2. Appendix to Minutes (01/13/26) — Anaheim City Council, March 24, 2026 (part 1 of 2)

Date: 12/16/2025 4:05: 11 PM
From:" Jen McCool"
To:" Public Comment" publiccomment@anaheim. net
Subject:[ EXTERNAL] Any developments in Anaheim hills
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When uout driving last night was in villa park Yorba Linda and Anahrim hills, one thing is consistent these are residential areas with one and two lane roads most have no shoulders and no center dividers they are all master planned communities that were not ever zoned for high density or apartments of large amounts all property in question is not zoned for it. Yorba Linda recently shut down a proposal directly across freeway as it was not zoned and did possed problems in high fire area as well as current traffic which is no where near the traffic we have over here. My heart breaks when I see emergency sitting on the road with no possible way to get through anywhere to a fire or someone in need for a medical emergency . Ways has shows the IE traffic how to cut through orange to Anahrim hills to the 91 freeway. It has trapped us in our homes and made a huge mess! Our current evacuation states 3 hours not tested btw and on a regular night can take a hour just to go 2-3 miles people make up there own lanes exit freeway going backwards and it’s very dangerous out there. When you look at these pictures know there is NO possible way to get through this traffic on a regular day of the week throw in a accident on the freeway and our wing of the city shuts down. We need to keep zones in place and we can not add to thus current situation and bridges etc will only add to the problem we need to reduce current traffic re direct off our side streets. This is not normal traffic that other cities share this is you are just excuse my language screwed. La Palma on opposing side of freeway all the way to gypsum also no movement and residents can not leave homes as it stands. Just do you know this is new in the last couple years this was never a problem before. Now think about a development day in Irvine with 5 lanes a shoulder to every road no rush of wildfire and parallel streets every block totally different it was designed like that same with other parts if Anahrim or other cities. 91 freeway is one of the worst in this area and everyone tries to avoid it and now it has caused issues for residents. I expect there to be many lawsuits about medical or fire etc and not being able to get to our homes or for us to get out. The last fire it took till the next day to reach our oldest who was fleeing from the fire and hours to get our youngest literally on foot from Santa Ana canyon to el rancho, I had no way out a fire tornado and thick smoke took over and I was unable to see only feel my way around to get back into home, a few other neighbors used hoses to battle the fire on the hillside. This is not a joke it’s not about change it’s about improvement and keeping us safe and allowing the police or fire to be able to get to us. I can provide other pictures as well. I’m tired as we all are of this constant push for all these developments which are all right next to each other none zoned for any of this for a good reason. This area is no dirtent then directly across the freeway in Yorba Linda the answer was no they were not about to further put residents at risk I urge you to reach out to there mayor as well. She is a stand up woman and is protecting her city Janice Lim. We should not be wasting city time and money discussing any of this. MOST important stop looking at Anaheim hills when we have high winds your know your way is a joke your a Linda was on fire villa park is on fire orange park aces is on fire not just Anaheim hills it’s a absolute trap. Your looking at populations form 3/4 cities trying to escape all at once and that has never once been recognized or addressed other then fire narshall acknowledging the issue. You can not outrun a fire when everything is on fire riverbed surrounding the freeway too it was all shut down there is no escape to our neighboring cities they were also on fire, you need to look beyond our own city just as Yorba Linda just ruled No last month.

You don't often get email from Learn why this is important Date: 12/16/2025 4:46:56 PM
From:" Maria Bessem"
To:" Public Comment" [email protected]
Subject:[ EXTERNAL] Fairmont proposal
Warning: This email originated fromoutside the City of Anaheim. Do not click links or open attachme nts unless you recognize the sender and are expecting the message.

Dear Council Members,
As a resident off of Fairmont and Santa Ana Cyn of 30 years, I am concerned about the suggestions for Fairmont.

The off-ramp at Fairmont, if build will dump additional cars off the the freeway, depending on Waze and other apps, commuters will pop off, travel Santa Ana cyn and then get back on at Gypsum.

The induced traffic, evacuation safety, and cumulative impacts reduce my quality of life.

Proposed developments near Festival, will add cumulative trips ( perhaps 4 per resident) a day. This makes it so difficult just to go to the market at Festival and impossible during crisis management.

I don’t think the proposed Fairmont plan will ease traffic at all.

Sincerely,
Maria Bessem
1 You don't often get email from Learn why this is important Date: 12/16/2025 5:55:23 PM
From:" Grace Branche"
To:" Public Comment" publiccomment@anaheim. net
Subject:[
EXTERNAL] Safety concerns about proposed Festival Project inAnaheim Hills DEVELOPMENT APPLICATION NO. 2023-00043
Warning: This email originated fromoutside the City of Anaheim. Do not click links or open attachme nts unless you recognize the sender and are expecting the message.

HI,
I am writing to formally register my opposition to the proposed development project at the Festival Shopping Center. Traffic conditions in the surrounding area are already severe and, at times, untenable.

As wildfire risk continues to increase, adding significant new congestion raises serious concerns for public health and safety, particularly in the event of an emergency evacuation. Increased traffic volume could materially impair the community’ s ability to evacuate safely and efficiently.

Moreover, the addition of a large apartment complex with permanent residents represents a fundamentally different and far more impactful use than the existing or previously planned commercial uses, such as a movie theater. The long-term traffic, infrastructure, and safety implications are substantially greater.

For these reasons, I strongly urge you not to approve this development and to avoid further exacerbating an already critical situation for current residents.

Thanks,
Grace Branche
1 Date: 12/16/2025 8:10:02 PM
From:" Rick Pollgreen"
To:" Public Comment" [email protected]
Subject:[ EXTERNAL] Festival project
Warning: This email originated from outs ide the City of Anaheim. Do not click links or open attachments unles s you recognize the sender and are expecting the mes sage.

Hi,
This email is to voice my oppos ition to the Fes tival project. Specifically with regards to adding any more cars and people into this area that is already woefully prepared for evacuating in the cas e of wildfires .

Why don’ t you FIRST upgrade the infras tructures and evacuation routes to be able to handle the current population before ADDING ANY MORE people and cars ? I mean, that makes sens e, right?
Lis ten to our Fire chief and the police chief.

They are well aware of how poorly prepared this area is in the cas e of wildfire evacuations . As seen by the las t couple of evacuations in this area! Thanks ,
Richard Pollgreen
You don't often get email from Learn why this is important Date: 12/16/2025 8:32:30 PM
From:" sveti ugarte"
To:" Public Comment" publiccomment@anaheim. net
Subject:[ EXTERNAL] Anaheim Hills Festival Project (DEV2023-00043) – Public Comment / Opposition Warning: This email originated fromoutside the City of Anaheim. Do not click links or open attachme nts unless you recognize the sender and are expecting the message.

Dear Mayor and Members of the City Council,
I am writing to formally express my opposition to the Anaheim Hills Festival Project (DEV2023- 00043).

After reviewing the proposal, I respectfully request that the City Council reject this plan due to its potential negative impacts on the surrounding community. Specifically, I am concerned about increased traffic congestion, public safety risks, environmental impacts, and the overall incompatibility of the proposed development with the existing character of the Anaheim Hills area.

This project appears to prioritize commercial interests over the quality of life of nearby residents. The anticipated increase in traffic, noise, and density would place additional strain on already impacted local roads and infrastructure. Furthermore, the project does not adequately address community concerns or demonstrate meaningful benefits that outweigh these impacts.

Anaheim Hills has a distinct residential character, and developments of this scale should align with long-term community planning goals, environmental responsibility, and resident well-being. I urge the City Council to listen to the voices of local residents and reject this proposal as currently presented.

Thank you for your time and consideration. Please include this email as part of the official public record.

Sincerely,
Sveti Ugarte
City of Anaheim Resident
Date: 12/17/2025 12:15:47 PM
From:" Carol Jacobs"
To:" Public Comment" [email protected]
Subject:[ EXTERNAL] Festival Project
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To the members of the Anaheim City Council.

Regarding the propos ed apartments at the Fes tival Project, I urge you to recons ider adding to an already exis ting problem of traffic conges tion. I have lived in Anaheim Hills since 1975 with 39 of thos e years at the farthes t Eas t end. To say I have witnes sed the increas e in conges tion is an unders tatement but mos t importantly an EXTREME DANGER. We are gridlocked mos t afternoons with the traffic on Serrano Avenue and worry what would happen if there was a need to evacuate. PLEASE, vis it our area to witnes s this for yours elves . We DO NOT have the infrastructure to support more homes & the added traffic it will bring.

Res pectfully,
Carol Jacobs
Prayer Changes Things !
Sent from Carol’ s iPad
You don't often get email from Learn why this is important Date: 12/19/2025 9:55:48 AM
From:" Mike Jacobs"
To:" Public Comment" [email protected]
Subject:[ EXTERNAL] Festival Center Development
Warning: This email originated fromoutside the City of Anaheim. Do not click links or open attachme nts unless you recognize the sender and are expecting the message.

Dear Members of Anaheim City Council,
I am voicing opposition to the idea of developing the property, previously housing the Festival Movie Theater, into 447 apartment units.

If any council members live inAnaheim Hills, and must endure the daily grind of traffic in this area, your choice would be obvious and clear. If you DON'T reside in this area, you have no idea of the congestion this will further bare on the residents who DO live here.

There is no existing evacuation plan that will accommodate the number of cars and residence currently residing here, let alone the anticipated addition of approx. 600 additional cars trying to exhaust an already over-burden area during an emergency.

My family has live inAnaheim Hills for over 52 years and have seen the problem escalate to the point it is now, barely able to negotiate our roads during work hour, not to mention if a fire the likes of Pacific Palisades should impact our area. The loss of life and structures would be unconscionable and unforgivable....

I implore you to vote against any plan or measure that would create this burden on the good folks who live in this area, already dealing with the daily traffic and fears of an emergency situation...

Respectfully,
Mike Jacobs
From: Paulina Alvare z <pal varez@ocbc. org>
Se nt: Monday, De ce mbe r 15, 2025 10: 46 AM
To: The re sa Bass < TBass@anaheim. net>; Amanda Lauffer < ALauffe r@anahe im. ne t> Cc: Amanda Wal sh < aw alsh@ocbc. org>
Subje ct: [ EXTERN AL] OCBC Le tte r re: Anahe im Hi lls Fe stival_ Ci ty Council Me eting De ce mbe r 16 Warning: This email originated from outside the City of Anaheim. Do not click links or open attachments unless you recogniz e the sender and are expecting the message.

He llo,
Ple ase find OCBC’ s support letter re : Anaheim Hills Festi val Redeve lopme nt attache d.

If you have any spe cif ic questi ons, please let me know.

Thank you,

PAULINA ALVAREZ
Government Affairs Manager
Orange County Business Council
palvarez@ocbc. org
626-588-7565
PLEASE NOTE OCBC’S NEW ADDRESS: 3210 El Camino Real, Ste 100, Irvine 92602 ocbc.org | locationoc. com
2 Park Plaza, Suite 100, Irvine, CA 92614 | P 949.476.2242 | F 949.476.0443 | www.ocbc.org

THE LEADING VOICE OF BUSINESS IN ORANGE COUNTY
December 15, 2025
City of Anaheim
200 S Anaheim Blvd
Anaheim CA 92805
Re: Anaheim Hills Festival Redevelopment – DEV2023-00043 Dear Mayor and Councilmembers,
For more than three decades, the Orange County Business Council (OCBC) has served as the leading voice for Orange County’ s business community. Our work centers on advancing economic development, expanding housing opportunities, and supporting infrastructure investments that strengthen the region’ s long-term competitiveness. On behalf of our members, we are pleased to express strong support for the Anaheim Hills Festival redevelopment project scheduled for consideration on November 17.

Shea Properties, in partnership with Vestar, has put forward a thoughtful and forward -looking plan that reinvests in an important community asset while preserving the character that Anaheim Hills residents value. The proposed redesign creates a modern, vibrant destination with new retail and dining options, enhanced pedestrian access, and inviting open spaces that promote community gathering and quality of life.

Importantly, the project also responds to the significant housing needs in District 6 by integrating much-needed apartment homes into an area with strong access to retail, services, and amenities. This type of mixed -use investment is essential to supporting workforce stability, ensuring long-term economic vitality, and meeting the expectations of a changing marketplace.

Shea Properties has a long and successful history of delivering high-quality developments throughout Orange County. Their track record, combined with Vestar’ s operational expertise, ensures this project will attract strong tenants, create local jobs, and generate sustainable revenue that benefits Anaheim for decades.

OCBC strongly supports the Anaheim Hills Festival redevelopment and encourages the City Council to approve this important investment.

Thank you for your consideration.

Sincerely,
Amanda Walsh
Vice President of Government Affairs
Orange County Business Council
You don't often get email from Learn why this is important Date: 1/1/2026 12:02:34 PM
From:" Julie Filppi"
To:

Public Comment" publiccomment@anaheim. net, "Ashleigh Aitken" AAitken@anahe im.net, "Natalie Meeks" [email protected], "Ryan Balius" [email protected], "Carlos A. Leon" CLeon@anahe im.net, " Natalie Rubalcava" [email protected], " Norma C. Kurtz" NKurtz@anahe im.net, "Kristen Maahs" [email protected]
Subject:[ EXTERNAL] Proposed Shea Development located inFestival Shopping Center Attachment: Letter to City Council Members Festival Center.doc; Warning: This email originated fromoutside the City of Anaheim. Do not click links or open attachme nts unless you recognize the sender and are expecting the message.

Mayor Aitken and City Council Representatives,
Please see the attached document regarding the proposed Shea Property Development in the Festival Shopping Center. Thank you for your careful consideration in this matter.

Respectfully,
Julie Filppi
8 Mayor Aitken and City Council Representatives:

On October 29, 2024, the City Council denied a 498-unit Hills Preserve project specifically citing an EIR showing evacuation times in the area already exceeding 3 hours. The council concluded that the proposed project would become life-threatening with the added density. The proposal of yet another 450- 600 unit project less than one mile from that project would have the same impact. I am having a hard time understanding how this proposed project is any different.

As of October 14, 2025, the California Department of Housing and Community Development HCD) officially certified Anaheim’ s Housing Element.

Anaheim is now mandated to plan for 17,454 new housing units by 2029. The Housing Element identifies “Candidate Sites” to meet this goal. As a resident in this VHFSHZ that has only one way in and one way out, I sincerely hope that one of those “ Candidate Sites” was not the potential pipeline” of a 600 unit apartment complex located in the Festival Shopping center. If this is the case, it could put a potential 1000+ vehicle blockade in front of current residents in an evacuation situation. Have we learned nothing from Paradise, Lahaina, and the Pacific Palisades? Approving this project would show a total lack of understanding of how vulnerable Anaheim residents are in a wildfire evacuation!
Per state law (SB 1035) Anaheim was required to update its Safety Element concurrently with the Housing Element. This update must specifically address wildfire risks and identify residential developments that lack at least two emergency evacuation routes.

I would urge you to deal with the current limited ingress/ egress that exists for a safe fire evacuation of the area BEFORE any additional high density building is approved. It would not be prudent to put existing and hundreds more additional residents at risk. We have a problem here that needs to be solved FIRST!
This project would have a " specific, adverse impact upon the public health or safety." This impact is significant, quantifiable, direct, and unavoidable. There is no feasible method to mitigate the impact other than disapproval.

The following two pages include factual/ legal data of interest to read prior to your vote on this issue on January 13, 2026. I sincerely thank you for your careful consideration of this project.

Many lives depend on your NO vote.

Sincerely,
Julie Filppi
8 Summary Table: Housing Law vs. Fire Zones
Law Exclusion for High Fire
Zones? How it affects Anaheim Hills
SB 330 Yes Does not apply in VHFHSZs.

SB 35 / SB 423 Yes Projects are generally ineligible in high fire risk areas.

Builder's
Remedy No (Conditional) Can proceed unless the city proves a "specific, adverse safety impact." The following was taken directly from the City of Anaheim website:

Safety Element Update
Project Update
The Anaheim City Council approved Resolution No. 2023-005 on January 10, 2023 amending the Safety Element of the General Plan
Click the link below to review the approved Safety Element document and contact SafetyLHMP@Anaheim. net with any questions.

View Safety Element
What is a Safety Element?
A Safety Element is a key component of the City’s General Plan. The purpose of the Anaheim Safety Element is to identify and include safety considerations during the decision- making and planning process by establishing goals and policies as they relate to future developments within the city. These goals and policies aim to reduce personal injury and loss of life, prevent property destruction, and reduce environmental damage throughout the community. The Safety Element focuses on addressing potential threats associated with:

Wildland / Urban Fire
Earthquake
Severe Weather (Windstorms / Extreme Heat / Drought)
Dam Failure
Landslide
Flood/Storm
Why is the City Updating the Safety Element?
Safety Elements are governed by California Government Code Section 65302( g). This set of regulations governs the how, when, and what is included in a Safety Element, and identifies the triggers for future updates. Recent additions to the code requiring the City to update the Element include:

SB 1241 ( 2014): Requires the City to address wildfire hazard issues due to the presence of Very High Fire Hazard Severity Zones ( VHFHSZ). To learn more about where these zones are located in Anaheim, view this online map.

SB 379 (2017): Requires the City to address climate adaptation and resiliency through the preparation of a vulnerability assessment or reliance on a Local Hazard Mitigation Plan that addresses climate adaptation risks and vulnerabilities.

SB 1035 (2018): Aligns the update of the Safety Element with the next Housing Element update, which shall be updated at least every eight years to address new requirements and incorporate updated information during this time.

SB 99 (2020): Requires the Safety Element to identify residential developments in any hazard area that do not have at least two emergency evacuation routes.

Here is a recent mapping of the VHFHSZ in relation to the proposed Festival Center project. It is clear that the building would be inside the VHFHSZ. Evacuation from this area is gridlocked in all directions ( currently 3+ hours) as witnessed in the 2017 evacuation from Canyon Fire 2.

PROPOSED DEVELOPMENT
You don't often get email from Learn why this is important Date: 1/6/2026 6:07:37 PM
From:" Amy Chiusolo"
To:" Public Comment" [email protected]
Subject:[ EXTERNAL] NO to the Festival development
Warning: This email originated fromoutside the City of Anaheim. Do not click links or open attachme nts unless you recognize the sender and are expecting the message.

