Anaheim City Council
March 3, 2026

Anaheim Hills Festival Specific Plan Amendment Project Findings of Fact

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FINDINGS OF FACT IN SUPPORT OF A

STATEMENT OF OVERRIDING CONSIDERATIONS FOR THE

ANAHEIM HILLS FESTIVAL SPECIFIC PLAN AMENDMENT PROJECT

ENVIRONMENTAL IMPACT REPORT
STATE CLEARINGHOUSE NO. 2024010859
Section 1: Introduction
This Findings of Fact ( “Findings”) addresses the significant environmental effects associated with the Anaheim Hills Festival Specific Plan Amendment Project (Project), as evaluated in the certified Final Environmental Impact Report ( “Final EIR”) (State Clearinghouse No. 2024010859) . These Findings are made by the City of Anaheim (“City”) in its capacity as lead agency under the California Environmental Quality Act (CEQA) (Public Resources Code [PRC] § 21000 et seq.) and the State CEQA Guidelines (14 California Code of Regulations [CCR] § 15000 et seq.), specifically §§ 15091, 15093, 21081, 21081.5, and 21081.6.

The Final EIR evaluates the potential environmental effects of the Project , identifies feasible mitigation measures to reduce significant effects, and analyzes project alternatives. In adopting these Findings, the City also adopts the Mitigation Monitoring Program (“MM P”), which ensures implementation of the mitigation measures consistent with PRC §21081.6.

1.1 Project Summary
As defined by the State CEQA Guidelines §15378(a), the Project is a discretionary action undertaken by a public agency with potential to cause a direct or reasonably foreseeable indirect physical change in the environment. The Project would amend the Anaheim Hills Festival Specific Plan to create a new Development Area (“DA 5") within the existing Specific Plan boundaries to allow for the development of residential uses mixed in with the existing commercial development. The newly created area is referred to as DA 5. As part of the Project, DA 5 would be created by reducing DA 2 from 48 to 31.8 acres. The net reduction of 16.2 acres from DA 2 would be used to create DA 5. The development that would occur as part of the Project would be limited to DA 5, which includes the following APNs: 354-451-19 and -32. The existing Specific Plan’s exterior boundary area would not change. The proposed DA 5 is referred to as the proposed development area.

As part of the Project’s requested entitlements, a General Plan Amendment and Specific Plan Amendment would be required to allow for the proposed residential uses and the creation of the new DA 5. The General Plan Amendment would change the land use designation within DA 5 from Regional Commercial to Mixed-Use Medium. The Mixed -Use Medium land use designation is intended to allow flexibility for parcels that could transition from strip commercial uses to residential or a mix of residential, commercial, and office development. This land use designation allows residential development in either a stand-alone or mixed-use configuration at a density of up to 36 du/acre. The non-residential component of mixed-use development is permitted at a maximum FAR of 0.35. The Specific Plan Amendment would be required to amend the current Specific Plan to allow for mixed-use land uses on a total of 16.2 acres (DA 5) and would include other clarifying text amendments related to signage, permitted uses, and development standards.

The Specific Plan would be amended and restated through the code provisions of Anaheim Municipal Code Chapter 18.72, Specific Plans. Anaheim Municipal Code Chapter Section 18.72.040, Procedures, states that any amendments to specific plans shall be conduct ed in the same manner as zoning Anaheim Hills Festival Specific Plan Amendment Project Findings of Fact

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classifications under Chapter 18.76, Zoning Amendments. In addition, the Specific Plan Amendment would update Anaheim Municipal Code Section 18.108, Festival Specific Plan, to incorporate the proposed residential standards into DA 5 and other clarifying changes referenced above in relation to signage, permitted uses, and development standards.

1.2 Project Objectives
State CEQA Guidelines §15124(b) requires “a statement of objectives sought by the proposed project. A clearly written statement of objectives would help the lead agency develop a reasonable range of alternatives to evaluate in the EIR and aid the decision -makers in preparing findings or a statement of overriding considerations, if necessary. The statement of objectives should include the underlying purpose of the project.”
The underlying purpose of the Project is to increase the availability of housing units in the City of Anaheim.

The specific objectives of the Project are to:
• Transform the Project site into a visually attractive and safe environment. • Increase the City’s housing inventory and provide new housing opportunities for existing and future City residents in a mixed-use setting.
• Assist the City in meeting its Regional Housing Needs Assessment (RHNA) for the 2021 -2029 Housing Element cycle.
• Establish a “sense of place” through the design of the Project site, creating a design that is sensitive to the natural environment, compatible with the surrounding urbanizing area, and consistent with the requirements of the City’s Scenic Corridor Overlay Zone. • Build a residential community with robust amenities that promote healthy engagement among its residents and other site users.
• Provide landscaping that is appropriate to the level of development and that is sensitive to surrounding areas.
• Develop a high -quality architectural design shaped by Southern California's contextual and regional vernacular.
• Provide affordable housing options for existing and future residents of the City.

1.3 Purpose and Legal Requirements
Pursuant to State CEQA Guidelines § 15091, no agency may approve a project with significant environmental effects identified in an EIR unless it makes one or more of the following written findings, supported by substantial evidence in the record:

1. Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect as identified in the final EIR. [referred to in these Findings as “Finding 1”].

2. Such changes or alterations are within the responsibility and jurisdiction of another public agency and not the agency making the finding. Such changes have been adopted by such other agency or can and should be adopted by such other agency. [referred to in these Findings as “Finding 2”].

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3. Specific economic, legal, social, technological, or other considerations, including provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or project alternatives identified in the final EIR. [referred to in these Findings as “Finding 3”].

When significant effects cannot be reduced to less than significant, State CEQA Guidelines § 15093 requires the agency to adopt a Statement of Overriding Considerations (“SOC”), balancing the project’s benefits against its unavoidable adverse environmental effects. If the benefits outweigh the adverse effects, those effects may be deemed acceptable.

1.4 Records of Proceedings
The record of proceedings for the Project includes all documents and materials described in PRC §21167.6(e) and maintained by the City of Anaheim Planning and Building Department, including but not limited to:
 The Notice of Preparation, Notice of Availability, and all other public notices issued by the City in conjunction with the Project.
 All written comments submitted by agencies, organizations, or members of the public during the NOP public review comment period, inclusive of the Scoping Meeting  The Draft EIR for the Project and all technical appendices, technical memoranda, and documents relied upon or incorporated by reference.
 All written comments submitted by agencies, organizations, or members of the public review comment period on the Draft EIR and the City’s responses to those comments, including related referenced technical materials
 The EIR for the Project
 The MMP for the Project
 All reports, studies, memoranda, maps, staff reports, or other planning documents relating to the Project prepared by the City or consultants to the City with respect to the City’s compliance with the requirements of CEQA and with respect to the City’s action on the Project.  All documents submitted to the City by other public agencies or members of the public in connection with the Program EIR
 Any minutes and/or verbatim transcripts of all information sessions, public meetings, and public hearings held by the City in connection with the Project.  Any documentary or other evidence submitted to the City at such information sessions, public meetings, and public hearings.
 All resolutions adopted by the City regarding the Project, and all staff reports, analyses, and summaries related to the adoption of those resolutions.  Matters of common knowledge to the City, including, but not limited to, federal, State, and local laws and regulations.
 Any documents expressly cited in these Findings, in addition to those cited above, and any other materials required for the record of proceedings by PRC Section 21167.6(e) Anaheim Hills Festival Specific Plan Amendment Project Findings of Fact

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The official record is available at the City of Anaheim Planning and Building Department – 200 S. Anaheim Boulevard, Anaheim, CA 92805.

