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4. Response to MND Comments, and Errata

Anaheim City Council
November 13, 2024

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4. Response to MND Comments, and Errata
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November 13, 2024
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Cover Letter
September 13, 2024
Thomas Gorham, Contract Planner
Anaheim Planning and Building Department
200 South Anaheim Boulevard, Suite 162
Anaheim, CA 92805
Subject: The Mill Residential Townhome Project (DEV2023-00042), Anaheim– Responses to Comments
Dear Mr. Gorham:

FirstCarbon Solutions (FCS) is pleased to submit this Response to Comments letter for the proposed The Mill Residential Townhome Project (proposed project) in the City of Anaheim.

To date, the following letters has been received with regard to the proposed project:
• Letter #1: Letter from the California Department of Toxic Substances Control (DTSC), dated August 29, 2024
• Letter #2: Letter from the California Department of Transportation (Caltrans), District 12, dated September 3, 2024.

Although a lead agency is not required to provide written responses to comments on Negative Declarations or Mitigated Negative Declarations under the California Environmental Quality Act (CEQA), the City of Anaheim has evaluated the comments received on The Mill Residential Townhome Project (DEV2023-00042) Draft Initial Study/Mitigated Negative Declaration (Draft IS/MND) and has elected to provide responses to comments. None of the comments received included information resulting in the need to recirculate the Draft IS/MND or to prepare an Environmental Impact Report (EIR).

This letter includes a list of the comments and responses to comments on the Draft IS/MND.

A copy of the letters received regarding the Draft IS/MND is included as Attachment A and B, respectively.

Should you have any questions, please do not hesitate to contact us.

Sincerely,

Cecilia So, Senior Project Manager
FirstCarbon Solutions
250 Commerce, Suite 210
Irvine, CA 92602
Enc: Attachment A: DTSC Comment Letter
Attachment B: Caltrans Comment Letter

1 ERRATA
Pursuant to CEQA Guidelines Section 15073.5, a lead agency would be required to recirculate a negative declaration prior to adoption when the document must be substantially revised after public notice of its availability has previously been given pursuant to Section 15072, but prior to its adoption. Notice of recirculation shall comply with Sections 15072 and 15073. A “substantial revision” of the negative declaration is defined as a new, avoidable significant effect is identified and mitigation measures or project revisions must be added in order to reduce the effect to insignificance, or the lead agency determines that the proposed mitigation measures or project revisions will not reduce potential effects to less than significance and new measures or revisions must be required.

CEQA Guidelines 15073.5(c) states that recirculation is not required under the following circumstances:
(1) Mitigation measures are replaced with equal or more effective measures pursuant to Section 15074.1.
(2) New project revisions are added in response to written or verbal comments on the project’s effects identified in the proposed negative declaration which are not new avoidable significant effects.
(3) Measures or conditions of project approval are added after circulation of the negative declaration which are not required by CEQA, which do not create new significant environmental effects and are not necessary to mitigate an avoidable significant effect. (4) New information is added to the negative declaration which merely clarifies, amplifies, or makes insignificant modifications to the negative declaration.

The following are revisions to the Draft IS/MND for The Mill Residential Townhome Project. These revisions are minor modifications and clarifications to the document. The revisions do not change the significance of any of the environmental issue conclusions within the Draft IS/MND and would not require recirculation of the Draft IS/MND. All additions to the text are underlined (underlined) and all deletions from the text are stricken (stricken).

Mitigation Measure (MM) TCR-1
The following changes to MM TCR-1 and MM TCR-2 have been revised throughout the document to accommodate all consulting tribes.