W e get flip ped off a nd to ld to f off by tho se w ho use our stre e t as a cut- th rough to ge t to the 91 ea st boun d . If w e ne ed to le a ve our pro pe rty w e a re in the sa m e situa tio n. G od forbid w e ha ve a me dica l eme rgency or w orse and are una ble to ge t out of our ow n drivew ay . W he n w e ha d to eva cua te for th e fire in 200 8, it w a s the sca rie st da y of my life . Be in g a t home w ith m y 2 dogs a nd 3 to rto ise s and ha vin g a he lico pte r fly ove r my ho use a nd a nno unce to le a ve imme dia te ly w as te rrif ying . I pa cke d as ma ny things as I co uld a nd lo ade d my anim a ls up in th e ca r . As I drove dow n Sa nta An a C a nyo n it w as a slo w cr aw l a nd a ll I co uld se e w as smo ke a nd fla m e s in my re arvie w mirro r . Drivin g aw ay from my ho me and no t kno w ing if it w ould still be the re w a s such a sa d a stre ssf ul situ a tio n for me a nd my family. If ano the r ma jo r fire co me s th rough our a re a , ha ving this Fe stiva l C e nte r de ve lo pme nt w ill only a dd to the cha os and diff iculty of ha ving to e va cu a te . M a ny live s co uld be lo st as w e ll a s ho me s. I fee l it is se lfish for the co un cil m emb e rs of Ana he im w ho a re co nsid e rin g vo ting ye s to this proje ct. Due to the e xisting traffic issue s a nd th e un te ste d fire eva cua tio n pla n, if a ny of th e se ho using proje cts ge t a ppro ve d , w e 're he ade d for a "de a th trap " like the one se en in La ha in a , w he re pe ople bur ne d a live in the ir ca rs tryin g to e sca pe . T he co uncil me mb ers w ho cho ose to app rove this proje ct w ill be he ld pe rso na lly re sp onsib le for any lo ss of life tha t occu rs fro m an un te ste d eva cua tio n pla n.

Please do the right thing and think about the people , wildlife , community, and quality of life for the individuals who will be impacted by this reckless decision.

Sincerely,
Amy Chiusolo
m
You don't often get email from Learn why this is important Date: 1/6/2026 7:21:51 PM
From:" Maria Bessem"
To:" Public Comment" [email protected]
Subject:[ EXTERNAL] 1/13/26 Opposition to Festival Center high density housing Warning: This email originated fromoutside the City of Anaheim. Do not click links or open attachme nts unless you recognize the sender and are expecting the message.

Dear Mayor and City Council,
I am writing to express my opposition to the proposed Festival Center project due to unresolved public safety and evacuation concerns.

This area already is within a
Very High Fire Hazard zone. The limited ingress and egress compounds the danger.

Evacuation is currently a known problem, and the City ofAnaheim has not demonstrated that the Festival Center project will improve evacuation safety for current residents.

Proposed traffic or circulation measures have not been shown to significantly address evacuation reliability under emergency conditions.

Public safety must be resolved before additional density is considered.

Approving a major new development without a proven, effective evacuation plan places existing residents at increased risk.

I urge the city to deny this project because Public Safety cannot be relied upon with these conditions.

Sincerely,
Maria Bessem
8 Date: 1/6/2026 8:39:17 PM
From:" Rick Pollgreen"
To:" Public Comment" [email protected]
Subject:[ EXTERNAL] Festival apartments opposition!
Warning: This email originated from outs ide the City of Anaheim. Do not click links or open attachments unles s you recognize the sender and are expecting the mes sage.

Hi City council,
On January 13, the Anaheim City Council will cons ider a 450– 600 unit high- dens ity apartment project at the Fes tival Shopping Center, located in a Very High Fire Hazard Severity Zone with limited evacuation routes .

I URGE YOU TO VOTE NO!
Jus t months ago, City Council denied a similar 498- unit project after an EIR showed evacuation times already exceeded 3 hours , calling the added dens ity lifethreatening. This new propos al is les s than one mile away, with no infrastructure improvements, and raises the same serious safety ris ks .

State hous ing mandates do not override public safety. Evacuation gridlock is real, and we’ ve seen the cons equences in Paradis e and Lahaina. Pleas e, cons ider addres sing the evacuation routes and lack of infras tructure BEFORE adding in more cars and people.

Protect your res idents .

Say NO to uns afe development.

Thanks for lis tening.

Rick Pollgreen
You don't often get email from Learn why this is important Date: 1/7/2026 4:43:08 PM
From:"
To:" Public Comment" publiccomment@anaheim. net
Subject:[ EXTERNAL] Opposition to Festival Center Project Warning: This email originated fromoutside the City of Anaheim. Do not click links or open attachme nts unless you recognize the sender and are expecting the message.

Dear Mayor and CityCouncil,
Iam writing in strong opposition to the proposed Festival Center projectdue to unresolved public safetyand evacuation concerns in an area that has and continues to have a history of natural fire hazards, unlike other areas of Anaheim.

First and foremost, the proposed action impedes the health and safety of Anaheim residents. This area already suffers from limited ingress and egress and is located within aVeryHigh Fire Hazard SeverityZone. Evacuation is currentlya known problem and the proposed project will onlyexacerbate existing issues, particularly evacuation under emergency conditions.

No other residents ofAnaheim have had to flee their homes during wildfires only to be faced with gridlocked traffic as they tryto escape to safety. The proposed developmentwill make this type situation even more precarious, significantlyincreasing evacuation times during awildfire, and potentiallycause catastrophic loss of life. Approving a major new development without a proven, effective evacuation plan places existing residents at increased risk. Public safety must be resolved before additional densityis considered.

We get it. Traffic and development is afactof life throughoutthe cityandAnaheim Hills should not and is not exempt from this. Our streets alreadyexperience major gridlock as commuters tryto find alternatives to the 91 freeway. Each area of the cityhas different nuances, however, and the wildfire dangers in Anaheim Hills are unique and should not be ignored or pushed aside to accommodate this development.

For these reasons, I urge the Cityto denyapproval of the Festival Center until evacuation and emergencyaccess issues are fullyand transparently addressed. The CityCouncil has a moral and legal obligation to protect the life and safetyofits residents.

Sincerely,
Naomi Goodwin
ConcernedAnaheim Hills Resident
Date: 1/7/2026 5:16:09 PM
From:" Jenny Stewart"
To:" Public Comment" [email protected]
Subject:[ EXTERNAL] NO to the proposed festival center project!! You don' t often get email from Learn why this is important at https :// aka. ms /LearnAboutSenderIdentification ] Warning: This email originated from outs ide the City of Anaheim. Do not click links or open attachments unles s you recognize the sender and are expecting the mes sage.

Dear Mayor and City Council,
I am writing to expres s my oppos ition to the propos ed Fes tival Center Project due to public safety and evacuation is sues that still remain. Thes e same concerns were brought up by concerned res idents as well as the council members while discus sing the previously propos ed development in deer canyon and NOTHING has changed!! This area is located in a very high fire hazard severity zone. I have seen no evidence of the city providing improved evacuation safety for exis ting res idents , not to mention the additional res idents this project would add right in the heart of previously gridlocked areas of evacuation. Public safety mus t be addres sed and res olved before additional dens ity is even cons idered! We have been homeowners in Anaheim Hills since 1999 and love it here. Over the years we have experienced several wildfires , faced mandatory evacuations , and experienced gridlock as so many tried to es cape the area. I can' t even imagine the daily traffic on Santa Ana Canyon if the propos ed development is allowed. It is well known that many drivers take Santa Ana Canyon though Anaheim to avoid the traffic on the 91 freeway and we live right in the middle of that path. Even wors e is imagining the evacuations in the event of more wildfires . It will be impos sible to get out! Several years ago as a wildfire quickly spread I watched parents abandon their cars on the side of the road to run to get their kids from school. It was chaos! Every day our family drives on the stretch of Santa Ana Canyon that will be impacted the greates t and it's already so conges ted on a regular day. In the event of an emergency the gridlock can be catas trophic! I am urging the city to deny or at leas t delay ANY hous ing development until the public safety concerns are adequately and trans parently addres sed! Thank you for your time and attention.

Res pectfully,
Jenny Stewart
Date: 1/7/2026 5:21:25 PM
From:" Tim Tynan"
To:" Public Comment" [email protected]
Subject:[ EXTERNAL] High Density Apartment Complex
You don' t often get email from Learn why this is important at https:// aka. ms /LearnAboutSenderIdentification ] Warning: This email originated from outs ide the City of Anaheim. Do not click links or open attachments unles s you recognize the sender and are expecting the mes sage.

Pleas e vote no agains t this high dens ity apartment complex propos ed at the Festival Shopping Center.

There is jus t too much traffic on Santa Ana Canyon Road and Weir Road from local homeowners there now and from people traveling to and from work us ing thes e routes since the 91 freeway is badly conges ted, particularly at late afternoon and night.

The las t time there was a big emergency due to the fire mos t of the roads , Santa Ana Canyon where Canyon imperial Highway were gridlocked. The police and fire shut down one lane in each direction, caus ing near stands till traffic on the road. Adding that many more cars due to the number of apartment units propos ed creates a serious hazard for everybody currently living in the area.

It took me me an hour and a half to get from the Canyon Hills library around to La Palma Ave. and the entrance to the regional park where my daughter lives and we were evacuated too.

The state mandate for additional hous ing does not, and should not supers ede the safety and security of thos e living in an area already. We don’ t need a res ult and los s of life and structures similar to the Pacific Palis ades and or Pas adena/ Alta Dena fires.

Jus t vote No from a 52 year res ident of Anaheim Hills .

Thank you
Tim Tynan
You don't often get email from Learn why this is important Date: 1/7/2026 7:15:15 PM
From:" Justin Jordan"
To:" Public Comment" publiccomment@anaheim. net
Subject:[ EXTERNAL] Opposition to Festival Center - Public Safety and Evacuation Concerns Warning: This email originated fromoutside the City of Anaheim. Do not click links or open attachme nts unless you recognize the sender and are expecting the message.

Dear Mayor and City Council,
I am writing to formally oppose the propos ed Festival Center project due to unresolved public safety and evacuation concerns .

This area already suffers from limited ingress and egress and is located within a Very High Fire Hazard Severity Zone. Evacuation is currently a known problem, and the City has not demons trated that the Festival Center will improve evacuation safety for existing residents . Proposed traffic or circulation measures have not been shown to meaningfully address evacuation reliability under emergency conditions .

Approving a major new development without a proven, effective evacuation plan places existing residents at increased risk. Public safety must be resolved before additional density is considered.

For these reasons , I urge the City to deny or delay approval of the Festival Center until evacuation and emergency access issues are fully and transparently addressed.

Sincerely,
Jus tin Jorda n
Laurelwood Condo Community
Date: 1/7/2026 7:47:54 PM
From:" Arlene J Ring"
To:" Public Comment" [email protected]
Subject:[ EXTERNAL] Building at Festival
You don' t often get email from Learn why this is important at https:// aka. ms /LearnAboutSenderIdentification ] Warning: This email originated from outs ide the City of Anaheim. Do not click links or open attachments unles s you recognize the sender and are expecting the mes sage.

I strongly object to the propos ed plan to build hous ing at the location of the clos ed Edward’ s Theaters in Anaheim Hills . We need to acknowledge that it is simply not safe to put more people in this area. Thos e of us who already live there are doing our bes t to live in the new reality of cons tant threat and imminent evacuation.

Don’ t make it wors e.

Arlene Ring
You don't often get email from Learn why this is important Date: 1/7/2026 9:30:43 PM
From:" Rouhina Mehregan"
To:" Public Comment" [email protected]
Subject:[ EXTERNAL] Opposition to festival center
Warning: This email originated fromoutside the City of Anaheim. Do not click links or open attachme nts unless you recognize the sender and are expecting the message.

Opposition to Festival Center - PublicSafetyand
Evacuation Concerns
Dear Mayor and CityCouncil,
Iam writing to formally oppose the proposed Festival Center project due to unresolved public safety and evacuation concerns.

This area alreadysuffers from limited ingress and egress and is located within a VeryHighFire Hazard SeverityZone. Evacuation is currentlya known problem, and the City has not demonstrated that the Festival Center will improve evacuation safety for existing residents. Proposed traffic or circulation measures have not been shown to meaningfullyaddress evacuation reliabilityunder emergencyconditions.

Approving a major new development without a proven, effective evacuation plan places existing residents at increased risk. Public safety must be resolved before additional densityis considered
For these reasons, I urge the City to deny or delay approval of the Festival Center until evacuation and emergency access issues are fullyand transparently addressed.

Sincerely,
Rouhina Mehregan
e
Date: 1/8/2026 5:17:03 AM
From:" Keith S. Dellalonga"
To:" Public Comment" [email protected]
Subject:[ EXTERNAL] Festival Center Development
You don' t often get email from Learn why this is important at https:// aka. ms /LearnAboutSenderIdentification ] Warning: This email originated from outs ide the City of Anaheim. Do not click links or open attachments unles s you recognize the sender and are expecting the mes sage.

To Whom it May Concern,
Pleas e do not approve the Fes tival Center hous ing development proposal in Anaheim Hills. Public safety should be the firs t priority not increas ing hous ing for state mandates . This is a high fire danger area and increas ed development will reduce evacuation time potentially caus ing the los s of life.

Thank you for reading this email.

Keith Dellalonga
You don't often get email from Learn why this is important Date: 1/8/2026 5:47:55 AM
From:" Michelle MacDonald"
To:" Public Comment" publiccomment@anaheim. net
Subject:[ EXTERNAL] Opposition to Festival Center - Public Safety and Evacuation Concerns Warning: This email originated fromoutside the City of Anaheim. Do not click links or open attachme nts unless you recognize the sender and are expecting the message.

Dear Mayor and City Council,
I am writing to formally oppose the proposed Festival Center project, citing unresolved public safety and evacuation concerns that necessitate immediate attention and resolution.

This area is already characterized by limited entry and exit and is situated within a Very High Fire Hazard Severity Zone, which exacerbates existing evacuation challenges. The City has yet to demonstrate that the Festival Center will enhance evacuation safety for existing residents.

Moreover, proposed traffic or circulation measures have not been shown to effectively address evacuation reliability under emergency conditions.

Approving a major new development without a proven, effective evacuation plan would place existing residents at increased risk. Therefore, it is crucial that public safety concerns be comprehensively addressed before additional density is considered.

For these reasons, I strongly urge the City to deny or delay approval of the Festival Center until evacuation and emergency access issues are fully and transparently addressed.

Sincerely,
Michelle MacDonald
You don't often get email from Learn why this is important Date: 1/8/2026 12:33:30 PM
From:" Joy Pickett"
To:" Public Comment" [email protected]
Subject:[ EXTERNAL] Festival Project
Warning: This email originated fromoutside the City of Anaheim. Do not click links or open attachme nts unless you recognize the sender and are expecting the message.

I strongly oppose this project. Without the added cars this project would bring, it is already a difficult situation trying to leave the area if evacuating.

In addition, current traffic during rush hours is very heavy.

Please consider the needs of the current community and veto this project.

Thank you.

Joy Pickett
You don't often get email from Learn why this is important Date: 1/8/2026 4:54:56 PM
From:" Terry Hanly"
To:" Public Comment" publiccomment@anaheim. net
Subject:[ EXTERNAL] Opposition to Festival Center - Public Safety and Evacuation Concerns Warning: This email originated fromoutside the City of Anaheim. Do not click links or open attachme nts unless you recognize the sender and are expecting the message.

Dear Mayor and City Council,
I am writing to formally oppose the propos ed Festival Center project due to unresolved public safety and evacuation concerns .

This area already suffers from limited ingress and egress and is located within a Very High Fire Hazard Severity Zone. Evacuation is currently a known problem, and the City has not demons trated that the Festival Center will improve evacuation safety for existing residents . Proposed traffic or circulation measures have not been shown to meaningfully addres s evacuation reliability under emergency conditions .

Approving a major new development without a proven, effective evacuation plan places existing residents at increased risk. Public safety must be resolved before additional density is considered.

For these reasons , I urge the City to deny or delay approval of the Festival Center until evacuation and emergency access issues are fully and transparently addressed.

Sincerely,
Teresa Hanly
You don't often get email from Learn why this is important Date: 1/8/2026 6:48:04 PM
From:" Lawrence Harrison"
To:" Public Comment" [email protected]
Subject:[ EXTERNAL] Proposed development inAnaheim Hills Warning: This email originated fromoutside the City of Anaheim. Do not click links or open attachme nts unless you recognize the sender and are expecting the message.

Dear Mayor and CityCouncil,
Iam writing to formally oppose the proposed Festival Center project due to unresolved public safety and evacuation concerns.

This area alreadysuffers from limited ingress and egress and is located within a VeryHighFire Hazard Zone. Evacuation is currentlyaknown problem, and the City has not demonstrated that the proposed Festival Center development will improve evacuation safety for existing - or future - residents. Proposed traffic or circulation measures have notbeen shown to meaningfullyaddress evacuation reliabilityunder emergencyconditions.

Approving a major new development without a proven, effective evacuation plan places the existing populace at increased risk of a horrible death byfire. Public safetymustbe resolved before additional densityis considered.

For these reasons, I urge the City to deny approval of the Festival Center apartment complex until evacuation and emergency access issues are fullyand transparentlyaddressed.

Thank you for your attention.

Sincerely,
Lawrence Harrison, MD
Sent from my iPhone
You don't often get email from Learn why this is important Date: 1/9/2026 2:39:40 PM
From:" Katherine Novich"
To:" Public Comment" [email protected]
Subject:[ EXTERNAL] Anaheim Hills Festival Center Project - OPPOSED! Warning: This email originated fromoutside the City of Anaheim. Do not click links or open attachme nts unless you recognize the sender and are expecting the message.

Dear Mayor and City Council
I am OPPOSED to the Festival Center Development Project!!! My BIGGEST concern is evacuating during a fire. Our area is located in a Very High Fire Hazard Severity Zone. Timely evacuation is currently a known problem. The residents don't need additional cars on Santa Ana Canyon Road during normal days, but imagine what it's like when you have to evacuate for a fire. Sitting still, in traffic, while trees and brush are burning all around, fearing for your life and the lives of your family. I've been in that situation, likely you have not.

Approving a major new development without a proven, effective evacuation plan places residents at increased risk.

Public safety must be resolved before additional density to the area is considered.

For these reasons, I urge the City to deny or delay approval of the Festival Center until traffic implications and evacuation/ emergency access issues are fully addressed.

Thank you,
Katherine Novich
35+ Year Anaheim Hills resident
Some people who received this message don't often get email from awalsh@ocbc. org. Learn why this is important Date: 1/9/2026 3:10:28 PM
From:" Theresa Bass"
To:" Public Comment" publiccomment@anaheim. net
Subject: FW: [EXTERNAL] RE: OCBC Letter re: Anaheim Hills Festival Attachment: Updated_OCBC support_Anaheim Hills Festival Redevelopment.pdf; From: Amanda Wal sh < aw alsh@ocbc. org>
Se nt: Fri day, January 9, 2026 3:05 PM
To: The re sa Bass < TBass@anaheim. net>; Amanda Lauffer < ALauffe r@anahe im. ne t> Cc: Paulina Alvare z <pal varez@ocbc. org>
Subje ct: [ EXTERN AL] RE: OCBC Le tte r re: Anahe im Hi lls Fe stival Warning: This email originated fromoutside the City of Anaheim. Do not click links or open attachme nts unless you recognize the sender and are expecting the message.