1.5 Independent Judgment
Pursuant to PRC §21082.1( c), the City affirms that the EIR and these Findings reflect its independent judgment as the lead agency. The City has reviewed and considered the Draft and Final EIR, the MMP, the comments received during the public review, and all other information in the administrative record prior to certifying the Final EIR and approving the Project.

The City finds that the Final EIR constitutes a complete, accurate, and adequate disclosure of the environmental effects of the Project in compliance with CEQA and the State CEQA Guidelines.

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Section 2: Environmental Impacts Found to Have No Impact As documented in the Notice of Preparation circulated between January 29, 2024, and February 28, 2024, and confirmed in the Draft and Final EIR, the City determined that the Project would have no impact on certain environmental topics under the CEQA thresholds of significance. Based on the EIR’s analysis and all comments received during public review, no substantial evidence has been presented demonstrating that the Project would result in an impact in the areas listed below. The conclusions are supported by substantial evidence in the administrative record.

Agricultural and Forestry
“Would the P roject convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non- agricultural use?”
“Would the Project conflict with existing zoning for agricultural use, or a Williamson Act contract?”
“Would the Project conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g))?”
“Would the Project result in the loss of forest land or conversion of forest land to non - forest use?”
“Would the P roject involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to non-forest use?”
Basis for Conclusion: There is no Prime Farmland, Unique Farmland, Farmland of Statewide Importance, or Farmland of Local Importance on the Project site or in its vicinity. The Project site is zoned SP 90 -1 (Anaheim Hills Festival Specific Plan), which does not allow for agricultural land uses , and no Williamson Act contracts apply. No forest land, timberland, or timberland zoned for production is present. Therefore, the Project would not result in the conversion of farmland or forest land to other uses. No impact would occur.

Biological Resources
“Would the Project conflict with the provisions of an adopted Habitat Conservation Plan (HCP), Natural Community Conservation Plan (NCCP), or other approved local, regional, or State habitat conservation plan?”
Basis for Conclusion: The Project would conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or State habitat conservation plan; thus, no impact would occur.

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Cultural Resources
“Would the Project cause a substantial adverse change in the significance of a historical resource pursuant to §15064.5?”
Basis for Conclusion: No historical resources are present on the Project site; therefore, the Project would not cause a substantial adverse change in the significance of a historical resource pursuant to §15064.5, and no impact would occur.

Geology and Soils
“Would the Project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:
i) Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault?”
Basis for Conclusion: The Project site is not located within an Alquist-Priolo Earthquake Fault Zone or on a known active fault. Therefore, the Project would not directly or indirectly cause potential substantial adverse effects involving rupture of a known earthquake fault. No impact would occur. “Would the Project have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater?”
Basis for conclusion: The Project would connect to existing sewer infrastructure and would not use septic tanks. No impact would occur.

Hazards and Hazardous Materials
“Would the project be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code §65962.5 and, as a result, would it create a significant hazard to the public or the environment?” Basis for Conclusion: The Project site is not listed a list of hazardous materials sites compiled pursuant to Government Code §65962.5. Therefore, the Project would not create a significant hazard to the public or the environment as a result of being located on a listed hazardous materials site. No impact would occur. “For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area?” Basis for conclusion: The Project site is not located within an airport land use plan or within two miles of a public airport or public use airport. Therefore, the Project would not result in a safety hazard or expose people residing or working in the Project area to excessive noise associated with airport operations. No impact would occur.

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Hydrology and Water Quality
“Would the Project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would:
ii) Substantially increase the rate or amount of surface run-off in a manner which would result in flooding on- or off-site?
Basis for conclusion: The Project would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner that would substantially increase the rate or amount of surface runoff in a manner that would result in flooding on- or off-site. No impact would occur. iii) Create or contribute run-off water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted run-off? Basis for conclusion: The Project would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner that would create or contribute run-off water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted water. No impact would occur.
iv) Impede or redirect flood flows?
Basis for conclusion: The Project would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner that would impede or redirect flood flows. No impact would occur. “Would the Project in flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?”
Basis for conclusion: The Project site is not located within a mapped flood hazard, tsunami, or seiche zone and therefore would not risk the release of pollutants due to inundation; thus, no impact would occur.

Land Use and Planning
“Would the Project physically divide an established community?” Basis for Conclusion: The Project would not physically divide an established community; thus, there is no significant impact.

Mineral Resources
“Would the project result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state”? “Would the project result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan?”
Basis for conclusion: T he Project would not result in the loss of availability of any mineral resource or displace active mineral extraction activities. No impact would occur.

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Noise
“For or a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in th e project area to excessive noise levels?”
Basis for conclusion: The Project site is not located within the vicinity of a private airstrip or an airport land use plan, or within two miles of a public airport or public use airport. Therefore, the Project would not expose people residing or working in the Project area to excessive noise levels associated with airport operations. No impact would occur.

Population and Housing
“Would the Project displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?” Basis for conclusion: The Project would not displace existing people or housing or necessitate the construction of replacement housing elsewhere; thus, no impact would occur.

Recreation
“Does the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment?”
Basis for conclusion: The Project would include the development of recreational amenities within the Project site . Potential impacts from these amenities have been addressed in the topical analyses presented in the EIR . The Project would be required to pay applicable park dedication fees in accordance with the Anaheim Municipal Code in lieu of land dedication. Any future off- site park development undertaken by the City, including projects partially funded through the Project’s development fees, would be a separate project subject to its own environmental review pursuant to the CEQA. The Project would not require the expansion of other public recreational facilities that could result in adverse physical environmental effects. No impact would occur.

Tribal Cultural Resources
“Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in PRC §21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
i) Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in PRC §5020.1(k)?” Basis for conclusion: The Project would not cause a substantial adverse change in the significance of a tribal cultural resource, as defined in PRC §21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is listed or Anaheim Hills Festival Specific Plan Amendment Project Findings of Fact

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eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in PRC §5020.1(k); thus, no impact would occur.

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Section 3: Environmental Impacts Found to be Less Than Significant (No Mitigation Required)
As documented in the EIR, the City determined, based upon the applicable CEQA threshold of significance, that the Project would result in a less than significant impact on the following potential environmental effects. No mitigation measures are required related to these environmental issue areas.

Where a potential impact can be reduced to less than significant solely through compliance with applicable regulations, ordinances, and standard conditions of approval, such measures are considered incorporated into the Project and are relied upon to avoid or substantially lessen the potential effect.

Based upon the analysis in the EIR and comments received during public review, no substantial evidence was submitted to or identified by the City demonstrating that the Project would result in a significant impact on the following environmental issue areas evaluated in the EIR.

