4. Findings of Fact — Anaheim City Council, December 9, 2025

OC RIVER WALK PROJECT

CEQA FINDINGS OF FACT FOR THE
FINAL ENVIRONMENTAL IMPACT REPORT No. 357
SCH No. 2023030639

Prepared for:

City of Anaheim
Community Services Department, Parks Division
200 S. Anaheim Boulevard, Suite 433
Anaheim, CA 92805

November 2025

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Chapter 1.0 Introduction

1.1 Findings of Facts
The following California Environmental Quality Act (CEQA) Findings of Fact (Findings) are made for the OC River Walk Project (project). The environmental effects of the project are addressed in the Final Environmental Impact Report (EIR) dated November 2025 (State Clearinghouse No. 2023030639), which is incorporated by reference herein.

California Public Resources Code Section 21081(a) and Section 15091(a) of the CEQA Guidelines require that no public agency shall approve or carry out a project for which an EIR has been certified identifying one or more significant effects on the environment unless such public agency makes one or more of the following findings:
1) Changes or alterations have been required in, or incorporated into, the project that mitigate or avoid the significant environmental effects on the environment; 2) Those changes or alterations are within the responsibility and jurisdiction of another public agency and have been, can, or should be adopted by that other agency; or 3) Specific economic, legal, social, technological, or other considerations, including considerations for the provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or alternatives identified in the EIR.

CEQA also requires that the Findings made pursuant to Section 15091 of the CEQA Guidelines be supported by substantial evidence in the record (CEQA Guidelines Section 15091[b]). Under CEQA, substantial evidence means enough relevant information has been provided (and reasonable inferences may be derived from this information) that a fair argument can be made to support a conclusion even though other conclusions might also be reached. Substantial evidence must include facts, reasonable assumptions predicated upon facts, and expert opinion supported by facts (CEQA Guidelines Section 15384).

CEQA further requires the decision-making agency to balance, as applicable, the economic, legal, social, technological, or other benefits of a proposed project against its unavoidable environmental effects when determining project approval. If the specific economic, legal, social, technological, or other benefits of a proposed project outweigh the unavoidable adverse environmental effects, the adverse environmental effects may be considered “acceptable” (Section 15093(a) of the CEQA Guidelines). When the lead agency approves a project which will result in the occurrence of significant effects which are identified in the Final EIR but are not avoided or substantially lessened, the agency shall state in writing the specific reasons to support its actions based on the Final EIR and/or other information in the record. The Final EIR did not include any significant impacts that cannot be avoided or substantially lessened. Therefore, no Statement of Overriding Considerations is required for this project.

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The Findings have been submitted to the City of Anaheim (City) for consideration by the decision- making body (City Council). They are provided to allow the public an opportunity to review the project applicant’s position on this matter and to review potential reasons for approving the project. It is the role of staff to independently evaluate the proposed Findings, and to make a recommendation to the decision maker regarding their legal adequacy. It is the exclusive discretion of the decision maker certifying the EIR to determine the adequacy of the proposed Findings.

1.2 Records of the Proceedings
For purposes of CEQA, the Record of Proceedings for the project consists of the following documents and other evidence, at a minimum:
• The Notice of Preparation and all other public notices issued by the City in conjunction with the Project;
• All responses to the Notice of Preparation received by the City; • The Draft EIR;
• The Final EIR;
• All written comments submitted by agencies or members of the public during the public review comment period on the Draft EIR;
• All responses to the written comments included in the Final EIR; • All written and oral public testimony presented during a noticed public hearing for the Project at which such testimony was taken;
• The Mitigation Monitoring and Reporting Program;
• The reports and technical memoranda included or referenced in any responses to comments in the Final EIR;
• Matters of common knowledge to the City, including, but not limited to, federal, state, and local laws and regulations;
• Any documents expressly cited in these Findings and SOC; and • Any other relevant materials required to be in the Record of Proceedings by Public Resources Code Section 21167.6(e).

1.3 Custodian and Location of Records
The documents and other materials that constitute the Record of Proceedings for the City’s actions on the project are located at the following location: Anaheim City Hall, Community Services Department, Parks Division, 200 S. Anaheim Boulevard, Suite 433, Anaheim, CA 92805. The Community Services Department is the custodian of the project’s administrative record. Copies of the document that constitute the Record of Proceedings are and at all relevant times have been available upon request at the offices of the Community Services Department.

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The Draft EIR and the Final were placed on the City’s website at:
https://www.anaheim.net/876/Environmental-Documents. This information is provided in compliance with Public Resources Code Section 21081.6(a)(2) and CEQA Guidelines Section 15091(e).

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Chapter 2.0 Project Summary

2.1 Project Objectives

The specific objectives for the project are as follows:

1. Adopt the OC River Walk Conceptual Master Plan to further enhance and accentuate existing recreational areas, facilitate pedestrian and bicycle access, and promote the use of the river corridor open space area for the community benefit.

2. Implement projects identified in the OC River Walk Conceptual Master Plan that will create visually appealing outdoor public amenities that will benefit and promote environmental and community health, recreation, safety, entertainment, wayfinding, art, education, cultural awareness, beauty, connectivity, water supply, economic, and natural resource needs.

3. Provide seamless and cohesive improvements across jurisdictions on the project site to benefit the public and the area’s aesthetics.

4. Implement projects to transform and improve the river and riverbed’s groundwater recharge potential and improve the river corridor’s ecology (flora and fauna).

5. Maintain and enhance flood protection capacity and resiliency.

6. Enhance connectivity and community access by leveraging the project site's location near Anaheim Regional Transportation Intermodal Center (ARTIC), major entertainment venues, and adjacent mixed-use developments.

2.2 Project Description

2.2.1 Project Location
The project site is located along the Santa Ana River corridor, generally extending from Orangewood Avenue north to Ball Road and the existing Anaheim Coves at Burris Basin. It generally encompasses approximately a 2-mile stretch of the Santa Ana River, covering approximately 111 acres. It is approximately 15 miles upstream from the Pacific Ocean and adjacent to Angel Stadium, Anaheim Regional Transportation Intermodal Center (ARTIC), the Honda Center, and the Arena Corporate Center (ACC) buildings on the west side in the City of Anaheim (City). The ARTIC, the Honda Center, and the ACC buildings are all part of the OCVIBE Master Site Plan Project (OCVIBE Project). On the east side of the Santa Ana River, in the City of Orange, the project is near the Sandra Hutchens Regional Law Enforcement Training Center (a facility that includes a combat shooting range), the Orange County Public Works offices, the Stadium Promenade shopping mall, the Extended Stay America – Orange, and the Kinder Morgan Orange Terminal.

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2.2.2 Project Background
In 2021, the OC River Walk Engineering Feasibility Study identified 17 design opportunities along the Santa Ana River within the project site. The opportunities outlined in the Feasibility Study align with the U.S. Army Corps of Engineers Operating Principles, as well as the California State Coastal Conservancy's Santa Ana River Conservancy Program goals of (1) protection and preservation of water resources through multi-benefit projects, (2) habitat and wildlife preservation and enhancement, and (3) equitable education and recreation access. The Feasibility Study served as the launching point for the OC River Walk Conceptual Master Plan and design documents for multiple projects within OC River Walk.

2.2.3 Orange County Water District Groundwater Replenishment System Turnout Structure
On May 18, 2022, the Orange County Water District (OCWD) adopted the Initial Study/Mitigated Negative Declaration (IS/MND) for the Recycled Water Conveyance Improvement Project. This project includes the installation of an outlet facility (referred to as a turnout or pipeline turnout structure) to enable the diversion of treated water from the groundwater replenishment system (GWRS) into the Burris Basin for groundwater recharge. It also includes modifying the existing operational protocol for releasing GWRS water into the Carbon Creek Diversion Channel. The GWRS turnout structure is planned to be located in the southeastern portion of the Burris Basin, adjacent to the Santa Ana River, and is included within The OC River Walk project site. The Burris Basin, an existing groundwater recharge basin owned and operated by the OCWD, is part of the OCWD’s recharge system network in central Orange County. An existing GWRS pipeline that varies between 66 and 60 inches extends from the OCWD’s GWRS plant in Fountain Valley, running along the Santa Ana River embankment to other recharge basins north of Burris Basin. From the Burris Basin, the OCWD can use the Burris Pump Station to move ultra-pure water to the Santiago Basin, further supporting groundwater recharge.

The project would require modifications to this turnout structure, allowing additional options to discharge into either the pipeline leading to the two impoundments or directly into the river, thereby supplying ultra-pure GWRS water to the impoundments.

2.2.4 Project Components
The OC River Walk Conceptual Master Plan consists of various multi-purpose improvements to transform the Santa Ana River corridor and portions of the existing Santa Ana River Trail (SART), along with related off-site improvements necessary for its implementation (collectively referred to as the project). The main components of the Conceptual Master Plan involve creating two water impoundments by installing three inflatable rubber dams, modifying the riverbanks, constructing two pedestrian/bike bridges, providing new trails, improving existing trails, cre ating new and

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protection of existing access ramps, constructing two new undercrossings on the west bank at the Union Pacific Railroad and the Metrolink railroad, providing enhanced community recreation amenities (e.g., terraced seating, nature play areas, parklets, plazas, gathering areas for large-scale events, festivals, and other activities, water access, kayak launch, etc.), and other improvements.

These improvements would require the implementation of 19 project elements, which have been categorized into four groups: Group A – Impoundments, Storm Drain Diversions, and Embankments; Group B – New Pedestrian/Bike Bridges; Group C – New Trails and Trail Improvements; and Group D – Enhanced Community Recreation Amenities, as shown in Table 1, OC River Walk Conceptual Master Plan Elements, and on FEIR Figures 2-7, Proposed Impoundments and Trail Improvements; 2-8, Overall Project Elements; and 2-8a through 2-8d, Proposed Improvements Group A through D. The OC River Walk project conforms with the design goals and function of the SAR described in the U.S. Army Corps of Engineers (USACE) 1988 General Design Memorandum. The project design (e.g., levee design, vegetation, and freeboard, etc.) would be reviewed and permitted by the USACE and the Orange County Flood Control District (OCFCD) through the 408 permitting process.

Table 1. OC River Walk Conceptual Master Plan Elements
No. Conceptual Master Plan Elements Quantity (Approximate)1 Group A: Impoundments, Storm Drain Diversions, and Embankments 1 River Impoundments
1a North Impoundment and Inflatable Rubber Dam
3,000' length, 22 ac area,
110 AF volume
Rubber Dam: 8' x 300'
1b North Impoundment – Rubber Dam Concrete Foundation
310' x 24' x 2' = 700 CY reinforced
concrete
10,000 CY of earthwork subgrade
preparation
1c North Impoundment – Rubber Dam Air Compressor, Controls, and Flow Bypass
10' x 10' x 7' precast concrete vault or
building (preferred)
1d South Impoundment and Inflatable Rubber Dam
1,700' length, 11.5 ac area,
90 AF volume
Rubber Dam: 10' x 300'
1e South Impoundment – Rubber Dam Concrete Foundation
310' x 24' x 2' = 700 CY reinforced concrete
10,000 CY of earthwork subgrade
preparation
1f South Impoundment – Rubber Dam Air Compressor, Controls, and Flow Bypass
10' x 10' x 7' precast concrete vault or
building (preferred)
1g Collins Channel – Inflatable Rubber Dam Rubber Dam: 6' x 45' 1h Collins Channel – Rubber Dam Concrete Foundation
60' x 24' x 2' = 130 CY
1,500 CY of earthwork subgrade
preparation
1i Collins Channel – Rubber Dam Air Compressor and Controls 10' x 10' x 7' precast concrete vault or building (preferred)

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Table 1. OC River Walk Conceptual Master Plan Elements
No. Conceptual Master Plan Elements Quantity (Approximate)1

2. Impoundment Evacuation Pumps 4 pumps at 5 MGD ea. (20 MGD total), 85 HP ea. (340 HP total)

3. Pipeline from Pump Station to GWRS Turnout
(N. of Orangewood Avenue to Burris Basin) 8,000 LF, 30-40" HDPE

4. GWRS Turnout – Concrete Flow Control Structure with
Dechlorination Facilities (Located at South End of Burris Basin) – Off-Site Improvement
50 MGD

5. Storm Drain Diversions (Dry-Weather Flow)
5a Anaheim – Storm Drain Outlets w/ Flap Gates 8 gates, 18"-54" 5b Anaheim – Diversion Manholes 8 manholes
5c Anaheim – Diversion Pump Stations 2 pump stations w/ 2 pumps ea., 125 GPM and 5 HP per pump
5d Anaheim – Storm Drain Diversion Pipe to Sewer 4-6" PVC pipe, 2,200 LF 5e Orange – Storm Drain Outlets w/ Flap Gates 7 gates, 18"-54" 5f Orange – In-Channel Diversion Structure at Collins Channel TBD 5g Orange – Diversion Manholes 7 manholes
5h Orange – Diversion Pump Stations
1 pump station w/ 2 pumps,
200 GPM and 7.5 HP per pump;
2 pump stations w/ 2 pumps ea., 125 GPM
and 5 HP per pump
5i Orange – Storm Drain Diversion Pipe to Sewer 4-6" PVC pipe, 7,250 LF 5j Wet Weather Storm Drain Diversion to Impoundments 1 ±200 AF

6. River Embankments 9,600 LF total
6a North Impoundment Embankment 6,200 LF, 23' avg. height to 26' max, up to 33' at drop structure
6b South Impoundment Embankment 3,400 LF, 23' avg. height to 26' max, up to 33' at drop structure
Group B: New Pedestrian/Bike Bridges

1. Pedestrian/Bike Bridge North of Katella Avenue 400 LF, 36'-58' width, 3 River Piers

2. Pedestrian/Bike Bridge North of Orangewood Avenue 350 LF, 12'-18' width, 5 River Piers

3. Bridge Retaining Walls
3a New Pedestrian/Bike Bridge N. of Katella West Bank Retaining Wall #1 500 LF, <8' height
3b New Pedestrian/Bike Bridge N. of Katella West Bank Retaining Wall #2 500 LF, <8' height
3c New Pedestrian/Bike Bridge N. of Katella East Bank Retaining Wall #3 500 LF, <8' height

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Table 1. OC River Walk Conceptual Master Plan Elements
No. Conceptual Master Plan Elements Quantity (Approximate)1 Group C: New Trails and Trail Improvements

1. Trail West Bank – Katella Avenue to Anaheim Coves 6,400 LF total, 18' typ. width 1a UPRR – Undercrossing (New Undercrossing) 500 LF, 20' typ. width 1b UPRR Undercrossing Retaining Wall 500 LF, <10' height 1c UPRR – At-Grade Crossing (Existing Maintenance Access) 100 LF, 18' typ. width 1d OC River Walk and River Road Retaining Wall 750 LF, <8' height 1e Ball Road Culvert Undercrossing (Existing 14x14 RCB) 800 LF, 18' typ. width 1f Ball Road Bridge Undercrossing w/ City and County and OCWD (Existing Maintenance Access) TBD
1g River Access/Kayak Ramp South of Cerritos (Existing Ramp) TBD 1h Interim UPRR Crossing at Phoenix Club Drive (Existing RR Crossing and New Interim Connection Trail) TBD
1i Replace Access Road Only (For New Pedestrian/Bike Bridge North of Katella Ave.) N/A