Good Afte rnoon:

For proce dural purpose s, I am attaching OCBC’ s support letter of the Anaheim Hills Festi val rede ve lopme nt that has be en reage ndi ze d for this upcoming council me eting.

Thank you kindl y,
Amanda Walsh
Vice President of Government Affairs
Orange County Business Council
awalsh@ocbc. org
714- 292- 7080
3210 El Camino Real, Ste 100, Irvine 92602
ocbc.org | locationoc.com
From: Paulina Alvare z
Se nt: Monday, De ce mbe r 15, 2025 10: 45: 31 AM
To:

Cc: Amanda Wal sh < aw alsh@ocbc. org>
Subje ct: OCBC Le tte r re : Anaheim Hills Festi val _City Counci l Meeti ng December 16 He llo,
Ple ase find OCBC’ s support letter re : Anaheim Hills Festi val Redeve lopme nt attache d.

If you have any spe cif ic questi ons, please let me know.

Thank you,

PAULINA ALVAREZ
Government Affairs Manager
Orange County Business Council
palvarez@ocbc. org
626-588-7565
PLEASE NOTE OCBC’ S NEW ADDRESS: 3210 El Camino Real, Ste 100, Irvine 92602 ocbc.org | locationoc. com
2 Park Plaza, Suite 100, Irvine, CA 92614 | P 949.476.2242 | F 949.476.0443 | www.ocbc.org

THE LEADING VOICE OF BUSINESS IN ORANGE COUNTY
January , 2025
City of Anaheim
200 S Anaheim Blvd
Anaheim CA 92805
Re: Anaheim Hills Festival Redevelopment – DEV2023 -00043 Dear Mayor and Councilmembers,
For more than three decades, the Orange County Business Council (OCBC) has served as the leading voice for Orange County’s business community. Our work centers on advancing economic development, expanding housing opportunities, and supporting infrastructur e investments that strengthen the region’ s long-term competitiveness. On behalf of our members, we are pleased to express strong support for the Anaheim Hills Festival redevelopment project scheduled for consideration on November 17.

Shea Properties, in partnership with Vestar, has put forward a thoughtful andforward -looking plan that reinvests in an important community asset while preserving the character that Anaheim Hills residents value. The proposed redesign creates a modern, vibrant destination with new retail and dining options, enhanced pedestrian access, and inviting open spaces that promote community gathering and quality of life.

Importantly, the project also responds to the significant housing needs in District 6 by integrating much -needed apartment homes into an area with strong access to retail, services, and amenities. This type of mixed -use investment is essential to supporting workforce stability, ensuring long-term economic vitality, and meeting the expectations of a changing marketplace.

Shea Properties has a longand successful history of delivering high -quality developments throughout Orange County. Their track record, combined with Vestar’ s operational expertise, ensures this project will attract strong tenants, create local jobs, and generate sustainable revenue that benefits Anaheim for decades.

OCBC strongly supports the Anaheim Hills Festival redevelopment and encourages the City Council to approve this important investment.

Thank you for your consideration.

Sincerely,
Amanda Walsh
Vice President of Government Affairs
Orange County Business Council
You don't often get email from Learn why this is important Date: 1/7/2026 7:46:18 AM
From:" Anthony Chiusolo"
To:" Public Comment" [email protected]
Subject:[ EXTERNAL] FW: NO to the Festival development
Warning: This email originated fromoutside the City of Anaheim. Do not click links or open attachme nts unless you recognize the sender and are expecting the message.

To Whom it May Concern,
Please reconsider your yes vote for the Festival Center project. Adding this additional housing development will be horrible for our community. Being a resident of Anaheim Hills for the past 27 years, we have seen traffic become a nightmare. There are numerous days, each month, where traffic is so bad on our street that we cannot even get into our driveway coming home from work. We get flipped off and told to f off by those who use our street as a cut-through to get to the 91 east bound. If we need to leave our property we are in the same situation. God forbid we have a medical emergency or worse and are unable to get out of our own driveway. When we had to evacuate for the fire in 2008, it was the scariest day of my life. Being at home with my 2 dogs and 3 tortoises and having a helicopter fly over my house and announce to leave immediately was terrifying. Ipacked as many things as Icould and loaded my animals up in the car. As Idrove down Santa Ana Canyon it was a slow crawl and all Icould see was smoke and flames in my rearview mirror. Driving away from my home and not knowing if it would still be there was such a sad a stressful situation for me and my family. If another major fire comes through our area, having this Festival Center development will only add to the chaos and difficulty of having to evacuate. Many lives could be lost as well as homes. Ifeel it is selfish for the council members of Anaheim who are considering voting yes to this project. Due to the existing traffic issues and the untested fire evacuation plan, if any of these housing projects get approv ed, we're headed for a "death trap" like the one seen in Lahaina, where people burned alive in their cars trying to escape. The council members who choose to approve this project will be held personally responsible for any loss of life that occurs from an untested evacuation plan.

Please do the right thing and think about the people, wildlife, community, and quality of life for the individuals who will be impacted by this reckless decision.

Sincerely,
Anthony Chiusolo
You don't often get email from Learn why this is important Date: 1/10/2026 10:27:34 AM
From:" Hozair Syed"
To:" Public Comment" [email protected]
Subject:[ EXTERNAL] Opposition for building 450 appt complex infestival drive area Warning: This email originated fromoutside the City of Anaheim. Do not click links or open attachme nts unless you recognize the sender and are expecting the message.

Hi we bring the resident of Belsomet community in Anaheim Hills strongly oppose the proposal or acceptance to build apartment complex in this area of festival drive due to having serious congestion in any case of evacuation of fire breakout alert and already this area is full of his capacity now , no more place for others to build or live
Dr Hozair Syed
Member Belsomet community
You don't often get email from Learn why this is important Date: 1/10/2026 10:47:46 AM
From:" Frances Chase"
Subject:[ EXTERNAL] Urgent: Life-Safety Risks of Shea Properties Festival CenterApartment Project Warning: This email originated fromoutside the City of Anaheim. Do not click links or open attachme nts unless you recognize the sender and are expecting the message.

Dear Anaheim City Council Members,
I am writing as a resident of Anaheim Hills for over 30 years regarding the proposed Shea Properties ~450+ unit apartment complex at the Festival Shopping Center. I have supported the growth of our community through donations to local churches and schools, but I cannot support a project of this scale that creates such serious risk.

Our streets are already dangerously constrained during emergencies. Residents vividly remember the 2017 fire evacuation— streets were gridlocked, and families with children, elderly loved ones, and pets faced real fear while trying to escape. Every fire season anxiety levels increase, as neighbors discuss their fears that Anaheim Hills may realize a weather driven fire catastrophe as so many others.

Adding 1,000+ cars fromthis development could turn a serious emergency into another potential tragedy. The previously proposed Deer Canyon project, which posed the same risks, was rightly rejected.

I urge the Council to prioritize the safety ofAnaheim Hills families and reconsider this project before it puts lives at risk.

Sincerely,
Frances Chase
CONFIDENTIALITY STATEMENT: The information contained in this email and any attached documents isconfidential, privil eged and only for the informati on of the intended recipient and may not be used, published or redistributed without the prior written consent of If you received thi smessage by mistake, please repl y to this message and follow with itsdeletion.

From: Stacy McGe e <
Se nt: Fri day, January 9, 2026 6:17 PM
To: Natal ie Me eks < N Me eks@anahe im. ne t>
Subje ct: [ EXTERN AL] Fe stival Ce nter Proje ct - Li ability on Anaheim Ci ty Council You don't often get email from Learn why this is important Warning: This email originated fromoutside the City of Anaheim. Do not click links or open attachme nts unless you recognize the sender and are expecting the message.

Dear Council Member Natalie Meeks,
I am writing to formally oppose the proposed Festival Center project due to unresolved public safety and evacuation concerns.

This area already suffers from limited ingress and egress and is located within a Very High Fire Hazard Severity Zone. Evacuation is currently a known problem and the City has not demonstrated that the Festival Center will improve evacuation safety for existing residents. Propose traffic or circulation measures have not been shown to meaningfully address evacuation reliability under emergency conditions.

Approving a major new development without a proven, effective evacuation plan places existing residents a increased risk. Public safety must be resolved before additional density is considered.

M y family and I have lived in the 92807 zip code for 24 years. We have experienced many fires in the area and have been forced to evacuate. The traffic in the surrounding areas is often gridlocked. It is terrifying to imagine adding residential projects that would increase the population in the area.

For these reasons, I urge you to deny or delay approval of the Festival Center until evacuation and emergency access issues are fully and transparently addressed.

W ith kind regards,
Stacy McGee
3 From: Kathe rine N ovich <
Se nt: Fri day, January 9, 2026 2:53 PM
To: Natal ie Me eks < N Me eks@anahe im. ne t>
Subje ct: [ EXTERN AL] Anahe im Hills Festi val Cente r Project - OPPOSED! You don't often get email from Learn why this is important Warning: This email originated fromoutside the City of Anaheim. Do not click links or open attachme nts unless you recognize the sender and are expecting the message.

Dear Ms. Meeks,
I am OPPOSED to the Festival Center Development Project!!! My BIGGEST concern is evacuating during a fire. Our area is located in a Very High Fire Hazard Severity Zone. Timely evacuation is currently a known problem. The residents don't need additional cars on Santa Ana Canyon Road during normal days, but imagine what it's like when you have to evacuate for a fire. Sitting still, in traffic, while trees and brush are burning all around, fearing for your life and the lives of your family. I've been in that situation, likely you have not.

Approving a major new development without a proven, effective evacuation plan places residents at increased risk.

Public safety must be resolved before additional density to the area is considered.

For these reasons, I urge the City to deny or delay approval of the Festival Center until traffic implications and evacuation/ emergency access issues are fully addressed.

Thank you,
Katherine Novich
Year Anaheim Hills resident
From: Je nny Ste w art <
Se nt: We dne sday, January 7, 2026 6:13 PM
To: Natal ie Me eks < N Me eks@anahe im. ne t>
Subje ct: [ EXTERN AL] NO to the proposed Festi val proje ct! You don't often get email from Learn why this is important at https:// aka. ms/LearnAboutSenderIdentification ] Warning: This email originated from outside the City of Anaheim. Do not click links or open attachments unless you recognize the sender and are expecting the message.

Dear Council Woman Meeks,
I am writing to express my opposition to the proposed Festival Center project due to public safety and evacuation issues that still remain. These same concerns were brought up by concerned residents as well as the council members while discussing the previously proposed development in deer canyon and NOTHING has changed!! This area is located in a very high fire hazard severity zone. I have seen no evidence of the city providing improved evacuation safety for existing residents, not to mention the additional residents this project would add right in the heart of previously gridlocked areas of evacuation. Public safety must be addressed and resolved before additional density is even considered! We have been homeowners in Anaheim Hills since 1999. Over the years we have experienced several wildfires, faced mandatory evacuations, and experienced gridlock as so many tried to escape the area. I can't even imagine the daily traffic on Santa Ana Canyon if the proposed development is allowed. It is well known that many drivers take Santa Ana Canyon though Anaheim to avoid the traffic on the 91 freeway and we live right in the middle of that path. Even worse is imagining the evacuations in the event of more wildfires. It will be impossible to get out! Several years ago as a wildfire quickly spread I watched parents abandon their cars on the side of the road to run to get their kids from school. It was chaos! Every day our family drives on the stretch of Santa Ana Canyon that will be impacted the greatest and it's already so congested on a regular day. In the event of an emergency the gridlock can be catastrophic!
I am urging the city to deny or at least delay ANY major housing development until the public safety concerns are adequately and transparently addressed! Thank you for your time and attention.

Respectfully,
Jenny Stewart
From: Dougl as R Robbins <
Se nt: Fri day, January 2, 2026 3:27 PM
To: Natal ie Me eks < N Me eks@anahe im. ne t>
Subje ct: [ EXTERN AL] Fw: Anahe im Hi lls Fe stival Apartme nt Compl ex Warning: This email originated fromoutside the City of Anaheim. Do not click links or open attachme nts unless you recognize the sender and are expecting the message.

Honorable Council Member,
I am writing you again, in opposition to this Project. That's how important it to me for you to vote NO on this Project. The area of this Project is located in a High to Very High Fire Risk Zone Area. The traffic in this area is very bad , particularly on Eastbound Santa Ana Canyon at Weir Canyon road, and Weir Canyon heading North where it intersects with Santa Ana Canyon. In the evenings these lanes already get blocked by all the cars trying to avoid the 91 Freeway. I live in zone 8 and these are my evacuation lanes. Couple that already bad traffic in the evening with a Santa Ana Wind driven fire. Iwill already not be able to safely evacuate! Your own planning commissions assessment for evacuation when the Council was consideri ng approval for the Deer Canyon Project last year was it would take 3 Hours. Iam telling you we do not have 3 hours to evacuate in a Santa Wind Fire condition! There will be gridlock, and we will burn to death in our cars! We have experienced this gridlock before and were unable to move, lucky for us the wind changed direction and sent the Fire to Yorba Linda. But what about next time? And you are considering adding this Development to an already awful situation? Another 1000 cars to evacuate? What the heck! That makes no sense! And if you think the 1000 cars is equal to the traffic form the Movie Theatre. That would be a false assumption. That theatre never had that kind of traffic, that's why the theatre closed. And the people that did go there were local residents. And nobody's going to the theatre during a raging wild fire! Lets use some common sense here.

Last year with the Deer Canyon Project the Council voted NO on that Project. This project is geographically in nearly the same area, and nearly the same as far as the amount of traffic added to the already unrealistic evacuation times in the event of a fire.

So this project should be voted down, just like the other! Why are we talking about all these new building projects without addressing the lack of infrastructure to safely evacuate in a wildfire! As a council member, public SAFETY should be your number one concern! And this project posts a huge safety risk to residents in the area! Ask your police and fire chief if they would recommend this project from a safety perspective! VOTE NO!
Thank You
Douglas Robbins
Forwarded Message -----
From: Douglas R Robbins <
To: Natalie Meeks < nmeeks@anaheim. net>
Sent: Thursday, December 4, 2025 at 01:50:13 PM PST
Subject: Anaheim Hills Festival Apartment Complex
Honorable Council Member Meeks,
I attended the Planning Commission Meeting on November 17 regarding this Project. Much to my surprise, they voted 6-1 in favor of this project. To say I am disappointed, would be an understatement. Again they put money and big corporati ons, over the Safety of their residents. This is unacceptable!
First of all, the EIR study regarding wildfires. Studied a scenario where a fire started in Deer Canyon which is West of the proposed project and went on to say that this would add a total of 7 additional minutes to the evacuation time of the area. That is BS, and it does not take into consideration the Santa Ana Winds. I have lived here for 35 years and have never once needed to evacuate because of a fire in Deer Canyon. The ONLY time an evacuation was ever necessary, is when a Fire is accompanied by a Santa Ana Wind Condition. Which always is a threat from the East pushing West, that is the way the winds blow during these conditions. There is plenty of dry brush in the Canyon to the East of the Festival Center to catch fire. which seems to happen every time we have Santa Ana Conditions. The EIR should be reflecting these wind conditions in relati on to Fire, not in a perfect scenario as it was presented.

Second , it was mentioned that the additional 1000 + vehicles this Project would add was a mute point. Sayi ng that the study they used to determine the traffic that the Regal Theatre experienced was based off the 1000 parking spots designated for the theatre. Therefore the traffic was equivalent to the same amount. While the parking lot may have been bui lt to accommodate that amount of traffic, that was not the reality of traffic to the theatre. My wife and Iwent there many times and we were the only ones in the theatre, or sometimes another couple. That's why the Theatre closed, there simply was not enough people attending to keep the place open. And I would also add that the people that did visit the theatre where mostly local residents. Therefore adding no additional vehicles to the area, as the apartments would. So Idon't believe that study is accurate either, it seems like these studies where biased in the applicants favor.

Third, discussing the lack of infrastructure to Safely evacuate the Residents. There was discussion of the "Know Your Way Plan". While I appreciate the effort to make things better in an evacuation event, this will do little to solve the issue we face.

People know how to get in to their neighborhoods, and the options are few. People are going to go whatever way they think is going to move better at the time, given the circumstances they are facing at that moment. And this doesn't include the people that have an elderly loved one at home, or a child at school that may need help getting evacuated. Sorry, it isn't going to do much to help, if anything. The planning commission inquired about about the Feasibility of the proposed Fairmont Bridge. It was discovered that there is no current plan to work on this project. It alone would not fix the problem anyway.

By your own planning staff assessment for the Deer Canyon Project last year, it would take 3 hours to evacuate. In a Santa Wind condition, we DO NOT have 3 hours to evacuate! We will burn to death in our cars, unable to move due to gridlock! This condition is not acceptable, and now you considering adding more traffic from this development! Public Safety has to be the number one concern! NO new building of homes should even be considered, until the infrastructure issue is completely dealt with and resolved. But there doesn't really seem to be any appetite to do that.

Next time the winds come screaming through the Canyon pushing an uncontrolled fire, I invite you to come up here to my neighborhood and experience it for yourself. It is very scary! Its not a matter of IF, we will have a Lahaina Event, its more of When, we will have it. Ask your Police and Fire Captains if they think this is a potentially dangerous situation! Please vote NO on this Project! Literally, my life or my neighbors life could depend on your vote for this Project.

Thank you!
Douglas Robbins
5 From: De Wayne Fi lppi <
Se nt: Tue sday, De ce mbe r 30, 2025 12: 29 PM
To: Natal ie Me eks < N Me eks@anahe im. ne t>
Subje ct: [ EXTERN AL] Shae Properties Festi val Redeve lopme nt Project You don't often get email from Learn why this is important Warning: This email originated fromoutside the City of Anaheim. Do not click links or open attachme nts unless you recognize the sender and are expecting the message.

Ms Meeks,
The proposed redevelopment of the Anaheim Hills Festival Center by Shea Properties would advers ely impac t the safety of loc al residents by exacerbating an already untenable wildfire evacuation crisis. W hile the developer proposes replacing a mostly vac ant cinema with 447 multi- family units, they are essentially replacing a "transient" commercial population with a permanent res idential population of approximately 1,664 people and their associated vehicles, all located within a Very High Fire Hazard Severity Zone VHFHSZ).