Aesthetics
“Would the Project have a substantial adverse effect on a scenic vista?” Basis for Conclusion: The Project would not result in a substantial adverse effect on a scenic vista; thus, there is no significant impact.
“Would the project substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway?” Basis for Conclusion: The Project would not result in substantial damage to any scenic resources; thus, there is no significant impact.
“If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality?”
Basis for consideration : The Project would not conflict with applicable zoning and other regulations governing scenic quality; thus, there is no significant impact. “Would the project create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?”
Basis for consideration : The Project would not create a new source of substantial light or glare which would adversely affect day or nighttime views in the area; thus, there is no significant impact.

Air Quality
“Would the Project conflict with or obstruct implementation of the applicable air quality plan?”
Basis for Conclusion: The Project would not conflict with the South Coast Air Quality Management District 2016 and 2022 Air Quality Management Plans (AQMPs); thus, there is no significant impact. “Would the Project result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non -attainment under an applicable federal or state ambient air quality standard?”
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Basis for Conclusion : The Project would not result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non -attainment under an applicable federal or state ambient air quality standard; thus, there is no significant impact.

Biological Resources
“Would the Project have a substantial effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service?” Basis for Conclusion: The Project would not have a substantial effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service; thus, there is no significant impact. “Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service?” “Would the project have a substantial adverse effect on a State or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?” Basis for Conclusion: The Project would not have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service nor would it have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service; thus, there is no significant impact.
“Would the project interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites?”
Basis for consideration: The Project would not interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites; thus, there is not significant impact. “Would the project conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?” Basis for consideration: The Project would not result in any substantial conflicts related to applicable local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance ; thus, there is no significant impact.

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Cultural Resources
“Would the Project disturb any human remains, including those interred outside of dedicated cemeteries?”
Basis for Conclusion: The Project would not disturb any human remains, including those interred outside of dedicated cemeteries; thus, there is no significant impact.

Energy
“Would the Project result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during Project construction or operation?”
Basis for Conclusion: The Project would not result in a potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during Project construction or operation; thus, there is no significant impact.
“Would the Project conflict with or obstruct a State or Local plan for renewable energy or energy efficiency?”
Basis for Conclusion: The Project would not result in any substantial conflicts with any applicable state or local plans for renewable energy or energy efficiency; thus, there is no significant impact.

Geology and Soils
“Would the Project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:
iv) landslides”
Basis for Conclusion : The Project would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving landslides; thus, there is no significant impact. “Would the Project result in substantial soil erosion or the loss of topsoil?” Basis for Conclusion: The Project would not result in substantial soil erosion or the loss of topsoil; thus, there is no significant impact.

Greenhouse Gas Emissions
“Would the Project generate GHG emissions, either directly or indirectly, that could have a significant impact on the environment?”
Basis for conclusion: The Project would not generate GHG emissions, either directly or indirectly, that could have a significant impact on the environment; thus, there is no significant impact. “Would the Project conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases?” Basis for consideration: The Project would have a less than significant impact related to the potential to conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases; thus, there is no significant impact.

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Hazards and Hazardous Materials
“Would the Project create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials?” Basis for Conclusion: The Project would not create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials; thus, there is no significant impact. “Would the Project create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?”
Basis for Conclusion: The Project would not create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment; thus, there is no significant impact. “Would the Project emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one -quarter mile of an existing or proposed school?”
Basis for Conclusion : The Project would not Project emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one -quarter mile of an existing or proposed school; thus, there is not significant impact.
“Would the project expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires?” Basis for Conclusion: The Project would not expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires; thus, there is not significant impact.

Hydrology and Water Quality
“Would the Project violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality?” Basis for Conclusion : The Project would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality; thus, there is no significant impact.
“Would the Project substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the Project may impede sustainable groundwater management of the basin?”
Basis for Conclusion : The Project would not substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the Project may impede sustainable groundwater management of the basin; thus, there is no significant impact. “Would the Project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would result in substantial erosion or siltation on- or off-site?”
Basis for Conclusion: The Project would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of Anaheim Hills Festival Specific Plan Amendment Project Findings of Fact

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impervious surfaces, in a manner which would result in substantial erosion or siltation on- or off-site; thus, there is no significant impact.
“Would the Project conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?”
Basis for Conclusion: The Project would not conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan; thus, there is no significant impact.

Land Use and Planning
“Would the Project cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect?”
Basis for Conclusion : The Project would not cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect; thus, there is no significant impact.

Noise
“Would the Project result in the generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies?” Basis for Conclusion: The Project would not result in the generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies ; thus, there is no significant impact.
“Generation of excessive ground-borne vibration or ground-borne noise levels?” Basis for Conclusion: The Project would not generate excessive ground-borne vibration or ground-borne noise levels; thus, there is no significant impact.

Population and Housing
“Would the Project induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?” Basis for Conclusion: The Project would not directly or indirectly induce substantial unplanned population growth in an area; thus, there is no significant impact.

Public Services
“Would the Project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant Anaheim Hills Festival Specific Plan Amendment Project Findings of Fact

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environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:
i) fire protection?
Basis for Conclusion: The Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for fire protection services; thus, there is no significant impact.
ii) police protection?
Basis for Conclusion: The Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for police protection services; thus, there is no significant impact. iii) schools?
Basis for Conclusion: The Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for schools ; thus, there is no significant impact.
iv) parks?
Basis for Conclusion: The Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for parks; thus, there is no significant impact.
v) other public facilities?”
Basis for Conclusion: The Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for other public services; thus, there is no significant impact.

Recreation
“Would the Project increase the use of existing neighborhood, community and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated?”
Basis for Conclusion: The Project would not result in an increase in the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated; thus, there is no significant impact.

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Transportation
“Would the Project conflict with a program, plan, ordinance , or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities?” Basis for Conclusion: The Project would not conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities ; thus, there is no significant impact.
“Would the P roject substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)?”
Basis for conclusion: The Project would not substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment); thus, there is no significant impact.

Utilities and Service Systems
“Would the Project require or result in the relocation or construction of new or expanded water, wastewater treatment, or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could caus e significant environmental effects?”
Basis for Conclusion: The Project would not require or result in the relocation or construction of new or expanded water, wastewater treatment, or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects; thus, there is no significant impact. “Would the Project have sufficient water supplies available to serve the Project and reasonably foreseeable future development during normal, dry, and multiple dry years?”
Basis for Conclusion: The Project would have sufficient water supplies available to serve the Project and reasonably foreseeable future development during normal, dry, and multiple dry years; thus, there is no significant impact.
“Would the Project result in a determination by the wastewater treatment provider, which serves or may serve the Project, that it has adequate capacity to serve the Project’s projected demand in addition to the provider’s existing commitments?” Basis for Conclusion : The Project would not result in a determination by the wastewater treatment provider, which serves or may serve the Project, that it has adequate capacity to serve the Project’s projected demand in addition to the provider’s existing commitments; thus, there is no significant impact. “Would the Project generate solid waste in excess of state or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?”
Basis for Conclusion: The Project would not generate solid waste in excess of state or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals; thus, there is no significant impact.

