FINAL ENVIRONMENTAL IMPACT REPORT
ANAHEIM HILLS FESTIVAL SPECIFIC PLAN
AMENDMENT PROJECT
(STATE CLEARINGHOUSE NO. 2024010859)
Prepared for City of Anaheim
200 S. Anaheim Boulevard, Suite 162
Anaheim, California 92805
Contact: Amanda Lauffer
Prepared by Kimley-Horn and Associates, Inc.
1100 W. Town & Country Road, Suite 700
Orange, California 92868
Contact: Kiana Daniels, AICP
SEPTEMBER 2025
Anaheim Hills Festival Specific Plan Amendment Project
Final Environmental Impact Report Table of Contents
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TABLE OF CONTENTS
1.0 INTRODUCTION .................................................................................................................... 1
1.1 Public Review Draft Environmental Impact Report ................................................................ 1
1.2 Final Environmental Impact Report ....................................................................................... 1
2.0 RESPONSE TO COMMENTS ................................................................................................... 3
2.1 List of Written Commenters .................................................................................................. 3
2.2 List of Commenters at the Planning Commission Workshop .................................................. 4
2.3 Responses to Written Comments .......................................................................................... 5
2.3.1 Comment Letters and Responses: Agencies (A) ..................................................................... 5
2.3.2 Comment Letters and Responses: Organizations (B) ........................................................... 14
2.3.3 Comment Letters and Responses: Individuals (C) ................................................................ 22
2.4 Responses to Planning Commission Workshop Comments .................................................. 26
3.0 CLARIFICATIONS AND REVISIONS ........................................................................................ 29 Appendices
Appendix A: Written Comments on the Draft EIR
Appendix B: Verbal Comments from Individuals at Planning Commission Workshop Appendix C: Mitigation Monitoring Program
Appendix D: Traffic Impact Analysis
Appendix E: Vehicle Miles Traveled (VMT) Analysis
Appendix F: Localized Emissions and Health Risk Assessment Anaheim Hills Festival Specific Plan Amendment Project Section 1.0 Final Environmental Impact Report Introduction
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1.0 INTRODUCTION
1.1 Public Review Draft Environmental Impact Report
In accordance with State California Environmental Quality Act (CEQA) Guidelines §§15120 through 15132, the City of Anaheim (“City”) prepared a Draft Environmental Impact Report (Draft EIR) for the Anaheim Hills Festival Specific Plan Amendment Project (Project) (State Clearinghouse Number 2024010859). The Draft EIR was made available for review and comment to the public, responsible and trustee agencies, interested groups, and organizations for a 45-day review period that occurred between June 20, 2025, and August 4, 2025. The Draft EIR was also made available directly to State agencies through the State Clearinghouse, Office of Land Use and Climate Innovation.
1.2 Final Environmental Impact Report
As previously noted, the Draft EIR for this Project was made available for review and comment for a 45- day public review period. The City evaluated all written comments received during the Draft EIR public review period concerning significant environmental issues pursuant to State CEQA Guidelines §15088.
Pursuant to State CEQA Guidelines §15088.5(f)(2), the City prepared written responses to comments received during the Draft EIR circulation period that relate to the Draft EIR. Additionally, pursuant to State CEQA Guidelines §15088(b), at least 10 days prior to certifying the EIR, the City will provide a written response to each public agency on comments made by that public agency.
State CEQA Guidelines §15132 state that a Final EIR shall consist of:
The Draft EIR or a revision of the draft;
Comments and recommendations received on the Draft EIR either verbatim or in summary; A list of persons, organizations, and public agencies commenting on the DEIR; The Lead Agency’s responses to significant environmental points raised in the review and consultation process; and
Any other information added by the Lead Agency.
As such, this Final EIR consists of the following components:
Section 1.0: Introduction
Section 2.0: Response to Comments
o Section 2.1: List of Written Commenters
o Section 2.2: List of Commenters at the Planning Commission Workshop o Section 2.3: Responses to Written Comments
o Section 2.4: Responses to Planning Commission Workshop Comments Section 3.0: Corrections and Revisions
Appendix A: Written Comments on the Draft EIR
Appendix B: Verbal Comments from Individuals at Planning Commission Workshop Appendix C: Mitigation Monitoring Program
Appendix D: Traffic Impact Analysis
Appendix E: Vehicle Miles Traveled (VMT) Analysis
Appendix F: Localized Emissions and Health Risk Assessment Anaheim Hills Festival Specific Plan Amendment Project Section 1.0 Final Environmental Impact Report Introduction
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This Final EIR will allow the public and Lead Agency an opportunity to review the Draft EIR revisions, the comments and responses, and other EIR components, such as the MMP before Project consideration. This Final EIR will serve as the environmental document to support a decision on the Project.
It is noted, none of the corrections/clarifications identified in this Final EIR constitute “significant new information” pursuant to State CEQA Guidelines §15088.5. The corrections/clarifications identified in this Final EIR merely clarify/amplify and make insignificant modifications to the Draft EIR. The corrections/clarifications do not involve changes in the Project or environmental setting, or significant new information.
Pursuant to State CEQA Guidelines §15090, prior to approving a project, the Lead Agency must certify that:
This Final EIR has been completed in compliance with CEQA; This Final EIR was presented to the decision-making body of the Lead Agency, and that the decision-making body reviewed and considered the information in this Final EIR prior to approving the Project; and
This Final EIR reflects the Lead Agency’s independent judgment and analysis.
This certification, of “Findings of Fact,” are included in a separate Findings document. Both this Final EIR and the Findings will be submitted to the Lead Agency for consideration of the Project.
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2.0 RESPONSE TO COMMENTS
All of the written comment letters and email comments received by the City during the public review period, as well as the oral comments that were provided at the July 14, 2025, Planning Commission Workshop, have been included and responded to in this Final EIR, with particular focus on comments that raise questions regarding the Project’s environmental analyses. While comments that (1) do not address the adequacy or completeness of the Draft EIR; (2) do not raise substantive environmental issues pursuant to CEQA; (3) do not address the Project; or (4) request the incorporation of additional information not relevant to environmental issues do not require a response, this Final EIR has responded to all comments received during the public review period.
2.1 List of Written Commenters
In accordance with the State CEQA Guidelines § 15132, the following is a list of public agencies, organizations, and individuals that submitted comments on the Draft EIR received as of the close of the public review period on August 4, 2025. Comments have been numbered, and responses have been developed with corresponding numbers. Written comments are provided as Appendix A of this Final EIR.
Table 2-1: Comment Letters
Letter Reference Commenter
Date of
Correspondence
Page
No.
Agencies (A)
A1 South Coast Air Quality Management District July 1, 2025 1 A2 South Coast Air Quality Management District August 1, 2025 3 A3 California Department of Transportation, District 12 August 4, 2025 7 Organizations (B)
B1 Supporters Alliance for Environmental Responsibility (SAFER) June 30, 2025 12
B2 Western States Regional Council of Carpenters (WSRCC) August 4, 2025 14 Individuals(C)
C1 Rich Fagner June 20, 2025 300
C2 Shelley Shuff June 28, 2025 301
C3 Joy Pickett July 3, 2025 303
C4 Grace McGee July 14, 2025 304
C5 Marcia Anderson July 29, 2025 305
C6 Allison Valdivia July 30, 2025 306
C7 Betty and Dana Farnsworth July 30, 2025 307
C8 Evalina Loyo July 30, 2025 308
C9 Joy Pickett August 1, 2025 310
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2.2 List of Commenters at the Planning Commission Workshop The following is a list of individuals who commented at the Planning Commission Workshop, provided below in Table 2-2. Verbal comments from this workshop are provided within Appendix B of this Final EIR.
Table 2-2: Commenters at the Planning Commission Workshop Comment Identifier Commenter Name
D1 John Mozzarella
D2 Jimmy Arrivallo (Western States Regional Council of Carpenters) D3 Betty Farnsworth
D4 Mark Herbert
D5 Mr. Hill
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2.3 Responses to Written Comments
This section presents responses to written comments received from agencies, organizations, and individuals during the public review period for the Draft EIR for the Project. Each comment letter is assigned a unique letter designation (e.g., A1, B1, C1), and individual comments within each letter are bracketed and numbered sequentially (e.g., A1-1, A1-2, etc.) for reference purposes.
Copies of the full comment letters, with bracketed comment numbers, are provided in Appendix A of this Response to Comments. The responses to individual comments are provided below and are organized to correspond to the bracketed comments in Appendix A.
Where portions of the Draft EIR are excerpted in this section for reference or clarification, the text is shown indented. Where changes to the Draft EIR have been made in response to comments or to clarify the analysis, additions are shown in underlined text and deletions are shown in strikeout text, unless otherwise noted.
2.3.1 COMMENT LETTERS AND RESPONSES: AGENCIES (A)
Comment Letter A1 – South Coast Air Quality Management District (AQMD), July 1, 2025 Response A1-1
South Coast AQMD staff requested electronic copies of all live modeling and emissions calculation files used to support the Draft EIR’s analysis of air quality impacts. Specifically, the comment requests the following file types:
CalEEMod input files (.csv and. json),
EMFAC output files,
emission calculation spreadsheets (live Excel versions), AERMOD input/output files and View files,
HARP input/output and risk assessment spreadsheets, and any post-processing files used to derive pollutant-specific concentrations.
As of the date of this Final EIR, the Lead Agency has coordinated with the Project’s air quality consultants and provided the requested modeling and calculation files to South Coast AQMD via a secure file-sharing platform. This comment does not raise any substantive concerns regarding the adequacy or conclusions of Draft EIR’s air quality or health risk analysis. Rather, it seeks underlying technical files to assist South Coast AQMD’s review. As such, no changes to the Draft EIR are required in response to this comment.
Comment Letter A2 - South Coast AQMD, August 1, 2025
Response A2-1
This comment references an attached letter from the South Coast AQMD dated August 1, 2024, from Sam Wang, Program Supervisor, CEQA IGR Planning, Rule Development & Implementation to the City of Anaheim Planning and Building Department. Written responses to each of the substantive comments raised in the letter (A2-2 through A2-5) are included in this Final EIR, consistent with State CEQA Guidelines §15088 and Public Resources Code §21092.5(a).
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Response A2-2
South Coast AQMD provides introductory remarks summarizing the Project and outlining the structure of the agency’s comments. As the comment does not raise any specific issues regarding the content or adequacy of the Draft EIR, no further response is necessary.
Response A2-3
The commenter states that the Draft EIR does not include an operational health risk assessment (HRA) or a localized significance threshold (LST) analysis for operational emissions and asserts that such evaluations are necessary due to potential diesel particulate matter (DPM) emissions from mobile sources. The commenter also notes the proximity of sensitive receptors, including residential uses and a nearby medical clinic, and recommends further evaluation of operational air quality impacts.
The Draft EIR appropriately evaluates operational air quality impacts in Section 4.3, consistent with the State CEQA Guidelines, South Coast AQMD CEQA Air Quality Handbook, and applicable screening thresholds and methodologies. As explained in Section 4.3.5 (Impact Analysis), under South Coast AQMD LST methodology, LSTs apply to the operational phase of a project only if the project includes substantial stationary sources or attracts mobile sources that may spend extended periods idling on-site (e.g., transfer facilities and warehouse buildings). The Project does not include such uses. Due to the absence of significant stationary source emissions or long-duration queuing and idling activity, an operational LST analysis is not required.
Mobile source emissions associated with typical residential land uses (e.g., passenger vehicles, delivery vans, and landscape maintenance equipment) are generally intermittent, short in duration, and spatially dispersed. These sources do not typically generate localized concentrations of toxic air contaminants (TACs) or DPM at levels that would warrant an HRA under South Coast AQMD guidance. The Draft EIR conservatively accounts for operational emissions from all relevant sources, including mobile, area, and energy sources. As shown in Table 4.3-7, projected operational emissions would not exceed any of the South Coast AQMD’s regional thresholds of significance for criteria pollutants. Therefore, operational air quality impacts would be less than significant, and no mitigation is required.
The commenter has not provided substantial evidence that the Project would result in significant operational air quality impacts not already disclosed in the Draft EIR. The issues raised are general in nature and not supported by project-specific data, technical modeling, or expert opinion. CEQA does not require an EIR to evaluate speculative or minor emission sources that are not reasonably expected to cause significant impacts based on the nature and scale of the proposed development. Accordingly, the Draft EIR’s conclusion that an operational HRA and LST analysis are not warranted is legally adequate and consistent with South Coast AQMD methodology and CEQA requirements. No revisions to the Draft EIR are required in response to this comment. Notwithstanding, the additional operational LST and HRA analysis requested by the commenter has been prepared and is included in Appendix F. The supplemental analysis confirms that the Project would not result in new or more severe operational air quality impacts, and no revisions to the Draft EIR are required.
Response A2-4
The commenter expresses concern regarding the siting of new sensitive receptors, such as residences, in proximity to existing air pollution sources (e.g., freeways and rail lines) and recommends the implementation of health-protective strategies to reduce potential exposure. The commenter also references guidance from the California Air Resources Board (CARB), including the Air Quality and Land Anaheim Hills Festival Specific Plan Amendment Project Section 2.0 Final Environmental Impact Report Response to Comments
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Use Handbook and the Technical Advisory on Strategies to Reduce Air Pollution Exposure Near HighVolume Roadways, and suggests measures such as enhanced HVAC filtration (e.g., MERV 13 or higher), building design features, and vegetative screening.
The Draft EIR evaluates potential air quality impacts in Section 4.3 and concludes that the Project would not result in significant emissions of criteria pollutants or expose sensitive receptors to substantial concentrations of toxic air contaminants (TACs). As explained in Section 4.3.5, the Project does not include substantial stationary sources or high-idling land uses, and mobile source emissions associated with residential uses (e.g., passenger vehicles and service vehicles) are intermittent and widely dispersed. The Draft EIR conservatively modeled operational emissions from all area, energy, and mobile sources using CalEEMod, and found that the Project would not exceed South Coast AQMD’s operational significance thresholds (see Table 4.3-8). Therefore, the Project’s operational air quality impacts would be less than significant and would not require mitigation.
The CARB guidance documents cited by the commenter are advisory in nature and do not establish mandatory thresholds or mitigation requirements under CEQA. While the City acknowledges the public health value of measures such as high-efficiency HVAC filtration or vegetative buffers, such measures are not required unless a project would result in a significant environmental impact. In this case, the commenter has not presented substantial evidence that the Project would expose new residents to significant pollutant concentrations or health risks. Additionally, the Project would comply with applicable California Building Code and Title 24 energy efficiency requirements, including indoor air quality standards that incorporate MERV 13 filtration or equivalent in many new residential buildings.
Moreover, CEQA does not generally require an EIR to evaluate the impacts of existing environmental conditions on future users of a proposed project. This argument, commonly referred to as “reverse CEQA,” was directly addressed by the California Supreme Court in California Building Industry Association v. Bay Area Air Quality Management District (2015) 62 Cal.4th 369. The Court held that CEQA focuses on a project’s impacts on the environment, not the environment’s impact on the project, except in limited circumstances (e.g., school siting, projects in hazardous locations). Because the Project does not fall under one of these statutory exceptions, and because the Draft EIR demonstrates that the Project would not result in significant air quality impacts, no further analysis of existing off-site air pollution sources or mitigation measures to reduce exposure is required under CEQA.
The commenter’s suggestions may inform future project design or Citywide policy discussions, but do not identify a deficiency in the Draft EIR or present new information that would alter its significance conclusions. No revisions to the Draft EIR are required in response to this comment.
Response A2-5
South Coast AQMD cites Public Resources Code §21092.5(a) and State CEQA Guidelines §15088(a)–(c), which require the Lead Agency to evaluate and provide written responses to public agency comments on the Draft EIR and to provide those responses at least 10 days prior to certification of this Final EIR. The commenter further notes that if the Lead Agency’s position differs from the agency’s recommendations, it must explain its reasoning with reference to substantial evidence in the record.
The City acknowledges this procedural request and confirms that this Final EIR includes written responses to each substantive comment received from South Coast AQMD. As required by State CEQA Guidelines §15088 and Public Resources Code §21092.5(a), the responses will be provided to South Coast AQMD and made available to the public at least 10 days prior to certification of this Final EIR. Where the City’s Anaheim Hills Festival Specific Plan Amendment Project Section 2.0 Final Environmental Impact Report Response to Comments
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responses differ from South Coast AQMD’s recommendations, the responses are supported by substantial evidence in the administrative record, consistent with State CEQA Guidelines §15088(c).
Comment Letter A3 – California Department of Transportation (Caltrans) District 12, August 4, 2025 Response A3-1
This comment states that Caltrans appreciate the opportunity to review the Draft EIR. The commenter provides a summary of the Project description. Given that the comment does not raise any specific issues regarding the content or adequacy of the Draft EIR, no further response is necessary.
Response A3-2
This comment states that State Route 91 (SR-91) is owned and operated by Caltrans, and therefore, Caltrans is a commenting agency on the Project. The comment is noted. Given that the comment does not raise any specific issues regarding the content or adequacy of the Draft EIR, no further response is necessary.
Response A3-3
The commenter states that there is a connection between land use and transportation and expresses support for smart growth, multimodal planning, and the City’s efforts to meet its RHNA obligations. Given that the comment does not raise any specific issues regarding the content or adequacy of the Draft EIR, no further response is necessary.
Response A3-4
This comment encourages the use of transit among future residents, visitors, and workers of the Project.
The commenter states that increasing multimodal transportation will lead to a reduction in congestion, vehicle miles traveled (VMT) and improve air quality. This comment is noted. Given that the comment does not raise any specific issues regarding the content or adequacy of the Draft EIR, no further response is necessary.
Response A3-5
This comment encourages the design of Complete Streets that include high-quality pedestrian, bicycle, and transit facilities that are safe and comfortable for users of all ages and abilities. This comment is noted.
Given that the comment does not raise any specific issues regarding the content or adequacy of the Draft EIR, no further response is necessary.
Response A3-6
This comment expresses Caltrans’ support of the Project’s inclusion of short- and long-term bike parking.
This comment is noted. Given that the comment does not raise any specific issues regarding the content or adequacy of the Draft EIR, no further response is necessary.
Response A3-7
The comment requests that appropriate safety measures and clearly signed detours be provided for bicyclists, pedestrians, and transit users during construction, and recommends the use of "May Use Full Lane" (MUTCD R4-11) signage for any temporary bike lane closures. The comment is acknowledged and will be forwarded to the appropriate City staff and the Property Owner/Developer for consideration during final design and construction planning. Given that the comment does not raise any specific issues regarding the content or adequacy of the Draft EIR, no further response is necessary.
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Response A3-8
The commenter requests information on how freight vehicles currently serve the existing retail center and how the Project may affect truck turning movements or goods delivery logistics. This comment is noted; however, the comment does not raise a significant environmental issue or identify a deficiency in the Draft EIR under CEQA. Because the comment does not relate to the adequacy or accuracy of the environmental analysis, no further response is required under CEQA. Nonetheless, as noted in the Draft EIR, the Project would be subject to City design review and must comply with applicable standards to ensure that circulation and loading access remain adequate. No revisions to the Draft EIR are required in response to this comment.
Response A3-9
The commenter requests that a commercial truck circulation plan be provided, including turning templates (e.g., WB-50), identification of off-street loading zones, and confirmation that truck movements will not conflict with high pedestrian activity or parking areas. The commenter also requests confirmation that updated driveway designs will support both multimodal access and freight compatibility.
This comment is acknowledged; however, the comment does not raise a significant environmental issue under CEQA or identify a deficiency in the Draft EIR. Rather, it pertains to site-level design and operational considerations that fall within the scope of the City’s development review and permitting process.
Nonetheless, the Project would be required to comply with applicable City design standards related to circulation, driveway design, and loading access.
Response A3-10
The commenter requests that the Caltrans Freight-Focused Land Use Compatibility Planning Matrix be used to evaluate whether the Project’s modified land use mix may conflict with regional freight operations, given the Project’s location within a commercial area currently served by freight activity. This comment is acknowledged. The Freight-Focused Land Use Compatibility Planning Matrix is a planning guidance tool developed by Caltrans to assist local jurisdictions in considering freight compatibility when introducing new sensitive uses near freight corridors or facilities. However, the matrix is not a CEQA significance threshold or regulatory standard, and its application is not required under CEQA.
The Project would not directly interfere with regional freight infrastructure such as rail lines, intermodal facilities, or designated truck routes. The Project would be required to comply with City land use and circulation policies that ensure safe and compatible site design, including setbacks, screening, and internal circulation plans that minimize potential conflicts between residential uses and commercial loading areas.
Furthermore, the Project site is not located adjacent to heavy industrial or high-frequency freight operations that would typically present elevated land use compatibility concerns. The City retains land use authority to determine appropriate zoning and site planning approaches, and no evidence has been presented that the Project would result in a significant land use conflict under CEQA. Therefore, no revisions to the Draft EIR are required in response to this comment.
Response A3-11
The commenter requests that the EIR include a policy consistency analysis with SCAG’s Goods Movement Appendix and Caltrans’ freight strategies, particularly regarding retail centers near regional highway corridors. This comment is noted. However, the comment does not raise a significant environmental issue or identify a deficiency in the Draft EIR under CEQA. The EIR includes consistency analysis with applicable land use and transportation plans, including SCAG’s Connect SoCal 2024, as required by State CEQA Anaheim Hills Festival Specific Plan Amendment Project Section 2.0 Final Environmental Impact Report Response to Comments
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Guidelines §15125 and §15126.2(d). The Project would introduce 447 multiple-family dwelling units to an existing commercial center and would maintain access to regional highway corridors, and would not impede goods movement or freight operations. Site access and circulation would comply with City standards to support safe and efficient freight and vehicle movement. No revisions to the Draft EIR are required in response to this comment.
Response A3-12
The commenter recommends that, if future analysis identifies significant impacts on State transportation facilities, the City coordinate with Caltrans District 12 Local Development to prepare a Traffic Mitigation Agreement or similar mechanism.
This comment is acknowledged. However, the comment does not raise a new significant environmental issue or identify a deficiency in the Draft EIR. Should future refinements to the Project or subsequent review identify new or more severe impacts on State facilities, the City and the Property Owner/Developer will coordinate with Caltrans as appropriate, including consideration of a Traffic Mitigation Agreement if warranted. No revisions to the Draft EIR are required in response to this comment.
Response A3-13
The commenter provides information regarding Caltrans requirements for any work within the State rightof-way, including the need for discretionary review, an encroachment permit, and completion of the QMAP Checklist (Form TR-0416) to determine whether coordination with a Caltrans Project Manager is necessary. The commenter also outlines submittal requirements for the Encroachment Permit Application Package through the Caltrans Encroachment Permit System.
This comment is acknowledged. However, the comment does not raise a significant environmental issue or identify a deficiency in the Draft EIR. The Project does not propose any construction or improvements within Caltrans right-of-way and therefore would not require an encroachment permit. Should future design modifications result in any work within the State right-of-way, the Property Owner/Developer would be required to obtain all necessary permits and approvals from Caltrans or any other applicable agency. The information provided will be included in the administrative record and shared with the Property Owner/Developer for reference. No revisions to the Draft EIR are required in response to this comment.
Response A3-14
The commenter provides detailed guidance regarding Caltrans submittal requirements for any future encroachment permit, including the need for plans to be signed and stamped by a licensed engineer, clear labeling of Caltrans right-of-way features, and inclusion of supporting documents such as environmental clearance documentation, traffic control and management plans, drainage and construction plans, and certifications as applicable.
This comment is acknowledged. However, the comment does not raise a significant environmental issue or identify a deficiency in the Draft EIR. As noted previously, the Project does not propose any work within Caltrans right-of-way and therefore does not require an encroachment permit. If future design modifications involve work within the State right-of-way, the Property Owner/Developer will be required to prepare and submit all necessary plans and documentation in accordance with Caltrans’ permit requirements and review process. The information provided will be forwarded to the Property Anaheim Hills Festival Specific Plan Amendment Project Section 2.0 Final Environmental Impact Report Response to Comments
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Owner/Developer for consideration during final design and permitting. No revisions to the Draft EIR are required in response to this comment.
Response A3-15
The commenter refers to Table 4-1 on page 33 of the Traffic Impact Analysis (Appendix 4.17-2 of the Draft EIR) and requests that trip generation rates for other land uses be shown for reference alongside the Project. This comment is acknowledged. However, the comment does not raise a significant environmental issue under CEQA or identify a deficiency in the Draft EIR. The requested comparative rates for existing or previously entitled uses are not required for determining significance under CEQA but may be reviewed in supporting technical documents or provided during future design or planning review, if relevant. No revisions to the Draft EIR are required in response to this comment.
Notwithstanding, to be responsive to this comment, the trip generation rate for the shopping center has been added to Table 4-1; however, no rates are provided for the Cinema. As noted in the footnote in Table 4-3, the trips associated with the Cinema are taken directly from the prior referenced study. The complete revised Traffic Analysis is provided as Appendix D.
Land Use1 ITE
LU
Code
Units2
AM Peak Hour PM Peak Hour Daily
In Out Total In Out Total
Multifamily (Mid-Rise)
Residential 221 DU 0.09 0.28 0.37 0.24 0.15 0.39 4.54
Shopping Center >150,000 SF 820 TSF 0.52 0.32 0.84 1.63 1.77 3.40 37.01 1 Trip Generation Source: Institute of Transportation Engineers (ITE), Trip Generation Manual, Eleventh Edition (2021) 2 DU = Dwelling Units; TSF = Thousand Square Feet Response A3-16
The commenter requests that the traffic movement and volume exhibits be revised to remove any turning movements that do not physically exist at study intersections, such as at Intersections #13 and #14, because it is difficult to distinguish between movements with zero volume and those that are not present due to geometric constraints. This comment is acknowledged. The comment does not raise a significant environmental issue under CEQA or identify a deficiency in the Draft EIR’s traffic analysis. CEQA does not require the removal of unused turning movements from volume exhibits for purposes of determining traffic-related impact significance.
Notwithstanding, to enhance clarity and to be responsive to the commenter’s request, the traffic volume exhibits have been updated to remove northbound left-turn and southbound left-turn movements at ramp intersections that do not physically exist (previously shown with zero volumes). This correction has been applied to all ramp locations (four intersections total) in the study area. The revisions are reflected in all updated traffic volume exhibits in the Traffic Analysis, which is included in its entirety as Appendix D to this Final EIR. These corrections do not alter the technical analysis, conclusions, or significance determinations presented in the Draft EIR. Therefore, no revisions to the Draft EIR text are required under State CEQA Guidelines §§15088.
Response A3-17
The commenter refers to Table 4-3 on page 34 of the Traffic Impact Analysis and requests verification that trip credits associated with the former cinema use were not double counted, particularly if the Opening Year traffic volumes already account for existing conditions with the vacant cinema. This comment is Anaheim Hills Festival Specific Plan Amendment Project Section 2.0 Final Environmental Impact Report Response to Comments
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acknowledged. As described in the Traffic Impact Analysis, the trip generation data in Table 4-3 is provided for informational purposes only to facilitate comparison between the Project and the entitled use scenario. Because the cinema was vacant at the time of the traffic counts and analysis, no trip credits were applied for that use. For purposes of the near-term and long-range traffic forecasts, the trip generation shown for the Project in Table 4-2 was applied, without any adjustment for the prior cinema use.
Accordingly, the analysis does not double-count trips associated with the former cinema use, and the methodology is consistent with standard traffic engineering practice and CEQA requirements. No revisions to the Draft EIR are required in response to this comment.
Response A3-18
The commenter refers to Section 4.7 on page 42 of the Traffic Impact Analysis (Appendix 4.17-2 of the Draft EIR) and requests verification of whether any existing land uses on the Project site were vacant during the 2024 traffic counts. The commenter notes that additional trip credits should not be applied and states that a significant amount of trip credit was taken during the PM peak hour and daily periods.
Please refer to Response A3-17. No revisions to the Draft EIR are required in response to this comment.
Response A3-19
The commenter requests correction of a labeling error in footnote 3, changing “I-215” to “SR-91,” and verification of all related tables. This comment is acknowledged. The comment does not raise a significant environmental issue or identify a deficiency in the Draft EIR, but the correction is noted. The labeling of “I-215” in footnote 3 is a typographical error; it should reference “SR-91.” The Traffic Engineer has revised the affected footnote in Table 6-3 and verified that all related tables are accurate. This correction is minor and does not affect the analysis or conclusions of the EIR. No revisions to the Draft EIR are required in response to this comment.
Response A3-20
The commenter requests clarification regarding the baseline year used in the VMT analysis, noting an apparent reference to “linear interpolation” and questioning the years reflected in the baseline and cumulative scenarios. This comment is acknowledged. The reference to “linear interpolation” in the VMT analysis was a typographical error and has been removed. This clarification does not affect the methodology, results, or conclusions of the Draft EIR. As stated in the City of Anaheim Traffic Impact Analysis Guidelines (page 8), “Baseline” and “Baseline plus Project” conditions reflect information contained in the Orange County Transportation Analysis Model (OCTAM) base year model run. This reference is provided in the footnote to Table 2 of the VMT Analysis. For the VMT analysis, all references to “baseline” correspond to the 2016 OCTAM base year. The corrected VMT Analysis is provided as Appendix E of this Final EIR. No further response is required.
Response A3-21
The commenter requests that the source and publication date of the “Handbook” cited on page 7 of the VMT Analysis be provided for reference. This comment is acknowledged. However, the comment does not raise a significant environmental issue or identify a deficiency in the Draft EIR, but clarification is provided for completeness.
The cited “Handbook” refers to the California Air Pollution Control Officers Association (CAPCOA) Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity (December 2021), as noted on page 5 of the VMT Analysis Report. No revisions to the Draft EIR are required in response to this comment.
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Response A3-22
The commenter asks for the average U.S. residential density and a comparison with the Project’s density to support the use of CAPCOA Measure T-1. According to the 2021 CAPCOA Handbook, the national average residential density is 9.1 dwelling units per acre. The Project proposes 447 units on approximately
16.2 acres, resulting in a residential density of about 28 units per acre, significantly higher than the national average and consistent with the intent of Measure T-1. As stated in the VMT Analysis, the Project’s land use inputs were incorporated into the OCTAM model, and any associated VMT-reducing effect from higher residential density is already reflected in the modeled VMT estimates shown in Table
4. No additional VMT reduction credit was applied. No changes to the Draft EIR are required in response to this comment.
Response A3-23
The commenter encourages continued coordination with Caltrans for any future development that may affect State transportation facilities and provides contact information for further inquiries. This comment is acknowledged. However, the comment does not raise a significant environmental issue or identify a deficiency in the Draft EIR. The City and the Property Owner/Developer will continue to coordinate with Caltrans, as appropriate, to ensure compliance with applicable requirements for any future improvements that may affect State facilities. No changes to the Draft EIR are required in response to this comment.
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2.3.2 COMMENT LETTERS AND RESPONSES: ORGANIZATIONS (B)
Comment Letter B1 – Supports Alliance for Environmental Responsibility (SAFER), June 30, 2025 Response B1-1
On June 30, 2025, Chase Preciado, Legal Assistant at Lozeau Drury LLP, submitted an email on behalf of the Supporters Alliance for Environmental Responsibility (SAFER), transmitting a comment letter on the Draft EIR for the Project. The email requests confirmation of receipt and does not raise additional substantive CEQA issues beyond those included in the attached letter. The City acknowledges receipt of the June 30, 2025, email and attached comment letter from Lozeau Drury LLP on behalf of SAFER. As required by State CEQA Guidelines §15088, a written response to the substantive comment in the attached letter is provided in this Final EIR (see Response to Comment B1-2). No further response to the transmittal email is required.
Response B1-2
Lozeau Drury LLP submitted this comment on behalf of SAFER, expressing concern that the Draft EIR for the Project fails to serve as an adequate informational document under CEQA and fails to impose all feasible mitigation measures to reduce project impacts. The commenter requests that the City prepare and recirculate a revised Draft EIR and reserves the right to supplement its comments during the administrative process. The City acknowledges this general comment. State CEQA Guidelines §15151 establishes that an EIR should be prepared with sufficient detail to allow the public and decision-makers to understand the significant effects of a proposed project. The Draft EIR complies with this standard by disclosing potentially significant environmental impacts, identifying feasible mitigation measures, and providing substantial evidence in support of its conclusions. The document is also supported by comprehensive technical studies addressing air quality, greenhouse gas emissions, noise, transportation, biological resources, and other environmental issues.
As this comment does not raise specific factual, technical, or legal deficiencies with the analysis or mitigation measures presented in the Draft EIR, no revisions or recirculation are required. Under State CEQA Guidelines §15088.5, recirculation is only required when significant new information is added to the EIR after public review, which is not the case here. The City remains open to receiving and considering additional comments submitted during the CEQA process and will ensure that all public input is addressed in accordance with CEQA. No changes to the Draft EIR are required in response to this comment.
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Comment Letter B2 – Western States Regional Council of Carpenters Response B2-1
The commenter, the Western States Regional Council of Carpenters (WSRCC), provides introductory remarks summarizing the Project description and expressing general interest in environmental review and proper land use planning. The commenter reserves the right to supplement its comments at or before future hearings, incorporates by reference all other comments submitted on the Draft EIR prior to certification, and requests to receive future CEQA and Planning and Zoning Law notices.
This comment is acknowledged. As of the close of the public review period, this is the only comment letter received from WSRCC. No specific environmental issue or alleged deficiency in the Draft EIR is raised in this portion of the letter. The City will add WSRCC to the mailing list for all future CEQA notices related to the Project in accordance with Public Resources Code §§21092.2 and 21167(f), and Government Code §65092. No revisions to the Draft EIR are required in response to this comment.
Response B2-2
The commenter encourages the City to require the use of a local, state-certified workforce and cites potential environmental and economic benefits, including reduced greenhouse gas (GHG) emissions and VMT. This comment is acknowledged. CEQA does not require analysis of labor practices unless their absence would result in a significant physical environmental impact. The Draft EIR evaluates GHG and VMT impacts using standard modeling assumptions and does not rely on workforce location or training status for its conclusions. Local hire provisions may be considered by the City as part of project approvals, but are outside the scope of CEQA. No revisions to the Draft EIR are required in response to this comment.
Response B2-3
The commenter requests that the City require detailed infectious disease prevention protocols and training during construction, including COVID-19 screening procedures and the use of workers trained in Infection Control Risk Assessment (ICRA) protocols.
This comment is acknowledged. As of the time of this Final EIR, there are no active statewide or local emergency declarations related to COVID-19, and the California Department of Public Health has lifted nearly all pandemic-era mandates. CEQA does not require the imposition of specific occupational health and safety measures unless their absence would result in a significant physical environmental impact. The Draft EIR fully evaluates construction-related impacts, including air quality and health risk, and identifies mitigation measures where appropriate. The Project will comply with all applicable worker health and safety regulations, including those administered by Cal/OSHA. Any additional health and safety protocols adopted by the contractor or required by the City through its permitting authority are beyond the scope of CEQA. No revisions to the Draft EIR are required in response to this comment.
Response B2-4
The commenter provides a summary of CEQA requirements, including legal standards for EIRs, the fair argument test, and the conditions under which recirculation is required. The commenter asserts that the Draft EIR fails to substantiate its conclusions, does not fully assess environmental impacts, and lacks sufficient mitigation measures, and therefore must be revised and recirculated.
This comment is acknowledged. However, it does not identify a specific factual or analytical deficiency in the Draft EIR. The Draft EIR was prepared in full compliance with CEQA, including the requirements for disclosure, analysis, and mitigation of significant environmental impacts. Substantial evidence supports Anaheim Hills Festival Specific Plan Amendment Project Section 2.0 Final Environmental Impact Report Response to Comments
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the impact conclusions, and mitigation measures have been identified and incorporated where required.
As no significant new information has been presented that would trigger the need for recirculation under State CEQA Guidelines §15088.5, no revisions or recirculation of the Draft EIR are required in response to this comment.
Response B2-5
The commenter asserts that the Draft EIR fails to support its conclusions with substantial evidence and must be revised and recirculated under CEQA. The commenter references legal standards related to significance thresholds, mitigation requirements, and evidentiary support for EIR findings, but does not identify any specific impact area where the DEIR's analysis is deficient.
This comment is acknowledged. The Draft EIR was prepared consistent with State CEQA Guidelines and includes substantial evidence to support its findings and conclusions. The analysis relies on scientific and factual data, technical studies, modeling tools, and agency-adopted thresholds to determine significance and to identify feasible mitigation measures. The Draft EIR does not dismiss any potentially significant effects without explanation or evidentiary support. To the extent that subsequent comments raise specific concerns about particular issue areas, responses are provided below. However, the general assertion that the Draft EIR lacks substantial evidence does not, on its own, demonstrate a need for revision or recirculation under State CEQA Guidelines §15088.5. No changes to the Draft EIR are required in response to this comment.
Response B2-6
The commenter raises concerns regarding the adequacy of the Draft EIR’s construction noise analysis.
Specifically, the commenter claims that the EIR misapplies the City’s Noise Ordinance by using a 60 dBA threshold rather than the 65 dBA CNEL standard in Anaheim Municipal Code (AMC) Section 18.40.090, and that the noise analysis underestimates impacts at receptors R3 and R4 due to the placement of monitoring equipment. However, the commenter also references language and receptor locations (e.g., residences along North La Brea Avenue) that are not part of this Project or EIR, and appear to be taken from a different project entirely. Those portions of the comment are not applicable and are not addressed further.
With respect to the commenter’s claim that the EIR misapplies the City’s Noise Ordinance by using a 60 dBA threshold rather than the 65 dBA CNEL standard set forth in Anaheim Municipal Code Section
18.40.090, the commenter is incorrect in the applicability of this noise standard as the Project site is not located within 600 feet of any railroad, freeway, expressway, major arterial, primary arterial or secondary arterial, as designated by the General Plan Circulation Element. Further, while the City’s Noise Ordinance establishes a noise level limit of 60 dBA, Anaheim Municipal Code Section 6.70.010 exempts construction activities from the City’s noise standards between the hours of 7:00 AM and 7:00 PM. The Draft EIR includes modeled construction noise levels at representative receptors, including R3 and R4, and acknowledges that temporary exceedances may occur. However, these exceedances would be shortterm, intermittent, and restricted to the City’s allowed construction hours under Anaheim Municipal Code Section 6.70.010. Therefore, construction noise impacts were determined to be less than significant, and no mitigation is required.
In conclusion, the commenter has not provided substantial evidence that the modeling or measurement locations were improper or that the analysis fails to capture representative conditions. No revisions to the Draft EIR are required in response to this comment.
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Response B2-7
The commenter asserts that the Draft EIR fails to adequately evaluate impacts to nesting birds and that reliance on Regulatory Compliance Measure (RCM) BIO-1 is insufficient.