The FEIR explicitly admits the " elephant in the room": that our neighborhood already fac es evacuation times exceeding three hours. It further admits that this project will add nearly 1,700 new residents and their vehicles, extending that gridlock by another 24 minutes (a dubious claim for many hundreds of cars thrown into gridlock). In a fast- moving fire— like the 2017 Canyon Fire 2—a 24- minute delay is the difference between life and death.

The City’ s apparent current reasoning— that a 24- minute increase is "less than significant" because the situation is already critic al— is a moral and legal fallacy. Adding more people to a failed system does not mitigate the problem; it compounds it. By approving this density, the City is normalizing a life-safety deficiency. This is not " incremental growth"; it is the intentional expans ion of a known hazard zone.

The developer suggests that mitigations such as improved internal circulation and adherenc e to wildfire res ilience building codes ( MM HAZ- 4, HAZ- 5, and HAZ- 9) render this impact acceptable. However, no amount of internal " circulation" or fire- resis tant roofing solves the physics of a "bottleneck" at the primary exit points of the Hills. The project residents, no doubt grateful for the wildfire resilienc e of the building, would soon find themselves in the 3 hour escape queue with the rest of us. Under CEQA, when a bas eline condition is already at a level of critical failure, any additional impact is inherently 'significant.' I urge the Council to consider the recent legal precedent in People v. County of Lake ( 2024), where the court held that " bare conclusions" are insufficient to dismiss evacuation risks. Furthermore, under SB 1241, the City is mandated to avoid " unreasonable wildfire risks." Choosing to add residents to a "trap" area while residents are already fac ing three- hour delays is the definition of an unreasonable risk and an odd form of compassion. Also, any proposed infrastructure improvements must be shown effective for current residents before adding more victims to the pyre. I urge you to prioritize the lives of current ( and new) res idents and disapprove the General Plan and Specific Plan amendments for this project.

DeW ayne Filppi
6 You don't often get email from Learn why this is important Date: 1/10/2026 11:52:54 AM
From:" Abner Pinedo"
To:" Public Comment" [email protected]
Subject:[ EXTERNAL] Oppose High Density Apartments at The Festival Center Warning: This email originated fromoutside the City of Anaheim. Do not click links or open attachme nts unless you recognize the sender and are expecting the message.

Dear City Council Member - City of Anaheim
Oppose High Density Apartments at The Festival Center
I’m writing this letter as a good neighbor and responsible citizen, living in Anaheim Hills since 1993 (more than 32 years)
I am writing to call your attention to a proposed ~450+ unit apartment complex at the Festival shopping center. Shea Properties seeks approval from the Anaheim City Council Those of us that lived in Anaheim Hills during the fire evacuation of 2017 will recall the utter traffic gridlock in our streets. The drive from Belsomet to Santa Ana Canyon took more than 45 minutes! Consider how adding another ~1000+ cars to this area might impact our collective ability to evacuate safely in another fire.

The City Council will vote on this project on TUESDAY, JANUARY 13, 5 PM at Anaheim City Council Chambers.

For the above reasons I OP POSE to this Project at The Festival Center Rev Abner Pinedo / Owner
l
You don't often get email from Learn why this is important Date: 1/10/2026 2:40:24 PM
From:" Susan Montagnino"
To:" Public Comment" publiccomment@anaheim. net
Subject:[ EXTERNAL] Fwd: Proposed 450 unit apartment complex Warning: This email originated fromoutside the City of Anaheim. Do not click links or open attachme nts unless you recognize the sender and are expecting the message.

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From: Susan Montagnino <
Date: January 10, 2026 at 2:39:28 PM PST
To: kmaahs@anaheim. net
Subject: Fwd: Proposed 450 unit apartment complex
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From: Susan Montagnino <
Date: January 10, 2026 at 2:38:32 PM PST
To: nkurtz@anaheim. net
Subject: Fwd: Proposed 450 unit apartment complex
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Begin forwarded message:

From: Susan Montagnino <
Date: January 10, 2026 at 2:37:39 PM PST
To: nrubalcava@anaheim. net
Subject: Fwd: Proposed 450 unit apartment complex
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Begin forwarded message:

From: Susan Montagnino <
Date: January 10, 2026 at 2:36:45 PM PST
To: [email protected]
Subject: Fwd: Proposed 450 unit apartment complex
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From: Susan Montagnino <
Date: January 10, 2026 at 2:33:35PM PST
To: cleon@anaheim. net
Subject: Fwd: Proposed 450 unit apartment complex
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Begin forwarded message:

From: Susan Montagnino <
Date: January 10, 2026 at 2:22:14 PM PST
To: nmeeks@anaheim. net
Subject: Proposed 450 unit apartment complex
To Whom It May Concern,
We are Anaheim Hills residents writing to express my opposition to the proposed 450 unit apartment complex in the Festival Center. This area is already extremelu congested and has high traffic volume. It is already difficult to evacuate
in the event of a fire or other emergencies. Adding additional residents will add to that difficulty and increase the danger. Please vote no on this proposal.

Respectfully,
Joseph Montagnino
Susan Montagnino
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You don't often get email from Learn why this is important Date: 1/11/2026 8:42:58 AM
From:" Tannis Soto"
To:" Public Comment" publiccomment@anaheim. net
Subject:[ EXTERNAL] Opposition to Festival Center's proposed apartment building - Public Safety and Evacuation Concerns Warning: This email originated fromoutside the City of Anaheim. Do not click links or open attachme nts unless you recognize the sender and are expecting the message.

Dear Mayor Ashleigh Aitken and City Council Members,
I write to you all to express my opposition to the proposed Festival Center project as I am deeply concerned about the ramifications of the project due to public safety and evacuation concerns.

In light of what occurred in the catastrophic and devastating Pacific Palisades fire I believe the only thing that prevented a similar fire occurring in Anaheim Hills is that there was not a shift in the winds. Plain and simple...... we were lucky last time. With the gridlock that happened the last time we had a fire in Anaheim Hills if you add hundreds of more people and their cars to a similar situation the time frame for evacuating puts at risk lives significantly more especially if we were to experience winds similar to what happened in the Palisades. This area already has experienced fires which proved there is limited ingress and egress making evacuation a known problem.

Approving a major new development without a proven, effective evacuation plan places us residents at increased risk. The safety of the residents of Anaheim Hills must be paramount to allowing a new apartment development to be built.

I ask that you all deny the approval of the Festival Center' s proposed building of apartments or alternatively delay it until evacuation and emergency access issues are fully resolved so as to ensure the safety of all of us in Anaheim Hills.

I ask that the owners of the property look beyond and consider building other services for the community on that property. We don't need more housing up here. We could use more restaurants and services. We no longer have a theatre in Anaheim Hills since the Festival Theatre and Cinema City theatres closed. We miss the theatres.

Independently fromexpressing my above concerns, I want to propose that the planning departme nt incollaboration with Cal Trans and the Highway Patrol consider coming up with a plan inthe event of a catastrophic fire event to close down access to the 91 freeway at outlying areas and block certain entrances to the freeway so that only entrances in Anaheim Hills or Yorba Linda would be open so as to allowresidents to flee the area ina significantly shorter amount of time . Furthermore , given the close proximity of Santa Ana Canyon Road and the 91 Fwy additional access points fromSanta Ana Canyon Road onto the 91 Fwy could be planned and built so as to be opened up as needed to allowvehicles to get onto the 91 freeway fasterthus getting people away fromany fire faster. I believe this should be done whether or not the proposed project goes forward of not.

Thank you for your service to our community.

Peace,
Tannis Dunbar- Soto
7 You don' t often get email from Learn why this is important Date: 1/11/ 2026 1:08: 42 PM
From:" Kathy Vargas"
To:" Public Comment" publiccomment@anaheim. net
Subject:[ EXTERNAL] Fwd: Festival Center Project
Warning: This email originated from outside the City of Anaheim. Do not click links or open attachments unless you recognize the sender and are expecting the message.

Begin forwarded message:

From: KathyVargas <
Date: January 11, 2026 at 11:54:43AM PST
To: Publiccomments@anaheim. net
Subject: Festival Center Project
Thank you,
Very Sincerely,
Frank and Kathy Vargas
Martin Rd
Anaheim Hills, Ca 92808
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You don't often get email from Learn why this is important Date: 1/11/2026 5:23:10 PM
From:" corliss williford"
To:" Public Comment" publiccomment@anaheim. net
Subject:[ EXTERNAL] Opposition to proposed 450-600 unit apartment complex in the Festival Center Warning: This email originated fromoutside the City of Anaheim. Do not click links or open attachme nts unless you recognize the sender and are expecting the message.

As residents of Anaheim Hills we are adamantly opposed to any attempt to build a high-density 450-unit apartment complex at the Festival shopping center where Shea Properties is seeking approval from the Anaheim City Council for a high-density apartment structure in the location of the former Regal Edwards theater.

Stanley Williford
Corliss Williford
Date: 1/11/2026 7:57:00 PM
From:" Judy Gorden"
To:" Public Comment" [email protected]
Subject:[ EXTERNAL] Deer Canyon Development
You don' t often get email from Learn why this is important at https:// aka. ms /LearnAboutSenderIdentification ] Warning: This email originated from outs ide the City of Anaheim. Do not click links or open attachments unles s you recognize the sender and are expecting the mes sage.

My hus band and I are 29-year res idents living above the Fes tival and have watched the traffic build as the area has been developed. We exit are area from Kennedy onto Monte Vis ta. The traffic is already noticeable. Can’ t imagine what it might be like with a pos sible addition of 1000 cars us ing that route to and from the propos ed apartment complex .

Daily conges tion would be an is sue in and of its elf but in cas e of an evacuation , would be impos sible. We would be better off going into our neighbor’ s pool than evacuating on the roadways .

Pleas e do not approve this propos ed development.

Judy and Dale Gorden
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You don't often get email from Learn why this is important Date: 1/12/2026 7:40:50 AM
From:" Janet Sabato"
To:" Public Comment" [email protected]
Subject:[ EXTERNAL] Deer Canyon- Opposition to Festival Center - Public Safety and Evacuation Concerns Warning: This email originated fromoutside the City of Anaheim. Do not click links or open attachme nts unless you recognize the sender and are expecting the message.

Dear Mayor and CityCouncil,
Iam writing to formallyoppose the proposed Festival Center project due to unresolved publicsafetyand evacuation concerns.

This area already suffers from limited ingress and egress and is located within a VeryHigh Fire Hazard Severity Zone. Evacuation is currently a known problem, and the Cityhas not demonstrated thatthe Festival Center will improve evacuation safetyfor existing residents. Proposed traffic or circulation measures have not been shown to meaningfully address evacuation reliability under emergency conditions.

Approving a major new developmentwithoutaproven, effective evacuation plan places existing residents at increased risk. Public safetymust be resolved before additional density is considered.

For these reasons, 1 urge the Cityto denyor delayapproval of the Festival Center until evacuation and emergencyaccess issues are fullyand transparently addressed.

Sincerely,
JanetSabato
Hunter’s Point Neighborhood
You don't often get email from Learn why this is important Date: 1/12/2026 9:13:52 AM
From:" Andrew Winger"
To:" Public Comment" [email protected]
Subject:[ EXTERNAL] 1/13/26 Meeting Comment
Warning: This email originated fromoutside the City of Anaheim. Do not click links or open attachme nts unless you recognize the sender and are expecting the message.

This is in regards to the Festival Project at the next city council meeting. It is listed as item 16 on the agenda.

Dear Anaheim City Council,
This letter is in opposition to the propos ed Festival project due to Fire Evacuation time concerns .

When it comes to Fire Safety, nobody goes shopping when they think their house is going to burn down. Instead, everybody goes home. This Festival Project is going to add to the fire evacuation danger if you rezone from commerc ial to residential . You absolutely cannot rezone this if you unders tand this fundamental difference.

This project is the same size, scope, and location as the Deer Canyon project, which was denied due to strong concerns about Fire Evacuation times . You must apply the same logic to this proposed project and deny it.

The Know Your Way plan is flawed and untested. You cannot use that as an excuse for building residential units in a high fire danger zone. You must solve the current infrastructure problem if you are interested in saving lives . The 3+ hour evacuation times remain unchanged and unacceptable.

You have had over 1 year since the Deer Canyon project to take ANY steps to fix the infrastructure problem but have taken ZERO steps .

The residents of Anaheim are in the same amount of danger in the event of a Fire than we were a year ago.

Please deny this project. If you truly want it, please make the necessary infrastructure changes before you allow more buildings to be built.

Thanks ,
Andrew Winger
7 Date: 1/12/2026 4:00:25 PM
From:" Linda Pigott"
To:" Public Comment" [email protected]
Subject:[ EXTERNAL] Festival Center Housing
You don' t often get email from Learn why this is important at https :// aka. ms/ LearnAboutSenderIdentification ] Warning: This email originated from outs ide the City of Anaheim. Do not click links or open attachments unles s you recognize the sender and are expecting the mes sage.

I am concerned about additional hous ing replacing the movie theatre area at the Fes tival Center. I’d like to hear what our police and fire departments say about our public safety regarding this matter. I was here when Serrano was evacuated and there were not enough lanes for us to get out in a timely matter. Maybe a smaller hous ing footprint? It’ s a was te of space jus t having the theatre' s there but something smaller would be more ideal.

Thank you,
Linda
Some people who received this message don't often get email from Learn why this is important Date: 1/13/2026 6:26:12 AM
From:" Peyman, Nader"
To:" Ashleigh Aitken" [email protected]
Cc:

Natalie Meeks" [email protected], " Ryan Balius" [email protected], " Carlos A. Leon" [email protected], " Natalie Rubalcava" [email protected], "Norma C. Kurtz" [email protected], Kristen Maahs" [email protected], "Public Comment" publiccomment@anaheim. net Subject:[ EXTERNAL] URGENT: Opposition to Shea Properties Festival Center Project – Life Safety & Evacuation Concerns Warning: This email originated fromoutside the City of Anaheim. Do not click links or open attachme nts unless you recognize the sender and are expecting the message.

Dear Mayor Aitken and Members of the Anaheim City Council, As a resident of the Belsomet community and a licensed Professional Engineer (PE), I am writing to formally express my strong opposition to the proposed high-density apartment complex at the Festival shopping center.

While Iunderstand the need for housing, this specific location presents critical Life Safety and Infrastructure risks that have not been adequately mitigated:

Evacuation Gridlock: During the 2017 fires, our community experienced total gridlock. Adding a projected 1,000+ additional vehicles to this specific bottleneck will dangerously compromise the City’s ability to evacuate Anaheim Hills residents during the next inevitable wildfire.

Infrastructure Strain: As an engineer, I am concerned that the existing road density and utility infrastructure in the Canyon area were not designed to support this level of high-density residential concentrati on at this specific site.

Precedent: This Council correctly recognized these same safety risks when the Deer Canyon project was voted down. The Festival Center project carries the same—if not greater—risks to public safety.

I urge you to prioritize the safety of existing residents and vote NO on the Shea Properties proposal today.

Sincerely,
Nader Peyman, MSME, PE Resident of Belsomet ( District 6) Regards,
Nader Peyman, M SME, PE, LEED® AP BD+ C
You don't often get email from Learn why this is important Date: 1/13/2026 7:34:55 AM
From:" Nafar, Rose"
To:" Ashleigh Aitken" [email protected]
Cc:

Dear Mayor Aitken and Members of the Anaheim City Council, As a resident of the Belsomet community and Civil Engineer, Iam submitting formal opposition to the proposed high-density residential development at the Festival Shopping Center based on unresolved life-safety and infrastructure capacity concerns.

Although the demand for additional housing is acknowledged, the proposed site presents significant technical constraints that have not been adequately mitigated through the current project design or supporting studies:

Emergency Evacuation Capacity: The local roadway network serving the project area experienced full operational failure during the 2017 wildfire events, resulting in complete traffic gridlock. The introduction of an estimated 1,000 or more additional vehicle trips within this constrained network will materially reduce available evacuation capacity and increase clearance times during future wildfire emergencies.

Transportation and Utility Infrastructure Limitations: Based on established engineering standards, the existing roadway geometry, access limitations, and utility systems within the Canyon area were not designed to accommodate high-density residential loading at this location.

No feasible off-site improvements have been identified that would sufficiently mitigate these deficiencies.

Consistency with Prior Council Determinations: The City Council previously determined that similar evacuation and infrastructure constraints warranted denial of the Deer Canyon project. The Festival Shopping Center proposal presents equal or greater technical risk with respect to emergency access, evacuation performance, and public safety.

For these reasons, I respectfully recommend denial of the Shea Properties proposal unless and until the applicant can demonstrate, through verifiable engineering analysis, that emergency evacuation performance and infrastructure capacity meet acceptable public safety standards.

Thank you,
Belsomet ( District 6)
Rose Nafar
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You don't often get email from Learn why this is important Date: 1/13/2026 9:24:28 AM
From:" Cindy Hanke"
To:" Public Comment" [email protected]
Subject:[ EXTERNAL] Festival building
Warning: This email originated fromoutside the City of Anaheim. Do not click links or open attachme nts unless you recognize the sender and are expecting the message.

To whom it may concern, I have lived in my home here in Anaheim Hills by the Festival Center for 28 years. I would like to go to the meeting tonight to speak however, I am not well today.

Please know that when we tried to escape the fires in the past, we could not get out of our neighborhood. It took me an hour and a half to get from my house, which is half a mile from Target to get to Target . I am very concerned with adding on all of these new residents that we will all die in a fire.

Jim and Cindy Hanke
s
You don't often get email from Learn why this is important Date: 1/13/2026 9:53:15 AM
From:" Mary Heistand"
To:" Public Comment" [email protected]
Subject:[ EXTERNAL] Festival Center Development
Warning: This email originated fromoutside the City of Anaheim. Do not click links or open attachme nts unless you recognize the sender and are expecting the message.

As I am unable to atte nd the City Council me eting toni ght, I would like to expre ss my opposi tion to the proje ct at the Fe sti val Ce nte r. Many of us felt the une ase from the high winds over the we ekend. We remember the past fire s in our are a and the difficul ties in evacuati on. We appre ciate all me asure s the city of Anahe im has take n, but the evacuation plan is not enough. Traff ic issue s must be addre sse d be fore more housing is bui lt. Thank you for consideri ng publ ic safety.

Mary He istand
Re side nt of The Hi ghlands De velopment- 92808
You don't often get email from shreyasp@mitchtsailaw. com. Learn why this is important Date: 1/13/2026 10:33:09 AM
From:" Shreyas Pingle"
To:

Public Comment" publiccomment@anaheim. net, " City Clerk" [email protected], " Amanda Lauffer" [email protected], " Mitchell M. Tsai Attorney at Law, P.C." [email protected], "Jeremy Herwitt" [email protected]
Subject:[
EXTERNAL] WSRCC - [City of Anaheim, Anaheim Hills Festival CenterSpecific Plan Amendment] - Comment Letter Submission for 1/13 City Council Hearing
Attachment: 20260113_WSRCC_Anaheim_AnaheimHillsFestivalCtr_CCMeeting_CL_Signed.pdf; Warning: This email originated fromoutside the City of Anaheim. Do not click links or open attachme nts unless you recognize the sender and are expecting the message.

