No. 331 included several PDFs that addressed the previously Approved Project’s internal circulation system, which has since then been modified. The PDF’s were developed to address the Approved Project’s corresponding development areas, whereas the Proposed Project only involves DA 5. Due to that reason, PDF 7-1 and 7-2 (noted in Table 2.B, above) that relate to entry roadway would remain applicable, where feasible.

The Initial Study prepared for the Approved Project determined that the Approved Project would not result in a significant change in air traffic patterns, including either an increase in traffic levels or a change in location that result in substantial safety risks. As a result of the previous analysis, the Proposed Project would result in the same conclusion as the Approved Project. Consequently, no further analysis is necessary regarding this threshold in terms of the approved and Proposed Project.

Would the project cause a change in air traffic patterns including either an increase in traffic levels or change in location that result in substantial safety risks? Would the project cause an increase in traffic which is substantial in relation to the existing traffic load and capacity of the street system? Or would the project exceed, either individually, or cumulatively, a level of service standard established by the congestion management agency for designated roads or highways?
Approved Project
Less Than Significant With Mitigation Incorporated. EIR No. 331 utilized trip generation estimates for the MPSP traffic analyses that were based on the proposed land uses. According to the document, the Approved Project is expected to generate approximately 25,154 daily trips (2,325 of which would be generated in the a.m. peak hour and 2,522 of which would be generated during the p.m. peak hour).

The Traffic Impact Analysis conducted traffic volume forecasts of the Approved Project traffic conditions if the MPSP’s anticipated 1,595 residential units in the DAs were to be built out otherwise known in the study as the General Plan Buildout (2045) No Project scenario. These conditions were calculated using the OCTAM and existing traffic volume data to generate daily roadway traffic volume estimates for the Approved Project scenario. The General Plan Buildout No Project scenario results indicated that with buildout of the roadway improvements included in the General Plan, the intersections and roadway segments would operate at satisfactory LOS if the Approved Project were to be built out with the exception of Gypsum Canyon Road/La Palma Avenue.

EIR No. 331 was adopted in 2005. In 2005, LOS was used for measuring traffic impacts. EIR No. 311 identified the traffic street systems that are anticipated to operate at an unacceptable LOS based on future scenarios: the Weir Canyon Road and La Palma Ave intersection in Yorba Linda and south of the Weir Canyon Road and La Palma Ave intersection. Additionally, the Approved Project’s anticipated impact to the Weir Canyon Road and Santa Ana Canyon ICU constituted a significant contribution of future traffic where long-range improvements were not identified in the City of Anaheim General Plan. EIR No. 331 includes PDFs and mitigation measures to ensure traffic improvements in relation to the Approved Project would not exceed satisfactory LOS. To address EIR

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No. 331 increases in traffic due to construction, however, MM 7-4 required a traffic control plan prior to construction of the development areas that would provide construction haul routes and location of lane closures along with pedestrian-related impacts to sidewalks and intersection crossings. Overall, EIR No. 331 concluded that with implementation of the PDFs and mitigation measures, development of the Approved Project, including the development of DA 5, would not result in a significant impact on the existing traffic capacity of the street system or exceed a LOS standard established by the Orange County CMP and City of Anaheim Traffic Guidelines.

Proposed Project
Less Than Significant With Mitigation Incorporated. The Traffic Impact Analysis calculated the daily and peak-hour trips for the Proposed Project using trip rates contained in the Institute of Transportation Engineers’ (ITE) Trip Generation, 11th Edition. The Proposed Project is anticipated to generate approximately 1,084 new daily trips, 30 of which would occur in the a.m. peak hour (25 inbound and 5 outbound) and 83 of which would occur in the p.m. peak hour (25 inbound and 58 outbound). Compared to the Approved Project, the Proposed Project would result in substantially lower trip generation.

The Traffic Impact Analysis also conducted an Existing Plus Project theoretical scenario, which is the calculation of existing traffic volume plus a fully built and operating project. The total project trips were added to the existing traffic volumes at the study intersections and roadway segments for this Existing Plus Project scenario. The results indicated that all the aforementioned roadway segments and intersections would continue to operate at satisfactory LOS under this scenario except for the Gypsum Canyon Road and Santa Ana Canyon Road intersection, which operates at unsatisfactory LOS in Existing and Existing Plus Project scenarios as an unsignalized intersection. Traffic signal warrants were considered consistent with the City’s guidelines, however, installation of a traffic signal is not recommended as part of the Proposed Project because the intersection does not meet Manual on Uniform Traffic Control Device (MUTCD) traffic signal warrants.

Additionally, the Traffic Impact Analysis conducted a General Plan Buildout (2045) Plus Project scenario in which it eliminates the 1,595 residential units and replaces them with the Proposed Project’s lower trip generation. The previously mentioned General Plan Buildout No Project scenario reflects the Approved Project use, whereas the General Plan Buildout Plus Project scenario reflects the Proposed Project use. Mountain Park Drive would not be extended into Development Area 5 under the proposed project and the intersection of Gypsum Canyon Road/Mountain Park Drive would not be constructed at the previously anticipated location. The Proposed Project is not constructing the extension of Weir Canyon Road or Mountain Park Drive elements of the Approved Project but does not preclude their future construction. The General Plan Buildout Plus Project scenario indicates that reduced trip generation from the project site is anticipated to improve the performance of Gypsum Canyon Road/La Palma Avenue. All four study intersections are forecast to operate at satisfactory LOS with the Proposed Project without the extension of Weir Canyon Road and construction of Mountain Park Drive but with Gypsum Canyon Road and Santa Ana Canyon Road roadway improvements included in the General Plan. Further, the General Plan Buildout Plus Project scenario demonstrates that the four roadway segments would continue to operate at satisfactory LOS. Overall, the General Plan Buildout Plus Project scenario would provide an improvement to daily traffic volumes due to reduced trips generated by the project site compared 3-101
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to land uses in the MPSP even without the extension of Weir Canyon Road and Mountain Park Drive.

As mentioned previously for the Approved Project, the General Plan Buildout No Project scenario indicated that the intersection and of Gypsum Canyon Road/La Palma Avenue was anticipated to exceed the satisfactory LOS conditions. The Proposed Project results in lower trip generation and maintains satisfactory LOS at the Gypsum Canyon Road/La Palma Avenue intersection.

Note that the Gypsum Canyon Road/Santa Ana Canyon Road is currently unsignalized, operates at unsatisfactory LOS, and queuing on the SR-91 Eastbound on-ramp extends through this intersection.

Continued vehicle queueing in the intersection could inhibit northbound and southbound through traffic into and out of the project site and impair intersection operation. Eastbound driver failure to comply with stop signs and watch for oncoming vehicles could also impair intersection operation.

The following improvements have been included in the project description of the Proposed Project (listed above) to enhance the intersection of Gypsum Canyon Road/Santa Ana Canyon Road at the time the northbound leg is modified to permit through traffic:
• Southbound Gypsum Canyon Road
○ Retain retroreflect strip (consistent with Section 2A.21 of MUTCD) already mounted to sign support.
○ Install R3-18 sign below existing stop sign indicating no left or U-turns. • Eastbound Santa Ana Canyon Road
○ Retain retroreflect strip (consistent with Section 2A.21 of the MUTCD) already mounted to sign support.
○ Replace existing 30 by 30-inch stop sign to 36 by 36 inch stop sign (R1-1) and (for a temporary period of six months consistent with Section 2A.15 of the MUTCD) add two red flags above the stop sign for enhanced conspicuity.
○ Add R10-7 Do Not Block Intersection sign below the stop sign. ○ Place an additional R10-7 Do Not Block Intersection sign on east side of Gypsum Canyon Road directly opposite eastbound leg.
○ Add 30 by 30-inch warning sign W23-2 New Traffic Pattern Ahead 250 feet in advance of intersection on a temporary basis for six months (consistent with Section 2C.52 of the MUTCD) to alert drivers to the addition of north-south traffic.

Therefore, based on the analysis above, implementation of the applicable PDF’s, improvements to the Gypsum Canyon Road and Santa Ana Canyon Road, submitting a traffic phasing plan and traffic control plan in MM 7-3 and 7-4 as mentioned in EIR No. 311, the Proposed Project would not result in a significant impact on the existing traffic capacity of the street system or exceed a LOS standard established by the Orange County CMP and City of Anaheim Traffic Guidelines.

Subsequent to certification of EIR No. 331, the State CEQA Guidelines were revised on July 1, 2020, and now require a VMT analysis for land use projects. Among the changes to the guidelines was the removal of vehicle delay and LOS from consideration under CEQA. With the adopted guidelines,

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transportation impacts are evaluated based on a project’s effect on VMT. As previously described, a VMT Analysis was prepared utilizing the OCTAM travel demand model and calculated the VMT per service population metric for the General Plan Buildout in 2045 (known as the Approved Project) and the Proposed Project in 2045. Table 3.E demonstrates the comparison of the General Plan Buildout scenario in comparison to the Proposed Project.

Table 3.E: Comparison of Future Land Use
VMT Service Population VMT Per Service Population
General Plan Buildout 265,732 6,337 41.7
Proposed Project 11,130 524 21.3
Difference (254,602) (5,853) (20.4)
Source: Gypsum Canyon Cemeteries – Vehicle Miles Traveled Analysis (2023) and OCTAM 5.

VMT= vehicle miles traveled

The study found the Proposed Project’s VMT per service population to be 21.3 VMT per service population, which is approximately half of the VMT per service population for the General Plan Buildout (41.7 VMT per service population).

Additionally, the analysis also included OCTAM calculations that demonstrate the Proposed Project generated VMT per service population in both a baseline (2016) and future year (2045) buildout scenario in comparison to the Orange County regional average threshold standard. Please note that the City establishes a significance threshold of 85 percent (i.e., the Orange County average). Table

3.F shows the results of the project-generated VMT per service population and the Orange County regional average threshold.

Table 3.F: Project-Generated VMT
VMT Service Population VMT Per Service
Population
Significance Threshold
(85% of County Average)
Baseline (2016) 11,662 524 22.3 25.7
Future Year (2046) 11,130 524 21.3 25.6
Source: Gypsum Canyon Cemeteries – Vehicle Miles Traveled Analysis (2023) and OCTAM 5.

County = County of Orange
VMT= vehicle miles traveled

The study found the Proposed Project generated VMT per service population for baseline and future year conditions would be below the significance threshold for Orange County.

Furthermore, per the City’s guidelines of disclosing VMT impacts, the analysis also included OCTAM calculations demonstrating citywide conditions with and without the Proposed Project under both the baseline and future scenarios. Table 3.G demonstrates the OCTAM calculations for the citywide VMT per service population scenarios.
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Table 3.G: Citywide VMT per Service Population
VMT Service Population VMT Per Service Population
Baseline (2016)
Without Project 10,299,989 525,861 19.6
With Project 10,342,652 526,385 19.6
Future Year (2045)
Without Project 11,730,486 639,996 18.3
With Project 11,618,445 634,143 18.3
Source: Gypsum Canyon Cemeteries – Vehicle Miles Traveled Analysis (2023) and OCTAM 5.

VMT= vehicle miles traveled

As a result, the Proposed Project would have no effect on citywide VMT per service population in comparison to the no project condition. Based on the previous analysis above, the Proposed Project would not cause a significant impact on traffic in relation to existing traffic load or capacity, and the project would have a less than significant impact on VMT. Therefore, the Proposed Project would not conflict with an applicable plan, ordinance, or policy establishing measures of effectiveness for intersections or be inconsistent with State CEQA Guidelines Section 15064.3(b). Therefore, the conclusions of EIR No. 331 regarding traffic impacts remain valid.

Would the project substantially increase hazards due to a design feature or incompatible uses? Approved Project
Less Than Significant Impact with Mitigation. EIR No. 331 provides an evaluation of the design of the internal roadway with respect to potential design hazards. Specifically, the previously proposed Mountain Park Drive was observed to have fairly steep grades due to its topography and could create potential safety hazards related to speed and visibility in DA 4. EIR No. 331 would implement MM 7-2, which involves the final roadway design of Mountain Park Drive to be modified with curvilinear alignments that provide adequate sight distance for safety in DA 4. Overall, the Approved Project would not substantially increase hazards due to design features or incompatible uses.

Therefore, EIR No. 331 determined that impacts associated with hazardous design features would be less than significant with mitigation.