As discussed in Section 4.4 of the Draft EIR, the Project site is fully developed and supports ornamental vegetation but no native habitat or special-status species. The Draft EIR acknowledges the potential for existing trees to support nesting migratory birds protected under the Migratory Bird Treaty Act (MBTA) and California Fish and Game Code (CFGC) and concludes that compliance with applicable wildlife protection laws will avoid significant impacts.
RCM BIO-1 requires a qualified biologist to conduct pre-construction nesting bird surveys and prepare a Nesting Bird Plan with protective buffers if active nests are found. While the measure identifies February– August as the typical nesting season, it does not preclude surveys or protections outside that period. The requirement applies regardless of timing. RCM BIO-1 is included in both the Project’s Mitigation Monitoring Program (MMP) and as a condition of approval. It is therefore fully enforceable pursuant to State CEQA Guidelines §15097 and Public Resources Code §21081.6.
CEQA allows lead agencies to rely on compliance with existing regulations where supported by substantial evidence (State CEQA Guidelines §15064(d)). The Draft EIR provides such evidence here. The comment does not present substantial evidence of a potentially significant impact not already addressed in the DEIR. Therefore, no additional mitigation or recirculation is required.
Response B2-8
The commenter asserts that the Draft EIR fails to adequately analyze or mitigate potential biological resources impacts associated with the proposed removal of 211 on-site trees, and that the City’s reliance on compliance with the local Tree Preservation Ordinance is insufficient under CEQA.
As discussed in Section 4.4 of the Draft EIR and the Specimen Tree Report (Appendix 4.4-1 of the Draft EIR), the Project site is developed with ornamental landscaping and does not contain native vegetation, riparian habitat, or special-status species. The biological resources analysis appropriately focuses on potential impacts to nesting birds protected under the MBTA and CFGC, which are addressed through implementation of RCM BIO-1. This regulatory compliance measure requires pre-construction surveys and protective buffers, if needed, and is included in the Project’s MMP and as a condition of approval, ensuring enforceability under State CEQA Guidelines §15097 and Public Resources Code §21081.6.
The commenter is correct that the Project proposes removal of 211 trees; however, as documented in the Specimen Tree Report, none of the trees meet the City’s definition of “specimen trees” and are therefore not subject to mandatory replacement under the City’s Tree Preservation Ordinance. The Draft EIR discloses this regulatory framework and correctly concludes that removal of these trees would not result in significant impacts to biological resources as defined under CEQA. CEQA does not require mitigation for aesthetic or non-biological concerns unless those features support habitat for protected species, which is not the case here.
The Draft EIR’s conclusions are supported by substantial evidence, and no new information or analysis is required to demonstrate compliance with CEQA. Therefore, no revisions or recirculation of the Draft EIR are warranted in response to this comment.
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Response B2-9
The commenter generally asserts that the Draft EIR fails to include adequate mitigation measures but does not identify any specific impact or mitigation measure that is deficient. As such, the comment does not raise a significant environmental issue or provide substantial evidence requiring further response under State CEQA Guidelines §15088. The Draft EIR meets CEQA’s requirements by identifying all significant environmental impacts and proposing specific, feasible, and enforceable mitigation measures or regulatory compliance measures. All measures are included in the Project’s MMP and will be imposed as conditions of approval. No mitigation is improperly deferred, and all measures include performance standards consistent with State CEQA Guidelines §15126.4. No revisions to the Draft EIR are required in response to this comment.
Response B2-10
The commenter generally asserts that the Draft EIR’s mitigation measures are improperly deferred. This assertion is unfounded. As required by State CEQA Guidelines §15126.4(a)(1)(B), the Draft EIR includes enforceable mitigation measures that clearly specify performance standards, identify the responsible implementing party, and establish the timing and method of implementation. The City has not deferred formulation of mitigation; rather, where project-specific implementation details may depend on future conditions (e.g., biological pre-construction surveys, preparation of construction management plans), the Draft EIR includes clearly defined performance criteria that must be met, subject to City review and approval. These are not instances of unlawful deferral, but rather consistent with well-established CEQA precedent allowing limited deferral where full formulation of the measure is impractical at the time of EIR preparation. Moreover, all mitigation measures have been incorporated into the Project’s MMP in accordance with Public Resources Code §21081.6 and will be imposed as conditions of approval. The City has therefore committed itself to the implementation of all feasible mitigation necessary to avoid or substantially lessen the Project’s significant impacts. Accordingly, the Draft EIR complies with CEQA’s requirements for enforceable and effective mitigation. No revisions to the Draft EIR are required in response to this comment.
Response B2-11
The commenter asserts that Mitigation Measure (MM) CUL-2 in the Draft EIR improperly defers formulation of cultural resource mitigation procedures and precludes meaningful public and agency review. However, this assertion is based on a misreading of the Draft EIR. There is no “Mitigation Measure CUL-2” included in the Draft EIR or the MMP for the Project. The sole mitigation measure addressing cultural resources is identified as MM CUL-1, which appears in Section 4.5.5 of the Draft EIR (see p. 4.5- 11) and is fully incorporated into the MMP as an enforceable measure.
MM CUL-1 is consistent with State CEQA Guidelines §15126.4(a)(1)(B), which allows lead agencies to adopt mitigation that includes performance standards and specifies procedures to be followed in the event of an unanticipated discovery of archaeological resources. MM CUL-1 does not constitute improper deferral. Rather, it (1) commits the Property Owner/Developer to archaeological monitoring during grading in undisturbed soils, (2) requires that work be halted in the event of a find, and (3) mandates treatment and evaluation in accordance with Public Resources Code §21083.2 and State CEQA Guidelines §15064.5. These procedures ensure compliance with CEQA’s requirements for treatment of unique archaeological resources and are consistent with established CEQA practice.
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While the commenter argues that the Draft EIR fails to provide sufficient detail to assess the measure’s effectiveness, CEQA does not require that all implementation details be known or finalized at the time of EIR certification. Courts have repeatedly held that performance-based mitigation is permissible where further site-specific detail is not feasible at the time of environmental review and the measure ensures enforceability and effectiveness. (Oakland Heritage Alliance v. City of Oakland (2011) 195 Cal.App.4th 884, 906; Defend the Bay v. City of Irvine (2004) 119 Cal.App.4th 1261, 1275.) Because the commenter misidentifies the mitigation measure and MM CUL-1 complies with CEQA both procedurally and substantively, no revisions to the Draft EIR are required.
Response B2-12
The commenter contends that MM GEO-1 and MM GEO-2 improperly defer mitigation and fail to meet CEQA’s standard for enforceable and specific mitigation. MM GEO-1 requires that all project grading, foundation, structural, and related construction plans be reviewed by the City of Anaheim’s Building Division and Public Works Department for compliance with the recommendations contained in the Project’s Geotechnical Exploration and Feasibility Report (Appendix 4.7-1 of the Draft EIR). The referenced report provides site-specific design recommendations based on subsurface investigation and laboratory testing, including seismic ground shaking, expansive soils, foundation and retaining wall design, and slope stability. These recommendations are specific and tailored to the site’s geologic conditions and are intended to ensure that geologic hazards are appropriately addressed. Incorporating these recommendations into construction plans, subject to review and approval by City departments prior to issuance of grading and building permits, constitutes a standard and legally acceptable form of mitigation under CEQA. Courts have repeatedly upheld the adequacy of mitigation measures that require adherence to the recommendations of a technical study prepared for the project, where those recommendations are specific, performance-based, and subject to implementation through subsequent permit review and conditions of approval. (See San Franciscans Upholding the Downtown Plan v. City and County of San Francisco (2002) 102 Cal.App.4th 656, 695.) MM GEO-1 is not an open-ended or speculative commitment; it incorporates specific engineering recommendations based on substantial evidence and ensures their enforceable application during project construction. The measure is also included in the Draft EIR’s MMP and will be incorporated as a condition of approval, ensuring implementation and enforceability.
MM GEO-2 similarly meets CEQA’s requirements for mitigation of potential impacts to paleontological resources. The measure requires that in the event of inadvertent discovery of such resources, the contractor must cease all earth-disturbing activities within a 50-foot radius, and a qualified paleontologist must evaluate the find and determine an appropriate course of action. The measure provides a clear protocol, including avoidance where feasible and salvage where necessary. This approach is consistent with State CEQA Guidelines §15064.5 and has been upheld as an appropriate mitigation strategy for unanticipated discoveries of subsurface resources. (See Oakland Heritage Alliance v. City of Oakland (2011) 195 Cal.App.4th 884, 906)
Both MM GEO-1 and MM GEO-2 are supported by substantial evidence, contain clear performance standards, and are enforceable through the City’s MMP and permit conditions. They are consistent with CEQA and do not constitute unlawful deferral. Accordingly, no revisions to the Draft EIR are required in response to this comment.
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Response B2-13
The commenter asserts that MM HAZ-1 improperly defers mitigation by requiring the Construction Management Plan (CMP) to be prepared prior to grading permit issuance, rather than during the environmental review process. This argument misstates the legal standards applicable to mitigation under CEQA and misconstrues the nature and function of MM HAZ-1. MM HAZ-1 requires the Property Owner/Developer to prepare a CMP in coordination with Anaheim Fire & Rescue and in accordance with the Manual on Uniform Traffic Control Devices (MUTCD) prior to issuance of grading permits. The CMP must identify emergency access points and routes throughout all construction phases. The measure clearly specifies the timing of compliance, identifies the responsible reviewing agency, and imposes enforceable performance standards related to emergency access. It is also included in the Project’s MMP, ensuring that its implementation is subject to monitoring and enforcement by the Lead Agency. Contrary to the commenter’s claim, CEQA does not prohibit all instances in which the details of a mitigation measure are finalized after certification of an EIR. State CEQA Guidelines §15126.4(a)(1)(B) expressly allows deferral of the specific design or implementation of a mitigation measure where it is impractical or infeasible to provide full detail at the time of environmental review, so long as the agency commits to the performance of mitigation and articulates performance standards and a process for ensuring compliance. (See Oakland Heritage Alliance v. City of Oakland (2011) 195 Cal. App.4th 884, 906; Defend the Bay v. City of Irvine (2004) 119 Cal. App.4th 1261, 1275.) MM HAZ-1 satisfies these standards. It commits the Property Owner/Developer to the preparation of a CMP consistent with applicable safety standards, subject to review and approval by the City’s emergency services agency, and prior to any physical site disturbance.
The requirement to prepare a CMP prior to grading permits is consistent with standard practice for construction-phase mitigation and allows site-specific conditions and construction phasing plans to be incorporated into the CMP in coordination with the City’s permitting authorities. This approach ensures a more effective and implementable mitigation strategy than a generalized plan prepared during CEQA review.
In addition, the Project’s Fire Protection Plan (Appendix 4.9-3 of the Draft EIR) and Evacuation Travel Time Analysis (Appendix 4.9-2 of the Draft EIR) provide further analysis and evidence supporting the adequacy of emergency access and hazard mitigation under the proposed development scenario. These documents reinforce the conclusion that MM HAZ-1, when implemented in combination with regulatory requirements and other mitigation measures, will reduce potential hazards-related impacts to a less-thansignificant level. Accordingly, MM HAZ-1 does not constitute an improper deferral of mitigation. It is legally adequate under CEQA, enforceable through the MMP, and no revisions or recirculation of the Draft EIR are required in response to this comment.
Response B2-14
The commenter asserts that the Draft EIR improperly classifies mitigation measures as Project Design Features (PDFs), specifically PDFs HAZ-1 and HAZ-2 (fire safety and evacuation plans) and PDFs TRANS-1 and TRANS-2 (VMT reduction strategies), and thereby unlawfully avoids the duty to adopt and analyze mitigation under CEQA. This assertion is not supported by CEQA law or the substantial evidence in the administrative record. As a threshold matter, CEQA allows lead agencies to consider a project’s design features, including applicant-proposed actions that avoid or reduce impacts, as part of the impact analysis and significance determination. State CEQA Guidelines §15126.4(a)(1)(A) expressly states that:
“Mitigation measures are not required for effects which are not found to be significant. Measures which are required as part of the project design should be distinguished from measures which are proposed to minimize significant effects.” Here, the Project Design Features were proposed by the Property Anaheim Hills Festival Specific Plan Amendment Project Section 2.0 Final Environmental Impact Report Response to Comments
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Owner/Developer as components of the Project and are part of the Project Description. They were not formulated in response to a finding of significant impact and were not relied upon to reduce impacts to a less-than-significant level. As such, they are appropriately characterized as PDFs.
PDF HAZ-1, the Construction Fire Prevention Plan, is a standard fire safety protocol required by Anaheim Fire & Rescue for large-scale construction sites in wildland-urban interface areas. It outlines best management practices to prevent accidental ignition during site disturbance and building activities. The Draft EIR does not rely on PDF HAZ-1 to mitigate a significant hazard impact under CEQA. Rather, the Draft EIR concludes, based on substantial evidence, including consultation with the City's emergency services departments and compliance with California Fire Code access and suppression requirements, that the Project would not expose people or structures to a significant wildfire hazard or impair an adopted emergency response or evacuation plan. This conclusion is supported by the Evacuation Travel Time Analysis (Appendix 4.9-2 of the Draft EIR), the Fire Protection Plan (Appendix 4.9-3 of the Draft EIR), and the Project’s code-compliant emergency access design described in Section 4.9 of the Draft EIR.
PDF HAZ-2, the Wildfire Evacuation and Awareness Plan, further supplements emergency preparedness through public education, tenant communication protocols, and on-site alert systems. It is not a mitigation measure to reduce physical impacts; it serves a planning and communication function and is not tied to any quantified evacuation travel time threshold or deficiency. As the Draft EIR explains, under both modeled evacuation scenarios (i.e., Deer Canyon Park Preserve and SR-91/SR-241 Interchange) the Project would result in evacuation travel time increases (14–22 minutes) that are not considered significant under CEQA, particularly because: (1) the City has not adopted a quantitative threshold of significance for evacuation travel time; (2) the analysis was conservatively modeled as a full-capacity, unassisted evacuation; and (3) the Anaheim Police Department and Anaheim Fire & Rescue confirmed that the Project does not necessitate modifications to the existing Know Your Way program or present a conflict with adopted plans.
Similarly, PDF TRANS-1 (affordable housing) and PDF TRANS-2 (reduced parking) are not mitigation measures designed to reduce otherwise significant transportation impacts. As shown in the VMT analysis (Appendix 4.17-2 of the Draft EIR), the Project achieves a per capita VMT that is 10.4 percent below the City’s baseline average. No additional credit is assumed from either PDF, and they are not needed to reach a less-than-significant conclusion under State CEQA Guidelines §15064.3(b).
The commenter’s reliance on Lotus v. Department of Transportation (2014) 223 Cal.App.4th 645 is misplaced. That case held that measures essential to a less-than-significant impact determination must be treated as mitigation under CEQA. In contrast, the Project’s Project Design Features are not required to avoid or reduce a significant impact but rather reflect voluntary design elements that exceed regulatory requirements and are not necessary to support the Draft EIR’s less-than-significant impact findings. The Project Design Features in question were not adopted to mitigate a significant effect, are not relied upon to reduce an otherwise significant impact to less-than-significant and were appropriately included in the Project description and environmental analysis. No recirculation or revisions are required.
Response B2-15
The commenter asserts that the Draft EIR is legally inadequate under CEQA and must be revised and recirculated. They claim the document fails to support its conclusions with substantial evidence and improperly defers or mischaracterizes mitigation measures. The City acknowledges the commenter’s concerns but disagrees that recirculation of the Draft EIR is required. As detailed in the responses above, Anaheim Hills Festival Specific Plan Amendment Project Section 2.0 Final Environmental Impact Report Response to Comments
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the Draft EIR complies with CEQA’s procedural and substantive requirements. It discloses potentially significant environmental effects, supports its conclusions with substantial evidence in the record— including modeling, technical studies, and expert input—and identifies all feasible mitigation measures where necessary. The commenter has not presented new significant information or substantial evidence that would trigger recirculation under State CEQA Guidelines §15088.5. Accordingly, the Draft EIR remains legally adequate, and no revisions or recirculation are required in response to this comment.
2.3.3 COMMENT LETTERS AND RESPONSES: INDIVIDUALS (C)
Comment Letter C1 – Rich Fagner, June 20, 2025
Response C1-1
The commenter expresses general opposition to the size of the Project and raises concerns about emergency evacuation capacity in the surrounding area. The commenter states that emergency evacuation is already difficult and that adding hundreds of new residents would worsen this condition by increasing pressure on already strained streets. The commenter urges the City to consider these factors when evaluating the scale of the Project.
The comment regarding evacuation concerns is acknowledged. However, this comment does not address the Draft EIR’s adequacy or raise a significant environmental issue. As such, no further response is necessary. Nonetheless, in the interest of public transparency and responsiveness, the City provides the following clarification.
As described in Draft EIR Section 4.9, Hazards and Hazardous Materials, and supported by technical studies in Draft EIR Appendices 4.9-2 (Evacuation Travel Time Analysis) and 4.15-3 (Fire Protection Plan), the Project site is located within a Very High Fire Hazard Severity Zone (VHFHSZ). Accordingly, the EIR includes a robust evaluation of wildfire and evacuation-related risks. The Evacuation Travel Time Analysis modeled a worst-case evacuation scenario under “Existing without Project,” “Existing with Cinema,” and “With Project” conditions. As shown in Draft EIR Table 4.9-1, the modeled evacuation travel time for the Deer Canyon Park Preserve neighborhood increases by approximately 14 minutes with the Project, compared to existing conditions. This is a 7-minute increase compared to the Project site’s former use as a cinema.
The analysis concludes that this increase would not substantially impair the ability of residents to evacuate in the event of an emergency.
In addition, the Project includes multiple design features and regulatory compliance measures that further reduce potential risk. Project Design Feature (PDF) HAZ-1 requires the preparation and implementation of a Construction Fire Prevention Plan, which must be reviewed and approved by Anaheim Fire & Rescue prior to construction. PDF HAZ-2 requires a Wildfire Evacuation and Awareness Plan to be implemented prior to occupancy. This plan includes tenant-facing evacuation guidance, public alert systems (such as a PA system or emergency texting service), and annual emergency drills. These proactive features exceed what is typically required under CEQA and serve to enhance emergency preparedness at the Project site.
Finally, Mitigation Measure (MM) HAZ-1 requires the preparation of a Construction Management Plan that ensures emergency vehicle access and fire lane clearance during all phases of construction. This plan must be reviewed and approved by Anaheim Fire & Rescue prior to the commencement of construction.
Together, these measures demonstrate that the Project would not expose people or structures to a significant risk of loss, injury, or death involving wildland fire beyond existing conditions, nor would it impair implementation of the City’s Emergency Operations Plan, Local Hazard Mitigation Plan (“Be Ready Anaheim Hills Festival Specific Plan Amendment Project Section 2.0 Final Environmental Impact Report Response to Comments
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Anaheim”), or Know Your Way initiative. The Draft EIR concludes that wildfire impacts would be less than significant with mitigation, and this conclusion is supported by substantial evidence.
Because the comment does not present new information or identify a CEQA deficiency, no revisions to the Draft EIR are required.
Comment Letter C2 – Shelley Shuff, June 28, 2025
Response C2-1
The commenter expresses opposition to the Project and raises concerns regarding emergency evacuation.
The commenter describes personal evacuation challenges experienced during a past wildfire event and expresses concern about the ability of elderly and disabled residents to safely evacuate in future emergencies. The commenter urges the City to protect the safety of existing residents by not approving the Project. The comment regarding evacuation concerns is acknowledged. However, this comment does not address the Draft EIR’s adequacy or raise a significant environmental issue. As such, no further response is necessary. Notwithstanding, the Draft EIR does consider the Project’s effect on evacuation; see Response C1-1 above.
Comment Letter C3 – Grace McGee, July 14, 2025
Response C3-1
The commenter expresses concern that the Project would exacerbate existing fire evacuation constraints in Anaheim Hills, an area designated as VHFHSZ. They state that evacuation from Weir Canyon to Imperial Highway already takes over three hours, the City’s “Know Your Way” plan does not substantially improve evacuation times, and the addition of over 1,000 vehicles from the Project would increase risks to residents, schoolchildren, and public safety. The commenter requests that the City not approve additional housing in this area due to the potential to endanger tens of thousands of lives. The comment regarding evacuation concerns is acknowledged. However, this comment does not address the Draft EIR’s adequacy or raise a significant environmental issue. As such, no further response is necessary. Notwithstanding, the Draft EIR does consider the Project’s effect on evacuation; see Response C1-1 above.
Comment Letter C4 – Joy Pickett, July 3, 2025
Response C4-1
The City acknowledges the commenter’s opposition to the Project and appreciates their participation in the CEQA process. The comment raises general concerns about traffic congestion on Santa Ana Canyon Road and evacuation during emergencies, and references a prior project (SALT). However, the comment does not identify a specific deficiency in the Draft EIR or present new information that would alter the environmental conclusions reached.
As discussed in Section 4.14, Transportation, and Section 4.9, Hazards and Hazardous Materials, of the Draft EIR, the Project’s potential impacts on traffic operations and emergency evacuation were evaluated based on site-specific and project-specific data. The analyses concluded that with implementation of identified mitigation measures, the Project would not result in significant transportation or evacuationrelated impacts under CEQA. Accordingly, no revisions to the Draft EIR are required in response to this comment.
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Comment Letter C5 – Marcia Anderson, July 29, 2025
Response C5-1
The commenter expresses concern about the number of apartment units proposed in the Project and the potential impact on wildfire evacuation in a high fire hazard area with limited access points. The commenter requests further study and consideration of reducing the number of apartments or pursuing an alternative use for the site.
The City acknowledges the commenter’s concerns regarding wildfire risk, emergency access, and the proposed number of apartment units. The comment does not identify a specific deficiency in the Draft EIR or present new information requiring further analysis. Wildfire-related impacts, including emergency evacuation in a Very High Fire Hazard Severity Zone, are addressed in Section 4.9 of the Draft EIR and Appendix 4.9-2. The analysis concludes impacts would be less than significant with mitigation. No revisions to the Draft EIR are required.
Comment Letter C6 – Allison Valdivia, July 30, 2025
Response C6-1
The commenter opposes the Project due to concerns that existing evacuation routes are inadequate for current residents. The commenter describes personal experience during the 2017 wildfire evacuation and asserts that no additional development should be approved until more evacuation routes are created.
The City acknowledges the commenter’s concerns. The comment expresses general opposition and references past evacuation challenges but does not identify a specific deficiency in the Draft EIR or present new information requiring further analysis under CEQA. Wildfire evacuation impacts are addressed in Section 4.9 of the Draft EIR and Appendix 4.9-2. The analysis concludes that impacts would be less than significant with mitigation. No revisions to the Draft EIR are required.
Comment Letter C7 - Betty and Dana Farnsworth, July 30, 2025 Response C7-1
The commenter expresses opposition to the proposed apartment project at the Festival Center, citing concerns about emergency evacuation during wildfires. The commenter states that evacuation during the last fire event took over three hours to travel just three miles, and believes additional housing should not be approved until infrastructure improvements are made. The commenter specifically requests that the Fairmont overpass be completed before considering any new development along Santa Ana Canyon Road.
The comment emphasizes that evacuation safety and lives are at risk. The commenter also asks to be notified of future meetings or updates regarding the project.
The City acknowledges the commenter’s concerns. The comment expresses general opposition and references past evacuation challenges but does not identify a specific deficiency in the Draft EIR or present new information requiring further analysis under CEQA. Wildfire evacuation impacts are addressed in Section 4.9 of the Draft EIR and Appendix 4.9-2. The analysis concludes that impacts would be less than significant with mitigation. No revisions to the Draft EIR are required.
Comment Letter C8 – Evalina Loyo, July 30, 2025
Response C8-1
The commenter opposes the Project and raises concerns about impacts to infrastructure, public safety, and quality of life. The commenter notes that local streets and the 91 Freeway are already heavily Anaheim Hills Festival Specific Plan Amendment Project Section 2.0 Final Environmental Impact Report Response to Comments
City of Anaheim 25
congested, particularly during peak hours, and that the area lies within a high fire hazard zone with limited and inefficient evacuation routes. The commenter shares firsthand experience of delays during past wildfire evacuations and warns that adding hundreds of new residents could further compromise public safety and emergency response. While acknowledging the need for housing, the commenter urges the City to reconsider the location and scale of the project given these challenges and expresses interest in participating in future community hearings.
The City acknowledges the commenter’s concerns. The comment expresses general opposition and references past evacuation challenges but does not identify a specific deficiency in the Draft EIR or present new information requiring further analysis under CEQA. Wildfire evacuation impacts are addressed in Section 4.9 of the Draft EIR and Appendix 4.9-2. Traffic impacts are addressed in Section 4.17. The analysis concludes that impacts would be less than significant with mitigation. No revisions to the Draft EIR are required.
Comment Letter C9 – Joy Pickett, August 1, 2025
Response C9-1
The commenter opposes the Project and raises concerns regarding traffic, emergency evacuation, school capacity, and noise. The commenter also references the rejection of the Deer Canyon project down the road. The City acknowledges the commenter’s opposition and concerns. However, the comment does not identify a specific deficiency in the Draft EIR or present new information that would require additional analysis under CEQA. Emergency evacuation and wildfire risk are addressed in Section 4.9, with supporting analysis in the Evacuation Travel Time Analysis (Appendix 4.9-2 of the Draft EIR). Traffic impacts are addressed in Section 4.17, school services in Section 4.15, and noise impacts in Section 4.11. The Draft EIR concludes that impacts in these areas would be less than significant with mitigation, where applicable. No revisions to the Draft EIR are required in response to this comment.
Anaheim Hills Festival Specific Plan Amendment Project Section 2.0 Final Environmental Impact Report Response to Comments
City of Anaheim 26
2.4 Responses to Planning Commission Workshop Comments
Verbal Comment D1 – John M.
Response D1
The commenter stated that he lives less than a mile from the proposed development and watched the City Council vote against the Salt project, which raised two key concerns. He referenced a previous speaker’s use of the medical principle “do no harm” and emphasized that the area is a very high-risk fire zone. He expressed concern that adding 1,000 more vehicles and residents would worsen an already difficult evacuation situation, referencing a past fire in Pacific Palisades and delays on Santa Ana Canyon Road. He shared that his homeowner’s insurance was not renewed due to fire risk, and he was denied by four other companies before obtaining a more expensive policy. He stated the area is not appropriate for apartments and recalled that the evacuation took two hours in 2017. He criticized the Project as “adding fuel to the fire” and referenced a comment from a general plan contributor who said allowing the SALT project would effectively discard the General Plan. He expressed concern that the developer is planning to convert the area to apartments incrementally and stated the best option would be to keep the site asis or rezone it for commercial use, preserving the movie theater.
This comment is acknowledged. An Evacuation Travel Time Analysis report was prepared for the Project, which was incorporated into the Draft EIR to assess the Project’s impacts on evacuation timing. The Evacuation Travel Time Analysis report was provided as Appendix 4.9-2 to the Draft EIR. As discussed in greater detail in Section 4.9, Hazards and Hazardous Materials, of the Draft EIR, although the project would result in additional congestion that would result in a potential extension of time to evacuate (by approximately 14 minutes), given the Project’s numerous design features that enhance wildfire resilience and facilitate emergency access, combined with adherence to all applicable laws and regulations as well as local policies and programs and implementation of MM HAZ-1, the Project would not impair implementation of or physically interfere with the City’s Emergency Operation Plan, Local Hazard Mitigation Plan (“Be Ready Anaheim” plan) or its Know Your Way initiative, nor would the Project expose people or structures, with directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires beyond existing conditions. Given that this comment does not raise any new information that was not addressed in the Draft EIR, no further response is necessary.
Verbal Comment D2 – Jimmy A (Western States Regional Council of Carpenters) Response D2
The commenter, speaking on behalf of the Western States Regional Council of Carpenters, expressed concern about the Project based on Shea Homes’ past use of contractors alleged to engage in unfair labor practices. These concerns include non-payment of livable wages, worker misclassification, and failure to pay workers. The commenter does not oppose housing development generally but urges the City not to approve the Project unless Shea Homes commits to using law-abiding contractors that treat workers fairly.
The City acknowledges the commenter’s concerns regarding labor practices. However, CEQA is limited to evaluating a project’s potential to result in physical environmental impacts. Labor issues, including wage practices and contractor selection, are not within the scope of CEQA review unless they result in a reasonably foreseeable physical environmental impact, which the comment does not identify. While the City encourages all developers to comply with applicable labor laws and promote fair employment Anaheim Hills Festival Specific Plan Amendment Project Section 2.0 Final Environmental Impact Report Response to Comments
City of Anaheim 27
practices, this comment does not raise a CEQA issue requiring further environmental analysis or revisions to the EIR.
Verbal Comment D3 – Betty F.
Response D3
The commenter thanked City staff for their efforts and expressed concern about the Project. She questioned the need for 377 apartments and identified wildfire evacuation and transportation as major issues. She cited past evacuation delays on Santa Ana Canyon Road and congestion on the 91 Freeway, and stated that additional vehicles would worsen conditions. She indicated a preference for Option 2, which would redevelop the theater into a home improvement store with different traffic patterns. She noted that the wildfire consultant challenged previous Salt project assumptions and commended that analysis. She also raised concerns about VMT and reduced parking, stating that such reductions could result in spillover parking in surrounding neighborhoods. She supported the idea of “do no harm” and referenced past fire disasters.
This comment is acknowledged. Please refer to Response D1 for wildfire evacuation discussion.
Transportation and VMT impacts are addressed in Section 4.17 of the Draft EIR. The Project includes reduced parking (PDF TRANS-2) and moderate-income housing (PDF TRANS-1) as VMT-reduction strategies consistent with CAPCOA guidance. These features would not result in significant impacts under CEQA. The commenter’s preference for Alternative 2 is noted. As no new information or substantial evidence was presented that would alter the conclusions of the Draft EIR, no further response is required.
Verbal Comment D4 – Mark H.
Response D4
The commenter questioned who prepared the environmental document for the Project—whether it was completed by City staff or a consultant, and who paid for it. He expressed support for the inclusion of affordable housing but questioned whether any units would serve lower-income categories. He stated that Anaheim is behind on its RHNA targets. He disagreed with the wildfire risk characterization and stated that, based on his experience, the greatest fire danger comes from east-to-west Santa Ana winds. He also suggested that developers should contribute to infrastructure improvements, such as a bridge over Fairmont. Finally, he raised concerns about the timing and transparency of overriding considerations in City decision-making, referencing past experience with the Disney Forward project.
This comment is acknowledged. Kimley-Horn, a consulting firm under contract to the Property Owner/Developer, prepared the Draft EIR. Kimley-Horn is also on the City of Anaheim’s On-Call Environmental Consultant list as a pre-qualified CEQA consultant. The City retained full control and independent judgment over the document’s content, consistent with State CEQA Guidelines §15084. To ensure objectivity and technical adequacy, the City retained Psomas to peer review the Draft EIR and the Project’s technical studies on behalf of the City as Lead Agency. The Project includes 45 moderate-income units, which satisfy the City’s inclusionary housing requirements but do not include very low- or lowincome units. Deeper affordability levels are not required under CEQA. Wildfire evacuation was evaluated in Section 4.9 of the Draft EIR, supported by the Evacuation Travel Time Analysis (Appendix 4.9-2 of the Draft EIR). The analysis modeled two worst-case fire scenarios in Deer Canyon Park under northeast and south-southwest wind conditions. In both scenarios, fire progression was forecast to reach the Project vicinity after 2 to 3 hours, providing a conservative basis for evacuation modeling. The commenter Anaheim Hills Festival Specific Plan Amendment Project Section 2.0 Final Environmental Impact Report Response to Comments
City of Anaheim 28
provides no evidence that the modeling or scenarios are inaccurate. Developer funding of off-site infrastructure, such as the Fairmont bridge, is beyond the scope of CEQA unless necessary to mitigate a significant environmental impact. No such impact was identified. No further response is required.
Verbal Comment D5 – Mr. Hill
Response D5
The commenter expresses concern regarding wildfire evacuation and the adequacy of emergency access, citing the lack of alternate evacuation routes and referencing past fire disasters. As discussed in Section
4.9, Hazards and Hazardous Materials, of the Draft EIR, and the supporting Evacuation Travel Time Analysis (Appendix 4.9-2 of the Draft EIR), the Project would not significantly impair emergency evacuation. Modeled worst-case fire scenarios indicate that fire progression toward the site would take 2–3 hours, during which evacuation would remain feasible. The Project includes design features and MM HAZ-1 to ensure compliance with applicable fire safety standards and coordination with emergency services. CEQA does not require off-site improvements, such as a new overpass, unless necessary to reduce significant physical impacts. Because evacuation impacts are less than significant with mitigation, no additional improvements are required. No new information has been presented; therefore, no changes to the Draft EIR are necessary.
Anaheim Hills Festival Specific Plan Amendment Project Section 3.0 Final Environmental Impact Report Clarifications and Revisions City of Anaheim 29
3.0 CLARIFICATIONS AND REVISIONS
This section presents revisions to the Draft EIR text, tables, and figures that were generated in response to agency comments. These revisions are intended solely to clarify, correct, or amplify information in the Draft EIR based on the comments received during the public review period. None of the revisions alter the Draft EIR’s methodology, analysis, or conclusions.
Pursuant to State CEQA Guidelines §15088.5(a), recirculation of a Draft EIR is required when “significant new information” is added after public notice of availability but before certification. Significant new information includes, but is not limited to, disclosure of a new or substantially more severe impact, the identification of a feasible project alternative or mitigation measure considerable different from those previously analyzed, or substantial changes to the proposed mitigation measures.
None of the comments, responses, or revisions to the Draft EIR constitutes “significant new information” as defined in State CEQA Guidelines §15088.5(a). The revisions do not change the Draft EIR in a way that would deprive the public of a meaningful opportunity to comment on a substantial adverse environmental effect of the Project or on a feasible way to mitigate or avoid such an effect (including a feasible alternative) that the Project’s proponents have declined to adopt. Instead, the revisions clarify or supplement information already provided, or make only insignificant modifications to an otherwise adequate Draft EIR.
Accordingly, recirculation of the Draft EIR is not required. The EIR revisions presented in the following pages are organized in the same order as the corresponding information in the Draft EIR. Revisions in text are identified by strikeouts for deleted text and double underlined for added text. Page references to the Draft EIR are provided for ease of review.
Anaheim Hills Festival Specific Plan Amendment Project Section 3.0 Final Environmental Impact Report Clarifications and Revisions City of Anaheim 30
Draft EIR
Page
Number
Section Revision or Clarification
2-5 2.6, Project
Characteristics
In addition, a zoning code the Specific Plan Amendment would update to Anaheim Municipal Code Section 18.108, Festival Specific Plan, would be required to incorporate the proposed residential standards into DA 5 and other clarifying changes referenced above in relation to signage, permitted uses, and development standards.
Appendix
4.17-2, vii
AUGUST 11,
2025
REVISIONS
AUGUST 11, 2025 REVISIONS
The revisions included on August 11, 2025, were prepared in response to the California Department
of Transportation (Caltrans) comment letter dated August 4, 2025.
Specifically, these revisions include
the following:
• Revisions to Table 4-1 to include the Shopping Center trip generation rates.
• All Turning Volume exhibits updated to ensure volumes are only displayed for applicable turning
• movements at each location. • • Typographical error in all Queuing tables updated to correctly reference SR-91 Freeway.
Appendix
4.17-2,
page 33
Section 4
Projected
Future Traffic
Land Use1
ITE
LU
Code
Units2 AM Peak Hour PM Peak Hour Daily
In Out Total In Out Total
Multifamily
(Mid-Rise)
Residential
221 DU 0.09 0.28 0.37 0.24 0.15 0.39 4.54
Shopping
Center
>150,000 SF
820 TSF 0.52 0.32 0.84 1.63 1.77 3.40 37.01 1 Trip Generation Source: Institute of Transportation Engineers (ITE), Trip Generation Manual, Eleventh Edition (2021) 2 DU = Dwelling Units; TSF = Thousand Square Feet Appendix
4.17-2,
page 37
Section 4
Projected
Future Traffic
Exhibit 4-2: Project Only Traffic Volumes was updated to remove the northbound left and southbound left turn movements (which showed 0 volumes) for Intersection Nos. 1, 2, 13, and 14.
Appendix
4.17-2,
page 41
Section 4
Projected
Future Traffic
Exhibit 4-4: Cumulative Only Traffic Volumes was updated to remove the northbound left and southbound left turn movements (which showed 0 volumes) for Intersection Nos. 1, 2, 13, and 14.
Appendix
4.17-2,
page 44
Section 5
Opening Year
(2029) Traffic
Conditions
Exhibit 5-2: E+A+A (2029) Traffic Volumes was updated to remove the northbound left and southbound left turn movements (which showed 0 volumes) for Intersection Nos. 1, 2, 13, and 14.
Appendix
4.17-2,
page 45
Section 5
Opening Year
(2029) Traffic
Conditions
Exhibit 5-2: E+A+A+P (2029) Traffic Volumes was updated to remove the northbound left and southbound left turn movements (which showed 0 volumes) for Intersection Nos. 1, 2, 13, and 14.
Anaheim Hills Festival Specific Plan Amendment Project Section 3.0 Final Environmental Impact Report Clarifications and Revisions City of Anaheim 31
Appendix
4.17-2,
page 54
Section 6
General Plan
Buildout
Traffic
Conditions
Exhibit 6-1: General Plan Buildout Without Project Traffic Volumes was updated to remove the northbound left and southbound left turn movements (which showed 0 volumes) for Intersection Nos. 1, 2, 13, and 14.
Appendix
4.17-2,
page 55
Section 6
General Plan
Buildout
Traffic
Conditions
Exhibit 6-2: General Plan Buildout With Project Traffic Volumes was updated to remove the northbound left and southbound left turn movements (which showed 0 volumes) for Intersection Nos. 1, 2, 13, and 14.
Appendix
4.17-1,
page 1
AUGUST 7,
2025
REVISIONS
AUGUST 7, 2025 REVISIONS
The revisions included on August 7, 2025, were prepared in response to the California Department of Transportation (Caltrans) comment letter dated August 4, 2025. These revisions consist of typographical edits and clarifications to the sections titled Orange County Baseline VMT per SP and Project Design Features – VMT Reductions; T1 – Increase Residential Density.
Appendix
4.17-1,
page 3
Orange
County
Baseline VMT
per SP
The Orange County baseline VMT per SP value has been calculated using OCTAM 5.0. Base year and cumulative year results were used to calculate the baseline condition using straight line linear interpolation.
Table 2 presents the resulting Orange County baseline VMT per SP value of 25.7. Based on this, 15% below the Orange County baseline VMT per SP is 21.9.