MM TCR-1 Retain a Native American Monitor Prior to Commencement of Ground-disturbing Activities
a. The project applicant/lead agency shall retain a Native American Monitor from the consulting Tribe(s). The monitor shall be retained prior to the commencement of any “ground-disturbing activity” for the subject project at all project locations (i.e., both on-site and any off-site locations that are included in the project

2 description/definition and/or required in connection with the project, such as public improvement work). “Ground-disturbing activity” shall include, but is not limited to, demolition, pavement removal, potholing, auguring, grubbing, tree removal, boring, grading, excavation, drilling, and trenching.
b. A copy of the executed monitoring agreement with the consulting Tribe(s) shall be submitted to the lead agency prior to the commencement of any ground-disturbing activity, or the issuance of any permit necessary to commence a ground-disturbing activity.
c. The tribal monitor shall complete daily monitoring logs that shall provide descriptions of the relevant ground-disturbing activities, the type of construction activities performed, locations of ground-disturbing activities, soil types, cultural- related materials, and any other facts, conditions, materials, or discoveries of significance to the consulting Tribe(s). Monitor logs shall identify and describe any discovered Tribal Cultural Resources (TCRs), including but not limited to, Native American cultural and historical artifacts, remains, places of significance, etc., (collectively, Tribal Cultural Resources, or “TCR”), as well as any discovered Native American (ancestral) human remains and burial goods. Copies of monitor logs shall be provided to the project applicant/lead agency upon written request to the consulting Tribe(s).
d. On-site Tribal monitoring shall conclude upon the latter of the following (1) written confirmation to the Kizh consulting Tribe(s) from a designated point of contact for the project applicant/lead agency that all ground-disturbing activities and phases that may involve ground-disturbing activities on the project site or in connection with the project are complete; or (2) a determination and written notification by the Kizh consulting Tribe(s) to the project applicant/lead agency that no future, planned construction activity and/or development/construction phase at the project site possesses the potential to impact Kizh TCRs.
e. The Owner/Developer shall provide the following note on all grading plans:
• This project requires the applicant to contract with a Native American Monitor to be available to evaluate any Tribal and cultural resources unearthed during excavation and grading activities. Contractor shall maintain direct contact information for City-approved Monitor and make available to Public Works Inspector at pre-construction meeting.
• Contractor will be responsible to copy Public Works Inspector on correspondence to third-party monitor to schedule monitoring. • In the event that Tribal and cultural resources are inadvertently unearthed during excavation and grading activities, the Contractor shall immediately cease all earth-disturbing activities within a 100-foot radius of the area of discovery until such time that avoidance or salvage operations are concluded under the direction of the Paleontologist.

3 • A final summary prepared by the monitor that identifies any materials found and noting that monitoring activities have been concluded must be provided to the Public Works Inspector, prior to pad certification/building permit issuance (when no pad certification).

MM TCR-2 Unanticipated Discovery of Tribal Cultural Resource Objects (Non-Funerary/Non- Ceremonial)
a. Upon discovery of any Tribal Cultural Resources (TCRs), all construction activities in the immediate vicinity of the discovery shall cease (i.e., not less than the surrounding 50 feet) and shall not resume until the discovered TCR has been fully assessed by the Kizh consulting Tribe(s) Tribal Monitor and/or Kizh Archaeologist.

The Kizh consulting Tribe(s) shall recover and retain all discovered TCRs in the form and/or manner the Tribe deems appropriate, in the consulting Tribe(s)’s sole discretion, and for any purpose the consulting Tribe(s) deems appropriate, including for educational, cultural and/or historic purposes.

4 RESPONSE TO COMMENTS
The comment letters are included as Attachment A and B, respectively, of this memorandum and listed below. A list of public agencies, organizations, and individuals who commented on the Draft IS/MND is presented below. Each comment has been assigned a code. Individual comments within each communication have been numbered so comments can be cross-referenced with responses. Following this list, the text of the communication is reprinted and followed by the corresponding response.