Proposed Project
Less Than Significant. The Proposed Project includes the development of an entry plaza located south of the existing Santa Ana Canyon Road and Gypsum Canyon intersection and construction of an external road that provides access to both the public and CalVet cemeteries within DA 5. The Proposed Project proposes cemetery uses on DA 5 and would not impact design considerations with roadway design through DA 4. The street roadway system for the Proposed Project would be designed to appropriate roadway standards to ensure that no hazard related to speed or visibility would occur. Although the proposed roadway design within DA 5 would be different than the previously Approved Project, appropriate safety design measures would be implemented to ensure the Proposed Project would not substantially increase hazards or incompatible uses. The conclusions of EIR No. 331 regarding hazardous design features remain valid.

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Would the project result in inadequate emergency access or parking capacity? Approved Project
No Impact. The Approved Project included provision of access to the Proposed Project from Santa Ana Canyon Road and Gypsum Canyon Road to the north and from a proposed extension of Weir Canyon Road to the west. In addition, the Approved Project would provide the following roadway design features to facilitate emergency access/service: a drivable median on Gypsum Canyon Road into DAs 1 and 2 and the entrance to DA 4; emergency accessways into cul-de-sac areas, where feasible; provisions for emergency access at entry gates; and use of the existing access road in the TNC ACE and NCCP/HCP Reserve as an emergency egress route. These emergency access features are included in the Fire Master Plan for the MPSP. The Approved Project was determined to not result in an unrelated impact related to emergency access.

EIR No. 331 concluded that parking would be provided for residential and nonresidential (private community recreation center, fire station, etc.) uses, and would be consistent with the parking requirements outlined in the approved MPSP Amendment. These parking requirements are consistent with the City of Anaheim parking requirements outlined in the Zoning Code. No significant impact related to parking would result from project implementation, and no mitigation is required. As a result, no significant impacts to parking would occur, and impacts would remain less than significant.

Proposed Project
No Impact. As described in Section 2.3.1.5, Circulation/Roadways, of the Project Description, the primary access to the Proposed Project would be from Santa Ana Canyon Road and Gypsum Canyon Road through a security gated entry plaza. The entry plaza would be located south of the existing Santa Ana Canyon Road/Gypsum Canyon Road intersection and there would be an exterior entry or loop road divided into a 46-foot access road (one southbound lane with a median and two northbound lanes) that would utilize two bridges (14 feet wide and 100–120 feet long) to cross over Gypsum Creek. One bridge would provide ingress, and the other would provide egress from the cemetery and join into one 36-foot access road that provides single-lane inbound and outbound access to both proposed cemeteries. The project proposes two access points to the OCCD cemetery on the lower pad: (1) the primary cemetery entrance built during the first phase of construction, and (2) secondary access to the exterior loop road for additional site circulation. Based on the Proposed Project design, the Proposed Project would provide adequate emergency access designed to the City of Anaheim Municipal Code and California Fire Code.

The Parking Demand Study based the parking spaces on the site plans provided for both the public and State cemetery. The public cemetery site plan indicates 44 marked parking spaces near the proposed administrative building and noted that number of potential on-street parking spaces for each of the internal streets, which resulted in 361 on-street parking spaces, totaling 405 parking spaces. The State cemetery plans 24 marked parking spaces in a parking lot near the administrative building, with internal roadways (totaling 8,375 linear feet) could accommodate approximately 335 to 380 parking spaces, which totals approximately 359 to 404 parking spaces. The roadway connecting the two cemetery sites is approximately 3,530 feet between the public and private 3-105
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cemetery, which could accommodate 141 to 160 additional parked vehicles during periods of unusually high parking demand.

The Parking Demand Study utilized parking data from three different cemeteries (El Toro Memorial Park, Santa Ana Cemetery, and Riverside National Cemetery) to assist in determining parking demand for both proposed cemeteries. Surveys were conducted during clear weather on typical weekdays, a typical Saturday, and also on Veteran’s Day (for the Veterans’ Cemetery) to generate reliable data inputs. Based on the results of the study, it was determined that the Proposed Project’s parking supply exceeds the calculated parking demand necessary to serve the Proposed Project.

Please see Table 3.H for the calculated parking demand for both the public and private cemetery.

Table 3.H: Project Parking Demand
Public Cemetery
(405 Parking Spaces)
Veterans’ Cemetery
(359 to 404 Parking Spaces)
Developable Area 80 acres 100 acres
Weekday Parking Rate 1.76 spaces per acre 1.20 spaces per acre Weekday Parking Demand 141 spaces 120 spaces
Saturday Parking Rate 3.08 spaces per acre 0.27 space per acre Saturday Parking Demand 246 spaces 27 spaces
Veterans’ Day Parking Rate – 2.96 spaces per acre
Veterans’ Day Parking Demand – 296 spaces
Minimum Surplus Parking 159 63
Source: LSA (2023).

As noted in the Parking Study, if the Proposed Project were to experience high levels of parking demand, the Proposed Project would be able to accommodate additional parking along the access road, which is typical for cemetery operations. Therefore, the conclusions of EIR No. 331 remain valid, and no significant impacts to parking capacity or emergency access would occur.

Would the project comply with adopted policies, plans and programs for alternative transportation? Approved Project
No Impact. EIR No. 331 indicated that the MPSP includes public and private sidewalks and trails, as well as on-street bikeways to accommodate the recreational and transportation needs of residents.

These facilities would provide for an alternative mode of transportation for project residents and residents in surrounding existing communities. Additionally, the Orange County Transportation Authority (OCTA) provides bus service in Anaheim and surrounding jurisdictions. Based on information presented in the City of Anaheim General Plan regarding OCTA’s 10-year transit plan, there are no existing or planned bus routes east of Weir Canyon Road. The Approved Project would not interfere with or impact existing bus service or future transit facilities.

Proposed Project
No Impact. The Proposed Project involves the creation of two cemeteries instead of the previously proposed residential development. Although the Proposed Project does not include on-road bicycle

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improvements, it does provide for enhanced access to the Gypsum Canyon Wilderness Area trailhead. More specifically, the project is located adjacent to the proposed Gypsum Canyon Road and Santa Ana Canyon Road intersection, which is adjacent to existing and planned bikeways within Anaheim. The City of Anaheim’s Bicycle Master Plan includes an existing Class II bikeway on Santa Ana Canyon Road and proposes a Class II bikeway on Gypsum Canyon Road. The Proposed Project would not conflict with planned bicycle facilities and would provide enhanced trail access to the Gypsum Canyon Wilderness Area from existing roadways and Featherly Park. Therefore, the Proposed Project would not conflict with any adopted policies, plans, or programs for alternative transportation, and the findings of EIR No. 331 remain valid.

Would the project conflict with any applicable plan, policy or regulation of an agency with jurisdiction over the project adopted for the purpose of avoiding or mitigating an environmental effect?
Approved Project
No Impact. EIR No. 331 concludes that it remains consistent with the City of Anaheim’s General Plan’s Circulation Element goals and policies along with the SCAG’s Regional Transportation Plan (RTP) through several traffic improvements proposed in the MPSP. Additionally, the Approved Project includes transportation facilities necessary to serve the planned housing, employment, education, recreation, and other land uses included in the MPSP. As such, EIR No. 331 found that the Approved Project would not conflict with any applicable plan, policy, or regulation of an agency with jurisdiction over the project for the purpose of mitigating an environmental effect, and the findings remain valid.

Proposed Project
No Impact. The Proposed Project results in fewer vehicle trips within DA 5 than the Approved Project and continues to promote alternative modes of transportation by providing enhanced access to the Gypsum Canyon Wilderness Area. The Proposed Project would not preclude the implementation of planned bicycle facilities on Santa Ana Canyon Road or Gypsum Canyon Road as envisioned in the MPSP and the City of Anaheim’s General Plan Circulation Element and Bicycle Master Plan. The Proposed Project would be consistent with the City of Anaheim’s General Plan Circulation Element, and the findings of EIR No. 331 remain valid.

3.7.3 Cumulative Traffic and Circulation Impacts
Approved Project
Less Than Cumulatively Considerable Impact. EIR No. 331 considered cumulative traffic scenarios for future years (2010 and 2025) based on the City of Anaheim citywide traffic model, which considers land use assumptions outlined in the City of Anaheim’s General Plan as well as the general plans of neighboring jurisdictions. As a result, the analysis presented in EIR No. 331 assessed the potential impacts of cumulative development anticipated under the aforementioned planning documents. EIR No. 331 concluded that the potential significant (and therefore cumulatively considerable) traffic impacts resulting from implementation of the Approved Project would be mitigated to a level considered less than significant. As such, EIR No. 331 found that the Approved Project would not result in significant cumulative traffic impacts. 3-107
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Proposed Project
Less Than Cumulatively Considerable Impact. Due to the passage of time since the certification of EIR No. 331 in 2005, the Approved Project future year scenarios would be outdated in respect to the Proposed Project. As such, the Traffic Impact Analysis (LSA 2024) prepared for the Proposed Project considered 2045 as the future year, based on the City of Anaheim General Plan buildout year. As discussed in the analysis presented above, the Proposed Project would generate substantially fewer vehicle trips and VMT than the Approved Project. As stated previously, the General Plan Buildout (2045) Plus Project scenario demonstrates that the four roadway segments evaluated would continue to operate at satisfactory LOS. Overall, the 2045 General Plan buildout with the Proposed Project would provide an overall improvement to daily traffic volumes compared to the Approved Project, due to reduced trips generated by the proposed cemetery uses within the project site in comparison to the approved residential land uses approved under the MPSP within DA 5. Given this reduction in trip generation and VMT and analysis in conjunction with the 2045 General Plan buildout scenario, the Proposed Project would not result in cumulatively considerable traffic and circulation impacts, and the findings of EIR No. 331 remain valid.

3.7.4 Findings Related to Traffic and Circulation

3.7.4.1 No New Significant Effects Requiring Major Revisions to the Certified EIR Based on the foregoing analysis and information, there is no evidence that the Proposed Project requires a major change to EIR No. 331. The Proposed Project would not result in new significant environmental impacts related to traffic and circulation, and there would not be a substantial increase in the severity of impacts described in EIR No. 331.

3.7.4.2 No Substantial Change in Circumstances Requiring Major Revisions to the Certified EIR No major changes to the Approved Project have taken place since preparation of EIR No. 331 that would require revisions to the analysis in EIR No. 331. There is no information in the record or otherwise available that indicates that there are substantial changes in circumstances pertaining to traffic and circulation that would require major changes to EIR No. 331.

3.7.4.3 No New Information Showing Greater Significant Effects than the Certified EIR No major changes to the Approved Project have taken place since preparation of EIR No. 331 that would require revisions to the analysis in EIR No. 331. There is no information in the record or otherwise available that indicates that there are substantial changes in circumstances pertaining to traffic and circulation that would require major changes to EIR No. 331.

3.7.4.4 No New Information Showing the Ability to Reduce Significant Effects in the Certified EIR There is no new information, new alternatives to the Proposed Project, or additional mitigation measures that would substantially reduce one or more significant impacts pertaining to traffic and circulation identified and considered in EIR No. 331.

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3.7.5 Standard Conditions and Mitigation Measures
Standard Condition (SC) 7-1 was identified as applicable to the Approved Project and would remain applicable to the Proposed Project.

SC 7-1 Prior to the issuance of each building permit, the Foothill/Eastern Transportation Corridor Major Thoroughfare and Bridge Fees shall be paid by the property owner/developer to the City of Anaheim. Payment of these fees provides for the project's fair share contribution to the ultimate improvements to SR-241 and SR- 261.

In addition to SC 7-1, Mitigation Measures (MM) MM 7-3 and 7-4 are applicable to the Proposed Project because they pertain to roadway construction and traffic management.

MM 7-3 Prior to the approval of each development area plan, the property owner/developer shall submit a traffic phasing plan. The plan shall be reviewed and approved by the Department of Public Works, Development Services Division and Traffic Engineering Division, and the Fire Department. The plan shall also be submitted for review and comment by Caltrans if any portion of the plan involves Caltrans facilities. The plan shall include the following items:

1. Documentation of the number of units and product types of each development area and resulting VMT shall be provided for locations.

2. Phasing of roadway construction, specifying which roads shall be constructed as backbone streets and which roads shall be constructed with tract development.

3. Traffic improvements (including signals, signage and striping) to local streets, arterials and intersections, freeway interchanges and bridge over-crossings.