Appendix
4.17-1,
page 4
Orange
County
Baseline VMT
per SP
Appendix
4.17-1,
page 6
Locational
Context
Appendix
4.17-1,
page 6
Project Design
Features –
VMT
Reductions
This measure accounts for the VMT reduction achieved by a project that is designed with a higher density of dwelling units compared to the average residential density in the U.S. (9.1 DU/AC). Increased densities affect the distance people travel and provide greater options for the mode of travel they choose. Increasing residential density results in shorter and fewer trips by single-occupancy vehicles and thus a reduction in VMT.
As the land use information and densities ranging from 15.0 to 28.0 DU/AC that represents the Project was input into the OCTAM, any increased density over the National average that would reduce VMT is Anaheim Hills Festival Specific Plan Amendment Project Section 3.0 Final Environmental Impact Report Clarifications and Revisions City of Anaheim 32
included in the VMT estimates in Table 4 and no additional VMT reduction credit is assumed to avoid double-counting.
Appendix
4.17-1,
Attachment
B
CAPCOA VMT
Reduction
Measures
Not Applicable in at the Project level.
Note that this typo was corrected throughout Attachment B.
Appendix
4.17-1,
Attachment
B
CAPCOA VMT
Reduction
Measures
(T-4)
Not Applicable, all units proposed are at market rate. Applicable.
Appendix
4.17-1,
Attachment
B
CAPCOA VMT
Reduction
Measures
(T-20)
T-20 Expend Expand Bikeway Network
APPENDIX A
WRITTEN COMMENTS ON THE DRAFT EIR
A1-1
1 2
A2-1
3 SENT VIA E-MAIL: August 1, 2025
[email protected]
Amanda Lauffer, Senior Planner
City of Anaheim, Planning and Building Department
200 S. Anaheim Boulevard, Suite 162
Anaheim, CA 92805
Draft Environmental Impact Report (DEIR) for the
Festival Anaheim Hills Project (Proposed Project)
(SCH No: 2024010859)
South Coast Air Quality Management District (South Coast AQMD) staff appreciate the opportunity to review the above-mentioned document. The City of Anaheim is the California Environmental Quality Act (CEQA) Lead Agency for the Proposed Project. To provide context, South Coast AQMD staff has provided a brief summary of the project information and prepared the following comments which are organized by topic of concern.
Summary of Proposed Project Information in the DEIR
Based on the DEIR, the Proposed Project consists of: 1) a new 16.5-acre Development Area (DA5) within the existing boundaries of the Anaheim Hills Festival Specific Plan to accommodate residential uses in combination with the sites existing commercial development.
General Plan Amendment Specific Plan Amendment, and a Zoning code Amendment to incorporate the proposed residential standards into DA5; 2) demolishing a 62.676 square foot theater and constructing 447 residential units.1
Project construction is conservatively estimated in
this EIR to commence in September 2026 and conclude by December 2029. 2 The project is
located at the southeast corner of East Santa Ana Canyon Road and South Festival Drive, Anaheim.3
Based on staff review of the aerial imagery, the nearest residential sensitive receptor is located directly adjacent to the south west and west of the Project site.
South Coast AQMD Comments
Insufficient Consideration of Operational Air Quality Impacts in the DEIR: Need for Operational HRA and LST Evaluations
The DEIR omits an operational health risk assessment (HRA) and localized significance analysis for operational emissions, based on the assumption that the project lacks stationary sources or prolonged idling activity. However, this conclusion is not adequately supported. Regardless of whether the project is primarily residential, it may still generate operational emissions from mobile sources such as residential traffic, delivery and service vehicles, waste collection, and 1 DEIR. Page 8. 2
Ibid. Page 58.
3 Ibid. Page 47.
A2-2
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4 Amanda Lauffer, Senior Planner 2 August 1, 2025
landscape maintenance equipment. Additionally, commercial components of the project may contribute to recurring on-site mobile activity and idling.
Based on South Coast AQMD guidance, the toxic air contaminants (TACs), especially diesel particulate matter (DPM) from operational mobile sources should be evaluated when sensitive receptors are located nearby.4
In this case, sensitive receptors include the adjacent residential uses, and additional nearby receptors include the St. Jude Heritage Medical Group Anaheim Hills, a medical clinic that serves vulnerable populations. Given the proximity of these receptors, an operational HRA and operational localized significance analysis for criteria pollutants should health risk and air quality impacts on surrounding land uses. This is consistent with CEQA's requirement to disclose and mitigate significant environmental impacts the project may cause to the surrounding community.
Emission Reductions from Health Risk Strategies
South Coast AQMD is concerned about the potential public health impacts of siting existing and new sensitive populations within the proximity of existing air pollution sources (e.g., freeway, railroad). For this reason, prior to approving this Proposed Project as well as any future development projects, the Lead Agency is recommended to consider the impacts of air pollutants on people who will live in the new project area and provide effective mitigation. Additionally, South Coast AQMD suggests that the Lead Agency review and apply the guidance provided in:
1) the California Air Resources Board (CARB) Air Quality Land Use and Handbook: A Community Health Perspective5
which provides criteria for evaluating and reducing air pollution advisory which contains strategies to reduce air pollution exposure near high-volume roadways.6 Many strategies are available for residential receptors to reduce being exposed to particulate matter, including, but not limited to, HVAC systems equipped with filters rated at a minimum efficiency reporting value (MERV) 13 or higher air filtration capabilities. In some cases, MERV 15 or better is recommended, for building design, orientation, location, vegetation barriers, landscaping screening, etc. Enhanced filtration units are capable of reducing exposure. However, enhanced filtration systems have limitations. For example, filters rated MERV 13 or higher are able to screen out greater than or equal to 50% of DPM7 but they have no ability to filter out
volatile organic compound (VOC) emissions. Also, in a study that South Coast AQMD conducted to investigate filters rated at MERV 13 or better in classrooms,89 a cost burden is expected to be within the range of $120 to $240 per year to replace each filter panel. The initial 4 South Coast AQMD HRA guidance for TACS: https://www.aqmd.gov/home/rules-compliance/ceqa/air-qualityanalysis-handbook/mobile-source-toxics-analysis?utm_source=chatgpt.com 5 California Air Resources Board (CARB), Air Quality Land Use and Handbook: A Community Health Perspective, April 2005. Available at: https://ww2.arb.ca.gov/sites/default/files/2023-05/Land%20Use%20Handbook_0.pdf 6 -Volume Roadways. Available at:
https://ww2.arb.ca.gov/sites/default/files/2017-10/rd_technical_advisory_final.pdf 7 https://www.https://www.epa.gov/indoor-air-quality-iaq/whatmerv-rating. 8 South Coast AQMD, Draft Pilot Study of High-Performance Air Filtration For Classroom Applications, October 2009. Available at: https://www.aqmd.gov/docs/default-source/ceqa/handbook/aqmdpilotstudyfinalreport.pdf. 9 South Coast AQMD, Draft Pilot Study of High-Performance Air Filtration For Classroom Applications, October 2009. Available at: https://www.aqmd.gov/docs/default-source/ceqa/handbook/aqmdpilotstudyfinalreport.pdf.
A2-3
cont.
A2-4
5 Amanda Lauffer, Senior Planner 3 August 1, 2025
start-up cost could substantially increase if an HVAC system needs to be installed and if standalone filter units are required. Installation costs may vary, including costs for conducting site assessments and obtaining permits and approvals before filters can be installed. Other costs may include filter life monitoring, annual maintenance, and training for conducting maintenance and reporting. In addition, the filters would not have any effect unless the HVAC system is running. Therefore, when in use, the increased energy consumption from each HVAC system should be evaluated in the Draft EIR. While the filters operate 100 percent of the time when the HVAC is in use while the residents are indoors, the environmental analysis does not generally account for the times when the residents are not using their HVAC and instead have their windows or doors open or are moving throughout the common space outdoor areas of the Proposed Project. Furthermore, when used filters are replaced with new filters, emissions associated with trucks delivering the new filters and waste disposal trucks transporting the used filters to disposal sites should be evaluated in the Draft EIR. Therefore, any presumed effectiveness and feasibility of a particular HVAC filter should be carefully evaluated in more detail based on supporting evidence before assuming they will sufficiently alleviate exposure to DPM emissions.
Conclusion
As set forth in California Public Resources Code Section 21092.5(a) and CEQA Guidelines Section 15088(a-b), the Lead Agency shall evaluate comments from public agencies on the environmental issues and prepare a written response at least 10 days prior to certifying the Final EIR. As such, please provide South Coast AQMD written responses to all comments contained herein at least 10 days prior to the certification of the Final EIR. In addition, as provided by CEQA Guidelines Section 15088(c)if the Lead Agency
recommendations provided in this comment letter, detailed reasons supported by substantial evidence in the record to explain why specific comments and suggestions are not accepted must be provided.
Thank you for the opportunity to provide comments. South Coast AQMD staff is available to work with the Lead Agency to address any air quality questions that may arise from this comment letter. Please contact Sahar Ghadimi, Air Quality Specialist, at [email protected] should you have any questions.
Sincerely,
Sam Wang
Sam Wang
Program Supervisor, CEQA IGR
Planning, Rule Development & Implementation
ORC250624-04
SW:SG
Control Number
A2-4
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6 A3-1
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8 A3-6
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11 B1-1
12 Via Email
June 30, 2025
Amanda Lauffer, Senior Planner
Planning Services Division
Planning and Building Department
City of Anaheim
200 S. Anaheim Boulevard, 1st Floor
Anaheim, CA 92805
[email protected]
Re: Comment on Draft Environmental Impact Report, Festival Anaheim Hills Project (DEV2023-00043)
Dear Ms. Lauffer:
This comment is submitted on behalf of Supporters Alliance for Environmental Responsibility (“SAFER”) regarding the Draft Environmental Impact Report (“DEIR”) prepared for the Festival Anaheim Hills Project (DEV2023-00043), which proposes the demolition of a 62,676 square-foot theatre to make way for the development of a 447-unit multi-family residential building with a five-level wraparound parking structure with one level of subterranean parking, located on an 85.7-acre project site located within the Anaheim Hills Festival Specific Plan in the City of Anaheim (“Project”).
SAFER is concerned that the DEIR fails as an informational document and fails to impose all feasible mitigation measures to reduce the Project’s impacts. SAFER requests that the Planning and Building Department address these shortcomings in a revised draft environmental impact report and recirculate it prior to considering approvals for the Project.
SAFER reserves the right to supplement these comments during the administrative process. Galante Vineyards v. Monterey Peninsula Water Management Dist., 60 Cal. App. 4th 1109, 1121 (1997).
Sincerely,
Rebecca Davis
Lozeau Drury LLP
B1-2
13 VIA E-MAIL
August 4, 2025
Amanda Lauffer, Senior Planner
Planning and Building Department
City of Anaheim
200 S. Anaheim Boulevard, Suite 162
Anaheim, CA 92805
Ph: (714) 765-4479
Em: [email protected] RE: City of Anaheim’s Anaheim Hills Festival Specific Plan Amendment Project – Draft Environmental Impact Report (SCH# 2024010859)
Dear Amanda Lauffer,
On behalf of the Western States Regional Council of Carpenters (“Western Carpenters” or “WSRCC”), our firm is submitting these comments in connection with the City of Anaheim’s (“City”) Anaheim Hills Festival Specific Plan Amendment (“Project”) and the Draft Environmental Impact Report (“DEIR”) associated therewith.
The Notice of Availability of the Project’s DEIR describes the Project as follows:
The proposed project would establish a new Development Area (DA 5) within the existing boundaries of the Anaheim Hills Festival Specific Plan to accommodate residential uses in combination with the site's existing commercial development. DA 5 would be created by reallocating land from the existing DA 2, reducing its size from approximately 48 acres to
31.8 acres. The resulting 16.2-acre area would form the new DA 5. All proposed development would be confined to DA 5, which encompasses Assessor’s Parcel Numbers (APNs) 354-451-19 and 354-451-32. The overall exterior boundary of the Specific Plan would remain unchanged.
The proposed project includes the demolition of an approximately 62,676- square-foot cinema within DA 5 and the development of a new 447-unit B2-1
14 multiple-family rental residential community. The proposed multiplefamily community would consist of a four-story residential building, wrapped around a five-level parking structure with one subterranean level.
All residential units are single-story and include one-bedroom, twobedroom, and three-bedroom options with private patios or balconies.
Project amenities include a clubhouse, two swimming pools, courtyards, a fitness center, leasing office, and mail area. In addition to the project amenities, the applicant is proposing an enclosed outdoor public dog park along Festival Drive and public bluff park along the edge of the newly proposed DA 5 and the lower tier of the shopping center, DA 2, which would be open to residents of the community and the general public.
NOA, p. 1.
The Western States Regional Council of Carpenters is a labor union representing almost 90,000 union carpenters in 12 states, including California, and has a strong interest in well-ordered land use planning and in addressing the environmental impacts of development projects.
Individual members of the Western Carpenters live, work, and recreate in the City and surrounding communities and would be directly affected by the Project’s environmental impacts.
The Western Carpenters expressly reserves the right to supplement these comments at or prior to hearings on the Project, and at any later hearing and proceeding related to this Project. Gov. Code, § 65009, subd. (b); Pub. Res. Code, § 21177, subd. (a); see Bakersfield Citizens for Local Control v. Bakersfield (2004) 124 Cal.App.4th 1184, 1199- 1203; see also Galante Vineyards v. Monterey Water Dist. (1997) 60 Cal.App.4th 1109, 1121.
The Western Carpenters incorporates by reference all comments raising issues regarding the Environmental Impact Report (EIR) submitted prior to certification of the EIR for the Project. See Citizens for Clean Energy v City of Woodland (2014) 225 Cal.App.4th 173, 191 (finding that any party who has objected to the project’s environmental documentation may assert any issue timely raised by other parties).
Moreover, the Western Carpenters requests that the City provide notice for any and all notices referring or related to the Project issued under the California Environmental Quality Act (CEQA) (Pub. Res. Code, § 21000 et seq.), and the B2-1
cont.
15 California Planning and Zoning Law (“Planning and Zoning Law”) (Gov. Code, §§ 65000–65010). California Public Resources Code Sections 21092.2, and 21167(f) and California Government Code Section 65092 require agencies to mail such notices to any person who has filed a written request for them with the clerk of the agency’s governing body.
I. THE CITY SHOULD REQUIRE THE USE OF A LOCAL
WORKFORCE TO BENEFIT THE COMMUNITY’S ECONOMIC
DEVELOPMENT AND ENVIRONMENT
The City should require the Project to be built using a local workers who have graduated from a Joint Labor-Management Apprenticeship Program approved by the State of California, have at least as many hours of on-the-job experience in the applicable craft which would be required to graduate from such a state-approved apprenticeship training program, or who are registered apprentices in a state-approved apprenticeship training program.
Community benefits such as local hire can also be helpful to reduce environmental impacts and improve the positive economic impact of the Project. Local hire provisions requiring that a certain percentage of workers reside within 10 miles or less of the Project site can reduce the length of vendor trips, reduce greenhouse gas emissions, and provide localized economic benefits. As environmental consultants Matt Hagemann and Paul E. Rosenfeld note:
[A]ny local hire requirement that results in a decreased worker trip length from the default value has the potential to result in a reduction of construction-related GHG emissions, though the significance of the reduction would vary based on the location and urbanization level of the project site.
March 8, 2021 SWAPE Letter to Mitchell M. Tsai re Local Hire Requirements and Considerations for Greenhouse Gas Modeling.
Workforce requirements promote the development of skilled trades that yield sustainable economic development. As the California Workforce Development Board and the University of California, Berkeley Center for Labor Research and Education concluded:
[L]abor should be considered an investment rather than a cost—and investments in growing, diversifying, and upskilling California’s workforce B2-1
cont.
B2-2
B2- text
16 can positively affect returns on climate mitigation efforts. In other words, well-trained workers are key to delivering emissions reductions and moving California closer to its climate targets.1
Furthermore, workforce policies have significant environmental benefits given that they improve an area’s jobs-housing balance, decreasing the amount and length of job commutes and the associated greenhouse gas (GHG) emissions. In fact, on May 7, 2021, the South Coast Air Quality Management District found that that the “[u]se of a local state-certified apprenticeship program” can result in air pollutant reductions.2 Locating jobs closer to residential areas can have significant environmental benefits.
As the California Planning Roundtable noted in 2008:
People who live and work in the same jurisdiction would be more likely to take transit, walk, or bicycle to work than residents of less balanced communities and their vehicle trips would be shorter. Benefits would include potential reductions in both vehicle miles traveled and vehicle hours traveled.3
Moreover, local hire mandates and skill-training are critical facets of a strategy to reduce vehicle miles traveled (VMT). As planning experts Robert Cervero and Michael Duncan have noted, simply placing jobs near housing stock is insufficient to achieve VMT reductions given that the skill requirements of available local jobs must match those held by local residents.4 Some municipalities have even tied local hire and 1 California Workforce Development Board (2020) Putting California on the High Road: A Jobs and Climate Action Plan for 2030 at p. ii, available at https://laborcenter.berkeley.edu/ wp-content/uploads/2020/09/Putting-California-on-the-High-Road.pdf. 2 South Coast Air Quality Management District (May 7, 2021) Certify Final Environmental Assessment and Adopt Proposed Rule 2305 – Warehouse Indirect Source Rule – Warehouse Actions and Investments to Reduce Emissions Program, and Proposed Rule 316 – Fees for Rule 2305, Submit Rule 2305 for Inclusion Into the SIP, and Approve Supporting Budget Actions, available at http://www.aqmd.gov/docs/defaultsource/Agendas/Governing-Board/2021/2021-May7-027.pdf?sfvrsn=10. 3 California Planning Roundtable (2008) Deconstructing Jobs-Housing Balance at p. 6, available at https://cproundtable.org/static/media/uploads/publications/cpr-jobshousing.pdf 4 Cervero, Robert and Duncan, Michael (2006) Which Reduces Vehicle Travel More: JobsHousing Balance or Retail-Housing Mixing? Journal of the American Planning Association 72 (4), 475-490, 482, available at http://reconnectingamerica.org/assets/Uploads/UTCT825.pdf.
B2-2
cont.
17 other workforce policies to local development permits to address transportation issues. Cervero and Duncan note that:
In nearly built-out Berkeley, CA, the approach to balancing jobs and housing is to create local jobs rather than to develop new housing. The city’s First Source program encourages businesses to hire local residents, especially for entry- and intermediate-level jobs, and sponsors vocational training to ensure residents are employment-ready. While the program is voluntary, some 300 businesses have used it to date, placing more than 3,000 city residents in local jobs since it was launched in 1986. When needed, these carrots are matched by sticks, since the city is not shy about negotiating corporate participation in First Source as a condition of approval for development permits.
Recently, the State of California verified its commitment towards workforce development through the Affordable Housing and High Road Jobs Act of 2022, otherwise known as Assembly Bill No. 2011 (“AB2011”). AB2011 amended the Planning and Zoning Law to allow ministerial, by-right approval for projects being built alongside commercial corridors that meet affordability and labor requirements.
The City should consider utilizing local workforce policies and requirements to benefit the local area economically and to mitigate greenhouse gas, improve air quality, and reduce transportation impacts.
II. THE CITY SHOULD IMPOSE TRAINING REQUIREMENTS FOR
THE PROJECT’S CONSTRUCTION ACTIVITIES TO PREVENT
COMMUNITY SPREAD OF COVID-19 AND OTHER INFECTIOUS
DISEASES
Construction work has been defined as a Lower to High-risk activity for COVID-19 spread by the Occupations Safety and Health Administration. Recently, several construction sites have been identified as sources of community spread of COVID19.5 5 Santa Clara County Public Health (June 12, 2020) COVID-19 CASES AT
CONSTRUCTION SITES HIGHLIGHT NEED FOR CONTINUED VIGILANCE IN SECTORS THAT HAVE REOPENED, available at https://www.sccgov.org/sites/ covid19/Pages/press-release-06-12-2020-cases-at-construction-sites.aspx.
B2-2
cont.
B2-3
18 Western Carpenters recommend that the Lead Agency adopt additional requirements to mitigate public health risks from the Project’s construction activities. Western Carpenters requests that the Lead Agency require safe on-site construction work practices as well as training and certification for any construction workers on the Project Site.
In particular, based upon Western Carpenters’ experience with safe construction site work practices, Western Carpenters recommends that the Lead Agency require that while construction activities are being conducted at the Project Site:
Construction Site Design:
• The Project Site will be limited to two controlled entry points.
• Entry points will have temperature screening technicians taking temperature readings when the entry point is open. • The Temperature Screening Site Plan shows details
regarding access to the Project Site and Project Site logistics for conducting temperature screening.
• A 48-hour advance notice will be provided to all trades prior to the first day of temperature screening.
• The perimeter fence directly adjacent to the entry points will be clearly marked indicating the appropriate 6-foot social distancing position for when you approach the screening area. Please reference the Apex temperature screening site map for additional details.
• There will be clear signage posted at the project site directing you through temperature screening. • Provide hand washing stations throughout the construction site.
Testing Procedures:
• The temperature screening being used are non-contact
devices.
• Temperature readings will not be recorded.
B2-3
cont.
19 • Personnel will be screened upon entering the testing center and should only take 1-2 seconds per individual.
• Hard hats, head coverings, sweat, dirt, sunscreen or any other cosmetics must be removed on the forehead before
temperature screening.
• Anyone who refuses to submit to a temperature screening or does not answer the health screening questions will be
refused access to the Project Site.
• Screening will be performed at both entrances from 5:30 am to 7:30 am.; main gate [ZONE 1] and personnel gate
[ZONE 2]
• After 7:30 am only the main gate entrance [ZONE 1] will continue to be used for temperature testing for anybody gaining entry to the project site such as returning personnel, deliveries, and visitors.
• If the digital thermometer displays a temperature reading above 100.0 degrees Fahrenheit, a second reading will be taken to verify an accurate reading.
• If the second reading confirms an elevated temperature, DHS will instruct the individual that he/she will not be allowed to enter the Project Site. DHS will also instruct the individual to promptly notify his/her supervisor and his/her human resources (HR) representative and provide them with a copy of Annex A.
Planning • Require the development of an Infectious Disease Preparedness and Response Plan that will include basic
infection prevention measures (requiring the use of personal protection equipment), policies and procedures for prompt identification and isolation of sick individuals, social distancing (prohibiting gatherings of no more than 10
people including all-hands meetings and all-hands lunches) B2-3
cont.
20 communication and training and workplace controls that meet standards that may be promulgated by the Center for Disease Control, Occupational Safety and Health
Administration, Cal/OSHA, California Department of
Public Health or applicable local public health agencies.6 The United Brotherhood of Carpenters and Carpenters International Training Fund has developed COVID-19 Training and Certification to ensure that Carpenter union members and apprentices conduct safe work practices. The Agency should require that all construction workers undergo COVID-19 Training and Certification before being allowed to conduct construction activities at the Project Site.
Western Carpenters has also developed a rigorous Infection Control Risk Assessment (“ICRA”) training program to ensure it delivers a workforce that understands how to identify and control infection risks by implementing protocols to protect themselves and all others during renovation and construction projects in healthcare environments.7
ICRA protocols are intended to contain pathogens, control airflow, and protect patients during the construction, maintenance and renovation of healthcare facilities.
ICRA protocols prevent cross contamination, minimizing the risk of secondary infections in patients at hospital facilities.
The City should require the Project to be built using a workforce trained in ICRA protocols.
III. THE CALIFORNIA ENVIRONMENTAL QUALITY ACT
CEQA is a California statute designed to inform decision-makers and the public about the potential significant environmental effects of a project. 14 California Code of Regulations (“CEQA Guidelines”), § 15002, subd. (a)(1).8 At its core, its purpose
6 See also The Center for Construction Research and Training, North America’s Building Trades Unions (April 27 2020) NABTU and CPWR COVIC-19 Standards for U.S Constructions Sites, available at https://www.cpwr.com/sites/default/files/NABTU_ CPWR_Standards_COVID-19.pdf; Los Angeles County Department of Public Works (2020) Guidelines for Construction Sites During COVID-19 Pandemic, available at https://dpw.lacounty.gov/building-and-safety/docs/pw_guidelines-construction-sites.pdf. 7 For details concerning Western Carpenters’ ICRA training program, see https://www.swmsctf.org/courses/icra-best-practices-in-health-care-construction/ 8 The CEQA Guidelines, codified in Title 14 of the California Code of Regulations, section 15000 et seq., are regulatory guidelines promulgated by the state Natural Resources Agency for the B2-3
cont.
B2-4
21 is to “inform the public and its responsible officials of the environmental consequences of their decisions before they are made. Thus, the EIR ‘protects not only the environment but also informed self-government[.]’” Citizens of Goleta Valley v.
Board of Supervisors (1990) 52 Cal.3d 553, 564 (internal citation omitted).
To achieve this purpose, CEQA mandates preparation of an Environmental Impact Report (“EIR”) for projects so that the foreseeable impacts of pursuing the project can be understood and weighed. Communities for a Better Environment v. Richmond (2010) 184 Cal. App. 4th 70, 80. The EIR requirement “is the heart of CEQA.” CEQA Guidelines, § 15003(a).
CEQA directs public agencies to avoid or reduce environmental damage, when possible, by requiring alternatives or mitigation measures. CEQA Guidelines, § 15002, subds. (a)(2)-(3); see also Berkeley Keep Jets Over the Bay Committee v. Board of Port Commissioners of the City of Oakland (2001) 91 Cal.App.4th 1344, 1354; Laurel Heights Improvement Assn. v. Regents of University of California (1988) 47 Cal.3d 376, 400. The Environmental Impact Report (EIR) serves to provide public agencies and the public in general with information about the effect that a proposed project is likely to have on the environment and to “identify ways that environmental damage can be avoided or significantly reduced.” CEQA Guidelines, § 15002, subd. (a)(2).
A public agency must prepare an EIR whenever substantial evidence supports a “fair argument” that a proposed project “may have a significant effect on the environment.” Pub. Res. Code, §§ 21100, 21151; CEQA Guidelines, §§ 15002, subds. (f)(1)-(2), 15063; No Oil, supra, 13 Cal.App.3d at p. 75; Communities for a Better Environment v. California Resources Agency (2002) 103 Cal.App.4th 98, 111-112. If the project has a significant effect on the environment, the agency may approve the project only upon finding that it has “eliminated or substantially lessened all significant effects on the environment where feasible” and that any unavoidable significant effects on the environment are “acceptable due to overriding concerns” specified in Public Resources Code section 21081. See CEQA Guidelines, §§ 15092, subds. (b)(2)(A)-(B).
Essentially, should a lead agency be presented with a fair argument that a project may have a significant effect on the environment, the lead agency shall prepare an EIR implementation of CEQA. Pub. Res. Code, § 21083. The CEQA Guidelines are given “great weight in interpreting CEQA except when . . . clearly unauthorized or erroneous.” Center for Biological Diversity v. Dept. of Fish & Wildlife (2015) 62 Cal.4th 204, 217.
B2-4
cont.
22 even though it may also be presented with other substantial evidence that the project will not have a significant effect. CEQA Guidelines, §§ 15064(f)(1)-(2); see No Oil, supra, 13 Cal.App.3d at p. 75 (internal citations and quotations omitted). Substantial evidence includes “enough relevant information and reasonable inferences from this information that a fair argument can be made to support a conclusion, even though other conclusions might also be reached.” CEQA Guidelines, § 15384, subd. (a).
The EIR has been described as “an environmental ‘alarm bell’ whose purpose it is to alert the public and its responsible officials to environmental changes before they have reached ecological points of no return.” Berkeley Keep Jets Over the Bay v. Bd. of Port Comm’rs. (2001) 91 Cal. App. 4th 1344, 1354 (“Berkeley Jets”); County of Inyo v. Yorty (1973) 32 Cal. App. 3d 795, 810.
The preparation and circulation of an EIR is more than a set of technical hurdles for agencies and developers to overcome. Communities for a Better Environment v. Richmond (2010) 184 Cal.App.4th 70, 80 (quoting Vineyard Area Citizens for Responsible Growth, Inc. v. City of Rancho Cordova (2007) 40 Cal.4th 412, 449-450). The EIR’s function is to ensure that government officials who decide to build or approve a project do so with a full understanding of the environmental consequences and, equally important, that the public is assured those consequences have been considered. Id. For the EIR to serve these goals it must present information so that the foreseeable impacts of pursuing the project can be understood and weighed, and the public must be given an adequate opportunity to comment on that presentation before the decision to go forward is made. Id. A strong presumption in favor of requiring preparation of an EIR is built into CEQA.
This presumption is reflected in what is known as the “fair argument” standard under which an EIR must be prepared whenever substantial evidence in the record supports a fair argument that a project may have a significant effect on the environment. Quail Botanical Gardens Found., Inc. v. City of Encinitas (1994) 29 Cal.App.4th 1597, 1602; Friends of “B” St. v. City of Hayward (1980) 106 Cal.3d 988, 1002.
Further, it is the duty of the lead agency, not the public, to conduct the proper environmental studies. “The agency should not be allowed to hide behind its own failure to gather relevant data.” Sundstrom, supra, 202 Cal.App.3d at p. 311. “Deficiencies in the record may actually enlarge the scope of fair argument by lending a logical plausibility to a wider range of inferences.” Ibid; see also Gentry v. City of B2-4
cont.
23 Murrieta (1995) 36 Cal.App.4th 1359, 1382 (lack of study enlarges the scope of the fair argument which may be made based on the limited facts in the record).
Thus, refusal to complete recommended studies lowers the already low threshold to establish a fair argument. The court may not exercise its independent judgment on the omitted material by determining whether the ultimate decision of the lead agency would have been affected had the law been followed. Environmental Protection Information Center v. Cal. Dept. of Forestry (2008) 44 Cal.4th 459, 486 (internal citations and quotations omitted). The remedy for this deficiency would be for the trial court to issue a writ of mandate. Ibid.
While the courts review an EIR using an ‘abuse of discretion’ standard, the reviewing court is not to uncritically rely on every study or analysis presented by a project proponent in support of its position. Berkeley Keep Jets, supra, 91 Cal.App.4th at p. 1355 (quoting Laurel Heights, supra, 47 Cal.3d at pp. 391, 409 fn. 12) (internal quotations omitted). A clearly inadequate or unsupported study is entitled to no judicial deference. Ibid. Drawing this line and determining whether the EIR complies with CEQA’s information disclosure requirements presents a question of law subject to independent review by the courts. Sierra Club v. County of Fresno (2018) 6 Cal.5th 502, 515; Madera Oversight Coalition, Inc. v. County of Madera (2011) 199 Cal.App.4th 48, 102, 131. As the First District Court of Appeal has previously stated, prejudicial abuse of discretion occurs if the failure to include relevant information precludes informed decision-making and informed public participation, thereby thwarting the statutory goals of the EIR process. Berkeley Keep Jets, supra, 91 Cal.App.4th at p. 1355 (internal quotations omitted).
Both the review for failure to follow CEQA’s procedures and the fair argument test are questions of law, thus, the de novo standard of review applies. Vineyard Area Citizens for Responsible Growth v. City of Rancho Cordova (2007) 40 Cal.4th 412, 435.
Whether the agency’s record contains substantial evidence that would support a fair argument that the project may have a significant effect on the environment is treated as a question of law. Consolidated Irrigation Dist., supra, 204 Cal.App.4th at p. 207; Kostka and Zischke, Practice Under the Environmental Quality Act (2017, 2d ed.) at § 6.76.
Section 15088.5(a) of the CEQA Guidelines provides that an EIR must be recirculated whenever there is disclosure of significant new information. Significant new information includes: (1) disclosure of a new significant environmental impact resulting from the project or from a new proposed mitigation measure; (2) disclosure B2-4
cont.
24 of a substantial increase in the severity of an environmental impact unless mitigation measures are adopted that reduce the impact to a level of insignificance; and (3) disclosure of a feasible project alternative or mitigation measure considerably different from others previously analyzed which would clearly lessen the significant environmental impacts of the project which the project proponents decline to adopt.
Id.
Additionally, an EIR must be recirculated when it is so fundamentally inadequate and conclusory in nature that meaningful public review and comment is precluded. Id. [citing Mountain Lion Coalition v. Fish & Game Com. (1989) 214 Cal.App.3d 1043].
Here, as discussed below, the DEIR fails to substantiate all of its conclusions to allow meaningful public review and comment, provide adequate mitigation measures, and fully assess all pertinent environmental factors. Accordingly, this comment letter discloses significant new information, necessitating revision and recirculation of the DEIR.
IV. THE DEIR IS INADEQUATE UNDER CEQA AND SHOULD BE
REVISED AND RECIRCULATED
A. The DEIR Fails to Support Its Findings with Substantial Evidence CEQA requires that an EIR identify and discuss the significant effects of a Project, how those significant effects can be mitigated or avoided. CEQA Guidelines § 15126.2; PRC §§ 21100(b)(1), 21002.1(a). If a project has a significant effect on the environment, an agency may approve the project only upon finding that it has “eliminated or substantially lessened all significant effects on the environment where feasible” and that any unavoidable significant effects on the environment are “acceptable due to overriding concerns.” CEQA Guidelines § 15092(b)(2) (A–B). Such findings must be supported by substantial evidence. CEQA Guidelines § 15091(b).
When new information is brought to light showing that an impact previously discussed in the DEIR but found to be insignificant with or without mitigation in the DEIR’s analysis has the potential for a significant environmental impact supported by substantial evidence, the DEIR must consider and resolve the conflict in the evidence.
See Visalia Retail, L.P. v. City of Visalia (2018) 20 Cal.App.5th 1, 13, 17; see also Protect the Historic Amador Waterways v. Amador Water Agency (2004) 116 Cal. App. 4th 1099, 1109. While a lead agency has discretion to formulate standards for determining significance and the need for mitigation measures—the choice of any standards or B2-4
cont.
B2-5
25 thresholds of significance must be “based to the extent possible on scientific and factual data and an exercise of reasoned judgment based on substantial evidence.
CEQA Guidelines § 15064(b); Cleveland Nat'l Forest Found. v. San Diego Ass'n of Gov'ts (2017) 3 Cal. App. 5th 497, 515; Mission Bay Alliance v. Office of Community Inv. & Infrastructure (2016) 6 Cal. App. 5th 160, 206. And when there is evidence that an impact could be significant, an EIR cannot adopt a contrary finding without providing an adequate explanation along with supporting evidence. East Sacramento Partnership for a Livable City v. City of Sacramento (2016) 5 Cal. App. 5th 281, 302.
Here, for the reasons discussed in detail below, the DEIR fails to comply with the foregoing requirements.
1. The DEIR for the Project concludes that the Project will result in less than significant noise and vibration impacts based, in part, on its finding that: “[t]he closest noise sensitive receptors near the site are multi-family residences approximately 300 feet south of the southernmost project boundary along North La Brea Avenue.” (DEIR, pp. 4.10-4 – 5; see also DEIR, p. 4.10-12.) However, in reaching this conclusion the DEIR misstates and misapplies the City’s Noise Ordinance as the threshold of significance for noise impacts, claiming that the Noise Ordinance “establishes a noise level limit of 60 dBA.” DEIR, p. 4.13-13. The standard that the DEIR should have considered and analyzed as a its threshold of significance for the Project’s anticipated noise impacts is set forth by Anaheim Municipal Code section 18.40.090, which provides an exterior construction noise limit of 65 dBA CNEL for exterior yards and common areas of existing residential developments. Meanwhile, the DEIR, by its own studies (and which appear to have further underreported the Project’s noise impacts based on the improper placement of noise measurement equipment L3/R3 and L4/R4), determined that the sensitive receptors in R3 and R4 would be exposed to construction noise levels in excess of 65 dBA CNEL. See DEIR, p. 4.13-13, Tables
4.13-6 and 4.13-7.
Accordingly, the DEIR admits that the Project’s noise impacts are potentially significant, and yet, it improperly does not provide for any mitigation to reduce its anticipated significant noise impacts. As such, and absent revision and recirculation of the DEIR to include added noise mitigation measures that demonstrably reduce the B2-5
cont.
B2-6
26 Project’s construction noise impacts below the threshold of significance, the Project will continue to violate CEQA with regard to its noise impacts.
B. The DEIR Improperly Relies Exclusively on Regulatory Compliance in Its Assessment of Biological Resources Impacts The DEIR notes that construction of the Project would require removal of 211 existing on-site trees located throughout the Project site. (IS, p. 30.) While the DEIR notes the potential for the removal of these trees to affect nesting and/or special status bird species (see DEIR p. 4.4-9 – “The existing trees have the potential to support nesting migratory birds that are protected by the MBTA and CFGC.”), the DEIR for the Project then proceeds to conduct of the
Project’s Biological Resources impacts, while inexplicably determining that the Project’s baseline Biological Resources impacts will be “Less Than Significant” before mitigation. See DEIR, p. ES-9. The DEIR goes on to rely entirely upon its purported Regulatory Compliance Measure RCM BIO-1 (Nesting Migratory Birds) to dispose of any potential concerns over such impacts, concluding that no actual mitigation is required to achieve less than significant impacts. See DEIR pp. 4.4-8 – 9.
RCM BIO-1 provides as follows:
To prevent inadvertent disturbance to potential nesting migratory birds, a qualified biologist shall be contracted by the Property Owner/Developer prior to the issuance of any demolition permits to perform biological monitoring during all demolition, clearing, grubbing, and grading activities.
To the extent feasible, all demolition, clearing, grubbing, and grading activities shall be conducted outside of the state-identified nesting season for migratory birds (i.e., typically February 1 through August 31). If not feasible, a Pre-Construction Nesting Bird Survey within and adjacent to the Project site shall be conducted by a qualified biologist no more than three days before beginning these activities. If active nests are found during the Pre-Construction Nesting Bird Survey, a Nesting Bird Plan (NBP) shall be prepared by a qualified biologist and implemented during construction with approval from the City. At a minimum, the NBP shall include guidelines for addressing the active nest(s), proposed protective buffers, proposed monitoring approach, and proposed reporting Type tex
B2-6
cont.
B2-7
27 approach. The size and location of all buffer zones, if required, shall be based on the nesting species, nesting sage, nest location, its sensitivity to disturbance, and intensity and duration of the disturbance activity. A memorandum describing the results of the Pre-Construction Nesting Bird Survey shall be submitted to the Planning and Building Department for verification prior to proceeding with demolition, clearing, grubbing, and/or grading activities subject to this measure. Any NBP developed pursuant to this measure shall be submitted to the City for review and approval prior to implementation.