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“Would the Project comply with federal, state, and local management and reduction statutes and regulations related to solid waste?”
Basis conclusion: The Project would comply with federal, state, and local management and reduction statutes and regulations related to solid waste; thus, there is no significant impact.

Wildfire
“If located in or near State Responsibility Areas or lands classified as Very High Fire Hazard Severity Zones, would the Project , due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose Project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?” Basis for Conclusion: The Project would not, due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose Project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire; thus, there is no significant impact. “If located in or near State Responsibility Areas or lands classified as Very High Fire Hazard Severity Zones , would the Project require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment?”
Basis for Conclusion : The Project would not require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment ; thus, there is no significant impact.
“If located in or near State Responsibility Areas or lands classified as Very High Fire Hazard Severity Zones, would the Project expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post - fire slope instability, or drainage changes?”
Basis for conclusion: The Project would not expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post -fire slope instability, or drainage changes; thus, there is no significant impact.

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Section 4: Environmental Impacts Found to be Less Than Significant with Mitigation Incorporated
The EIR analyzed the following potentially significant environmental impacts of the Project. Based on the EIR analysis, compliance with applicable laws, codes, and statutes, and the incorporation of feasible mitigation measures, these impacts have been reduced to less than significant.

Pursuant to State CEQA Guidelines §15091(a)(1), the City finds that “changes or alterations have been required in, or incorporated into, the Project which mitigate or avoid the significant effects on the environment” (“Finding 1”). Where applicable, and pursuant to State CEQA Guidelines §15091(a)(2), the City further finds that “those changes or alterations are within the responsibility and jurisdiction of another public agency and have been, or can and should be, adopted by that other agency” (“Finding 2”).

Cultural Resources
“Would the P roject cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5?”
Finding
The City adopts Finding 1 (State CEQA Guidelines §15091(a)(1)). The City finds that MM CUL-1 is feasible, adopted, and would reduce potential archeological resources impacts to a less than significant level.

Pursuant to PRC §21081(a)(1) and State CEQA Guidelines §15091(a)(1), changes or alterations have been incorporated into the Project to mitigate or avoid potentially significant impacts identified in the EIR.

Basis for Conclusion : The Project site, developed as the Anaheim Hills Festival Shopping Center, has undergone prior disturbance, reducing the likelihood of intact archaeological resources. However, its location south of the Santa Ana River indicates high archaeological sensiti vity. Therefore, MM CUL -1 is required to ensure that any previously unidentified archaeological resources are appropriately identified, evaluated, and protected.

Mitigation Measures
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 soil s 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 establis h, 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.

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Geology and Soils
“Would the Project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:
ii) Strong seismic ground shaking?”
Finding
The City adopts Finding 1 (State CEQA Guidelines §15091(a)(1)). The City finds that MM GEO-1 is feasible, adopted, and would reduce potential seismic ground shaking impacts to a less than significant level.

Pursuant to PRC §21081(a)(1) and State CEQA Guidelines §15091(a)(1), changes or alterations have been incorporated into the Project to mitigate or avoid potentially significant impacts identified in the EIR.

Basis for Conclusion: The Project site could experience moderate to strong seismic ground shaking from nearby faults, including the Peralta Hills and Whittier Faults. The City would require compliance with the California Building Code (CBC) seismic design standards and the Project’s Geotechnical Exploration and Feasibility Report (Draft EIR Appendix 4.7 -1), which provides site -specific seismic design parameters, foundation, and gradi ng recommendations. MM GEO -1 requires City review of all plans to ensure consistency with these recommendations and applicable codes. Compliance with MM GEO -1 and regulatory requirements would reduce potential seismic ground shaking impacts to a less than significant level.

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.
“Would the Project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:
ii) Seismic-related ground failure, including liquefaction?” Finding
The City adopts Finding 1 (State CEQA Guidelines §15091(a)(1)). The City finds that MM GEO-1 is feasible, adopted, and would reduce potential impacts from seismic-related ground failure to a less than significant level. Pursuant to PRC §21081(a)(1) and State CEQA Guidelines §15091(a)(1), changes or alterations have been incorporated into the Project to mitigate or avoid potentially significant impacts identified in the EIR.

Basis for Conclusion: The Project site is not located within an area susceptible to liquefaction and is underlain by a very dense to hard artificial fill and sedimentary bedrock, resulting in a very low liquefaction potential. The Anaheim Planning and Building Department’s Bui lding Division and Public Works Department would review construction plans for compliance with the CBC, Anaheim Municipal Code, and the Project’s Geotechnical Exploration and Feasibility Report’s recommendations (Draft EIR Appendix 4.7- 1). Compliance with MM GEO -1 and applicable engineering standards would ensure potential impacts from seismic-related ground failure, including liquefaction, are reduced to a less than significant level.

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 ens ure compliance with the recommendations contained in the Project’s Geotechnical Exploration and Feasibility Report.

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“Would the Project be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on - or off -site landslide, lateral spreading, subsidence, liquefaction, or collapse?” Finding
The City adopts Finding 1 (State CEQA Guidelines §15091(a)(1)). The City finds that MM GEO-1 is feasible, adopted, and would reduce potential geotechnical hazards to a less than significant level. Pursuant to PRC §21081(a)(1) and State CEQA Guidelines §15091(a)(1), changes or alterations have been incorporated into the Project to mitigate or avoid potentially significant impacts identified in the EIR.

Basis for Conclusion: The Project site is not susceptible to seismically induced liquefaction or landslides and has negligible risk of subsidence due to its developed condition and lack of groundwater, oil, or gas extraction. The Project’s Geotechnical Exploration and Feasibility Report (Draft EIR Appendix 4.7 -1) concludes the site is geotechnically suitable for development and provides recommendations for seismic design parameters, foundations, slabs, and grading. The Anaheim Building Division and Public Works Department would review construction plans for compliance with the CBC, Anaheim Municipal Code, and the Geotechnical Report recommendations. Compliance with MM GEO -1 and applicable engineering standards would ensure the Project is not located on or create unstable geologic conditions, reducing impacts to a less than significant level.
“Would the Project be located on expansive soil, as defined in Table 18 -1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property?”
Finding
The City adopts Finding 1 (State CEQA Guidelines §15091(a)(1)). The City finds that MM GEO-1 is feasible, adopted, and would reduce potential geotechnical hazards to a less than significant level. Pursuant to PRC §21081(a)(1) and State CEQA Guidelines §15091(a)(1), changes or alterations have been incorporated into the Project to mitigate or avoid potentially significant impacts identified in the EIR.

Basis for Conclusion: The Project’s Geotechnical Exploration and Feasibility Report ( Draft EIR Appendix

4.7-1) found near-surface soils have low to medium expansion potential. The report recommends either a post-tension slab-on-grade system or a slab design per the Wire Reinforcement Institute method. The Anaheim Building Division and Public Works Department would review construction plans for compliance with the CBC, Anaheim Municipal Code, and the Geotechnical Report’s recommendations. Compliance with MM GEO -1 and applicable engineering standards would ensure expansive soils do not create substantial risks to life or property, reducing impacts to a less than significant level. “Would the Project directly or indirectly destroy a unique paleontological resource or site, or a unique geologic feature?”
Finding
The City adopts Finding 1 (State CEQA Guidelines §15091(a)(1)). The City finds that MM-GEO 2 is feasible, adopted, and would reduce potential impacts to paleontological resources to a less than significant level.