4. Identification of measures that will be incorporated to minimize the impacts of project construction traffic on Gypsum Canyon Road between the SR-91 westbound off-ramp and Santa Ana Canyon Road; Gypsum Canyon Road/SR-91 interchange ramps; and Santa Ana Canyon Road between Gypsum Canyon Road and Weir Canyon Road.

MM 7-4 Prior to approval of a grading plan for each development area, the property owner/developer shall submit a traffic control plan including construction haul routes, duration and location of lane closures, and any pedestrian-related impacts to sidewalks and intersection crossings, for review and approval by the Department of Public Works, Development Services Division and Traffic Engineering Division. 3-109
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3.8 AIR QUALITY

3.8.1 Existing Environmental Setting
No substantial changes to the Planning Area have occurred since preparation of EIR No. 331. There have been no major changes to the existing setting of the Planning Area with respect to air quality.

The Proposed Project site is in the South Coast Air Basin (SCAB) which is within the jurisdiction of the South Coast Air Quality Management District (SCAQMD) and the California Air Resources Board (CARB). The SCAQMD adopts and enforces regulations for stationary sources in the SCAB and, together with the SCAG, local governments, and the private sector, develops the Air Quality Management Plan (AQMP) for the air basin. The SCAQMD reports to CARB and all emissions are also governed by the California Ambient Air Quality Standards (CAAQS) as well as the National Ambient Air Quality Standards (NAAQS). The SCAB is currently designated as nonattainment for ozone (O3) and particulate matter less than 10 microns in diameter and less than 2.5 microns in diameter (PM10 and PM2.5, respectively). Emissions of volatile organic compounds (VOC) and nitrogen oxides (NOX) are precursors to the formation of O3. In addition, NOX is a precursor to the formation of particulate matter (PM10 and PM2.5). A review of the SCAQMD monitoring data and the iADAM tool on the CARB website was conducted for the La Habra, Anaheim, and Mission Viejo Monitoring Stations. The results of the review indicate that since EIR No. 331 was certified, criteria pollutant emissions (Ozone, CO, PM10, PM2.5, and NO2) documented at these monitoring stations have been reduced and air quality has experienced an improvement compared to the federal and State standards. As such, these results are representative that the local air quality near the project site has experienced improvements since EIR No. 331.

3.8.2 Comparison of Impacts for the Approved Project and the Proposed Project Would the project create objectionable odors affecting a substantial number of people? EIR No. 331 indicated that in the previous Initial Study, the City of Anaheim determined that the Approved Project would not have significant impacts for creating an objectionable odor that would affect a substantial number of people. As implementation of the Proposed Project would occur on a portion of the same site analyzed in EIR No. 331 (DA 5), impacts related to objectionable odors that would affect a substantial number of people are expected to be similar to the Approved Project.

Thus, no further analysis for this threshold is necessary.

Would the project violate any air quality standard or contribute substantially to an existing or projected air quality violation?
Approved Project
Significant and Unavoidable Impact. EIR No. 331 mentions that short-term temporary air quality impacts would result from Approved Project construction activities. Air pollutants would be emitted by construction equipment and construction worker vehicles, and fugitive dust would be generated during construction of the Approved Project facilities and grading of the site. EIR No. 331 concluded that grading would be the construction activity that would result in the highest levels of project- related air pollutant emissions. More specifically, peak air pollutant estimates (regarding grading of the Approved Project) were generated and were found to exceed thresholds of significance for the

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following air pollutants: carbon monoxide (CO), reactive organic gases (ROG), NOX, and PM10. This is considered a significant short-term impact of the Approved Project that applies to several of the on- and off-site project features or development. In terms of long-term air quality impacts, EIR No. 331 concluded that local air quality impacts would not be significant. However, in terms of long-term air quality impacts in relation to regional air quality, the Approved Project-related emissions of CO, ROG, and NOX are projected to exceed the SCAQMD thresholds, which is considered a significant regional air quality impact. Overall, the Approved Project’s mitigation measures listed in EIR No. 331 would reduce the significant impacts of short-term and long-term air quality, but not to a level considered less than significant as the impacts are unavoidable.

Proposed Project
Less Than Significant Impact. As mentioned previously in the project description, the Proposed Project would develop two cemetery sites that initially may require an overall site mass and rough grading operation to be conducted to balance site earthwork for the upper and lower pads and to build the keyway buttress slope. However, construction of the Proposed Project (two administrative buildings, one for each cemetery) would be less construction in comparison to the Approved Project (1,595 dwelling units) and would result in fewer short-term air quality impacts. The previous EIR No. 331 mitigation measures in relation to site grading would be implemented to ensure short term air quality impacts are reduced for the Proposed Project. Additionally, the Proposed Project in comparison with the Approved Project (residential land use) would result in reduced long-term air quality impacts based on the functions associated with the cemetery use. Vehicle trip generation of the Approved Project’s residential use would be significantly higher than the Proposed Project’s cemetery use, thus proving that the Approved Project would have higher operational long-term emissions (25,154 average daily trips [ADT] for the Approved Project versus 1,084 ADT for the Proposed Project). Overall, the Proposed Project would reduce short-term and long-term operational air quality impacts.

Would the project result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors)? Approved Project
Significant and Unavoidable Impact. As described in EIR No. 331, the Approved Project would result in significant short-term and long-term air quality impacts because emissions of the following pollutants would exceed SCAQMD thresholds: CO, NOX, PM10 (short-term only), and ROG. Because the region is in nonattainment for O3, CO, and nitrogen dioxide (NO2) and project-related increases of these pollutants are above SCAQMD thresholds, operation of the project would result in a significant cumulative air quality impact for CO, NOX, and ROG (an O3 precursor). During the construction phase, the project would result in short-term significant impacts for CO, NOX, ROG, and PM10. Thus, the Approved Project contributes to a cumulatively net increase in CO, NOX, PM10, and ROG. Overall, the Approved Project’s mitigation measures listed in EIR No. 331 would reduce these impacts but not to a level considered less than significant as the impacts are unavoidable. The daily maximum and annual GHG emissions from the Approved Project were re-modeled using the current version of CalEEMod, version 2022.1.1.21, as shown in Tables 3.I and 3.J. 3-111
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Table 3.I: Approved Project Daily Maximum Emissions (lbs/day) Source ROG NOX CO SO₂ PM10 PM2.5
Mobile 53 58 629 2 170 44
Area 63 1 91 <1 <1 <1
Energy 1 12 5 <1 1 1
Total Daily Maximum 117 71 725 2 171 45
SCAQMD Thresholds 55 55 550 150 150 55
Exceeds? Yes Yes Yes No Yes No
Source: California Emission Estimator Model (CalEEMod).

CO= carbon monoxide
lbs/day = pounds per day
NOX = nitrogen oxides
PM10 = particulate matter less than 10 microns in size
PM2.5 = particulate matter less than 2.5 microns in size ROG = reactive organic gases
SCAQMD = South Coast Air Quality Management District
SO2 = sulfur dioxide

Table 3.J: Approved Project Annual GHG Emissions (MT/Year) Source CO2 CH4 N2O CO2e
Mobile 29,021 1.1 1.1 29413
Area 27 0 0 28
Energy 6,927 0.6 0.1 6,960
Water 589 2.0 0.1 656
Waste 209 10.9 0 382
Refrigeration 117 0 0 3
Total 36,674 14.6 1.2 37,441
Source: California Emission Estimator Model (CalEEMod).

CH4 = methane
CO2 = carbon dioxide
CO2e = carbon dioxide equivalent
MT/year = metric tons per year
N2O = nitrous oxide

Proposed Project
Less Than Significant Impact. Although less than the Approved Project, the construction and operation of the Proposed Project does have the potential to result in short-term and long-term air quality impacts. The daily maximum and annual GHG emissions from the Proposed Project were modeled using CalEEMod, as shown in Tables 3.K and 3.L. As shown by comparing Table 3.I to Table

3.K, the Approved Project’s long-term air quality impacts are higher based on the anticipated emissions from operation of the land uses in DA 5 compared to the Proposed Project. Annual GHG emissions were not evaluated in EIR No. 331; this was not a threshold when EIR No. 331 was certified. For disclosure purposes, in this Addendum, the potential GHG emissions for the Approved Project were generated for comparison to potential GHG emissions from the Proposed Project. As demonstrated by comparing annual GHG emissions in Tables 3.J and 3.L, the Approved Project would have substantially higher annual GHG emissions.

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Table 3.K: Proposed Project Daily Maximum Emissions (lbs/day) Source ROG NOx CO SO₂ PM10 PM2.5
Mobile 4 4 49 <1 13 3
Area 15 2 298 <1 <1 <1
Energy <1 <1 <1 <1 <1 <1
Total Daily Max 19 7 347 <1 13 3
SCAQMD Thresholds 55 55 550 150 150 55
Exceeds? No No No No No No
Source: California Emission Estimator Model (CalEEMod).

CO= carbon monoxide
lbs/day = pounds per day
NOX = nitrogen oxides
PM10 = particulate matter less than 10 microns in diameter PM2.5 = particulate matter less than 2.5 microns in diameter ROG = reactive organic gases
SCAQMD = South Coast Air Quality Management District
SO2 = sulfur dioxide

Table 3.L: Proposed Project Annual GHG Emissions (MT/Year) Source CO2T CH4 N2O CO2e
Mobile 2,262 0.08 0.08 2,292
Area 115 0 0 115
Energy 630 0.06 0.01 634
Water 534 0.05 0.01 537
Waste 1 0.14 0 5
Total 3,541 0.33 0.10 3,583
Source: California Emission Estimator Model (CalEEMod).

CH4 = methane
CO2 = carbon dioxide
CO2e = carbon dioxide equivalent
MT/year = metric tons per year
N2O = nitrous oxide

The Proposed Project would reduce the cumulatively considerable net increase (short-term and long-term impacts) based on the reduction of 1,595 residential dwelling units and the proposed cemetery use. Overall, the Proposed Project would reduce the Approved Project’s cumulatively net increase in the criteria pollutants for the SCAQMD thresholds and would not exceed those thresholds. Also, annual GHG emissions would be reduced.

Would the project expose sensitive receptors to substantial pollutant concentrations? Approved Project
Significant and Unavoidable Impact. SCAQMD defines a sensitive receptor as land uses such as residences, schools, daycare centers, health facilities, and prisons. According to EIR No. 331, there are sensitive receptors that are located within a 1-mile radius west and north of the Approved Project boundary. In addition to those sensitive receptors, the Approved Project has a school planned on the project site. During the construction phase, the project would result in short-term 3-113
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exceedances of SCAQMD thresholds for CO, NOX, ROG and PM10. Sensitive receptors (primarily residences) adjacent to the western boundary of the project site would be exposed to these pollutants during construction. As stated previously, the Approved Project would result in long-term exceedances of SCAQMD thresholds for CO, ROG, and NOx. However, many of these emissions occur due to vehicle emissions and electrical generation which would take place off site. EIR No. 331 indicated that the project would not cause or contribute to any ambient air quality violations next to roadways served by the project. Overall, EIR No. 311 concluded that short-term construction impacts and long-term vehicle operation or electricity generation of the Approved Project would expose sensitive receptors to pollutant concentration that exceed SCAQMD thresholds.

Proposed Project
Less Than Significant Impact. The Proposed Project is located on the northeastern portion of the Specific Plan Area. Currently, there are no sensitive receptors that are located adjacent to the site.

During the construction phase, project construction emissions would result in short-term air quality impacts, but not as high as the levels of the Approved Project based on grading and construction equipment usage. However, the Proposed Project’s mobile-source emissions would be less than the Approved Project due to significant reductions in ADT (25,154 for the Approved Project versus 1,084 for Proposed Project). The previous analysis above mentions daily maximum mobile-source emissions from the Proposed Project (19) are substantially lower than for the Approved Project (117), thus supporting the reduction in mobile-source emissions. Overall, the Proposed Project’s short-term construction impacts and long-term vehicle operation of the Proposed Project may have the potential to cause impacts to sensitive receptors, but impacts would be less than significant and less than the Approved Project.

Would the project conflict with or obstruct implementation of the applicable air quality plan? Approved Project
Less Than Significant Impact. EIR No. 331 included a consistency analysis for the Approved Project on two particular criteria outlined in the 1997 SCAQMD AQMP. The two criteria and analysis are listed below:
• Criterion 1: Increase in the Frequency or Severity of Violations: Based on the air quality modeling analysis contained in EIR No. 331, there would be significant short-term construction and long-term operational impacts due to the project based on the SCAQMD thresholds of significance. While emissions would be generated in excess of SCAQMD’s threshold criteria, it is unlikely that short-term construction activities would increase the frequency or severity of existing air quality violations due to required compliance with SCAQMD Rules and Regulations.