Id. Notably, the RCM defines the nesting period as February-August, contrary to the California Department of Fish and Wildlife’s (“CDFW”) finding that raptor nesting may commence before and/or after this timeframe.9
Further investigation of the information contained on the CDFW’s “California Outdoors Q&A” webpage reveals that the boundaries of bird nesting season in California are broad and variable: “[N]esting season can vary based on location and species of bird, and in some parts of the state, birds nest year-round.”10 Furthermore, as noted by the California Department of Fish and Wildlife in a November 18, 2021, letter to the City of Adelanto concerning a similar preconstruction nesting bird survey mitigation measure:
CDFW is concern[ed] that [the mitigation measure] is conditioned to only require surveys during the peak bird nesting season considering that birds, such as hummingbirds may nest year-round. Furthermore, [the mitigation measure] defines bird nesting season as February 1 to August 31. Please note that nesting may commence before and/or after this timeframe. For example, some species of raptors (e g. owls, hawks, etc.) may commence nesting activities in January, and passerines may nest later than August 31.
Fish and Game Code Section 3503 makes it unlawful to take, possess, or 9 “…[S]ome species of raptors (e g. owls, hawks, etc.) may commence nesting activities in January.” See CDFW November 18, 2021 letter to City of Adelanto, available at https://files.ceqanet.opr.ca.gov/273819-1/attachment/
zo76RgD7dUdj5BLJTEhEMdf74g6f100RrKiWBQSquhFFe5l0X53rLsbLSGMPRXgXM4AaYnJST fZB6JpY0 10 See CDFW California Outdoors Q&A – Nesting Birds https://wildlife.ca.gov/COQA/ ArticlePage/2/tag/conflict#gsc.tab=0
B2-7
cont.
28 needlessly destroy the nest or eggs of any bird, except as otherwise provided by Fish and Game Code or any regulation made pursuant thereto.
These added qualifications by CDFW regarding bird nesting season are consistent with, and underscore, CDFW’s separate finding that birds and raptor nesting in the Project’s geographic region can and does occur outside the more general bird nesting period of February-August sought by the DEIR in RCM BIO-1. Moreover, CDFW’s collective findings on this issue, coupled with the Project site’s adjacency and/or very close proximity to undeveloped wildland and conservation areas (e.g., Deer Canyon Park, the Weir Canyon Nature Preserve, the Oak Canyon Nature Center, and the Fremont Canyon Nature Preserve) confirm the inadequacy of both the City’s analysis of the Project’s potential biological resources impacts to nesting and migratory birds and the exclusive regulatory reliance as a basis for disposing of the potential for any such impacts.
Furthermore, a determination that regulatory compliance will be sufficient to prevent significant adverse impacts must be based on a project-specific analysis of potential impacts and the effect of regulatory compliance. In Californians for Alternatives to Toxics v.
Department of Food & Agric. (2005) 136 Cal. App. 4th 1, the court set aside an EIR for a statewide crop disease control plan because it did not include an evaluation of the risks to the environment and human health from the proposed program but simply presumed that no adverse impacts would occur from use of pesticides in accordance with the registration and labeling program of the California Department of Pesticide Regulation. See also Ebbetts Pass Forest Watch v Department of Forestry & Fire Protection (2008) 43 Cal. App. 4th 936, 956 (fact that Department of Pesticide Regulation had assessed environmental effects of certain herbicides in general did not excuse failure to assess effects of their use for specific timber harvesting project).
Here, the DEIR does not set forth any analysis or study demonstrating the Project’s baseline potential impacts on biological resources, juxtaposed with an analysis of how the Project’s purported regulatory compliance would reduce potential impacts on nesting bird species to a less than significant level, such that no further study or analysis would be warranted. Rather, the DEIR bases its conclusion regarding the mitigating effects of regulatory compliance simply on assumptions regarding the Project Site and the surrounding urbanized areas. Under CEQA, such unsupported assumptions are improper. To that end, the RCM violates CEQA, as its use here B2-7
cont.
29 results in the DEIR failing to disclose “the analytic route that the agency took from the evidence to its findings.” (Cal. Public Resources Code § 21081.5; CEQA Guidelines § 15093; Village Laguna of Laguna Beach, Inc. v. Board of Supervisors (1982) 134 Cal. App. 3d 1022, 1035 [quoting Topanga Assn for a Scenic Community v. County of Los Angeles (1974) 11 Cal. 3d 506, 515.])
Additionally, RCM BIO-1 as framed, presents as a commonplace biological mitigation measure implemented as part of CEQA review for a development project. The language and requirements included in the measures are indicative of an overall finding that the Project has the potential to result in significant impacts on biological resources. However, because of the methodology being applied by the City in the DEIR for this Project, the RCM will not be enforceable in the same manner as standard mitigation measures incorporated in the Project’s Mitigation Monitoring and Reporting Plan. A mitigation measure must be enforceable through conditions of approval, contracts or other means that are legally binding. (PRC § 21081.6; CEQA Guidelines § 15126.4(a)(2).) Mitigation measures should be implemented, not adopted and ignored (Federation of Hillside & Canyon Ass’ns v. City of Los Angeles (2000) 83 Cal.App.4th 1252, 1261.) The DEIR for the Project currently provides no concrete assurance that RCM BIO-1 (even in its current in adequate form) will in fact be implemented in connection with the construction of the Project.
Accordingly, the nesting period and survey plan set forth in the RCM BIO-1 is inadequate based on CDFW’s own guidance, and the DEIR cannot permissibly rely exclusively on regulatory compliance without a greater showing and analysis, based on substantial evidence, that the Project’s biological resources impacts will be less than significant based on said regulatory compliance. Given that, at a minimum, the DEIR must be revised and recirculated to demonstrate sufficient analysis and study of the Project’s biological resources impacts and substantial evidence to indicate that the Project’s compliance with the Fish and Game Code and Migratory Bird Treaty Act will sufficiently mitigate any such impacts. Based on the positions set forth by CDFW in its guidance, the DEIR should further be revised to require that prior to construction of the Project, a sweep should be conducted verifying the absence of any nesting birds during both nesting and non-nesting seasons in order to account for CDFW’s findings pertaining to the bird/raptor nesting season within the Project’s geographic region.
Absent such revision, the proposed RCM and, by extension, the DEIR will be in direct violation of the CEQA Guidelines.
B2-7
cont.
30 As stated above, the Project, as proposed, plans and intends to remove 211 mature trees currently present on the Project site, with some as tall as 65 feet and/or having trunk circumferences as large as 57 inches and crown widths of 30 feet across. See DEIR Appendix 4.4-1, pp. 2-3. Despite its removal of a large number of established trees, the proposed Project does not contemplate or provide specifics on any new replacement trees that will be planted as part of the development process. Instead, the Project’s DEIR and its associated Specimen Tree Report (Appendix 4.4-1) hides behind the notion that the City’s Tree Ordinance does not require any replacement trees to be planted as mitigation for the tree removal. In this regard, the DEIR improperly conflates the Project’s regulatory compliance as to the contemplated tree removal with a less than significant biological resources impact.
Again, a determination that regulatory compliance will be sufficient to prevent significant adverse impacts must be based on a project-specific analysis of potential impacts and the effect of regulatory compliance. See Californians for Alternatives to Toxics, supra, (2005) 136 Cal.App.4th 1. Here, the DEIR improperly fails to disclose “the analytic route that the agency took from the evidence to its findings.” (Cal. Public Resources Code § 21081.5; CEQA Guidelines § 15093; Village Laguna of Laguna Beach, Inc. v. Board of Supervisors (1982) 134 Cal. App. 3d 1022, 1035 [quoting Topanga Assn for a Scenic Community v. County of Los Angeles (1974) 11 Cal. 3d 506, 515.]) The deficiency of the DEIR and its mitigation of the impacts of the planned tree removal is underscored by the fact that the DEIR’s Specimen Tree Report recommends that “…trees be incorporated be incorporated into the redeveloped landscape…” for the Project.
DEIR, Appendix 4.4-1, p. 3. Despite this acknowledgement in the impact study, the Project and its DEIR fail to commit to any types or quantities of tree to be replanted as part of the development.
Accordingly, the DEIR further fails to properly study, analyze, and mitigate the Project’s biological resources impacts, despite the substantial evidence of potentially significant impacts, such that revision and recirculation of the DEIR is now required under CEQA.
B2-8
31 C. The DEIR’s Mitigation Measures Are Insufficient
A fundamental purpose of an EIR is to identify ways in which a proposed project's significant environmental impacts can be mitigated or avoided. Pub. Res. Code §§ 21002.1(a), 21061. To implement this statutory purpose, an EIR must describe any feasible mitigation measures that can minimize the project's significant environmental effects. PRC §§ 21002.1(a), 21100(b)(3); CEQA Guidelines §§ 15121(a), 15126.4(a).
If the project has a significant effect on the environment, the agency may approve the project only upon finding that it has “eliminated or substantially lessened all significant effects on the environment where feasible” PRC §§ 21002; 21002.1, 21081; CEQA Guidelines §§ 15091, 15092(b)(2)(A); and find that ‘specific overriding economic, legal, social, technology or other benefits of the project outweigh the significant effects on the environment.” PRC §§ 21002; 21002.1, 21081; CEQA Guidelines §§ 15091, 15092(b)(2)(B). “A gloomy forecast of environmental degradation is of little or no value without pragmatic, concrete means to minimize the impacts and restore ecological equilibrium.” Environmental Council of Sacramento v. City of Sacramento (2006) 142 Cal.App.4th 1018, 1039.
CEQA mitigation measures proposed and adopted are required to describe what actions will be taken to reduce or avoid an environmental impact. (CEQA Guidelines § 15126.4(a)(1)(B) [providing “[f]ormulation of mitigation measures should not be deferred until some future time.”].) While the same Guidelines section 15126.5(a)(1)(B) acknowledges an exception to the rule against deferrals, such exception is narrowly proscribed to situations where it is impractical or infeasible to include those details during the project's environmental review.
According to CEQA Guidelines, “[w]hen an EIR has been prepared for a project, the Responsible Agency shall not approve the project as proposed if the agency finds any feasible alternative or feasible mitigation measures within its powers that would substantially lessen or avoid any significant effect the project would have on the environment.” CEQA Guidelines Section 15096(g)(2).
Here, the EIR’s mitigation measures for the Project are inadequate as follows:
CEQA forbids deferred mitigation. Guidelines § 15126.4(a)(1)(B). CEQA allows deferral of details of a mitigation measure only “when it is impractical or infeasible to include those details during the project’s environmental review.” (Id.) CEQA further B2-9
B2-10
32 requires: “that the agency (1) commits itself to the mitigation, (2) adopts specific performance standards the mitigation will achieve, and (3) identifies the type(s) of potential action(s) that can feasibly achieve that performance standard…” Guidelines § 15126.4(a)(1)(B). Deferring formulation of a Project’s actual mitigation measures to some undefined time after the Project’s approval is improper and cannot be used as a substitute for proper mitigation under CEQA. Impermissible deferral can occur when an EIR calls for mitigation measures to be created based on future studies or describes mitigation measures in general terms but the agency fails to commit itself to specific performance standards. (Preserve Wild Santee v. City of Santee (2012) 210 Cal.App.4th 260, 281 [city improperly deferred mitigation to butterfly habitat by failing to provide standards or guidelines for its management].) Here, the EIR improperly defers details of the Project’s mitigation measures as discussed in detail below.
i. Cultural Resources Mitigation Measures
The Project’s Cultural Resources Mitigation Measure CUL-2 provides as follows, in relevant part:
Archaeologist Monitoring: Prior to the issuance of the grading permit, the Property Owner/Developer shall retain a qualified archaeologist to observe grading activities within previously undisturbed soils and to salvage and catalog archaeological resources, as necessary. The archaeologist will establish procedures for surveillance and for temporarily halting or redirecting work for artifact sampling, identification, and evaluation.
DEIR at p. ES-10.
The above mitigation measure, on its face, defers the preparation of the required procedures for monitoring and halting/redirecting construction activities based on the presence and/or discovery of protected cultural resources at the project site. The postponement of the preparation of the substance of this mitigation measure denies the public and the City’s decisionmakers of the opportunity to assess the adequacy of the Project’s cultural resources mitigation and monitoring plan, and the Project’s overall impact on cultural resources with respect to ensuring such impacts are adequately mitigated and minimized. Indeed, because of this deferment, the City’s decisionmakers have been denied the opportunity to fully consider the scope of the Type tex
B2-10
cont.
B2-11
33 Project’s potential impacts to cultural resources and whether such impacts have been adequately mitigated, while the general public has also been denied the opportunity to assess and comment upon the associated impacts and the adequacy of the mitigation plans.
Thus, in the context of MM CUL-1, the City has failed to meet CEQA’s preconditions and requirements concerning mitigation, as the DEIR has failed to show why the Project’s cultural resources response plan, and a comprehensive analysis of the Project’s anticipated impacts on such cultural resources, cannot be completed or achieved at this time prior to adoption of the EIR. The deferment of this study and analysis also improperly constrains the DEIR’s assessment of the impacts that the measure will have individually or cumulatively, and the specific performance criteria the Applicant will have to meet with regard to the measures. Accordingly, the proposed mitigation measure is improperly deferred as it defers the formulation of components of the mitigation to a later time and further does not explain how the measure will clearly reduce the Project’s cultural resources impacts to a level of insignificance. ii. Geology and Soils Mitigation Measures
The Project’s Geology and Soils Mitigation Measure MM GEO-1 provides as follows, in relevant part:
Prior to the issuance of grading and building permits, the City of Anaheim Building Division and Public Works Department shall review all Project plans for grading, foundation, structural, infrastructure, and all other relevant construction permits to ensure compliance with the recommendations contained in the Project's Geotechnical Exploration and Feasibility Report.
DEIR at p. ES-13.
Moreover, MM GEO-2 provides as follows, in relevant part:
If paleontological resources are inadvertently unearthed, the contractor shall immediately cease all earth-disturbing activities within a 50-foot radius.
, including salvage operations if
avoidance is not feasible.
DEIR at p. ES-14 (emphasis added).
B2-11
cont.
B2-12
34 Much like the Project’s MM CUL-1, the above mitigation measures impermissibly defer the preparation of any actual mitigation associated with the Project’s geological impacts. Worse yet, MM GEO-1 vaguely attempts to incorporate by reference the “recommendations” of the Project’s Geotechnical Exploration and Feasibility Report as potential mitigation measures for the Project. The deferment of the preparation of these mitigation measures, coupled with MM GEO-1’s lack of specificity and certainty regarding what mitigation will in fact be deployed to combat impacts associated with potential seismic ground shaking and/or unstable/expansive soils, render the mitigation measures improperly deferred and uncertain. In this regard, the mitigation measure makes no commitment whatsoever to mitigation on this issue, which is required by CEQA.
Thus, in the context of MM GEO-1 and MM GEO-2, the City has failed to meet CEQA’s preconditions and requirements concerning mitigation, as the DEIR has failed to make the “recommendations” of the Geotechnical Exploration and Feasibility Report a mandatory component of mitigation on the Project and has failed to present a clear response plan in the event that paleontological resources are discovered during construction. Accordingly, the proposed mitigation measures, as currently constituted, violate CEQA and must be appropriately revised and recirculated.
iii. Hazards and Hazardous Materials Mitigation Measures The Project’s Hazards and Hazardous Materials Mitigation Measure MM HAZ-1 provides as follows, in relevant part:
Construction Management Plan: Prior to the issuance of grading permits, a Construction Management Plan shall be prepared by the Property Owner/Developer for review and approval by Anaheim Fire and Rescue, in accordance with MUTCD. It must identify emergency access points and routes throughout all construction phases.
DEIR at p. ES-17.
The Project’s Mitigation Measure MM HAZ-1 improperly and unjustifiably defers preparation of the Construction Management Plan (CMP) until after the Project has been approved by the City and shortly before construction is to commence. The preparation of the CMP in connection with the Project’s hazards mitigation efforts has been established as a required, unconditional mitigation effort in connection with B2-12
cont.
B2-13
35 the Project. As such, there is simply no valid explanation for the DEIR’s failure to prepare and include the required CMP the as part of the appendices for the Project’s environmental review, thereby providing the City and the general public with an full and appropriate opportunity to assess the adequacy of the Project’s hazards mitigation plans in this regard. The DEIR’s failure to prepare and provide this information at this time once again violates CEQA.
Thus, with respect to MM HAZ-1, the DEIR has once again failed to meet CEQA’s preconditions and requirements concerning mitigation by deferring the further study, analysis and preparation of mitigation measures and plans to address the Project’s anticipated Hazards impacts. The DEIR’s cannot permissibly constrain its assessment of the individual and cumulative impacts of these measures, or withhold reporting of the specific performance criteria the Applicant will have to meet with regard to the measures, particularly when there is nothing to prevent current further study of these impacts and the preparation of the required mitigation plan vis-à-vis the CMP. Once again, the DEIR has violated CEQA by deferring the formulation of critical aspects of its hazards mitigation to a later time, such that revision and recirculation of the DEIR to supply this necessary study and information is now required.
D. The DEIR Improperly Mischaracterizes its Transportation and Hazards Mitigation Measure as “Project Design Features” In this instance, the DEIR also improperly recasts what would otherwise be essential Transportation and Hazards impact mitigation measures as a “Project Design Features” or “PDF.” Relying in part on these PDFs for the Project, the DEIR then concludes that the Project’s Transportation impacts will be less than significant, and that no further mitigation is required, while also improperly leveraging the PDFs aimed at the Project’s Hazards impacts in conjunction with the Project’s lone Hazards mitigation measure, MM HAZ-1, to conclude that the Project’s otherwise significant hazards impacts have been to a less than significant level.
It is established that “‘[a]voidance, minimization and / or mitigation measure’ . . . are not ‘part of the project.’ . . . compressing the analysis of impacts and mitigation measures into a single issue . . . disregards the requirements of CEQA.” (Lotus v.
Department of Transportation (2014) 223 Cal. App. 4th 645, 656.) When “an agency decides to incorporate mitigation measures into its significance determination, and relies on those mitigation measures to determine that no B2-13
cont.
B2-14
36 significant effects will occur, that agency must treat those measures as though they were adopted following a finding of significance.” (Lotus, supra, 223 Cal. App. 4th at 652 [citing CEQA Guidelines § 15091(a)(1) and Cal. Public Resources Code § 21081(a)(1).])
By mischaracterizing the Transportation and Hazards mitigation measures as PDFs, the City violates CEQA by failing to disclose “the analytic route that the agency took from the evidence to its findings.” (Cal. Public Resources Code § 21081.5; CEQA Guidelines § 15093; Village Laguna of Laguna Beach, Inc. v. Board of Supervisors (1982) 134 Cal. App. 3d 1022, 1035 [quoting Topanga Assn for a Scenic Community v. County of Los Angeles (1974) 11 Cal. 3d 506, 515.])
Specifically, the DEIR delineates the following Transportation and Hazards PDFs to be applied to the project, which are tantamount to (and otherwise routinely adopted as) mitigation measures under CEQA:
PDF HAZ-1 Construction Fire Prevention Plan: Prior to
commencement of construction activities, the Property
Owner/Developer shall prepare and implement a Construction Fire Prevention Plan that identifies fire safety measures to be followed by the Project's contractor throughout all phases of construction. The Plan shall be submitted to Anaheim Fire & Rescue for review and approval prior to the start of construction activities.
PDF HAZ-2 Wildfire Evacuation and Awareness Plan: Prior to issuance of a certificate of occupancy for the first multiple-family residential unit, the Property Owner/Developer shall prepare and implement a Project-specific Wildfire Evacuation and Awareness Plan.
The Plan shall be subject to review and approval by the City of Anaheim Planning Department, Anaheim Police Department, and Anaheim Fire & Rescue. The Plan shall include, at a minimum, the following components:
(1) The Plan shall be provided to all tenants along with all lease agreements for development and dissemination of wildfire evacuation outreach materials. These materials shall be provided to residents and employees within the Project annually. The outreach materials shall depict evacuation routes to use in case of a wildfire event and will provide other practical wildfire preparedness information; (3) The Plan shall include requirements for annual emergency evacuation drills for residents and employees in the B2-14
cont.
37 Project site; and (4) The Plan shall include the development, implementation, and ongoing maintenance of a method for the Property Owner/Developer to quickly and effectively communicate emergency alerts to individuals at the Project site, such as through the installation and maintenance of a wireless Public Address (PA) system and/or wireless texting services, or other equivalent systems or methods approved by Anaheim Fire & Rescue. … PDF TRANS-1 Affordable Housing (CAPCOA Measure T-4): The Project shall include 45 moderate-income level housing units, representing 10 percent of the total 447 dwelling units. This measure is estimated to reduce project-generated VMT by approximately 2.86 percent or 1,621 VMT.
PDF TRANS-2 Limit Residential Parking Supply (CAPCOA
Measure T-15): The Project shall provide a total of 893 parking spaces, which is 70 spaces fewer than the 963 spaces required by the City's development standards. This reduction in parking supply is expected to reduce project-generated VMT by 1.0 percent, or 567 VMT.
DEIR, pp. ES-15 – 17, ES-24.
Notably, the DEIR acknowledges that, absent the incorporation of the foregoing PDFs in the Project, the Project is anticipated to have both significant Hazards and Transportation impacts with respect to (i) impairing the implementation of or physically interfering with an adopted emergency response plan or emergency evacuation plan, (ii) conflicting or being inconsistent with State CEQA Guidelines Section 15064.3(b), and (iii) resulting in inadequate emergency access . Id. According to the DEIR, these significant impacts of the Project will purportedly be cured, either in whole or in part, via the incorporation of PDF HAZ-1, PDF HAZ-2, PDF TRANS-1, and PDF TRANS-2.
However, implementing a Wildfire Evacuation and Awareness Plan, ensuring minimum levels of affordable housing, and limiting residential parking are not bona fide features of “project design.” Rather, the PDFs amount to the DEIR’s mislabeling and disguising of what are otherwise a mitigation measures for the Project. Here, the DEIR has premised it analysis regarding the allegedly “less than significant impact” on B2-14
cont.
38 Transportation and Hazards on the incorporation of the so-called PDFs. To that end, the Transportation and Hazards impacts analysis put forth in the DEIR is demonstrably tainted and flawed by the improper application and incorporation of these PDFs.
By recasting its transportation and hazards mitigation measures in this manner, the DEIR has attempted to skirt its responsibilities to fully analyze the various environmental impacts implicated by the PDFs. Such an attempt to evade accountability for addressing the Project’s transportation and hazards impacts directly violates CEQA, and the DEIR cannot permissibly be certified unless and until this deficiency is rectified.
V. CONCLUSION
Based on the foregoing concerns, the City should require revision and recirculation of the DEIR for the Project pursuant to CEQA. Absent doing so, the DEIR in its current form directly violates CEQA in multiple respects. If the City should have any questions or concerns, please do not hesitate to contact this office.
Sincerely, ______________________
Jeremy Herwitt
Attorneys for Western States Regional Council of Carpenters Attached:
March 8, 2021 SWAPE Letter to Mitchell M. Tsai re Local Hire Requirements and Considerations for Greenhouse Gas Modeling (Exhibit A); Air Quality and GHG Expert Paul Rosenfeld CV (Exhibit B); and Air Quality and GHG Expert Matt Hagemann CV (Exhibit C).
B2-14
cont.
B2-15
39 EXHIBIT A
40 1
2656 29th Street, Suite 201
Santa Monica, CA 90405
Matt Hagemann, P.G, C.Hg.
(949) 887-9013
[email protected]
Paul E. Rosenfeld, PhD
(310) 795-2335
[email protected]
March 8, 2021
Mitchell M. Tsai
155 South El Molino, Suite 104
Pasadena, CA 91101
Subject: Local Hire Requirements and Considerations for Greenhouse Gas Modeling Dear Mr. Tsai,
Soil llowing draft technical report
explaining the significance of worker trips required for construction of land use development projects with respect to the estimation of
local hire requirements to reduce the length of worker trips, and consequently, reduced or mitigate the potential GHG impacts.
Worker Trips and Greenhouse Gas Calculations
The California Emissions Estimator Model ( CalEEMod is a statewide land use emissions computer model designed to provide a uniform platform for government agencies, land use planners, and environmental professionals to quantify potential criteria pollutant and greenhouse gas (GHG) emissions associated with both construction and operations from a variety of land use projects 1 CalEEMod quantifies construction-related
emissions associated with land use projects resulting from off-road construction equipment; on-road mobile equipment associated with workers, vendors, and hauling; fugitive dust associated with grading, demolition, truck loading, and on-road vehicles traveling along paved and unpaved roads; and architectural coating activities; and paving.2
The number, length, and vehicle class of worker trips are utilized by CalEEMod to calculate emissions associated with the on-road vehicle trips required to transport workers to and from the Project site during construction.3 1 California Emissions Estimator Model CAPCOA, 2017, available at: http://www.aqmd.gov/caleemod/home. 2 California Emissions Estimator Model CAPCOA, 2017, available at: http://www.aqmd.gov/caleemod/home. 3 available at: http://www.aqmd.gov/docs/defaultsource/caleemod/01_user-39-s-guide2016-3-2_15november2017.pdf?sfvrsn=4, p. 34. 41 2
Specifically, the number and
associated with construction. Then, utilizing vehicle-class specific EMFAC 2014 emission factors, CalEEMod calculates the vehicle exhaust, evaporative, and dust emissions resulting from construction-related VMT, including personal vehicles for worker commuting.4
Specifically, in order to calculate VMT, CalEEMod multiplies the average daily trip rate by the average overall trip length (see excerpt below):
d Daily Trip Rate i
* Average Overall Trip Length i) n Where:
5 Furthermore, to calculate the on-road emissions associated with worker trips, CalEEMod utilizes the following equation (see excerpt below):
Emissionspollutant = VMT * EFrunning,pollutant Where:
Emissionspollutant = emissions from vehicle running for each pollutant VMT = vehicle miles traveled
EFrunning,pollutant = emission factor for running emissions. 6 Thus, there is a direct relationship between trip length and VMT, as well as a direct relationship between VMT and vehicle running emissions. In other words, when the trip length is increased, the VMT and vehicle running emissions increase as a result. Thus, vehicle running emissions can be reduced by decreasing the average overall trip length, by way of a local hire requirement or otherwise.
Default Worker Trip Parameters and Potential Local Hire Requirements As previously discussed, the number, length, and vehicle class of worker trips are utilized by CalEEMod to calculate emissions associated with the on-road vehicle trips required to transport workers to and from the Project site during construction.7
In order to understand how local hire requirements and associated worker trip length reductions impact GHG emissions calculations, it is important to consider the CalEEMod default worker trip parameters. CalEEMod provides recommended default values based on site-specific information, such as land use type, meteorological data, total lot acreage, project type and typical equipment associated with project type. If more specific project information is known, the user can change the default values and input projectspecific values, but the California Environmental Quality Act substantial evidence.8 The default number of construction-related worker trips is calculated by multiplying the 4 available at: http://www.aqmd.gov/docs/defaultsource/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 14-15. 5 available at: http://www.aqmd.gov/docs/defaultsource/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 23. 6 available at: http://www.aqmd.gov/docs/defaultsource/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 15. 7 available at: http://www.aqmd.gov/docs/defaultsource/caleemod/01_user-39-s-guide2016-3-2_15november2017.pdf?sfvrsn=4, p. 34. 8 CalEEMod User Guide, available at: http://www.caleemod.com/, p. 1, 9. 42 3
number of pieces of equipment for all phases by 1.25, with the exception of worker trips required for the building construction and architectural coating phases.9 Furthermore, the worker trip vehicle class is a 50/25/25 percent mix of light duty autos, light duty truck class 1 and light duty truck class 2, respectively 10 Finally, the default worker trip length is consistent with the length of the operational home-to-work vehicle trips.11 The operational home-to-work vehicle trip lengths are:
location and urbanization selected on the project characteristic screen. These values were supplied by the air districts or use a default average for the state. Each district (or county) also 12 Thus, the default worker trip length is based on the location and urbanization level selected by the User when modeling emissions. The below table shows the CalEEMod default rural and urban worker trip lengths by air basin (see excerpt below and Attachment A).13
Worker Trip Length by Air Basin
Air Basin Rural (miles) Urban (miles)
Great Basin Valleys 16.8 10.8
Lake County 16.8 10.8
Lake Tahoe 16.8 10.8
Mojave Desert 16.8 10.8
Mountain Counties 16.8 10.8
North Central Coast 17.1 12.3
North Coast 16.8 10.8
Northeast Plateau 16.8 10.8
Sacramento Valley 16.8 10.8
Salton Sea 14.6 11
San Diego 16.8 10.8
San Francisco Bay Area 10.8 10.8
San Joaquin Valley 16.8 10.8
South Central Coast 16.8 10.8
South Coast 19.8 14.7
Average 16.47 11.17
Minimum 10.80 10.80
Maximum 19.80 14.70
Range 9.00 3.90 9 available at: http://www.aqmd.gov/docs/defaultsource/caleemod/01_user-39-s-guide2016-3-2_15november2017.pdf?sfvrsn=4, p. 34. 10 available at:
http://www.aqmd.gov/docs/default-source/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 15. 11 available at:
http://www.aqmd.gov/docs/default-source/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 14. 12 available at:
http://www.aqmd.gov/docs/default-source/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 21. 13 available at: http://www.aqmd.gov/docs/defaultsource/caleemod/05_appendix-d2016-3-2.pdf?sfvrsn=4, p. D-84 D-86. 43 4
As demonstrated above, default rural worker trip lengths for air basins in California vary from 10.8- to 19.8- miles, with an average of 16.47 miles. Furthermore, default urban worker trip lengths vary from 10.8- to 14.7- miles, with an average of 11.17 miles. Thus, while default worker trip lengths vary by location, default urban worker trip lengths tend to be shorter in length. Based on these trends evident in the CalEEMod default worker trip lengths, we can reasonably assume that the efficacy of a local hire requirement is especially dependent upon the urbanization of the project site, as well as the project location.
Practical Application of a Local Hire Requirement and Associated Impact To provide an example of the potential impact of a local hire provision on construction-related GHG emissions, we estimated the significance of a local hire provision for the Village South Specific Plan . The Project proposed to construct 1,000 residential units, 100,000-SF of retail space, 45,000-SF of office space, as well as a 50-room hotel, on the 24-acre site. The Project location is classified as Urban and lies within the Los Angeles-South Coast County. As a result, the Project has a default worker trip length of 14.7 miles.14 In an effort to evaluate the potential for construction-related GHG emissions, we prepared an updated model, reducing all worker trip lengths to 10 miles (see Attachment B). Our analysis estimates that if a local hire provision with a 10-mile radius were to be implemented, the GHG emissions associated with Project construction would decrease by approximately 17% (see table below and Attachment C).
Local Hire Provision Net Change
Without Local Hire Provision
Total Construction GHG Emissions (MT CO2e) 3,623
Amortized Construction GHG Emissions (MT CO2e/year) 120.77 With Local Hire Provision
Total Construction GHG Emissions (MT CO2e) 3,024
Amortized Construction GHG Emissions (MT CO2e/year) 100.80 % Decrease in Construction-related GHG Emissions 17%
As demonstrated above, by implementing a local hire provision requiring 10 mile worker trip lengths, the Project could reduce potential GHG emissions associated with construction worker trips. More broadly, any local hire requirement that results in a decreased worker trip length from the default value has the potential to result in a reduction of construction-related GHG emissions, though the significance of the reduction would vary based on the location and urbanization level of the project site.
This serves as an example of the potential impacts of local hire requirements on estimated project-level GHG emissions, though it does not indicate that local hire requirements would result in reduced construction-related GHG emission for all projects. As previously described, the significance of a local hire requirement depends on the worker trip length enfor
location. 14 available at: http://www.aqmd.gov/docs/defaultsource/caleemod/05_appendix-d2016-3-2.pdf?sfvrsn=4, p. D-85. 44 5
Disclaimer
SWAPE has received limited discovery. Additional information may become available in the future; thus, we retain the right to revise or amend this report when additional information becomes available. Our professional services have been performed using that degree of care and skill ordinarily exercised, under similar circumstances, by reputable environmental consultants practicing in this or similar localities at the time of service. No other warranty, expressed or implied, is made as to the scope of work, work methodologies and protocols, site conditions, analytical testing results, and findings presented. This report reflects efforts which were limited to information that was reasonably accessible at the time of the work, and may contain informational gaps, inconsistencies, or otherwise be incomplete due to the unavailability or uncertainty of information obtained or provided by third parties.
Sincerely,
Matt Hagemann, P.G., C.Hg.
Paul E. Rosenfeld, Ph.D.
45 Location Type Location Name Rural H-W
(miles)
Urban H-W
(miles)
Air Basin Great Basin 16.8 10.8
Air Basin Lake County 16.8 10.8
Air Basin Lake Tahoe 16.8 10.8
Air Basin Mojave Desert 16.8 10.8
Air Basin Mountain 16.8 10.8
Air Basin North Central 17.1 12.3
Air Basin North Coast 16.8 10.8
Air Basin Northeast 16.8 10.8
Air Basin Sacramento 16.8 10.8
Air Basin Salton Sea 14.6 11
Air Basin San Diego 16.8 10.8
Air Basin San Francisco 10.8 10.8
Air Basin San Joaquin 16.8 10.8
Air Basin South Central 16.8 10.8
Air Basin South Coast 19.8 14.7
Air District Amador County 16.8 10.8
Air District Antelope Valley 16.8 10.8
Air District Bay Area AQMD 10.8 10.8
Air District Butte County 12.54 12.54
Air District Calaveras 16.8 10.8
Air District Colusa County 16.8 10.8
Air District El Dorado 16.8 10.8
Air District Feather River 16.8 10.8
Air District Glenn County 16.8 10.8
Air District Great Basin 16.8 10.8
Air District Imperial County 10.2 7.3
Air District Kern County 16.8 10.8
Air District Lake County 16.8 10.8
Air District Lassen County 16.8 10.8
Air District Mariposa 16.8 10.8
Air District Mendocino 16.8 10.8
Air District Modoc County 16.8 10.8
Air District Mojave Desert 16.8 10.8
Air District Monterey Bay 16.8 10.8
Air District North Coast 16.8 10.8
Air District Northern Sierra 16.8 10.8
Air District Northern 16.8 10.8
Air District Placer County 16.8 10.8
Air District Sacramento 15 10
46 Air District San Diego 16.8 10.8
Air District San Joaquin 16.8 10.8
Air District San Luis Obispo 13 13
Air District Santa Barbara 8.3 8.3
Air District Shasta County 16.8 10.8
Air District Siskiyou County 16.8 10.8
Air District South Coast 19.8 14.7
Air District Tehama County 16.8 10.8
Air District Tuolumne 16.8 10.8
Air District Ventura County 16.8 10.8
Air District Yolo/Solano 15 10
County Alameda 10.8 10.8
County Alpine 16.8 10.8
County Amador 16.8 10.8
County Butte 12.54 12.54
County Calaveras 16.8 10.8
County Colusa 16.8 10.8
County Contra Costa 10.8 10.8
County Del Norte 16.8 10.8
County El Dorado-Lake 16.8 10.8
County El Dorado- 16.8 10.8
County Fresno 16.8 10.8
County Glenn 16.8 10.8
County Humboldt 16.8 10.8
County Imperial 10.2 7.3
County Inyo 16.8 10.8
County Kern-Mojave 16.8 10.8
County Kern-San 16.8 10.8
County Kings 16.8 10.8
County Lake 16.8 10.8
County Lassen 16.8 10.8
County Los Angeles- 16.8 10.8
County Los Angeles- 19.8 14.7
County Madera 16.8 10.8
County Marin 10.8 10.8
County Mariposa 16.8 10.8
County Mendocino- 16.8 10.8
County Mendocino- 16.8 10.8
County Mendocino- 16.8 10.8
County Mendocino- 16.8 10.8
County Merced 16.8 10.8
County Modoc 16.8 10.8
County Mono 16.8 10.8
County Monterey 16.8 10.8
County Napa 10.8 10.8
47 County Nevada 16.8 10.8
County Orange 19.8 14.7
County Placer-Lake 16.8 10.8
County Placer-Mountain 16.8 10.8
County Placer- 16.8 10.8
County Plumas 16.8 10.8
County Riverside- 16.8 10.8
County Riverside- 19.8 14.7
County Riverside-Salton 14.6 11
County Riverside-South 19.8 14.7
County Sacramento 15 10
County San Benito 16.8 10.8
County San Bernardino- 16.8 10.8
County San Bernardino- 19.8 14.7
County San Diego 16.8 10.8
County San Francisco 10.8 10.8
County San Joaquin 16.8 10.8
County San Luis Obispo 13 13
County San Mateo 10.8 10.8
County Santa Barbara- 8.3 8.3
County Santa Barbara- 8.3 8.3
County Santa Clara 10.8 10.8
County Santa Cruz 16.8 10.8
County Shasta 16.8 10.8
County Sierra 16.8 10.8
County Siskiyou 16.8 10.8
County Solano- 15 10
County Solano-San 16.8 10.8
County Sonoma-North 16.8 10.8
County Sonoma-San 10.8 10.8
County Stanislaus 16.8 10.8
County Sutter 16.8 10.8
County Tehama 16.8 10.8
County Trinity 16.8 10.8
County Tulare 16.8 10.8
County Tuolumne 16.8 10.8
County Ventura 16.8 10.8
County Yolo 15 10
County Yuba 16.8 10.8
Statewide Statewide 16.8 10.8
48 Air Basin Rural (miles) Urban (miles)
Great Basin Valleys 16.8 10.8
Lake County 16.8 10.8
Lake Tahoe 16.8 10.8
Mojave Desert 16.8 10.8
Mountain Counties 16.8 10.8
North Central Coast 17.1 12.3
North Coast 16.8 10.8
Northeast Plateau 16.8 10.8
Sacramento Valley 16.8 10.8
Salton Sea 14.6 11
San Diego 16.8 10.8
San Francisco Bay Area 10.8 10.8
San Joaquin Valley 16.8 10.8
South Central Coast 16.8 10.8
South Coast 19.8 14.7
Average 16.47 11.17
Mininum 10.80 10.80
Maximum 19.80 14.70
Range 9.00 3.90
Worker Trip Length by Air Basin
49 50
51 52
53 54
55 56
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Total Construction GHG Emissions (MT CO2e) 3,623
Amortized (MT CO2e/year) 120.77
Total Construction GHG Emissions (MT CO2e) 3,024
Amortized (MT CO2e/year) 100.80
% Decrease in Construction-related GHG Emissions 17%
Local Hire Provision Net Change
With Local Hire Provision
Without Local Hire Provision
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EXHIBIT B
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EXHIBIT C
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1640 5th St.., Suite 204 Santa
Santa Monica, California 90401
Tel: (949) 887-9013
Email: [email protected]
Matthew F. Hagemann, P.G., C.Hg., QSD, QSP
Geologic and Hydrogeologic Characterization
Industrial Stormwater Compliance
Investigation and Remediation Strategies
Litigation Support and Testifying Expert
CEQA Review
Education:
M.S. Degree, Geology, California State University Los Angeles, Los Angeles, CA, 1984.