Author Code
Department of Toxic Substances Control ................................................................................................ DTSC Caltrans, District 12 ......................................................................................................................... CALTRANS Letter from DTSC, Dated August 29, 2024
Comment DTSC-1
The Limited Phase II Subsurface Investigation Report Section 3.1 Laboratory Results states:
“Concentrations of diesel and oil range hydrocarbons below 1,000 mg/Kg are typically considered insignificant in commercial cases” and Section 5.0 Limitations states “This Subsurface Investigation was performed in accordance with generally and currently accepted engineering practices and principles; however, the procedures and methodologies used in this investigation are not intended to meet all specific regulatory guidelines as this work was completed as a self-directed effort.” Since the proposed Project will be developed into a residential community, DTSC recommends the City of Anaheim enter into DTSC’s Standard Voluntary Agreement (SVA) program so a proper evaluation of the Project is completed. If entering into an SVA with DTSC, the FLUXX portal link is provided and the page also has a link to the Fluxx User Guide that can help you navigate the system. You will need to create a new profile and once in the system, click “Start a Request for Lead Agency Oversight Application.” DTSC recommends that once the SVA is signed, a Preliminary Endangerment Assessment Report (PEA Report) be submitted for DTSC review. The PEA Report shall summarize all existing data and provide an evaluation of the possible risk to current and future users of the site. If you have any questions about the application portal, please contact the DTSC Brownfield Coordinator Gregory Shaffer or contact the Application Portal Inbox.

Response to Comment DTSC-1
While this is the recommendation made by the DTSC, it is not a requirement for the development of the proposed project. It is Hillmann’s professional opinion that an “SVA” is not warranted for this property and that a Soil Management Plan (SMP) will be required as a condition of approval that will address possible risk to future users of the site.

Comment DTSC-2
DTSC recommends that all imported soil and fill material should be tested to assess any contaminants of concern meet screening levels as outlined in DTSC's Preliminary Endangerment Assessment (PEA)

5 Guidance Manual. Additionally, DTSC advises referencing the DTSC Information Advisory Clean Imported Fill Material Fact Sheet if importing fill is necessary. To minimize the possibility of introducing contaminated soil and fill material there should be documentation of the origins of the soil or fill material and, if applicable, sampling be conducted to ensure that the imported soil and fill material are suitable for the intended land use. The soil sampling should include analysis based on the source of the fill and knowledge of the prior land use. Additional information can be found by visiting DTSC’s Human and Ecological Risk Office (HERO) webpage. DTSC believes the City of Anaheim must address these comments to determine whether any significant impacts under the California Environmental Quality Act (CEQA) will occur and, if necessary, avoid significant impacts under CEQA. DTSC may provide additional comments on future environmental documents as further information becomes available.

Response to Comment DTSC-2
Comment noted. It is industry standard practice to test all imported soil to ensure it will not impact future users of the site.

Comment DTSC-3
If buildings or other structures are to be demolished on any project sites included in the proposed project, surveys should be conducted for the presence of lead-based paints or products, mercury, asbestos containing materials, and polychlorinated biphenyl caulk. Removal, demolition, and disposal of any of the above-mentioned chemicals should be conducted in compliance with California environmental regulations and policies. In addition, sampling near current and/or former buildings should be conducted in accordance with DTSC’s Preliminary Endangerment Assessment (PEA) Guidance Manual.

Response to Comment DTSC-3
A comprehensive inspection of the structures of the property will be conducted before demolition. Any building materials containing elevated levels of lead-based paints or products, mercury, asbestos- containing materials, and polychlorinated biphenyl caulk will be removed per all applicable local, State and federal regulations.

Letter from Caltrans, District 12, Dated September 3, 2024 Comment CALTRANS-1
Please provide discussion of City’s multimodal mobility strategies for improvement opportunities and coordination efforts that will accommodate additional demand for transit services related to this proposed project.

Response to CALTRANS-1
Discussion has been included in Section 2.17 of the Draft IS/MND regarding the City’s multimodal mobility strategies. This additional discussion is provided for informational purposes and does not change any of the analysis or conclusions in the document.

6 Comment CALTRANS-2
Please encourage the use of transit among future residents, visitors, and workers of the development.

Increasing multimodal transportation will lead to a reduction in congestion, Vehicle Miles Traveled, and improve air quality.

Response to CALTRANS-2
As discussed in Section 2.17, Transportation, of the Draft IS/MND, the proposed project would include a pedestrian-friendly design, including sidewalks and streetlights for pedestrians. The sidewalks would connect to the existing sidewalks along East Santa Ana Street, Claudina Street, Philadelphia Street, and Olive Avenue.