Similarly, the emissions from the project are projected to be a fraction of a percentage of the basin-wide emissions. The analysis for long-term local air quality impacts showed that local pollutant concentrations are not projected to exceed any of the air quality standards. The Approved Project is not projected to contribute to the exceedance of any air pollutant concentration standards; thus, the project is found to be consistent with the AQMP for the first criterion; and

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• Criterion 2: Exceed Assumptions in the AQMP in 2010 or Increments Based on the Year of Project Buildout and Phase: Consistency with the AQMP assumptions is determined by comparing the project’s population, housing, and employment growth with the growth assumptions in the AQMP. Thus, the emphasis of this criterion is to ensure that the project growth and associated emissions do not exceed those assumed as a basis for the AQMP. At the time of EIR No. 331, the 1997 AQMP was the applicable federally approved air plan for the SCAB, which includes the project area. The 2003 AQMP was locally adopted but has not yet been fully federally approved as a replacement for the 1997 AQMP. In May 2004, the City of Anaheim approved a General Plan Update (GPA No. 2004-00419) that decreased the intensity of development in the MPSP area from 7,966 residential units to 2,500 units and eliminated proposed commercial and mineral extraction uses, two school sites, and one neighborhood park site. Thus, both the applicable 1997 AQMP and the 2003 AQMP, pending full federal approval, assume development of the larger, previously Approved Project in their emissions inventories.

The larger project would have produced substantially higher emissions than the currently Approved Project. Since the growth and projected emissions that would be generated by Approved Project are less than what is assumed for the area in the AQMP, the project is consistent with the AQMP assumptions.

Therefore, the Approved Project would remain consistent with the two applicable 1997 SCAQMD AQMP criteria.

Proposed Project
Less Than Significant Impact. Similar to the Approved Project, the Proposed Project was evaluated under the two particular criteria outlined in the 1997 SCAQMD AQMP. The two criteria and analysis are listed below:
• Criterion 1: Increase in the Frequency or Severity of Violations: As previously described, EIR No. 331 included a consistency analysis for the Approved Project on two criterions outlined in the 1997 SCAQMD AQMP. The Proposed Project would result in short- and long-term air quality impacts but would contribute an overall reduction in those impacts in comparison to the Approved Project. In comparison to the Approved Project in the SCAQMD 1997 AQMP Criterion 1, the Proposed Project would not increase the frequency of severity of existing air violations as it would not be exceed SCAQMD thresholds. Additionally, EIR No. 331 indicated that the Approved Project would not cause long-term local air quality impacts in terms of air pollutant concentrations to exceed air quality standards. The Proposed Project would result in the same findings and potentially reduce the local long-term air quality impacts; thus, the Proposed Project is found to be consistent with the AQMP for the first criterion; and • Criterion 2: Exceed Assumptions in the AQMP in 2010 or Increments Based on the Year of Project Buildout and Phase: Consistency with the AQMP assumptions is determined by comparing the Proposed Project’s population, housing, and employment growth with the growth assumptions in the AQMP in order to ensure that project growth and associated emissions do not exceed those assumed as a basis for the AQMP. Both the applicable 1997 AQMP and 2003 AQMP assume development of the larger Approved Project in their emission inventories. The Proposed Project removes the 1,595 dwelling units, which would decrease the 3-115
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intensity of development and reduces the substantially higher emissions that would occur in the Approved Project. Since the growth and project emissions for the Proposed Project would be less than what would be generated by the Approved Project in the area in the AQMP, the Proposed Project remains consistent with the AQMP assumptions.

Would the project conflict with any applicable plan, policy or regulation of an agency with jurisdiction over the project adopted for the purpose of avoiding or mitigating an environmental effect?
Approved Project
EIR No. 331 included a consistency analysis for the Approved Project on related goals and policies outlined in the City’s General Plan, SCAG’s RCPG, and the SCAQMD AQMP. EIR No. 331 identified goals related to reducing locally generated emissions through improved traffic flows and construction management practices in tandem with the City of Anaheim’s General Plan Green Element. Further, the Approved Project construction traffic would utilize the City of Anaheim’s General Plan identified truck routes (La Palma Avenue to Weir Canyon Road, Weir Canyon Road, and Imperial Highway) to minimize impacts from trucks on local roadways. Additionally, the Approved Project would be consistent with SCAG’s Air Quality Chapter on ensuring that through the environmental document review process, all levels of government consider air quality to be consistent with CEQA guidelines. Overall, EIR No. 331’s findings of consistency with the applicable plan, policy, or regulation of an agency would remain valid.

Proposed Project
The Proposed Project would be similar to the Approved Project consistency conclusion with the City’s General Plan, SCAG’s RCPG, and the SCAQMD AQMP. The Proposed Project would decrease the intensity of development in comparison to the Approved Project, meaning that there would be less construction traffic and less short-term construction emissions. The Proposed Project would also reduce the Approved Project’s cumulative net increase in criteria pollutants for the SCAQMD thresholds and annual GHG emissions. Due to less construction traffic, less short-term construction emissions, and reduction in the previous EIR No. 331 cumulatively net increase of SCAQMD threshold pollutants, the Proposed Project would work in tandem with the City of Anaheim’s General Plan Green Element goal of reducing air quality emissions. Similar to the Approved Project, the Proposed Project would utilize the City’s General Plan identified truck routes to minimize impacts from trucks on local roadways. This addendum would be consistent with SCAG’s Air Quality Chapter on ensuring that through the environmental document review process, all levels of government consider air quality to be consistent with CEQA guidelines. Overall, the Proposed Project would remain consistent with the applicable plan, policy, or regulation of any agency and the findings of EIR No. 331 remain valid.

3.8.3 Cumulative Air Quality Impacts
Approved Project
Cumulatively Considerable Impact. As previously discussed, the Specific Plan Area is located within the SCAB, a 6,600-square-mile area comprising Orange County and the nondesert portions of Los Angeles, Riverside, and San Bernardino counties. As such, EIR No. 331 considered SCAB as the study

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area for cumulative air quality impacts. The air basin was found to be in federal non-attainment for ozone, CO, fine particulate matter (PM10), and nitrogen dioxide (NO2). Further, the Anaheim, La Habra, and Mission Viejo monitoring station data, representative of the Specific Plan Area, show that violations of thresholds existed for NOX and PM10. As addressed in this Addendum, the Approved Project would have a significant construction-related impact on air quality for CO, NOX, PM10, and ROG. Additionally, as shown in Table 3.I, the Approved Project would have a significant long-term regional impact on air quality related to CO, NOX, PM0, and ROG. A project that contributes to a cumulatively considerable impact and causes a net increase of any criteria pollutant for which the project region is in nonattainment is considered to result in a cumulatively significant impact. Therefore, the Approved Project’s impacts associated with the exceedance of CO, NOX, PM10 and ROG thresholds were considered cumulatively significant. Feasible mitigation measures to reduce the impacts from operations were identified for implementation under the Approved Project; however, even after mitigation, EIR No. 331 noted that cumulative impacts would be significant and unavoidable.

Proposed Project
Less Than Significant Impact. Because the project site is located within the Specific Plan Area, the SCAB remains the study area for cumulative air quality impacts. Implementation of the Proposed Project would result in a reduction in cumulative air quality impacts (short-term and long-term) in comparison to the Approved Project (see Tables 3.K and 3.L). The reduction is attributable to the development of cemetery uses where residential development has previously been approved, along with the reduction in anticipated traffic generation. In 2022, the City of Anaheim approved minor building reconfigurations and other improvements to the Kindred Community Church, located approximately 0.7-mile west of the project site at 8712 East Santa Ana Canyon Road. It is possible that the construction timeline of these improvements could overlap with the construction timeline of the Proposed Project. Therefore, the Proposed Project could result in significant construction- related cumulative impacts to air quality, but these impacts would occur to a lesser extent than the Approved Project. Therefore, the Proposed Project would likely result in a reduction of cumulative air quality impacts; however, even after applying applicable mitigation measures from EIR No. 331, the Proposed Project’s air quality impacts would be cumulatively considerable.

3.8.4 Findings Related to Air Quality

3.8.4.1 No New Significant Effects Requiring Major Revisions to the Certified EIR Based on the foregoing analysis and information, there is no evidence that the Proposed Project requires a major change to EIR No. 331. The Proposed Project would not result in new significant environmental impacts related to air quality, and there would not be an increase in the severity of impacts described in EIR No. 331.

3.8.4.2 No Substantial Change in Circumstances Requiring Major Revisions to the Certified EIR No major changes have taken place since preparation of EIR No. 331 that would require revisions to the analysis in EIR No. 331. There is no information in the record or otherwise available that indicates that there are substantial changes in circumstances pertaining to air quality that would require major changes to EIR No. 331.
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3.8.4.3 No New Information Showing Greater Significant Effects than the Certified EIR This Addendum has analyzed all available relevant information to determine whether there is new information that was not available at the time EIR No. 331 was certified, indicating that a new significant effect not reported in that document may occur. Based on the information and analyses above, there is no substantial new information indicating that there would be a new significant impact related to air quality requiring major revisions to EIR No. 331.

3.8.4.4 No New Information Showing the Ability to Reduce Significant Effects in the Certified EIR Based on the analysis above comparing the Proposed Project and Approved Project emissions generated, the Proposed Project would reduce one or more significant impacts pertaining to air quality identified and considered in EIR No. 331.

3.8.5 Standard Conditions and Mitigation Measures
While no Standard Conditions were identified for the Approved Project pertaining to air quality, Mitigation Measures (MM) 8-1 through 8-3 were identified to address potentially significant impacts of the Approved Project. While MM 8-3 pertains to residential development and would not apply to the Proposed Project, MM 8-1 and 8-2 would remain applicable to the Proposed Project.

Construction: Particulate Emission (PM10) Control
MM 8-1 Prior to approval of the first grading plan, the following requirements shall be incorporated into the Storm Water Pollution Prevention Program (SWPPP) and Erosion and Sedimentation Control Plan submitted for review and approval by the Department of Public Works. During construction of the Proposed Project, the property owner/development and its contractors shall be required to comply with regional rules, which shall assist in reducing short-term air pollutant emissions.

SCAQMD Rule 402 requires that air pollutant emissions not be a nuisance off-site.

SCAQMD Rule 403 requires that fugitive dust be controlled with the best available control measures so that the presence of such dust does not remain visible in the atmosphere beyond the property line of the emission source. Two options are presented in Rule 403: monitoring of particulate concentrations or active control.

Monitoring involves a sampling network around the project with no additional control measures unless specified concentrations are exceeded. The active control option does not require any monitoring but requires that a list of measures be implemented starting with the first day of construction.

Rule 403 requires that “No person conducting active operations without utilizing the applicable best available control measures included in Table 1 of this Rule to minimize Fugitive dust emissions from each fugitive dust source type within the active operation.” The measures from Table 1 of Rule 403 are presented in Table 15 in Appendix H of EIR No. 331. The applicable measures presented in Table 1 are required to be implemented by Rule 403.
• Rule 403 requires that “Large Projects” implement additional measures. A Large Project is defined as “any active operations on property which contains 50 or

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more acres of disturbed surface area; or any earth-moving operation with a daily earth-moving or throughput volume of 3,850 cubic meters (5,000 cubic yards) or more three times during the most recent 365 day period. Grading of the project would be considered a Large Project under Rule 403. Therefore, the project shall be required to implement the applicable actions specified in Table 2 of the Rule. Table 2 from Rule 403 is presented in Table 16 of Appendix H. As a Large Operation, the project shall also be required to:
• Submit a fully executed Large Operation Notification (SCAQMD Form 403N) to the SCAQMD Executive Officer within 7 days of qualifying as a large operation; • Include, as part of the notification, the name(s), address(es), and phone number(s) of the person(s) responsible for the submittal, and a description of the operation(s), including a map depicting the location of the site; • Maintain daily records to document the specific dust control actions taken, maintain such records for a period of not less than three years; and make such records available to the Executive Officer upon request. • Install and maintain project signage with project contact signage that meets the minimum standards of the Rule 403 Implementation Handbook, prior to initiating any earthmoving activities.
• Identify a dust control supervisor that is employed by or contracted with the property owner/developer, is on the site or available on site within 30 minutes during working hours, has the authority to expeditiously employ sufficient dust Mitigation Measures to ensure compliance with all Rule requirements, and has completed the AQMD Fugitive Dust Control Class and has been issued a valid Certificate of Completion for the class.
• Notify the SCAQMD Executive Officer in writing within 30 days after the site no longer qualifies as a large operation.