Pursuant to PRC §21081(a)(1) and State CEQA Guidelines §15091(a)(1), changes or alterations have been incorporated into the Project to mitigate or avoid potentially significant impacts identified in the EIR.

Basis for Conclusion: A records search by the Natural History Museum of Los Angeles County ( Draft EIR Appendix 4.7-2) found no known fossil localities within the Project site, but identified fossil finds in similar Anaheim Hills Festival Specific Plan Amendment Project Findings of Fact

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sedimentary deposits nearby. As a result, unidentified resources could be encountered during ground - disturbing activities. MM GEO -2 requires monitoring and appropriate treatment if paleontological resources are discovered during construction. With implemen tation of MM GEO -2, impacts would be reduced to a less than significant level.

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 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) i s 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
“Would the Project impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?”
Finding
The City adopts Finding 1 (State CEQA Guidelines §15091(a)(1)). The City finds that MM-HAZ 1 is feasible, adopted, and would reduce the potential impacts related to interference with an adopted emergency response or evacuation plan to a less than significant level. Pursuant to PRC §21081(a)(1) and State CEQA Guidelines §15091(a)(1), changes or alterations have been incorporated into the Project to mitigate or avoid potentially significant impacts identified in the EIR.

Basis for Conclusion : The Project would connect to existing public infrastructure and does not conflict with the City’s Emergency Operations Plan, Local Hazard Mitigation Plan, or Know Your Way evacuation program. Construction activities would not require full road closures, and MM HAZ-1 ensures that a City- approved Construction Management Plan would maintain emergency access during construction.

Additionally, the Project’s construction fire plan would reduce the risk of fire -related incidents during construction that could otherwise interfere with emergency response or evacuation.

An Evacuation Travel Time Analysis (Draft EIR Appendix 4.9-2) modeled wildfire scenarios and found that the Project would increase modeled evacuation times by up to 14 minutes compared to existing conditions, and by 5 –7 minutes compared to the entitled cin ema use. Anaheim Police Department and Anaheim Fire & Rescue confirmed that the Project would not require changes to the Know Your Way evacuation maps. In practice, phased evacuations, active traffic control, and prioritization of at-risk areas would further reduce travel times compared to modeled worst -case scenarios. The Project’s circulation and access design meet California Fire Code requirements for multiple access points, roadway width and clearance, fire apparatus access, and turnaround provisions. In addition, the Project’s Evacuation and Awareness Plan provides resident wildfire evacuation outreach, drills, and an emergency communication system.

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In summary, although the Project would result in additional congestion that would result in a potential extension of time to evacuate, 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, an adopted emergency response or evacuation plan.

Impacts would be less than significant with mitigation incorporated.

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 app licable 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 Anahe im 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.

Transportation
“Would the Project result in inadequate emergency access?” Finding
The City adopts Finding 1 (State CEQA Guidelines §15091(a)(1)). The City finds that MM-HAZ 1 is feasible, adopted, and would reduce potential emergency access impacts to a less than significant level. Pursuant to PRC §21081(a)(1) and State CEQA Guidelines §15091(a)(1), changes or alterations have been incorporated into the Project to mitigate or avoid potentially significant impacts identified in the EIR.

Basis for Conclusion : The Project would provide three vehicular access points along Festival Drive, including two existing and one new driveway, with internal circulation designed to meet California Fire Code and Anaheim Fire & Rescue standards for emergency vehicle access, turning radii, and hammerhead turnaround requirements. Fire apparatus access would be provided within 150 feet of all exterior walls, consistent with California Fire Code §503.1.1, except for localized areas where site constraints preven t full compliance. The Project also does not provide an aerial fire apparatus road located entirely within the required 10- to 30-foot setback range along one building side.

To address these deviations, the Project includes Alternative Materials and Methods under California Fire Code §104.9, as documented in the Fire Protection Plan ( Draft EIR Appendix 4.9 -1). These measures — developed in coordination with Anaheim Fire & Rescue —include fire walls to compartmentalize the building, enhanced roof access, stretcher -sized elevators, two -hour fire -rated interior passageways, widened driveways for aerial ladder access, and courtyard standpipes to ensure adequate hose reach and water supply.

Evacuation modeling (Draft EIR Appendix 4.9-2) indicates the Project would increase wildfire evacuation travel times by 14 to 22 minutes compared to existing conditions and 5 to 7 minutes relative to the entitled Anaheim Hills Festival Specific Plan Amendment Project Findings of Fact

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cinema use. The City of Anaheim has not adopted quantitative thresholds for evacuation time increases, and the projected changes are not considered substantial because they do not alter, obstruct, or reroute designated evacuation routes, nor impair the ope rational effectiveness of the City’s Know Your Way program. Coordination with Anaheim Fire & Rescue and Anaheim Police Department confirmed that no modifications to existing evacuation routes or procedures are necessary and that emergency responders would retain operational flexibility for traffic control and evacuation management.

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 result in in adequate emergency access.

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 app licable 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 Anahe im 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.

Tribal Cultural Resources
“Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code § 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
ii) A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code § 5024.1. In applying the criteria set forth in subdivision (c) of Public Resource Code § 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe?”
Finding
The City adopts Finding 1 (CEQA Guidelines §15091(a)(1)). The City finds that MM CUL -1 and MM TCR-1 are feasible , are adopted, and would reduce potential tribal cultural resource impacts to a less than significant level. Pursuant to PRC §21081(a)(1) and State CEQA Guidelines §15091(a)(1), changes or alterations have been incorporated into the Project to mitigate or avoid potentially significant impacts identified in the EIR.

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Basis for Conclusion: On February 19, 2024, the City invited tribal representatives identified by the Native American Heritage Commission to consult under AB 52 and SB 18 (Appendix 4.18 -1). The City received one request for consultation from the Gabrieliño Band of Mission India ns – Kizh Nation, which occurred on July 3, 2024. The Project site has been previously disturbed, and the Cultural Resources Assessment did not identify sensitivity for cultural resources; however, a Sacred Lands File search returned positive results ( Draft EIR Appendix 4.5 -1), indicating the potential for accidental discovery during ground disturbance. MM CUL-1 requires archaeological monitoring in previously undisturbed soils and salvage of resources as necessary, and MM TCR -1 requires a qualified Native American tribal monitor during specified activities. With these measures, the Project would result in a less than significant impact related to this threshold.

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 qualifi ed 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, 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) acknowled gment 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 Indi ans – 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.

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Wildfire
“If located in or near State Responsibility Areas or lands classified as Very High Fire Hazard Severity Zones, would the Project substantially impair an adopted emergency response plan or emergency evacuation plan?”
Finding
The City adopts Finding 1 (State CEQA Guidelines §15091(a)(1)). The City finds that MM-HAZ 1 is feasible, adopted, and would reduce the potential impacts related to interference with an adopted emergency response or evacuation plan to a less than significant level. Pursuant to PRC §21081(a)(1) and State CEQA Guidelines §15091(a)(1), changes or alterations have been incorporated into the Project to mitigate or avoid potentially significant impacts identified in the EIR.