2. Trail West Bank – Katella Avenue to Orangewood Avenue 4,000 LF, 18' typ. width 2a Embankment Seating and Steps 350 LF
2b Metrolink RR Undercrossing (Existing Undercrossing) 800 LF, 20' typ. width 2c Metrolink Underpass Retaining Wall 900 LF, <12' height 2d River Walk South Embankment Seating and Steps 450 LF 2e SR-57 Underpass Trail Widening 400 LF
2f SR-57 Retaining Wall 400 LF, <14' height

3. Trail East Bank Katella Avenue to Ball Road 4,300 LF, 18' typ. width 3a Replace Access Road Only (For New Pedestrian/Bike Bridge North of Katella Avenue) N/A
3b Improve Trail w/ Terrace and Community Access 4,300 LF, 12'-40' width 3c East Bank Park/River Terrace Retaining Wall #1 500 LF, <8' height 3d City of Orange Water Recreation Opportunity1 N/A
3e East Bank Park/River Terrace Retaining Wall #2 1,000 LF, <8' height

4. Trail East Bank Katella to Orangewood: SART – Main Line Reroute to East Bank of River 4,000 LF, 18' typ. width
Group D: Enhanced Community Recreation Amenities

1. River Recreation – North Impoundment
1a Kayaking and Water Recreation Activities (kayak launch ramp is identified in Group C 1g.) 22 ac
1b Swimming / Wading Recreational Opportunity 1-3 ac
1c Recirculation and Water Feature Pumps1 1,000-5,000 GPM (1.5-7.5 MGD)
1d Water Feature Elements (Water show, water screen, etc.) 1 TBD 1e Swimming Water Quality Pumps and Treatment 1 5,000-10,000 GPM

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Table 1. OC River Walk Conceptual Master Plan Elements
No. Conceptual Master Plan Elements Quantity (Approximate)1

2. River Recreation – South Impoundment
2a Kayaking and Water Recreation Activities 11.5 ac
2b Under SR-57 – Lighting and Other Amenities TBD
2c Recirculation and Water Feature Pumps1 1,000-5,000 GPM (1.5-7.5 MGD)
2d Water Feature Elements1 TBD

3. OCVIBE Lot B Parking Lot, Potential Future OC River Walk Park 2.2 ac

4. Park / River Terrace: East Bank North of Katella Avenue 4a East Bank (City of Orange) Katella Avenue to UPRR 8.3 ac 4b UPRR to Ball Road 2.2 ac

5. Riverbed Between Impoundments (future recreation TBD) 3.8 ac, 650 LF

6. Art / Education / Signage (Conceptual locations)
6a Iconic Signage1 TBD
6b Bridge Mural and Lighting at freeway underpass TBD
6c Mosaic / Art Installations TBD
6d Reflective Shade Canopies TBD
6e Zen Zone / Wildflower Spaces1 TBD
6f River Poetry Walk TBD
6g Interactive Educational Components TBD
6h Wayfinding Signage1 TBD
6i Conceptual Locations for Art/Signage Opportunities¹ TBD Notes: ac = acres; AF = acre-feet; CY = cubic yards; GPM = gallons per minute; HDPE = high-density polyethylene; HP = horsepower; LF = linear feet; MGD = million gallons per day; N/A = Not Applicable; TBD = to be determined; typ. = typical; UPRR = Union Pacific Railroad; All project dimensions and locations are approximate as of the time of EIR preparation and have been assumed for analysis purposes.
1 Project element is not specifically located at this time or encompasses the entire project site.

For CEQA analysis, it is assumed that these various components could be implemented simultaneously or at different stages within an approximately 10-year period tentatively scheduled between 2026 and 2036. The initial construction is expected to take appro ximately 24 to 36 months.

Additionally, all necessary new and/or upgrades to existing on- and off-site utilities and systems, such as electrical facilities, lighting, landscaping, irrigation, seating, and signage to implement various components of the project, would be provided in compliance with applicable City of Anaheim and City of Orange rates, rules, and regulations; municipal codes; the California Green Building Standards Code; and any applicable engineering standards and specifications, as deemed necessary by the approving agency. The dimensions (e.g., lengths, heights, volumes) and locations

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specified in each element are approximate as of the time of EIR preparation and have been assumed for analysis purposes.

Public Law 84-99, Emergency Response to Natural Disasters, is the USACE’s basic authority to provide for emergency activities in support of State and Local governments prior to, during, and after a flood event. Under PL 84-99, the USACE can provide both emergency technical and direct assistance in response to flood and coastal storms, and can assist if there is a flood threat from damage caused by earthquakes to flood risk management projects. The SAR is currently eligible for Public Law 84-99 program coverage, and it should be noted that the project would not change this eligibility status.

2.2.5 Discretionary Actions
The Project requires the following discretionary actions:
• Approval of the OC River Walk Conceptual Master Plan
• Certification of the EIR
• Adoption of the Mitigation Monitoring and Reporting Program • Minor update to Figure 4, Existing and Planned Bikeway Network, of the City’s Circulation Element.

2.2.6 Other Agency Approvals
Under CEQA, state and local agencies (other than the lead agency) with discretionary authority over a project or aspects of a project are considered responsible agencies. Federal agencies are not responsible agencies under CEQA. The following federal, state, regional, and local agencies may have discretionary authority over the project:
• Lead agency
− Approval of Street Improvement Plans
− Issuance of grading permits
− Encroachment and access permit applications
• Federal
− U.S. Fish and Wildlife Service (USFWS) – Approval of Sections 7 and 10(a) of the federal Endangered Species Act (FESA) compliance
− USACE – Approval of Section 404 Permit and Section 408 Permit, flood contingency plan review and approval
• State
− California Department of Fish and Wildlife (CDFW) – Approval of Section 1602 Permit

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− California Department of Transportation (Caltrans) – Approval of access and encroachment permits within Caltrans right-of-way (i.e., SR-57 freeway), any public artwork within Caltrans right-of-way
− State Historic Preservation Office (SHPO) – Approval of Section 106 compliance − California Public Utilities Commission – Approval of railroad undercrossings at UPRR north of Katella and at Metrolink/LOSSAN adjacent to ARTIC, possible GWRS waterline encroachment permit and access agreement. − California Department of Water Resources – Approval of groundwater management permit (if not covered by the OCWD)
− California State Water Board, Division of Drinking Water – Approval of Title 22 Reuse Permit Amendment for GWRS water, amendment to the OCWD’s existing Title 22 permit
• Regional
− RWQCB – Approval of Section 401 Water Quality Certification; Approval of NPDES Permit; Approval of amendments to OCWD’s Waste Discharge Requirements and Master Recycling Permit for the GWRS
− Southern California Regional Rail Authority – Approval of encroachment/right- of-entry and road crossings permits related to Metrolink, access and installation permitting for public artwork
− UPRR – Approval of encroachment/right-of-way entry and road crossing permit related to UPRR
− Southern California Edison – Approval of encroachment permit • Local
− City of Orange – Approval of encroachment and access permits; minor amendments to the City of Orange General Plan Circulation and Mobility Element and the Bikeways Master Plan may be necessary as improvements are undertaken.
− OCPW and OCFCD – Approval of encroachment and conditional use permits, construction and general use permits, flood contingency plan review and approval, amendment to OCWD-OCFCD agreement for maximum height of OCWD dams within the SAR, OCFCD permit for modifications to undercrossing − OCWD and OCFCD – Approval of easement for trail purposes − Orange County Parks – OCFCD’s permits for trail improvements requires review and approval by OC Parks prior to issuance as it pertains to the maintenance responsibilities identified in the County of Orange’s Memorandum of Understanding. Amendments to existing agreements for the management of trail areas from OC Parks to the City of Anaheim may be required.

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− OCWD – Approval of encroachment and use permits, approval of ownership and maintenance agreements, amendment to OCWD-OCFCD agreement for maximum height of OCWD dams within the SAR, modification/relocation of existing at-grade infrastructure
− OCSAN – Approval of any on and off-site sewer improvements (encroachment permits, permit to discharge dry-weather flow to sewer) − Orange County Transportation Authority – Approval of access permit

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Chapter 3.0 Environmental Review Process and Public
Participation
The lead agency approving the Project and conducting environmental review under CEQA (California Public Resources Code Section 21000 et seq.), and the CEQA Guidelines (California Code of Regulations, Title 14, Section 15000 et seq.), is the City of Anaheim. As lead agency, the City is primarily responsible for carrying out the project, and undertook the following:
• Circulated a Notice of Preparation (NOP) to the Governor’s Office of Land Use and Climate Innovation (the “State Clearinghouse”), Responsible Agencies, Trustee Agencies, and other interested parties on March 23, 2023, for a 30-day review period between March 23, 2023, and April 24, 2023;
• The NOP was posted on the City’s website: https://www.anaheim.net/876/Environmental- Documents;
• The NOP was posted at the Orange County Clerk’s office on September 26, 2022 ; • Held a publicly noticed EIR Scoping Meeting on March 29, 2023, at the Honda Center, Brewery X Room, 2695 E. Katella Avenue, Anaheim, CA 92806, to solicit comments from the public on the environmental issue areas that should be analyzed in the EIR. The Scoping Meeting was also available to attend virtually;
• Submitted a Notice of Availability (NOA) and Notice of Completion (NOC) and electronic copies of the DEIR to the State Clearinghouse, on July 24, 2025; • Sent emails with proof of receipt and mailed, via certified mail, a copy of the NOA to all Responsible Agencies, Trustee Agencies, and other interested parties and organizations not included on the State Clearinghouse’s list of reviewing agencies, to inform rec ipients that the DEIR was available for a 45-day review period from July 24, 2025, to September 8, 2025 ; • The NOA was posted on the City’s website and at the Orange County Clerk’s office on July 24, 2025;
• Published the NOA in the Anaheim Bulletin, which is the newspaper of general circulation in the area affected by the Project, on July 24, 2025;
• The DEIR was posted on the City’s website at: https://www.anaheim.net/876/Environmental- Documents during the public review period for the DEIR; • Prepared responses to comments on the DEIR received during the 45 -day comment period on the DEIR, which have been included in the FEIR;

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• Provided the FEIR, including individual responses to agencies that commented on the DEIR in the Staff Report for Planning Commission on November 13, 2025; • Held a Parks and Recreation Commission Hearing on October 22, 2025; • Held a Planning Commission hearing on November 17, 2025; • Distributed the FEIR, including individual responses to agencies that commented on the DEIR on November 26, 2025; and
• Held a City Council hearing on December 9, 2025.

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Chapter 4.0 Summary of Impacts
Section 15128 of the California Environmental Quality Act (CEQA) Guidelines requires that an EIR contain a brief statement disclosing the reasons why various possible significant effects of a project were found not to be significant and, therefore, would not be discussed in detail in the EIR. The City of Anaheim reviewed the project against the environmental issue areas in Appendix G of the CEQA Guidelines. All environmental issue areas, including those found to have potentially significant impacts, are addressed in Chapter 4 of the Final EIR except the following issues that were deemed no impact or less than significant impact in the Initial Study prepared and circulated with the Notice of Preparation:
• Aesthetics
• Agriculture and Forestry Resources
• Land Use and Planning
• Mineral Resources
• Population and Housing
• Public Services
• Recreation
• Utilities and Service Systems
• Wildfire
The Final EIR concluded that the project would have less than significant impacts and thus, not require mitigation measures with respect to the following issues:
• Air Quality
• Cultural Resources
• Geology and Soils
• Greenhouse Gas Emissions
• Hazards and Hazardous Materials
• Transportation
Potentially significant impacts of the project would be mitigated to below a level of significance with respect to the following issues:
• Biological Resources
• Hydrology and Water Quality
• Noise
• Tribal Cultural Resources
This EIR did not determine any significant and unavoidable environmental impact that would result from development of the project.

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Chapter 5.0 Findings Regarding Impacts
California Environmental Quality Act (CEQA) and the CEQA Guidelines require that the environmental impacts of a project be examined before a project is approved. Specifically, regarding Findings, CEQA Guidelines Section 15091 provides:
(a) No public agency shall approve or carry out a project for which an EIR has been certified that identifies one or more significant environmental effects of th e project unless the public agency makes one or more written findings for each of those significant effects, accompanied by a brief explanation of the rationale for each finding. The possible findings are:
(1) Changes or alterations have been required in, or incorporated into, the project that avoid or substantially lessen the significant environmental effect a s identified in the final EIR.
(2) Such changes or alterations are within the responsibility and jurisdiction of another public agency and not the agency making the finding. Such changes have been adopted by such other agency or can and should be adopted by such other agency.
(3) Specific economic, legal, social, technological, or other considerations, including provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or project alternatives identified in the final EIR.
(b) The findings required by subdivision (a) shall be supported by substantial evidence in the record.
(c) The findings in subdivision (a)(2) shall not be made if the agency making the findings has concurrent jurisdiction with another agency to deal with identified feasible mitigation measures or alternatives. The findings in subdivision (a)(3) shall describe the specific reasons for rejecting identified mitigation measures and project alternatives. (d) When making the findings required in subdivision (a)(1), the agency shall also adopt a program for monitoring and/or reporting on the changes that it has either required in the project or made a condition of approval to avoid or substantially lessen significant environmental effects. These measures must be fully enforceable through permit conditions, agreements, or other measures.
(e) The agency shall specify the location and custodian of the documents or other materials that constitute the record of the proceedings upon which its decision is based. (f) A statement made pursuant to Section 15093 does not substitute for the findings required by this section.

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The “changes or alterations” referred to in CEQA Guidelines Section 15091(a)(1), which are required in, or incorporated into, the project that mitigate or avoid the significant environmental effects of a project, may include a variety of measures or actions as set forth in CEQA Guidelines Section 15370, including the following:
(a) Avoiding the impact altogether by not taking a certain action or parts of an action . (b) Minimizing impacts by limiting the degree or magnitude of the action and its implementation.
(c) Rectifying the impact by repairing, rehabilitating, or restoring the impacted environment. (d) Reducing or eliminating the impact over time by preservation and maintenance operations during the life of the action.
(e) Compensating for the impact by replacing or providing substitute resources or environments, including through permanent protection of such resources in the form of conservation easements.

Having received, reviewed, and considered the Final EIR for the project, as well as other information in the Record of Proceedings on this matter, the following Findings are hereby adopted by the City Council in its capacity as the lead agency decision maker. These Findings set forth the environmental basis for current and subsequent discretionary actions to be undertaken by the City and responsible agencies for the implementation of the project.

5.1 Issues Deemed No Impact Or Less Than Significant Impact In the Notice Of Preparation
The Initial Study/Notice of Preparation (IS/NOP) concluded that the following impacts of the project would not be significant. Those issues include: Aesthetics, Air Quality, Biological Resources, Cultural Resources, Energy, Geology and Soils, Greenhouse Gas Emissions (GHG), Hazards and Hazardous Materials, Hydrology and Water Quality, Land Use and Planning, Mineral Resources, Noise, Population and Housing, Public Services, Recreation, Transportation, Utilities and Service Systems, Wildfire. CEQA Guidelines Section 15091 requires that an EIR may not be certified for a project which has one or more significant environmental effects unless one of three possible findings is made for each significant effect. Since the following environmental issue areas were dete rmined to have no impact or a less than significant impact, no findings are required for these issue areas.