Rule 403 also requires that the construction activities “shall not cause or allow PM10 levels exceed 50 micrograms per cubic meter when determined by simultaneous sampling, as the difference between upwind and downwind sample.” Large Projects that cannot meet this performance standard are required to implement the applicable actions specified in Table 3 of Rule 403. Table 3 from Rule 403 is presented in Table 17 of Appendix H. Rather than perform monitoring to determine conformance with the performance standard, which will not reduce PM10 emissions, the project shall implement all applicable measures presented in Rule 403 Table 3 regardless of conformance with the Rule 403 performance standard.

This potentially results in a higher reduction of particulate emissions than if these measures were implemented only after being determined to be required by monitoring.
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Further, Rule 403 requires that that the project shall not “allow track-out to extend 25 feet or more in cumulative length from the point of origin from an active operation.” All track-out from an active operation is required to be removed at the conclusion of each workday or evening shift. Any active operation with a disturbed surface area of five or more acres or with a daily import or export of 100 cubic yards or more of bulk materials must utilize at least one of the measures listed in Table 18 of Appendix H at each vehicle egress from the site to a paved public road.

Construction Equipment Emission Control
MM 8-2 Prior to approval of grading plans, the property owner/developer shall include the following notes on the contractor specifications submitted for review and approval by the Department of Public Works: “To reduce construction equipment emissions, the following measures shall be implemented when feasible. • Use low emission mobile construction equipment with engines that meet or exceed the CARB Tier 2 emission standards. The property owner/developer shall comply with CARB requirements for heavy construction equipment. • Idling times shall be minimized by either shutting equipment off when not in use or reducing the maximum idling time to 5 minutes (as required by the California airborne toxics control measure Title 13, Section 2485 of the California Code of Regulations [CCR]).
• Maintain construction equipment engines by keeping them maintained and tuned in accordance with manufacturer’s specifications. • Use low sulfur fuel for stationary construction equipment. This is required by SCAQMD Rules 431.1 and 431.2.
• Utilize existing power sources (i.e., power poles) when feasible. This measure would minimize the use of higher polluting gas or diesel generators. • Configure construction parking to minimize traffic interference. • Minimize obstruction of through-traffic lanes. When feasible, construction should be planned so that lane closures on existing streets are kept to a minimum.
• Schedule construction operations affecting traffic for off-peak hours. • Develop a traffic plan to minimize traffic flow interference from construction activities (the plan may include advance public notice of routing, use of public transportation and satellite parking areas with a shuttle service. • Use aqueous diesel fuel where feasible and reasonably commercially available.

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• Use cooled exhaust gas recirculation (EGR) where feasible and reasonably commercially available.

Several of the mitigation measures listed above are advanced emission control technologies, which are currently not commercially available. For example, aqueous diesel fuel reduces NOX formation by reducing combustion temperatures, resulting in lower NOX emissions. According to the SCAQMD, the current availability of this fuel technology is limited, and it may not be available for use for the project. In addition, with EGR diesel engines, a small amount of hot exhaust gas is routed through a cooler and mixed with fresh air entering the engine. The exhaust gas helps reduce the temperature during combustion, which lowers the formation of thermal NOX. EGR technology is in the development phase, and has not been fully commercialized. To the extent that the advanced emissions control technologies become reasonably commercially available, or are required by the CARB from grading contractors, then such advanced emissions control technologies shall be used.

3.9 NOISE

3.9.1 Existing Environmental Setting
No substantial changes to the Specific Plan Area or neighboring land uses have occurred since the preparation of EIR No. 331 relating to noise. One change that has occurred has been the removal of sand and gravel plant operations that were previously located within DA 5 and provided an existing source of noise. However, this change was accounted for in EIR No. 331 and was not included in baseline measurements for the Approved Project because it was known that this land use would be removed by the time the Approved Project was implemented. Noise-sensitive receptors in the Specific Plan Area’s vicinity mostly include residences and open space/recreational uses. The major sources of noise are mobile sources of traffic traveling on various roadways and freeways, including SR-91 and SR-241. The city of Anaheim, including the project site, is not located within the 65 A- weighted decibel (dBA) Community Noise Equivalent Level (CNEL) contours for any commercial or private airports, and fixed-wing aircraft typically fly too high to add measurably to local noise.

However, local helicopter air traffic can regularly occur throughout Anaheim. The city also includes stationary noise sources from industrial land uses that are mostly restricted to appropriate areas.

Sources of “stationary” noise also include the regular fireworks displays at Disneyland and special events at Angel Stadium, neither of which are located in the vicinity of the Specific Plan Area.

As part of the analysis supporting EIR No. 331, noise measurements were gathered throughout the Specific Plan Area. One measurement, Measurement Site 1, was taken within DA 5. Measurement Site 1 was located along the northern edge of the project site adjacent to SR-91. Noise at this location was dominated by traffic on SR-91. The measured hourly noise level was 78 dBA Leq. As presented in Exhibit 4.9-6 of EIR No. 331, ultimate traffic noise contours along SR-91, SR-241, and Gypsum Canyon Road have the potential to exceed 70 dBA CNEL at the northernmost portions of DA

5. EIR No. 331 went on to say that noise levels around the project site are highest adjacent to SR-91 and SR-241. Noise levels are very high along SR-91 and moderately high along SR-241. Toward the interior of the project site, away from roadways, ambient noise levels are relatively low. Areas with 3-121
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ambient noise levels below 40 dBA are generally considered quiet. Noise levels in developed areas, away from a major roadway are typically in the low to mid-50 dBA ranges.

3.9.2 Comparison of Impacts for the Approved Project and the Proposed Project It should be noted that the Approved Project was found to have no impacts pertaining to excessive noise level exposure within airport land use plans or private airstrips and this threshold was therefore not analyzed in EIR No. 331. Because the project site and the Specific Plan Area as a whole are not located within an airport land use plan or in the vicinity of a private airstrip, this conclusion remains valid for the Proposed Project, and these thresholds will not be discussed further in this Addendum.

3.9.2.1 Short-Term Construction-Related Impacts
Would the project result in a temporary or periodic increase in ambient noise levels in the project vicinity above levels existing without the project?
Would the project result in exposure of persons to or generation of excessive groundborne vibration or groundborne noise levels?
Would the project result in exposure of persons to or generation of noise levels in excess of standards established in the local general plan or noise ordinance, or applicable standards or other agencies? Approved Project
Less Than Significant with Mitigation Incorporated. The three thresholds presented above were analyzed in conjunction in EIR No. 331. According to analysis of the Approved Project, the distance from the various DAs to existing residential developments within the vicinity would substantially reduce the impacts of construction noise levels on these communities during grading activities associated with the Approved Project. These grading activities were anticipated to reach noise levels of up to 67 dBA, which would exceed the 60 dBA limit set forth in the Anaheim Noise Ordinance.

However, the Approved Project’s compliance with the Anaheim Municipal Code, which limits construction activities to between the hours of 7:00 a.m. and 7:00 p.m., would result in an exemption from the 60 dBA noise limit. This compliance would be ensured by the implementation of SC 9-1. As such, no potentially significant effects pertaining to grading activities were identified.

Construction noise associated with off-site features of the Approved Project, including Caltrans- related features, were found to potentially reach noise levels between 72 and 90 dBA, which would exceed the 60 dBA limit set forth by the Anaheim Noise Ordinance. In a similar manner to on-site activities, because the Anaheim Municipal Code exempts construction activities from the Noise Ordinance noise level limits between the hours of 7:00 a.m. and 7:00 p.m., noise impacts from off- site construction activities would be less than significant. Off-site construction activities associated with the Proposed Project were identified within and nearby Featherly Regional Park and near the intersection of Gypsum Canyon Road and La Palma Avenue. These activities would occur within Yorba Linda. The Noise Ordinance limits in the County of Orange (which operates the park) and the city of Yorba Linda are specifically applicable to noise impacting nearby residential properties. As such, SC 9-2 was included in EIR No. 331’s analysis to ensure compliance with the City of Yorba

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Linda’s Noise Ordinance, in addition to the City of Anaheim’s. Based on compliance with the Anaheim and Yorba Linda Municipal Codes’ construction timing limitations and Mitigation Measure 3-3, the Approved Project was not found to result in less than significant impacts under these three thresholds.

The previous construction vibration analysis in EIR No. 331 assumed that, due to distance, vibration impacts would only occur during blasting activities. Other standard construction activities, including heavy equipment, would generated minimal amounts of vibration given the large distances between construction areas and surrounding structures. Because blasting activities were deemed potentially necessary under the Approved Project but would be dependent upon the results of grading operations, specific calculations of its noise impacts were unable to be quantified in EIR No. 331. As such, a potentially significant impact was identified but was found to be less than significant with incorporation of Mitigation Measure 3-3, identified in Section 4.3, Geology and Soils, of EIR No. 331.

Proposed Project
Less Than Significant Impact. The Proposed Project would only occur in DA 5 and would not include any blasting, pile driving, or any of the previously analyzed off-site construction activities. The three thresholds presented above were analyzed in conjunction with EIR No. 331. Consistent with EIR No. 331, the distance from the various DAs to existing residential developments within the vicinity would substantially reduce the impacts of construction noise levels on these communities during grading activities associated with the Approved Project. These grading activities were anticipated to reach noise levels of up to 67 dBA, which would exceed the 60 dBA limit set forth in the Anaheim Noise Ordinance. However, the Approved Project’s compliance with the Anaheim Municipal Code, which limits construction activities between the hours of 7:00 a.m. and 7:00 p.m., would result in an exemption from the 60 dBA noise limit. This compliance would be ensured by the implementation of SC 9-1. As such, no potentially significant effects pertaining to grading activities were identified.

Furthermore, as stated in EIR No. 331, DAs 3 and 7 are closest to existing residential units, while the project site is located in DA 5. There are no new impacts associated with the construction of the Proposed Project and no mitigation measures are required.

As stated above, the Proposed Project would not include blasting or similar construction methods, therefore, due to the distance between the project boundary and the nearest surrounding structures, there would be no groundborne vibration impacts during construction.

3.9.2.2 Long-Term Operation-Related Noise Impact Analysis Consistent with EIR No. 331, the first threshold below is relevant to the short-term construction- related impacts discussed above and long-term operation-related noise impacts addressed below.

Note that the following analysis addresses the potential long-term noise impacts resulting from project traffic and on-site stationary sources.

Would the project result in exposure of persons to or generation of noise levels in excess of standards established in the local general plan or noise ordinance, or applicable standards or other agencies? Would the project result in substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project?
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Approved Project
Less Than Significant with Mitigation Incorporated. The two thresholds presented above were analyzed in conjunction in EIR No. 331. Noise levels associated with Approved Project-generated traffic were found to increase by 3 dB or more along portions of Oak Canyon Road, Weir Canyon Road, and Gypsum Canyon Road. Although Oak Canyon Road and Weir Canyon Road are located adjacent to existing residential uses, worst-case future noise levels under the Approved Project were found to be below the City’s exterior residential noise threshold of 65 dBA CNEL; therefore, no significant impacts were identified. In addition to traffic generated by the Approved Project, several on-site operational uses were analyzed for potential noise impacts. Operations of the planned school, park, and water pump station were determined to not have substantial noise impacts due to distance from planned residences within the Specific Plan Area and intervening topography. Further, as governmental facilities, the school and park would qualify for an exemption from the City’s Noise Ordinance. Activities at the gated entrance to the Specific Plan Area, including conversations and movement of the gates themselves, were not considered to reach noise levels in exceedance of the City’s Noise Ordinance limit as measured at the nearest noise sensitive receptors. Potential exterior noise impacts to planned residential uses from SR-91, SR-241, and other roadways were analyzed and found to expose residential uses in DA 3, 4, 5, and 7 to traffic noise levels in excess of 65 dBA CNEL. PDF 9-1 and MM 9-1, which pertain to the incorporation of berms as noise barriers, were identified to reduce potential impacts to a less than significant level. Interior noise levels within the same DA residences would exceed the maximum allowable level of 55 dBA CNEL, but building upgrades identified In PDF 9-1, MM 9-2, and MM 9-3 would reduce potential impacts to a less than significant level. Noise impacts from planned facilities to planned residences were generally found to have less than significant impacts due to distance and exemptions, aside from the planned water pump station. Because specific design information for the water pump station was unavailable at the time, it could not be guaranteed that the City’s Noise Ordinance limits would be met, and a potentially significant impact was identified. However, this potential impact was reduced to less than significant levels with implementation of MM 9-4. The PDF discussed above was determined based on the Approved Project’s conceptual grading plan to ensure the presence of berms within the Specific Plan Area to manage the passage of noise from adjacent roadways to planned on-site residences. Based on the discussion above, including the PDF and mitigation measures, impacts pertaining to excessive noise or increased ambient noise levels under the Approved Project were found to be less than significant with mitigation incorporated.