Basis for Conclusion: Evacuation modeling conducted for the Project (Draft EIR Appendix 4.9-2) evaluated two wildfire scenarios and determined that, while the Project would increase evacuation travel times compared to existing conditions, the net increase relative to the entitled operational use of the site is minimal and does not alter, obstruct, or require rerouting of designated evacuation routes. Coordination with Anaheim Fire & Rescue and the Anaheim Police Department confirmed that the Project would not necessitate modifications to existing evacuation routes or procedures, and emergency responders would retain the ability to adjust evacuation timing, traffic control, and signal operations as needed.

Implementation of MM HAZ -1 would ensure construction activities maintain emergency access in compliance with applicable fire safety regulations. With MM HAZ- 1 incorporated, the Project would not substantially impair an adopted emergency response plan or emergency evacuation plan, and imp acts would be less than significant.

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 app licable 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 Anahe im 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.

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Section 5: Environmental Impacts Found to be Significant and Unavoidable Where, as a result of the environmental analysis of the Project, the City has determined that either (1) even with compliance with applicable laws, codes, and statutes and/or implementation of feasible mitigation measures, potentially significant impacts c annot be reduced to less than significant levels, or (2) no feasible mitigation measures or alternatives are available, the City may adopt Finding 3 (State CEQA Guidelines §15091(a)(3)). Under this finding, “specific economic, legal, social, technological, or other considerations, including considerations for the provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or alternatives identified in the environmental impact report.” The significant unavoidable impacts identified below require adoption of a Statement of Overriding Considerations pursuant to CEQA Guidelines §15093 if the Project is approved.

Transportation
“Would the Project conflict or be inconsistent with State CEQA Guidelines § 15064.3, subdivision (b)?”
Finding
The City adopts Finding 3 (CEQA Guidelines §15091(a)(3)). The City finds that, even with compliance with applicable policies, ordinances, and regulations, the Project would result in a significant project-generated vehicle miles traveled (VMT) impact. There are no feasible mitigation measures or alternatives that would reduce this impact to a less than significant level. Accordingly, pursuant to PRC §21081(a)(3) and CEQA Guidelines §15091(a)(3), the City finds that specific economic, social, and other consi derations, as set forth in the Statement of Overriding Considerations, outweigh the significant unavoidable impacts.

Basis for Conclusion: The Project would exceed the City’s VMT per service population threshold s under both baseline and cumulative conditions. The baseline Project-generated VMT would need to be reduced by 18.8 percent, and cumulative Project -generated VMT by 20.1 percent, to meet the City’s significance thresholds.

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) (Handbook) was consulted to identify feasible and quantifiable VMT reduction strategies applicable to the Project. The Handbook provides a comprehensive framework for evaluating greenhouse gas (GHG) reduction measures, including transportation-related strategies that can also reduce VMT. Each reduction measure is accompanied by a factsheet detailing its descr iption, locational context, scale of application, implementation requirements, and other relevant considerations to assess feasibility and effectiveness.

CAPCOA Measure T-4 (Affordable Housing) and T-15 (Limit Residential Parking Supply) were found to be feasible and were incorporated into the Project as part of its design. In alignment with CAPCOA Measure T-4 (Affordable Housing), the Project includes 45 moderate-income 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 (see Draft EIR Appendix 4.17-1). The Property Owner/Developer evaluated the feasibility of providing additional affordable housing units above the 45 units proposed to further reduce VMT; however, the Property Owner/Developer determined that doing so would not be economically viable due to the substantial costs associated with site development. In addition, in alignment with CAPCOA Measure T -15 (Limit Residential Parking Supply), the Project proposes a total of 893 parking spaces, which is 70 fewer spaces than the 963 parking spaces required by the City’s development standards. This measure is estimated to decrease project-generated VMT by approximately 1 percent or 567 VMT. Togeth er, these measures are projected to reduce VMT by a total of 2,188 VMT. Therefore, Anaheim Hills Festival Specific Plan Amendment Project Findings of Fact

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even with the feasible CAPCOA VMT Reduction Measures incorporated, the Project would still result in a VMT per service population in exceedance of the City’s adopted VMT impact threshold. Therefore, despite incorporation of CAPCOA Measure T-5 and CAPCOA Measure T-15, the Project would result in a significant and unavoidable impact concerning VMT.

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Section 6: Alternatives to the Project
Pursuant to State CEQA Guidelines §15126.6, and as discussed in detail below the City evaluated a reasonable range of potentially feasible alternatives to the Project. These alternatives were selected based on their ability to feasibly attain most of the basic objectives of the Project while avoiding or substantially lessening one or more of the Project’s significant environmental effects.

The three alternatives carried forward for detailed consideration are described below in sufficient detail to permit meaningful evaluation, analysis, and comparison to the Project. Each alternative is analyzed relative to the Project’s environmental impacts, feasibility, and ability to achieve the Project’s objectives, consistent with the requirements of §15126.6.

6.1 Elimination or Reduction of Significant Impacts
State CEQA Guidelines §15126.6(b) provides that “because an EIR must identify ways to mitigate or avoid the significant effects that a project may have on the environment (PRC §21002.1), the discussion of alternatives shall focus on alternatives to the project or its location which are capable of avoiding or substantially lessening any significant effects of the project, even if these alternatives would impede to some degree the attainment of the project objectives, or would be more costly.” With implementation of the Mitigation Program identified for each environmental topic , many of the potentially significant impacts resulting from Project implementation would be reduced to less than significant levels. However, the analysis determined that the Project would result in a significant and unavoidable impact in the following topical area for which no feasible mitigation measures are available that would reduce the Project’s impacts to a less than significant level:
 Transportation – Conflict with or inconsistency with State CEQA Guidelines §15064.3(b) (VMT) Because no feasible mitigation measures or alternatives have been identified that would reduce this impact to a less than significant level, the Project’s impact related to this topic remains significant and unavoidable.

6.2 Project Alternatives Considered
Alternative 1: No Project/No Build Alternative
Description: Pursuant to State CEQA Guidelines § 15126.6(e)(1), the No Project/No Build Alternative assumes the Project would not be approved, no development would occur , and the requested entitlements (Specific Plan Amendment, General Plan Amendment, Development Agreement, and Development Review) would not be granted . With the No Project/No Build Alternative, e xisting commercial uses within the Project site would remain, with the cinema continuing to be vacant.

Environmental Effects: A detailed comparison between impacts identified in the Project and Alternative 1 is provided in Section 5.5 of the Draft EIR.

Ability to Achieve Project Objectives:

Project Objective Alternative 1
Meets Objectives?
Objective 1: Transform the Project site into a
visually attractive and safe environment.

No. The No Project/No Build Alternative would not include any development that would modify the aesthetic value of the Project site or provide additional safety features.

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Alternative 1 Findings: The City Council rejects Alternative 1 (No Project/No Build Alternative) pursuant to State CEQA Guidelines §15126.6(e)(1) because it would not meet the underlying purpose of the Project, to increase the availability of housing units in Anaheim, or achieve the majority of the Project objectives.