B.A. Degree, Geology, Humboldt State University, Arcata, CA, 1982.
Professional Certifications:
California Professional Geologist
California Certified Hydrogeologist
Qualified SWPPP Developer and Practitioner
Professional Experience:
Matt has 25 years of experience in environmental policy, assessment and remediation. He spent nine years with the U.S. EPA in the RCRA and Superfund programs and served as EPA’s Senior Science Policy Advisor in the Western Regional Office where he identified emerging threats to groundwater from perchlorate and MTBE. While with EPA, Matt also served as a Senior Hydrogeologist in the oversight of the assessment of seven major military facilities undergoing base closure. He led numerous enforcement actions under provisions of the Resource Conservation and Recovery Act (RCRA) while also working with permit holders to improve hydrogeologic characterization and water quality monitoring.
Matt has worked closely with U.S. EPA legal counsel and the technical staff of several states in the application and enforcement of RCRA, Safe Drinking Water Act and Clean Water Act regulations. Matt has trained the technical staff in the States of California, Hawaii, Nevada, Arizona and the Territory of Guam in the conduct of investigations, groundwater fundamentals, and sampling techniques.
Positions Matt has held include:
Founding Partner, Soil/Water/Air Protection Enterprise (SWAPE) (2003 – present); Geology Instructor, Golden West College, 2010 – 2 4;
Senior Environmental Analyst, Komex H2O Science, Inc. (2000 -- 2003); 291
Executive Director, Orange Coast Watch (2001 – 2004);
Senior Science Policy Advisor and Hydrogeologist, U.S. Environmental Protection Agency (1989– 1998);
Hydrogeologist, National Park Service, Water Resources Division (1998 – 2000); Adjunct Faculty Member, San Francisco State University, Department of Geosciences (1993 – 1998);
Instructor, College of Marin, Department of Science (1990 – 1995); Geologist, U.S. Forest Service (1986 – 1998); and
Geologist, Dames & Moore (1984 – 1986).
Senior Regulatory and Litigation Support Analyst:
With SWAPE, Matt’s responsibilities have included:
Lead analyst and testifying expert in the review of over 100 environmental impact reports since 2003 under CEQA that identify significant issues with regard to hazardous waste, water resources, water quality, air quality, Valley Fever, greenhouse gas emissions, and geologic hazards. Make recommendations for additional mitigation measures to lead agencies at the local and county level to include additional characterization of health risks and implementation of protective measures to reduce worker exposure to hazards from toxins and Valley Fever.
Stormwater analysis, sampling and best management practice evaluation at industrial facilities.
Manager of a project to provide technical assistance to a community adjacent to a former Naval shipyard under a grant from the U.S. EPA.
Technical assistance and litigation support for vapor intrusion concerns.
Lead analyst and testifying expert in the review of environmental issues in license applications for large solar power plants before the California Energy Commission.
Manager of a project to evaluate numerous formerly used military sites in the western U.S.
Manager of a comprehensive evaluation of potential sources of perchlorate contamination in Southern California drinking water wells.
Manager and designated expert for litigation support under provisions of Proposition 65 in the review of releases of gasoline to sources drinking water at major refineries and hundreds of gas stations throughout California.
Expert witness on two cases involving MTBE litigation.
Expert witness and litigation support on the impact of air toxins and hazards at a school.
Expert witness in litigation at a former plywood plant.
With Komex H2O Science Inc., Matt’s duties included the following:
Senior author of a report on the extent of perchlorate contamination that was used in testimony by the former U.S. EPA Administrator and General Counsel.
Senior researcher in the development of a comprehensive, electronically interactive chronology of MTBE use, research, and regulation.
Senior researcher in the development of a comprehensive, electronically interactive chronology of perchlorate use, research, and regulation.
Senior researcher in a study that estimates nationwide costs for MTBE remediation and drinking water treatment, results of which were published in newspapers nationwide and in testimony against provisions of an energy bill that would limit liability for oil companies.
Research to support litigation to restore drinking water supplies that have been contaminated by MTBE in California and New York.
292
Expert witness testimony in a case of oil production-related contamination in Mississippi.
Lead author for a multi-volume remedial investigation report for an operating school in Los Angeles that met strict regulatory requirements and rigorous deadlines. 293
Development of strategic approaches for cleanup of contaminated sites in consultation with clients and regulators.
Executive Director:
As Executive Director with Orange Coast Watch, Matt led efforts to restore water quality at Orange County beaches from multiple sources of contamination including urban runoff and the discharge of wastewater. In reporting to a Board of Directors that included representatives from leading Orange County universities and businesses, Matt prepared issue papers in the areas of treatment and disinfection of wastewater and control of the discharge of grease to sewer systems. Matt actively participated in the development of countywide water quality permits for the control of urban runoff and permits for the discharge of wastewater. Matt worked with other nonprofits to protect and restore water quality, including Surfrider, Natural Resources Defense Council and Orange County CoastKeeper as well as with business institutions including the Orange County Business Council.
Hydrogeology:
As a Senior Hydrogeologist with the U.S. Environmental Protection Agency, Matt led investigations to characterize and cleanup closing military bases, including Mare Island Naval Shipyard, Hunters Point Naval Shipyard, Treasure Island Naval Station, Alameda Naval Station, Moffett Field, Mather Army Airfield, and Sacramento Army Depot. Specific activities were as follows:
Led efforts to model groundwater flow and contaminant transport, ensured adequacy of monitoring networks, and assessed cleanup alternatives for contaminated sediment, soil, and groundwater.
Initiated a regional program for evaluation of groundwater sampling practices and laboratory analysis at military bases.
Identified emerging issues, wrote technical guidance, and assisted in policy and regulation development through work on four national U.S. EPA workgroups, including the Superfund Groundwater Technical Forum and the Federal Facilities Forum.
At the request of the State of Hawaii, Matt developed a methodology to determine the vulnerability of groundwater to contamination on the islands of Maui and Oahu. He used analytical models and a GIS to show zones of vulnerability, and the results were adopted and published by the State of Hawaii and County of Maui.
As a hydrogeologist with the EPA Groundwater Protection Section, Matt worked with provisions of the Safe Drinking Water Act and NEPA to prevent drinking water contamination. Specific activities included the following:
Received an EPA Bronze Medal for his contribution to the development of national guidance for the protection of drinking water.
Managed the Sole Source Aquifer Program and protected the drinking water of two communities through designation under the Safe Drinking Water Act. He prepared geologic reports, conducted public hearings, and responded to public comments from residents who were very concerned about the impact of designation.
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Reviewed a number of Environmental Impact Statements for planned major developments, including large hazardous and solid waste disposal facilities, mine reclamation, and water transfer.
Matt served as a hydrogeologist with the RCRA Hazardous Waste program. Duties were as follows:
Supervised the hydrogeologic investigation of hazardous waste sites to determine compliance with Subtitle C requirements.
Reviewed and wrote "part B" permits for the disposal of hazardous waste.
Conducted RCRA Corrective Action investigations of waste sites and led inspections that formed the basis for significant enforcement actions that were developed in close coordination with U.S.
EPA legal counsel.
Wrote contract specifications and supervised contractor’s investigations of waste sites.
With the National Park Service, Matt directed service-wide investigations of contaminant sources to prevent degradation of water quality, including the following tasks:
Applied pertinent laws and regulations including CERCLA, RCRA, NEPA, NRDA, and the Clean Water Act to control military, mining, and landfill contaminants.
Conducted watershed-scale investigations of contaminants at parks, including Yellowstone and Olympic National Park.
Identified high-levels of perchlorate in soil adjacent to a national park in New Mexico and advised park superintendent on appropriate response actions under CERCLA.
Served as a Park Service representative on the Interagency Perchlorate Steering Committee, a national workgroup.
Developed a program to conduct environmental compliance audits of all National Parks while serving on a national workgroup.
Co-authored two papers on the potential for water contamination from the operation of personal watercraft and snowmobiles, these papers serving as the basis for the development of nationwide policy on the use of these vehicles in National Parks.
Contributed to the Federal Multi-Agency Source Water Agreement under the Clean Water Action Plan.
Policy:
Served senior management as the Senior Science Policy Advisor with the U.S. Environmental Protection Agency, Region 9. Activities included the following:
Advised the Regional Administrator and senior management on emerging issues such as the potential for the gasoline additive MTBE and ammonium perchlorate to contaminate drinking water supplies.
Shaped EPA’s national response to these threats by serving on workgroups and by contributing to guidance, including the Office of Research and Development publication, Oxygenates in Water: Critical Information and Research Needs.
Improved the technical training of EPA's scientific and engineering staff.
Earned an EPA Bronze Medal for representing the region’s 300 scientists and engineers in negotiations with the Administrator and senior management to better integrate scientific principles into the policy-making process.
Established national protocol for the peer review of scientific documents. 295
Geology:
With the U.S. Forest Service, Matt led investigations to determine hillslope stability of areas proposed for timber harvest in the central Oregon Coast Range. Specific activities were as follows:
Mapped geology in the field, and used aerial photographic interpretation and mathematical models to determine slope stability.
Coordinated his research with community members who were concerned with natural resource protection.
Characterized the geology of an aquifer that serves as the sole source of drinking water for the city of Medford, Oregon.
As a consultant with Dames and Moore, Matt led geologic investigations of two contaminated sites (later listed on the Superfund NPL) in the Portland, Oregon, area and a large hazardous waste site in eastern Oregon. Duties included the following:
Supervised year-long effort for soil and groundwater sampling.
Conducted aquifer tests.
Investigated active faults beneath sites proposed for hazardous waste disposal.
Teaching:
From 1990 to 1998, Matt taught at least one course per semester at the community college and university levels:
At San Francisco State University, held an adjunct faculty position and taught courses in environmental geology, oceanography (lab and lecture), hydrogeology, and groundwater contamination.
Served as a committee member for graduate and undergraduate students.
Taught courses in environmental geology and oceanography at the College of Marin.
Matt taught physical geology (lecture and lab and introductory geology at Golden West College in Huntington Beach, California from 2010 to 2014.
Invited Testimony, Reports, Papers and Presentations:
Hagemann, M.F., 2008. Disclosure of Hazardous Waste Issues under CEQA. Presentation to the Public Environmental Law Conference, Eugene, Oregon.
Hagemann, M.F., 2008. Disclosure of Hazardous Waste Issues under CEQA. Invited presentation to U.S.
EPA Region 9, San Francisco, California.
Hagemann, M.F., 2005. Use of Electronic Databases in Environmental Regulation, Policy Making and Public Participation. Brownfields 2005, Denver, Coloradao.
Hagemann, M.F., 2004. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water in Nevada and the Southwestern U.S. Presentation to a meeting of the American Groundwater Trust, Las Vegas, NV (served on conference organizing committee).
Hagemann, M.F., 2004. Invited testimony to a California Senate committee hearing on air toxins at schools in Southern California, Los Angeles.
296
Brown, A., Farrow, J., Gray, A. and Hagemann, M., 2004. An Estimate of Costs to Address MTBE Releases from Underground Storage Tanks and the Resulting Impact to Drinking Water Wells.
Presentation to the Ground Water and Environmental Law Conference, National Groundwater Association
Hagemann, M.F., 2004. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water in Arizona and the Southwestern U.S. Presentation to a meeting of the American Groundwater Trust, Phoenix, AZ (served on conference organizing committee).
Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water in the Southwestern U.S. Invited presentation to a special committee meeting of the National Academy of Sciences, Irvine, CA.
Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River. Invited presentation to a tribal EPA meeting, Pechanga, CA.
Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River. Invited presentation to a meeting of tribal repesentatives, Parker, AZ.
Hagemann, M.F., 2003. Impact of Perchlorate on the Colorado River and Associated Drinking Water Supplies. Invited presentation to the Inter-Tribal Meeting, Torres Martinez Tribe.
Hagemann, M.F., 2003. The Emergence of Perchlorate as a Widespread Drinking Water Contaminant.
Invited presentation to the U.S. EPA Region 9.
Hagemann, M.F., 2003. A Deductive Approach to the Assessment of Perchlorate Contamination. Invited presentation to the California Assembly Natural Resources Committee.
Hagemann, M.F., 2003. Perchlorate: A Cold War Legacy in Drinking Water. Presentation to a meeting of the National Groundwater Association.
Hagemann, M.F., 2002. From Tank to Tap: A Chronology of MTBE in Groundwater. Presentation to a meeting of the National Groundwater Association.
Hagemann, M.F., 2002. A Chronology of MTBE in Groundwater and an Estimate of Costs to Address Impacts to Groundwater. Presentation to the annual meeting of the Society of Environmental Journalists.
Hagemann, M.F., 2002. An Estimate of the Cost to Address MTBE Contamination in Groundwater (and Who Will Pay). Presentation to a meeting of the National Groundwater Association.
Hagemann, M.F., 2002. An Estimate of Costs to Address MTBE Releases from Underground Storage Tanks and the Resulting Impact to Drinking Water Wells. Presentation to a meeting of the U.S. EPA and State Underground Storage Tank Program managers.
Hagemann, M.F., 2001. From Tank to Tap: A Chronology of MTBE in Groundwater. Unpublished report.
297
Hagemann, M.F., 2001. Estimated Cleanup Cost for MTBE in Groundwater Used as Drinking Water.
Unpublished report.
Hagemann, M.F., 2001. Estimated Costs to Address MTBE Releases from Leaking Underground Storage Tanks. Unpublished report.
Hagemann, M.F., and VanMouwerik, M., 1999. Potential W a t e r Quality Concerns Related to Snowmobile Usage. Water Resources Division, National Park Service, Technical Report.
VanMouwerik, M. and Hagemann, M.F. 1999, Water Quality Concerns Related to Personal Watercraft Usage. Water Resources Division, National Park Service, Technical Report.
Hagemann, M.F., 1999, Is Dilution the Solution to Pollution in National Parks? The George Wright Society Biannual Meeting, Asheville, North Carolina.
Hagemann, M.F., 1997, The Potential for MTBE to Contaminate Groundwater. U.S. EPA Superfund Groundwater Technical Forum Annual Meeting, Las Vegas, Nevada.
Hagemann, M.F., and Gill, M., 1996, Impediments to Intrinsic Remediation, Moffett Field Naval Air Station, Conference on Intrinsic Remediation of Chlorinated Hydrocarbons, Salt Lake City.
Hagemann, M.F., Fukunaga, G.L., 1996, The Vulnerability of Groundwater to Anthropogenic Contaminants on the Island of Maui, Hawaii. Hawaii Water Works Association Annual Meeting, Maui, October 1996.
Hagemann, M. F., Fukanaga, G. L., 1996, Ranking Groundwater Vulnerability in Central Oahu, Hawaii. Proceedings, Geographic Information Systems in Environmental Resources Management, Air and Waste Management Association Publication VIP-61.
Hagemann, M.F., 1994. Groundwater C h ar ac te r i z a ti o n and C l ean up a t Closing Military Bases in California. Proceedings, California Groundwater Resources Association Meeting.
Hagemann, M.F. and Sabol, M.A., 1993. Role of the U.S. EPA in the High Plains States Groundwater Recharge Demonstration Program. Proceedings, Sixth Biennial Symposium on the Artificial Recharge of Groundwater.
Hagemann, M.F., 1993. U.S. EPA Policy on the Technical Impracticability of the Cleanup of DNAPLcontaminated Groundwater. California Groundwater Resources Association Meeting. 298
Hagemann, M.F., 1992. Dense Nonaqueous Phase Liquid Contamination of Groundwater: An Ounce of Prevention... Proceedings, Association of Engineering Geologists Annual Meeting, v. 35.
Other Experience:
Selected as subject matter expert for the California Professional Geologist licensing examination, 2009- 2011.
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APPENDIX B
VERBAL COMMENTS FROM INDIVIDUALS AT PLANNING COMMISSION
WORKSHOP
Anaheim Hills Festival Specific Plan Amendment Project Appendix B Final Environmental Impact Report Verbal Comments from Individuals at Planning Commission Workshop City of Anaheim 1
Verbal Comments from Individuals at the Planning Commission Workshop (July 14, 2025)
John M. Uh, good evening. Thank you very much for having this forum here and the workshop.
Um, I'm a resident less than a mile away from this proposed development. Um, and last November, you know, I watched the city council meeting, which they just voted no on the salt project. And there were two main issues that were raised there. And there was a gentleman who raised the idea of the medical term do no harm. And the deal is in where I live, that whole area is a very high-risk re zone, as was pointed out. And you're going to add a thousand more vehicles, a thousand more people. And already, the evacuation is a nightmare. Um, as you saw with the in the Palace, they had to take a bulldozer and I to add a thousand more vehicles that would down Sana Canyon Road. And I myself, my insurance was not renewed at the end of the year. My State Farm decided not to renew my insurance because I live in a high- I was rejected by four insurance companies because of the high-risk more money and at a much higher premium. So, unfortunately, I know that you area to put apartments in, but this is not the area to do it. It's already the evacuation of which I believe in 2017 took people two hours just to go a few miles down San Canyon, and you're basically literally adding fuel to by putting a development like this into this area. So, one last thing was that a gentleman made a comment. He worked on the general plan, and he said that with the salt development, if you allow that to happen, you can just take the general plan and throw it in the toilet. And the email address for Shea Properties for this development is the future of the festival. So I think they foresee the whole future of the festival is that they're going to take it bit by bit and try to put apartments in this area. The area was originally zoned this way.
It was just shown that, environmentally, the best option is to leave it the way it is or just rezone it commercially for that theater. And I know that the model of movie watching has somewhat changed, but, um, theaters are coming back in certain areas. This is the only there is no uh theater in that area.
Jimmy A. Good evening, commissioners. My name is Jimmy Aravalo, speaking on behalf of the Western States Regional Council of Carpenters. We're deeply concerned about Shea Homes' proposed development, not because we oppose housing, but because of Shea Homes' historical use to build their projects. Shea's track record of using contractors who don't pay livable wages, misclassify workers, and sometimes don't pay them at all. We urge you, don't greenlight this project unless Shea commits to using contractors who treat workers fairly and follow the law.
Thank you. Thank you very much,
Betty.
just incredible. I appreciate them every day. And thank you for allowing us to speak.
Anaheim Hills Festival Specific Plan Amendment Project Appendix B Final Environmental Impact Report Verbal Comments from Individuals at Planning Commission Workshop City of Anaheim 2
Um, I am concerned about the development of the festival. It does need a shot in the arm. Do we transportation, which was even outlined in the presentation. Um, it took over three hours for people to go less than three miles down San Canyon. And if you add to that even more and more vehicles, it's just going to make matters worse. Um, in just reviewing this, I haven't made up my mind, I am leaning more towards option number two, where the movie theater is developed into egress throughout the day as opposed to that log jam down San Ana Canyon in '91. Um, if you look at travel down that way anytime after 11:35, then in the morning, the 91 eastbound is a parking lot, and to or in order to try and evacuate the existing homes up behind the festival and up Eucalyptus and Mhler. I know there are two zones where they go, perhaps in ways, but nobody can predict which way
credit to in the presentation and reading through some of the the company that did the study really took some of the salt development and studies to task, and really did not agree with some of their numbers. So, I give them kudos for bringing that out into the open. Um, again, I'd like to reiterate that I think option number two is the better way to go. One of the other things that they mentioned was the VMT, transportation, and fewer parking spots. That's just going to force people to park in the neighborhoods. If you go down any street where there are condos or apartments, even up Soriano to what is it? Um, by the elementary school, there are people parked throughout because they can't park in their own condo area.
I like that gentleman who said Do no harm. I think that's really critical. I think one of the important things to remember is Paradise, Lahina
Mark H. Hello again. Hi, Mark Herbert, anaheimgree.com. In a company town, the city often provides cover for the special interest within the city limits. In this case, it was indicated that the environmental impact report was conducted by the city. My question was, was it conducted by the city Was it outsourced to a consultant? And three, if it was outsourced, who paid for it? The salt development had some questions around that.
On the question of housing, I like that it's included in this, but let's remember that the target for Anaheim is 9,100 units in their housing element target, which is still out of compliance.
And so far, they have 453 in the pipeline halfway through the 8-year cycle. And let's remember Will this have any in the bottom category, or will they all be in the top category? Uh, it was mentioned that they thought the most re risk was a re to the west of this.
It's been my experience living in this area for 60-plus years. The highest re risk is in the fall when we have Santa Ana winds blowing from east to west.
Anaheim Hills Festival Specific Plan Amendment Project Appendix B Final Environmental Impact Report Verbal Comments from Individuals at Planning Commission Workshop City of Anaheim 3
As far as the evacuation plan, oftentimes in Orange County now, developers are responsible for Perhaps the bridge at Fairmont over the 91 freeway should be a project like that, where the developer contributes or orchestrates it using their to get it done. The city hasn't been able to do it. As for the overriding considerations in a company town, there's always surprise information at the end, and it's not often introduced at the beginning of the process. We found that out at Disney Forward when the overriding consideration was presented at the end of a long process and remained private. We were not allowed to look at it, nor was the council. I wish the overriding consideration were presented now so the public could engage with it.
Mr. Hill. Good evening, and thank you again for allowing us all to speak today. Um, and thank you especially to the uh, planning commission for the hard work you guys do in order to protect the citizens of this community. It is my understanding that it is the government's primary responsibility to protect its citizens.
that. You not only put us existing residents at risk, but also any new residents that come into the area. This project, along with what Salt is now proposing, 300 more homes in Deer Canyon, puts us all at severe risk.
Paradise, Lahina, and Palisades at Altadena are perfect examples of city councils allowing development to take place without proper evacuation. There's really only one way out of this area and that's Sana Canyon Road. The 91 freeway would be so congested during a re evacuation To me, the solution is to build another route out. The most logical route would be an overpass irresponsible and needs to be addressed and built prior to any further dense housing developments in East Anaheim. Thank you.
ANAHEIM HILLS FESTIVAL SPECIFIC PLAN
AMENDMENT PROJECT
MITIGATION MONITORING PROGRAM
Prepared for City of Anaheim
200 South Anaheim Boulevard, Suite 162
Anaheim, California 92805
Prepared by Kimley-Horn and Associates, Inc.
1100 W Town and Country Road, Suite 700
Orange, California 92868
Date: September 2025
Anaheim Hills Festival Specific Plan Amendment Project
Mitigation Monitoring Program
1 1.0 PURPOSE OF THE MITIGATION MONITORING PROGRAM
The Mitigation Monitoring Program (MMP) for the Anaheim Hills Festival Specific Plan Amendment Project has been prepared pursuant to the California Environmental Quality Act (CEQA), specifically Public Resources Code (PRC) §21081.6 and State CEQA Guidelines §15097. CEQA requires public agencies to adopt a monitoring or reporting program whenever a Mitigated Negative Declaration (MND) or Environmental Impact Report (EIR) identifies measures to mitigate or avoid significant environmental impacts.
This MMP ensures that all mitigation measures adopted as part of the Anaheim Hills Festival Specific Plan Amendment Project EIR are implemented in a timely and verifiable manner, and that project implementation remains fully consistent with the mitigation commitments disclosed in the environmental document. As the Lead Agency, the City of Anaheim is responsible for administering and ensuring compliance with the MMP.
Public Resources Code §21081.6 provides that:
The public agency shall adopt a reporting or monitoring program for the changes made to the project or conditions of project approval, adopted in order to mitigate or avoid significant effects on the environment. The reporting or monitoring program shall be designed to ensure compliance during project implementation. For those changes which have been required or incorporated into the project at the request of a responsible agency or a public agency having jurisdiction by law over natural resources affected by the project, that agency shall, if so requested by the lead or responsible agency, prepare and submit a proposed reporting or monitoring program.
Additionally, State CEQA Guidelines §15097(a) requires that the MMP be adopted when a project is approved and that the program be enforceable and capable of ensuring actual implementation of mitigation measures during all relevant phases of the project.
The MMP for the Anaheim Hills Festival Specific Plan Amendment Project has been developed to:
Provide a clear and enforceable mechanism for monitoring and verifying the implementation of mitigation measures identified in the EIR; Ensure that mitigation measures are incorporated into the design, permitting, construction, and operation phases of the Project as applicable; Assign responsibilities for monitoring;
Document compliance through written verification and record-keeping; and Ensure consistency with City of Anaheim procedures and CEQA legal standards.
The MMP includes a comprehensive table that identifies each mitigation measure by number and title (as presented in the EIR), the timing of implementation, the department responsible for verification, and a method for documenting compliance. The table also includes a column for City staff or authorized representatives to sign off once implementation has been verified.
All mitigation measures contained in this MMP are incorporated into the Project either through conditions of approval, permit requirements, or development agreements, and are enforceable Anaheim Hills Festival Specific Plan Amendment Project
Mitigation Monitoring Program
2 pursuant to CEQA. The MMP will be maintained as part of the administrative record for the Project and will be available for public inspection at the City of Anaheim Planning and Building Department.
In summary, this MMP serves as the implementation tool for ensuring the Project’s compliance with CEQA mitigation requirements and the long-term protection of environmental resources in accordance with the intent of CEQA.
Anaheim Hills Festival Specific Plan Amendment Project Appendix C Final Environmental Impact Report Mitigation Monitoring Program 3 2.0 MITIGATION MONITORING PROGRAM TABLE
In accordance with the requirements of Public Resources Code §21081.6 and State CEQA Guidelines §15097, the following MMP has been prepared for the Anaheim Hills Festival Specific Plan Amendment Project. This program is designed to ensure that all Mitigation Measures (MMs), Regulatory Compliance Measures (RCMs), and Project Design Features (PDFs) identified in the EIR are implemented and verified during the appropriate stages of Project approval, permitting, construction, and operation.
This MMP ensures compliance with CEQA by establishing a clear and enforceable implementation framework for each environmental commitment. It assigns responsibilities for implementation and oversight and establishes verification procedures to be followed by the City of Anaheim, the Project Applicant, and any retained qualified professionals (e.g., biologists, archaeologists, tribal monitors).
This program includes three categories of environmental commitments:
Mitigation Measures (MMs): Measures adopted to reduce or avoid significant environmental impacts to a less-than-significant level under CEQA.
Regulatory Compliance Measures (RCMs): Existing requirements under federal, State, regional, or local law or regulation that apply independently of CEQA but are relevant to the Project’s environmental effects and help reduce potential impacts.
Project Design Features (PDFs): Specific features of the Project or applicant-proposed commitments that reduce potential impacts. While not considered formal mitigation under CEQA, these are binding and enforceable components of the Project as analyzed in the EIR.
Each commitment is included in the table below with the following columns:
Measure Number and Title (e.g., MM BIO-1, RCM AQ-1, PDF HAZ-2) and the full text of the requirement;
Implementation Timing indicating when the commitment must be implemented; Responsible for Monitoring indicating the responsible parties for verification; Verification Section for sign-off by City staff, with fields for date and initials.
Unless otherwise stated, the Project Applicant is responsible for implementing all measures. The City of Anaheim, primarily through its Planning and Building Department, is responsible for ensuring compliance and maintaining documentation in the Project’s administrative record.
This MMP shall be adopted concurrently with Project approvals and incorporated into all relevant permits and conditions of approval. It will be maintained on file at the City of Anaheim Planning and Building Department and used as a tool to track and verify compliance throughout Project implementation.
Anaheim Hills Festival Specific Plan Amendment Project Appendix C Final Environmental Impact Report Mitigation Monitoring Program 4 ANAHEIM HILLS FESTIVAL SPECIFIC PLAN AMENDMENT MITIGATION MONITORING PROGRAM Measure Number and Title Implementation Timing Department Responsible for Monitoring Verification Date Initials Air Quality AQ RCM-1 Rule 402 (Nuisance) – This rule prohibits the discharge from any source whatsoever such quantities of air contaminants or other material which cause injury, detriment, nuisance, or annoyance to any considerable number of persons or to the public or which endanger the comfort, repose, health, or safety of any such persons or the public, or which cause, or have a natural tendency to cause, injury or damage to business or property. This rule does not apply to odors emanating from agricultural operations necessary for the growing of crops or the raising of fowl or animals. Rule 403 (Fugitive Dust) – This rule requires fugitive dust sources to implement best available control measures for all sources, and all forms of visible particulate matter are prohibited from crossing any property line. This rule is intended to reduce PM10 emissions from any transportation, handling, construction, or storage activity that has the potential to generate fugitive dust. PM10 suppression techniques are summarized below. Portions of a construction site to remain inactive longer than a period of three months will be seeded and watered until grass cover is grown or otherwise stabilized. All on-site roads will be paved as soon as feasible or watered periodically or chemically stabilized. All material transported off-site will be either sufficiently watered or securely covered to prevent excessive amounts of dust. Ongoing during all construction activities City of Anaheim Planning and Building Department, Planning Services Division Anaheim Hills Festival Specific Plan Amendment Project Appendix C Final Environmental Impact Report Mitigation Monitoring Program 5 Measure Number and Title Implementation Timing Department Responsible for Monitoring Verification Date Initials The area disturbed by clearing, grading, earthmoving, or excavation operations will be minimized at all times Where vehicles leave a construction site and enter adjacent public streets, the streets will be swept daily or washed down at the end of the workday to remove soil tracked onto the paved surface. Rule 1113 (Architectural Coatings) – This rule requires manufacturers, distributors, and end users of architectural and industrial maintenance coatings to reduce ROG emissions from the use of these coatings, primarily by placing limits on the ROG content of various coating categories. Biological Resources BIO RCM-1 Nesting Migratory Birds. To prevent inadvertent disturbance to potential nesting migratory birds, a qualified biologist shall be contracted by the Property Owner/Developer prior to the issuance of any demolition permits to perform biological monitoring during all demolition, clearing, grubbing, and grading activities. To the extent feasible, all demolition, clearing, grubbing, and grading activities shall be conducted outside of the state-identified nesting season for migratory birds (i.e., typically February 1 through August 31). If not feasible, a Pre-Construction Nesting Bird Survey within and adjacent to the Project site shall be conducted by a qualified biologist no more than three days before beginning these activities. If active nests are found during the Pre- Construction Nesting Bird Survey, a Nesting Bird Plan (NBP) shall be prepared by a qualified biologist and implemented during construction with approval from the City. At a minimum, the NBP shall include guidelines for addressing the active nest(s), proposed protective buffers, proposed monitoring approach, and proposed reporting approach. The size and location of all buffer zones, if required, shall be based on the nesting species, nesting sage, nest location, its sensitivity to disturbance, and intensity and duration Prior to demolition or ground disturbance; during demolition, clearing, grubbing, and grading (if within nesting season) City of Anaheim Planning and Building Department, Planning Services Division Anaheim Hills Festival Specific Plan Amendment Project Appendix C Final Environmental Impact Report Mitigation Monitoring Program 6 Measure Number and Title Implementation Timing Department Responsible for Monitoring Verification Date Initials of the disturbance activity. A memorandum describing the results of the Pre-Construction Nesting Bird Survey shall be submitted to the Planning and Building Department for verification prior to proceeding with demolition, clearing, grubbing, and/or grading activities, subject to this measure. Any NBP developed pursuant to this measure shall be submitted to the City for review and approval prior to implementation. Cultural Resources MM CUL-1. Archaeologist Monitoring. Prior to the issuance of the grading permit, the Property Owner/Developer shall provide written evidence to the City that the Property Owner/Developer has retained a qualified archaeologist to observe grading activities within previously undisturbed soils and to salvage and catalog archaeological resources, as necessary. The archaeologist shall be present at the pre-grade conference, shall establish procedures for archaeological resource surveillance within previously undisturbed soils, and shall establish, in cooperation with the Property Owner/Developer, procedures for temporarily halting or redirecting work to permit the sampling, identification, and evaluation of the artifacts as appropriate. If soils cannot be shown in geotechnical reports or by other means to have been previously disturbed, archaeological monitoring shall be conducted. If archaeological resources are inadvertently unearthed during excavation activities, the contractor shall immediately cease all earth-disturbing activities within a 100-foot radius of the area of discovery, and the archaeologist and City shall be notified immediately. If the City, in consultation with the archaeologist, determines the archaeological resources to be significant, the City, in consultation with the archaeologist, shall determine appropriate actions for exploration and/or salvage. After the find has been appropriately avoided or mitigated, work in the area may resume. Prior to grading permit issuance; during ground- disturbing activities City of Anaheim Planning and Building Department, Planning Services Division Anaheim Hills Festival Specific Plan Amendment Project Appendix C Final Environmental Impact Report Mitigation Monitoring Program 7 Measure Number and Title Implementation Timing Department Responsible for Monitoring Verification Date Initials RCM CUL-1. If human remains are found during ground-disturbing activities, no further excavation or disturbance of the site or any nearby area reasonably suspected to overlie adjacent remains shall occur, in accordance with Section 7050.5 of the California Health and Safety Code. The Coroner shall be notified of the discovery immediately. If the Coroner determines that the remains are or are believed to be Native American, s/he shall notify the NAHC in Sacramento within 24 hours of the discovery. In accordance with Section 5097.98 of the California Public Resources Code, the NAHC must immediately notify those persons it believes to be the most likely descended from the deceased Native American. The descendants shall complete their inspection within 48 hours of being granted access to the site by the City. The City would meet and confer with the most likely descendant regarding their recommendations prior to disturbing the site with further construction activity. During all ground-disturbing activities City of Anaheim Planning and Building Department, Planning Services Division Geology and Soils MM GEO-1. Prior to the issuance of grading and building permits, the City of Anaheim Building Division and Public Works Department shall review all Project plans for grading, foundation, structural, infrastructure, and all other relevant construction permits to ensure compliance with the recommendations contained in the Project’s Geotechnical Exploration and Feasibility Report. Prior to issuance of grading and building permits City of Anaheim Planning and Building Department, Building Division City of Anaheim Public Works Department, Development Services Division MM GEO-2. Prior to the issuance of the first grading permit or permit for ground-disturbing activities, the Project applicant shall provide evidence to the City of Anaheim Planning and Building Department that a qualified professional paleontologist meeting the criteria established by the Society for Vertebrate Paleontology has been retained. If paleontological resources are inadvertently unearthed during excavation and grading activities of any future development project, the contractor shall immediately cease all earth-disturbing Prior to issuance of grading permit; during ground- disturbing activities City of Anaheim Planning and Building Department, Planning Services Division Anaheim Hills Festival Specific Plan Amendment Project Appendix C Final Environmental Impact Report Mitigation Monitoring Program 8 Measure Number and Title Implementation Timing Department Responsible for Monitoring Verification Date Initials activities within a 50-foot radius of the discovery area. The qualified paleontologist shall be contacted to evaluate the significance of the finding and determine an appropriate course of action. If avoidance of the resource(s) is not feasible, the Project applicant shall follow salvage operation requirements pursuant to State CEQA Guidelines Section 15064.5. After the Project applicant has appropriately avoided or mitigated the find, work in the area may resume. Hazards and Hazardous Materials PDF HAZ-1 Construction Fire Prevention Plan. Prior to commencement of construction activities, the Property Owner/Developer shall prepare and implement a Construction Fire Prevention Plan that identifies fire safety measures to be followed by the Project’s contractor throughout all phases of construction. The Plan shall be submitted to Anaheim Fire & Rescue for review and approval prior to the start of construction activities. Prior to commencement of construction City of Anaheim Fire & Rescue PDF HAZ-2 Wildfire Evacuation and Awareness Plan. Prior to issuance of a certificate of occupancy for the first multiple-family residential unit, the Property Owner/Developer shall prepare and implement a Project-specific Wildfire Evacuation and Awareness Plan. The Plan shall be subject to review and approval by the City of Anaheim Planning Department, Anaheim Police Department, and Anaheim Fire & Rescue. The Plan shall include, at a minimum, the following components: (1) The Plan shall be provided to all tenants along with all lease agreements for tenants; (2) The Plan shall include the development and dissemination of wildfire evacuation outreach materials. These materials shall be provided to residents and employees within the Project annually. The outreach materials shall depict evacuation routes to use in case of a wildfire event and will provide other practical wildfire preparedness information; (3) The Plan shall include requirements for annual emergency evacuation drills for residents and employees in the Project site; and (4) The Plan shall include the development, implementation, and ongoing maintenance of a method for the Property Owner/Developer to Prior to certificate of occupancy for first residential unit City of Anaheim Planning and Building Department, Planning Services Division City of Anaheim Police Department City of Anaheim Fire & Rescue Anaheim Hills Festival Specific Plan Amendment Project Appendix C Final Environmental Impact Report Mitigation Monitoring Program 9 Measure Number and Title Implementation Timing Department Responsible for Monitoring Verification Date Initials quickly and effectively communicate emergency alerts to individuals at the Project site, such as through the installation and maintenance of a wireless Public Address (PA) system and/or wireless texting services, or other equivalent systems or methods approved by Anaheim Fire & Rescue. MM HAZ-1 Construction Management Plan. Prior to the issuance of grading permits, a Construction Management Plan shall be prepared by the Property Owner/Developer for the review and approval by Anaheim Fire and Rescue. The Construction Management Plan shall be prepared in accordance with the applicable requirements contained in the Manual on Uniform Traffic Control Devices (MUTCD). Construction activities shall comply with the approved Construction Management Plan to the reasonable satisfaction of the Anaheim Fire and Rescue. The Property Owner/Developer shall begin coordination with the City on the Construction Management Plan as soon as practicable during the final design process and in advance of construction so that effective measures can be developed to avoid, minimize, and mitigate, to the extent feasible, construction impacts to parking and circulation on-site and in the vicinity of the Project site. At a minimum, the Construction Management Plan shall identify emergency access points and emergency access routes to allow for adequate emergency access to/within the Project site and to parcels surrounding the site throughout all phases of construction. During final design; prior to issuance of grading permits City of Anaheim Fire & Rescue Hydrology and Water Quality RCM HYDRO-1. Prior to issuance of a grading permit for sites that disturb more than one (1) acre of soil, the property owner/developer shall obtain coverage under the NPDES Statewide Industrial Stormwater Permit for General Construction Activities from the State Water Resources Control Board. The applicant shall prepare and implement a Stormwater Pollution Prevention Plan (SWPPP). A copy of the SWPPP shall be kept at the Project site and available for City review upon request. Evidence of permit attainment shall be Prior to issuance of grading permit; ongoing during construction City of Anaheim Planning and Building Department, Building Services Division Anaheim Hills Festival Specific Plan Amendment Project Appendix C Final Environmental Impact Report Mitigation Monitoring Program 10 Measure Number and Title Implementation Timing Department Responsible for Monitoring Verification Date Initials submitted to the Planning and Building Department, Building Services Division. Transportation PDF TRANS-1 Affordable Housing (CAPCOA Measure T-4). The Project shall include 45 moderate-income level housing units, representing 10 percent of the total 447 dwelling units. This measure is estimated to reduce project generated VMT by approximately 2.86 percent or 1,621 VMT. Prior to issuance of grading permit City of Anaheim Planning and Building Department, Planning Services Division PDF TRANS-2 Limit Residential Parking Supply (CAPCOA Measure T- 15). The Project shall provide a total of 893 parking spaces, which is 70 spaces fewer than the 963 spaces required by the City’s development standards. This reduction in parking supply is expected to reduce project-generated VMT by 1.0 percent, or 567 VMT. No feasible mitigation measures were identified that would reduce the significant impact to a level less than significant. Prior to issuance of grading permit City of Anaheim Planning and Building Department, Planning Services Division Tribal Cultural Resources MM TCR-1. Prior to the issuance of the first grading permit, the Property Owner/Developer or contractor as designee shall provide evidence in the form of an executed Agreement to the City of Anaheim Planning and Building Department that they have retained a qualified Native American tribal monitor to provide third-party monitoring (Monitor) during specified excavation and grading activities and to evaluate any previously unknown TCRs that are discovered during Project ground-disturbing activities, and also to provide recommended mitigation measures, such as, for example, recovery and catalogue, as necessary to the extent the find is determined to be significant. The Monitor shall be from or approved by the Gabrieleño Band of Mission Indians – Kizh Nation and shall be a qualified professional based on generally accepted professional qualifications and/or certifications, as may be applicable. The Agreement shall include (i) the professional qualifications of the Monitor; (ii) a reasonably detailed scope of services to be provided, Prior to issuance of grading permit; during ground- disturbing activities City of Anaheim Planning and Building Department, Planning Services Division Anaheim Hills Festival Specific Plan Amendment Project Appendix C Final Environmental Impact Report Mitigation Monitoring Program 11 Measure Number and Title Implementation Timing Department Responsible for Monitoring Verification Date Initials including but not limited to pre-construction education, observation, evaluation, protection, salvage, notification, and/or curation requirements, as applicable, with final documentation/report to Public Works Inspector; (iii) contact information; (iv) communication protocols between Contractor and Monitor for scheduling to facilitate timely performance; (v) acknowledgment that if the Monitor is unavailable or unresponsive based on terms stipulated in the Agreement, Property Owner/Developer or Contractor as designee may contract with another qualified professional Monitor approved by the Gabrieleño Band of Mission Indians – Kizh Nation and/or Native American tribe with established ancestral decadency to the project location, and reasonably acceptable to the City. The cover sheet of the grading plans shall include a note to identify that (a) third-party monitoring for tribal cultural resources is required during specified excavation and grading activities in accordance with the Agreement, and (b) contact information for the Tribe-approved Monitor shall be provided by the Contractor to the City inspector at the pre-construction meeting. Utilities and Service Systems RCM UTIL-1 Commercial/Multifamily Mandatory Recycling. In compliance with AB 341, recycling bins shall be provided at appropriate locations to promote the recycling of paper, metal, glass, and other recyclable materials. These bins shall be emptied and recycled accordingly as part of the Project’s regular solid waste disposal program. The Project Applicant shall only contract for waste disposal services with a company that recycles solid waste in compliance with AB 341. Ongoing during construction and operation City of Anaheim Public Works Department, Streets and Sanitation Division RCM UTIL-2 Construction Waste Recycling. To meet the diversion goals of the California Integrated Waste Management Act, the Applicant shall salvage and recycle construction and demolition materials to ensure that a minimum of 65 percent of construction- related solid waste that can be recycled is diverted from the waste Prior to demolition permit; ongoing during construction City of Anaheim Planning and Building Department, Building Division Anaheim Hills Festival Specific Plan Amendment Project Appendix C Final Environmental Impact Report Mitigation Monitoring Program 12 Measure Number and Title Implementation Timing Department Responsible for Monitoring Verification Date Initials stream to be landfilled. Solid waste diversion would be accomplished by either using Republic Services, the City’s franchise trash hauler, or completing a Construction and Demolition Waste Diversion Application before a demolition permit may be issued.