5.1.1 Aesthetics
• a) Has a substantial adverse effect on a scenic vista: No Impact. • b) Substantially damages scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway : No Impact.

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• c) In non-urbanized areas, substantially degrades the existing visual character or quality of public views of the site and its surroundings. (Public views are those that are experienced from publicly accessible vantage point.) If the project is in an urbanized area, conflicts with applicable zoning and other regulations governing scenic quality: No Impact. • d) Creates a new source of substantial light or glare which would adversely affect day or nighttime views in the area: Less than significant impact.

Reference: These Findings incorporate by reference the information and analysis included in Final EIR Appendix A, Initial Study/Notice of Preparation and Final EIR Section 6.4, Table 6-1, Effects Found Not to be Significant.

5.1.2 Agriculture and Forestry Resources.
• a) Converts Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use: No Impact.
• b) Conflicts with existing zoning for agricultural use, or a Williamson Act contract : No Impact. No Impact.
• c) Conflicts with existing zoning for, or cause rezoning of, forest land (as defined in California Public Resources Code section 12220(g)), timberland (as defined by California Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by California Government Code section 51104(g)): No Impact. • d) Results in the loss of forest land or conversion of forest land to non -forest use: No Impact.
• e) Involves other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to non-forest use: No Impact.

5.1.3 Air Quality
• a) Conflicts with or obstruct implementation of the applicable air quality plan. No Impact.

The types of improvements associated with the project are consistent with SCAQMD’s Air

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Quality Management Plan as it includes various multi-purpose improvements. These improvements would promote alternative modes of transportation: No Impact. • b) Results 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: Less than significant impact.
• c) Exposes sensitive receptors to substantial pollutant concentrations : Less than significant impact.
• d) Results in other emissions (such as those leading to odors) adversely affecting a substantial number of people: Less than significant impact.

5.1.4 Biological Resources
• e) Conflicts with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance: No impact.
• f) Conflicts with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan: No impact.

5.1.5 Cultural Resources
• c) Disturbs any human remains, including those interred dedicated cemeteries : No impact.

5.1.6 Energy
• a) Results in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation :

Less than significant impact.

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• b) Conflicts with or obstruct a state or local plan for renewable energy or energy efficiency :

No impact.

5.1.7 Geology and Soils
• e) Has soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater: Less than significant impact.
• f) Directly or indirectly destroys a unique paleontological resource or site or unique geologic feature: Less than significant impact
Reference: These Findings incorporate by reference the information and analysis included in Final EIR Appendix A, Initial Study/Notice of Preparation and Final EIR Section 6.4, Table 6 -1, Effects Found Not to be Significant.

5.1.8 Greenhouse Gas Emissions
• a) Generates greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment: Less than significant impact. • b) Conflicts with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases: No impact.

5.1.9 Hazards and Hazardous Materials
• Creates a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials: Less than significant impact. • c) Emits hazardous emissions or handles hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school: No Impact.
• e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, results in a safety hazard or excessive noise for people residing or working in the project are a: No impact.

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• f) Impairs implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan: Less than significant impact. • g) Exposes people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires: Less than significant impact.

5.1.10 Hydrology and Water Quality
• b) Substantially decreases groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin: Less than significant impact.
• e) Conflicts with or obstruct implementation of a water quality control plan or sustainable groundwater management plan: Less than significant impact.

5.1.11 Land Use and Planning
• a) Physically divides an established community: No impact. • b) Causes a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect:

No impact.

5.1.12 Mineral Resources
• a) Results in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state: No impact.
• b) Results in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan: No impact.

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Reference: These Findings incorporate by reference the information and analysis included in Final EIR Appendix A, Initial Study/Notice of Preparation and Final EIR Section 6.4, Table 6 -1, Effects Found Not to be Significant.

5.1.13 Noise
• c) For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, exposes people residing or working in the project area to excessive noise levels: No impact.

5.1.14 Population and Housing
• a) Induces substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure): No impact.
• b) Displaces substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere: No impact.

5.1.15 Public Services
• a) Results in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:
o Fire protection: Less than significant impact.
o Police protection: Less than significant impact.
o Schools: Less than significant impact.
o Parks: Less than significant impact.
o Other public facilities: Less than significant impact.

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Reference: These Findings incorporate by reference the information and analysis included in Final EIR Appendix A, Initial Study/Notice of Preparation and Final EIR Section 6.4, Table 6 -1, Effects Found Not to be Significant.

5.1.16 Recreation
• a) Increases the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated: Less than significant impact.
• b) Includes recreational facilities or requires the construction or expansion of recreational facilities that might have an adverse physical effect on the environment: Less than significant impact.

5.1.17 Transportation
• a) Conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities: Less than significant impact. • c) Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment): Less than significant impact.
• d) Result in inadequate emergency access: No impact.

5.1.18 Utilities and Service Systems
• a) Requires or results in the relocation or construction of new or expanded water, wastewater treatment or stormwater drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects: Less than significant impact. • b) Has sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry, and multiple dry years: Less than significant impact.

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• c) Results in a determination by the wastewater treatment provider that serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments: Less than significant impact. • d) Generates solid waste in excess of state or local standards, or in excess of the capacity of local infrastructure, or otherwise impairs the attainment of solid waste reduction goals:

Less than significant impact.
• e) Complies with federal, state, and local management and reduction statutes and regulations related to solid waste: Less than significant impact.

5.1.19 Wildfire
• a) Substantially impairs an adopted emergency response plan or emergency evacuation plan: No impact.
• b) Due to slope, prevailing winds, and other factors, exacerbates wildfire risks, and thereby exposes project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire: No impact.
• c) Requires the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines, or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment: No impact. • d) Exposes people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes:

No impact.

5.2 Findings On No Impact and Less Than Significant Impacts

5.2.1 Air Quality
Finding: The project would have a less than significant direct, indirect, and cumulative impact on the below listed thresholds of significance. Accordingly, no changes or alterations to the project were required to avoid or substantially lessen any significant environmental impacts under those

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thresholds. The FEIR evaluated the following impacts and found that no mitigation was required for the identified reasons:

5.2.1.1 Threshold AQ-2: Cumulative Increase in Criteria Pollutant Emissions (Construction)
Less Than Significant: The project would not result in a cumulatively considerable net increase of any criteria air pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard.

Facts in Support of Findings: Construction activities would result in the temporary generation of air pollutants from operation of heavy construction equipment and generation of fugitive dust in the construction area and emissions from worker vehicle trips and hauling of import and exp ort materials. Construction emissions were modeled for the project using CalEEMod Version 2022.1.1.29 using the linear construction project model. The project’s estimated maximum daily construction emissions and the South Coast Air Quality Management District’s (SCAQMD) regional emissions thresholds are summarized in FEIR Table 4.1-4, Construction-Related Regional Pollutant Emissions (pounds/day). As shown in the FEIR Table 4.1-4, the project daily construction emissions would not exceed the SCAQMD thresholds for any pollutant during any phase. It should be noted that even if construction phases were to occur concurrently, the total daily maximum would not exceed the SCAQMD maximum daily thresholds except for NOx emissions. As such, the project would not result in a cumulatively considerable net increase of any criteria air pollutant during construction. This impact would be less than significant.

Reference: These Findings incorporate by reference the information and analysis included in Final EIR Section 4.1, Air Quality, and Appendix C, Air Quality/GHG Data.

5.2.1.2 Threshold AQ-3: Sensitive Receptors (Construction) Less Than Significant: The project would not expose sensitive receptors to substantial pollutant concentrations.

Facts in Support of Findings:

Localized Impacts from Criteria Air Pollutants : The SCAQMD’s screening look-up tables, or Localized Significance Thresholds (LSTs) are used in determining the significance of the project’s localized air quality impacts, and to determine if further detailed analysis is required. The local air emissions from construction were analyzed using the SCAQMD’s Mass Rate Localized Significant Threshold Look-up Tables and the methodology described in the LST Methodology prepared by SCAQMD. The FEIR Table 4.1-5, Local Construction Emissions at the Nearest Receptor, shows the on-site daily emissions from the CalEEMod for the different construction phases compared to the SCAQMD’s LST emissions thresholds. The LST emissions threshold options are for 25, 50, 100, and

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200 meter; therefore, 25 meters is the most conservative threshold distance. The Extended Stay America hotel, the nearest sensitive receptors, is located approximately 75 feet from the project site. As such, the thresholds for a receptor distance of 25 meters (approximately 82 feet), the most conservative distance, is assumed to determine construction air quality impacts. The data provided in FEIR Table 4.1-5 shows that none of the analyzed criteria air pollutants would exceed the local emissions thresholds at the nearest sensitive receptor, the Extended Stay America hotel. Therefore, a less than significant local air quality impact would occur from construction.

Reference: These Findings incorporate by reference the information and analysis included in Final EIR Section 4.1, Air Quality, and Appendix C, Air Quality/GHG Data.

5.2.1.3 Threshold AQ-4: Odors (Construction)
Less Than Significant: The project would not result in other emissions (such as those leading to odors) adversely affecting a substantial number of people.

Facts in Support of Findings: The project does not propose or require any additional land uses typically associated with emitting objectionable odors. Potential odor sources associated with the project may result from construction equipment exhaust and the application of asphalt and architectural coatings during construction activities. Standard construction requirements would minimize odor impacts from construction. The construction odor emissions would be temporary, short-term, and intermittent in nature and would cease upon completion of the respective phase of construction. Emissions of sulfurous gases, the main source of odors from construction equipment, would be extremely limited during construction. Therefore, odors associated with the project construction would be less than significant.

Reference: These Findings incorporate by reference the information and analysis included in Final EIR Section 4.1, Air Quality, and Appendix C, Air Quality/GHG Data.

Plans, Programs, and Policies
While no mitigation measures have been identified for the above-listed thresholds, the following existing plans, programs, and policies are identified in the FEIR as applicable to the project.

PPP AQ-1 The project is required to comply with applicable rules and regulations set forth by SCAQMD, including but not limited to Rules 402, 403, and 1108.

PPP AQ-2 The project is required to comply with the goals and policies related to air quality outlined in the City of Anaheim Green Element and the City of Orange Natural Resources Element.

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5.2.2 Biological Resources
Finding: The project would have less than significant direct, indirect, and cumulative impacts on the below listed threshold of significance. Accordingly, no changes or alterations to the project were required to avoid or substantially lessen any significant environmental impacts under those thresholds. The Final EIR evaluated the following impacts and found that no mitigation was required for the identified reasons

5.2.2.1 Threshold BIO-4: Native Resident or Migratory Fish or Wildlife Species
Less Than Significant: The project would not 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.

Facts in Support of Findings:

Direct Impacts: The project area is likely used as a wildlife movement corridor and provides suitable nesting, foraging, and dispersal areas primarily for highly mobile species like bats and birds, and some movement opportunities for mammals. The dense urban development surrounding the survey area restricts movement opportunities for many small and large mammals, amphibians, and reptiles. However, mesocarnivores and medium-size mammals, such as raccoons, coyotes, or bobcats, could use the access roads that border the Santa Ana River channel for movement and may use the channel as a water source when moving through the area. The Santa Ana River channel, the widest and longest uninterrupted path through the dense urban sprawl of Orange County connecting to open space areas to the north, presents a viable route of wildlife movement through the survey area. The survey area also holds value for migrating birds, protected by the Migratory Bird Treaty Act (MBTA), flying within the Pacific Flyway to their wintering grounds.

Project impacts are proposed primarily in areas adjacent to and within existing development and would only be temporary impacts that occur during construction activities in the survey area.

Existing wildlife corridors would remain in place, and their quality would increase after implementation of the project. Therefore, significant direct long -term impacts to wildlife corridors and habitat connectivity provided by the survey area are not expected to occur. While project activities may temporarily disrupt wildlife movement through the survey area, the project is not expected to have a significant impact on habitat linkage over the long term because the overall habitat quality of the existing corridors would be maintained and improved following project implementation. Therefore, impacts to wildlife corridors and habitat connectivity would be less than significant.

Indirect Impacts: Wildlife movement corridors and habitat connectivity would be impacted by many of the other indirect effects discussed in FEIR Section 4.2.4.1, for impacts to sensitive wildlife

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species. The project is required to comply with the National Pollutant Discharge Elimination System (NPDES) regulations through implementation of site design, source control, and incorporation of construction and permanent best management practices (BMPs). The project is designed to implement sustainable project elements that would transform the Santa Ana River to create a visually appealing asset and provide recreational amenities while improving the ecology of the river corridor. Therefore, indirect impacts to wildlife movement corridors and habitat connectivity during construction activities and operation of the project would be less than significant.

Reference: These Findings incorporate by reference the information and analysis included in Final EIR Section 4.2, Biological Resources, and Appendix D, Biological Resources Technical Report.

PPP BIO-1 Potential direct/indirect impacts to common and sensitive bird and raptor species will require compliance with the California Fish and Game Code Section 3503.

PPP BIO-2 The project is required to comply with the NPDES Municipal Permit and other regional permits issued by the Santa Ana Regional Water Quality Control Board regulations through implementation of site design, source control, and incorporation of construction and permanent BMPs.

PPP BIO-3 The project is required to comply with the California Building Code and all other applicable laws, rules, and regulations governing grading as required by the Cities of Anaheim and Orange.

PPP BIO-4 The project is required to comply with regulatory permit requirements under CWA Sections 404 and 401, Rivers and Harbors Act Section 408, and California Fish and Game Code Section 1602 administered by California Department of Fish and Wildlife.

5.2.3 Cultural Resources
Finding: The project would have less than significant direct, indirect, and cumulative impacts on the below listed threshold of significance. Accordingly, no changes or alterations to the project were required to avoid or substantially lessen any significant environmental impacts under those thresholds. The Final EIR evaluated the following impacts and found that no mitigation was required for the identified reasons

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5.2.3.1 Threshold CUL-1: Historical Resources
No Impact: The project would not cause a substantial adverse change in the significance of a historical resource pursuant to Section 15064.5.

Facts in Support of Findings: The project site is not designated as a historic resource nor is the site proposed as a historic resource. Additionally, no listed or designated historical resources are in proximity to the site.

According to the records search using the California Historic Resources Inventory System, five resources (four historic structures and one prehistoric isolate) were previously recorded within the

0.50-mile radius. One resource, the Atchison, Topeka & Santa Fe Railroad (ATS) Bridge, crosses over the project site. The ATS Bridge was evaluated in 1987 by Roger Hatheway and was determined not to possess a high degree of integrity as the original structure was replaced more than once and that it did not meet criteria for eligibility to the National Register of Historic Places (NRHP). It will also not be impacted by the project because it crosses over the project site. The site does not contain any existing structures that are 50 years old that would meet the criteria for eligibility to the California Register of Historical Resources or NRHP. Therefore, redevelopment of the project site would not impact historical resources; no impacts would occur.

Reference: T These Findings incorporate by reference the information and analysis included in Final EIR Section 4.3, Cultural Resources, and Appendix E, Cultural Memo.

5.2.3.2 Threshold CUL-2: Archaeological Resources
Less Than Significant: The project would not cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5.