Proposed Project
Less Than Significant Impact. As stated above, EIR No. 331 assessed potential noise impacts to the more noise-sensitive residential uses. In order to reduce noise levels in exceedance of the exterior noise levels standards, barriers and additional analysis to determine interior noise mitigation were prescribed. Because the Proposed Project would develop cemetery uses instead of residential uses, MM 9-1 through 9-4 as described above would not be applicable to the Proposed Project.

Furthermore, consistent with Figure N-2, Land Use Compatibility for Community Noise Exposure (Exterior), exterior noise levels of up to 75 dBA CNEL are considered normally acceptable. As presented in Exhibit 4.9-6 of EIR No. 331, the ultimate traffic noise contours along SR-91, SR-241, and Gypsum Canyon Road have the potential to exceed 70 dBA CNEL at the northernmost portions

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of DA 5, but it is not expected that noise levels would exceed 75 dBA CNEL in the portions of the proposed DAs where people would congregate; therefore, no exterior noise impacts would occur.

EIR No. 331 concluded that there would be no operational noise impacts from uses on DA 5. With the development of the Proposed Project, an approximately 100-acre development area has been provided for within the upper pad of the project site. The ultimate design of the State veterans cemetery would be determined by CalVet; however, the exterior loop roadway and utility infrastructure have been designed to accommodate future development of the State veterans cemetery. Build-out of the State veterans cemetery would occur as demand warrants, is anticipated to span over 100 years, and could include up to 200,000 interment spaces. The final number of interment spaces and sizing of administration and maintenance facilities would be determined by CalVet during its final design. Interments or events could include the performance of the three- volley salute using rifles. These events would be of short duration (i.e., seconds or minutes) and would be limited to the daytime hours of operation. Predicted instantaneous noise levels associated with burial events involving the sounding of bugles or firing of rifle volleys could reach up to approximately 95 dBA L max at a distance of 100 feet.5 As a result, significant increases in average- hourly or average-daily noise levels at nearby land uses would not occur due to the short duration of the event.

Lastly, the Proposed Project is expected to result in a net decrease in trip generation of 24,070 ADT.

With an overall decrease in the project trips, off-site traffic noise impacts would be less than those identified in EIR No. 331.

Would the project conflict with any applicable plan, policy or regulation of an agency with jurisdiction over the project adopted for the purpose of avoiding or mitigating an environmental effect?
Approved Project
No Impact. EIR No. 331 evaluated the Approved Project’s consistency with the City’s General Plan Noise Element in Table 4.9-5, Consistency of the Approved Project with Noise Related Goals and Policies. This table addressed the Approved Project’s consistency with policies under the two general goals of protecting sensitive land uses from excessive noise through planning and regulation, and encouraging the reduction of transportation-related noise. Because the environmental review for the Approved Project included a detailed noise analysis and the implementation of mitigation measures to address potential noise impacts, the Approved Project was determined to be consistent with these goals and policies.

The Approved Project was also found to be consistent with Policy 3.23 of the SCAG RCPG regarding the utilization of mitigation measures to reduce noise, based on the same analysis as used with the General Plan policies.

Further, as discussed above, PDF 9-1 and MM 9-1 through 9-4 incorporated into the Approved Project would result in the inclusion of berms to reduce exterior noise levels and compliance with

5 Denise Duffy & Associates, Inc. 2019. Draft Environmental Impact Report/Environmental Assessment California Central Coast Veterans Cemetery. April.
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the City’s Noise Ordinance and Municipal Code. As such, the Approved Project was found to have no impacts relating to conflicts with applicable noise plans, policies, and regulations.

Proposed Project
No Impact. Consistent with EIR No. 331, the Proposed Project was evaluated using the same General Plan Policies and Goals. Because the environmental review for the Approved Project included a detailed noise analysis and the implementation of mitigation measures to address potential noise impacts, the Approved Project was determined to be consistent with these goals and policies.

While PDF 9-1 and MM 9-1 through 9-4 would not be applicable to the Proposed Project, based on the analysis presented in the above responses, the Proposed Project would result in compliance with the City’s Noise Ordinance and Municipal Code. As such, the Proposed Project would have no impacts relating to conflicts with applicable noise plans, policies, and regulations.

3.9.3 Cumulative Noise Impacts
Approved Project
Less Than Cumulatively Considerable Impact. EIR No. 331 estimated cumulative traffic noise impacts based on traffic projections presented in the 2005 Mountain Park Traffic Study and discussed in Section 3.7, Traffic and Circulation, of this Addendum. Cumulative increases in traffic noise levels along roadways in the vicinity of the Approved Project were estimated by comparing different future year (2010 and 2025) traffic scenarios to existing conditions. This comparison found that traffic noise levels were projected to increase above existing conditions by 3 dB or more along seven roadway segments in the vicinity of the Specific Plan Area. However, future exterior noise levels for residences near these roadway segments would remain below the City of Anaheim’s 65 dBA CNEL noise standard. In Anaheim, a project would only have a significant cumulative impact if it contributes 1 dB to an increase of 3 dB or more where noise levels are 65 dBA CNEL or above.

Because the Approved Project would not result in the exceedance of the 65 dBA CNEL noise standard, no significant cumulative impacts to existing or future year traffic scenarios were identified.

Proposed Project
Less Than Cumulatively Considerable Impact. Due to the passage of time since the certification of EIR No. 331 in 2005, the Approved Project future year scenarios would be outdated in respect to the Proposed Project. As such, the Traffic Impact Analysis (LSA 2023) prepared for the Proposed Project considered 2045 as the future year, based on the City of Anaheim General Plan buildout year.

As stated in Section 3.7, Traffic and Circulation, the Proposed Project would generate substantially fewer vehicle trips and VMT than the Approved Project. Because traffic noise levels are directly correlated with the number of vehicles, this is anticipated to result in a reduction of overall traffic noise levels. Because the Proposed Project would cause a reduction in traffic noise due to a substantial decrease in vehicular trips, under consideration of existing and future year traffic scenarios and based upon the cumulative impact significance criteria set forth by the City, the Proposed Project would not have cumulatively considerable impacts related to noise.

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3.9.4 Findings Related to Noise

3.9.4.1 No New Significant Effects Requiring Major Revisions to the Certified EIR Based on the foregoing analysis and information, there is no evidence that the Proposed Project requires a major change to the Certified EIR. The Proposed Project would not result in new significant environmental impacts related to noise, and there would not be a substantial increase in the severity of impacts described in EIR No. 331.

3.9.4.2 No Substantial Change in Circumstances Requiring Major Revisions to the Certified EIR No major changes to the Specific Plan Area have taken place since preparation of EIR No. 331 that would require revisions to the analysis in EIR No. 331. There is no information in the record or otherwise available that indicates that there are substantial changes in circumstances pertaining to noise that would require major changes to EIR No. 331.

3.9.4.3 No New Information Showing Greater Significant Effects than the Certified EIR This Addendum has analyzed all available relevant information to determine whether there is new information that was not available at the time EIR No. 331 was approved, indicating that a new significant effect not reported in that document may occur. Based on the information and analyses above, there is no substantial new information indicating that there would be a new significant impact related to noise requiring major revisions to EIR No. 331.

3.9.4.4 No New Information Showing the Ability to Reduce Significant Effects in the Certified EIR There is no new information, mitigation, or alternatives to the Proposed Project that would substantially reduce one or more significant impacts pertaining to noise identified and considered in EIR No. 331.

3.9.5 Standard Conditions and Mitigation Measures
The mitigation measures from EIR No. 331 pertaining to noise are not applicable to the Proposed Project because they pertain to noise impacts to planned residential development within the Specific Plan Area. DA 5, which contains the project site, would no longer be developed with residential uses under the Proposed Project. As such, Mitigation Measures 9-1 through 9-4 would not apply to the Proposed Project.

Although none of the mitigation measures set forth in EIR No. 331 would be applicable to the Proposed Project, Standard Conditions SC 9-1 and SC 9-2 were identified to be applicable to the Approved Project. While SC 9-1 is also applicable to Approved Project components within DA 5, SC 9-2 was prescribed for construction activities north of SR-91 beyond the boundaries of the project site and would therefore not apply to the Proposed Project. SC 9-1, as follows, would remain applicable to the Proposed Project:
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SC 9-1 Prior to approval issuance of grading plans and/or prior to issuance of or building permits, plans shall include a note indicating that noise-generating project construction activities in the City of Anaheim shall not occur between the hours of 7:00 p.m. and 7:00 a.m. This requirement applies to construction activities within 3,000 feet of residential uses, consistent with the City of Anaheim Noise Ordinance.

3.10 HAZARDS AND HAZARDOUS MATERIALS

3.10.1 Existing Environmental Setting

3.10.1.1 Quarry Site
Information for this section is based on information provided in the most recent Phase I Environmental Site Assessment for the site prepared by Ninyo and Moore (December 2023). The Robertson’s lease area encompassed approximately 300 acres in the northeastern portion of the project site. Various licensees have used the site for sand and gravel excavation as well as concrete and asphalt mix production since the mid-1950s. Robertson’s assumed the license agreement in 1995. All American Asphalt, a sub-licensee, operated an asphalt batch plant at the site.

Historical uses at the quarry have been the subject of investigation and remediation activities over the years under the oversight of various regulatory agencies. Historical activities may have contributed to environmental impacts, including those associated with USTs at several facilities that have operated at the quarry site (Owl Rock, R.F. White, and Robertson’s). A number of USTs have been removed from the quarry area. These historical uses have ceased and have been subject to remediation and cleanup.

Based on the results of the Phase I ESA for the quarry site, areas identified as requiring further analysis were evaluated in an ESA and Remediation Work Plan (Remediation Plan) prepared by GeoSyntec Consultants (2004). The Remediation Plan provided plans for further assessment and remediation of potential environmental conditions that have resulted from historical operations, which were implemented by Robertson’s during its reclamation activities.

The City of Anaheim and/or OCHCA oversaw Robertson’s remediation activities for the quarry site.

The City oversaw the removal of USTs. As part of the most recent Phase I ESA (prepared in December 2023), Ninyo and Moore conducted a soil gas investigation of the quarry area. The results of the soil gas investigation did not indicate any remaining soil contamination. However, Ninyo and Moore indicated that there could be small areas of remaining contamination that was undetected during the soil gas investigation. This potential for residual contamination and its implications for the Proposed Project will be discussed further in Section 3.10.2 below.

3.10.1.2 Southern Trails (Questar) Pipeline
The Southern Trails Pipeline (formerly referred to as the Four Corners Pipeline) owned by the Questar Corporation traverses the northern portion of the site in an east-west direction. The pipeline is an interstate facility that originates in Long Beach and extends to Farmington, New Mexico. The pipeline is a 16-inch steel pipeline. It is not currently in operation; however, it is maintained by Questar and is filled with nitrogen and has surface pipeline route indicators as identified in the current Phase I ESA prepared by Ninyo and Moore.

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3.10.1.3 Fire Hazards
Fire hazards threaten lives, property, and natural resources, and impact vegetation and wildlife habitats. The project site is primarily undeveloped and characterized with dry, steep slopes covered with combustible vegetation. Summer and autumn seasons render these areas of the site highly susceptible to uncontrollable fire hazards because of reduced soil and vegetation moisture compounded by dry “Santa Ana” winds that can accelerate and intensify wildfires. Santa Ana winds typically occur during the fire season (typically from June to the first significant rain in November).

The project site is located in the Hill and Canyon Area of Anaheim, and is currently located within a designated CALFIRE Local Resource Area (LRA) Very High Fire Hazard Severity Zone (VHFHSZ). The VHFHSZ generally includes ridgelines areas and undeveloped wildland areas located east of SR-55 and south of SR-91. The current vegetation risk within undeveloped portions of the Hill and Canyon Area, including the project site, is estimated to be a moderate-probability/high-consequence event.