APPENDIX
ANAHEIM HILLS
FESTIVAL SPA NO. 6
TRAFFIC ANALYSIS
Reference Number Agency Date
15699-08A TA Report City of Anaheim August 11, 2025
PREPARED BY: Charlene So, PE | [email protected]
Jared Brawner | [email protected]
Aric Evatt | [email protected]
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TABLE OF CONTENTS
Table of Contents ............................................................................................................................................... ii Appendices......................................................................................................................................................... iv List of Exhibits..................................................................................................................................................... v List of Tables ...................................................................................................................................................... vi List of Abbreviated Terms ............................................................................................................................... vii 1 Introduction............................................................................................................................................... 1
1.1 Summary of Findings............................................................................................................................................ 1
1.2 Project Overview ................................................................................................................................................... 3
1.3 Analysis Scenarios ................................................................................................................................................. 6
1.4 Study Area ................................................................................................................................................................ 7
1.5 Deficiencies .............................................................................................................................................................. 9
1.6 Recommendations ............................................................................................................................................. 12 2 Methodologies ........................................................................................................................................15
2.1 Level of Service.................................................................................................................................................... 15
2.2 Intersection Capacity Analysis........................................................................................................................ 15
2.3 Traffic Signal Warrant Analysis Methodology.......................................................................................... 17
2.4 Roadway Segment Capacity Analysis.......................................................................................................... 18
2.5 Off-Ramp Queuing Analysis ........................................................................................................................... 19
2.6 Minimum Acceptable Levels of Service (LOS) ......................................................................................... 19
2.7 Deficiency Criteria .............................................................................................................................................. 19
2.8 Fair Share Contribution ....................................................................................................................................20 3 Area Conditions ......................................................................................................................................21
3.1 Existing Circulation Network .......................................................................................................................... 21
3.2 Existing Roadway Network ............................................................................................................................. 21
3.3 Bicycle and Pedestrian Facilities.................................................................................................................... 24
3.4 Transit Service...................................................................................................................................................... 24
3.5 Existing Traffic Counts ......................................................................................................................................28
3.6 Intersection Operations Analysis.................................................................................................................. 30
3.7 Traffic Signal Warrants Analysis .................................................................................................................... 30
3.8 Roadway Segment Analysis ............................................................................................................................ 30
3.9 Off-Ramp Queuing Analysis ........................................................................................................................... 30
3.10 Existing Deficiencies and Improvements ................................................................................................... 32 4 Projected Future Traffic .........................................................................................................................33
4.1 Project Trip Generation....................................................................................................................................33
4.2 Project Trip Distribution................................................................................................................................... 35
4.3 Modal Split............................................................................................................................................................. 35
4.4 Project Trip Assignment ................................................................................................................................... 35
4.5 Background Traffic ............................................................................................................................................. 35
4.6 Cumulative Development Traffic.................................................................................................................. 38
4.7 Near-Term Traffic Conditions........................................................................................................................ 42 Anaheim Hills Festival SPA No. 6 Traffic Analysis
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4.8 General Plan Buildout Volume Development .......................................................................................... 42 5 Opening Year (2029) Traffic Conditions...............................................................................................43
5.1 Roadway Improvements ..................................................................................................................................43
5.2 Opening Year (2029) Without Project Traffic Volume Forecasts..................................................... 43
5.3 Opening Year (2029) With Project Traffic Volume Forecasts ........................................................... 43
5.4 Intersection Operations Analysis.................................................................................................................. 43
5.5 Traffic Signal Warrants Analysis .................................................................................................................... 46
5.6 Roadway Segment Analysis ............................................................................................................................ 47
5.7 Off-Ramp Queuing Analysis ........................................................................................................................... 47
5.8 Deficiencies and Improvements.................................................................................................................... 50 6 General Plan Buildout Traffic Conditions............................................................................................53
6.1 Roadway Improvements ..................................................................................................................................53
6.2 General Plan Buildout Without Project Traffic Volume Forecasts................................................... 53
6.3 General Plan Buildout With Project Traffic Volume Forecasts.......................................................... 53
6.4 Intersection Operations Analysis.................................................................................................................. 53
6.5 Traffic Signal Warrants Analysis .................................................................................................................... 56
6.6 Roadway Segment Analysis ............................................................................................................................ 56
6.7 Off-Ramp Queuing Analysis ........................................................................................................................... 58
6.8 Deficiencies and Improvements.................................................................................................................... 58 7 Local and Regional Funding Mechanisms...........................................................................................61
7.1 City of Anaheim Transportation Impact and Improvement Fee Program..................................... 61 8 References...............................................................................................................................................63 Anaheim Hills Festival SPA No. 6 Traffic Analysis
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APPENDICES
Appendix 1.1: Approved Traffic Study Scoping Agreement
Appendix 3.1: Traffic Counts
Appendix 3.2: Existing (2024) Conditions Intersection Operations Analysis Worksheets Appendix 3.3: Existing (2024) Conditions Traffic Signal Warrant Analysis Worksheets Appendix 3.4: Existing (2024) Conditions Off-Ramp Queuing Analysis Worksheets Appendix 4.1: Post Processing Worksheets
Appendix 5.1: Opening Year (2029) Without Project Conditions Intersection Operations Analysis Worksheets
Appendix 5.2: Opening Year (2029) With Project Conditions Intersection Operations Analysis Worksheets
Appendix 5.3: Opening Year (2029) Without Project Traffic Signal Warrant Analysis Worksheets Appendix 5.4: Opening Year (2029) With Project Traffic Signal Warrant Analysis Worksheets Appendix 5.5: Opening Year (2029) Without Project Off-Ramp Queuing Analysis Worksheets Appendix 5.6: Opening Year (2029) With Project Off-Ramp Queuing Analysis Worksheets Appendix 6.1: General Plan Buildout Without Project Conditions Intersection Operations Analysis Worksheets
Appendix 6.2: General Plan Buildout With Project Conditions Intersection Operations Analysis Worksheets
Appendix 6.3: General Plan Buildout Without Project Traffic Signal Warrant Analysis Worksheets Appendix 6.4: General Plan Buildout With Project Traffic Signal Warrant Analysis Worksheets Appendix 6.5: General Plan Buildout Without Project Off-Ramp Queuing Analysis Worksheets Appendix 6.6: General Plan Buildout With Project Off-Ramp Queuing Analysis Worksheets Anaheim Hills Festival SPA No. 6 Traffic Analysis
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LIST OF EXHIBITS
Exhibit 1-1: Location Map..................................................................................................................................2 Exhibit 1-2: SPA Proposed Development Areas .............................................................................................4 Exhibit 1-3: Preliminary Site Plan .....................................................................................................................5 Exhibit 1-4: Study Area.......................................................................................................................................8 Exhibit 1-5: Site Access Recommendations ..................................................................................................13 Exhibit 3-1: Existing Number of Through Lanes and Intersection Controls .............................................22 Exhibit 3-2: City of Anaheim General Plan Planned Roadway Map...........................................................23 Exhibit 3-3: City of Anaheim Existing and Planned Bicycle Facilities .........................................................25 Exhibit 3-4: Existing Pedestrian Facilities ......................................................................................................26 Exhibit 3-5: City of Anaheim Transit Facilities...............................................................................................27 Exhibit 3-6: Existing (2024) Traffic Volumes ..................................................................................................29 Exhibit 4-1: Project Trip Distribution..............................................................................................................36 Exhibit 4-2: Project Only Traffic Volumes ......................................................................................................37 Exhibit 4-3: Cumulative Development Location Map ..................................................................................40 Exhibit 4-4: Cumulative Only Traffic Volumes ..............................................................................................41 Exhibit 5-1: Opening Year (2029) Without Project Traffic Volumes ...........................................................44 Exhibit 5-2: Opening Year (2029) With Project Traffic Volumes ................................................................. 45 Exhibit 6-1: General Plan Buildout Without Project Traffic Volumes ........................................................54 Exhibit 6-2: General Plan Buildout With Project Traffic Volumes ..............................................................55 Anaheim Hills Festival SPA No. 6 Traffic Analysis
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LIST OF TABLES
Table 1-1: Intersection Analysis Locations ......................................................................................................7 Table 1-2: Roadway Segment Capacity Analysis Locations ..........................................................................9 Table 1-3: Summary of Intersection LOS.........................................................................................................9 Table 1-4: Summary of Roadway Segment Analysis Results ......................................................................10 Table 2-1: Signalized Intersection LOS Thresholds......................................................................................15 Table 2-2: Signalized Intersection LOS Thresholds with HCM....................................................................16 Table 2-3: Unsignalized Intersection LOS Thresholds .................................................................................17 Table 2-4: Traffic Signal Warrant Analysis Locations ...................................................................................18 Table 2-5: City of Anaheim Deficiency Criteria .............................................................................................19 Table 3-1: Intersection Analysis for Existing (2024) Conditions ................................................................. 31 Table 3-2: Roadway Segment Analysis for Existing (2024) Conditions......................................................31 Table 3-3: Peak Hour Queuing Summary for Existing (2024) Conditions .................................................32 Table 4-1: Project Trip Generation Rates ......................................................................................................33 Table 4-2: Project Trip Generation Summary ...............................................................................................34 Table 4-3: Trip Generation Comparison........................................................................................................34 Table 4-4: Cumulative Development land use Summary ...........................................................................38 Table 4-5: Cumulative Development Trip Generation Rates......................................................................39 Table 4-6: Cumulative Development Trip Generation Summary...............................................................39 Table 5-1: Intersection Analysis for Opening Year (2029) Conditions.......................................................46 Table 5-2: Roadway Segment Analysis for Opening Year (2029) Conditions ...........................................48 Table 5-3: Peak Hour Queuing Summary for Opening Year (2029) Conditions.......................................49 Table 5-4: Peak Hour Roadway Segment Analysis for Opening Year (2029) Conditions........................51 Table 6-1: Intersection Analysis for General Plan Buildout Conditions ....................................................56 Table 6-2: Roadway Segment Analysis for General Plan Buildout Conditions.........................................57 Table 6-3: Peak Hour Queuing Summary for General Plan Buildout Conditions ....................................58 Table 6-4: Peak Hour Roadway Segment Analysis for General Plan Buildout Conditions .....................60 Anaheim Hills Festival SPA No. 6 Traffic Analysis
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LIST OF ABBREVIATED TERMS
(1) Reference
ADT Average Daily Traffic
ATAM Anaheim Transportation Analysis Model
CA MUTCD California Manual on Uniform Traffic Control Devices Caltrans California Department of Transportation
CMP Congestion Management Program
DA Development Area
EIR Environmental Impact Report
HCM Highway Capacity Manual
ICU Intersection Capacity Utilization
ITE Institute of Transportation Engineers
LOS Level of Service
MPAH Master Plan of Arterial Highways
MPH Miles Per Hour
NCHRP National Cooperative Highway Research Program
OCTA Orange County Transportation Authority
PHF Peak Hour Factor
Project Anaheim Hills Festival SPA No. 6
SP Specific Plan
SPA Specific Plan Amendment
TA Traffic Analysis
TIIF Transportation Impact and Improvement Fee
TIM Transportation Implementation Manual
v/c Volume to Capacity
vphgpl Vehicles per Hour Green per Lane
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AUGUST 11, 2025 REVISIONS
The revisions included on August 11, 2025, were prepared in response to the California Department of Transportation (Caltrans) comment letter dated August 4, 2025. Specifically, these revisions include the following:
Revisions to Table 4-1 to include the Shopping Center trip generation rates.
All Turning Volume exhibits updated to ensure volumes are only displayed for applicable turning movements at each location.
Typographical error in all Queuing tables updated to correctly reference SR-91 Freeway.
Anaheim Hills Festival SPA No. 6 Traffic Analysis
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1 1 INTRODUCTION
This report presents the results of the Traffic Analysis (TA) for the Anaheim Hills Festival Specific Plan Amendment (SPA) (Project), located south of Santa Ana Canyon Road and west of Roosevelt Road in the City of Anaheim, as shown in Exhibit 1-1. The purpose of this TA is to evaluate the potential circulation system deficiencies that may result from the development of the proposed Project, and, where necessary, recommend improvements to achieve acceptable operations consistent with General Plan level of service goals and policies. This traffic study has been prepared in accordance with the City of Anaheim’s Criteria for Preparation of Traffic Impact Studies (City Guidelines) and consultation with City staff during the traffic study scoping process. (1) The City-approved Project Traffic Study Scoping Agreement is provided in Appendix 1.1 of this TA.
1.1 SUMMARY OF FINDINGS
All study area intersections are forecast to operate at an acceptable level of service (LOS) during the AM and PM peak hours under Opening Year (2029 With Project traffic conditions and General Plan Buildout traffic conditions based on the Highway Capacity Manual (HCM) or Intersection Capacity Utilization (ICU) methodology.
Santa Ana Canyon Road, from Imperial Highway to Anaheim Hills Road, is anticipated to operate at an unacceptable LOS based on the daily roadway capacity thresholds and minimum LOS criteria under Opening Year (2029) traffic conditions and General Plan Buildout traffic conditions. Santa Ana Canyon Road, from Anaheim Hills Road to Fairmont Boulevard, is also anticipated to operate at an unacceptable LOS based on the daily roadway capacity thresholds and minimum LOS criteria under General Plan Buildout traffic conditions. Based on the peak hour roadway capacity thresholds, Santa Ana Canyon Road, from Imperial Highway to Anaheim Hills Road, is anticipated to operate at an unacceptable LOS in the westbound direction during the AM and PM peak hour and in the eastbound direction during the PM peak hour only, under Opening Year (2029) With Project traffic conditions and General Plan Buildout traffic conditions. Under both the daily and peak hour analyses, the Project is anticipated to increase the Volume-to-Capacity (V/C) by less than the threshold identified for intersections. As such, the Project-related increase in V/C is deemed not significant.
The high volume of through vehicles is attributable to vehicles bypassing the SR-91 Freeway during peak hour commute hours throughout the day. Introducing additional lanes along Santa Ana Canyon Road would encourage more vehicles to utilize this roadway segment and would be counterintuitive to the State’s goals with regards to Vehicle Miles Traveled. Moreover, roadway widening is infeasible due to right-of-way limitations and is inconsistent with the City’s General Plan. Additionally, the intersections on both ends of the roadway segment are anticipated to operate at an acceptable LOS suggesting that the additional capacity accommodated through turn lanes at the choke-points of the roadway segments (e.g., intersections) can sufficiently handle the anticipated future traffic. 1 Anaheim Hills Festival SPA No. 6 Traffic Analysis
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3 Access to the Project site will be provided via two driveways on Festival Drive. Driveway 1 is an existing full access driveway (no turn restrictions) on the north side of the Project. The Project is to construct the following improvements in conjunction with development to facilitate site access:
Project to construct Driveway 2 on Festival Drive. The Project is to install a stop control on the southbound approach and a shared left-right turn lane.
Festival Drive appears to be built to its ultimate curb-to-curb width adjacent to the Project. However, the Project should improve the curb-and-gutter, sidewalks, and landscape along the frontage as necessary in addition to accommodating improvements to facilitate site access at the driveways.
1.2 PROJECT OVERVIEW
The existing Specific Plan (SP) is divided into four Development Areas (DA) by land use. DA 1 is the Scenic Commercial area fronting Santa Ana Canyon Road between Festival Drive and Roosevelt Road, DA 2 is the Regional Commercial use that contains the department stores, grocery, other food/retail uses, and the vacant cinema, DA 3 is the Visitor Commercial area located west of Festival Drive which includes the existing hotel, and DA 4 is the Senior Residential area south of Festival Drive. The SPA proposes the implementation of a new 16.2-acre mixed-use development area on the upper level of the commercial center as a new DA 5 (which is a portion of the old DA 2). Exhibit 1-2 illustrates the proposed DA locations for the SPA.
Specifically, the Project proposes to demolish the existing 62,676-square-foot vacant cinema and develop in its place 447 multi-family residential dwelling units while retaining the remaining existing commercial uses within the new DA 5. Approximately 13,310 square feet of existing retail would be retained in DA 2 as a result of the new DA 5 (resulting in a net reduction of 49,366 square feet of retail space). The retail within DA 5 will include the following existing uses: 6,475 square feet of restaurant use, 9,200 square feet of office use, 38,160-square-foot fitness/gym, 13,276 square feet of tutor/retail space, and 11,033-square-foot medical office building. A preliminary site plan for the proposed multifamily residential development is shown at Exhibit 1-3. Access to the Project site will be provided via two driveways on Festival Drive. Driveway 1 is an existing driveway on the north side of the Project.
Both driveways are assumed to have full access (no turn restrictions). For the purposes of the Traffic Analysis, the Project is expected to be developed within a single phase with an anticipated Opening Year of 2029.
In order to develop the traffic characteristics of the proposed Project, trip-generation statistics published in the Institute of Transportation Engineers (ITE) Trip Generation Manual (11th Edition, 2021) for ITE Land Use Code 221 for Multifamily Housing (Mid-Rise, 4-10 Floors) has been utilized. (2) Only traffic for the proposed multi-family development is taken into consideration as the existing retail, restaurant, and office uses would be captured as part of the existing intersection traffic count program. The Project is anticipated to generate a total of 1,624 vehicle trip-ends per day with 132 AM peak hour trips and 139 PM peak hour trips. The assumptions and methods used to estimate the Project’s trip generation characteristics are discussed in greater detail in Section 4.1 Project Trip Generation of this report.
3 4
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6 1.3 ANALYSIS SCENARIOS
Consistent with the City’s Guidelines, for the purposes of the Traffic Analysis, potential deficiencies to traffic and circulation have been assessed for each of the following conditions:
Existing (2024) Conditions
Opening Year (2029) Without Project Conditions: Cumulative existing traffic conditions plus all developments within the study area which have not yet been constructed but has been approved through a discretionary action or building permit issuance. This alternative corresponds to the no project alternative for purposes of an Environmental Impact Report (EIR).
Opening Year (2029) With Project Conditions
General Plan Buildout Without Project Conditions: Buildout of all developments anticipated in the City’s General Plan or implied by the City’s Zoning Ordinance. Anaheim Transportation Analysis Model (ATAM) Year 2025 or later projections shall be utilized for this purpose.
General Plan Buildout With Project Conditions
1.3.1 EXISTING (2024) CONDITIONS
Information for Existing (2024) conditions is disclosed to represent the baseline traffic conditions as they existed at the time this report was prepared.
1.3.2 OPENING YEAR (2029) CONDITIONS
The Opening Year (2029) Without Project conditions analysis determines the potential near-term cumulative circulation system deficiencies. The roadway network is similar to Existing conditions except for new connections to be constructed other approved cumulative development projects. To account for background traffic growth, an ambient growth factor from Existing (2024) conditions of
5.10 percent (1 percent per year, compounded over 5 years) is included for Opening Year (2029) Without Project conditions, in conjunction with traffic associated from approved cumulative development projects. This comprehensive list was compiled from information provided by the City of Anaheim. The assumed ambient growth factor is based on the requirements per the City Guidelines.
The Opening Year (2029) With Project conditions include the Opening Year (2029) Without Project conditions traffic forecasts plus the traffic generated by the proposed Project. The roadway network is similar to Opening Year (2029) Without Project except for new connections to be constructed by the Project. The Opening Year (2029) With Project conditions analysis is intended to identify “Opening Year” deficiencies associated with the development of the proposed Project based on the expected background growth within the study area.
1.3.3 GENERAL PLAN BUILDOUT CONDITIONS
Traffic projections for General Plan Buildout conditions were derived from the latest ATAM using accepted procedures for model forecast refinement and smoothing. The General Plan Buildout postprocessing volumes have been provided by the City’s traffic consultant. The General Plan Buildout conditions analysis has been utilized to determine if improvements funded through regional transportation mitigation fee programs can accommodate the long-range cumulative traffic at the target LOS identified in the City of Anaheim (lead agency) General Plan. Each of the applicable transportation fee programs are discussed in more detail in Section 7 Local and Regional Funding Mechanisms. 6
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7 1.4 STUDY AREA
To ensure that this TA satisfies the City of Anaheim’s traffic study requirements, Urban Crossroads, Inc. prepared a Project traffic study scoping package for review by City of Anaheim staff prior to the preparation of this report. This agreement provides an outline of the Project study area, trip generation, trip distribution, and analysis methodology. The agreement approved by the City is included in Appendix 1.1 of this TA.
1.4.1 INTERSECTIONS
The following 16 study area intersections shown at Exhibit 1-4 and listed in Table 1-1 were selected for this TA based on consultation with City of Anaheim staff. The “50 peak hour trip” criterion utilized by the City of Anaheim is consistent with the methodology employed by the County of Orange, and generally represents a minimum number of trips at which a typical intersection would have the potential to be affected by a given development proposal. Although each intersection may have unique operating characteristics, this traffic engineering rule of thumb is a widely utilized tool for estimating a potential area of influence (i.e., study area). Other analysis intersections within the adjacent cities were not selected for evaluation as the Project is anticipated to contribute less than 50 peak hour trips.
TABLE 1-1: INTERSECTION ANALYSIS LOCATIONS
The intent of a Congestion Management Program (CMP) is to directly link land use, transportation, and air quality, thereby prompting reasonable growth management programs that will effectively utilize new transportation funds, alleviate traffic congestion and related deficiencies, and improve air quality. Counties within California have developed CMPs with varying methods and strategies to meet the intent of the CMP legislation. Imperial Highway at the SR-91 westbound and eastbound ramps (study area intersections #1 and #2) are identified as CMP facilities in the County of Orange per the Orange County CMP. (3)
# Intersection Jurisdiction CMP Facility?
1 Imperial Hwy. & SR-91 WB Ramps Anaheim, Caltrans Yes
2 Imperial Hwy. & SR-91 EB Ramps Anaheim, Caltrans Yes
3 Imperial Hwy. & Santa Ana Canyon Rd. Anaheim No
4 Anaheim Hills Rd. & Santa Ana Canyon Rd. Anaheim No
5 Fairmont Bl. & Santa Ana Canyon Rd. Anaheim No
6 Deer Canyon Rd. & Santa Ana Canyon Rd. Anaheim No
7 Festival Dr. & Santa Ana Canyon Rd. Anaheim No
8 Festival Dr. & Driveway 1 Anaheim No
9 Driveway 2 & Festival Dr. Anaheim No
10 Festival Center Dwy. & Santa Ana Canyon Rd. Anaheim No 11 Roosevelt Rd. & Santa Ana Canyon Rd. Anaheim No
12 Roosevelt Rd. & Festival Dr./Monte Vista Rd. Anaheim No 13 Weir Canyon Rd. & SR-91 WB Ramps Yorba Linda, Caltrans No 14 Weir Canyon Rd. & SR-91 EB Ramps Anaheim, Caltrans No 15 Weir Canyon Rd. & Santa Ana Canyon Rd. Anaheim No
16 Weir Canyon Rd. & Monte Vista Rd. Anaheim No
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9 1.4.2 ROADWAY SEGMENTS
Based on consultation with City of Anaheim staff, the study area roadway segments selected for evaluation are shown at Exhibit 1-4 and listed in Table 1-2.
TABLE 1-2: ROADWAY SEGMENT CAPACITY ANALYSIS LOCATIONS
1.5 DEFICIENCIES
This section provides a summary of deficiencies by analysis scenario. Section 2 Methodologies provides information on the methodologies used in the analysis and Section 3 Area Conditions, Section 5 Opening Year (2029) Traffic Conditions, and Section 6 General Plan Buildout Conditions includes the detailed analysis. A summary of the Intersection Operations Analysis LOS results and Roadway Segment Analysis results for all analysis scenarios is presented in Tables 1-3 and 1-4, respectively.
TABLE 1-3: SUMMARY OF INTERSECTION LOS
# Study Area Roadway Segments
1 Santa Ana Canyon Rd., Imperial Hwy. to Anaheim Hills Rd. 2 Santa Ana Canyon Rd., Anaheim Hills Rd. to Fairmont Bl. 3 Santa Ana Canyon Rd., Fairmont Bl. to Deer Canyon Rd. 4 Santa Ana Canyon Rd., Deer Canyon Rd. to Festival Dr. 5 Santa Ana Canyon Rd., Festival Dr. to Roosevelt Rd.
6 Santa Ana Canyon Rd., Roosevelt Rd. to Weir Canyon Rd. 7 Roosevelt Rd., Santa Ana Canyon Rd. to Festival Dr.
8 Festival Dr., Santa Ana Canyon Rd. to Driveway 1
9 Festival Dr., Driveway 2 to Roosevelt Rd.
10 Monte Vista Rd., Roosevelt Rd. to Weir Canyon Rd.
11 Weir Canyon Rd., SR-91 Freeway to Santa Ana Canyon Rd. 12 Weir Canyon Rd., Santa Ana Canyon Rd. to Festival Dr. # Intersection AM PM AM PM AM PM AM PM AM PM
1 Imperial Hwy. & SR-91 WB Ramps B A B B B B B B B B
2 Imperial Hwy. & SR-91 EB Ramps B A C A C A C B C B
3 Imperial Hwy. & Santa Ana Canyon Rd. B B B B B B B B B B 4 Anaheim Hills Rd. & Santa Ana Canyon Rd. A A B A B A B B B B 5 Fairmont Bl. & Santa Ana Canyon Rd. B C B C C C C D C D 6 Deer Canyon Rd. & Santa Ana Canyon Rd. B B B C B C C D C D 7 Festival Dr. & Santa Ana Canyon Rd. A A A A A B B B B B 8 Festival Dr. & Driveway 1 A B A B A B A B
9 Driveway 2 & Festival Dr. A A A A A A A A A A
10 Festival Center Dwy. & Santa Ana Canyon Rd. B B B B B B B B B B 11 Roosevelt Rd. & Santa Ana Canyon Rd. A A B B
12 Roosevelt Rd. & Festival Dr./Monte Vista Rd. A A A A A A A A A A 13 Weir Canyon Rd. & SR-91 WB Ramps A A A A A A A A A B 14 Weir Canyon Rd. & SR-91 EB Ramps A A A A A A A A A A 15 Weir Canyon Rd. & Santa Ana Canyon Rd. A B A B A B A B B B 16 Weir Canyon Rd. & Monte Vista Rd. A A A B A B A B A B Opening Year (2029) General Plan Buildout
Existing (2024)
Future Intersection
Future Intersection Future Intersection Future Intersection Without Project With Project Without Project With Project 9 Anaheim Hills Festival SPA No. 6 Traffic Analysis
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10 TABLE 1-4: SUMMARY OF ROADWAY SEGMENT ANALYSIS RESULTS
1.5.1 EXISTING (2024) CONDITIONS
Intersections
The study area intersections are currently operating at an acceptable LOS during the peak hours.
Roadway Segments
There are no study area roadway segments currently operating at an unacceptable LOS based on the daily roadway capacity thresholds and minimum LOS criteria.
Off-Ramp Queues
There are no movements that currently experience queuing issues during the weekday AM or weekday PM peak 95th percentile traffic flows for Existing (2024) traffic conditions. # Roadway Segment Limits
Without
Project
With
Project
Without
Project
With
Project
1 Santa Ana Canyon Rd. Imperial Hwy. to Anaheim Hills Rd. C D D D D 2 Anaheim Hills Rd. to Fairmont Bl. C C C D D
3 Fairmont Bl. to Deer Canyon Rd. C C C C C
4 Deer Canyon Rd. Festival Dr. C B B C C
5 Festival Dr. to Roosevelt Rd. C A A A A
6 Roosevelt Rd. to Weir Canyon Rd. C C C C C
7 Roosevelt Rd. Santa Ana Canyon Rd. to Festival Dr. C A A A A 8 Festival Dr. Santa Ana Canyon Rd. to Driveway 1 C A A A A 9 Driveway 2 to Roosevelt Rd. C A A A A
10 Monte Vista Rd. Roosevelt Rd. to Weir Canyon Rd. C A A A A 11 Weir Canyon Rd. SR-91 Freeway to Santa Ana Canyon Rd. C C C C C 12 Santa Ana Canyon Rd. to Monte Vista Rd. C A A A A
* BOLD = Level of Service (LOS) does not meet the applicable jurisdictional requirements (i.e., unacceptable LOS). # Roadway Segment Limits Peak Hour Direction
Without
Project
With
Project
Without
Project
With
Project
1 Santa Ana Canyon Rd. AM EB N/A C C C C
AM WB N/A C D D D
PM EB N/A D D D D
PM WB N/A E E E E
2 Santa Ana Canyon Rd. AM EB N/A N/A N/A B B
AM WB N/A N/A N/A C C
PM EB N/A N/A N/A B C
PM WB N/A N/A N/A B C
1 Peak Hour Roadway Segment Analyses has been analyzed for segments anticpated to operate at an unacceptable LOS under the Daily Roadway Segment Analysis.
Imperial Hwy. to
Anaheim Hills Rd.
Anaheim Hills Rd. to
Fairmont Bl.
Summary of Daily Roadway Segment Analysis
Summary of Peak Hour Roadway Segment Analysis
Existing
(2024)
Opening Year (2029) General Plan
Existing
(2024)
Opening Year (2029) General Plan
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11 1.5.2 OPENING YEAR (2029) CONDITIONS
Intersections
The study area intersections are anticipated to continue to operate at an acceptable LOS during the peak hours under Opening Year (2029) Without Project and With Project traffic conditions.
Roadway Segments
The following study area roadway segments are anticipated to operate at an unacceptable LOS based on the daily roadway capacity thresholds and minimum LOS criteria under both Opening Year (2029) Without Project and With Project traffic conditions:
Santa Ana Canyon Road, from Imperial Highway to Anaheim Hills Road (#1) – LOS D Off-Ramp Queues
There are no movements that are anticipated to experience queuing issues during the weekday AM or weekday PM peak 95th percentile traffic flows under both Opening Year (2029) Without Project and With Project traffic conditions.
1.5.3 GENERAL PLAN BUILDOUT CONDITIONS
Intersections
The study area intersections are anticipated to continue to operate at an acceptable LOS under General Plan Buildout Without Project and With Project traffic conditions.
Roadway Segments
The following study area roadway segments are anticipated to operate at an unacceptable LOS based on the daily roadway capacity thresholds and minimum LOS criteria under both General Plan Buildout Without Project and With Project traffic conditions:
Santa Ana Canyon Road, from Imperial Highway to Anaheim Hills Road (#1) – LOS D Santa Ana Canyon Road, from Anaheim Hills Road to Fairmont Boulevard (#2) – LOS D Off-Ramp Queues
There are no movements that are anticipated to experience queuing issues during the weekday AM or weekday PM peak 95th percentile traffic flows under both General Plan Buildout Without Project and With Project traffic conditions.
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12 1.6 RECOMMENDATIONS
1.6.1 SITE ADJACENT AND SITE ACCESS RECOMMENDATIONS
The following recommendations are based on the minimum improvements needed to accommodate site access and maintain acceptable peak hour operations for the proposed Project. The site adjacent recommendations are shown at Exhibit 1-5.
The existing stop control and intersection geometry should remain at the intersections of Festival Drive & Driveway 1 (#8).
Recommendation 1 – Driveway 2 & Festival Drive (#9) – The following improvement is necessary to accommodate site access:
Project to install a stop control on the southbound approach and a shared left-right turn lane.
Recommendation 2 – Festival Drive is located on the Project’s western and southern boundary.
Festival Drive is a Private Street, and therefore its ultimate condition is not defined by the City of Anaheim General Plan. However, the Project is to construct Festival Drive along the Project’s frontage to its ultimate half width as defined in the SP.
On-site traffic signing and striping should be implemented agreeable with the provisions of the California Manual on Uniform Traffic Control Devices (CA MUTCD) and in conjunction with detailed construction plans for the Project site.
Sight distance at each Project access point should be reviewed with respect to standard California Department of Transportation (Caltrans) and City of Anaheim sight distance standards at the time of preparation of final grading, landscape, and street improvement plans. 12 13
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14 1.6.2 OFF-SITE RECOMMENDATIONS
There are no off-site improvements recommended as all study area intersections are anticipated to operate at an acceptable LOS for all analysis scenarios during the morning and evening peak hours.
However, the Project Applicant shall pay requisite fees for the applicable pre-existing fee programs (see Section 7 Local and Regional Funding Mechanisms). Although the roadway segments of Santa Ana Canyon Road, from Imperial Highway to Anaheim Hills Road and from Anaheim Hills Road to Fairmont Boulevard, are anticipated to operate at an unacceptable LOS based on the daily and peak roadway capacity thresholds and minimum LOS criteria under General Plan Buildout With Project traffic conditions, no roadway widening improvements have been recommended.
The high volume of through vehicles is attributable to vehicles bypassing the SR-91 Freeway during peak commute hours throughout the day. Introducing additional lanes along Santa Ana Canyon Road would encourage more vehicles to utilize this roadway segment and would be counterintuitive to the State’s goals with regards to Vehicle Miles Traveled. Roadway widening is also infeasible due to rightof-way limitations and is inconsistent with the City’s General Plan. Additionally, the Project is anticipated to increase the V/C by less than the City of Anaheim’s deficiency criteria threshold identified for intersections, and the intersections on both ends of the roadway segments are anticipated to operate at an acceptable LOS (LOS D or better) suggesting that the additional capacity accommodated through turn lanes at the choke-points of the roadway segments (e.g., intersections) can sufficiently handle the anticipated future traffic. Discussion in greater detail is found in Sections
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15 2 METHODOLOGIES
This section of the report presents the methodologies used to perform the traffic analyses summarized in this report. The methodologies described are consistent with the City of Anaheim’s traffic study guidelines.
2.1 LEVEL OF SERVICE
Traffic operations of roadway facilities are described using the term ”Level of Service“ (LOS). LOS is a qualitative description of traffic flow based on several factors, such as speed, travel time, delay, and freedom to maneuver. Six levels are typically defined ranging from LOS A, representing completely free-flow conditions, to LOS F, representing a breakdown in flow resulting in stop-and-go conditions.
LOS E represents operations at or near capacity, an unstable level where vehicles are operating with the minimum spacing for maintaining uniform flow.
2.2 INTERSECTION CAPACITY ANALYSIS
The definitions of LOS for interrupted traffic flow (flow restrained by the existence of traffic signals and other traffic control devices) differ slightly depending on the type of traffic control. The LOS is typically dependent on the quality of traffic flow at the intersections along a roadway. LOS analysis was conducted to determine existing traffic conditions using the ICU methodology for signalized study intersections.(4) The HCM (7th Edition) methodology was used to determine the LOS for unsignalized intersections and Caltrans facilities. The HCM methodology expresses the LOS at an intersection in terms of average control delay time for the various intersection approaches. (5) The HCM uses different procedures depending on the type of intersection control.
2.2.1 SIGNALIZED INTERSECTIONS
The City of Anaheim requires signalized intersection operations analysis to be evaluated through ICU methodology, which compares the peak hour traffic volumes to intersection capacity. Lane capacities of 1,700 vehicles per hour green per lane (vphgpl) have been utilized for this analysis, consistent with the City’s traffic study guidelines. A 0.05 lost time factor (clearance) and inherent vehicle delay between cycles with an assumed signal cycle of 100 seconds has been assumed for the ICU calculations. The ICU LOS definitions based on V/C ratio are presented in Table 2-1.