Hello,
Please find attached a comment letter my office is submitting regarding the Anaheim Hills Festival Specific Plan Amendment Project for the 1/13 City Council Meeting, agenda item 16, as well as the project's associated FEIR.

We would greatly appreciate confirmation ofreceipt of this email and its attachment.

Best,
Shreyas Pingle, Paralegal and Case Manager
Mitchell M. Tsai Law Firm - Environmental and Land Use Litigation 139 South Hudson Avenue Suite 200
Pasadena, CA 91101
Phone: (626) 314- 3821
Fax: (626) 389-5414
Email: shreyasp@mitchtsailaw. com
Website: https://www.mitchtsailaw. com
CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages accompanying it, may contain confidential information that is legally privileged. If you are not the intended recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that any disclosure, copying, distribution or use of any of the information contained in or attached to this message is STRICTLY PROHIBITED and may violate applicable laws including the Electronic Communications Privacy Act. If you have received this transmission in error, please immediately notify us by reply e-mail at shreyasp@mitchtsailaw. com or by telephone at (626) 314- 3821 and destroy the original transmission and its attachments without reading them or saving them to disk.

P: (626) 314- 3821
E: info@mitchtsailaw. com
Mitchell M. Tsai
Law Firm
139 S. Hudson Ave., Suite 200
Pasadena, California 91101

VIA E-MAIL
January 13, 2026
City Council
City of Anaheim
Council Chamber, City Hall
200 South Anaheim Boulevard
Anaheim, California 92805
Ph: (714) 765-5139
Em: publiccomment@anaheim. net
Em: [email protected]
Amanda Lauffer, Senior Planner
Planning and Building Department
City of Anaheim
200 S. Anaheim Boulevard, Suite 162
Anaheim, CA 92805
Ph: (714) 765-4479
Em: [email protected]
RE: City of Anaheim’s January 13, 2026, City Council Meeting – Agenda Item No. 16 – Anaheim Hills Festival Specific Plan Amendment Project – Final Environmental Impact Report (SCH# 2024010859)
Dear Mayor Aitken, Honorable Councilmembers, and Amanda Lauffer, On behalf of the Western States Regional Council of Carpenters (“ Western Carpenters” or “WSRCC”), our firm is submitting these comments in connection with the City of Anaheim’s (“ City”) January 13, 2026, City Council hearing for the Anaheim Hills Festival Specific Plan Amendment (“ Project”) (Agenda Item No. 16), and the Final Environmental Impact Report (“ FEIR”) associated therewith. This correspondence restates and expands upon the issues raised in WSRCC’s written comments dated December 16, 2025, submitted in connection with the previous continued City Council hearing on the Project of the same date.

The Notice of Availability of the Project’s Draft EIR (“DEIR”) describes the Project as follows:

The proposed project would establish a new Development Area (DA 5) within the existing boundaries of the Anaheim Hills Festival Specific Plan to accommodate residential uses in combination with the site's existing commercial development. DA 5 would be created by reallocating land from the existing DA 2, reducing its size from approximately 48 acres to City of Anaheim – Anaheim Hills Festival Center Project January 13, 2026

Page 2 of 36 ends

31.8 acres. The resulting 16.2-acre area would form the new DA 5. All proposed development would be confined to DA 5, which encompasses Assessor’s Parcel Numbers ( APNs) 354-451-19 and 354-451-32. The overall exterior boundary of the Specific Plan would remain unchanged.

The proposed project includes the demolition of an approximately 62,676- square-foot cinema within DA 5 and the development of a new 447-unit multiple-family rental residential community. The proposed multiplefamily community would consist of a four-story residential building, wrapped around a five-level parking structure with one subterranean level.

All residential units are single-story and include one-bedroom, twobedroom, and three-bedroom options with private patios or balconies.

Project amenities include a clubhouse, two swimming pools, courtyards, a fitness center, leasing office, and mail area. In addition to the project amenities, the applicant is proposing an enclosed outdoor public dog park along Festival Drive and public bluff park along the edge of the newly proposed DA 5 and the lower tier of the shopping center, DA 2, which would be open to residents of the community and the general public.

NOA, p. 1.

The Western States Regional Council of Carpenters is a labor union representing almost 90,000 union carpenters in 12 states, including California, and has a strong interest in well-ordered land use planning and in addressing the environmental impacts of development projects.

Individual members of the Western Carpenters live, work, and recreate in the City and surrounding communities and would be directly affected by the Project’s environmental impacts.

The Western Carpenters expressly reserves the right to supplement these comments at or prior to hearings on the Project, and at any later hearing and proceeding related to this Project. Gov. Code, § 65009, subd. (b); Pub. Res. Code, § 21177, subd. (a); see Bakersfield Citizens for Local Control v. Bakersfield ( 2004) 124 Cal.App.4th 1184, 1199- 1203; see also Galante Vineyards v. Monterey Water Dist. (1997) 60 Cal.App.4th 1109, 1121.

The Western Carpenters incorporates by reference all comments raising issues regarding the Environmental Impact Report (EIR) submitted prior to certification of City of Anaheim – Anaheim Hills Festival Center Project January 13, 2026

Page 3 of 36 ends

the EIR for the Project. See Citizens for Clean Energy v City of Woodland ( 2014) 225 Cal.App.4th 173, 191 (finding that any party who has objected to the project’s environmental documentation may assert any issue timely raised by other parties).

Moreover, the Western Carpenters requests that the City provide notice for any and all notices referring or related to the Project issued under the California Environmental Quality Act (CEQA) (Pub. Res. Code, § 21000 et seq.), and the California Planning and Zoning Law (“ Planning and Zoning Law”) (Gov. Code, §§ 65000–65010). California Public Resources Code Sections 21092.2, and 21167(f) and California Government Code Section 65092 require agencies to mail such notices to any person who has filed a written request for them with the clerk of the agency’s governing body.

I. THE CITY SHOULD REQUIRE THE USE OF A LOCAL
WORKFORCE TO BENEFIT THE COMMUNITY’S ECONOMIC

DEVELOPMENT AND ENVIRONMENT
The City should require the Project to be built using a local workers who have graduated from a Joint Labor-Management Apprenticeship Program approved by the State of California, have at least as many hours of on-the-job experience in the applicable craft which would be required to graduate from such a state-approved apprenticeship training program, or who are registered apprentices in a state-approved apprenticeship training program.

Community benefits such as local hire can also be helpful to reduce environmental impacts and improve the positive economic impact of the Project. Local hire provisions requiring that a certain percentage of workers reside within 10 miles or less of the Project site can reduce the length of vendor trips, reduce greenhouse gas emissions, and provide localized economic benefits. As environmental consultants Matt Hagemann and Paul E. Rosenfeld note:

A]ny local hire requirement that results in a decreased worker trip length from the default value has the potential to result in a reduction of construction-related GHG emissions, though the significance of the reduction would vary based on the location and urbanization level of the project site.

March 8, 2021 SWAPE Letter to Mitchell M. Tsai re Local Hire Requirements and Considerations for Greenhouse Gas Modeling.

City of Anaheim – Anaheim Hills Festival Center Project January 13, 2026

Page 4 of 36 ends

Workforce requirements promote the development of skilled trades that yield sustainable economic development. As the California Workforce Development Board and the University of California, Berkeley Center for Labor Research and Education concluded:

L]abor should be considered an investment rather than a cost—and investments in growing, diversifying, and upskilling California’s workforce can positively affect returns on climate mitigation efforts. In other words, well-trained workers are key to delivering emissions reductions and moving California closer to its climate targets.1
Furthermore, workforce policies have significant environmental benefits given that they improve an area’s jobs-housing balance, decreasing the amount and length of job commutes and the associated greenhouse gas (GHG) emissions. In fact, on May 7, 2021, the South Coast Air Quality Management District found that that the “[ u]se of a local state-certified apprenticeship program” can result in air pollutant reductions.2 Locating jobs closer to residential areas can have significant environmental benefits.

As the California Planning Roundtable noted in 2008:

People who live and work in the same jurisdiction would be more likely to take transit, walk, or bicycle to work than residents of less balanced communities and their vehicle trips would be shorter. Benefits would include potential reductions in both vehicle miles traveled and vehicle hours traveled.3
Moreover, local hire mandates and skill-training are critical facets of a strategy to reduce vehicle miles traveled (VMT). As planning experts Robert Cervero and 1 California Workforce Development Board ( 2020) Putting California on the High Road: A Jobs and Climate Action Plan for 2030 at p. ii, available at https:// laborcenter. berkeley. edu/ wp-content/ uploads/ 2020/ 09/ Putting- California- on-the-High- Road. pdf. 2 South Coast Air Quality Management District ( May 7, 2021) Certify Final Environmental Assessment and Adopt Proposed Rule 2305 – Warehouse Indirect Source Rule – Warehouse Actions and Investments to Reduce Emissions Program, and Proposed Rule 316 – Fees for Rule 2305, Submit Rule 2305 for Inclusion Into the SIP, and Approve Supporting Budget Actions, available at http:// www.aqmd. gov/ docs/ defaultsource/ Agendas/ Governing- Board/ 2021/ 2021- May7- 027.pdf?sfvrsn= 10. 3 California Planning Roundtable ( 2008) Deconstructing Jobs- Housing Balance at p. 6, available at https:// cproundtable. org/ static/ media/ uploads/ publications/ cpr-jobshousing. pdf City of Anaheim – Anaheim Hills Festival Center Project January 13, 2026

Page 5 of 36 ends

Michael Duncan have noted, simply placing jobs near housing stock is insufficient to achieve VMT reductions given that the skill requirements of available local jobs must match those held by local residents.4 Some municipalities have even tied local hire and other workforce policies to local development permits to address transportation issues. Cervero and Duncan note that:

In nearly built-out Berkeley, CA, the approach to balancing jobs and housing is to create local jobs rather than to develop new housing. The city’s First Source program encourages businesses to hire local residents, especially for entry- and intermediate-level jobs, and sponsors vocational training to ensure residents are employment-ready. While the program is voluntary, some 300 businesses have used it to date, placing more than 3,000 city residents in local jobs since it was launched in 1986. When needed, these carrots are matched by sticks, since the city is not shy about negotiating corporate participation in First Source as a condition of approval for development permits.

Recently, the State of California verified its commitment towards workforce development through the Affordable Housing and High Road Jobs Act of 2022, otherwise known as Assembly Bill No. 2011 (“ AB2011”). AB2011 amended the Planning and Zoning Law to allow ministerial, by-right approval for projects being built alongside commercial corridors that meet affordability and labor requirements.

The City should consider utilizing local workforce policies and requirements to benefit the local area economically and to mitigate greenhouse gas, improve air quality, and reduce transportation impacts.

II. THE CITY SHOULD IMPOSE TRAINING REQUIREMENTS FOR
THE PROJECT’S CONSTRUCTION ACTIVITIES TO PREVENT
COMMUNITY SPREAD OF COVID-19 AND OTHER INFECTIOUS

DISEASES
Construction work has been defined as a Lower to High-risk activity for COVID-19 spread by the Occupations Safety and Health Administration. Recently, several 4 Cervero, Robert and Duncan, Michael ( 2006) Which Reduces Vehicle Travel More: JobsHousing Balance or Retail- Housing Mixing? Journal of the American Planning Association 72 (4), 475- 490, 482, available at http:// reconnectingamerica. org/ assets/ Uploads/ UTCT825.pdf.

City of Anaheim – Anaheim Hills Festival Center Project January 13, 2026

Page 6 of 36 ends

construction sites have been identified as sources of community spread of COVID19.5 Western Carpenters recommend that the Lead Agency adopt additional requirements to mitigate public health risks from the Project’s construction activities. Western Carpenters requests that the Lead Agency require safe on-site construction work practices as well as training and certification for any construction workers on the Project Site.

In particular, based upon Western Carpenters’ experience with safe construction site work practices, Western Carpenters recommends that the Lead Agency require that while construction activities are being conducted at the Project Site:

Construction Site Design:

The Project Site will be limited to two controlled entry points.

Entry points will have temperature screening technicians taking temperature readings when the entry point is open.

The Temperature Screening Site Plan shows details
regarding access to the Project Site and Project Site logistics for conducting temperature screening.

A 48-hour advance notice will be provided to all trades prior to the first day of temperature screening.

The perimeter fence directly adjacent to the entry points will be clearly marked indicating the appropriate 6-foot social distancing position for when you approach the screening area. Please reference the Apex temperature screening site map for additional details.

There will be clear signage posted at the project site directing you through temperature screening.
5 Santa Clara County Public Health ( June 12, 2020) COVID- 19 CASES AT

CONSTRUCTION SITES HIGHLIGHT NEED FOR CONTINUED VIGILANCE IN SECTORS THAT HAVE REOPENED, available at https:// www. sccgov. org/ sites/ covid19/ Pages/ press- release- 06-12-2020- cases- at-construction- sites. aspx.

City of Anaheim – Anaheim Hills Festival Center Project January 13, 2026

Page 7 of 36 ends

Provide hand washing stations throughout the construction site.

Testing Procedures:

The temperature screening being used are non-contact
devices.

Temperature readings will not be recorded.

Personnel will be screened upon entering the testing center and should only take 1-2 seconds per individual.

Hard hats, head coverings, sweat, dirt, sunscreen or any other cosmetics must be removed on the forehead before
temperature screening.

Anyone who refuses to submit to a temperature screening or does not answer the health screening questions will be
refused access to the Project Site.

Screening will be performed at both entrances from 5:30 am to 7:30 am.; main gate [ ZONE 1] and personnel gate
ZONE 2]
After 7:30 am only the main gate entrance [ ZONE 1] will continue to be used for temperature testing for anybody gaining entry to the project site such as returning personnel, deliveries, and visitors.

If the digital thermometer displays a temperature reading above 100.0 degrees Fahrenheit, a second reading will be taken to verify an accurate reading.

If the second reading confirms an elevated temperature, DHS will instruct the individual that he/ she will not be allowed to enter the Project Site. DHS will also instruct the individual to promptly notify his/ her supervisor and his/ her human resources (HR) representative and provide them with a copy of Annex A.

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Planning
Require the development of an Infectious Disease
Preparedness and Response Plan that will include basic
infection prevention measures (requiring the use of personal protection equipment), policies and procedures for prompt identification and isolation of sick individuals, social distancing ( prohibiting gatherings of no more than 10
people including all-hands meetings and all-hands lunches) communication and training and workplace controls that
meet standards that may be promulgated by the Center for Disease Control, Occupational Safety and Health
Administration, Cal/ OSHA, California Department of
Public Health or applicable local public health agencies.6 The United Brotherhood of Carpenters and Carpenters International Training Fund has developed COVID-19 Training and Certification to ensure that Carpenter union members and apprentices conduct safe work practices. The Agency should require that all construction workers undergo COVID-19 Training and Certification before being allowed to conduct construction activities at the Project Site.

Western Carpenters has also developed a rigorous Infection Control Risk Assessment ICRA”) training program to ensure it delivers a workforce that understands how to identify and control infection risks by implementing protocols to protect themselves and all others during renovation and construction projects in healthcare environments.7
ICRA protocols are intended to contain pathogens, control airflow, and protect patients during the construction, maintenance and renovation of healthcare facilities.

ICRA protocols prevent cross contamination, minimizing the risk of secondary infections in patients at hospital facilities.
6 See also The Center for Construction Research and Training, North America’ s Building Trades Unions ( April 27 2020) NABTU and CPWR COVIC- 19 Standards for U.S Constructions Sites, available at https:// www. cpwr. com/ sites/ default/ files/ NABTU_ CPWR_ Standards_ COVID- 19.pdf; Los Angeles County Department of Public Works 2020) Guidelines for Construction Sites During COVID- 19 Pandemic, available at https:// dpw.lacounty. gov/ building- and- safety/ docs/ pw_guidelines- construction- sites.pdf. 7 For details concerning Western Carpenters’ ICRA training program, see https:// www. swmsctf. org/ courses/ icra- best- practices- in-health- care- construction/ City of Anaheim – Anaheim Hills Festival Center Project January 13, 2026

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The City should require the Project to be built using a workforce trained in ICRA protocols.

III. THE CALIFORNIA ENVIRONMENTAL QUALITY ACT
CEQA is a California statute designed to inform decision-makers and the public about the potential significant environmental effects of a project. 14 California Code of Regulations (“ CEQA Guidelines”), § 15002, subd. (a)(1).8 At its core, its purpose is to “inform the public and its responsible officials of the environmental consequences of their decisions before they are made. Thus, the EIR ‘protects not only the environment but also informed self-government[.]’” Citizens of Goleta Valley v.

Board of Supervisors ( 1990) 52 Cal.3d 553, 564 (internal citation omitted).

To achieve this purpose, CEQA mandates preparation of an Environmental Impact Report (“ EIR”) for projects so that the foreseeable impacts of pursuing the project can be understood and weighed. Communities for a Better Environment v. Richmond ( 2010) 184 Cal. App. 4th 70, 80. The EIR requirement “ is the heart of CEQA.” CEQA Guidelines, § 15003(a).

CEQA directs public agencies to avoid or reduce environmental damage, when possible, by requiring alternatives or mitigation measures. CEQA Guidelines, § 15002, subds. (a)(2)-(3); see also Berkeley Keep Jets Over the Bay Committee v. Board of Port Commissioners of the City of Oakland (2001) 91 Cal.App.4th 1344, 1354; Laurel Heights Improvement Assn. v. Regents of University of California (1988) 47 Cal.3d 376, 400. The Environmental Impact Report (EIR) serves to provide public agencies and the public in general with information about the effect that a proposed project is likely to have on the environment and to “identify ways that environmental damage can be avoided or significantly reduced.” CEQA Guidelines, § 15002, subd. (a)(2).

A public agency must prepare an EIR whenever substantial evidence supports a “ fair argument” that a proposed project “ may have a significant effect on the environment.” Pub. Res. Code, §§ 21100, 21151; CEQA Guidelines, §§ 15002, subds. f)(1)-(2), 15063; No Oil, supra, 13 Cal.App.3d at p. 75; Communities for a Better Environment v. California Resources Agency ( 2002) 103 Cal.App.4th 98, 111-112. If the 8 The CEQA Guidelines, codified in Title 14 of the California Code of Regulations, section 15000 et seq., are regulatory guidelines promulgated by the state Natural Resources Agency for the implementation of CEQA. Pub. Res. Code, § 21083. The CEQA Guidelines are given “ great weight in interpreting CEQA except when . . . clearly unauthorized or erroneous.” Center for Biological Diversity v. Dept. of Fish & Wildlife ( 2015) 62 Cal.4th 204, 217.