Furthermore, there are existing Class III bike routes on Anaheim Boulevard south of Santa Ana Street and on Santa Ana Street west of Anaheim Boulevard. There is a planned Class III bike route along the proposed project’s frontage on South Olive Street and East Santa Ana Street east of Anaheim Boulevard.

There is a planned Class II bike lane on Anaheim Boulevard in the vicinity of the proposed project.

The proposed project is located conveniently to transit services, which ensures access to residents and encourages their use. The closest Orange County Transportation Authority (OCTA) transit route runs along Anaheim Boulevard (near East Santa Ana Street), and the nearest bus stop is located approximately 465 feet west of the project site. This bus stop provides service to OCTA Route 47. This route could serve the proposed project. The proposed project would not result in any adverse impacts to public transit, bicycle, or pedestrian facilities.

Comment CALTRANS-3
On page 114 of the Initial Study MND, under Environmental Setting, provide the specific OCTA transit route service information and any other existing transit route services for all such as local, intracounty, and/or interregional bus services if any, within the nearby proposed project areas including the regional connectivity into the rail services provided by Metrolink and Amtrak Pacific Surfliner.

Response to CALTRANS-3
Discussion has been included in Section 2.17 of the Draft IS/MND regarding the specific OCTA transit route service information near the proposed project area. This clarification is provided for informational purposes and does not change any of the analysis or conclusions in the document.

Comment CALTRANS-4
Please provide adequate wayfinding signage and related amenities for transit stops where needed within the project vicinity.

7 Response to CALTRANS-4
The proposed project would encourage the use of multimodal opportunities within its vicinity. Signage to nearby transit facilities would be designed to meet applicable City regulations. This suggestion does not raise any issues related to the adequacy of the Draft IS/MND or allege any potential adverse environmental impacts associated with the proposed project. This comment is noted.

Comment CALTRANS-5
Consider utilizing alley space or similar areas to reduce the need for on street parking which may conflict with highway/street flows.

Response to CALTRANS-5
The proposed project will comply with all applicable City design standards related to parking, access, and traffic flows. This suggestion does not raise any issues related to the adequacy of the Draft IS/MND or allege any potential adverse environmental impacts associated with the proposed project. This comment is noted.

Comment CALTRANS-6
Please consider the creation of emergency plans that include emergency routes and paths. This can alleviate congestion in the event of an emergency and allow EMS to easily access the site.

Response to CALTRANS-6
The proposed project would be compliant with the City Building Division and Anaheim Fire & Rescue standards. To ensure compliance, Anaheim Fire & Rescue would review project plans for final approval prior to issuance of a Building Permit. This suggestion does not raise any issues related to the Draft IS/MND or allege any potential adverse environmental impacts associated with the proposed project.

This comment is noted.

Comment CALTRANS-7
Please ensure the project site provides posted speed signs.

Response to CALTRANS-7
The proposed project will comply with all applicable design guidelines related to the posting of signs.

This suggestion does not raise any issues related to the Draft IS/MND or allege any potential adverse environmental impacts associated with the proposed project. This comment is noted.

Comment CALTRANS-8
Encourage commercial and high-density residential developments to offer pickup point services or automated parcel systems (e.g., Amazon Lockers) so that deliveries can be made with one truck stop instead of multiple stops to individual residences.

8 Response to CALTRANS-8
Impacts related to Vehicle Miles Traveled (VMT) are less than significant and do not require additional mitigation. This comment is noted, and this request has been forwarded to the applicant for consideration.

Comment CALTRANS-9
Bicycle parking design may need to accommodate cargo bikes, such as for food delivery services. This can alleviate the need for delivery trucks and GHG emissions associated with them.

Response to CALTRANS-9
Bicycle parking design will meet all City requirements. This suggestion does not raise any issues related to the adequacy of the Draft IS/MND or allege any potential adverse environmental impacts associated with the proposed project. This comment is noted, and this request has been forwarded to the applicant.