Facts in Support of Findings: An archaeological field survey was conducted on July 30, 2024, to determine if cultural resources exist on the project site. The survey was completed in accordance with CEQA significance evaluation criteria. According to the Cultural Resources Survey Letter Report, included as Appendix E, no resources were recorded on the project site. There is little potential for archaeological resources to the present or disturbed by the proposed development.

Based on the records search and the results of the field survey, archaeological resources are not expected to occur on the project site.

Reference: These Findings incorporate by reference the information and analysis included in Final EIR Section 4.3, Cultural Resources, and Appendix E, Cultural Memo.

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PPP CUL-1: The project shall comply with Section 7050.5 of the California Health and Safety Code in the event of discovery or recognition of any human remains in the project site. This provision states that no further disturbance would occur until the County Coroner makes a determination of origin and disposition pursuant to California Public Resources Code, Section 5097.98.

5.2.4 Geology and Soils
Finding: The project would have less than significant direct, indirect, and cumulative impacts on the below listed threshold of significance. Accordingly, no changes or alterations to the project were required to avoid or substantially lessen any significant environmental impacts under those thresholds. The Final EIR evaluated the following impacts and found that no mitigation was required for the identified reasons

5.2.4.1 Threshold GEO-1.i: Exposure to Seismic-Related Hazards - Rupture of a Known Earthquake Fault
No Impact: The project would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault. Refer to Division of Mines and Geology Special Publication 42.

Facts in Support of Findings: The Alquist-Priolo Special Study Zone Map does not delineate any known earthquake fault on the project site. Therefore, the project would not directly or indirectly cause substantial adverse effects involving rupture of a known earthquake fault as delinea ted on the most recent Alquist-Priolo Earthquake Fault Zoning Map. No impact would occur.

Reference: These Findings incorporate by reference the information and analysis included in Final EIR Section 4.4, Geology and Soils, and Appendix F, Geotechnical Report.

5.2.4.2 Threshold GEO-1.ii: Exposure to Seismic-Related Hazards – Ground Shaking
Less Than Significant: The project would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving strong seismic ground shaking.

Facts in Support of Findings: As with all Southern California, the project site has the potential for strong seismic shaking. However, the project would not involve development of any habitable structures. Additionally, the project would be constructed using appropriate foundation methods for the planned improvements, shallow foundation s1 for impoundment structures, pump

1 A shallow foundation is a type of foundation that transfers building loads to the earth near the surface, typically at a depth less than 3 meters (or less than the width of the foundation), rather than relying on deeper soil or rock layers Shallow foundations,

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stations, retaining walls, amphitheater seating walls, drop structures, and grade control structures, and steel HP pile or cast-in-drilled-hole (CIDH) pile foundations for the bridges. During construction of proposed improvements, remedial grading consisting of the excavation and recompaction of the existing undocumented fill or loose natural materials would be required pursuant to the recommendations contained in the Preliminary Geotec hnical Evaluation (Appendix F of the FEIR) or any subsequent updates . In addition, requirements of the appropriate governing jurisdictions and applicable building codes would be considered in the design of the structures for seismic safety, such as ground shaking. Some of the a pplicable building and infrastructure regulations include the California Building Code ( CBC), American Association of State Highway and Transportation Officials Load and Resistance Factor Design Bridge Design Specifications with California Amendments, the latest versions of the California Department of Transportation Standard Plans, Seismic Desing Criteria, and Geotechnical Manual , California Public Utilities Commission’s General Orders , Rules of Practice and Procedures, Public Utiliti es Code, and the Manual on Uniform Traffic Control Devices, the City of Anaheim Municipal Code , and the City of Orange Municipal Code . Therefore, impacts from strong ground shaking would be less than significant.

Reference: These Findings incorporate by reference the information and analysis included in Final EIR Section 4.4, Geology and Soils, and Appendix F, Geotechnical Report.

5.2.4.3 Threshold GEO-1.iii: Exposure to Seismic-Related Hazards – Liquefaction
Less Than Significant: The project would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving seismic-related ground failure, including liquefaction.

Facts in Support of Findings: The project site is located in an area mapped as being potentially susceptible to liquefaction per the State of California Seismic Hazard Zones map). The project involves impoundments, storm drain diversions, embankments, retaining walls, pump stations, trails and undercrossings, trail improvements, bridges, and enhanced community amenities that require ground-disturbing activities, including but not limited to excavation, recompaction, mat and spread footing foundations, and steel H-pile or CIDH pile installation for the pedestrian bridge foundations.

Pursuant to California Code of Regulations, Section 3724, the project is required to be designed and constructed in compliance with the recommendations of the geotechnical evaluations prepared for the project, the Preliminary Geotechnical Evaluation (Appendix F of the FEIR).

including spread footings and mat foundations are proposed. Spread footings consist of concrete slabs or pads that support individual columns or walls. They are typically suitable for light to moderate loads and stable soils with adequate bearing capacity. Mat foundations, also known as raft foundations, are a type of shallow foundation that covers the entire area of the structure. They act as a single unit that supports multiple columns or walls. They are typically suitable for heavy loads and poor soils with low bearing capacity.

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The Preliminary Geotechnical Evaluation indicates that the project would require remedial grading and recompaction of the existing undocumented fill or loose natural materials for the purposes of bridge foundations. Excavation and recompaction would extend to the depth of the undocumented fill to expose firm and unyielding alluvium or to a depth that will provide 2 to 3 feet of compacted fill below the bottom of the proposed foundations, whichever is deeper. For impro vements constructed within the Santa Ana River channel, it is anticipated that the base of the improvements would extend approximately 2 feet below the potential scour depth unless the improvements are designed to prevent scour. If the remedial grading bottom is unstable under heavy equipment loads, additional excavation would be provided as needed to stabilize the bottom. Recompaction of materials would increase the stability of existing soil and reduce susceptibility to liquefaction. The Preliminary Geotechnical Evaluation also recommended that the removal and recompaction work include scarifying, moisture-conditioning, and compacting the exposed subgrade soils to a depth of 8 inches or more, and placing the excavated materials back as compacted fill. Trenches and excavations would be designed and constructed in accordance with the Occupational Safety and Health Administration (OSHA) regulations that provide shoring design parameters for excavations and trenches up to 20 feet deep based on the soil types encountered. Although not anticipated, if trenches over 20 feet deep are needed, they would be designed by the contractor’s engineer based on site-specific geotechnical analyses. The project would be designed in accordance with structural considerations and recommendations contained in the Preliminary Geotechnical Evaluation.

The Preliminary Geological Evaluation determined that the project is feasible from a geotechnical perspective. In addition, the project is required to adhere to the requirements of the appropriate governing jurisdictions and applicable building codes, including geologic stability for liquefaction.

Some of the a pplicable building and infrastructure regulations include the CBC, American Association of State Highway and Transportation Officials Load and Resistance Factor Design Bridge Design Specifications with California Amendments, the latest versions of the California Department of Transportation Standard Plans, Seismic Desing Criteria, and Geotechnical Manual , California Public Utilities Commission’s General Orders , Rules of Practice and Procedures, Public Utilities Code, and the Manual on Uniform T raffic Control Devices, the City of Anaheim Municipal Code, and the City of Orange Municipal Code . Therefore, impacts from liquefaction would be less than significant.

Reference: These Findings incorporate by reference the information and analysis included in Final EIR Section 4.4, Geology and Soils, and Appendix F, Geotechnical Report.

5.2.4.4 Threshold GEO-1.iv: Exposure to Seismic-Related Hazards – Landslide
No Impact: The Preliminary Geotechnical Evaluation (Appendix F) concluded that the project site is not located in an area considered susceptible to landsliding. The project site is not identified as being within

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high landslide susceptibility areas mapped by the California Geological Survey with Deep Seated Landslide Potential (Anaheim 2022, Orange 2022). Therefore, no impacts from landslide would occur.

Facts in Support of Findings: Construction activities would result in the temporary generation of air pollutants from operation of heavy cons
Reference: These Findings incorporate by reference the information and analysis included in Final EIR Section 4.4, Geology and Soils, and Appendix F, Geotechnical Report.

5.2.4.5 Threshold GEO-2: Soil Erosion or Topsoil Loss
Less Than Significant: The project would not result in substantial soil erosion or the loss of topsoil.

Facts in Support of Findings:

Construction-Related Erosion: Various project-related improvements would result in ground- disturbing activities during construction, exposing soils and potentially result in in the loss of topsoil.

The project involves more than one-acre of ground-disturbing activities within and adjacent to Santa Ana River, riverbed, and embankments on both sides of the river. However, the project is required to comply with the NPDES permit from the State Water Resources Control Board, including submittal of a Notice of Intent and preparation of a Storm Water Pollution Prevention Plan (SWPPP), which will specify BMPs to minimize stormwater pollution from project construction, including erosion and sediment. The project construction contractor would implement the specified BMPs to manage erosion, fugitive dust, and stormwater related issues. With implementation of standard construction BMPs in accordance with a SWPPP, the project’s construction would result in less than significant impacts related to soil erosion and loss of topsoil. Additionally, the project would comply with the City of Anaheim General Plan Green Element Policies 7.1-1 and 7.1-2, and the City of Orange Natural Resources Element Policies 2.13 through 2.15 to reduce erosion, siltation, and other run-off impacts.

With these mandatory BMPs, construction-related stormwater impacts would be less than significant.

Operational Impacts: According to the Preliminary Geotechnical Evaluation (Appendix F of the FEIR), soils on the project site and surrounding area vary in susceptibility to water erosion. This is due to the variation in soil stratigraphy, and site-specific borings would be required to prior to grading activities. Following construction, the project site would consist of paved and landscaped areas. As identified in the Preliminary Geotechnical Evaluation, the project s ite is located within a “Zone A” designated flood area (FEMA 2009). Specifically, the lower terrace path, and portions of the middle terrace path and amphitheater seating are planned at elevations that are lower than the 100-year flood level. Soil and topsoil located in these areas of the project site may be lost in severe

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storms or 100-year flood events. The project also includes components that aim to reduce runoff and maintain water quality during operation.

During dry weather operation, the impoundment water levels would be maintained using groundwater replenishment system (GWRS) water supplied by OCWD. To address impoundment water quality concerns, dry weather nuisance flows in all adjacent tributary storm drain lines would be captured/diverted by gravity. These nuisance flows would be pumped to Orange County Sanitation District sewer lines and treatment facilities, with a few storm drain lines on the east side of the project discharged to the river channel downstream of the lower impoundment. This would minimize the possibility of any dry weather flows reaching the impoundments and mixing with GWRS water. In this operational condition, the impoundments would be filled to within 6 to 12 inches of the impoundment overflow elevation and maintained with the ability to bypass a portion of the water through a bypass structure containing a modulating weir so water levels and discharge flow can be controlled.

A low flow event is defined as a precipitation event that produces expected flow volumes at the project site of less than 200 acre-feet (the volume of water retained by the two impoundments).

During a rain event, the dry weather nuisance diversion systems are turned off, allowing flow from the tributaries to enter the river. Flows to the project site would consist of a combination of flows from the surrounding tributaries and from Prado Dam releases. Generally, in low flow conditions the GWRS water supply to the impoundments would be halted, and the GWRS water would be allowed to infiltrate or may be pumped to Burris Basin. Santa Ana River flows, either tributary or from Prado Dam, would fill the impoundments up to the 200-acre-foot capacity. In any event where flows over the rubber dam reach a 6-inch nappe (approximately 320 cubic feet per second [cfs]), the inflatable dams would be deflated.

High flow events are defined as events where the flows reaching the project site, which include tributary runoff and flows from Prado Dam, are 200 acre-feet or greater. In these conditions, both impoundments would be evacuated, and the rubber dams would be deflated to allow complete storm conveyance in the Santa Ana River channel. For this operation, GWRS inflows to the impoundments would be halted and allowed to fully infiltrate, which takes approximately 10 days, or the GWRS water would be drained and pumped to Burris Basin, which is anticipated to take approximately 3 days. The impoundments would then be fully deflated to maintain peak flood capacity of the Santa Ana River channel. In the later parts of the storm, the rubber dams would be reinflated with the intent of capturing the full operation volume, or 200 acre-feet, in both impoundments. During any event, regardless of expected volume, when the flow exceeds 320 cfs (6- inch nappe) over the dams, they would automatically deflate as a safety mechanism to prevent damage. There would be no changes to other segments of the Santa Ana River. Therefore, the impoundments would not result in additional erosion or siltation impact compared to the existing conditions.

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The existing levee embankment within the project site consists of riprap-lined riverbank. The riverbank protection is comprised of loose and grouted riprap at a 2(H):1(V) slope. The project would modify the existing riprap with soil cement bank protection, reinforced concrete terraces and steps and new riprap, therefore, no erosion and siltation would occur during operation. Also, once constructed, surface drainage in the project site would primarily remain the same, with the river trails and surrounding areas draining to the Santa Ana River. The trail and trail improvement design would include various impervious surface materials and landscaping, and there would be no exposed soils with risk of substantial soil erosion or siltation. Additionally, a water quality management plan (WQMP) will be developed to address the required water quality components of the project elements.

The project would be designed to comply with the North Orange County technical Guidance Document and Model WQMP to achieve MS4 permit compliance.

Therefore, operational impacts related to substantial soil erosion or loss of topsoil would be less than significant.

Reference: These Findings incorporate by reference the information and analysis included in Final EIR Section 4.4, Geology and Soils, and Appendix F, Geotechnical Report.

5.2.4.6 Threshold GEO-3: Geologic Stability
Less Than Significant: The project would not 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.

Facts in Support of Findings:

Lateral Spreading. The project site is located within the free-faces of the Santa Ana River; therefore, there is a potential for seismically induced lateral spread. Lateral spreading is directly associated with areas of liquefaction, which is discussed in Threshold GEO -1.iv. As discussed under Threshold GEO-1.iv, similar to impacts from liquefaction, impacts from lateral spreading would be reduced to a less than significant level with the required compliance with the recommendations contained in the Preliminary Geotechnical Evaluation and requirements of the appropriate governing jurisdictions and applicable building codes that would be considered during the structural design and construction of the project. Impacts would be less than significant.

Subsidence: The City of Anaheim Local Hazard Mitigation Plan (2022) and the City of Orange Local Hazard Mitigation Plan (2016) do not identify subsidence as a hazard of concern for either city.

Additionally, the project would be designed and constructed by adhering to the site-specific recommendations contained in the Preliminary Geotechnical Evaluation and requirements of the appropriate governing jurisdictions and applicable building codes that would be considered during the structural design and construction of the project. Therefore, impacts from subsidence would be less than significant.

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Slope Stability: The project involves embankment improvements that required a slope stability analysis to evaluate the stability of the proposed embankment slopes based on the north impoundment area. The slope stability evaluation determined that while the proposed embankment slopes with a slope ratio of 2:1 (horizontal to vertical) would have adequate slope stability, the embankment slopes placed at a slope ratio of 1.5:1 (horizontal to vertical) may not result in adequate slope stability under certain scenarios. The slope stability analysis indicated that by removing the outer portion of the slope and replacing with a stabilization fill slope with an approximately 15-foot- wide soil cement zone, the slope stability safety level would increase to adequate levels. The project would be designed and constructed in compliance with the CBC standards and recommendations contained in the Geotech investigation to be reviewed and approved by the applicable governing entities. (PPP GEO-1). Therefore, the project would not be impacted by slope instability to result in adverse environmental impacts.