3.10.2 Comparison of Impacts for the Approved Project and the Proposed Project It should be noted that the Approved Project was found to have no impacts pertaining to public airports, airport land use plans, or private airstrips, as none were present within or in the vicinity of the Specific Plan Area and these thresholds were therefore not analyzed in EIR No. 331. Because this condition has not changed since the certification of EIR No. 331, these conclusions remain valid for the Proposed Project, and these thresholds will not be discussed further in this Addendum.

Would the project create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials or create a significant hazard to the public or the environment through reasonable foreseeable upset and accident conditions involving the release of hazardous materials into the environment?
Approved Project
Less Than Significant Impact. EIR No. 331 evaluated the development of residential units, public facilities (fire station, elementary school site, and trail staging area), recreational uses, and infrastructure improvements. Additionally, the Southern Trails (Questar) Pipeline traverses the project site in an east-west direction within an easement and relocation of the easement and pipeline was anticipated as part of the development of the MPSP. It was anticipated that the pipeline would be installed between 4 and 10 feet bgs within open space or under proposed private streets; the pipeline would not be located directly beneath any structures. Implementation of the MPSP would introduce people and structures to the project site in proximity to the pipeline. The pipeline was not in use; however, the owner/operator had plans to convert the pipeline to a natural gas facility in the future.

At the time the pipe was converted to natural gas, it would be brought up to current safety standards. The pipeline design would need to comply with current regulations and be reviewed and approved by the California Public Utilities Commission (CPUC). Because the pipeline relocation would be accomplished in accordance with appropriate design and safety standards, and because the uses in the MPSP do not include any uses that would involve the use, transport, disposal, or 3-129
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emission of hazardous materials, EIR No. 331 determined that residents would not be exposed to a significant hazard due to a foreseeable upset or accident condition.

Proposed Project
Less Than Significant Impact. The Proposed Project would include less development than what was analyzed under the Approved Project and any future facilities within the Questar easement are not expected to expose the Proposed Project to any greater risk of upset. Additionally, as described in Section 2.3, the existing Southern Trails (Questar) continues to be inactive and would be capped and removed. The easement would be realigned to provide for the on-site roadway to the VA Cemetery as part of the Proposed Project. OCCD is coordinating with Questar regarding the easement and capping of the existing pipeline. Any future facilities within the relocated Questar easement would be designed and constructed to meet current regulations and approved by CPUC. This condition is consistent with the analysis and the conclusions of EIR No. 331 remain valid.

Would the project emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? Comparison of Impacts for the Approved Project and the Proposed Project It should be noted that the Approved Project was found to have no impacts pertaining to emitting hazardous emissions or handle hazardous or acutely hazardous materials/substances/wastes within

0.25 mile of an existing or proposed school. This threshold was therefore not analyzed in EIR No. 331. The nearest school to the project site is Running Springs Elementary School, located approximately 0.9-mile west of the project site at 8670 Running Springs Drive. Based on this distance, and because the project site and the MPSP as a whole are generally undeveloped and do not contain any residential communities, this conclusion remains valid for the Proposed Project, and this threshold will not be discussed further in this Addendum.

Would the project be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and as a result, would it create a significant hazard to the public or the environment?
Approved Project
Less Than Significant Impact. Two Phase I ESAs were previously prepared for the project site: one addressing the quarry site, and the second addressing the remainder of the project site. As part of these efforts, State of California databases were searched pursuant to Government Code Section 65962.5 to confirm that the project site is not a hazardous waste facility subject to corrective action, a hazardous waste disposal site, or a site designated by the State as a hazardous waste property or border zone property. The databases identified facilities within the quarry area where features such as USTs were located or impacts to soils and/or groundwater had been documented. No locations outside the quarry area were listed on any of the databases searched. As previously noted, the remediation activities for hazardous materials within the quarry area were completed as a component of the reclamation work. Therefore, implementation of the Proposed Project on the quarry site would not create a hazard to the public or the environment.

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Proposed Project
Less Than Significant Impact. As previously noted, the remediation activities for hazardous materials within the quarry area were completed as a component of the completed reclamation plan. The potential hazardous waste impacts of the prior mining activities and rocket test site have been acknowledged in both EIR No. 331 and this Addendum to EIR No. 331, including the Phase I ESAs prepared for both documents. No conditions related to hazardous waste have been identified that would significantly affect the ability to construct the Proposed Project. The Phase I ESA for the Proposed Project was completed by Ninyo and Moore in December 2023 and identified all regulatory agency cases as closed.

As noted in the December 2023 Phase I ESA, there is the potential for residual shallow soil and ground contamination associated with prior mining activities to be encountered during grading activities in the central area of project and in the in the southeastern quadrant of the project site, based on review of the case closure reports. Spot contamination due to prior mining equipment operation/servicing could also be encountered during construction activities was also identified in the Phase I. Additionally, aerially deposited lead (ADL) could be present near SR-91. All three conditions were identified as recognized environmental concerns (RECs). As described in Mitigation Measure (MM) 10-1, a Phase II ESA shall be conducted during design of the Proposed Project to assess whether any residual contamination is present in the three locations identified and determine if additional measures would be required to address any identified residual contamination. Additionally, a response plan would be developed if unknown contamination is encountered during grading activities. Therefore, any potential residual contamination associated with past RECs in or near the project site would be addressed prior to development of the Proposed Project. Based on this, and because the Proposed Project reduces the development intensity originally analyzed under the Approved Project, the conclusions of EIR No. 331 remain valid.

Would the project expose people or structures to a significant risk of loss, injury or death involving wildland fires, including where wildlands areas adjacent to urbanized areas or where residences are intermixed with wildlands; impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
Approved Project
Less Than Significant With Mitigation Incorporated. EIR No. 331 identified potential fire hazards are a concern associated with the vegetation surrounding the proposed DAs within the project area. As previously noted, the project site is within a CAL FIRE designated VHFHSZ. The MPSP would involve developing residential structures, including DA 5, within and adjacent to high fire hazard areas; fire emanating from the project site or surrounding undeveloped areas could spread to developed areas of the project, threatening the health and safety of residents. This condition was considered a potentially significant impact without implementation of appropriate fire protection measures.

The Approved Project included the retention of open space that surrounded the proposed residential uses. Residents of the Approved Project at the margins of natural areas susceptible to fire would be at relatively the same distance from fire danger zones as existing residences in surrounding developments. However, implementation of the proposed residential in the MPSP increase the number of residences subject to threat of fire and needing fire protection. Also, the 3-131
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increased population would increase the opportunity for accidental or deliberately set fires, since public access to many natural areas would be increased. Potential fire risks include engine sparks, cigarettes, and/or arson. Fire protection features associated with the project were outlined in the Fire Master Plan and EIR No. 331 Project Description and generally include construction of a fire station; implementation of a fuel modification plan; structural fire protection design features; water supply for fire protection; and circulation and access considerations for emergency vehicles.

The intent of the fuel modification plan is to reduce the risk of houses and other combustible structures from being destroyed by vegetation fires. A preliminary Fire Master Plan, including structural and nonstructural fire project features and fuel modification, was prepared for the MPSP and included in the EIR. The intent of the fuel modification plan is to reduce the risk of houses and other combustible structures from being destroyed by vegetation fires.

The Approved Project would improve emergency access to the project site. There are currently no improved access to the site from the west, and access routes within the MPSP, including DA 5, are limited to unimproved dirt roads. Per the Vehicular Circulation Plan and Section Key Map, access to the MPSP would be provided from Gypsum Canyon Road to the north and Weir Canyon Road to the west. The proposed circulation system meets the requirements of the City of Anaheim Fire Department. In summary, residents and structures within the MPSP, including DA 5, would be exposed to potential wildland fires. However, with the implementation of fire protection features included as part of the Approved Project, including an extensive fuel modification plan, and development of a fire station, the ability to control wildfires on and off site would be extended further than currently exists. The risk of loss, injury, or death as a result of wildland fires would be less than significant with implementation of the PDFs, standard conditions, and mitigation measures related to fire protection.

Proposed Project
Less Than Significant with Mitigation Incorporated. The Proposed Project lessens the anticipated development within DA 5 by changing the originally proposed residential development to the development of two cemeteries and supporting administrative and maintenance facilities. The internal roadways/circulation system would improve access for the City of Anaheim Fire Department within the project site. However, there is still a potential for wildland fires in the area. The design of the Proposed Project incorporates fuel modification zones and appropriate landscaping/ architectural treatments and provides adequate fire flow on site. In addition, in a manner consistent with the requirements of the 2023 Wildfire Mitigation Plan, all new electrical facilities proposed under the Proposed Project would be constructed underground. Coordination with the City of Anaheim and Anaheim Fire Department has been conducted and incorporated into the design of the Proposed Project and assessing fire flow requirements. With the project design that includes fire protection features and implementation of mitigation measures as identified in Certified EIR, potential impacts due to wildland fires associated with the Approved Project would be reduced to less than significant. Therefore, the conclusions of EIR No. 331 remain valid.

Would the project conflict with any applicable plan, policy or regulation of any agency with jurisdiction over the project adopted for the purpose of avoiding or mitigating an environmental effect?

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Approved Project
Less Than Significant Impact. EIR No. 331 addressed the consistency of the Approved Project with the relevant goals and policies related to hazards and hazardous materials outlined in the City of Anaheim General Plan and SCAG RCPG. The goals and policies identified in the consistency review included: City of Anaheim General Plan Safety Element (Goal 2.1 and Goal 4.1) and the SCAG RCPG Growth Management Chapter (Policy 3.22) and Open Space Chapter, Public Health and Safety (Goal

9.04 and Goal 9.05). The Approved Project was determined to be consistent and no mitigation was necessary.

Proposed Project
Less Than Significant Impact. The Proposed Project proposes less development than the Approved Project. With these changes, the Proposed Project is also consistent with the relevant goals and policies related to hazards and hazardous materials outlined in the City of Anaheim General Plan and SCAG RCPG. The goals and policies identified in the consistency review included: City of Anaheim General Plan Safety Element (Goal 2.1 and Goal 4.1) and the SCAG RCPG Growth Management Chapter (Policy 3.22) and Open Space Chapter, Public Health and Safety (Goal 9.04 and Goal 9.05).

The Proposed Project was determined to be consistent and no mitigation was necessary. Therefore, the conclusions of EIR No. 331 are still valid.

3.10.3 Cumulative Hazards and Hazardous Materials Impacts Approved Project
Less Than Cumulatively Considerable Impact. Cumulative analysis with respect to hazards and hazardous materials pertain to the direct vicinity of the Specific Plan Area rather than the regional level as contamination and release of hazardous materials are generally concentrated to a small radius. EIR No. 331 identified several areas of environmental concern associated with the existing quarry site, which were evaluated as part of a Remediation Work Plan. According to the Remediation Work Plan, these identified potential sites of hazardous materials contamination would be remediated by Robertson’s, the most recent quarry operator, prior to development of the Approved Project, including DA5, and would not result in cumulative impacts. This remediation was required regardless of implementation of the Approved Project.

EIR No. 331 found that development of future projects would cumulatively increase development intensity, population, and traffic in the region, thereby exposing a greater number of people to potential hazards in the area (e.g., hazardous materials and/or waste contamination, and fire).

Because it would introduce new residential uses within the Specific Plan Area, the Approved Project, as well as other potential future projects, would be required to comply with applicable local, State, and federal requirements pertaining to hazardous materials. With compliance with these requirements, EIR No. 331 concluded that the Approved Project would not contribute to any significant cumulative hazardous materials impacts.

Proposed Project
Less Than Cumulatively Considerable Impact. As with EIR No. 331, the cumulative analysis with respect to hazards and hazardous materials pertain to the direct vicinity of the project site (which is 3-133
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located within DA 5 of the Specific Plan Area). The Approved Project specified that the former quarry site would undergo remediation prior to any additional development and would therefore not result in cumulative impacts. This remediation has since been completed. Development of future projects would cumulatively increase development intensity, population, and traffic in the region, thereby exposing a greater number of people to potential hazards in the area (e.g., hazardous materials and/or waste contamination, and fire). In 2022, the City of Anaheim approved minor building reconfigurations and other improvements to the Kindred Community Church, located approximately 0.7-mile west of the project site at 8712 East Santa Ana Canyon Road. However, these improvements supported a continuation of the existing land uses and would not introduce any new hazards or hazardous materials that would be cumulatively considerable. No other projects with the potential to introduce new hazards or hazardous materials to the cumulative study area are currently proposed or approved. Further, the Proposed Project, as well as other potential future projects, would be required to comply with applicable local, State, and federal requirements concerning hazardous materials. Therefore, the Proposed Project would not contribute to any significant cumulative hazardous materials impacts, and the conclusions of EIR No. 331 remain valid.