Under this alternative, no development would occur, the Project site would remain in its current condition, and the requested entitlements (Specific Plan Amendment, General Plan Amendment, Development Agreement, and Development Review) would not be granted. While this alternative would avoid the Project’s significant environmental impacts, it would also forego the economic, social, and housing benefits provided by the Project, and therefore is rejected as infeasible.

Project Objective Alternative 1
Meets Objectives?
Objective 2: Increase the City’s housing
inventory and provide new housing
opportunities for existing and future City
residents in a mixed-use setting.

No. No development would occur under the No Project/No
Build Alternative; therefore, no additional housing
opportunities would be built to increase the City’s housing inventory.

Objective 3: Assist the City in meeting its
Regional Housing Needs Assessment for the
2021-2029 Housing Element cycle.

No. No development would occur under the No Project/No
Build Alternative; therefore, no housing opportunities would be built to support meeting the City’s RHNA.

Objective 4: Establish a “sense of place”
through the design of the Project site, creating
a design that is sensitive to the natural
environment, compatible with the surrounding
urbanizing area, and consistent with the
requirements of the City’s Scenic Corridor
Overlay Zone.

No. The No Project/No Build Alternative would not include any development that would modify the existing design of the Project.

Objective 5: Build a residential community with
robust amenities that promote healthy
engagement among its residents and other site
users.

No. The No Project/No Build Alternative would not include any residential development that would modify the existing Project site or provide new amenities for residents or site users.

Objective 6: Provide landscaping that is
appropriate to the level of development and
that is sensitive to surrounding areas.

Yes. While the No Project/No Build Alternative would not provide additional landscaping elements, the existing Project site has landscaping to support the existing development and is compatible with the surrounding areas.

Objective 7: Develop a high -quality
architectural design shaped by Southern
California's contextual and regional vernacular.

Yes. While the No Project/No Build Alternative would not include any development that would modify the existing
architectural design, existing development on -site was constructed in compliance with the City’s Municipal Code and Specific Plan guidelines in regard to architectural features.

Objective 8: Provide affordable housing
options for existing and future residents of the
City.

No. No development would occur under the No Project/No
Build Alternative, therefore, no additional housing
opportunities would be built to provide potential affordable housing options for the City.

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City of Anaheim 30
Alternative 2: Existing Zoning Alternative
Description: Alternative 2 assumes that no new residential development would occur in the Project site.

Alternative 2 assumes the existing vacant cinema would be retrofitted to be used as a commercial retail use that is currently allowed under the existing Specific Plan, such as a home improvement/home goods retailer or as a seasonal retail space. No new commercial square footage would be constructed under Alternative 2. Alternative 2 would not require any of the Project’s requested entitlements (i.e., Specific Plan Amendment, General Plan Amendment, Development Agreement).

Environmental Effects: A detailed comparison between impacts identified in the Project and Alternative 1 is provided in Section 5.5 of the Draft EIR.

Ability to Achieve Project Objectives:

Project Objective Alternative 2
Meets Objectives?
Objective 1: Transform the Project site into a
visually attractive and safe environment.

Yes. Alternative 2 would remodel the existing cinema, which would include aesthetic features to enhance the site’s visual character and a safe environment. However, this would be provided at a lesser scale than the Project.

Objective 2: Increase the City’s housing
inventory and provide new housing
opportunities for existing and future City
residents in a mixed-use setting.

No. No residential development would occur in the Project site under Alternative 2. Therefore, no additional housing opportunities would be built to support the City’s housing inventory, particularly in a mixed-use setting.

Objective 3: Assist the City in meeting its
Regional Housing Needs Assessment for the
2021-2029 Housing Element cycle.

No. No development would occur in the Project site under Alternative 2; therefore, no housing opportunities would be built to support meeting the City’s RHNA.

Objective 4: Establish a “sense of place”
through the design of the Project site, creating
a design that is sensitive to the natural
environment, compatible with the surrounding
urbanizing area, and consistent with the
requirements of the City’s Scenic Corridor
Overlay Zone.

No. Although Alternative 2 would include the remodel of an existing building, Alternative 2 would not include any development that would modify the existing design of the Project.

Objective 5: Build a residential community
with robust amenities that promote healthy
engagement among its residents and other
site users.

No. Alternative 2 does not include the development of a residential community.

Objective 6: Provide landscaping that is
appropriate to the level of development and
that is sensitive to surrounding areas.

Yes. While Alternative 2 would not provide additional
landscaping elements, the existing Project site has landscaping to support the existing development and is compatible with the surrounding areas.

Objective 7: Develop a high-quality
architectural design shaped by Southern
California's contextual and regional vernacular.

Yes. While Alternative 2 would not include any development that would modify the existing architectural design, existing development on-site was constructed in compliance with the City’s Municipal Code and Specific Plan guidelines in regard to architectural features.

Anaheim Hills Festival Specific Plan Amendment Project Findings of Fact

City of Anaheim 31

Alternative 2 Findings: The City rejects Alternative 2 (Existing Zoning Alternative) pursuant to State CEQA Guidelines §15126.6 because Alternative 2 would not meet the underlying purpose of the Project, to increase the availability of housing units in Anaheim, nor would Alternative 2 achieve a majority of the Project’s objectives. Under Alternative 2, no residential development would occur in the Project site.

Instead, the Project site would be retrofitted for a commercial retail use consistent with the existing Specific Plan and General Plan designations. As such, the entitlements that are required for the Project would not be required for Alternative 2. Alternative 2 would reduce certain environmental impacts when compared to the Project; however, Alternative 2 would fail to provide any new housing opportunities, and Alternative 2 would not assist the City in meeting its 6th Cycle RHNA allocation. For these reasons, the City rejects Alternative 2 as infeasible.

Alternative 3: Reduced Project Alternative
Description: Alternative 3 assumes the development of 388 dwelling units in DA 5 within the Project site, at a density of 24 dwelling units per acre, which is consistent with other townhome projects in the City.

No affordable units are proposed under Alternative 3. Alternative 3 is intended to evaluate the potential for reduced environmental impacts associated with fewer residential dwelling units on the Project site.

Alternative 3 would require the same amendments and entitlements as are proposed for the Project, but Alternative 3 would include a change of the land use designation for DA 5 to Mixed -Use Mid with a reduced maximum density of 27 dwelling units per acre compared to 36 dwelling units per acre associated with the Mixed-Use Medium land use designation.

Alternative 3 would provide the same ratio of parking spaces for the proposed dwelling units ; thus, a proportional reduction in the total number of parking spaces provided would occur when compared to the Project. However, with Alternative 3, parking would be surface parking or tucked under buildings rather than in a parking structure as is proposed with the Project . Alternative 3 would still involve the demolition of the existing movie theater to allow for the proposed residential development.

Environmental Effects: A detailed comparison between impacts identified in the Project and Alternative 1 is provided in Section 5.5 of the Draft EIR.

Ability to Achieve Project Objectives:

Project Objective Alternative 2
Meets Objectives?
Objective 8: Provide affordable housing
options for existing and future residents of the
City.