Reference: These Findings incorporate by reference the information and analysis included in Final EIR Section 4.4, Geology and Soils, and Appendix F, Geotechnical Report.

5.2.4.7 Threshold GEO-4: Expansive Soils
Less Than Significant: The project would not be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property.

Facts in Support of Findings: The project site’s expansion index has not been tested. However, the Preliminary Geotechnical Evaluation (Appendix F to FEIR) included results from previous geotechnical evaluations in the nearby area, which identified an expansion index of “0.” Also, the Preliminary Geotechnical Evaluation concluded that the on-site soils are generally suitable for use as embankment fill and trench backfill as long as they are free of trash, debris, roots, vegetation, deleterious materials, and contamination. Therefore, it is anticipated that expansion potential for on-site soils is minimal, and impacts would be less than significant.

Reference: These Findings incorporate by reference the information and analysis included in Final EIR Section 4.4, Geology and Soils, and Appendix F, Geotechnical Report.

PPP GEO-1 The project will be designed and constructed in accordance with the California Building Code (CBC) adopted by the City of Anaheim and the City of Orange. The project shall comply with applicable development standards and ordinances and by the most recent building and seismic codes in effect at the time of project design for the respective cities. In accordance with Section 1803.2 of the CBC, a

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geotechnical investigation is required that must evaluate soil classification, slope stability, soil strength, position and adequacy of load-bearing soils, the effect of moisture variation on soil-bearing capacity, compressibility, liquefaction, and expansiveness, as determined by the applicable approval authority. The geotechnical investigation must be prepared by registered professionals (i.e., California Registered Civil Engineer or Certified Engineering Geologist).

Recommendations of the report pertaining to structural design and construction recommendations for earthwork, grading, slopes, foundations, pavements, and other necessary geologic and seismic considerations must be incorporated into the design and construction of the project.

PPP GEO-2 The project will be designed and constructed by incorporating recommendations contained in the Preliminary Geotechnical Evaluation prepared by Ninyo & Moore dated October 11, 2024 (Appendix F to the Draft Environmental Impact Report) and any subsequent updates prepared for the project to implement PPP GEO-1. In addition to the specific earthwork-, foundations-, retaining walls, pavement-, trails-, corrosivity-, concrete placement-, and drainage-related recommendations, the Preliminary Geotechnical Evaluation also contains the following construction monitoring programs to monitor ground vibrations, ground surface settlement, and lateral movement of shoring support systems. These monitoring programs will be in-place and conducted prior to the start of construction and the resulting data will be reviewed and evaluated during construction and be shown on all grading and building plans.

Documentation of Existing Conditions. Conduct pre-construction condition surveys on structures and railroad crossings within approximately 50 feet of the proposed excavations prior to construction. This distance will be extended to 100 feet adjacent to proposed excavations if driven and vibratory sheet or soldier piles are installed. This survey will include locating existing cracks and measuring widths of cracks, in combination with video documentation of existing conditions.

Interviews will be conducted with utility owners so that existing knowledge about the age, type, and maintenance history of affected utilities is available prior to construction.

Construction Vibrations. Monitor the vibration by using seismographs in the early stages. Seismographs will be located near structures and improvements next to the construction activities. Additional seismographs will be located at various structures and improvements farther from the construction activities to monitor vibrations as a function of distance from the sites. Periodic vibration monitoring will be conducted during other construction activities. After review of the data obtained, reduce the number of seismographs at the discretion of the governing/approval agencies/entities and the qualified geotechnical consultant.

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Ground Surface Settlement. Install arrays of ground surface settlement points around the proposed excavations. The construction contractor will submit a monitoring plan showing the proposed locations of settlement points for review and approval by the Project Engineer. The construction contractor will be responsible for maintaining total settlement at any survey point to less than 0.5 inch. If the settlement reaches this limit, further review of construction methodologies be performed and appropriate changes be made.

Lateral Movement for Shoring Support System. Install inclinometers or establish survey points behind excavations next to existing slopes. The inclinometers or survey points will be monitored and evaluated daily during excavation activities to provide an advanced warning system of potential problems. The shoring system will be designed to limit the ground settlement behind the shoring system to 0.5 inch or less to reduce the potential for distress to adjacent structures/improvements. If settlements reach 0.25 inch, a review of the construction contractor’s methods will be performed and appropriate changes be made, if needed.

Groundwater Monitoring. If construction dewatering is performed, the construction contractor will install groundwater monitoring wells to monitor water levels outside the excavations. The monitoring wells will be installed at locations that will be accessible during construction. The groundwater levels will be monitored daily during dewatering as appropriate.

PPP GEO-3 All bridges shall be designed and constructed in accordance with the latest edition of the American Association of State Highway and Transportation Officials Load and Resistance Factor Design Bridge Design Specifications with California Amendments, the latest versions of the California Department of Transportation Standard Plans, Seismic Desing Criteria, and Geotechnical Manual, as required for various elements of the project, as determined by the applicable approval authority.

PPP HYD-1 The project is required to be developed in compliance with the following state, regional, and local regulations concerning grading, stormwater, and water quality control, as determined by the applicable approval authority:
• National Pollutant Discharge Elimination System General Construction Permit:

Notice of Intent and Storm Water Pollution Prevention Plan Requirements • State Water Resources Control Board General Industrial Activities Storm Water Permit
• Santa Ana Regional Water Quality Control Board Waste Discharge Permits and Water Quality Certifications
• Orange County Grading Manual

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• Orange County Grading and Excavation Code
• Orange County Municipal Separate Storm Sewer Systems Permit • Orange County Model Water Quality Management Plan and Technical Guidance Document
• Orange County Drainage Area Management Plan: New Development/ Significant Redevelopment Program
• Orange County Hydrology Manual and 1996 Addendum
• Orange County Water District Groundwater Replenishment Program • Orange County Flood Control District Local Implementation Plan 2019 • City of Anaheim and City of Orange Municipal Codes
• City of Anaheim Grading Design Manual
• Anaheim Master Plan of Drainages North and West Santa Ana Tributaries • American Association of State Highway and Transportation Officials Load and Resistance Factor Design Bridge Design Specifications with California Amendments
• California Department of Transportation Standard Plans • California Department of Transportation Seismic Desing Criteria • California Department of Transportation Geotechnical Manual

5.2.5 Greenhouse Gas Emissions
Finding: The project would have less than significant direct, indirect, and cumulative impacts on the below listed threshold of significance. Accordingly, no changes or alterations to the project were required to avoid or substantially lessen any significant environmental impacts under those thresholds. The Final EIR evaluated the following impacts and found that no mitigation was required for the identified reasons

5.2.5.1 Threshold GHG-1: Generation of Greenhouse Gas Emissions (Construction)
Less Than Significant: The project would not generate greenhouse gas emissions during construction, either directly or indirectly, that may have a significant impact on the environment.

Facts in Support of Findings: The significance of project GHG emissions is determined based on the SCAQMD screening threshold of 3,000 Metric tons of carbon dioxide equivalent (MTCO2e) per year for non-industrial uses. Project GHG emissions are quantified for the construction effort and amortized over a 30-year project lifetime. Project construction would result in GHG emissions from use of fossil fuels for construction equipment, haul trucks, and worker vehicle trips. Construction emissions were modeled for the project using CalEEMod Version 2022.1.1.29 based on assumptions consistent with the air quality modeling outlined in FEIR Section 4.1, Air Quality. Refer to Appendix C, Air Quality/GHG Data, of the FEIR for detailed modeling input and output.

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Project construction is anticipated to require approximately 24 to 36 months. Based on the 24 - month construction schedule assumed for the air quality analysis, project construction is calculated to result in total emissions of 3,862 MTCO2e. The 24-month construction schedule is conservative for the air quality analysis because the applicable thresholds are concerned with maximum daily emissions. The reduced construction schedule assumes more intense daily construction activity to complete the same total construction effort in less time. However, for GHG emissions, the longer three-year construction schedule is more conservative because it assumes an additional year of equipment operation and worker vehicle trips. To estimate GHG emissions for a 36 -month schedule, the worst-case GHG emissions in a single year modeled for the air quality analysis (2,380 MTCO2e) are added to the total emissions for the 24-month construction schedule (3,862 MTCO2e).

Total construction emissions from project construction over 36 months would be approximately 6,242 MTCO2e. Therefore, amortized construction emissions would be 208 MTCO2e over a 30 -year period. As stated in Section 4.9, Transportation, during operation, the project would provide new active transportation facilities (new pedestrian/bicycle bridges and trails) and would not lead to a substantial or measurable increase in vehicle travel. As such, amortized construction emissions represent the project’s ongoing GHG emissions for comparison to the SCAQMD screening threshold. The project would result in amortized construction emissions of 208 MTCO2e and would not exceed the SCAQMD threshold of 3,000 MTCO2e per year for non -industrial uses. The project would not generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment.

Reference: These Findings incorporate by reference the information and analysis included in Final EIR Section 4.5, Greenhouse Gas Emissions, Section 4.9, Transportation, and Appendix C, Air Quality/GHG Data.

5.2.6 Hazards and Hazardous Materials
Finding: The project would have less than significant direct, indirect, and cumulative impacts on the below listed threshold of significance. Accordingly, no changes or alterations to the project were required to avoid or substantially lessen any significant environmental impacts under those thresholds. The Final EIR evaluated the following impacts and found that no mitigation was required for the identified reasons.

5.2.6.1 Threshold HAZ-2: Accidental Releases
Less Than Significant: The project would not create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment.

Facts in Support of Findings:

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Construction: Construction of the project would temporarily increase the transport, use, and disposal of construction-related hazardous materials that can come in the forms of gases, vapors, fumes, dusts, and mists, including but not limited to diesel fuel, lubricants, paints and solvents, silica dust from concrete, block, and mortar, and cleaning fluids. These materials are commonly used at construction sites, and construction activities would be required to comply with applicable state and federal regulations for proper transport, use, storage, and disposal of excess hazardous materials and hazardous construction waste. Therefore, the project is not anticipated to create a significant hazard to the public or the environment through reasonably foreseeable up set and accident conditions involving the release of hazardous materials into the environment.

Furthermore, in the event that hazardous waste is discovered during construction phase, the project is required to comply with the California Hazardous Substances Control Law (Health and Safety Code, Division 20, Chapter 6.5) and the California Code of Regulations, Title 22, Division 4.5 to properly identify, handle, and dispose hazardous waste or hazardous materials so that any accidental releases of hazardous materials into the environment is minimized. Therefore, implementation of the project would not create a significant hazard to the public or the environment, and impacts would be less than significant.

Operation: The project includes development of various improvements that will work to re- establish and activate the existing river corridor and transform and improve the river and riverbed’s groundwater recharge potential in multiple phases over approximately 10 years.

Considering the type of uses proposed for the OC River Walk project, which includes various components related to impoundments for additional groundwater recharge, pedestrian/bike bridges, new trails and existing trail improvements, and enhanced recreational, environmental, and educational amenities, none of the proposed improvements involve the use of hazardous materials. While some use of pesticides and herbicides for landscaping maintenance and cleaning products could occur, these uses are not anticipated to be associated with major hazardous materials and would not create unusually high quantities of hazardous waste that could potentially result in foreseeable upset and accident conditions involving the release of hazardous materials into the environment. Furthermore, any uses of hazardous materials during operation of the project would be required to comply with existing regulations. Therefore, impacts would be less than significant.

Reference: These Findings incorporate by reference the information and analysis included in Final EIR Section 4.6, Hazards and Hazardous Materials.

5.2.6.2 Threshold HAZ-4: Hazardous Materials Sites
Less Than Significant: The project would not 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.

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Facts in Support of Findings: Five environmental lists were searched for hazardous materials sites on the project site and within a 500-foot radius as below and the project site is not listed as hazardous materials sites:
• GeoTracker: State Water Resources Control Board (SWRCB 2024) • EnviroStor: Department of Toxic Substances Control (DTSC 2024) • EJScreen: U.S. Environmental Protection Agency (USEPA 2024a) • EnviroMapper: U.S. Environmental Protection Agency (USEPA 2024b) • Solid Waste Information System (SWIS): California Department of Resources Recovery and Recycling (CalRecycle 2024)
Although some of the properties immediately adjacent to the project site were included on a list of hazardous materials sites, they obtained “closed” status that require no further remediation or were undergoing remediation pursuant to the California Hazard ous Substances Control Law (Health and Safety Code, Division 20, Chapter 6.5) and according to the requirements of the California Administrative Code, Title 30, Chapter 22. Therefore, the project would not be located on a hazardous materials site and would not create a significant hazard to the public or the environment.

Reference: These Findings incorporate by reference the information and analysis included in Final EIR Section 4.6, Hazards and Hazardous Materials.

PPP HAZ-1 Any project-related hazardous materials and hazardous wastes will be transported to or from the project site in compliance with applicable state and federal requirements, including the U.S. Department of Transportation regulations listed in the Code of Federal Regulations (Title 49, Hazardous Materials Transportation Act); California Department of Transportation standards; and the California Occupational Safety and Health Administration standards.

PPP HAZ-2 Any project-related hazardous waste generation, transportation, treatment, storage, and disposal will be conducted in compliance with the Subtitle C of the Resource Conservation and Recovery Act (Code of Federal Regulations, Title 40, Part 263), which establishes the responsibilities of generators and transporters of hazardous waste in the handling, transportation, and management of that waste.

PPP HAZ-3 Project construction will occur in accordance with the regulations of the Orange County Health Care Agency, Environmental Health Department (OCHCA-EHD), which serves as the designated Certified Unified Program Agency (CUPA). The project will be designed and constructed in accordance with the regulations of the

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OCHCA-EHD, which, as the designated CUPA, implements state and federal regulations for the following programs: (1) Hazardous Waste Generator Program, (2) Hazardous Materials Release Response Plans and Inventory Program, (3) California Accidental Release Prevention, (4) Aboveground Storage Tank Program, and (5) Underground Storage Tank Program.

5.2.7 Hydrology and Water Quality
Finding: The project would have less than significant direct, indirect, and cumulative impacts on the below listed threshold of significance. Accordingly, no changes or alterations to the project were required to avoid or substantially lessen any significant environmental impacts under those thresholds. The Final EIR evaluated the following impacts and found that no mitigation was required for the identified reasons.

5.2.7.1 Threshold HYD-3a: Site Drainage and Hydrology (Erosion and Siltation).

Less Than Significant: The project would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would not result in substantial erosion or siltation on- or off-site.

Facts in Support of Findings:

Construction: Construction of the project could result in soil erosion due to earthmoving activities such as excavation, grading, soil compaction and moving, soil stockpiling, and slope modification.

The Construction General Permit requires preparation and implementation of a SWPPP for projects that involves construction or demolition activity, including but not limited to, clearing, grading, grubbing, or excavation, or any other activity that results in a land disturbance of equal t o or greater than one acre. The project involves more than one acre of ground disturbance for the trail improvements and additional riverbed and embankment areas. The project SWPPP will provide construction BMPs to reduce erosion, siltation, and other runoff-related impacts resulting from construction. Additionally, the project would comply with the City of Anaheim General Plan Green Element Policies 7.1-1 and 7.1-2, and the City of Orange Natural Resources Element Policies 2.13 through 2.15 to reduce erosion, siltation, and other run-off impacts. With these mandatory BMPs, construction-related stormwater impacts would be less than significant.