Comment CALTRANS-10
During construction, please ensure that appropriate detours and safety measures are in place to prioritize the mobility, access, and safety of bicyclists, pedestrians, and transit users. If adjacent sidewalks or bike lanes need to be closed during construction, please ensure that closures and detours are clearly signed.

Response to CALTRANS-10
The proposed project would be compliant with the City Building Division and Anaheim Fire & Rescue standards during construction and operation.

Comment CALTRANS-11
Please consider providing electric charging stations for personal vehicle use. This encourages adoption of electric or hybrid vehicles.

Response to CALTRANS-11
This suggestion does not raise any issues related to the Draft IS/MND or allege any potential adverse environmental impacts associated with the proposed project. The comment is noted, and this design request has been forwarded to the applicant.

Comment CALTRANS-12
Any work performed within Caltrans right-of-way (R/W) will require discretionary review and approval by Caltrans and an encroachment permit will be required for any work within the Caltrans R/W prior to construction. Prior to submitting to Caltrans Permit’s branch, applicant should fill out Applicant’s Checklist to Determine Applicable Review Process (QMAP List) Form TR-0416 to determine if project oversight/coordination with Caltrans Project Manager is needed. Applicant must submit a signed

9 Standard Encroachment Permit application form TR-0100 along with a deposit payable to Caltrans.

Deposit amount will be dependent on when the application is submitted. Public corporations are legally exempt from encroachment permit fees. However, contractors working for public corporations are not exempt from fees. Please note that all utility work should be disclosed prior to permit submittal, and utility companies are to apply for separate permits for their corresponding work.

Response to CALTRANS-12
It is not anticipated that the proposed project will involve any work within Caltrans right-of-way or in close enough proximity that an Encroachment Permit would be required. However, the applicant will be made aware of this requirement and will comply with the Encroachment Permit requirements, if applicable.

Comment CALTRANS-13
Project plans and traffic control plans must be stamped and signed by a licensed engineer. For all plans, including traffic control plans, Caltrans R/W lines should be clearly labeled, which includes existing and proposed (if there are any changes to Caltrans R/W), the north arrow, the edge of pavement, and edge of the sidewalk, if applicable. When submitting the application, please include final Environmental Clearance Documentation, relevant design details including design exception approvals and construction and drainage plans, traffic control plans, traffic management plan and traffic impact study if proposed traffic delay of 30 minutes above normal recurring traffic delay is anticipated, any Caltrans R/W certifications if needed, maintenance agreement as needed, shoring plans for any excavation 5-feet or more, ADA certification, and any letter of authorizations.

Response to CALTRANS-13
This comment is noted. It is not anticipated that the proposed project will involve any work within Caltrans right-of-way. However, the applicant will be made aware of this requirement.

Comment CALTRANS-14
Please submit all applications and associated documents/plans via email to [email protected] until further notice. Caltrans Encroachment Permits will be transitioning to an online web portal base for all applications in Fall 2023. Further details to be announced on the Caltrans Encroachment Permits homepage. Additional information regarding encroachment permits may be obtained by contacting the Caltrans Permits Office at (657) 328-6246. For specific details on Caltrans Encroachment Permits procedure and any future updates regarding the application process and permit rates, please visit the Caltrans Encroachment Permits homepage at https://dot.ca.gov/programs/traffic-operations/ep.

Response to CALTRANS-14
This comment is noted. It is not anticipated that the proposed project will involve any work within Caltrans right-of-way or in close enough proximity that an Encroachment Permit would be required.

However, the applicant will be made aware of this requirement.