No. No residential development would occur in the Project site under Alternative 2; therefore, no additional housing opportunities would be built to provide potential affordable housing options for the City with Alternative 2.

Project Objective Alternative 3
Meets Objectives?
Objective 1: Transform the Project site into a
visually attractive and safe environment.

Yes. Alternative 3 would develop the site similarly to the Project, except for fewer dwelling units. The proposed
development under Alternative 3 would incorporate aesthetic features to enhance the site’s visual character and create a safe environment.

Objective 2: Increase the City’s housing
inventory and provide new housing
Yes. Alternative 3 would develop 388 dwelling units in DA 5, increasing the City’s housing inventory and providing housing opportunities in a mixed-use setting. However, this Alternative Anaheim Hills Festival Specific Plan Amendment Project Findings of Fact

City of Anaheim 32

Alternative 3 Findings: Alternative 3 would meet most of the Project objectives ; however, it would not fully achieve the underlying purpose of the Project, which is to increase the availability of housing units in Anaheim consistent with the City’s Housing Element and RHNA obligations. Alternative 3 would develop 388 multiple -family residential units, which is fewer than the 447 units proposed under the Project .

Therefore, Alternative 3 would provide less housing and would assist the City to a lesser extent in meeting the City’s 6th Cycle RHNA allocation. This reduction in units, when comparing the Project with Alternative 3, would also limit the provision of affordable housing opportunities and the economic and social benefits associated with the Project. While Alternative 3 would reduce some environmental impacts compared to the Project, Alternative 3 would not eliminate the Project’s significant and unavoidable VMT impact .

Accordingly, Alternative 3 is rejected as infeasible because it would achieve the Project objectives to a substantially lesser degree than would the Project.

Project Objective Alternative 3
Meets Objectives?
opportunities for existing and future City
residents in a mixed-use setting.
would provide fewer dwelling units, therefore increasing the City’s housing inventory to a lesser degree compared to the Project.

Objective 3: Assist the City in meeting its
Regional Housing Needs Assessment for the
2021-2029 Housing Element cycle.

Yes. Alternative 3 would develop 388 dwelling units in DA 5, which would assist the City in meeting its RHNA. However, this Alternative would provide fewer dwelling units, therefore assisting the City’s RHNA to a lesser degree than the Project.

Objective 4: Establish a “sense of place”
through the design of the Project site, creating
a design that is sensitive to the natural
environment, compatible with the surrounding
urbanizing area, and consistent with the
requirements of the City’s Scenic Corridor
Overlay Zone.

Yes. Alternative 3 would develop the site similarly to the Project, except for fewer dwelling units. The proposed
development under Alternative 3 would include design
features that would create a “sense of place” and be
compatible with the surrounding urbanized area. The Project would also be consistent with the City’s Scenic Corridor Overlay Zone.

Objective 5: Build a residential community
with robust amenities that promote healthy
engagement among its residents and other
site users.

Yes. Alternative 3 would develop a residential community with 388 dwelling units in DA 5 with amenities to support residents.

Objective 6: Provide landscaping that is
appropriate to the level of development and
that is sensitive to surrounding areas.

Yes. Alternative 3 would develop the site similarly to the Project, with the exception of fewer dwelling units.

Development under Alternative 3 would include landscaping elements that would be compatible with the proposed
residential use and the surrounding area.

Objective 7: Develop a high-quality
architectural design shaped by Southern
California's contextual and regional vernacular.

Yes. Alternative 3 would develop the site similarly to the Project, with the exception of fewer dwelling units. Alternative 3 would develop residential uses that would be constructed to provide high-quality architectural design elements.

Objective 8: Provide affordable housing
options for existing and future residents of the
City.

No. Alternative 3 would not include affordable housing.

Anaheim Hills Festival Specific Plan Amendment Project Findings of Fact

City of Anaheim 33
Section 7: Statement of Overriding Considerations

7.1 Introduction
Pursuant to State CEQA Guidelines §15093, when a project will result in significant unavoidable impacts that cannot be reduced to less than significant levels, the decision -making body must balance those impacts against the project’s benefits in determinin g whether to approve the project. If the benefits outweigh the adverse effects, those effects may be considered acceptable (§15093(a)). The agency must adopt a written Statement of Overriding Considerations identifying specific reasons for approval despite such impacts, supported by substantial evidence in the EIR or elsewhere in the administrative record (§15093(b)).

As identified in Section 5 of these Findings, the Project would result in a significant and unavoidable impact related to transportation (VMT) even after implementation of the Mitigation Program.

The City adopts this Statement of Overriding Considerations, finding that the following benefits of the Project constitute separate and independent grounds for determining that the Project’s long -term benefits outweigh its significant unavoidable environmental effects and justify approval pursuant to CEQA Guidelines §15093.

7.2 Facts in Support of Statement of Overriding Considerations The Anaheim City Council finds that the benefits resulting from implementation of the Project outweigh the significant unavoidable adverse effects that would result from the Project related to transportation (VMT). The Anaheim City Council has reviewed the substantial evidence before it and concludes that these potentially significant unavoidable impacts are acceptable based upon the overriding considerations set forth herein. Any one of the following considerations is sufficient to support the City Council's determination:
 The Project would increase the City’s housing supply by 447 new multi -family residential units, including affordable units, consistent with the City’s adopted Housing Element and State housing law. This supports the City’s objective to increase the housing inventory, provide new housing opportunities in a mixed-use setting, and offer affordable housing options.  The Project would provide 45 moderate -income affordable housing units, expanding housing opportunities for lower - and moderate -income households and supporting the City’s housing equity goals.
 The Project would redevelop an underutilized and partially vacant site into a more v ibrant and mixed-use residential community.
 The Project would generate construction -related employment, ongoing operational jobs, and increased property and sales tax revenues, thereby contributing to the City’s fiscal stability and economic vitality, which supports the City’s ability to maintain infrastructure and services for a growing housing population.
 The Project would support the City’s long-term land use vision by implementing the goals of the Anaheim General Plan and the Anaheim Hills Festival Specific Plan. The Project : would provide residential uses in proximity to existing commercial amenities, and employment opportunities; establishes a “sense of place” through high-quality site design; and incorporates landscaping that is appropriate to the level of development and that is sensitive to the surrounding area.

Anaheim Hills Festival Specific Plan Amendment Project Findings of Fact

City of Anaheim 34
 The Project would provide on -site amenities such as landscaped open space, recreational facilities, and pedestrian connections, promoting resident well -being, fostering community interaction, and supporting the Property Owner/Developer’s goal of building a residential community with robust amenities.
 The Project would comply with the latest California Green Building Standards Code (CALGreen) and would incorporate energy -efficient building systems and water -efficient landscaping. This would ensure high-quality architectural design consistent with Southern California’s contextual and regional vernacular while reducing environmental impacts and supporting the City’s climate action goals.

Based on substantial evidence in the EIR and administrative record, the City finds that the foregoing benefits outweigh the Project’s significant and unavoidable transportation (VMT) impact. Therefore, approval of the Project is warranted pursuant to State CEQA Guidelines §15093.