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:
x Provide a clear and enforceable mechanism for monitoring and verifying the implementation of mitigation measures identified in the EIR; x Ensure that mitigation measures are incorporated into the design, permitting, construction, and operation phases of the Project as applicable; x Assign responsibilities for monitoring;
x Document compliance through written verification and record-keeping; and x 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:
x Mitigation Measures (MMs): Measures adopted to reduce or avoid significant environmental impacts to a less-than-significant level under CEQA.
x 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. x 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:
x Measure Number and Title (e.g., MM BIO-1, RCM AQ-1, PDF HAZ-2) and the full text of the requirement;
x Implementation Timing indicating when the commitment must be implemented; x Responsible for Monitoring indicating the responsible parties for verification; x 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
x 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.
x 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.
x 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.
x All on-site roads will be paved as soon as feasible or watered periodically or chemically stabilized.
x 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
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Date Initials
x The area disturbed by clearing, grading, earthmoving, or excavation operations will be minimized at all times
x 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.
x 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
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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
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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
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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
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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/D eveloper 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
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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
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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
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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.