Attachment A:

DTSC Comment Letter
Printed on Recycled Paper

SENT VIA ELECTRONIC MAIL
August 29, 2024
Thomas Gorham
Contract Planner
City of Anaheim
200 South Anaheim Boulevard, Suite 162
Anaheim, CA 92805
[email protected]
RE: MITIGATED NEGATIVE DECLARATION FOR THE MILL RESIDENTIAL TOWNHOME PROJECT (DEV2023-00042), DATED AUGUST 19 2024 STATE CLEARINGHOUSE NUMBER 2024080719
Dear Thomas Gorham,
The Department of Toxic Substances Control (DTSC) received a Mitigated Negative Declaration (MND) for the Mill Residential Townhome Project (DEV2023-00042) (Project). The proposed Project site is located at 275 and 301 East Santa Ana Street in the City of Anaheim, California. The proposed Project would develop a new residential infill community consisting of 56 for-sale 3-story condominium townhomes ranging in size from approximately 1,200 to 1,800 square feet with 24 two-bedroom and 32 three- bedroom units. After review of the MND, DTSC has the following comments for consideration:

1. The Limited Phase II Subsurface Investigation Report Section 3.1 Laboratory Results states: “Concentrations of diesel and oil range hydrocarbons below

Thomas Gorham
August 29, 2024

Page 2 ends

1,000 mg/Kg are typically considered insignificant in commercial cases” and Section 5.0 Limitations states “This Subsurface Investigation was performed in accordance with generally and currently accepted engineering practices and principles; however, the procedures and methodologies used in this investigation are not intended to meet all specific regulatory guidelines as this work was completed as a self-directed effort.”. Since the proposed Project will be developed into a residential community, DTSC recommends the City of Anaheim enter into DTSC’s Standard Voluntary Agreement (SVA) program so a proper evaluation of the Project is completed. If entering into an SVA with DTSC, the FLUXX portal link is provided and the page also has a link to the Fluxx User Guide that can help you navigate the system. You will need to create a new profile and once in the system, click “Start a Request for Lead Agency Oversight Application.” DTSC recommends that once the SVA is signed, a Preliminary Endangerment Assessment Report (PEA Report) be submitted for DTSC review. The PEA Report shall summarize all existing data and provide an evaluation of the possible risk to current and future users of the site. If you have any questions about the application portal, please contact the DTSC Brownfield Coordinator Gregory Shaffer or contact the Application Portal Inbox

2. DTSC recommends that all imported soil and fill material should be tested to assess any contaminants of concern meet screening levels as outlined in DTSC's Preliminary Endangerment Assessment (PEA) Guidance Manual.

Additionally, DTSC advises referencing the DTSC Information Advisory Clean Imported Fill Material Fact Sheet if importing fill is necessary. To minimize the possibility of introducing contaminated soil and fill material there should be documentation of the origins of the soil or fill material and, if applicable, sampling be conducted to ensure that the imported soil and fill material are suitable for the intended land use. The soil sampling should include analysis based on the source of the fill and knowledge of the prior land use. Additional information can be found by visiting DTSC’s Human and Ecological Risk Thomas Gorham
August 29, 2024

Page 3 ends

Office (HERO) webpage. DTSC believes the City of Anaheim must address these comments to determine if any significant impacts under the California Environmental Quality Act (CEQA) will occur and, if necessary, avoid significant impacts under CEQA. DTSC may provide additional comments on future environmental documents as further information becomes available.

3. If buildings or other structures are to be demolished on any project sites included in the proposed project, surveys should be conducted for the presence of lead-based paints or products, mercury, asbestos containing materials, and polychlorinated biphenyl caulk. Removal, demolition, and disposal of any of the above-mentioned chemicals should be conducted in compliance with California environmental regulations and policies. In addition, sampling near current and/or former buildings should be conducted in accordance with DTSC’s Preliminary Endangerment Assessment (PEA) Guidance Manual
DTSC appreciates the opportunity to comment on the Mill Residential Townhome Project (DEV2023-00042). Thank you for your assistance in protecting California’s people and environment from the harmful effects of toxic substances. If you have any questions or would like any clarification on DTSC’s comments, please respond to this letter or via email for additional guidance.