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project has a significant effect on the environment, the agency may approve the project only upon finding that it has “ eliminated or substantially lessened all significant effects on the environment where feasible” and that any unavoidable significant effects on the environment are “ acceptable due to overriding concerns” specified in Public Resources Code section 21081. See CEQA Guidelines, §§ 15092, subds. (b)(2)(A)-(B).

Essentially, should a lead agency be presented with a fair argument that a project may have a significant effect on the environment, the lead agency shall prepare an EIR even though it may also be presented with other substantial evidence that the project will not have a significant effect. CEQA Guidelines, §§ 15064(f)(1)-(2); see No Oil, supra, 13 Cal.App.3d at p. 75 (internal citations and quotations omitted). Substantial evidence includes “ enough relevant information and reasonable inferences from this information that a fair argument can be made to support a conclusion, even though other conclusions might also be reached.” CEQA Guidelines, § 15384, subd. (a).

The EIR has been described as “ an environmental ‘alarm bell’ whose purpose it is to alert the public and its responsible officials to environmental changes before they have reached ecological points of no return.” Berkeley Keep Jets Over the Bay v. Bd. of Port Comm’rs. (2001) 91 Cal. App. 4th 1344, 1354 (“ Berkeley Jets”); County of Inyo v. Yorty 1973) 32 Cal. App. 3d 795, 810.

The preparation and circulation of an EIR is more than a set of technical hurdles for agencies and developers to overcome. Communities for a Better Environment v. Richmond 2010) 184 Cal.App.4th 70, 80 (quoting Vineyard Area Citizens for Responsible Growth, Inc. v. City of Rancho Cordova ( 2007) 40 Cal.4th 412, 449-450). The EIR’s function is to ensure that government officials who decide to build or approve a project do so with a full understanding of the environmental consequences and, equally important, that the public is assured those consequences have been considered. Id. For the EIR to serve these goals it must present information so that the foreseeable impacts of pursuing the project can be understood and weighed, and the public must be given an adequate opportunity to comment on that presentation before the decision to go forward is made. Id.

A strong presumption in favor of requiring preparation of an EIR is built into CEQA.

This presumption is reflected in what is known as the “ fair argument” standard under which an EIR must be prepared whenever substantial evidence in the record supports a fair argument that a project may have a significant effect on the environment. Quail City of Anaheim – Anaheim Hills Festival Center Project January 13, 2026

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Botanical Gardens Found., Inc. v. City of Encinitas (1994) 29 Cal.App.4th 1597, 1602; Friends of “ B” St. v. City of Hayward (1980) 106 Cal.3d 988, 1002.

Further, it is the duty of the lead agency, not the public, to conduct the proper environmental studies. “ The agency should not be allowed to hide behind its own failure to gather relevant data.” Sundstrom, supra, 202 Cal.App.3d at p. 311.

Deficiencies in the record may actually enlarge the scope of fair argument by lending a logical plausibility to a wider range of inferences.” Ibid; see also Gentry v. City of Murrieta (1995) 36 Cal.App.4th 1359, 1382 (lack of study enlarges the scope of the fair argument which may be made based on the limited facts in the record).

Thus, refusal to complete recommended studies lowers the already low threshold to establish a fair argument. The court may not exercise its independent judgment on the omitted material by determining whether the ultimate decision of the lead agency would have been affected had the law been followed. Environmental Protection Information Center v. Cal. Dept. of Forestry ( 2008) 44 Cal.4th 459, 486 (internal citations and quotations omitted). The remedy for this deficiency would be for the trial court to issue a writ of mandate. Ibid.

While the courts review an EIR using an ‘abuse of discretion’ standard, the reviewing court is not to uncritically rely on every study or analysis presented by a project proponent in support of its position. Berkeley Keep Jets, supra, 91 Cal.App.4th at p. 1355 quoting Laurel Heights, supra, 47 Cal.3d at pp. 391, 409 fn. 12) (internal quotations omitted). A clearly inadequate or unsupported study is entitled to no judicial deference. Ibid. Drawing this line and determining whether the EIR complies with CEQA’s information disclosure requirements presents a question of law subject to independent review by the courts. Sierra Club v. County of Fresno ( 2018) 6 Cal.5th 502, 515; Madera Oversight Coalition, Inc. v. County of Madera ( 2011) 199 Cal.App.4th 48, 102, 131. As the First District Court of Appeal has previously stated, prejudicial abuse of discretion occurs if the failure to include relevant information precludes informed decision-making and informed public participation, thereby thwarting the statutory goals of the EIR process. Berkeley Keep Jets, supra, 91 Cal.App.4th at p. 1355 (internal quotations omitted).

Both the review for failure to follow CEQA’s procedures and the fair argument test are questions of law, thus, the de novo standard of review applies. Vineyard Area Citizens for Responsible Growth v. City of Rancho Cordova ( 2007) 40 Cal.4th 412, 435.

Whether the agency’s record contains substantial evidence that would support a fair City of Anaheim – Anaheim Hills Festival Center Project January 13, 2026

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argument that the project may have a significant effect on the environment is treated as a question of law. Consolidated Irrigation Dist., supra, 204 Cal.App.4th at p. 207; Kostka and Zischke, Practice Under the Environmental Quality Act (2017, 2d ed.) at § 6.76.

Section 15088.5(a) of the CEQA Guidelines provides that an EIR must be recirculated whenever there is disclosure of significant new information. Significant new information includes: (1) disclosure of a new significant environmental impact resulting from the project or from a new proposed mitigation measure; (2) disclosure of a substantial increase in the severity of an environmental impact unless mitigation measures are adopted that reduce the impact to a level of insignificance; and (3) disclosure of a feasible project alternative or mitigation measure considerably different from others previously analyzed which would clearly lessen the significant environmental impacts of the project which the project proponents decline to adopt.

Id.

Additionally, an EIR must be recirculated when it is so fundamentally inadequate and conclusory in nature that meaningful public review and comment is precluded. Id. citing Mountain Lion Coalition v. Fish & Game Com. ( 1989) 214 Cal.App.3d 1043].

Here, as discussed below, the FEIR for the Project fails to substantiate all of its conclusions to allow meaningful public review and comment, provide adequate mitigation measures, and fully assess all pertinent environmental factors. Accordingly, this comment letter discloses significant new information, necessitating revision and recirculation of the Project’s EIR.

IV. THE PROJECT’S EIR IS INADEQUATE UNDER CEQA AND

SHOULD BE REVISED AND RECIRCULATED
A. The FEIR Fails to Support Its Findings with Substantial Evidence CEQA requires that an EIR identify and discuss the significant effects of a Project, how those significant effects can be mitigated or avoided. CEQA Guidelines § 15126.2; PRC §§ 21100(b)(1), 21002.1(a). If a project has a significant effect on the environment, an agency may approve the project only upon finding that it has eliminated or substantially lessened all significant effects on the environment where feasible” and that any unavoidable significant effects on the environment are acceptable due to overriding concerns.” CEQA Guidelines § 15092(b)(2) (A–B). Such findings must be supported by substantial evidence. CEQA Guidelines § 15091(b).

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When new information is brought to light showing that an impact previously discussed in the EIR but found to be insignificant with or without mitigation in the EIR’s analysis has the potential for a significant environmental impact supported by substantial evidence, the EIR must consider and resolve the conflict in the evidence.

See Visalia Retail, L.P. v. City of Visalia (2018) 20 Cal.App.5th 1, 13, 17; see also Protect the Historic Amador Waterways v. Amador Water Agency ( 2004) 116 Cal. App. 4th 1099, 1109. While a lead agency has discretion to formulate standards for determining significance and the need for mitigation measures— the choice of any standards or thresholds of significance must be “ based to the extent possible on scientific and factual data and an exercise of reasoned judgment based on substantial evidence.” CEQA Guidelines § 15064(b); Cleveland Nat'l Forest Found. v. San Diego Ass'n of Gov'ts 2017) 3 Cal. App. 5th 497, 515; Mission Bay Alliance v. Office of Community Inv. & Infrastructure ( 2016) 6 Cal. App. 5th 160, 206. And when there is evidence that an impact could be significant, an EIR cannot adopt a contrary finding without providing an adequate explanation along with supporting evidence. East Sacramento Partnership for a Livable City v. City of Sacramento ( 2016) 5 Cal. App. 5th 281, 302.

Here, for the reasons discussed in detail below, the EIR fails to comply with the foregoing requirements.

1. The EIR Fails to Conduct Adequate Study, Analysis, and Mitigation of the Project’s Potentially Signficant Noise Impacts The EIR for the Project concludes that the Project will result in less than significant noise and vibration impacts to surrounding sensitive receptors based, in part, on its conclusion that receiver locations R3 and R4 would be the “ nearest receiver locations” for purposes of its analysis of the Project’s construction noise impacts.

DEIR, pp. 4.13-11 – 4.13-13, Tables 4.13-6 and 4.13-7.) However, in reaching this conclusion, the DEIR, by its own studies, determined that the sensitive receptors in R3 and R4 would be exposed to construction noise levels in excess of the City’s standard 65 dBA CNEL threshold of significance. See DEIR, p. 4.13-13, Tables 4.13- 6 and 4.13-7. Moreover, the DEIR’s receiver locations R3 and R4 are positioned at nearly the furthest edges of the Overlook at Anaheim Hills Apartments development senior apartment homes (“ the Overlook”) – located directly across S. Festival Drive from the proposed Project, which accounts for the nearest sensitive receptors to the Project site.

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Notably, the DEIR finds that the most significant anticipated construction noise impacts presented by the Project will be attributable to noise from demolition activity carrying to the R3 and R4 receiver locations at the easternmost and northernmost perimeters of the Overlook. However, by selecting noise study locations R3 and R4 to calculate the anticipated noise exposure values for the residents of the Overlook, the DEIR assessed the only furthest potential locations at the Overlook property from the core of the demolition work that will need to occur at the existing movie theater structure on the Project site. Thus, the DEIR failed to properly position receiver locations to account for the full scope of the Project’s potential construction noise impacts, in addition to admitting that, notwithstanding that failure, the Project will exceed the City’s significance threshold for noise impacts. Thus, the EIR has underreported the Project’s potential noise impacts based on the improper placement of noise measurement equipment at L3/ R3 and L4/ R4. To accurately characterize the Project’s potential noise impacts, the DEIR should have studied and assessed potential noise impacts for a receiver location at the Overlook that is substantially more proximate to the existing movie theater structure and the demolition to occur to it, as depicted below:

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In its response to WSRCC’s comments on potential noise impacts, the FEIR takes the position that the Project’s exceedances of the City’s noise significance thresholds would be short-term, intermittent, and restricted to the City’s allowed construction hours under Anaheim Municipal Code Section 6.70.010. Therefore, construction noise impacts were determined to be less than significant, and no mitigation is required.” FEIR, p. 16.

Thus, the FEIR appears to rest its conclusion regarding the Project’s construction noise impacts being less than significant primarily on the City’s Municipal Code section 6.70.010 exempting daytime construction activities from the City’s Noise Ordinance. However, a determination that regulatory compliance will be sufficient to prevent significant adverse impacts must be based on a project-specific analysis of potential impacts and the effect of regulatory compliance. See Californians for Alternatives to Toxics v. Department of Food & Agric. (2005) 136 Cal. App. 4th 1; see also Ebbetts Pass Forest Watch v Department of Forestry & Fire Protection ( 2008) 43 Cal. App. 4th 936, 956. Here, the EIR provides no adequate supporting study, documentation, or analysis that otherwise provides substantial evidence for its apparent conclusion that, because the City’s Municipal Code contains an exemption from its Noise Ordinance for construction noise, construction noise during daytime hours would not be subject to any thresholds of significance whatsoever, and by extension, that no mitigation is required for noise impacts that would otherwise be significant under the City’s enacted significance threshold.

The City’s November 18, 2025, responses to WSRCC’s prior comments on this issue Attachment 23 to City’s December 16, 2025, Staff Report) fail to address this critical point. The FEIR provides no quantitative data and analysis demonstrating that, because the Project’s construction noise will allegedly be “ intermittent, short term, and confined to hours when construction noise is expressly permitted by City law,” the Project’s noise impacts fall below the applicable threshold of significance and no mitigation is required under CEQA. To apply the City’s flawed reasoning on this issue yields the conclusion that any extreme level of noise caused by the Project’s construction work, no matter the volume or duration (e.g., demolition activity), would result in a less than significant impact because the City’s municipal code contains an exception from the established noise thresholds for construction activities during daytime hours. However, this noise threshold exemption for construction activities in the City’s code does not excuse the City from its obligations under CEQA to conduct City of Anaheim – Anaheim Hills Festival Center Project January 13, 2026

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proper forecasting and analysis of the full scope of the severity of the Project’s construction noise impacts, including by properly selecting receiver locations for nearby sensitive receptors, and then determining whether an actual, quantifiable threshold of significance would be exceeded by such activities. The City’s ongoing failure to incorporate such study and analysis in the EIR for the Project as part of any determination regarding the potential significance of the Project’s noise impacts continues to violate CEQA.

Despite this ongoing failure to adequately support its study, analysis, and improper reliance on regulatory compliance in determining that the Project would not result in significant construction noise impacts, the EIR further proceeds to offer absolutely nothing in the way of any mitigation measures for the Project’s admitted potentially significant noise impacts. Indeed, despite acknowledging the Project’s expected exceedance of the City’s noise significance thresholds during its construction phase, the EIR fails to include and incorporate even basic noise mitigation measures such as the implementation of temporary and moveable noise barriers along the southwestern edge of the proposed Project site to dampen construction noise and shield the nearby sensitive receptors residing at the Overlook from potentially significant impacts.

WSRCC maintains that the continuing failure of the EIR to account for these impacts and mitigate them renders it deficient and in violation of CEQA.

Accordingly, WSRCC reiterates and expands upon its prior comments that the EIR admits that the Project’s noise impacts are potentially significant, and yet, it improperly does not provide for any mitigation to reduce its anticipated significant noise impacts. This correspondence therefore provides significant new information based on substantial evidence of the Project’s potentially significant noise impacts, such that the EIR must now be revised and recirculated to correct the deficiencies in its study, analysis, and mitigation of said impacts. As such, and absent revision and recirculation of the EIR to include added noise mitigation measures that demonstrably reduce the Project’s construction noise impacts below the threshold of significance, most particularly for the senior citizens residing at the Overlook, the Project will continue to violate CEQA in the context of its noise impacts.

B. The DEIR Improperly Relies Exclusively on Regulatory Compliance in Its Assessment of Biological Resources Impacts The DEIR notes that construction of the Project would require removal of 211 existing on-site trees located throughout the Project site. (IS, p. 30.) While the DEIR City of Anaheim – Anaheim Hills Festival Center Project January 13, 2026

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notes the potential for the removal of these trees to affect nesting and/ or special status bird species ( see DEIR p. 4.4-9 – “ The existing trees have the potential to support nesting migratory birds that are protected by the MBTA and CFGC.”), the DEIR for the Project then proceeds to conduct no study or analysis whatsoever of the Project’s Biological Resources impacts, while inexplicably determining that the Project’s baseline Biological Resources impacts will be “ Less Than Significant” before mitigation. See DEIR, p. ES-9. The DEIR goes on to rely entirely upon its purported Regulatory Compliance Measure RCM BIO-1 (Nesting Migratory Birds) to dispose of any potential concerns over such impacts, concluding that no actual mitigation is required to achieve less than significant impacts. See DEIR pp. 4.4-8 – 9.

RCM BIO-1 provides as follows:

To prevent inadvertent disturbance to potential nesting migratory birds, a qualified biologist shall be contracted by the Property Owner/ Developer prior to the issuance of any demolition permits to perform biological monitoring during all demolition, clearing, grubbing, and grading activities.

To the extent feasible, all demolition, clearing, grubbing, and grading activities shall be conducted outside of the state-identified nesting season for migratory birds (i.e., typically February 1 through August 31). If not feasible, a Pre-Construction Nesting Bird Survey within and adjacent to the Project site shall be conducted by a qualified biologist no more than three days before beginning these activities. If active nests are found during the Pre-Construction Nesting Bird Survey, a Nesting Bird Plan NBP) shall be prepared by a qualified biologist and implemented during construction with approval from the City. At a minimum, the NBP shall include guidelines for addressing the active nest(s), proposed protective buffers, proposed monitoring approach, and proposed reporting approach. The size and location of all buffer zones, if required, shall be based on the nesting species, nesting sage, nest location, its sensitivity to disturbance, and intensity and duration of the disturbance activity. A memorandum describing the results of the Pre-Construction Nesting Bird Survey shall be submitted to the Planning and Building Department for verification prior to proceeding with demolition, clearing, grubbing, and/ or grading activities subject to this measure. Any NBP developed City of Anaheim – Anaheim Hills Festival Center Project January 13, 2026

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pursuant to this measure shall be submitted to the City for review and approval prior to implementation.

Id.

Notably, the RCM defines the nesting period as February-August, contrary to the California Department of Fish and Wildlife’s (“ CDFW”) finding that raptor nesting may commence before and/ or after this timeframe.9
Further investigation of the information contained on the CDFW’s “ California Outdoors Q&A” webpage reveals that the boundaries of bird nesting season in California are broad and variable: “[ N]esting season can vary based on location and species of bird, and in some parts of the state, birds nest year-round.” 10 Furthermore, as noted by the California Department of Fish and Wildlife in a November 18, 2021, letter to the City of Adelanto concerning a similar preconstruction nesting bird survey mitigation measure:

CDFW is concern[ed] that [the mitigation measure] is conditioned to only require surveys during the peak bird nesting season considering that birds, such as hummingbirds may nest year-round. Furthermore, [the mitigation measure] defines bird nesting season as February 1 to August 31. Please note that nesting may commence before and/ or after this timeframe. For example, some species of raptors (e g. owls, hawks, etc.) may commence nesting activities in January, and passerines may nest later than August 31.

Fish and Game Code Section 3503 makes it unlawful to take, possess, or needlessly destroy the nest or eggs of any bird, except as otherwise provided by Fish and Game Code or any regulation made pursuant thereto.