3.10.4 Findings Related to Hazards and Hazardous Materials

3.10.4.1 No New Significant Effects Requiring Major Revisions to the Certified EIR Based on the foregoing analysis and information, there is no evidence that the Proposed Project requires a major change to EIR No. 331. The Proposed Project would not result in new significant environmental impacts related to hazards and hazardous materials, and there would not be a substantial increase in the severity of impacts described in EIR No. 331.

3.10.4.2 No Substantial Change in Circumstances Requiring Major Revisions to the Certified EIR No major changes to the Specific Plan Area have taken place since preparation of EIR No. 331 that would require revisions to the analysis in EIR No. 331. There is no information in the record or otherwise available that indicates that there are substantial changes in circumstances pertaining to hazards and hazardous materials that would require major changes to EIR No. 331.

3.10.4.3 No New Information Showing Greater Significant Effects than the Certified EIR This Addendum has analyzed all available relevant information to determine whether there is new information that was not available at the time EIR No. 331 was approved, indicating that a new significant effect not reported in that document may occur. Based on the information and analyses above, there is no substantial new information indicating that there would be a new significant impact related to hazards and hazardous materials requiring major revisions to EIR No. 331.

3.10.4.4 No New Information Showing the Ability to Reduce Significant Effects in the Certified EIR There is no new information, mitigation, or alternatives to the Proposed Project that would substantially reduce one or more significant impacts pertaining to hazards and hazardous materials identified and considered in EIR No. 331.

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3.10.5 Standard Conditions and Mitigation Measures
While no Standard Conditions were identified pertaining to Hazards and Hazardous Materials in EIR No. 331, Mitigation Measures (MM) 10-1 through 10-4 were identified to reduce potentially significant impacts of the Approved Project. MM 10-1 through MM 10-4 are also applicable to the Proposed Project as they pertain to the quarry area and the Southern Trails Pipeline, both of which are located in DA 5 and are part of the project site.

MM 10-1 The Robertson’s Ready Mix Quarry area will not be developed until after reclamation and remediation are complete. Based on the Environmental Site Assessments performed for the project site (included in Appendix J), it is not anticipated that any underground storage tanks, septic systems, leach fields, or significant soil contamination will be encountered during construction, as construction shall occur after remediation and reclamation are complete (all regulatory agency cases on-site are closed). As described in the Phase I ESA (December 2023), residual shallow soil and groundwater contamination associated with prior mining activities and historic ADL contamination associated with SR-91 could be encountered during construction and were identified as RECs. Prior to the issuance of a grading permit, a Phase II ESA shall be conducted in order to confirm the presence/absence of these RECs and whether any further remedial actions would be required prior to or during grading activities.

During grading activities, in the event these subsurface features or contaminated soil are encountered, work shall immediately cease in the area and the property owner/developer shall notify the Fire Department and Public Utilities, Environmental Services Division, and other agencies as appropriate based on the circumstances of the contamination, and retain a qualified hazardous materials engineer or geologist to assess the impacts and prepare a response plan using risk- based cleanup standards of the City of Anaheim and the OC Health Care Agency, and any appropriate guidelines issued by the California Environmental Protection Agency, applicable to residential land use the Proposed Project. Upon approval of the response plan by the Fire Department or other agency, as applicable, the engineer shall obtain any required permits, oversee the removal of such features and/or conduct the response work to the satisfaction of the Fire Department or other agency, as applicable, until closure status is attained.

MM 10-2 Prior to approval of grading plans within an area in which the Southern Trails Pipeline is located or is proposed to be relocated within the grading plan boundaries, the property owner/developer shall obtain the approval of the Questar Pipeline Company. Written evidence of this approval shall be submitted to the Department of Public Works.

MM 10-3 Prior to approval of any grading plans within a development area wherein the Southern Trails Pipeline exists or is proposed to be relocated, the property owner/developer shall submit a safety plan to the Fire Department. If there are any environmental concerns relating to developing adjacent to the pipeline or relocating 3-135
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it identified during subsequent reviews, the property owner/developer shall be responsible for financing/implementing any necessary mitigation measures. The safety plan shall be consistent with safety regulations adopted by the Fire Department and shall also be consistent with the requirements of MM 10-4. The safety plan shall be reviewed by the Questar Pipeline Company and approved by the Fire Department. Relocation of the pipeline shall occur at no cost to the City.

MM 10-4 Prior to issuance of building permits, the property owner/developer shall provide written evidence to the Public Utilities Department that the relocated Southern Trails Pipeline has been inspected and approved by the California Public Utilities Commission (CPUC).

3.11 POPULATION AND HOUSING

3.11.1 Existing Environmental Setting
As previously discussed, the project site is situated within Anaheim and the City’s sphere of influence in Orange County. The United States Census Bureau publishes population, household, and employment statistics and information gathered in the decennial census. According to EIR No. 331, the populations of Anaheim and Orange County in 2003 were estimated to be approximately 337,440 and 2,978,816 individuals, respectively. According to the most current Census data (2022), the population estimates for the City of Anaheim and Orange County were 344,4616 and 3,151,1847 individuals, respectively. Table 4.11-3 in EIR No. 331 provided projected population statistics for five-year increments between 2000 and 2025. According to this table, the population of Anaheim was projected to reach 388,910 by the year 2020. The population of Orange County was projected to reach 3,342,829 by 2020. As indicated through the comparison of the 2022 Census data and the projections for 2020 included in EIR No. 331, actual population growth has been slightly slower than projected. However, this difference does not constitute a major change in circumstances in comparison to the setting at the time EIR No. 331 was prepared.

While the 2000-2005 Regional Housing Needs Allocation (RHNA) assigned to Anaheim at the time EIR No. 3 was certified was 11,508 units, the City’s 2021-2029 RHNA allocation was 17,453 units.8 This increase in RHNA-allocated housing units highlights the City’s growth in the time period since the certification of EIR No. 3 but does not mark a major change in the existing setting of the Specific Plan Area and the project site. Ultimately, aside from predictable growth in population, housing, and employment associated with thriving cities and counties, the general trends describing the population and housing characteristics of the project site, City, and County identified in EIR No. 331 remain valid. These trends include population growth outpacing housing supply growth, increasing employment opportunities, and a housing stock mostly consisting of single-family dwelling units.

6 United States Census Bureau. 2022. QuickFacts Anaheim City, California. Website: https://www.census. gov/quickfacts/fact/table/anaheimcitycalifornia/PST045222 (accessed December 10, 2023). 7 United States Census Bureau. 2022. QuickFacts Orange County, California. Website: https://www.census. gov/quickfacts/fact/table/orangecountycalifornia/PST045222 (accessed December 10, 2023). 8 City of Anaheim. Housing Element 2021-2029. Website: https://www.anaheim.net/5848/2021-2029- Housing-Element-Update (accessed December 10, 2023).

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3.11.2 Comparison of Impacts for the Approved Project and the Proposed Project It should be noted that the Approved Project was found to have no impacts pertaining to the displacement of substantial numbers of people or houses and this threshold was therefore not analyzed in EIR No. 331. Because the project site and the MPSP as a whole remain undeveloped and do not contain any residential communities, this conclusion remains valid for the Proposed Project, and this threshold will not be discussed further in this Addendum.

Would the project induce substantial population growth in the area, either directly (for example by proposing new homes and businesses), or indirectly (for example through extension of roads or other infrastructure)?
Approved Project
No Impact. EIR No. 331 analyzed the development of 2,500 residential units within the Specific Plan Area. Using the City of Anaheim’s average of 3.3 persons per household, this was estimated to generate approximately 8,250 new residents within Anaheim. This population generation was found to be consistent with the population assigned to the MPSP in the City’s May 2004 General Plan. EIR No. 331 stated that the Approved Project would result in 5,466 fewer housing units and fewer jobs than allowed in the previous iteration of the MPSP. In light of these factors, and because residential development within the MPSP would contribute to meeting the State-mandated Regional Housing Needs Allocation housing production targets, the Approved Project was found to have no impacts relating to inducement of growth.

Proposed Project
No Impact. While the MPSP as currently approved allows for the development of up to 2,500 dwelling units within the Specific Plan Area and 1,595 dwelling units within DA 5 specifically, the Proposed Project would introduce cemetery uses as conditionally permitted within DA 5 where these residential uses have been approved. Development of the cemetery use as conditionally permitted would mean that the 1,595 residential units approved within DA 5 would not be constructed within DA 5; however, it does not preclude the development of these units elsewhere within the Specific Plan Area.

The Approved Project anticipated that 5,263 new residents would occupy the 1,595 approved dwelling units within DA 5 based on the City’s average of 3.3 residents per household. Since the Proposed Project would involve the development of cemetery uses within DA 5 and does not include any residential uses, the population of the project site would remain unchanged from existing conditions. However, as stated above, the Proposed Project does not preclude the development of residential units, and therefore the addition of new residents, elsewhere within the MPSP.

Some of the 74 jobs anticipated under the Approved Project were associated with a private recreation center in DA 5 that is not included under the Proposed Project; however, the public and veterans cemetery uses proposed under the Proposed Project is anticipated to generate 32 jobs within DA 5. The 12 jobs associated with operations of the proposed cemetery would not represent a substantial increase or decrease in employment within the MPSP. Because the Proposed Project would not substantially alter employment within the MPSP and represents a reduction in housing 3-137
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units and population from the Approved Project, the Proposed Project would not directly induce substantial population growth. The Proposed Project would alter the roadway system and other infrastructure within DA 5 from what was planned under the Approved Project due to the proposed changes in land use and site layout. However, these changes would serve the proposed cemetery uses and would not indirectly induce population growth. Ultimately, the reduction in the scale of residential development associated with the Proposed Project would result in no impacts related to growth inducement, consistent with the conclusion reached in EIR No. 331.

Would the project conflict with any applicable plan, policy or regulation of any agency with jurisdiction over the project adopted for the purpose of avoiding or mitigating an environmental effect?
Approved Project
No Impact. Regulations pertaining to population and housing that were identified as relevant to the Approved Project and analyzed in a consistency table in EIR No. 331 include the City of Anaheim General Plan and the SCAG RCPG. Specific goals and policies presented in Table 4.11-9, Consistency of the Proposed Project with Population and Housing-Related Goals and Policies, pertained to the jobs-housing relationship, housing growth, and transit-oriented land uses. EIR No. 331 found that because the Approved Project would provide varied housing units in a jobs-rich area near transportation corridors, it would be consistent with all applicable population and housing-related goals and policies. As such, it was found that the Approved Project would have no impact to applicable policies related to population and housing.

Proposed Project
No Impact. As discussed in Section 3.1, Land Use and Planning, of this Addendum, the Proposed Project would be consistent with all applicable plans and policies. Inconsistencies arising from the cemetery land use within DA 5, which is designated for residential uses within the MPSP and the General Plan Land Use Element, would be eliminated through the addition of cemeteries as a conditionally permitted use in DA 5 within each document. Under the proposed amendments to the MPSP, Zoning Code, and General Plan Land Use element, the Proposed Project would be consistent with all applicable land use documents with aspects relating to population and housing. Further, the landscaping plans of the Proposed Project would ensure that the cemeteries are appropriately screened from future residential development within adjacent DAs. The proposed development would not otherwise interfere with future adjacent residential land uses and, as such, would not preclude the achievement of consistency with applicable policies listed in Table 4.11-9 in EIR No. 331. Although implementation of the Proposed Project does not include residential uses within DA 5, the other DAs would still include 905 units in a jobs-rich area near transportation corridors as identified in EIR No. 331. Further, the City’s April 2023 Draft General Plan Housing Element Update identifies 22,997 adequate sites for residential development, meaning any units that would not be developed within DA 5 could be developed elsewhere within the Specific Plan Area or the City of Anaheim to achieve its RHNA allocation. Applicable population and housing-related goals and policies would still be achieved, and all potential inconsistencies with planning documents would be eliminated through the proposed amendments. Therefore, the Proposed Project would have no impacts related to conflict with plans or policies.

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