Operation: Operational procedures of the impoundments are built on extensive analysis of the Santa Ana River hydrology and Prado Dam release procedures. The goals are effective utilization of GWRS supply through increased groundwater recharge, channel flood conveyanc e capacity, and water quality of the impoundments. Three operational conditions are defined: dry weather operation, low river flow operation, and high river flow operation.

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During dry weather operation, the impoundment water levels would be maintained using GWRS water supplied by OCWD. To address impoundment water quality concerns, dry weather nuisance flows in all adjacent tributary storm drain lines would be captured/divert ed by gravity. These nuisance flows would be pumped to Orange County Sanitation District sewer lines and treatment facilities, with a few storm drain lines on the east side of the project discharged to the river channel downstream of the lower impoundment. This would minimize the possibility of any dry weather flows reaching the impoundments and mixing with GWRS water. In this operational condition, the impoundments would be filled to within 6 to 12 inches of the impoundment overflow elevation and maintained, with the ability to bypass a portion of the water through a bypass structure containing a modulating weir so water levels and discharge flow can be controlled.

A low flow event is defined as a precipitation event that produces expected flow volumes at the project site of less than 200 acre-feet (the volume of water retained by the two impoundments).

Generally, in low flow conditions the GWRS water supply to the impoundments would be halted, and the GWRS water would be allowed to infiltrate or may be pumped to Burris Basin, an off -river basin operated by OCWD. Santa Ana River flows, either tributary or from Prado Dam, would fill the impoundments up to the 200-acre-foot capacity. In any event where flows over the rubber dam reach a 6-inch nappe (approximately 320 cfs), the inflatable dams would be deflated. It is anticipated that clogging materials from the river impoundments would be scoured during a high - flow storm event when the dams are deflated, or would be removed manually using bulldozers after the wet season, so that GWRS water can be placed into the impoundments after the captured stormwater has percolated or passed through.

High flow events are defined as events where the flows reaching the project site, which include tributary runoff and flows from Prado Dam, are 200 acre-feet or greater. In these conditions, both impoundments would be evacuated, and the rubber dams would be deflated to allow complete storm conveyance in the Santa Ana River channel. For this operation, GWRS inflows to the impoundments would be halted and allowed to fully infiltrate, which takes approximately 10 days, or the GWRS water would be drained and pumped to Burris Basin, which is anticipated to take approximately 3 days. The impoundments would then be fully deflated to maintain peak flood capacity of the Santa Ana River channel. In the later parts of the storm, the rubber dams would be reinflated with the intent of capturing the full operation volume, or 200 acre-feet, in both impoundments. During any event, regardless of expected volume, when the flow exceeds 320 cfs (6-inch nappe) over the dams, they would automatically deflate as a safety mechanism t o prevent damage. There would be no changes to other segments of the Santa Ana River. Therefore, the impoundments would not result in additional erosion or siltation impact compared to the existing conditions.

There is an inflatable dam located in Collins Channel where it meets the SAR. This inflatable dam prevents GWRS water from backing up into Collins Channel and prevents dry weather runoff from

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Collins Channel from entering the impoundments. The crest of the Collins Channel inflatable dam will be at the same elevation as the north SAR dam.

The Collins Channel dam would be operated in conjunction with the proposed impoundments and would be raised and lowered to facilitate various operating conditions. During dry weather, with the Collins Channel dam inflated, a pump station would pump flow in Collins Channel to the SAR downstream of the proposed impoundments. During storm events, the Collins Channel dam would be lowered in conjunction with the proposed rubber dams. The operation of the Collins Channel dam would maintain the flow pattern of the Collins Channel, and would not impact existing Collins Channel drainage capacity.

The existing levee embankment within the project site consists of riprap-lined riverbank. The riverbank protection is comprised of loose and grouted riprap at a 2(H):1(V) slope. The project would modify the existing riprap with soil cement bank protection, reinforced concrete terraces and steps and new riprap, therefore, no erosion and siltation would occur during operation. Also, once constructed, surface drainage in the project site would primarily remain the same, with the river trails and surrounding areas draining to the Santa Ana River. The trail and trail improvement design would include various impervious surface materials and landscaping, and there would be no exposed soils with risk of substantial soil erosion or siltation. Impacts would be less th an significant.

Reference: These Findings incorporate by reference the information and analysis included in Final EIR Section 4.7, Hydrology and Water Quality, and Updated Hydrology and Hydraulics Appendix to OC River Walk EIR dated September 2025 (Appendix A to Final EIR/Response to Comments) .

5.2.7.2 Thresholds HYD-3b and 3d: Site Drainage and Hydrology (Flooding and Flood Flows).

Less Than Significant: The project would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would not substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or offsite.

Facts in Support of Findings:

Hydraulic Impacts
Depth and Velocity: The project is designed using the USACE 190-year event flowrate, 40,000 cfs to 41,000 cfs. Under the existing condition HEC-RAS model, flow depths for the design discharge (Q190 = 40,000 to 41,000 cfs) ranged from 11.2 to 17.6 feet, and channel velocity ra nged from 7.6 to

11.5 feet per second. Under the proposed condition HEC-RAS model, flow depths for the design discharge ranged from 11.2 to 17.7 feet, and channel velocity for the design event ranged from 7.6

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to 11.7 feet per second. The change in depth as a result of the project shows a maximum increase of 0.5 ft, and in some areas a decrease in depth up to 0.2 ft. The changes to depth are generally upstream of the two proposed pedestrian bridges. The changes to velocity as a result of the proposed project include increases up to 0.6 feet per second (fps) and decreases up to 0.9 fps. The decreases are generally located around the proposed pedestrian bridges, where the addition of piers within the main channel slow down the flow, decreasing velocity. The maximum increase in velocity is localized to the proposed Meadow Park, which includes a small change in the bank alignment that slightly decreases flow area, therefore increasing velocity. As such, only negligibl e increases in channel depth and velocity would occur with implementation of the project, and impacts would be less than significant.

Freeboard: The Santa Ana River is designated as a levee which has minimum freeboard requirements. The freeboard analysis shows there is generally sufficient freeboard (a minimum of

2.5 feet) in the existing condition, with some deficiencies located just upstream of the SR -57 Freeway bridge, Metrolink/LOSSAN Corridor Bridge, and Katella Avenue Bridge, a nd around the crest of the downstream drop structure. In the proposed condition, the amount of freeboard gained or lost is directly related to the change in water surface elevation (refer to Appendix E of the Hydrology Report included as Appendix G to the FEIR). The project is intended to fix any deficiencies in freeboard in the existing condition by raising the top of bank to meet the freeboard requirement specified in the USACE General Design Memorandum. The project design would be reviewed and permitted by USACE and the OCFCD through the 408 permitting process. Freeboard would improve as a result of the project and impacts would be less than significant.

Scour: As discussed in the above depth and velocity discussion, changes in velocity are minimal, which mean changes in scour depth are also minimal. There are no anticipated changes to channel scour depth as a result of the proposed embankment improvements. Therefore, hydraulic impacts pertaining to scouring would be less than significant.

Hydrologic Impacts
Hydrologic changes are related to the ground cover on the project site. The project would change 26,400 linear feet of grouted/un-grouted riprap to soil cement and riprap. This may result in a small increase to impervious area on the project site. However, in the perspective of the lower Santa Ana River watershed, this is a negligible increase. The lower Santa Ana River watershed covers an approximately 200 square mile area, while the change in pervious area is less than 0.01 square mile. There would be no significant impacts to the Santa Ana River hydrology as a result of the proposed bank modifications.

Dam Deflation
The inflatable dams would be managed to accommodate projected storm events that would cause large flows through the project site. Any necessary evacuation of the impoundments is expected to occur

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through infiltration within 10 days, however, the hydraulics of a sudden deflation and resultant release of impounded water were investigated. Approximately 9,500 feet downstream of the south impoundment is the Riverview Golf Course. This 18-hole golf course is located within the Santa Ana River floodplain, with the Santa Ana River running directly through the fairway. Potential impacts to the Riverview Golf Course and downstream areas were analyzed considering an emergency deflation of the dams holding full impoundment volumes. Three deflation scenarios were modeled using a HEC-RAS model:
• North Impoundment deflation: Scenario where only the filled north impoundment is deflated.
• South Impoundment deflation: Scenario where only the filled south impoundment is deflated.
• Simultaneous North and South Impoundment Deflation: Scenario where both the north and south impoundments are deflated concurrently.

The HEC-RAS modeling determined that the Riverview Golf Course would not be negatively impacted by dam deflation from the project implementation. The modeling results indicated that the maximum profile for all three deflation scenarios have lower water surface elevations than the 2-year steady state event. This indicates that the dam deflation scenario has smaller impacts than a 2-year storm event. Therefore, the worst-case dam deflation scenario associated with the proposed impoundments would not result in adverse flooding impacts to the downstream Riverview Golf Course.

The project would not substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site, or impede or redirect flood flows to result in adverse hydrology or hydraulics impacts. Impacts would be less than significant.

5.2.7.3 Threshold HYD-3c: Site Drainage and Hydrology (Drainage Capacity).

Less Than Significant: The project would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would 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.

Facts in Support of Findings: According to the Hydrology and Hydraulics prepared by PACE (PACE 2025), surface drainage on the project site would primarily remain the same, with the river trails and surrounding areas draining to the Santa Ana River. Therefore, new impoundments would not create or contribute runoff water which would exceed the capacity of existing or planned

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stormwater drainage system. As required by MS4, a WQMP will be developed to address the required water quality components of the project elements. It is anticipated that BMPs will be implemented as required following the Orange County Model WQMP and T echnical Guidance Document, as appropriate. The stormwater runoff would be required to be managed following the low impact development (LID) BMPs contained in the WQMP to ensure that post-development runoff volume, time of concentration, and velocity do not adversely impact existing drainage facilities and downstream water bodies. Impacts would be less than significant.

5.2.7.4 Threshold HYD-4: Flood Hazard or Seiche
Less Than Significant: The project would not result in flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation.

Facts in Support of Findings:

Flood Hazard: Although the project site is within a floodplain, because the impoundments are for groundwater recharge, the released water to downstream during storm events would not be at risk of pollutants release during inundation. Impacts would be less than significant.

Seiches: A seiche is a surface wave created when an inland water body is shaken, usually by an earthquake or due to a change in atmospheric pressure. Inland water bodies such as the Santa Ana River, including two water impoundments to be created by the project, and the Burris Basin could generate seiches. However, as discussed above under Section 4.7.4.3 Threshold HYD-3b and HYD- 3d: Site Drainage and Hydrology (Flooding and Flood Flows), the impoundment structures would be lowered automatically during large storm events or other desired events, and flooding impact is not anticipated during the worst impoundment deflation scenario. Furthermore, a WQMP will be developed to address the required water quality components of the project elements and implementation of appropriate low impact development BMPs would ensure that the project would not result in substantial risk related to the release of pollutants due to inundation from a seiche.

Impacts would be less than significant.

5.2.7.5 Threshold HYD-5: Water Quality Control Plan.

Less Than Significant: The project would not conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan.

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Facts in Support of Findings:

The project would create semi-permanent water bodies in the Santa Ana River for groundwater recharge through installation of three inflatable rubber dams creating two water impoundments.

The recharge water would be of sufficient high quality that it satisfies the water quality objectives in the RWQCB’s Water Quality Control Plan for the Orange County Management Zone and the surface water bodies. GWRS water from OCWD would be dechlorinated prior to being discharged into the Santa Ana River. Further chemical addition prior to discharge is anticipated for concrete corrosion control (e.g. calcium chloride addition) and algae control (e.g. alum addition). It is assumed that the water quality of Collins Channel would be on par with other dry-weather flows, and percolation from Collins Channel was not taken into account due to its narrow width. The construction of the project would be conducted in accordance with all applicable local, state, and federal regulations that relate to water quality, ensuring that construction impacts to water quality and the Groundwater Management Plan would be less than significant.

Construction activities impacting jurisdictional waters or wetlands are subject to a permit Sections 401 and 404 of the Clean Water Act. Adherence to these regulatory requirements would ensure that surface and groundwater quality are not adversely impacted during construction and operation of development pursuant to the project. Other project components such as pump station, pedestrian and bike bridges, trails and trail improvements, and enhanced community amenities would be required to implement the requirements of the Construction General Plan, the Orange County MS4 Permit, and compliance with Section 10.09 of the City of Anaheim Municipal Code and Chapter 7.01 (Water Quality and Stormwater Discharges) of the City of Orange Municipal Code during construction to ensure that they do not conflict with a water quality control plan or sustainable groundwater management plan. After project completion, these uses would not involve activities that would adversely impact water quality. The Santa Ana RWQCB also does n ot list any impaired water bodies within the Reach 2 of the Santa Ana River. Therefore, the project would not obstruct or conflict with the implementation of the Santa Ana River Basin Water Quality Control Plan, the Groundwater Management Plan, nor the Basin 8-1 Alternative Plan. Impacts would be less than significant.

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PPP HYD-1 The project is required to be developed in compliance with the following state, regional, and local regulations concerning grading, stormwater, and water quality control, as determined by the applicable approval authority:
▪ National Pollutant Discharge Elimination System General Construction Permit:

Notice of Intent and Storm Water Pollution Prevention Plan Requirements ▪ State Water Resources Control Board General Industrial Activities Storm Water Permit
▪ Santa Ana Regional Water Quality Control Board Waste Discharge Permits and Water Quality Certifications
▪ Orange County Grading Manual
▪ Orange County Grading and Excavation Code
▪ Orange County Municipal Separate Storm Sewer Systems Permit ▪ Orange County Model Water Quality Management Plan and Technical Guidance Document
▪ Orange County Drainage Area Management Plan: New
Development/Significant Redevelopment Program
▪ Orange County Hydrology Manual and 1996 Addendum
▪ Orange County Water District Groundwater Replenishment Program ▪ Orange County Flood Control District Local Implementation Plan 2019 ▪ City of Anaheim and City of Orange Municipal Codes
▪ City of Anaheim Grading Design Manual
▪ Anaheim Master Plan of Drainages North and West Santa Ana Tributaries ▪ American Association of State Highway and Transportation Officials Load and Resistance Factor Design Bridge Design Specifications with California Amendments
▪ California Department of Transportation Standard Plans ▪ California Department of Transportation Seismic Desing Criteria ▪ California Department of Transportation Geotechnical Manual PPP HYD-2 The City of Anaheim is required to obtain a Section 401 Permit from the Regional Water Quality Control Board.

PPP HYD-3 The City of Anaheim is required to obtain Section 404 and 408 Permits from the U.S.

Army Corps of Engineers.

5.2.8 Transportation
Finding: The project would have less than significant direct, indirect, and cumulative impacts on the below threshold of significance. Accordingly, no changes or alterations to the project were required to avoid or substantially lessen any significant environmental impacts under those

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thresholds. The Final EIR evaluated the following impacts and found that no mitigation was required for the identified reasons.

5.2.8.1 Threshold T-2: Induction of Substantial Vehicle Miles Traveled.

Less Than Significant: The project would not conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b).