TABLE 2-1: SIGNALIZED INTERSECTION LOS THRESHOLDS
Level of Service Critical Volume-to-Capacity (V/C) Ratio A 0.00 - 0.60
B 0.61 - 0.70
C 0.71 - 0.80
D 0.81 - 0.90
E 0.91 - 1.00
F > 1.00
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16 Analysis of Caltrans operated facilities has been conducted in Synchro (Version 12) through the application of the HCM 7th Edition methodology for signalized intersections. Lane configurations and various other parameters such as signal timing was based on current operating characteristics as obtained from field review and signal timing worksheets provided by Caltrans District 12 staff. Future lane configurations were assumed the same as existing conditions for the General Plan Without Project and With Project scenarios. Table 2-2 presents the signalized intersection delay and LOS standards throughout the study area.
TABLE 2-2: SIGNALIZED INTERSECTION LOS THRESHOLDS WITH HCM Synchro is a macroscopic traffic software program that is based on the signalized intersection capacity analysis as specified in the HCM. Macroscopic level models represent traffic in terms of aggregate measures for each movement at the study intersections. Equations are used to determine measures of effectiveness such as delay and queue length. The level of service and capacity analysis performed by Synchro takes into consideration optimization and coordination of signalized intersections within a network.
The peak hour traffic volumes have been adjusted using a peak hour factor (PHF) to reflect peak 15- minute volumes. Customary practice for LOS analysis is to use a peak 15-minute rate of flow.
However, flow rates are typically expressed in vehicles per hour. The PHF is the relationship between the peak 15-minute flow rate and the full hourly volume (e.g., PHF = [Hourly Volume] / [4 x Peak 15- minute Flow Rate]). The use of a 15-minute PHF produces a more detailed analysis as compared to analyzing vehicles per hour. Existing PHFs have been used for all analysis scenarios. Per the HCM, PHF values over 0.95 often are indicative of high traffic volumes with capacity constraints on peak hour flows while lower PHF values are indicative of greater variability of flow during the peak hour. (5) Average Control Delay Level of Serice,
(Seconds), V/C < 1.0 V/C < 1.01 Operations with very low delay occurring with favorable progression and/or short cycle length. 0 to 10.00 A
Operations with low delay occurring with good progression and/or short cycle lengths. 10.01 to 20.00 B
Operations with average delays resulting from fair
progression and/or longer cycle lengths. Individual cycle failures begin to appear.
20.01 to 35.00 C
Operations with longer delays due to a combination of
unfavorable progression, long cycle lengths, or high V/C ratios. Many vehicles stop and indvidual cycle failures are noticeable.
35.01 to 55.00 D
Operations with high delay values indicating poor
progression, long cycle lengths, and high V/C ratios.
Individual cycle failures are frequent occurrences. This is considered to be the limit of acceptable delay.
55.01 to 80.00 E
Operation with delays unacceptable to most drivers
occurring due to over saturation, poor progression, or very long cycle lengths.
80.01 and up F
Source: HCM, 7th Edition
1 if V/C is greater than 1.0 then LOS is F per HCM
Description
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17 2.2.2 UNSIGNALIZED INTERSECTIONS
The City of Anaheim requires the operations of unsignalized intersections to be evaluated using the methodology described in the 7th Edition Highway Capacity Manual (HCM) methodology, which expresses the LOS at an intersection in terms of delay time for the various intersection approaches. (6) The LOS rating is based on the weighted average control delay expressed in seconds per vehicle (see Table 2-3). At two-way or side-street stop-controlled intersections, LOS is calculated for each controlled movement and for the left turn movement from the major street, as well as for the intersection as a whole. For approaches composed of a single lane, the delay is computed as the average of all movements in that lane. Delay for the intersection is reported for the worst individual movement at a two-way stop-controlled intersection. For all-way stop controlled intersections, LOS is computed for the intersection as a whole (average delay).
TABLE 2-3: UNSIGNALIZED INTERSECTION LOS THRESHOLDS
2.3 TRAFFIC SIGNAL WARRANT ANALYSIS METHODOLOGY
The term ”signal warrants“ refers to the list of established criteria used by Caltrans and other public agencies to quantitatively justify or determine the potential need for installation of a traffic signal at an otherwise unsignalized intersection. This TA uses the signal warrant criteria presented in the latest edition of the Caltrans California Manual on Uniform Traffic Control Devices (CA MUTCD). (7) The signal warrant criteria for Existing study area intersections are based upon several factors, including volume of vehicular and pedestrian traffic, frequency of accidents, and location of school areas. The CA MUTCD indicates that the installation of a traffic signal should be considered if one or more of the signal warrants are met. (7) Specifically, this TA utilizes the Peak Hour Volume-based Warrant 3 as the appropriate representative traffic signal warrant analysis for existing traffic conditions and for all future analysis scenarios for existing unsignalized intersections. Warrant 3 is appropriate to use for this TA because it provides specialized warrant criteria for intersections with rural characteristics. For the purposes of this study, the speed limit was the basis for determining whether Urban or Rural warrants were used for a given intersection. Urban warrants have been used as posted speed limits on the major roadways with unsignalized intersections are 40 miles per hour or below and rural warrants have been used where speeds exceed 40 miles per hour.
Average Control Delay Level of Serice,
(Seconds), V/C < 1.0 V/C < 1.01
Little or no delays. 0 to 10.00 A
Short traffic delays. 10.01 to 15.00 B
Average traffic delays. 15.01 to 25.00 C
Long traffic delays. 25.01 to 35.00 D
Very long traffic delays. 35.01 to 50.00 E
Extreme traffic delays with intersections capacity exceeded. >50.00 F Source: HCM, 7th Edition
1 if V/C is greater than 1.0 then LOS is F per HCM
Description
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18 Future intersections that do not currently exist have been assessed regarding the potential need for new traffic signals based on future average daily traffic (ADT) volumes, using the Caltrans planning level ADT-based signal warrant analysis worksheets. Similarly, the speed limit has been used as the basis for determining the use of Urban and Rural warrants. Traffic signal warrant analyses were performed for the following study area intersections shown in Table 2-4:
TABLE 2-4: TRAFFIC SIGNAL WARRANT ANALYSIS LOCATIONS
The Existing conditions traffic signal warrant analysis is presented in the subsequent section, Section 3 Area Conditions of this report. The traffic signal warrant analyses for future conditions are presented in Section 5 Opening Year (2029) Traffic Conditions and Section 6 General Plan Buildout Conditions of this report. It is important to note that a signal warrant defines the minimum condition under which the installation of a traffic signal might be warranted. Meeting this threshold condition does not require that a traffic control signal be installed at a particular location, but rather, that other traffic factors and conditions be evaluated in order to determine whether the signal is truly justified. It should also be noted that signal warrants do not necessarily correlate with LOS. An intersection may satisfy a signal warrant condition and operate at or above acceptable LOS or operate below acceptable LOS and not meet a signal warrant.
2.4 ROADWAY SEGMENT CAPACITY ANALYSIS
Roadway segment operations have been evaluated using the Roadway Capacity Thresholds provided in the Orange County Transportation Authority (OCTA) Guidance for Administration of the Orange County Master Plan of Arterial Highways (MPAH) and the County of Orange Transportation Implementation Manual (TIM). (8) (9) These roadway capacities are “rule of thumb” estimates for planning purposes and are affected by such factors as intersections (spacing, configuration and control features), degree of access control, roadway grades, design geometrics (horizontal and vertical alignment standards), sight distance, vehicle mix (truck and bus traffic) and pedestrian bicycle traffic.
In other words, while using ADT for planning purposes is suitable with regards to evaluating potential volume to capacity with future forecasts, it is not suitable for operational analysis because it does not account for the factors listed previously. As such, where the ADT based roadway segment analysis indicates a deficiency (unacceptable LOS), a review of the more detailed peak hour intersection analysis and progression analysis are undertaken. The more detailed peak hour intersection analysis explicitly accounts for factors that affect roadway capacity. # Intersection
6 Deer Canyon Rd. & Santa Ana Canyon Rd.
8 Festival Dr. & Driveway 1
9 Driveway 2 & Festival Dr.
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19 2.5 OFF-RAMP QUEUING ANALYSIS
Consistent with Caltrans requirements, the 95th percentile queuing of vehicles has been assessed at the off-ramps to determine potential queuing deficiencies at the freeway ramp intersections at the SR-91 Freeway at the Imperial Highway and Weir Canyon Road interchanges. Specifically, the off-ramp queuing analysis is utilized to identify any potential queuing and “spill back” onto the freeway mainline from the off-ramps. The 95th percentile queue has also been utilized to assess the queues at the study area interchanges to identify any potential peak hour queuing issues.
The traffic progression analysis tool and HCM intersection analysis program, Synchro, has been used to assess the potential deficiencies/needs of the intersections with traffic added from the proposed Project. Storage (turn-pocket) length recommendations at the ramps have been based upon the 95th percentile queue resulting from the Synchro progression analysis. The footnote from the Synchro output sheets indicates if the 95th percentile cycle exceeds capacity. Traffic is simulated for two complete cycles of the 95th percentile traffic in Synchro in order to account for the effects of spillover between cycles. In practice, the 95th percentile queue shown will rarely be exceeded and the queues shown with the footnote are acceptable for the design of storage bays. The 95th percentile queue is derived from the average queue plus 1.65 standard deviations.
2.6 MINIMUM ACCEPTABLE LEVELS OF SERVICE (LOS)
The City of Anaheim’s Growth Management Element requires a V/C ratio of 0.90 (Level of Service or LOS D) to be the lowest acceptable LOS at intersections following implementation of improvements. (10) Intersection improvements sufficient to bring intersections and roadway segments to the acceptable service levels must be identified. In order to maintain LOS D at intersections, arterial links (roadway segments) should be maintained to LOS C or better.
2.7 DEFICIENCY CRITERIA
A transportation impact on an intersection shall be deemed significant in accordance with the following Table 2-5 (per the City’s Guidelines):
TABLE 2-5: CITY OF ANAHEIM DEFICIENCY CRITERIA
The Final v/c Ratio shall mean the future V/C ratio at an intersection considering impacts with Project, ambient Growth, and Related Projects but without any proposed mitigation.
Cumulative traffic deficiencies are created as a result of a combination of the proposed Project together with other future developments contributing to the overall traffic deficiencies requiring additional improvements to maintain acceptable level of service operations with or without the Project. When the pre-Project condition is already below LOS D (i.e., unacceptable LOS), the Project will be responsible for contributing to the recommended improvements at intersections that receive 50 or more peak hour project-related trips through payment of fees into pre-existing fee programs or fair share contribution.
LOS Final v/c Ratio Project-Related Increase in v/c
C > 0.701-0.800
D > 0.801-0.900
E, F > 0.901
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20 2.8 FAIR SHARE CONTRIBUTION
For study area intersections identified as meeting the City’s deficiency thresholds (see Section 2.7 Deficiency Criteria), the Project's equitable share is to be calculated using the following equation:
= / ( )
Where:
P = The equitable share for the proposed project's traffic impact.
T = The vehicle trips generated by the project during peak hour of adjacent street, vph.
Tb = General Plan Buildout traffic volumes, vph.
Te = Existing traffic volume plus approved projects that have not been constructed or occupied (Opening Year (2029) Without Project), vph.
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21 3 AREA CONDITIONS
This section provides a summary of the existing circulation network, the City of Anaheim General Plan Circulation Network, and a review of existing peak hour intersection operations and traffic signal warrant analyses. (10)
3.1 EXISTING CIRCULATION NETWORK
Pursuant to the agreement with City of Anaheim staff (Appendix 1.1), the study area includes a total of 16 existing and future intersections as shown previously at Exhibit 1-4 Exhibit 3-1 illustrates the study area intersections located near the proposed Project and identifies the number of through traffic lanes for existing roadways and intersection traffic controls.
3.2 EXISTING ROADWAY NETWORK
Exhibit 3-2 shows the City of Anaheim General Plan Circulation Element. The City of Anaheim General Plan does not include roadway cross-sections.
Scenic Expressways are defined within the City of Anaheim General Plan Circulation Element as fourto-six-lane lane divided roadways with a right-of-way that varies from a width of 106 to 148 feet.
Scenic expressways have restricted access, serve intercity traffic, and provide scenic vistas.
Major Arterials are typically six-lane divided roadways with a 120-foot right-of-way. Typical major arterials have a landscaped median, left turn pockets, and parking lanes adjacent to each curb.
Primary Arterials are four- to six-lane divided roadways with a typical 106-foot right-of-way. Typical primary arterials with six lanes do not include parking; four-lane primary arterials include left turn pockets and two parking lanes.
Hillside Secondary Arterials are four-lane undivided roadways, with two parking lanes, and a typical right-of-way width of 66 feet without driveway access and 78 feet with driveway access.
Santa Ana Canyon Road is classified as a scenic expressway between Lakeview Avenue and Imperial Highway and between Roosevelt Road and Riverview Drive and is classified as a primary arterial between Imperial Highway and Roosevelt Road. Santa Ana Canyon Road currently exists within the study area with six lanes west of Imperial Highway and east of Festival Drive, five lanes from Imperial highway to Solomon Drive, and four lanes east of Solomon Drive. Santa Ana Canyon Road has a raised median, no street parking, and a posted speed limit of 45 miles per hour (MPH) west of Imperial Highway, 40 MPH from Imperial Highway to Festival Drive, 45 MPH from Festival Drive to Wier Canyon Road, and 50 MPH east of Weir Canyon Road.
Weir Canyon Road is classified as a scenic expressway between the SR-91 westbound ramps and Oak Canyon Drive and exists within the study area with six lanes, a raised median, no on-street parking, and a posted speed limit of 40 MPH.
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24 Imperial Highway is classified as a Major Arterial and currently exists within the study area with eight lanes, a raised median, no on-street parking, and a posted speed limit of 45 MPH north of SR-91 and 35 MPH south of SR-91.
Yorba Linda Boulevard is classified as a Primary Arterial north of SR-91 and exists within the study area with six lanes, a raised median, no on-street parking, and a posted speed limit of 40 MPH.
Anaheim Hills Road is classified as a Hillside Secondary Arterial and exists within the study area with four lanes south of Santa Ana Canyon Road, raised median, no on-street parking, and a posted speed limit of 35 MPH,
Fairmont Boulevard is classified as a Hillside Secondary Arterial and exists within the study area with two lanes, a raised median, no on-street parking, and a posted speed limit of 35 MPH.
Roosevelt Road is classified as a Hillside Secondary Arterial and exists within the study area with four lanes, a painted median, no on-street parking, and a posted speed limit of 25 MPH.
Monte Vista Road is classified as a Hillside Secondary Arterial and exists within the study area with four lanes, a painted median, no on-street parking, and a posted speed limit of 35 MPH.
3.3 BICYCLE AND PEDESTRIAN FACILITIES
Exhibit 3-3 illustrates the City of Anaheim existing and planned bicycle facilities. As shown at Exhibit 3-3, there are existing Class II bike lanes on Santa Ana Canyon Road, Anaheim Hills Road south of Santa Ana Canyon Road, and Weir Canyon Road south of Santa Ana Canyon Road. There is a planned Class I bike path and a planned Class II bike lane along Fairmont Boulevard, north and south of Santa Ana Canyon Road respectively. Class II bike lanes are signed and striped bike lanes on the roadway.
Existing pedestrian facilities within the study area are shown at Exhibit 3-4. As shown at Exhibit 3-4, there are existing pedestrian facilities along Festival Drive, Roosevelt Road, Monte Vista Road, Weir Canyon Road, and portions of Santa Ana Canyon Road in the vicinity of the Project site.
3.4 TRANSIT SERVICE
Exhibit 3-5 shows the City of Anaheim transit facilities. The study area within the City of Anaheim is currently served by OCTA, a public transit agency serving various jurisdictions within Orange County.
The closest OCTA transit routes (Route 30 and 38) run north of SR-91 with the nearest bus stop located at Imperial Highway and La Palma Avenue. Transit service is reviewed and updated by OCTA periodically to address ridership, budget, and community demand needs. Changes in land use can affect these periodic adjustments which may lead to either enhanced or reduced service where appropriate.
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28 3.5 EXISTING TRAFFIC COUNTS
The intersection LOS analysis is based on the traffic volumes observed during the peak hour conditions using traffic count data collected in November 2023 and January 2024. The following peak hours were selected for analysis:
Weekday AM Peak Hour (peak hour between 7:00 AM and 9:00 AM) Weekday PM Peak Hour (peak hour between 4:00 PM and 6:00 PM) The existing weekday AM and weekday PM peak hour count data is representative of typical weekday peak hour traffic conditions in the study area. There were no observations made in the field that would indicate atypical traffic conditions on the count dates, such as construction activity or detour routes and near-by schools were in session and operating on normal schedules. A comparison of historical traffic counts from September 2022 to traffic counts collected in November 2023 at four study area intersections showed a nominal growth factor. Given the short time span of only two months between the November 2023 and January 2024 data collection periods and the minimal growth factor observed, no growth was applied to establish the baseline condition. The existing weekday AM and weekday PM peak hour count data has been adjusted in some cases to achieve flow conservation between parallel routes. Flow conservation checks ensure that traffic flow between two closely spaced intersections, such as two adjacent driveway locations, is verified in order to make certain that vehicles leaving one intersection are entering the adjacent intersection and that there is no unexplained loss of vehicles.
The raw manual peak hour turning movement traffic count data sheets are included in Appendix 3.1.
Existing weekday ADT volumes are shown at Exhibit 3-6. Where actual 24-hour tube count data was not available, Existing ADT volumes were based upon factored intersection peak hour counts collected by Urban Crossroads, Inc. using the following formula for each intersection leg:
Weekday PM Peak Hour (Approach Volume + Exit Volume) x 10.2 = Leg Volume A comparison of the PM peak hour and daily traffic volumes of various roadway segments within the study area indicated that the peak-to-daily relationship is approximately 9.82 percent. As such, the above equation utilizing a factor of 10.2 estimates the ADT volumes on the study area roadway segments assuming a peak-to-daily relationship of 9.82 percent (i.e., 1/0.0982 = 10.2) and was assumed to sufficiently estimate ADT volumes for planning-level analyses. Existing weekday and weekend peak hour intersection volumes are also shown at Exhibit 3-6. 28 Anaheim Hills Festival SPA No. 6 Traffic Analysis
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30 3.6 INTERSECTION OPERATIONS ANALYSIS
Existing peak hour traffic operations have been evaluated for the study area intersections based on the analysis methodologies presented in Section 2.2 Intersection Capacity Analysis of this report. The intersection operations analysis results are summarized in Table 3-1, which indicates that the study area intersections are currently operating at an acceptable LOS during the peak hours. The delays and V/C reported at each study area intersection is based on an average of the overall intersection, as opposed to reporting of deficiencies to specific turning movements at an intersection. In other words, although intersections may have one or two movements that experience queuing/congestion, the effects are averaged against the operations of other movements at the intersection. The area of Santa Ana Canyon Road experiences congestion/queuing, especially going to the east of Weir Canyon Road which is attributable to commute traffic bypassing the SR-91 Freeway during the afternoon peak period. Queuing and operational deficiencies for specific turning movements may not have feasible improvements as the deficiencies are being caused by regional commute traffic associated with the congestion on the SR-91 Freeway and providing those improvements could potentially encourage additional traffic through the area. Additionally, periodic queues were observed within the study area during the morning peak hour near existing schools. It is common for intersections in close proximity to educational facilities to experience queues during morning drop-off and afternoon pick-up periods.
These queues typically last 15-20 minutes during the morning commute peak hour. The intersection operations analysis worksheets are included in Appendix 3.2 of this TA.
3.7 TRAFFIC SIGNAL WARRANTS ANALYSIS
Traffic signal warrants for Existing traffic conditions are based on existing peak hour intersection turning volumes. There are no unsignalized study area intersections that currently meet a traffic signal warrant under Existing (2024) traffic conditions. Existing conditions traffic signal warrant analysis worksheets are provided in Appendix 3.3.
3.8 ROADWAY SEGMENT ANALYSIS
The roadway capacities utilized for the study area roadway segment analysis are obtained from the OCTA Guidance of Administration of the Orange County MPAH and the County of Orange TIM. These roadway segment capacities are approximate figures only and are used to assist in determining the roadway functional classification (number of through lanes) needed to meet traffic demand. Table 3- 2 provides a summary of the Existing (2024) conditions roadway segment capacity analysis. As shown in Table 3-2, all of the study area roadway segments are currently operating at an acceptable LOS based on the daily roadway capacity thresholds and minimum LOS criteria.
3.9 OFF-RAMP QUEUING ANALYSIS
Queuing analysis findings for Existing (2024) traffic conditions are presented in Table 3-3. As shown in Table 3-3, there are no movements that are currently experiencing queuing issues during the weekday AM or weekday PM peak 95th percentile traffic flows under Existing (2024) traffic conditions.
Worksheets for Existing (2024) traffic conditions queuing analysis are provided in Appendix 3.4. 30 Anaheim Hills Festival SPA No. 6 Traffic Analysis
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31 TABLE 3-1: INTERSECTION ANALYSIS FOR EXISTING (2024) CONDITIONS TABLE 3-2: ROADWAY SEGMENT ANALYSIS FOR EXISTING (2024) CONDITIONS Level of
Traffic Evaluation Service
# Intersection Control 3 Methodology AM PM AM PM
1 Imperial Hwy. & SR-91 WB Ramps TS HCM 13.8 9.2 B A
ICU 0.686 0.543 B A
2 Imperial Hwy. & SR-91 EB Ramps TS HCM 12.8 11.2 B B
ICU 0.564 0.548 A A
3 Imperial Hwy. & Santa Ana Canyon Rd. TS ICU 0.640 0.714 B C 4 Anaheim Hills Rd. & Santa Ana Canyon Rd. TS ICU 0.610 0.700 B B 5 Fairmont Bl. & Santa Ana Canyon Rd. TS ICU 0.531 0.538 A A 6 Deer Canyon Rd. & Santa Ana Canyon Rd.
7 Festival Dr. & Santa Ana Canyon Rd. TS ICU 0.219 0.362 A A 8 Festival Dr. & Driveway 1 CSS HCM 10.2 10.9 B B
9 Driveway 2 & Festival Dr.
10 Festival Center Dwy. & Santa Ana Canyon Rd. TS ICU 0.197 0.400 A A 11 Roosevelt Rd. & Santa Ana Canyon Rd. TS ICU 0.295 0.484 A A 12 Roosevelt Rd. & Festival Dr./Monte Vista Rd. TS ICU 0.176 0.258 A A 13 Weir Canyon Rd. & SR-91 WB Ramps TS HCM 8.4 10.2 A B ICU 0.480 0.586 A A
14 Weir Canyon Rd. & SR-91 EB Ramps TS HCM 11.0 6.4 B
ICU 0.550 0.477 A A
15 Weir Canyon Rd. & Santa Ana Canyon Rd. TS ICU 0.508 0.732 A C 16 Weir Canyon Rd. & Monte Vista Rd. TS ICU 0.404 0.500 A A 1 2
3 TS = Traffic Signal; CSS = Cross-street Stop
All signalized intersections are evaluated utilizing Intersection Capacity Utilization (ICU) methodology, reported as a volume-tocapacity ratio. For intersections with all way or cross street stop control, the HCM delay and level of service for the worst individual movement (or movements sharing a single lane) are shown. Signalized intersections within Caltrans jurisdiction will be evalutaed utilizing both HCM and ICU methodology.
Per the Highway Capacity Manual (7th Edition), overall average intersection delay and level of service are shown for intersections with a traffic signal or all way stop control. For intersections with cross street stop control, the delay and level of service for the worst individual movement (or movements sharing a single lane) are shown. HCM delay reported in seconds.
Delay1 (secs.)
ICU (v/c)2
Future Intersection
Future Intersection
Roadway LOS Acceptable
# Roadway Segment Limits Section Capacity1 2024 V/C2 LOS3 LOS4 1 Santa Ana Canyon Rd. Imperial Hwy. to Anaheim Hills Rd. 5D 46,875 34,691 0.740 C C 2 Anaheim Hills Rd. to Fairmont Bl. 4D 37,500 25,273 0.674 B C 3 Fairmont Bl. to Deer Canyon Rd. 4D 37,500 22,989 0.613 B C 4 Deer Canyon Rd. Festival Dr. 4D 37,500 22,989 0.613 B C 5 Festival Dr. to Roosevelt Rd. 6D 56,250 18,829 0.335 A C 6 Roosevelt Rd. to Weir Canyon Rd. 6D 56,250 22,929 0.408 A C 7 Roosevelt Rd. Santa Ana Canyon Rd. to Festival Dr. 4D 25,000 9,139 0.366 A C 8 Festival Dr. Santa Ana Canyon Rd. to Driveway 1 2D 22,000 7,140 0.325 A C 9 Driveway 2 to Roosevelt Rd. 2D 22,000 4,300 0.195 A C 10 Monte Vista Rd. Roosevelt Rd. to Weir Canyon Rd. 4D 25,000 8,989 0.360 A C 11 Weir Canyon Rd. SR-91 Freeway to Santa Ana Canyon Rd. 6D 56,250 38,443 0.683 B C 12 Santa Ana Canyon Rd. to Monte Vista Rd. 6D 56,250 23,919 0.425 A C 1 The volumes shown are based on LOS "E" roadway capacity as defined by the County of Orange Growth Management Plan. 2 V/C = Volume to Capacity Ratio
3 LOS = Level of Service 4
The City of Anaheim roadway standard is LOS "C".
Existing (2024)
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32 TABLE 3-3: PEAK HOUR QUEUING SUMMARY FOR EXISTING (2024) CONDITIONS
3.10 EXISTING DEFICIENCIES AND IMPROVEMENTS
Improvement strategies have been recommended at intersections that have been identified as deficient under Existing (2024) traffic conditions in an effort to achieve an acceptable LOS.
3.10.1 IMPROVEMENTS TO ADDRESS DEFICIENCIES AT INTERSECTIONS All study area intersections currently operate at an acceptable LOS during the peak hours under Existing (2024) traffic conditions. As such, no improvements have been identified.
3.10.2 IMPROVEMENTS TO ADDRESS DEFICIENCIES AT ROADWAY SEGMENTS As shown in Table 3-2, there are no roadway segments currently operating at an unacceptable LOS based on the daily roadway capacity thresholds and minimum LOS criteria under Existing (2024) traffic conditions. As such, no improvements have been identified.
3.10.3 IMPROVEMENTS TO ADDRESS OFF-RAMP QUEUING DEFICIENCIES There are no movements that are currently experiencing queuing issues during the weekday AM or weekday PM peak 95th percentile traffic flows under Existing (2024) traffic conditions. As such, no improvements have been identified.
# Intersection AM PM
1 Imperial Hwy. & SR-91 WB Ramps WBL 1,280 371 243 Yes Yes WBR 495 459 320 Yes Yes
2 Imperial Hwy. & SR-91 EB Ramps EBL 2,365 335 301 Yes Yes EBR 510 403 360 Yes Yes
13 Weir Canyon Rd. & SR-91 WB Ramps WBL 1,580 178 312 Yes Yes WBR 350 213 369 3
Yes Yes
14 Weir Canyon Rd. & SR-91 EB Ramps EBL 1,740 294 156 Yes Yes EBR 225 338 3
206 Yes Yes 2
95th percentile volume exceeds capacity, queue may be longer. Queue shown is maximum after two cycles. 1 Stacking Distance is acceptable if the required stacking distance is less than or equal to the stacking distance provided. An additional 25 feet of stacking which is assumed to be provided in the transition for turn pockets is reflected in the stacking distance shown on this table, where applicable. 3 Although 95th percentile queue is anticipated to exceed the available storage for the turn lane, the adjacent through lane has sufficient storage to accommodate any spillover without spilling back and affecting the SR-91 mainline.
Movement
Available Stacking
Distance (Feet)
95th Percentile Queue (Feet) Acceptable? 1 AM Peak Hour PM Peak Hour 32 Anaheim Hills Festival SPA No. 6 Traffic Analysis
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33 4 PROJECTED FUTURE TRAFFIC
This section presents the traffic volumes estimated to be generated by the Project, as well as the Project’s trip assignment onto the study area roadway network. The existing SP is divided into four DAs by land use. DA 1 is the Scenic Commercial area fronting Santa Ana Canyon Road between Festival Drive and Roosevelt Road, DA 2 is the Regional Commercial use that contains the department stores, grocery, other food/retail uses, and the vacant cinema, DA 3 is the Visitor Commercial area located west of Festival Drive which includes the existing hotel, and DA 4 is the Senior Residential area south of Festival Drive. The proposed SPA proposes the implementation of a new 16.2-acre mixed-use development area on the upper level of the commercial center as a new DA 5 (which is a portion of the old DA 2).
Specifically, the Project proposes to demolish the existing 62,676-square-foot vacant cinema and develop, in its place, 447 multi-family residential dwelling units while retaining the remaining existing commercial uses within the new DA 5. Approximately 13,310 square feet of existing retail would be retained in DA 2 as a result of the new DA 5 (resulting in a net reduction of 49,366 square feet of retail space). The retail within DA 5 will include the following existing uses: 6,475 square feet of restaurant use, 9,200 square feet of office use, 38,160-square-foot fitness/gym, 13,276 square feet of tutor/retail space, and 11,033-square-foot medical office building. The Project will be developed within a single phase for the purposes of the Traffic Analysis with an anticipated Opening Year of 2029.
4.1 PROJECT TRIP GENERATION
Trip generation represents the amount of traffic which is both attracted to, and produced by, a development. Determining traffic generation for a specific project is therefore based upon forecasting the amount of traffic that is expected to be both attracted to, and produced by, the specific land uses being proposed for a given development.
The trip generation rates used for the proposed Project are based upon information collected by the ITE as provided in their latest Trip Generation Manual, 11th Edition, 2021. ITE Land Use Code 221 for Multifamily Housing (Mid-Rise, 4-10 Floors) has been used for the proposed Project (see Table 4-1). (2) The Project trip generation summary, illustrating daily and peak hour trip generation estimates for the Project based on the applicable ITE trip generation rates, is shown in Table 4-2. Only traffic for the proposed multi-family development is taken into consideration as the existing retail, restaurant, and office uses would be captured as part of the existing intersection traffic count program. However, given the proximity of the proposed residential to the adjacent existing uses within DA 1 and DA 2, the trip generation accounts for internal capture between these uses.
TABLE 4-1: PROJECT TRIP GENERATION RATES
ITE AM Peak Hour PM Peak Hour
Land Use1
LU Code In Out Total In Out Total
Multifamily (Mid-Rise) Residential 221 DU 0.09 0.28 0.37 0.24 0.15 0.39 4.54 Shopping Center > 150,000 SF 820 TSF 0.52 0.32 0.84 1.63 1.77 3.40 37.01 1 Trip Generation Source: Institute of Transportation Engineers (ITE), Trip Generation Manual, Eleventh Edition (2021). 2 DU = Dwelling Units; TSF = Thousand Square Feet
Units2 Daily
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34 TABLE 4-2: PROJECT TRIP GENERATION SUMMARY
Internal capture is a percentage reduction that can be applied to the vehicle trip generation estimates for individual land uses to account for trips internal to a site (trips that travel between uses without leaving the site). In other words, trips may be made between the existing retail, restaurant, and office uses and the proposed multi-family residential use on-site which can be made either by walking or using internal roadways without using external streets. An internal capture reduction was applied to recognize the interactions that would occur between the various complementary land uses within the SP. The internal capture is based on the National Cooperative Highway Research Program’s (NCHRP Report 684) internal trip capture estimation tool. These internal capture worksheets are provided in Attachment A of the scoping agreement (Appendix 1.1). For the purposes of the Traffic Study, the internal capture will be limited to 20%, consistent with the AM peak hour internal capture (although the PM peak hour worksheets reflect up to 67%).
As shown in Table 4-2, the Project is anticipated to generate 1,624 two-way trips per day with 132 AM peak hour trips and 139 PM peak hour trips.
As noted previously, the 62,676-square-foot cinema on the site is currently vacant. The proposed Project will redevelop the site to replace the existing cinema use with 447 multi-family (mid-rise) residential dwelling units and 13,310 square feet of future retail space retained in DA 2. In order to conduct a conservative analysis, no trip credit will be taken for the existing vacant use. However, the net change in trip generation between the multi-family residential, the existing cinema, and the future retail space to be added is summarized in Table 4-3 for informational purposes. As shown on Table 4- 3, the proposed Project is anticipated to generate a net increase in trips during the AM peak hour but would result in a net reduction of 532 two-way trips per day and 33 PM peak hour trips.
TABLE 4-3: TRIP GENERATION COMPARISON
Daily
Land Use Quantity Units1
In Out Total In Out Total
Multifamily (Mid-Rise) Residential 447 DU 38 127 165 106 68 174 2,030 Internal Capture (20% Reduction)2
-3 -30 -33 -21 -14 -35 -406
Total Project Trips 35 97 132 85 54 139 1,624 1
DU = Dwelling Units 2
Internal capture of residential to the adjacent existing restaurant, food, retail, and medical office uses per NCHRP 684.
AM Peak Hour PM Peak Hour
Daily
Trip Generation Comparison In Out Total In Out Total
Multifamily (Mid-Rise) Residential 38 127 165 106 68 174 2,030 Future Retail Space (13,310 SF) 1 0 1 2 2 3 38
Cinema (Vacant)2
0 0 0 -145 -65 -210 -2,600
Net Change in Trips 39 127 166 -37 5 -33 -532 1
DU = Dwelling Units; TSF = Thousand Square Feet 2
Source: Anaheim Hills Festival Traffic and Parking Study, dated January 29, 1990, prepared by Weston Pringle & Associates.
AM Peak Hour PM Peak Hour
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35 4.2 PROJECT TRIP DISTRIBUTION
The Project trip distribution and assignment process represents the directional orientation of traffic to and from the Project site. The trip distribution pattern is heavily influenced by the geographical location of the site, the location of surrounding uses, and the proximity to the regional freeway system. Exhibit 4-1 illustrates the Project trip distribution patterns for the Project. The Project trip distribution patterns are based on existing travel patterns.
4.3 MODAL SPLIT
The potential for Project trips to be reduced by the use of public transit, walking, or bicycling have not been included as part of the Project’s estimated trip generation. Essentially, the Project’s traffic projections are ”conservative“ in that these alternative travel modes would reduce the forecasted traffic volumes.
4.4 PROJECT TRIP ASSIGNMENT
The assignment of traffic from the Project area to the adjoining roadway system is based upon the Project trip generation, trip distribution, and the arterial highway and local street system improvements that would be in place by the time of initial occupancy of the Project. Based on the identified Project traffic generation and trip distribution patterns, Project weekday ADT and weekday peak hour intersection turning movement volumes are shown at Exhibit 4-2.
4.5 BACKGROUND TRAFFIC
Future year traffic forecasts have been based upon background (ambient) growth at 1 percent per year, compounded annually, for 2029 traffic conditions. The total ambient growth is 5.10 percent for 2029 traffic conditions. The ambient growth factor is intended to approximate regional traffic growth.
This ambient growth rate is added to existing traffic volumes to account for area-wide growth not reflected by cumulative development projects. Ambient growth has been added to daily and peak hour traffic volumes on surrounding roadways, in conjunction with traffic generated by the development of future projects that have been approved but not yet built and/or for which development applications have been filed and are under consideration by governing agencies. 2029 traffic volumes are provided in Sections 5 and 6 of this report. The traffic generated by the proposed Project was then manually added to the base volume to determine With Project forecasts. 35 36
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38 4.6 CUMULATIVE DEVELOPMENT TRAFFIC
A cumulative project list was developed for the purposes of this analysis through consultation with planning and engineering staff from the City of Anaheim. The cumulative projects listed are those that would generate traffic and would contribute traffic to study area intersections. Exhibit 4-3 illustrates the cumulative development location map. A summary of cumulative development projects and their proposed land uses are shown in Table 4-4. Consistent with the City’s traffic study guidelines, traffic from approved cumulative development projects was added to the Opening Year (2029) Without Project traffic forecasts and traffic from both pending and approved cumulative development projects were added to the Future Conditions (2029) traffic forecasts. In an effort to conduct a conservative analysis, the cumulative projects are added in conjunction with the ambient growth identified in Section 4.5 Background Traffic. The trip generation rates used for the cumulative projects are based upon information collected by the ITE as provided in their latest Trip Generation Manual, 11th Edition, 2021 (See Table 4-5). The cumulative project trip generation summary, illustrating daily and peak hour trip generation estimates for the cumulative projects based on the applicable ITE trip generation rates, is shown in Table 4-6. It should be noted that the trip generations for cumulative projects A1, A11, and Y1 were pulled directly from their respective traffic analyses reports. Cumulative Only ADT and peak hour intersection turning movement volumes are shown at Exhibit 4-4.