These added qualifications by CDFW regarding bird nesting season are consistent with, and underscore, CDFW’s separate finding that birds and raptor nesting in the Project’s geographic region can and does occur outside the more general bird nesting 9 “…[ S]ome species of raptors ( e g. owls, hawks, etc.) may commence nesting activities in January.” See CDFW November 18, 2021 letter to City of Adelanto, available at https:// files. ceqanet. opr.ca.gov/ 273819- 1/ attachment/ zo76RgD7dUdj5BLJTEhEMdf74g6f100RrKiWBQSquhFFe5l0X53rLsbLSGMPRXgXM4AaYnJST fZB6JpY0
10 See CDFW California Outdoors Q& A – Nesting Birds https:// wildlife. ca.gov/ COQA/ ArticlePage/ 2/ tag/ conflict# gsc. tab= 0
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period of February-August sought by the DEIR in RCM BIO-1. Moreover, CDFW’s collective findings on this issue, coupled with the Project site’s adjacency and/ or very close proximity to undeveloped wildland and conservation areas (e.g., Deer Canyon Park, the Weir Canyon Nature Preserve, the Oak Canyon Nature Center, and the Fremont Canyon Nature Preserve) confirm the inadequacy of both the City’s analysis of the Project’s potential biological resources impacts to nesting and migratory birds and the exclusive regulatory reliance as a basis for disposing of the potential for any such impacts.

Furthermore, a determination that regulatory compliance will be sufficient to prevent significant adverse impacts must be based on a project-specific analysis of potential impacts and the effect of regulatory compliance. In Californians for Alternatives to Toxics v.

Department of Food & Agric. (2005) 136 Cal. App. 4th 1, the court set aside an EIR for a statewide crop disease control plan because it did not include an evaluation of the risks to the environment and human health from the proposed program but simply presumed that no adverse impacts would occur from use of pesticides in accordance with the registration and labeling program of the California Department of Pesticide Regulation. See also Ebbetts Pass Forest Watch v Department of Forestry & Fire Protection 2008) 43 Cal. App. 4th 936, 956 (fact that Department of Pesticide Regulation had assessed environmental effects of certain herbicides in general did not excuse failure to assess effects of their use for specific timber harvesting project).

Here, the DEIR does not set forth any analysis or study demonstrating the Project’s baseline potential impacts on biological resources, juxtaposed with an analysis of how the Project’s purported regulatory compliance would reduce potential impacts on nesting bird species to a less than significant level, such that no further study or analysis would be warranted. Rather, the DEIR bases its conclusion regarding the mitigating effects of regulatory compliance simply on assumptions regarding the Project Site and the surrounding urbanized areas. Under CEQA, such unsupported assumptions are improper. To that end, the RCM violates CEQA, as its use here results in the DEIR failing to disclose “ the analytic route that the agency took from the evidence to its findings.” ( Cal. Public Resources Code § 21081.5; CEQA Guidelines § 15093; Village Laguna of Laguna Beach, Inc. v. Board of Supervisors ( 1982) 134 Cal. App. 3d 1022, 1035 [quoting Topanga Assn for a Scenic Community v. County of Los Angeles ( 1974) 11 Cal. 3d 506, 515.])
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In response to WSRCC’s prior comments on this issue, the FEIR and the City’s November 18, 2025, responses to comments claims only that RCM-BIO 1 “ does not preclude surveys or protections” for nesting birds for construction work performed outside of the purported typical nesting season of February to August. The fact that RCM-BIO 1 does not “ preclude” such surveys or protections does not amount to actual mitigation of the Project’s potentially significant impact that is suggested by the CDFW guidance. Under CEQA, a project’s mitigation measures are required to be mandatory and enforceable, rather than optional and discretionary, as the City has continued to advocate in the context of RCM-BIO 1. The City’s insistence on such an approach to RCM-BIO 1 underscores WSRCC’s position that mere regulatory compliance, without thorough analysis demonstrating the adequacy of its mitigating effects, does not qualify as sufficient and proper impact mitigation under CEQA.

Additionally, the FEIR and the City’s November 18, 2025, responses still completely fail to address and respond to the concerns identified by WSRCC regarding the Project site’s close proximity to undeveloped wildland and conservation areas such as Deer Canyon Park, the Weir Canyon Nature Preserve, the Oak Canyon Nature Center, and the Fremont Canyon Nature Preserve, which increases the potential for the use of the Project’s ornamental trees by nesting and migratory birds, including raptors. In this regard, the City’s responses still wholly fail to address the core concerns WSRCC has raised regarding the adequacy of the EIR’s study, analysis, and mitigation measures, applicable to the Project’s biological resources impacts.

Additionally, RCM BIO-1 as framed, presents as a commonplace biological mitigation measure implemented as part of CEQA review for a development project. The language and requirements included in the measures are indicative of an overall finding that the Project has the potential to result in significant impacts on biological resources.

Accordingly, WSRCC resubmits that the nesting period and survey plan set forth in the RCM BIO-1 remains inadequate based on CDFW’s own guidance, and the EIR cannot permissibly rely exclusively on regulatory compliance without a greater showing and analysis, based on substantial evidence, that the Project’s biological resources impacts will be less than significant based on said regulatory compliance. Given that, WSRCC maintains that the EIR must, at a minimum, be revised and recirculated to demonstrate sufficient analysis and study of the Project’s biological resources impacts and substantial evidence to indicate that the Project’s compliance with the Fish and Game City of Anaheim – Anaheim Hills Festival Center Project January 13, 2026

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Code and Migratory Bird Treaty Act will sufficiently mitigate any such impacts. Based on the positions set forth by CDFW in its guidance, the EIR should further be revised to require that prior to construction of the Project, a sweep should be conducted verifying the absence of any nesting birds during both nesting and non-nesting seasons in order to account for CDFW’s findings pertaining to the bird/ raptor nesting season within the Project’s geographic region. Absent such revision, the proposed RCM and, by extension, the EIR will remain in direct violation of the CEQA Guidelines.

1. The DEIR Fails to Study and Mitigate the Project’s Biological Resources Impacts Due to Planned Tree Removal
As stated above, the Project, as proposed, plans and intends to remove 211 mature trees currently present on the Project site, with some as tall as 65 feet and/ or having trunk circumferences as large as 57 inches and crown widths of 30 feet across. See DEIR Appendix 4.4-1, pp. 2-3. Despite its removal of a large number of established and mature trees, the proposed Project does not contemplate or provide specifics on any new replacement trees that will be planted as part of the development process.

Instead, the Project’s DEIR and its associated Specimen Tree Report (Appendix 4.4-1) hides behind the notion that the City’s Tree Ordinance does not require any replacement trees to be planted as mitigation for the tree removal. Moreover, the FEIR and the City’s November 18, 2025, responses to WSRCC’s prior comments on this issue do not address the core concern with the DEIR that the Project intends to remove over 200 mature trees without committing to any tree replacement within the boundaries of its development. Much akin the EIR’s flawed noise impact analysis, CEQA does not permit the City to assert that there is no applicable threshold of significance for this impact simply because the City’s Municipal Code does not require tree replacement for “non-specimen” trees. In this regard, the EIR and the City once again improperly conflate the Project’s regulatory compliance for purposes of the contemplated tree removal with a less than significant biological resources impact.

Again, a determination that regulatory compliance will be sufficient to prevent significant adverse impacts must be based on a project-specific analysis of potential impacts and the effect of regulatory compliance. See Californians for Alternatives to Toxics, supra, ( 2005) 136 Cal.App.4th 1. Here, the FEIR perpetuates the DEIR’s failure improperly fails to disclose “ the analytic route that the agency took from the evidence to its findings.” ( Cal. Public Resources Code § 21081.5; CEQA Guidelines § 15093; Village Laguna of Laguna Beach, Inc. v. Board of Supervisors ( 1982) 134 Cal. App. 3d 1022, City of Anaheim – Anaheim Hills Festival Center Project January 13, 2026

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1035 [quoting Topanga Assn for a Scenic Community v. County of Los Angeles ( 1974) 11 Cal. 3d 506, 515.]) WSRCC’s concerns regarding the Project’s potential biological resources impacts and the City’ study and analysis of them have remained wholly unaddressed by the FEIR and its responses to prior comments, with the City continuing to rely upon mere regulatory compliance for the proposition that no potentially significant biological resources impacts will arise from the removal of the 211 trees on the Project site. The deficiency of the EIR and its mitigation of the impacts of the planned tree removal is underscored by the fact that the DEIR’s Specimen Tree Report recommends that “… trees be incorporated into the redeveloped landscape…” for the Project. DEIR, Appendix 4.4-1, p. 3. Additionally, and once again, the Project is sited in close proximity to various undeveloped wildland and conservation areas, including Deer Canyon Park, the Weir Canyon Nature Preserve, the Oak Canyon Nature Center, and the Fremont Canyon Nature Preserve, which increases the likelihood of the use of the Project’s ornamental trees by nesting and migratory birds, including raptors, as habitat. The Project’s potential impacts in the form of bird habitat loss, as well as the loss of the trees themselves and the overall diminishment of the City’s urban forest, warrants and requires further study and mitigation of the biological impacts presented by the removal of all of the Project site’s trees. Despite this acknowledgement in the impact study, and WSRCC’s repeated prior comments emphasizing this unaddressed concern, the Project and its EIR still fail to commit to any types or quantities of trees to be replanted as part of the Project’s development.

Accordingly, the FEIR and the City’s November 18, 2025, response to comments has perpetuated the Project’s failure to properly study, analyze, and mitigate the Project’s biological resources impacts, despite the substantial evidence of potentially significant impacts, such that revision and recirculation of the EIR is now required under CEQA.

C. The DEIR’s Mitigation Measures Are Insufficient
A fundamental purpose of an EIR is to identify ways in which a proposed project's significant environmental impacts can be mitigated or avoided. Pub. Res. Code 21002.1(a), 21061. To implement this statutory purpose, an EIR must describe any feasible mitigation measures that can minimize the project's significant environmental effects. PRC §§ 21002.1(a), 21100(b)(3); CEQA Guidelines §§ 15121(a), 15126.4(a).

If the project has a significant effect on the environment, the agency may approve the project only upon finding that it has “ eliminated or substantially lessened all significant effects on the environment where feasible” PRC §§ 21002; 21002.1, 21081; City of Anaheim – Anaheim Hills Festival Center Project January 13, 2026

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CEQA Guidelines §§ 15091, 15092(b)(2)(A); and find that ‘specific overriding economic, legal, social, technology or other benefits of the project outweigh the significant effects on the environment.” PRC §§ 21002; 21002.1, 21081; CEQA Guidelines §§ 15091, 15092(b)(2)(B). “A gloomy forecast of environmental degradation is of little or no value without pragmatic, concrete means to minimize the impacts and restore ecological equilibrium.” Environmental Council of Sacramento v. City of Sacramento ( 2006) 142 Cal.App.4th 1018, 1039.

CEQA mitigation measures proposed and adopted are required to describe what actions will be taken to reduce or avoid an environmental impact. (CEQA Guidelines 15126.4(a)(1)(B) [providing “[ f]ormulation of mitigation measures should not be deferred until some future time.”].) While the same Guidelines section 15126.5(a)(1)(B) acknowledges an exception to the rule against deferrals, such exception is narrowly proscribed to situations where it is impractical or infeasible to include those details during the project's environmental review.

According to CEQA Guidelines, “[ w]hen an EIR has been prepared for a project, the Responsible Agency shall not approve the project as proposed if the agency finds any feasible alternative or feasible mitigation measures within its powers that would substantially lessen or avoid any significant effect the project would have on the environment.” CEQA Guidelines Section 15096(g)(2).

Here, the EIR’s mitigation measures for the Project are inadequate as follows:

1. The DEIR’s Mitigation Measures Are Improperly Deferred CEQA forbids deferred mitigation. Guidelines § 15126.4(a)(1)(B). CEQA allows deferral of details of a mitigation measure only “ when it is impractical or infeasible to include those details during the project’s environmental review.” ( Id.) CEQA further requires: “ that the agency (1) commits itself to the mitigation, (2) adopts specific performance standards the mitigation will achieve, and (3) identifies the type(s) of potential action(s) that can feasibly achieve that performance standard…” Guidelines 15126.4(a)(1)(B). Deferring formulation of a Project’s actual mitigation measures to some undefined time after the Project’s approval is improper and cannot be used as a substitute for proper mitigation under CEQA. Impermissible deferral can occur when an EIR calls for mitigation measures to be created based on future studies or describes mitigation measures in general terms but the agency fails to commit itself to specific performance standards. (Preserve Wild Santee v. City of Santee ( 2012) 210 City of Anaheim – Anaheim Hills Festival Center Project January 13, 2026

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Cal.App.4th 260, 281 [city improperly deferred mitigation to butterfly habitat by failing to provide standards or guidelines for its management].) Here, the EIR improperly defers details of the Project’s mitigation measures as discussed in detail below.
i. Cultural Resources Mitigation Measures
The Project’s Cultural Resources Mitigation Measure MM CUL-1 provides as follows, in relevant part:

Archaeologist Monitoring: Prior to the issuance of the grading permit, the Property Owner/ Developer shall provide written evidence to the City that the Property Owner/ Developer has retained a qualified archaeologist to observe grading activities within previously undisturbed soils and to salvage and catalog archaeological resources, as necessary. The archaeologist shall be present at the pre-grade conference, shall establish procedures for archaeological resource surveillance within previously undisturbed soils, and shall establish, in cooperation with the Property Owner/ Developer, procedures for temporarily halting or redirecting work to permit the sampling, identification, and evaluation of the artifacts as appropriate.

DEIR at p. 4.5-11.

The above mitigation measure, on its face, defers the preparation of the required procedures for monitoring and halting/ redirecting construction activities based on the presence and/ or discovery of protected cultural resources at the project site. WSRCC maintains that the postponement of the preparation of the substance of this mitigation measure denies the public and the City’s decisionmakers of the opportunity to assess the adequacy of the Project’s cultural resources mitigation and monitoring plan, and the Project’s overall impact on cultural resources with respect to ensuring such impacts are adequately mitigated and minimized. Indeed, because of this deferment, the City’s decisionmakers have been denied the opportunity to fully consider the scope of the Project’s potential impacts to cultural resources and whether such impacts have been adequately mitigated, while the general public has also been denied the opportunity to assess and comment upon the associated impacts and the adequacy of the mitigation plans. The FEIR contends that, “CEQA does not require that all implementation details be known or finalized at the time of EIR certification.” City of Anaheim – Anaheim Hills Festival Center Project January 13, 2026

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FEIR, p. 19. However, for purposes of the mitigation measure in question, there is no rational or credible basis for the City’s attempts to defer the preparation of the archaeologist’ s procedures for conducting surveillance for artifacts in the previously undisturbed soils or the Project procedures for halting and redirecting work to permit further archaeological exploration in the event of a potential find. The City’s November 18, 2025, responses to comments similarly dismiss WSRCC’s concerns on this issue without directly responding to them or identifying reasons why the City cannot develop, present, and circulate the archaeological mitigation procedures for public review, improperly asserting that it can formulate the details of the mitigation measure at a later time. However, the City and FEIR have not pointed to any unique site characteristics that would justify, for CEQA purposes, the deferment of preparation of these otherwise standard planning measures.

Thus, in the context of MM CUL-1, WSRCC maintains that the City has continued its failure to meet CEQA’s preconditions and requirements concerning mitigation, as the EIR has failed to show why the Project’s cultural resources response plan, and a comprehensive analysis of the Project’s anticipated impacts on such cultural resources, cannot be completed or achieved at this time prior to adoption of the EIR. The deferment of this study and analysis also improperly constrains the EIR’s assessment of the impacts that the measure will have individually or cumulatively, and the specific performance criteria the Applicant will have to meet with regard to the measures.

Accordingly, the proposed mitigation measure is improperly deferred as it defers the formulation of components of the mitigation to a later time and further does not explain how the measure will clearly reduce the Project’s cultural resources impacts to a level of insignificance.
ii. Geology and Soils Mitigation Measures
The Project’s Geology and Soils Mitigation Measure MM GEO-1 provides as follows, in relevant part:

Prior to the issuance of grading and building permits, the City of Anaheim Building Division and Public Works Department shall review all Project plans for grading, foundation, structural, infrastructure, and all other relevant construction permits to ensure compliance with the recommendations contained in the Project's Geotechnical Exploration and Feasibility Report.

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DEIR at p. ES-13.

Moreover, MM GEO-2 provides as follows, in relevant part:

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.

DEIR at p. ES-14 (emphasis added).

Much like the Project’s MM CUL-1, the above mitigation measures impermissibly defer the preparation of any actual mitigation associated with the Project’s geological impacts. Worse yet, MM GEO-1 vaguely attempts to incorporate by reference the recommendations” of the Project’s Geotechnical Exploration and Feasibility Report as potential mitigation measures for the Project. The deferment of the preparation of these actual mitigation measures, coupled with MM GEO-1’s lack of specificity and certainty regarding what mitigation will in fact be deployed to combat impacts associated with potential seismic ground shaking and/ or unstable/ expansive soils, render the mitigation measures improperly deferred and uncertain. In this regard, the mitigation measure does not adequately and clearly commit to the mitigation necessary to combat the Project’s potential geology and soils impacts, which is required by CEQA. At minimum, and to the extent the City will otherwise be required to ensure their implementation prior to the issuance of building and grading permits for the Project, the recommendations from the Project’s Geotechnical Report must be incorporated as mandatory mitigation measures in the Project’s MMRP to ensure they will be adequately noted, completed, and enforced. The FEIR and the City’s November 18, 2025, responses to WSRCC’s comments on this issue continue to evade discussion of the core deficiency identified – namely, that the recommendations of the Geotechnical Report for the Project have not been expressly incorporated into the Project’s MMRP, leaving the City to search in the guidance documents for the mitigation measures it will be required to complete. In this regard, FEIR has failed to address the technical deficiencies of MM GEO-1, and the EIR for the Project therefore remains deficient, in violation of CEQA, and subject to revision and recirculation.

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With regard to MM GEO-2, the formulation of the mitigation measure remains partially deferred, in that the FEIR provides no rationale or basis for why the mitigation plan to be formulated by the retained paleontologist in the event of a find cannot be developed to the maximum extent possible prior to the Project’s approval.

Indeed, the City’s decisionmakers and the general public are entitled to a full and fair opportunity to assess whether the mitigation efforts to be deployed on the Project in protecting paleontological resources are adequate and complete. As framed, MM GEO-2 continues to deny the City and the public of that opportunity by deferring its specific formulation to a later time. However, in its November 18, 2025, responses, the City continues to improperly claim that such deferral of the formulation of the mitigation measures is permitted under CEQA, all while continuing to offer no cognizable rationale or justification for why the mitigation measures cannot be completely formulated at this time and circulated for public review.