Facts in Support of Findings: The project elements accessible to the public would be pedestrian/bike bridges, trails, parks, and various recreational amenities serving visitors and the local population. The project would construct new Class I bike path connections bridging the Santa Ana River. Other project elements support community health and safety through water quality improvements.

The project would generate 70 average daily trips (ADT), therefore, meets the descriptions provided in the City of Anaheim Guidelines, the City of Orange guidelines, and the County of Orange guidelines for project types presumed to have a less than significant transportation impact under CEQA. Additionally, the project includes Class I bike path improvements and multi -use paths that serve non-motorized travel, not leading to a substantial or measurable increase in vehicle travel.

Therefore, no additional VMT analysis is necessary, and the project VMT impacts are presumed to have a less than significant impact.

Reference: These Findings incorporate by reference the information and analysis included in Final EIR Section 4.9, Transportation, and Appendix I, VMT Screening Memo.

PPP T-1 The Santa Ana River Trail will be constructed in compliance with the State Coastal Conservancy's Santa Ana River Parkway & Open Space Plan dated March 14, 2018, or any updates thereof, including trail design principles and guidelines, the California Transportation Department Highway Design Manual's Bikeway Design Criteria, and the design standards of the City of Anaheim, the City of Orange, or other appropriate design standards as required by the applicable approval authority.

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Seismic Desing Criteria, and Geotechnical Manual, as required for various elements of the project, as determined by the applicable approval authority.

5.3 Findings On Significant Impacts Mitigated to below a Level of Significance (CEQA Guidelines Section 15091[a][1])
Pursuant to Public Resources Code Section 21081(a)(1) and CEQA Guidelines Section 15091(a)(1) the City Council finds that changes or alterations have been required in, or incorporated into, the project that avoid, mitigate, or substantially lessen the significant effects on the environment as identified in the Final EIR.

The City, having reviewed and considered the information contained in the Final EIR, the Record of Proceedings pursuant to Public Resource Code Section 21081(a)(1), and CEQA Guidelines Section 15091(a)(1), adopts the following Findings regarding the significant effects of the project.

5.3.1 Biological Resources

5.3.1.1 Threshold BIO-1: Candidate, Sensitive, or Special-Status Species Significant Impact: Implementation of the project could adversely impact special status wildlife species.

Facts in Support of Findings: The project has the potential to directly impact sensitive wildlife species during construction activities through temporary displacement of individual wildlife or temporarily disrupt portions of their habitat (foraging habitat for American white pelican, double - crested cormorant, American peregrine falcon, and western mastiff bat , and suitable nesting and foraging habitat for least Bell's vireo and yellow warbler). Approximately 77.81 acres of aquatic communities and approximately 1.25 acres of scrub and riparian scrub vegetation communities occur on the project site and have the potential to be temporarily impacted during project implementation. Implementation of the project could result in temporary direct loss of habitat, including nesting and foraging habitat, for many of the sensitive wildlife species observed or with a high potential to occur in the survey area. Additionally, the project could result in temporary indirect impacts related to wildlife species, including nesting birds and sensitive roosting bats.

Prior to start of construction activities, the City of Anaheim will be required to implement Mitigation Measures BIO-1 through BIO-4 to ensure that temporary direct impacts related to wildlife species are reduced to a less than significant level. Mitigation measures include biological resources monitoring and reporting, pre-construction surveys, habitat restoration and/or compensation, and avoidance measures, ensuring impacts remain less than significant. Temporary direct impacts on the sensitive wildlife species and direct impacts to aquatic communities and scrub and riparian scrub vegetation communities would be mitigated to a less than significant level.

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Finding: Implementation of Mitigation Measure BIO-1 through Mitigation Measure BIO-4 would mitigate potential direct impacts to sensitive wildlife species and their habitats to below a level of significance through monitoring by a qualified biologist, providing mitigation ratios for acreage impacts, the creation and restoration of impacted vegetation communities, and pre -construction sensitive nesting bird surveys.

Implementation of Mitigation Measure BIO-1 would mitigate potential direct impacts to sensitive nesting birds and roosting bats to below a level of significance. This mitigation measure would require monitoring by a qualified biologist responsible for conducting pre-construction nesting bird surveys and identifying and flushing any roosting bats from trees before construction. No significant and unavoidable impacts would remain.

Reference: These Findings incorporate by reference the information and analysis included in Final EIR Section 4.2, Biological Resources, and Appendix D, Biological Resources Technical Report.

5.3.1.2 Threshold BIO-2: Riparian Habitat and Other Sensitive Natural Communities
Significant Impact: Implementation of the project could adversely impact sensitive vegetation communities.

Facts in Support of Findings: Nine vegetation communities and/or land cover types occur in the project survey area that cover 161.89 acres. Construction of the project has the potential to impact six sensitive vegetation communities that occur in the survey area, including 6.63 acres of fresh water, 0.97 acre of freshwater emergent wetland, 76.28 acres of non-vegetated channel, 1.16 acres of Diegan coastal sage scrub, 0.38 acre of mule fat scrub (disturbed), and 1.63 acres of southern willow scrub. Prior to start of construction activities, the City of Anaheim will be required to implement Mitigation Measures BIO-1 through BIO-3 to ensure that temporary direct impacts related to sensitive vegetation communities are reduced to a less than significant level. M itigation measures include biological resources monitoring and reporting, pre -construction surveys, habitat restoration and/or compensation, and avoidance measures, ensuring impacts remain less than significant with mitigation incorporated.

Finding: Implementation of Mitigation Measure BIO-1 through Mitigation Measure BIO-3 would reduce potential direct impacts to sensitive vegetation communities to below a level of significance through monitoring by a qualified biologist, adhering to required mitigat ion ratios for acreage impacts, and creating new vegetation communities and restoring impacted ones. No significant and unavoidable impacts would remain.

Reference: These Findings incorporate by reference the information and analysis included in Final EIR Section 4.2, Biological Resources, and Appendix D, Biological Resources Technical Report.

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5.3.1.3 Threshold BIO-3: Wetlands
Significant Impact: Implementation of the project could adversely impact state or federally protected wetlands.

Facts in Support of Findings: A total of 85.51 acres of non-wetland waters, freshwater emergent wetland, and riparian potentially under the jurisdiction of the USACE, RWQCB, and CDFW occur in the survey area. These potentially jurisdictional aquatic resources in the survey area include approximately 82.91 acres of non-wetland waters (Santa Ana River, Collin’s Channel, Burris Basin, and the Former Ball Road Basin), 0.97 acre of wetland (emergent wetland in the former Ball Road Basin), and 1.63 acre of riparian (southern willow scrub in Burris Basin).

Prior to start of construction activities, the City of Anaheim will be required to implement Mitigation Measures BIO-1 through BIO-3 to ensure that temporary direct impacts related to jurisdictional aquatic resources are reduced to a less than significant level. Mitigation measures include biological resources monitoring and reporting, pre-construction surveys, habitat restoration and/or compensation, and avoidance measures, ensuring impacts remain less than significant.

Implementation of Mitigation Measure BIO-1 through Mitigation Measure BIO-3 would mitigate potential direct impacts to jurisdictional aquatic resources to below a level of significance through monitoring by a qualified biologist, adhering to required mitigation ratios for acreage impacts, and restoring temporary impact areas.

Finding: With implementation of Mitigation Measures BIO-1 through Bio-3, no significant and unavoidable impacts would remain.

Reference: These Findings incorporate by reference the information and analysis included in Final EIR Section 4.2, Biological Resources, and Appendix D, Biological Resources Technical Report.

5.3.2 Hydrology and Water Quality

5.3.2.1 Threshold HYD-1 and HYD-3c: Water Quality Standards and Polluted Runoff
Significant Impact: Implementation of the project could violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality; or provide substantial additional sources of polluted runoff.

Facts in Support of Findings: Project construction activities include excavation, vegetation removal, grading, bridge and retaining wall construction, trenching, drainage improvements, paving, revegetation, and installation of fencing and trail amenities. Furthermore, the project involves impoundments, storm drain diversions, and embankment modifications to the Santa Ana

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River, requiring Sections 401 and 404 permits from the RWQCB and USACE, respectively, pursuant to the regulatory requirements of the CWA.

During operation of the proposed impoundments, there are opportunities to divert trash from the Santa Ana River. The semi-permanent water bodies created by the proposed impoundments are for groundwater recharge, and the recharge water would be of sufficiently high quality that it satisfies the water quality objectives in the Basin Plan for the Orange County Managemen t Zone and the surface water bodies. The project also includes a series of storm drain diversion pipe to sewer operated by the City of Anaheim and the City of Orange, depending on jurisdiction, further reducing pollutant entry into the river during dry-weather, contributing to improved water quality.

The project is required to comply with the requirements of the County of Orange, OCFCD local implementation plan, the OC Drainage Area Management Plan, and the MS4 permit to prevent long-term impacts of the project and, when feasible, incorporate LID/site design and source control BMPs to address post-construction stormwater runoff management. Additionally, the Santa Ana RWQCB does not list any impaired water bodies within the project reach. RWQCB Reach 2, of the Santa Ana River, which extends from Prado Dam to 17th Street in Santa Ana. However, the project would require long-term maintenance agreements with the City of Orange, County of Orange, and OCWD to identify the responsible parties and the specific tasks required for the proper maintenance and operation of the proposed water, trail, and recreational improvements, as intended and described herein, without adversely impacting water quality or creating polluted runoff. Therefore, to ensure that the project does not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality, maintenance and operations agreements with multiple parties would be required as mitigation to reduce impacts to a less than significant level.

Implementation of Mitigation Measure HYD-, which includes a Maintenance and Operations Agreement (MOA), would reduce potential water quality and polluted runoff impacts from the project to a less-than-significant level by ensuring that the trail, impoundments, and other water features are properly maintained and operated by the participating stakeholders.

Finding: With implementation of Mitigation Measure HYD-1, impacts would be reduced to a less than significant levels and no significant and unavoidable impacts would remain and no significant and unavoidable impacts would remain.

Reference: These Findings incorporate by reference the information and analysis included in Final EIR Section 4.7, Hydrology and Water Quality, and Appendix G, Hydrology Report.

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5.3.3 Noise

5.3.3.1 Threshold N-1: Exceedance of Noise Standards
Significant Impact: Implementation of the project could generate a substantial temporary increase in ambient noise levels in the vicinity of the project site in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agen cies.

Facts in Support of Findings: The operation of heavy equipment during project construction would result in temporary increases in noise in the immediate vicinity of the project site. Construction of the project would continue for approximately 24 to 36 months. Construction activities would include excavation of material sources; clearing and grubbing; grading; retaining wall and bridge construction; drainage improvements; paving; and installation of fencing, signs, and other safety - related features. Construction equipment and vehicles c ould include backhoes; loaders; tractors; excavators; cranes; graders; scrapers; lifts; concrete trucks and pump; paving machines; compactors/rollers; air compressors; generators; and trucks for demolition, grading, and materials delivery. Based on noise levels from construction that were evaluated based on typical equipment noise levels determined by the Federal Highway Administration Roadway Construction Noise Model (RCNM), construction noise would have the potential to exceed the screening levels establi shed by the Federal Transit Administration (FTA) during typical construction activities.

Implementation of Mitigation Measure NOI -1, which includes Construction Specifications for Sensitive Receptors , would muffle construction equipment to minimize levels at nearby sensitive receptors.

Finding: With implementation of Mitigation Measure NOI-1, impacts would be reduced to a less than significant levels and no significant and unavoidable impacts would remain.

Reference: These Findings incorporate by reference the information and analysis included in Final EIR Section 4.8, Noise, and Appendices C (Air Quality/GHG) and H (Noise).

5.3.3.2 Threshold N-2: Excessive Groundborne Vibration or Noise Significant Impact: Implementation of the project could generate excessive groundborne vibration or groundborne noise levels during construction.

Facts in Support of Findings: Groundborne vibration and noise would be limited to the project construction phase. The project does not include any components that would generate vibration after construction. Due to the linear nature of the project, construction activities would only be within 110 feet of the nearby Extended Stay America – Orange County hotel for a short time. Additionally, construction would occur during the day and would not disturb sleep. However, vibration could be a temporary annoyance to the hotel and staff, and exceed the significance threshold impact criteria.

Therefore, construction of the project would result in potentially significant exposure to groundborne

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vibration during construction. Implementation of Mitigation Measure NOI-2, which includes noticing requirements for construction specifications, would reduce impacts by minimizing the potential nuisance of vibration by allowing surrounding uses time to prepare for a potential nuisance.

Finding: With implementation of Mitigation Measure NOI-2, impacts would be reduced to a less than significant levels and no significant and unavoidable impacts would remain.

Reference: These Findings incorporate by reference the information and analysis included in Final EIR Section 4.8, Noise, and Appendices C (Air Quality/GHG) and H (Noise).

5.3.4 Tribal Cultural Resources

5.3.4.1 Threshold TCR-1: Tribal Cultural Resources
Significant Impact: Implementation of the project could cause a substantial adverse change in the significance of a Tribal Cultural Resource.

Facts in Support of Findings:

Because construction-related ground-disturbing activities could extend into previously undisturbed native soils, grading at depths exceeding 5 feet could potentially uncover TCRs. Therefore, impacts to subsurface TCRs could occur during grading and would be potentially significant without mitigation.

Implementation of Plans, Programs, and Policies (PPP) CUL-1, which includes compliance with the California Health and Safety Code rearing discovery of human remains, and Mitigation Measure TCR-1, which includes Native American Monitoring, would mitigate potential impacts associated with TCRs to a level that is less than significant. Mitigation Measure TCR-1 would require a Tribal monitor to be present if ground disturbance associated with the project exceeds 5 feet in depth.

Finding: With implementation of PPP CUL-1 and Mitigation Measure TCR-1, no significant unavoidable adverse impacts relating to TCRs would remain.

Reference: These Findings incorporate by reference the information and analysis included in Final EIR Section 4.10, Tribal Cultural Resources, and Appendix E, Cultural Memo.

5.4 Findings Regarding Mitigation that is within the
Responsibility and Jurisdiction of Another Public Agency (CEQA Guidelines Section 15091[a][2])
No changes or alterations are within the responsibility and jurisdiction of another public agency or the agency making the Findings.

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5.5 Findings Regarding Significant and Unavoidable Impacts (CEQA Guidelines Section 15091[a][3])
Section 15126.2(b) of the CEQA Guidelines requires that an EIR describe any significant impacts that could not be avoided, even with the implementation of feasible mitigation measures. The environmental effects of the project on various aspects of the envi ronment are discussed in detail in Chapter 4, Environmental Analysis, of the FEIR.

The Final EIR did not determine any significant and unavoidable environmental impact that would result from development of the project.

5.6 Findings Regarding Alternatives (Public Resources Code Section 21081 and CEQA Guidelines Section 15091[a][1])
In accordance with Section 15126.6(a) of the CEQA Guidelines, an EIR must contain a discussion of “a range of reasonable alternatives to a project, or the location of a project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of the alternatives.” Section 15126.6(f) further states that "the range of alternatives in an EIR is governed by the 'rule of reason' that requires the EIR to set forth only those alternatives necessary to permit a reasoned choice." Thus, the following discussion focuses on project alternatives that are capable of eliminating significant environmental impacts or substantially reducing them compared to the Project, even if the alternative would impede the attainment of some Project objectives, or would be more costly.