TABLE 4-4: CUMULATIVE DEVELOPMENT LAND USE SUMMARY
No. Project Name / Case Number Land Use Quantity Units1Location A1 The Hills Preserve Project Multi-Family Residential 498 DU S of Santa Ana Canyon Road, Single-Family Residential 6 DU N. of Deer Canyon Park,
Non-Resident Amenity Access 12.700 TSF between S. Eucalyptus Drive & Commercial 80.000 TSF Festival Drive
Open Space & Trails 43.2 AC
A2 DEV2022-00055 Industrial 94.540 TSF 180 N Riverside Drive A3 DEV2021-00046 Retail Plaza 5.315 TSF 8163 E Kaiser Boulevard DEV2013-00024C Preschool 43 STU
A4 DEV2022-00044 RV Storage 160 Spaces S of Crystal Drive & W of Pullman Street A5 DEV2020-00204 Cemetery 180.0 AC APN 51401235
A6 DEV2020-00097 Single-Family Residential 4 DU 6268 E Rio Grande Drive A7 DEV2022-00063 Warehouse 87.912 TSF 5510 E La Palma Avenue A8 DEV2022-00030 Multi-Family Residential 360 DU 4679 E Orchard Drive A9 DEV2019-00151 Single-Family Residential 4 DU 6140 E Santa Ana Canyon Road A10 DEV2020-00096 Warehouse 169.000 TSF 3939 E Coronado Street A11 DEV2021-00057 General Light Industrial 38.251 TSF 3855 E La Palma Avenue A12 DEV2021-00073 Single-Family Residential 3 DU 860 S Peralta Hills Drive Y1 ECTO Homes Senior Housing 240 DU SEC of Mariposa & Lakeview 1 AC = Acres; DU = Dwelling Units; STU = Students; TSF = Thousand Square Feet 38 Anaheim Hills Festival SPA No. 6 Traffic Analysis
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39 TABLE 4-5: CUMULATIVE DEVELOPMENT TRIP GENERATION RATES TABLE 4-6: CUMULATIVE DEVELOPMENT TRIP GENERATION SUMMARY ITE
Land Use1 Code Units2
In Out Total In Out Total Daily
General Light Industrial 110 TSF 0.651 0.089 0.740 0.091 0.559 0.650 4.870 Passenger Cars (AM=98.6%, PM=99.4%, Daily=94.9%) 0.085 0.645 0.730 0.086 0.554 0.640 4.620 Trucks 0.004 0.006 0.010 0.005 0.005 0.010 0.250 Strip Retail Plaza (<40k) 822 TSF 1.42 0.94 2.36 3.30 3.30 6.59 54.45 Day Care Center 565 STU 0.41 0.37 0.78 0.37 0.42 0.79 4.09 Mini-Warehouse (RV Parking) 151 Spaces 0.01 0.01 0.01 0.01 0.01 0.02 0.18 Cemetery 566 AC 0.14 0.03 0.17 0.14 0.32 0.46 6.02 Single-Family Residential 210 DU 0.18 0.52 0.70 0.59 0.35 0.94 9.43 Warehousing 150 TSF 0.131 0.039 0.170 0.050 0.130 0.180 1.710 Passenger Cars (AM=88.2%, PM=83.3%, Daily=64.9%) 0.030 0.120 0.150 0.034 0.116 0.150 1.110 Trucks 0.009 0.011 0.020 0.016 0.014 0.030 0.600 Multi-Family Residential 220 DU 0.10 0.30 0.40 0.32 0.19 0.51 6.74 1 Trip Generation Source: Institute of Transportation Engineers (ITE), Trip Generation Manual, Eleventh Edition (2021). 2 AC = Acres; DU = Dwelling Units; STU = Students; TSF = Thousand Square Feet AM Peak Hour PM Peak Hour
Land Use Quantity Units1In Out Total In Out Total Daily A1 - Mixed-Use2
-- -- 159 168 327 167 192 359 3,623
A2 - Industrial 34.46 TSF
Passenger Cars (AM=98.6%, PM=99.4%, Daily=94.9%) 22 3 25 3 19 22 160 Trucks 0 0 0 0 0 0 10
A3 - Retail Plaza 5.315 TSF 8 5 13 18 18 36 290
A3 - Preschool 43 STU 18 16 34 16 18 34 176
A4 - RV Storage 160 Spaces 1 1 2 1 1 2 30
A5 - Cemetery 180.0 AC 24 6 30 26 57 83 1,084
A6 - Single-Family Residential 4 DU 1 2 3 2 1 3 38
A7 - Warehousing 55.662 TSF 7 2 9 3 7 10 96
Passenger Cars (AM=88.2%, PM=83.3%, Daily=64.9%) 7 2 9 2 6 8 62 Trucks 1 1 2 1 1 2 34
A8 - Multi-Family Residential 360 DU 35 109 144 116 68 184 2,426 A9 - Single-Family Residential 4 TSF 1 2 3 2 1 3 38
A10 - Warehouse 169.000 TSF 22 7 29 9 22 31 290
A11 - General Light Industrial2
38.251 TSF
Passenger Cars 25 3 28 3 21 24 178
Trucks 0 0 0 0 0 0 10
A12 - Single-Family Residential 3 DU 1 2 3 2 1 3 28
Y1 - Senior Living2
240 DU/Beds 22 11 33 31 29 60 599 1
AC = Acres; DU = Dwelling Units; STU = Students; TSF = Thousand Square Feet 2 The trip generation has been pulled directly from the project's traffic analysis report.
AM Peak Hour PM Peak Hour
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42 4.7 NEAR-TERM TRAFFIC CONDITIONS
The “buildup” approach combines existing traffic counts with a background ambient growth factor to forecast Opening Year (2029) traffic conditions. An ambient growth factor accounts for background (area-wide) traffic increases that occur over time up to the year 2029 from the year 2024. Traffic volumes generated by the Project are then added to assess the near-term traffic conditions. The 2029 roadway networks are similar to the Existing conditions roadway network, with the exception of future driveways proposed to be developed by the Project. The near-term traffic analysis includes the following traffic conditions, with the various traffic components:
Opening Year (2029) Without Project Conditions o Existing 2024 counts o Ambient growth traffic (5.10%) o Approved Cumulative Development Traffic Opening Year (2029) With Project Conditions o Existing 2024 counts o Ambient growth traffic (5.10%) o Approved Cumulative Development Traffic o Project traffic
4.8 GENERAL PLAN BUILDOUT VOLUME DEVELOPMENT
Traffic projections for General Plan Buildout Without Project conditions were derived from the ATAM using accepted procedures for model forecast refinement and smoothing for study area intersections located within the City of Anaheim. The traffic forecasts reflect the area-wide growth anticipated in the City’s General Plan or implied by the City’s Zoning Ordinance.
The General Plan Buildout Without Project peak hour turning movements were then reviewed by Urban Crossroads, Inc. for reasonableness, and in some cases, were adjusted to achieve flow conservation, reasonable growth, and reasonable diversion between parallel routes. Flow conservation checks ensure that traffic flow between two closely spaced intersections, such as two adjacent driveway locations, is verified in order to make certain that vehicles leaving one intersection are entering the adjacent intersection and that there is no unexplained loss of vehicles. The result of this traffic forecasting procedure is a series of traffic volumes which are suitable for traffic operations analysis. Project traffic was then added for all With Project traffic conditions. The long-range traffic forecasts were developed by the City’s traffic consultant and are included in Appendix 4.1. 42 Anaheim Hills Festival SPA No. 6 Traffic Analysis
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43 5 OPENING YEAR (2029) TRAFFIC CONDITIONS
This section discusses the traffic forecasts for Opening Year (2029) conditions and the resulting intersection operations and traffic signal warrant analyses.
5.1 ROADWAY IMPROVEMENTS
The lane configurations and traffic controls assumed to be in place for Opening Year (2029) conditions are consistent with those shown previously at Exhibit 3-1, with the exception of the following:
Deer Canyon Road is assumed to be constructed to provide site access by the Hills Preserve Project. The intersection of Deer Canyon Road and Santa Ana Canyon Road (#6) is assumed to be a signalized intersection.
Project driveways and those facilities assumed to be constructed by the Project to provide site access are also assumed to be in place for Opening Year (2029) With Project conditions only (e.g., intersection and roadway improvements at the Project’s frontage and driveways).
5.2 OPENING YEAR (2029) WITHOUT PROJECT TRAFFIC VOLUME FORECASTS This scenario includes Existing traffic volumes with the application of a 5.10 percent growth adjustment factor plus the addition of traffic generated by approved cumulative development projects. The weekday ADT and weekday AM and PM peak hour volumes which can be expected for Opening Year (2029) Without Project traffic conditions are shown at Exhibit 5-1.
5.3 OPENING YEAR (2029) WITH PROJECT TRAFFIC VOLUME FORECASTS This scenario includes Existing traffic volumes with the application of a 5.10 percent growth adjustment factor plus the addition of traffic generated by approved cumulative development projects plus the addition of traffic generated by the proposed Project. The weekday ADT and weekday AM and PM peak hour volumes which can be expected for Opening Year (2029) With Project traffic conditions are shown at Exhibit 5-2.
5.4 INTERSECTION OPERATIONS ANALYSIS
Opening Year (2029) Without Project peak hour traffic operations have been evaluated for the study area intersections based on the analysis methodologies presented in Section 2 Methodologies of this TA. The intersection analysis results are summarized in Table 5-1 for Opening Year (2029) Without Project traffic conditions, which indicates that the study area intersections are anticipated to continue to operate at an acceptable LOS during the peak hours under Opening Year (2029) traffic conditions, consistent with Existing (2024) traffic conditions. The intersection operations analysis worksheets for Opening Year (2029) Without Project and With Project traffic conditions are included in Appendices
5.1 and 5.2, respectively.
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46 TABLE 5-1: INTERSECTION ANALYSIS FOR OPENING YEAR (2029) CONDITIONS
5.5 TRAFFIC SIGNAL WARRANTS ANALYSIS
The traffic signal warrant analysis for Opening Year (2029) traffic conditions is based on the peak hour volumes or planning level ADT volume-based traffic signal warrants. The following unsignalized study area intersection is anticipated to meet a traffic signal warrant under Opening Year (2029) Without Project traffic conditions (see Appendix 5.3):
Deer Canyon Road & Santa Ana Canyon Road (#6)
With the addition of Project traffic, there are no additional unsignalized study area intersections anticipated to meet a traffic signal warrant under Opening Year (2029) With Project traffic conditions (see Appendix 5.4).
Level of Level of
Evaluation Service Service
Methodology AM PM AM PM AM PM AM PM AM PM
1 Imperial Hwy. & SR-91 WB Ramps TS HCM 15.4 10.0 B B 15.5 10.1 B B -- -- ICU 0.722 0.572 C A 0.723 0.573 C A 0.001 0.001
2 Imperial Hwy. & SR-91 EB Ramps TS HCM 14.6 12.7 B B 14.7 12.9 B B -- -- ICU 0.603 0.588 B A 0.605 0.593 B A 0.002 0.005
3 Imperial Hwy. & Santa Ana Canyon Rd. TS ICU 0.696 0.785 B C 0.700 0.794 C C 0.004 0.009 4 Anaheim Hills Rd. & Santa Ana Canyon Rd. TS ICU 0.677 0.772 B C 0.687 0.781 B C 0.010 0.009 5 Fairmont Bl. & Santa Ana Canyon Rd. TS ICU 0.589 0.597 A A 0.599 0.606 A B 0.010 0.009 6 Deer Canyon Rd. & Santa Ana Canyon Rd. TS ICU 0.359 0.606 A B 0.362 0.615 A B 0.003 0.009 7 Festival Dr. & Santa Ana Canyon Rd. TS ICU 0.229 0.391 A A 0.247 0.405 A A 0.018 0.014 8 Festival Dr. & Driveway 1 CSS HCM 10.3 11.0 B B 10.6 11.5 B B -- -- 9 Driveway 2 & Festival Dr. CSS HCM 9.5 9.8 A A -- -- 10 Festival Center Dwy. & Santa Ana Canyon Rd. TS ICU 0.215 0.431 A A 0.215 0.431 A A 0.000 0.000 11 Roosevelt Rd. & Santa Ana Canyon Rd. TS ICU 0.329 0.537 A A 0.346 0.548 A A 0.017 0.011 12 Roosevelt Rd. & Festival Dr./Monte Vista Rd. TS ICU 0.183 0.276 A A 0.208 0.292 A A 0.025 0.016 13 Weir Canyon Rd. & SR-91 WB Ramps TS HCM 9.4 11.6 A B 9.4 11.8 A B -- -- ICU 0.480 0.626 A B 0.517 0.631 A B 0.037 0.005
14 Weir Canyon Rd. & SR-91 EB Ramps TS HCM 12.1 6.9 B A 12.3 7.1 B A -- -- ICU 0.583 0.516 A A 0.589 0.525 A A 0.006 0.009
15 Weir Canyon Rd. & Santa Ana Canyon Rd. TS ICU 0.557 0.799 A C 0.568 0.806 A D 0.011 0.007 16 Weir Canyon Rd. & Monte Vista Rd. TS ICU 0.425 0.527 A A 0.427 0.530 A A 0.002 0.003 1 2 3
TS = Traffic Signal; CSS = Cross-street Stop; TS = Improvement ProjectRelated
Increase in
ICU (v/c) V/C 2
ICU (v/c)2
Future Intersection
Per the Highway Capacity Manual (7th Edition), overall average intersection delay and level of service are shown for intersections with a traffic signal or all way stop control. For intersections with cross street stop control, the delay and level of service for the worst individual movement (or movements sharing a single lane) are shown. HCM delay reported in seconds. All signalized intersections are evaluated utilizing Intersection Capacity Utilization (ICU) methodology, reported as a volume-to-capacity ratio. For intersections with all way or cross street stop control, the HCM delay and level of service for the worst individual movement (or movements sharing a single lane) are shown. Signalized intersections within Caltrans jurisdiction will be evalutaed utilizing both HCM and ICU methodology.
Without Project With Project
Opening Year (2029)
# Intersection
Traffic
Control 3 Delay1
(secs.) Delay1 (secs.)
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47 5.6 ROADWAY SEGMENT ANALYSIS
The roadway capacities utilized for the study area roadway segment analysis are obtained from the OCTA Guidance of Administration of the Orange County MPAH and the County of Orange TIM. These roadway segment capacities are approximate figures only and are used to assist in determining the roadway functional classification (number of through lanes) needed to meet traffic demand. Table 5- 2 provides a summary of the Opening Year (2029) traffic conditions roadway segment capacity analysis. As shown in Table 5-2, the following study area roadway segment is anticipated to operate at an unacceptable LOS based on the daily roadway capacity thresholds and minimum LOS criteria under both Opening Year (2029) Without Project and With Project traffic conditions:
Santa Ana Canyon Road, from Imperial Highway to Anaheim Hills Road (#1) – LOS D
5.7 OFF-RAMP QUEUING ANALYSIS
Queuing analysis findings for Opening Year (2029) are presented in Table 5-3. As shown in Table 5-3, there are no movements that are anticipated to experience queuing issues during the weekday AM or weekday PM peak 95th percentile traffic flows under both the Opening Year (2029) traffic conditions.
Worksheets for Opening Year (2029) Without Project and With Project traffic conditions queuing analysis are provided in Appendices 5.5 and 5.6, respectively. 47 Anaheim Hills Festival SPA No. 6 Traffic Analysis
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50 5.8 DEFICIENCIES AND IMPROVEMENTS
Improvement strategies have been recommended at intersections that have been identified as deficient under Opening Year (2029) With Project traffic conditions in an effort to achieve an acceptable LOS.
5.8.1 IMPROVEMENTS TO ADDRESS DEFICIENCIES AT INTERSECTIONS As previously shown in Table 5-1, all study area intersections are anticipated to continue to operate at an acceptable LOS during the AM and PM peak hours under Opening Year (2029) With Project traffic conditions. As such, no improvements, aside from those that are needed to facilitate site access, have been identified.
5.8.2 IMPROVEMENTS TO ADDRESS DEFICIENCIES AT ROADWAY SEGMENTS As shown in Table 5-2, Santa Ana Canyon Road, from Imperial Highway to Anaheim Hills Road, is anticipated to operate at an unacceptable LOS based on the daily roadway capacity thresholds and minimum LOS criteria under General Plan Buildout With Project traffic conditions. The high volume of through vehicles is attributable to vehicles bypassing the SR-91 Freeway during peak commute hours throughout the day. Introducing additional lanes along Santa Ana Canyon Road would encourage more vehicles to utilize this roadway segment and would be counterintuitive to the State’s goals with regards to Vehicle Miles Traveled. Roadway widening is also infeasible due to right-of-way limitations and is inconsistent with the City’s General Plan.
The City of Anaheim lacks specific criteria to determine a significant project impact on roadway segments. However, based on criteria similar to the City’s intersection deficiency criteria, the Projectrelated increase in V/C is deemed not significant. The Project is anticipated to increase the V/C by
0.012 (1.2%), which is less than the threshold of 0.030 (3.0%) identified for intersections anticipated to operate at LOS D under pre-Project conditions. Additionally, the intersections on both ends of the roadway segment are anticipated to operate at an acceptable LOS (LOS D or better) suggesting that the additional capacity accommodated through turn lanes at the choke-points of the roadway segments (e.g., intersections) can sufficiently handle the anticipated future traffic.
At the City’s request, additional peak hour roadway segment analysis was conducted for the deficient roadway segments to determine whether or not there is a project impact at the respective roadway segment. The peak hour roadway segment analysis utilizes an adjusted segment capacity for each direction of the applicable roadway segment by multiplying the mid-block number of lanes in the applicable direction by a lane capacity of 1,900 vehicles per hour, then multiplied by the AM and PM peak hour V/C ratios percentage of green time at the controlling signalized intersections. This methodology is utilized to determine if congestion on a street segment is due to a lack of capacity or if traffic flows are affected by traffic signal coordination. Table 5-4 provides a summary of the Opening Year (2029) Without Project and With Project traffic conditions peak hour roadway segment capacity analysis.
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51 TABLE 5-4: PEAK HOUR ROADWAY SEGMENT ANALYSIS FOR OPENING YEAR (2029) CONDITIONS As shown in Table 5-4, Santa Ana Canyon Road between Imperial Highway and Anaheim Hills Road is anticipated to operate at an unacceptable LOS in the following directions and peak hours, based on the peak hour roadway capacity thresholds and minimum LOS criteria, under Opening Year (2029) With Project conditions:
Westbound during the AM peak hour
Eastbound during the PM peak hour
Westbound during the PM peak hour
As shown in Table 5-4, the Project is anticipated to continue to increase the V/C by less than the applicable threshold identified for intersections. As such, based on criteria similar to the City’s intersection deficiency criteria, the Project-related increase in V/C is deemed not significant.
5.8.3 IMPROVEMENTS TO ADDRESS OFF-RAMP QUEUING DEFICIENCIES There are no movements anticipated to experiencing queuing issues during the weekday AM or weekday PM peak 95th percentile traffic flows under Opening Year (2029) With Project traffic conditions. As such, no improvements have been identified.
Without Project:
LOS Acceptable
# Roadway Segment Limits Peak Hour Direction Lanes Capacity1 2029 V/C2 LOS3 LOS4 1 Santa Ana Canyon Rd. Imperial Hwy. to Anaheim Hills Rd. AM EB 2 1,403 1,073 0.765 C C AM WB 2 2,301 1,837 0.798 C C
PM EB 2 2,166 1,753 0.809 D C
PM WB 2 1,231 1,122 0.911 E C
With Project:
LOS Acceptable
# Roadway Segment Limits Peak Hour Direction Lanes Capacity1 2029 V/C2 LOS3 LOS4 1 Santa Ana Canyon Rd. Imperial Hwy. to Anaheim Hills Rd. AM EB 2 1,438 1,085 0.755 C C AM WB 2 2,323 1,871 0.805 D C
PM EB 2 2,190 1,783 0.814 D C
PM WB 2 1,265 1,141 0.902 E C BOLD = LOS does not meet the applicable jurisdictional requirements (i.e., unacceptable LOS). 1 The adjusted LOS capacity is calculated based on City of Anaheim methodology for Peak Hour Roadway Segment analyses. 2 V/C = Volume to Capacity Ratio
3 LOS = Level of Service 4
The City of Anaheim roadway standard is LOS "C".
Peak Hour Direction Threshold Significant?
1 Santa Ana Canyon Rd. Imperial Hwy. to Anaheim Hills Rd. AM WB 0.030 No PM EB 0.030 No
PM WB 0.010 No
0.007
0.005
-0.010
Without Project
With Project
Project-Related Increase in v/c
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53 6 GENERAL PLAN BUILDOUT TRAFFIC CONDITIONS
This section discusses the methods used to develop General Plan Buildout traffic forecasts, and the resulting intersection operations and traffic signal warrant analyses.
6.1 ROADWAY IMPROVEMENTS
The lane configurations and traffic controls assumed to be in place for General Plan Buildout conditions are consistent with those shown previously at Exhibit 3-1, with the exception of the following:
Deer Canyon Road is assumed to be constructed to provide site access by the Hills Preserve Project. The intersection of Deer Canyon Road and Santa Ana Canyon Road (#6) is assumed to be a signalized intersection.
Other parallel facilities, that although not evaluated for the purposes of this analysis, are anticipated to be in place for General Plan Buildout traffic conditions and would affect the travel patterns within the study area.
Project driveways and those facilities assumed to be constructed by the Project to provide site access are also assumed to be in place for General Plan Buildout With Project conditions only (e.g., intersection and roadway improvements along the Project’s frontage and driveways).
6.2 GENERAL PLAN BUILDOUT WITHOUT PROJECT TRAFFIC VOLUME
FORECASTS
This scenario includes the refined post-process volumes obtained from the ATAM (see Section 4.8 General Plan Buildout Volume Development of this TA for additional discussion on the development of the long-range traffic forecasts). The weekday ADT and weekday peak hour volumes which can be expected for General Plan Buildout Without Project traffic conditions are shown at Exhibit 6-1.
6.3 GENERAL PLAN BUILDOUT WITH PROJECT TRAFFIC VOLUME FORECASTS This scenario includes the refined post-process volumes obtained from the ATAM plus traffic generated by the proposed Project. The weekday ADT and weekday peak hour volumes which can be expected for General Plan Buildout With Project traffic conditions are shown at Exhibit 6-2.
6.4 INTERSECTION OPERATIONS ANALYSIS
General Plan Buildout peak hour traffic operations have been evaluated for the study area intersections based on the analysis methodologies presented in Section 2 Methodologies of this TA.
The intersection analysis results are summarized in Table 6-1 for General Plan Buildout traffic conditions, which indicates that the study area intersections are anticipated to continue to operate at an acceptable LOS during the peak hours under General Plan Buildout Without Project and With Project traffic conditions. The intersection operations analysis worksheets for General Plan Buildout Without Project and With Project traffic conditions are included in Appendices 6.1 and 6.2, respectively.
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56 TABLE 6-1: INTERSECTION ANALYSIS FOR GENERAL PLAN BUILDOUT CONDITIONS
6.5 TRAFFIC SIGNAL WARRANTS ANALYSIS
The traffic signal warrant analysis for General Plan Buildout Without Project and With Project traffic conditions is based on the peak hour volumes or planning level ADT volume-based traffic signal warrants. There are no unsignalized study area intersections anticipated to meet a traffic signal warrant under both General Plan Buildout Without Project and With Project traffic conditions (see Appendices 6.3 and 6.4, respectively).
6.6 ROADWAY SEGMENT ANALYSIS
The roadway capacities utilized for the study area roadway segment analysis are obtained from the OCTA Guidance of Administration of the Orange County MPAH and the County of Orange TIM. These roadway segment capacities are approximate figures only and are used to assist in determining the roadway functional classification (number of through lanes) needed to meet traffic demand. Table 6- 2 provides a summary of the General Plan Buildout Without Project and With Project traffic conditions roadway segment capacity analysis. As shown in Table 6-2, the following study area roadway segments are anticipated to operate at an unacceptable LOS based on the daily roadway capacity thresholds and minimum LOS criteria under both General Plan Buildout Without Project and With Project traffic conditions:
Santa Ana Canyon Road, from Imperial Highway to Anaheim Hills Road (#1) – LOS D Santa Ana Canyon Road, from Anaheim Hills Road to Fairmont Boulevard (#2) – LOS D Level of Level of
Evaluation Service Service
Methodology AM PM AM PM AM PM AM PM AM PM
1 Imperial Hwy. & SR-91 WB Ramps TS HCM 19.3 11.7 B B 19.3 11.8 B B -- -- ICU 0.788 0.612 C B 0.789 0.612 C B 0.001 0.000
2 Imperial Hwy. & SR-91 EB Ramps TS HCM 17.0 14.2 B B 17.1 14.4 B B -- -- ICU 0.655 0.626 B B 0.657 0.630 B B 0.002 0.004
3 Imperial Hwy. & Santa Ana Canyon Rd. TS ICU 0.753 0.831 C D 0.757 0.840 C D 0.004 0.009 4 Anaheim Hills Rd. & Santa Ana Canyon Rd. TS ICU 0.708 0.808 C D 0.718 0.817 C D 0.004 0.009 5 Fairmont Bl. & Santa Ana Canyon Rd. TS ICU 0.616 0.625 B B 0.626 0.634 B B 0.010 0.009 6 Deer Canyon Rd. & Santa Ana Canyon Rd. TS ICU 0.416 0.643 A B 0.420 0.652 A B 0.004 0.009 7 Festival Dr. & Santa Ana Canyon Rd. TS ICU 0.243 0.420 A A 0.255 0.427 A A 0.012 0.007 8 Festival Dr. & Driveway 1 CSS HCM 10.7 12.9 B B 11.0 13.6 B B -- -- 9 Driveway 2 & Festival Dr. CSS HCM 10.3 11.6 B B -- -- 10 Festival Center Dwy. & Santa Ana Canyon Rd. TS ICU 0.238 0.450 A A 0.239 0.450 A A 0.001 0.000 11 Roosevelt Rd. & Santa Ana Canyon Rd. TS ICU 0.376 0.598 A A 0.394 0.609 A B 0.018 0.011 12 Roosevelt Rd. & Festival Dr./Monte Vista Rd. TS ICU 0.229 0.312 A A 0.262 0.336 A A 0.033 0.024 13 Weir Canyon Rd. & SR-91 WB Ramps TS HCM 10.0 13.1 A B 10.1 13.4 B B -- -- ICU 0.539 0.666 A B 0.541 0.671 A B 0.002 0.005
14 Weir Canyon Rd. & SR-91 EB Ramps TS HCM 13.4 7.6 B A 13.7 7.8 B A -- -- ICU 0.618 0.556 B A 0.624 0.565 B A 0.006 0.009
15 Weir Canyon Rd. & Santa Ana Canyon Rd. TS ICU 0.622 0.860 B D 0.632 0.866 B D 0.010 0.006 16 Weir Canyon Rd. & Monte Vista Rd. TS ICU 0.443 0.550 A A 0.446 0.548 A A 0.003 -0.002 1 2 3
TS = Traffic Signal; CSS = Cross-street Stop; TS = Improvement # Intersection
Traffic
Control 3 General Plan Buildout
Without Project
General Plan Buildout
With Project
ProjectRelated
Increase in
V/C
Delay1
(secs.) Delay1 (secs.)
ICU (v/c)2
ICU (v/c)2
Future Intersection
Per the Highway Capacity Manual (7th Edition), overall average intersection delay and level of service are shown for intersections with a traffic signal or all way stop control. For intersections with cross street stop control, the delay and level of service for the worst individual movement (or movements sharing a single lane) are shown. HCM delay reported in seconds. All signalized intersections are evaluated utilizing Intersection Capacity Utilization (ICU) methodology, reported as a volume-to-capacity ratio. For intersections with all way or cross street stop control, the HCM delay and level of service for the worst individual movement (or movements sharing a single lane) are shown. Signalized intersections within Caltrans jurisdiction will be evalutaed utilizing both HCM and ICU methodology. 56 Anaheim Hills Festival SPA No. 6 Traffic Analysis
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58 6.7 OFF-RAMP QUEUING ANALYSIS
Queuing analysis findings for General Plan Buildout Without Project and With Project are presented in Table 6-3. As shown in Table 6-3, there are no movements that are anticipated to experience queuing issues during the weekday AM or weekday PM peak 95th percentile traffic flows under both the General Plan Buildout Without Project and With Project traffic conditions. Worksheets for General Plan Buildout Without Project and With Project traffic conditions queuing analysis are provided in Appendices 6.5 and 6.6, respectively.
TABLE 6-3: PEAK HOUR QUEUING SUMMARY FOR GENERAL PLAN BUILDOUT CONDITIONS
6.8 DEFICIENCIES AND IMPROVEMENTS
Improvement strategies have been recommended at intersections that have been identified as deficient under General Plan Buildout With Project traffic conditions in an effort to achieve an acceptable LOS.
6.8.1 IMPROVEMENTS TO ADDRESS DEFICIENCIES AT INTERSECTIONS As previously shown in Table 6-1, all study area intersections are anticipated to continue to operate at an acceptable LOS during the AM and PM peak hours under General Plan Buildout With Project traffic conditions. As such, no improvements, aside from those that are needed to facilitate site access, have been identified.
# Intersection AM PM AM PM
1 Imperial Hwy. & SR-91 WB Ramps WBL 1,280 457 302 Yes Yes 457 302 Yes Yes WBR 495 617 2,3 369 Yes Yes 617 2,3 369 Yes Yes
2 Imperial Hwy. & SR-91 EB Ramps EBL 2,365 397 357 Yes Yes 403 366 Yes Yes EBR 510 496 434 Yes Yes 493 436 Yes Yes
13 Weir Canyon Rd. & SR-91 WB Ramps WBL 1,580 258 384 Yes Yes 262 391 Yes Yes WBR 350 309 461 3
Yes Yes 312 461 3Yes Yes
14 Weir Canyon Rd. & SR-91 EB Ramps EBL 1,740 379 184 Yes Yes 380 187 Yes Yes EBR 225 442 3
260 3Yes Yes 447 3267 3Yes Yes 2
95th percentile volume exceeds capacity, queue may be longer. Queue shown is maximum after two cycles. 1 Stacking Distance is acceptable if the required stacking distance is less than or equal to the stacking distance provided. An additional 25 feet of stacking which is assumed to be provided in the transition for turn pockets is reflected in the stacking distance shown on this table, where applicable. 3 Although 95th percentile queue is anticipated to exceed the available storage for the turn lane, the adjacent through lane has sufficient storage to accommodate any spillover without spilling back and affecting the I-215 Freeway mainline.
Without Project With Project
Movement
Available
Stacking
Distance (Feet)
95th Percentile
Queue (Feet) Acceptable? 1 95th Percentile
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59 6.8.2 IMPROVEMENTS TO ADDRESS DEFICIENCIES AT ROADWAY SEGMENTS As shown in Table 6-2, Santa Ana Canyon Road, from Imperial Highway to Anaheim Hills Road and from Anaheim Hills Road to Fairmont Boulevard, is anticipated to operate at an unacceptable LOS based on the daily roadway capacity thresholds and minimum LOS criteria under General Plan Buildout With Project traffic conditions. The high volume of through vehicles is attributable to vehicles bypassing the SR-91 Freeway during peak commute hours throughout the day. Introducing additional lanes along Santa Ana Canyon Road would encourage more vehicles to utilize this roadway segment and would be counterintuitive to the State’s goals with regards to Vehicle Miles Traveled. Roadway widening is also infeasible due to right-of-way limitations and is inconsistent with the City’s General Plan.
The City of Anaheim lacks specific criteria to determine a significant project impact on roadway segments. However, based on criteria similar to the City’s intersection deficiency criteria, the Projectrelated increase in V/C is deemed not significant. The Project is anticipated to increase the V/C by less than 0.01 (1.0%) at each deficient segment, which is less than the threshold of 0.030 (3.0%) identified for intersections anticipated to operate at LOS D under pre-Project conditions. Additionally, the intersections on both ends of the roadway segments are anticipated to operate at an acceptable LOS (LOS D or better) suggesting that the additional capacity accommodated through turn lanes at the choke-points of the roadway segments (e.g., intersections) can sufficiently handle the anticipated future traffic.
At the City’s request, additional peak hour roadway segment analysis was conducted for the deficient roadway segments to determine whether or not there is a project impact at the respective roadway segment. The peak hour roadway segment analysis utilizes an adjusted segment capacity for each direction of the applicable roadway segment by multiplying the mid-block number of lanes in the applicable direction by a lane capacity of 1,900 vehicles per hour, then multiplied by the AM and PM peak hour V/C ratios percentage of green time at the controlling signalized intersections. This methodology is utilized to determine if congestion on a street segment is due to a lack of capacity or if traffic flows are affected by traffic signal coordination. Table 6-4 provides a summary of the General Plan Buildout Without Project and With Project traffic conditions peak hour roadway segment capacity analysis.
As shown in Table 6-4, Santa Ana Canyon Road between Imperial Highway and Anaheim Hills Road is anticipated to operate at an unacceptable LOS in the following directions and peak hours, based on the peak hour roadway capacity thresholds and minimum LOS criteria, under General Plan Buildout With Project conditions:
Westbound during the AM peak hour
Eastbound during the PM peak hour
Westbound during the PM peak hour
As shown in Table 6-4, the Project is anticipated to continue to increase the V/C by less than the applicable threshold identified for intersections. As such, based on criteria similar to the City’s intersection deficiency criteria, the Project-related increase in V/C is deemed not significant. 59 Anaheim Hills Festival SPA No. 6 Traffic Analysis
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60 TABLE 6-4: PEAK HOUR ROADWAY SEGMENT ANALYSIS FOR GENERAL PLAN BUILDOUT
CONDITIONS
6.8.3 IMPROVEMENTS TO ADDRESS OFF-RAMP QUEUING DEFICIENCIES There are no movements anticipated to experiencing queuing issues during the weekday AM or weekday PM peak 95th percentile traffic flows under General Plan Buildout With Project traffic conditions. As such, no improvements have been identified.
Without Project:
LOS Acceptable
# Roadway Segment Limits Peak Hour Direction Lanes Capacity1 GPBO V/C2 LOS3 LOS4 1 Santa Ana Canyon Rd. Imperial Hwy. to Anaheim Hills Rd. AM EB 2 1,449 1,127 0.778 C C AM WB 2 2,308 1,929 0.836 D C
PM EB 2 2,163 1,840 0.851 D C
PM WB 2 1,223 1,178 0.963 E C
2 Santa Ana Canyon Rd. Anaheim Hills Rd. to Fairmont Bl. AM EB 2 1,604 1,101 0.687 B C AM WB 2 2,097 1,610 0.767 C C
PM EB 2 2,614 1,828 0.699 B C
PM WB 2 1,520 1,065 0.700 B C
With Project:
LOS Acceptable
# Roadway Segment Limits Peak Hour Direction Lanes Capacity1 GPBO V/C2 LOS3 LOS4 1 Santa Ana Canyon Rd. Imperial Hwy. to Anaheim Hills Rd. AM EB 2 1,429 1,139 0.797 C C AM WB 2 2,329 1,963 0.843 D C
PM EB 2 2,186 1,870 0.856 D C
PM WB 2 1,256 1,197 0.953 E C
2 Santa Ana Canyon Rd. Anaheim Hills Rd. to Fairmont Bl. AM EB 2 1,578 1,113 0.705 B C AM WB 2 2,329 1,709 0.734 C C
PM EB 2 2,577 1,858 0.721 C C
PM WB 2 1,498 1,084 0.723 C C BOLD = LOS does not meet the applicable jurisdictional requirements (i.e., unacceptable LOS). 1 The volumes shown are based on the lane capacities per the City of Anaheim's guidelines. 2 V/C = Volume to Capacity Ratio
3 LOS = Level of Service 4
The City of Anaheim roadway standard is LOS "C".
Peak Hour Direction Threshold Significant?
1 Santa Ana Canyon Rd. Imperial Hwy. to Anaheim Hills Rd. AM WB 0.030 No PM EB 0.030 No
PM WB 0.010 No
Project-Related Increase in v/c
0.007
0.005
-0.010
Without Project
With Project
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61 7 LOCAL AND REGIONAL FUNDING MECHANISMS
Transportation improvements within the City of Anaheim are funded through a combination of construction of improvements, development impact fee programs or fair share contributions, such as the City of Anaheim Transportation Impact and Improvement Fee (TIIF) program. Identification and timing of needed improvements is generally determined through local jurisdictions based upon a variety of factors.
7.1 CITY OF ANAHEIM TRANSPORTATION IMPACT AND IMPROVEMENT FEE
PROGRAM
The Project will be subject to City of Anaheim’s TIIF program which includes a component for streets, traffic signals, and bridges. This program aims to mitigate the additional traffic burdens created by new development to the City’s arterial and collector street system. A transportation fee will be imposed on all new development in the City to finance the costs of street improvements, including widening and reconstruction, new traffic signals, street landscaping, intersection improvements, and freeway interchange improvements.
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63 8 REFERENCES
1. City of Anaheim. Criteria for Preparation of Traffic Impact Studies. City of Anaheim : s.n.
2. Institute of Transportation Engineers. Trip Generation Manual. 11th Edition. 2021.
3. Orange County Transportation Commission. 2021 Orange County Congestion Management Program. County of Orange : s.n., November 2021.
4. Husch, David and Albeck, John. Intersection Capacity Utilization: Evaluation Procedures for Intersections and Interchanges. Albany, California : Trafficware, 2003 Edition.
5. Transportation Research Board. Highway Capacity Manual (HCM). 6th Edition. Washington, D.C. :
National Academy of Sciences, 2016. 978-0-309-16077-3.
6. —. Highway Capacity Manual (HCM). 6th Edition. s.l. : National Academy of Sciences, 2016.
7. California Department of Transportation. California Manual on Uniform Traffic Control Devices (CA MUTCD). [book auth.] California Department of Transportation. California Manual on Uniform Traffic Control Devices (CA MUTCD). 2014, Updated March 30, 2021 (Revision 6).
8. Agency, Orange County Transit. Guidance for Administration of the Orange County Master Plan of Arterial Highways. County of Orange : s.n., August 14, 2017.
9. County of Orange. Transportation Implementation Manual. County of Orange : s.n., September 2021.
10. City of Anaheim. City of Anaheim General Plan. City of Anaheim : s.n., May 2004.
11. California Department of Transportation. Guide for the Preparation of Traffic Impact Studies.
December 2002.
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15699-08A TA Report
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64 APPENDIX
DATE: December 23, 2024; Revised August 7, 2025
TO: Cory Wilkerson, City of Anaheim
FROM: Alex So, Urban Crossroads, Inc.
JOB NO: 15699-05 VMT
ANAHEIM HILLS FESTIVAL SPECIFIC PLAN AMENDMENT NO. 6
VEHICLE MILES TRAVELED (VMT) ANALYSIS
Urban Crossroads, Inc. has completed the following Vehicle Miles Traveled (VMT) Analysis for Anaheim Hills Festival Specific Plan Amendment No. 6 (Project), which is located south of Santa Ana Canyon Road and west of Roosevelt Road in the City of Anaheim.
AUGUST 7, 2025 REVISIONS
The revisions included on August 7, 2025, were prepared in response to the California Department of Transportation (Caltrans) comment letter dated August 4, 2025. These revisions consist of typographical edits and clarifications to the sections titled Orange County Baseline VMT per SP and Project Design Features – VMT Reductions; T1 – Increase Residential Density. PROJECT OVERVIEW The existing Specific Plan is divided into four Development Areas (DA) by land use.
DA 1 is the Scenic Commercial area fronting Santa Ana Canyon Road between Festival Drive and Roosevelt Road, DA 2 is the Regional Commercial use that contains the department stores, grocery, other food/retail uses, and the vacant cinema, DA 3 is the Visitor Commercial area located west of Festival Drive which includes the existing hotel, and DA 4 is the Senior Residential area south of Festival Drive. The Specific Plan Amendment (SPA) proposes the implementation of a new
16.2-acre mixed-use development area on the upper level of the commercial center as a new DA 5 (which is a portion of the old DA 2).
Specifically, the Project proposes to demolish the existing 62,676-square-foot vacant cinema and develop in its place 447 multi-family residential dwelling units while retaining the remaining existing commercial uses within the new DA 5.
Approximately 13,310 square feet of existing retail would be retained in DA 2 as a result of the new DA 5 (resulting in a net reduction of 49,366 square feet of retail space). The retail within DA 5 will include the following existing uses: 6,475 square feet of restaurant use, 9,200 square feet of office use, 38,160-square-foot fitness/gym, 13,276 square feet of tutor/retail space, and 11,033-square-foot Cory Wilkerson, City of Anaheim
August 7, 2025