Sincerely,

Tamara Purvis
Associate Environmental Planner
CEQA Unit-Permitting – HWMP
Department of Toxic Substances Control
[email protected]

Thomas Gorham
August 29, 2024

Page 4 ends

cc: ( via email)
Governor’s Office of Planning and Research
State Clearinghouse
[email protected]
Louisa Feletto
Forward Planning Manager
MLC Holdings, Inc.
[email protected]
Cecilia So
Senior Project Manager
FirstCarbon Solutions
[email protected]
Scott Wiley
Associate Governmental Program Analyst
CEQA Unit-Permitting/HWMP
Department of Toxic Substances Control
[email protected]
Dave Kereazis
Associate Environmental Planner
CEQA Unit-Permitting/HWMP
Department of Toxic Substances Control
[email protected]

Attachment B:

Caltrans Comment Letter

“Provide a safe and reliable transportation network that serves all people and respects the environment” DISTRICT 12
1750 East 4 th Street, Suite 100 | SANTA ANA, CA 92705 (657) 328-6000 | FAX (657) 328-6522 TTY 711
https://dot.ca.gov/caltrans-near-me/district-12

September 3, 2024

Mr. Thomas Gorham File: LDR/CEQA
Contract Planner SCH: 2024080719
City of Anaheim 12-ORA-2024-02635
200 South Anaheim Blvd. SR 57, PM: 14.766
Anaheim, CA. 92805 SR 91, PM: 4.27
I-5, PM: 38.656

Dear Mr. Gorham,

Thank you for including the California Department of Transportation (Caltrans) in the review of the Mitigated Negative Declaration (MND) for the Mill Residential Townhome Project. The project proposes to develop a new residential infill community consisting of 56 for-sale 3-story condominium townhomes ranging in size from approximately 1,200 to 1,800 square feet with 24 two-bedroom and 32 three-bedroom units. The proposed project would provide private roadways and parking, pedestrian walkways, common space and amenity areas throughout the project site, landscaping, and a recreational amenity area within the project site. The proposed project would provide trash enclosures on each block on the north side of the project site. An Affordable Housing component is proposed with this development. A total of 10 percent (or six dwelling units) would be sold to moderate-income buyers.

The project site is located at 275 and 301 East Santa Ana Street in the City of Anaheim (City), in Orange County, California. The project site is bound by East Santa Ana Street to the south, South Claudine Street to the west, South Olive Street to the east, and an existing alley to the north. South Philadelphia Street divides the middle of the project area, creating two separate blocks. The approximately 2.05-acre project site consists of three parcels, Assessor’s Parcel Numbers (APNs) 037024-11, and 037-111-29, and -30.

The project site can be accessed regionally by State Route (SR) 57, SR 91 and Interstate 5 (I-5).

State Routes 57 and 91as well as Interstate 5 are all owned and operated by Caltrans.

Therefore, Caltrans is a responsible agency on this project, and has the following comments:

1. Please provide discussion of City’s multimodal mobility strategies for improvement opportunities and coordination efforts that will accommodate additional demand for transit services related to this proposed project.

City of Anaheim
September 3, 2024

Page 2 ends

“Provide a safe and reliable transportation network that serves all people and respects the environment”

2. Please encourage the use of transit among future residents, visitors, and workers of the development. Increasing multimodal transportation will lead to a reduction to congestion, Vehicle Miles Traveled, and improve air quality.

3. On page 114 of the Initial Study MND, under Environmental Setting, provide the specific OCTA transit route service information and any other existing transit route services for all such as local, intracounty, and/or interregional bus services if any, within the nearby proposed project areas including the regional connectivity into the rail services provided by Metrolink and Amtrak Pacific Surfliner.

4. Please provide adequate wayfinding signage and related amenities for transit stops where needed within the project vicinity.

5. Consider utilizing alley space or similar areas to reduce the need for on street parking which may conflict with highway/street flows.

6. Please consider the creation of emergency plans that include emergency routes and paths. This can alleviate congestion in the event of an emergency and allow EMS to easily access the site.

7. Please ensure the project site provides posted speed signs.

8. Encourage commercial and high-density residential developments to offer pick- up point services or automated parcel systems (e.g. Amazon Lockers) so that deliveries can be made with one truck stop instead of multiple stops to individual residences.

9. Bicycle parking design may need to accommodate cargo bikes, such as for food delivery services. This can alleviate the need for delivery trucks and GHG emissions associated with them.