In accordance with Section 15126.6(f)(1), the factors that may be taken into account when addressing the feasibility of alternatives include: (1) site suitability; (2) economic viability; (3) availability of infrastructure; (4) general plan consistency; (5) other plans or regulatory limitations; (6) jurisdictional boundaries; and (7) whether the proponent can reasonably acquire, control or otherwise have access to the alternative site.
“Feasible” is defined in Section 15364 of the CEQA Guidelines to mean “capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, legal, social, and technological factors.” The California Public Resources Code (Section 21081 and CEQA Guidelines Section 15019[a][3]) also provides that “other” considerations may form the basis for a finding of infeasibility. Case law makes clear that a mitigation measure or alternative can be deemed infeasible on the basis of its failure to meet project objectives or on related public policy grounds.

Pursuant to CEQA Guidelines, Section 15126.6(b), alternatives to the project include those that avoid or substantially lessen any significant effects of the project, even if these alternatives would impede to some degree the attainment of the project objectives or would be more costly. Based on

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the analysis contained in Chapter 4, Environmental Analysis, the project would not result in any significant and unavoidable adverse impacts.

5.6.1 Alternatives Considered But Rejected
CEQA requires that the discussion of alternatives focus on alternatives to the project or its location that are capable of avoiding or substantially lessening any significant effects of the project. The two alternatives listed below were considered but rejected during the scoping/planning process based on one or more of the listed criteria: i) failure to meet most of the basic project objectives, ii) infeasibility, or iii) inability to avoid significant environmental impacts. (CEQA Guidelines, Section 15126.6[c]).

The following section describes alternatives or alternative concepts that were given consideration by the lead agency but rejected from further analysis in the EIR.

5.6.1.1 Alternative Sites
The project site was selected due to its location adjacent to the Anaheim Regional Transportation Intermodal Center (ARTIC), a local and regional transportation hub providing rail, bus, taxi, and other services for daily commuters and visitors, and two major sports and entertainment venues, Honda Center and Angel Stadium of Anaheim. The project site is also located adjacent to and integrated with the existing City of Orange Stadium Promenade and the OCVIBE Entertainment District, which is currently being developed adjacent to the Honda Center. OCVIBE is a 100-acre master planned campus currently under development around the Honda Center with shopping, dining, sports, entertainment, open space, apartments, offices, and parking. By locating the OC River Walk project in this highly visited area near high quality transit, the trail and bridge improvements have the greatest potential to promote alternative modes and transportation and reduce regional vehicle miles travelled (VMT). Locating the project in another l ocation would reduce the VMT benefits and increase regional air quality and greenhouse gas emissions. Therefore, an Alternative Site would not reduce environmental impacts.

Another key factor in selection of the project site is the location of the Orange County Water District Groundwater Replenishment System (GWRS) Turnout Structure near the northwest corner of the project site, which will be the source of water for groundwater recharge in the Santa Ana River.

Moving the project to another location would not have a source of GWRS water and would not allow for groundwater replenishment, which is a major objective of the project. For these reasons, Alternative Sites have been rejected from further consideration.

5.6.1.2 No Impoundment Alternative
This Alternative would not include the proposed impoundment structures which are part of the Group A improvements (refer to Chapter 2 for descriptions of the project elements included in

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each group). All other components of the project would remain the same. Without the impoundments, this Alternative would not allow for groundwater replenishment using GWRS water, which is a major objective of the project. For these reasons, the No Impoundm ent Alternative has been rejected from further consideration.

5.6.2 Alternatives Under Consideration

5.6.2.1 Alternative 1: No Project/No Improvements Alternative CEQA Guidelines Section 15126.6(e) requires that an EIR evaluate a “No Project” alternative, along with its impacts. The purpose of describing and analyzing a No Project Alternative is to allow a lead agency to compare the impacts of approving a project to the impacts of not approving it. Specifically, Section 15126.6(e)(3)(B) requires that an EIR for a development project on an identifiable property address the No Project Alternative as circumstances under which a project does not proceed. In other words, the No Project Alternative assumes that a project site would not be developed with a project.

In accordance with CEQA Guidelines Section 15126.6(e), the No Project is the No Project/No Improvements Alternative. Under the No Project/No Improvements Alternative, none of the Group A, B, C, or D improvements would occur. Although this Alternative would avoid potential short- term, construction-related impacts, none of the long-term benefits of the project (e.g., trail improvements, groundwater recharge, open space restoration, enhanced community access, recreational opportunities, infrastructure improvements, etc.) would be realized. As a result, under this Alternative none of the Conceptual Master Plan Elements, as illustrated on Figures 2 -8a through 2-8d, would occur, including Group A – Impoundments, Storm Drain Diversions, and Embankments; Group B – New Pedestrian/Bike Bridges; Group C – New Trails and Trail Improvements; and Group D – Enhanced Community Amenities.

The No Project/No Improvement Alternative would avoid some of the short -term construction related impacts. Because no changes would occur under the No Project/No Improvement Alternative, less than significant impacts potentially resulting from the project for the following environmental topics would be avoided: aesthetics, air quality, biological resources, cultural resources, geology and soils, hazards and hazardous materials, and tribal cultural resources.

However, the long-term VMT, air quality, and GHG impacts would be greater under the No Project/No Improvement Alternative. Additionally, this alternative would not attain any of the Project Objectives established for the project.

The No Project/No Improvement Alternative would not involve any changes within the project site.

This alternative would not attain any of the Project Objectives, including environmental benefits related to trail improvements, groundwater recharge, and open space restoration. Additional benefits of the project, such as enhanced community access, recreational opportunities, wildlife and habitat benefits, and infrastructure improvements, would not occur.

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Potentially Significant Impact: Because no changes would occur under the No Project/No Improvement Alternative, less than significant impacts potentially resulting from the project for the following environmental topics would be avoided: aesthetics, air quality, biological resources, cultural resources, geology and soils, hazards and hazardous materials, and tribal cultural resources. However, the long-term VMT, air quality, and GHG impacts would be greater under the No Project/No Improvement Alternative.

Finding/Rationale: The No Project/No Improvement Alternative would avoid some of the short - term construction related impacts. Because no changes would occur under the No Project/No Improvement Alternative, less than significant impacts potentially resulting from the project for the following environmental topics would be avoided: aesthetics, air quality, biological resources, cultural resources, geology and soils, hazards and hazardous materials, and tribal cultural resources. However, the long-term VMT, air quality, and GHG impacts would be greater under the No Project/No Improvement Alternative. Additionally, this alternative would not attain any of the Project Objectives established for the project.

The No Project/No Improvement Alternative would not involve any changes within the project site.

This alternative would not attain any of the Project Objectives identified above in Section 2.1, Project Objectives, including environmental benefits related to trail improvements, groundwater recharge, and open space restoration. Additional benefits of the project, such as enhanced community access, recreational opportunities, wildlife and habitat benefits, and infra structure improvements, would not occur.

Reference: These Findings incorporate by reference the information and analysis included in Final EIR Chapter 4.0, Alternatives.

5.6.2.2 Alternative 2: Group A and C Impoundments and Trails Alternative Under the Group A and C Impoundments and Trails Alternative, none of the Group B or D improvements would occur. As a result, the Group B – New Pedestrian/Bike Bridges and Group D – Enhanced Community Amenities would not occur. Group B includes two new pede strian/bike bridges, and Group D includes park and open space along the east bank and in Lot B on the west side. Although this Alternative would reduce some potential short-term, construction-related impacts, some of the long-term benefits of the project would not be realized. Specifically, the elimination of new pedestrian and bike bridges would reduce some of the VMT, air quality, and GHG benefits associated with the project. This alternative would eliminate park and open space with the potential for habitat restoration or enhancement efforts; therefore, it would reduce some of the biological resource benefits that could have been achieved through project implementation.

Potentially Significant Impact: The Group A and C Impoundments and Trails Alternative would reduce some of the short-term construction-related impacts. Because no bridges would occur

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under Alternative 2, less than significant impacts resulting from the project for construction noise would be reduced. Although the area of disturbance would decrease under this alternative, some of park and open space improvements with potential habitat restoration would not occur, which would have a beneficial impact on the biological resources after construction. This alternative is considered to have similar impacts related to biological resources. As discussed above, the long - term VMT, air quality, and GHG impacts would be slightly greater under Alternative 2.

Finding/Rationale: The Group A and C Impoundments and Trails Alternative achieves most of the Project Objectives, including environmental benefits related to trail improvements in groundwater recharge. However, without the bridges, some of the VMT reduction benefits wo uld not occur to the same extent as the full project. This alternative would only partially meet the project objectives and only partially achieve the associated benefits. Therefore, the City rejects this alternative.

The Group A and C Impoundments and Trails Alternative achieves most of the Project Objectives, including environmental benefits related to trail improvements in groundwater recharge. However, without the bridges, some of the VMT reduction benefits would not occur to the same extent as the full project. This alternative would only partially meet the project objectives and only partially achieve the associated benefits.

Reference: These Findings incorporate by reference the information and analysis included in Final EIR Chapter 4.0, Alternatives.

5.6.3 Environmentally Superior Alternative
CEQA requires the identification of an environmentally superior alternative. Section 15126.6(e)(2) of the CEQA Guidelines states that, if the No Project Alternative is the environmentally superior alternative, then the EIR shall also identify an environmentally superior alternative among the other alternatives.

Of the alternatives analyzed, the environmentally superior alternative is Alternative 2: Group A and C Impoundments and Trails Alternative. As shown in DEIR Table 5-1, Comparison of Potentially Significant Impacts for Alternatives to the Project, Alternative 2 would have less impacts under three of the environmental topic areas; similar impacts under five of the environmental topic areas; and greater impacts under two of the environmental topic areas. However, this alternative would only partially meet project objectives and only partially achieve the associated benefits. While this alternative would achieve environmental benefits related to trail improvements in groundwater recharge, without the bridges, some of the VMT reduction benefits would not occur to the same extent as the full project.

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Chapter 6.0 Findings Regarding Other CEQA
Considerations

6.1 Growth Inducement
Section 15126.2(e) of the CEQA Guidelines mandates that the growth-inducing impact of a project be discussed. This discussion is presented in Chapter 6.0, Other CEQA Considerations, of the Final EIR. Per the CEQA Guidelines Section 15126.2(e), growth-inducing effects are not necessarily beneficial, detrimental, or of little significance to the environment. For the reasons outlined below, the City finds that the project would not result in short-or long-term growth-inducing impacts.

The project includes various groundwater recharge, trails, pedestrian/bike bridges, and enhanced community recreational amenities along the Santa Ana River corridor to benefit and promote environmental and community health, recreation, safety, entertainment, wayfindi ng, beauty, connectivity, water supply, economic, and natural resource needs. Most components of the project would operate passively and would not involve any growth inducing uses that would foster economic or population growth, or the construction of additional housing, either directly or indirectly, in the surrounding environment. The surrounding environment is already developed or is planned to be developed with mixed uses. Although the project would create groundwater recharging areas by installing two river impoundments, such project component is not intended to remove obstacles to population growth. The project also does not involve any changes to land use policies that provide economic stimulus such as industrial or commercial uses that may induce growth in the area. The project would improve the already existing Santa Ana River Trail to better serve the residents and visitors of the Cities of Anaheim and Orange. Furthermore, it is anticipated that the project can be serviced by the existing labor force within the County of Orange or surrounding communities during construction, and no relocation of construction workers to the Cities of Anaheim or Orange would be necessary. The project does not propose new infrastructure that would induce substantial growth within the vicinity or in the project Site that was not previously considered for development. Growth-inducing impacts would be less than significant.

6.2 Significant Irreversible Environmental Changes that will be Caused by the Project
Section 15126.2(d) of the CEQA Guidelines requires a discussion of any significant, irreversible environmental changes that would be caused by the project. Generally, a project would result in significant, irreversible environmental impacts if the following would occur:
• The project would involve a large commitment of nonrenewable resources. • The primary and secondary impacts would generally commit future generations to similar uses (e.g., a highway improvement that provides access to a previously inaccessible area).

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• The project would involve uses in which irreversible damage could result from any potential environmental accidents associated with the project.
• The proposed consumption of resources is not justified (e.g., the project involves wasteful use of energy).

The project would result in following minor irreversible environmental changes:
• Development of the project would include two water impoundments for groundwater recharge and recreation by installing inflatable three rubber dams (impoundments), modifying the riverbanks, constructing two pedestrian/bike bridges, providing new trails, improving existing trails, creating new and protection of existing access ramps, constructing two new undercrossings on the west bank at the Union Pacific Railroad and the Metrolink railroad, providing enhanced community recreation amenities, and other improv ements.

The project would require the irreversible consumption of energy and natural resources.

Electricity would be consumed for power tools, electric equipment, and lighting.

Nonrenewable and limited resources required for the project could include oil, natural gas, gasoline, lumber, sand and gravel, asphalt, aggregate, water, steel, and similar materials.

Additionally, nonrenewable fuels would be used by construction equipment, haul trucks, and worker vehicles. This commitment of natural resources and energy would be irreversible, and would limit the availability of such resources for other uses. However, given the size and nature of the project, the commitment of nonrenewable resources, while irretrievable, would not be of significant commitment. Post-construction, the project would have positive impacts on nonrenewable resources by providing active transportation facilities (trails and pedestrian/bike bridges), which would help reduce vehicle miles traveled, thereby lessen consumption of fossil fuels and electricity consumption for transportation. Additionally, the groundwater recharge area would support groundwater replenishment. Therefore, the project would result in minor irreversible environmental changes in this regard.
• The project would result in primary and secondary impact that would generally commit future generations to similar uses by providing new pedestrian/bike bridges, trail improvements, groundwater recharge, and recreation amenities. However, these uses would benefit future generations and would not be considered adverse environmental impacts of the project. Therefore, the project would not result in significant and irreversible environmental changes in this regard.
• The project would not involve uses in which irreversible damage could result from any potential environmental accidents associated with the project. As discussed in Sections 4.1 through 4.10, the project would not result in potentially significant impact during and after construction. However, those impacts would be mitigated to less than significant levels with mitigation measures, therefore, no significant and unavoidable impact would remain. The project would not result in significant and irreversible environmental changes in this regard.
• The project construction would not involve the wasteful use of energy, and consumption of resources is justified as the project would have beneficial impacts to the community’s health and natural resource needs, while complementing existing facilities, therefore, meet

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the project objectives listed in Section 2.2, Project Objectives. The project would not result in significant and irreversible environmental changes in this regard.

As discussed above, the project would generally result in irreversible changes that would benefit the environment and future generation with minor adverse impacts during construction.

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Chapter 7.0 Findings Regarding Responses to Comments
and Final EIR Revisions
The Final EIR includes the comments received on the Draft EIR and responses to those comments.

The focus of the responses to comments is on the disposition of significant environmental issues that are raised in the comments, as specified by CEQA Guidelines Section 15088(c).

Finding/Rationale: Responses to comments made on the Draft EIR and revisions in the Final EIR clarify and amplify the analysis presented in the Draft EIR, and do not trigger the need to recirculate per CEQA Guidelines Section 15088.5(b).

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Anaheim City CouncilDecember 9, 2025

Anaheim City Council
December 9, 2025