10. During construction, please ensure that appropriate detours and safety measures are in place to prioritize the mobility, access, and safety of bicyclists, pedestrians, and transit users. If adjacent sidewalks or bike lanes need to be closed during construction, please ensure that closures and detours are clearly signed.

City of Anaheim
September 3, 2024

Page 3 ends

“Provide a safe and reliable transportation network that serves all people and respects the environment”

11. Please consider providing electric charging stations for personal vehicle use. This encourages adoption of electric or hybrid vehicles.

12. Any work performed within Caltrans right-of-way (R/W) will require discretionary review and approval by Caltrans and an encroachment permit will be required for any work within the Caltrans R/W prior to construction. Prior to submitting to Caltrans Permit’s branch, applicant should fill out Applicant’s Checklist to Determine Applicable Review Process (QMAP List) Form TR-0416 to determine if project oversight/coordination with Caltrans Project Manager is needed. Applicant must submit a signed Standard Encroachment Permit application form TR-0100 along with a deposit payable to Caltrans. Deposit amount will be dependent on when the application is submitted. Public corporations are legally exempt from encroachment permit fees. However, contractors working for public corporations are not exempt from fees. Please note that all utility work should be disclosed prior to permit submittal, and utility companies are to apply for separate permits for their corresponding work.

13. Project plans and traffic control plans must be stamped and signed by a licensed engineer. For all plans, including traffic control plans, Caltrans R/W lines should be clearly labeled, which includes existing and proposed (if there are any changes to Caltrans R/W), the north arrow, the edge of pavement, and edge of the sidewalk, if applicable. When submitting the application, please include final Environmental Clearance Documentation, relevant design details including design exception approvals and construction and drainage plans, traffic control plans, traffic management plan and traffic impact study if proposed traffic delay of 30 minutes above normal recurring traffic delay is anticipated, any Caltrans R/W certifications if needed, maintenance agreement as needed, shoring plans for any excavation 5-feet or more, ADA certification, and any letter of authorizations.

14. Please submit all applications and associated documents/plans via email to [email protected] until further notice. Caltrans Encroachment Permits will be transitioning to an online web portal base for all applications in Fall 2023.

Further details to be announced on the Caltrans Encroachment Permits homepage. Additional information regarding encroachment permits may be obtained by contacting the Caltrans Permits Office at (657) 328-6246. For specific details on Caltrans Encroachment Permits procedure and any future updates regarding the application process and permit rates, please visit the Caltrans Encroachment Permits homepage
at https://dot.ca.gov/programs/traffic-operations/ep.

City of Anaheim
September 3, 2024

Page 4 ends

“Provide a safe and reliable transportation network that serves all people and respects the environment” Caltrans’ mission is to provide a safe and reliable transportation network that serves all people and respects the environment. Please continue to coordinate with Caltrans for any future developments that could potentially impact State transportation facilities. If you have any questions, please do not hesitate to contact Julie Lugaro at [email protected].

Sincerely,

Scott Shelley
Branch Chief,
LDR-Climate Change-Transit Planning
Caltrans, District 12

Mill Residential Townhome Project 12-
ORA-2024-02635
Final Audit Report 2024-09-03
Created: 2024-09-03
By: Julie Lugaro ([email protected])
Status: Signed
Transaction ID: CBJCHBCAABAA2Jezeq2o5MzxKr2G8maqj0o75Yn07Lld "Mill Residential Townhome Project 12-ORA-2024-02635" Histo ry
Document created by Julie Lugaro ([email protected])
2024-09-03 - 9:11:19 PM GMT- IP address: 149.136.33.246 Document emailed to Scott Shelley ([email protected]) for signature 2024-09-03 - 9:11:50 PM GMT
Email viewed by Scott Shelley ([email protected]) 2024-09-03 - 9:18:17 PM GMT- IP address: 146.75.136.1
Document e-signed by Scott Shelley ([email protected]) Signature Date: 2024-09-03 - 9:31:24 PM GMT - Time Source: server- IP address: 149.136.33.246 Agreement completed.
2024-09-03 - 9:31:24 PM GMT

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