Thus, in the context of MM GEO-1 and MM GEO-2, WSRCC maintains that the City has failed to meet CEQA’s preconditions and requirements concerning mitigation, as the EIR has failed to make the “ recommendations” of the Geotechnical Exploration and Feasibility Report a mandatory and express component of mitigation on the Project and has failed to present a clear response plan in the event that paleontological resources are discovered during construction. Accordingly, WSRCC resubmits that the proposed mitigation measures, as currently constituted, violate CEQA and must be appropriately revised and recirculated. iii. Hazards and Hazardous Materials Mitigation Measures The Project’s Hazards and Hazardous Materials Mitigation Measure MM HAZ-1 provides as follows, in relevant part:

Construction Management Plan: Prior to the issuance of grading permits, a Construction Management Plan shall be prepared by the Property Owner/ Developer for review and approval by Anaheim Fire and Rescue, in accordance with MUTCD. It must identify emergency access points and routes throughout all construction phases.

DEIR at p. ES-17.

The Project’s Mitigation Measure MM HAZ-1 improperly and unjustifiably defers preparation of the Construction Management Plan (CMP) until after the Project has been approved by the City and shortly before construction is to commence. The City of Anaheim – Anaheim Hills Festival Center Project January 13, 2026

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preparation of the CMP in connection with the Project’s hazards mitigation efforts has been established as a required, unconditional mitigation effort in connection with the Project. As such, there is simply no valid explanation for the DEIR’s failure to prepare and include the required CMP the as part of the appendices for the Project’s environmental review, thereby providing the City and the general public with an full and appropriate opportunity to assess the adequacy of the Project’s hazards mitigation plans in this regard.

In response to WSRCC’s prior comments on this issue, the FEIR and the City’s November 18, 2025, responses continue to assert that the City is permitted under CEQA to finalize the details of MM HAZ-1 after the EIR for the Project has been certified. However, once again, the FEIR and the City still have not provided any justification or explanation for why it would be infeasible to develop, formulate, and circulate the CMP for the Project for the public’s review at this time. The FEIR’s citation to the legal proposition that all details of a mitigation measure need not be circulated prior to an EIR’s certification does not dispose of the CEQA principle that a project’s mitigation measures must be developed to the fullest extent feasible prior to an EIR’s certification. The City’s November 18, 2025, responses provide no rebuttal whatsoever on this critical point, and WSRCC reiterates that the City has no legal support for its position in this regard. The specifications of the Project are sufficiently known at this time, as are the requirements set forth in the Manual on Uniform Traffic Control Devices (MUTCD), such that there is no cognizable obstacle to the preparation and circulation of the CMP at this time. To that end, WSRCC maintains that the EIR’s ongoing failure to prepare and provide the CMP once again violates CEQA, and the FEIR and the City have demonstrated no cognizable basis for why it cannot now be prepared for public review.

Thus, with respect to MM HAZ-1, the EIR has continued its failure to meet CEQA’s preconditions and requirements concerning mitigation by deferring the further study, analysis and preparation of mitigation measures and plans to address the Project’s anticipated Hazards impacts. The EIR’s cannot permissibly constrain its assessment of the individual and cumulative impacts of these measures, or withhold reporting of the specific performance criteria the Applicant will have to meet with regard to the measures, particularly when there is nothing to prevent current further study of these impacts and the preparation of the required mitigation plan vis-à-vis the CMP. Once again, the EIR has violated CEQA by deferring the formulation of critical aspects of City of Anaheim – Anaheim Hills Festival Center Project January 13, 2026

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its hazards mitigation to a later time, and the FEIR has failed to properly address and resolve concerns raised on these matters, such that revision and recirculation of the EIR to supply this necessary study and information remains required.

D. The EIR Improperly Mischaracterizes its Transportation and Hazards Mitigation Measure as “ Project Design Features” The FEIR also perpetuates the DEIR’s improper recasting of what would otherwise be essential Transportation and Hazards impact mitigation measures as “ Project Design Features” or “PDFs.” Relying in part on these PDFs for the Project, the EIR has concluded that the Project’s Transportation impacts will be significant, despite failing to deploy any bona fide mitigation measures on that impact category, while also improperly leveraging the PDFs aimed at the Project’s Hazards impacts in conjunction with the Project’s lone Hazards mitigation measure, MM HAZ-1, to conclude that the Project’s otherwise significant hazards impacts have been mitigated to a less than significant level.

It is established that “‘[ a]voidance, minimization and / or mitigation measure’ . . . are not ‘part of the project.’ . . . compressing the analysis of impacts and mitigation measures into a single issue . . . disregards the requirements of CEQA.” (Lotus v.

Department of Transportation ( 2014) 223 Cal. App. 4th 645, 656.) When “ an agency decides to incorporate mitigation measures into its significance determination, and relies on those mitigation measures to determine that no significant effects will occur, that agency must treat those measures as though they were adopted following a finding of significance.” ( Lotus, supra, 223 Cal. App. 4th at 652 [citing CEQA Guidelines § 15091(a)(1) and Cal. Public Resources Code § 21081(a)(1).])
By mischaracterizing the Transportation and Hazards mitigation measures as PDFs, the City violates CEQA by failing to disclose “ the analytic route that the agency took from the evidence to its findings.” ( Cal. Public Resources Code § 21081.5; CEQA Guidelines § 15093; Village Laguna of Laguna Beach, Inc. v. Board of Supervisors ( 1982) 134 Cal. App. 3d 1022, 1035 [quoting Topanga Assn for a Scenic Community v. County of Los Angeles ( 1974) 11 Cal. 3d 506, 515.])
Specifically, the DEIR delineates the following Transportation and Hazards PDFs to be applied to the project, which are tantamount to (and otherwise routinely adopted as) mitigation measures under CEQA:

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PDF HAZ-1 Construction Fire Prevention Plan: Prior to
commencement of construction activities, the Property
Owner/ Developer shall prepare and implement a Construction Fire Prevention Plan that identifies fire safety measures to be followed by the Project's contractor throughout all phases of construction. The Plan shall be submitted to Anaheim Fire & Rescue for review and approval prior to the start of construction activities.

PDF HAZ-2 Wildfire Evacuation and Awareness Plan: Prior to issuance of a certificate of occupancy for the first multiple-family residential unit, the Property Owner/ Developer shall prepare and implement a Project-specific Wildfire Evacuation and Awareness Plan.

The Plan shall be subject to review and approval by the City of Anaheim Planning Department, Anaheim Police Department, and Anaheim Fire & Rescue. The Plan shall include, at a minimum, the following components:
1) The Plan shall be provided to all tenants along with all lease agreements for development and dissemination of wildfire evacuation outreach materials. These materials shall be provided to residents and employees within the Project annually. The outreach materials shall depict evacuation routes to use in case of a wildfire event and will provide other practical wildfire preparedness information; (3) The Plan shall include requirements for annual emergency evacuation drills for residents and employees in the Project site; and ( 4) The Plan shall include the development, implementation, and ongoing maintenance of a method for the Property Owner/ Developer to quickly and effectively communicate emergency alerts to individuals at the Project site, such as through the installation and maintenance of a wireless Public Address ( PA) system and/ or wireless texting services, or other equivalent systems or methods approved by Anaheim Fire & Rescue.

PDF TRANS-1 Affordable Housing (CAPCOA Measure T-4): The Project shall include 45 moderate-income level housing units, representing 10 percent of the total 447 dwelling units. This measure is estimated to reduce project-generated VMT by approximately 2.86 percent or 1,621 VMT.

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PDF TRANS-2 Limit Residential Parking Supply ( CAPCOA
Measure T-15): The Project shall provide a total of 893 parking spaces, which is 70 spaces fewer than the 963 spaces required by the City's development standards. This reduction in parking supply is expected to reduce project-generated VMT by 1.0 percent, or 567 VMT.

DEIR, pp. ES-15 – 17, ES-24.

Notably, the DEIR acknowledges that, absent the incorporation of the foregoing PDFs in the Project, the Project is anticipated to have both significant Hazards and Transportation impacts with respect to (i) impairing the implementation of or physically interfering with an adopted emergency response plan or emergency evacuation plan, (ii) conflicting or being inconsistent with State CEQA Guidelines Section 15064.3(b), and (iii) resulting in inadequate emergency access . Id. According to the DEIR, these significant impacts of the Project will purportedly be cured, either in whole or in part, via the incorporation of PDF HAZ-1, PDF HAZ-2, PDF TRANS-1, and PDF TRANS-2.

However, implementing a Wildfire Evacuation and Awareness Plan, ensuring minimum levels of affordable housing, and limiting residential parking are not bona fide features of “project design.” Rather, the PDFs amount to the EIR’s mislabeling and disguising of what are otherwise a mitigation measures for the Project. Here, the EIR has premised it analysis regarding the allegedly “ less than significant impact” on Hazards on the incorporation of the so-called PDFs. It has also declined to incorporate bona fide mitigation measures against the Project’s significant and unavoidable Transportation impacts. To that end, the Transportation and Hazards impacts analysis put forth in the EIR is demonstrably tainted and flawed by the improper application and incorporation of these PDFs.

In response to WSRCC’s comments on these issues, the FEIR and the City misconstrue the application of the PDFs and attempt to validate their improper use on the Project. The FEIR makes plain that the PDFs, which are, by all accounts, mitigation measures, have been incorporated and applied as aspects of the Project’s baseline, rather than being correctly characterized and attributed as impact-reducing mitigation measures. See FEIR, pp. 20-21. The FEIR continues to tout the PDFs as voluntary design elements,” when in fact, for example, a Construction Fire Prevention Plan and a Wildfire Evacuation and Awareness Plan, cannot be credibly characterized as a part of a Project’s physical design and specifications. Indeed, such City of Anaheim – Anaheim Hills Festival Center Project January 13, 2026

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plans amount to planning documents the City and the Applicant must develop and comply with in order to ensure against otherwise significant hazards impacts arising from the Project.

1. The Project’s Improper Transportation PDFs also Fail to Incorporate All Feasible Mitigation Measures
Further still, the EIR appears to use the Project’s Transportation PDFs in order to attempt to relieve itself from the requirement under CEQA to formulate and deploy all feasible mitigation measures to combat the Project’s significant and unavoidable Transportation impacts in the form of exceeding CEQA VMT requirements. The DEIR’s conclusion that “[ n]o feasible mitigation measures were identified that would reduce the significant [Transportation] impact to a level less than significant,” ( DEIR, p. ES-24) is irrelevant and inapplicable to the City’s obligation under CEQA to deploy all available, feasible mitigation measures when faced with an otherwise significant and unavoidable impact resulting from a project.

When an EIR has identified significant environmental effects that have not been mitigated or avoided, the agency may not approve the project unless it first finds that s]pecific economic, legal, social, technological, or other considerations ... make infeasible the mitigation measures or alternatives identified in the environmental impact report." PRC § 21081 (a)(3); see 14 CCR §1509l(a)(3).) Rejected alternatives and mitigation measures must be “ truly infeasible.” City of Marina v. Bd. Of Trustees of Cal. State Univ. (2006) 39 Cal.4th 341, 369. Any infeasibility findings relied upon by a project’s lead agency are required be supported by substantial evidence in the record.

PRC s§ 21081.5; 14 CCR § 1509l(b). “The required findings constitute the principal means chosen by the Legislature to enforce the state's declared policy ‘that public agencies should not approve projects as proposed if there are feasible alternatives or feasible mitigation measures available which would substantially lessen the significant environmental effects of such projects ...’” City of Marina, supra, 39 Cal.4th at 350 quoting PRC§ 21002).

In the instant case, WSRCC resubmits that other straightforward impact-reducing measures such as increased bicycle parking and associated facilities, or payment into a local or state-sponsored VMT fund, could be incorporated into the Project to further reduce the significant transportation impacts it presents. Indeed, in its August 4, 2025, written comments, Caltrans identified several additional feasible measures to reduce the anticipated transportation impacts for the Project, including: (i) encouraging the City of Anaheim – Anaheim Hills Festival Center Project January 13, 2026

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use of public transit among future residents, visitors, and workers; (ii) implementing high-quality pedestrian, bicycle, and transit facilities, including safety measures like physically separated sidewalks and bike lanes, pedestrian-oriented LED lighting, and raised crosswalks; and (iii) strategic placement of short- and long-term bicycle parking.

Meanwhile, in response to the foregoing suggestions, the City has still failed to meaningfully respond to regarding these additional mitigation measures and their feasibility, without explaining why it rejected further consideration of the measures or providing any evaluation of the measures.

When a comment suggests “ better ways to avoid or mitigate the significant environmental impacts” ( 14 CCR §§ 15088(c), 15204(a)), the lead agency must respond to the comment by either explaining why further consideration of the alternative or mitigation was rejected or by providing an evaluation of the alternative.

Marin Mun. Water Dist. V. KG Land Cal. Corp. (1991) 235 Cal.App.3d 1652, 1666; see Cal. Native Plant Soc' y v. City of Santa Cruz (“ CNPS”) ( 2009) 177 Cal.App.4th 957, 992.

A]n adequate EIR must respond to specific suggestions for mitigating a significant environmental impact unless the suggested mitigation is facially infeasible.’ [ citation omitted] ‘While the response need not be exhaustive, it should evince good faith and a reasoned analysis.’” CNPS, 177 Cal.App.4th at 992 (citing L.A. Unified School Dist. V.

City of L.A. (1997) 58 Cal.App.4th 1019, 1029); see also, Citizens for Quality Growth v.

City of A1ount Shasta ( 1988) 198 Cal.App.3d 433, 442, fn. 8.

Under the CEQA and the foregoing authority, City has a legal obligation to develop and incorporate all such feasible mitigation measures for the Project, yet has thus far failed and refused to do so, in direct violation of CEQA’s requirements. Absent revision and recirculation of the Project’s EIR to incorporate all feasible mitigation measures to combat the Project’s significant and unavoidable transportation impacts, the EIR will remain in violation of CEQA and cannot permissibly be certified by the City in its present form.

2. The Project’s Improper Hazards PDFs also Illegally Defer Preparation of Their Specific Mitigation in Violation of CEQA Additionally, and notwithstanding the other legally improper attributes of PDF HAZ1 and PDF HAZ-2 discussed above, the foregoing PDFs collectively also improperly defer preparation of Project’s Construction Fire Prevention Plan (“ CFPP”) and Wildfire Evacuation and Awareness Plan (“ WEAP”) until after the public review and certification of the EIR has been completed. Indeed, PDF HAZ-1 defers preparation City of Anaheim – Anaheim Hills Festival Center Project January 13, 2026

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of the CFPP until “ prior to commencement of construction activities,” while PDF HAZ-2 defers preparation of the WEAP until “[ p]rior to issuance of a certificate of occupancy for the first multiple-family residential unit” of the Project. As discussed at length above in the context of MM CUL-1, MM GEO-1, MM GEO-2, and MM HAZ-1, CEQA prohibits ambiguous, deferred, and uncertain mitigation measures.

The EIR’s deferment of preparation of these wildfire-related mitigations is particularly glaring given the EIR’s acknowledgement that the majority of Project is sited in a State-designated Very High Fire Hazard Severity Zone (“VHFHSZ”). Thus, even if CEQA permitted the EIR for the Project to substitute PDFs for mitigation measures in the context of PDF HAZ-1 and PDF HAZ-2 (which it does not), such measures in the EIR still would not meet CEQA’s requirements based on their improper deferral of the actual substance of the mitigation measures.

In sum, by recasting its transportation and hazards mitigation measures as PDFs, and then deferring preparation of aspects of the PDFs that purport to provide mitigating effects on the Project’s impacts, the EIR has attempted to skirt its responsibilities to fully analyze and mitigate the various environmental impacts implicated by the PDFs.

Such an attempt to evade accountability for addressing the Project’s transportation and hazards impacts directly violates CEQA, and the EIR cannot permissibly be certified unless and until this deficiency is rectified.

3. The EIR Fails to Set Forth Substantial Evidence that its Improper Hazards Mitigation Measure and PDFs Will Be
Effective in Reducing the Project’s Fire and Evacuation Safety Impacts
Further still, a lead agency is required to determine, based on substantial evidence, that a project’s mitigation measures will be effective in mitigating the project’s anticipated impacts. Lotus, supra, 223 Cal.App.4th at 656-658. “[ M]itigation measure[s] that do] no more than require a report be prepared and followed” fail to provide adequate information for the informed decision-making that CEQA requires.

Endangered Habitats League, Inc. v. Cnty. of Orange ( 2005) 131 Cal.App.4th 777, 794; CEQA Guidelines§ 15126.4(a)(l)(B).

The EIR for the Project fails to provide any evidence, let alone substantial evidence, that MM HAZ-1 and the aforementioned legally improper hazards PDFs will actually be effective in meaningfully reducing the Project’s hazards impacts. Indeed, the City has failed to quantify the effectiveness of the mitigation measures and to compare the City of Anaheim – Anaheim Hills Festival Center Project January 13, 2026

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measures’ effectiveness against a numerical threshold of impact significance, and such calculations cannot be completed because the preparation of the measures’ actual mitigating components (i.e., the CMP, the CFPP, and the WEAP) have been improperly deferred and will not be prepared prior to the EIR being certified by the City.

Accordingly, the City’s decisionmakers and the general public have been improperly denied the opportunity to evaluate whether the CMP, CFPP, and WEAP for the Project will actually decrease the Project’s fire and evacuation safety impacts, and to the actual extent required to affirm the EIR’s otherwise conclusory findings regarding their mitigating effects on the Project’s impacts. Indeed, MM HAZ-1, PDF HAZ-1, and PDF HAZ-2, as presently constituted, do not provide the City with adequate information to conclude that they will in fact be effective. Thus, in its current form, the EIR violates CEQA and must be revised and recirculated to provide the requisite study and analysis of the mitigating effects of the Project’s hazards mitigation measures.

V. CONCLUSION
Based on the foregoing concerns, the City should require revision and recirculation of the EIR for the Project pursuant to CEQA. Absent doing so, the EIR in its current form directly violates CEQA in multiple respects. If the City should have any questions or concerns, please do not hesitate to contact this office.

Sincerely,
Jeremy Herwitt
Attorneys for Western States Regional Council of Carpenters Attached:

March 8, 2021 SWAPE Letter to Mitchell M. Tsai re Local Hire Requirements and Considerations for Greenhouse Gas Modeling (Exhibit A); Air Quality and GHG Expert Paul Rosenfeld CV (Exhibit B); and City of Anaheim – Anaheim Hills Festival Center Project January 13, 2026

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Air Quality and GHG Expert Matt Hagemann CV (Exhibit C).

EXHIBIT A
1 2656 29th Street, Suite 201
Santa Monica, CA 90405
Matt Hagemann, P.G, C. Hg.
949) 887- 9013
mhagemann@swape. com
Paul E. Rosenfeld, PhD
310) 795- 2335
prosenfeld@swape. com
March 8, 2021
Mitchell M. Tsai
155 South El Molino, Suite 104
Pasadena, CA 91101
Subject: Local Hire Requirements and Considerations for Greenhouse Gas Modeling Dear Mr. Tsai,
Soil Water Air Protection Enterprise (“ SWAPE”) is pleased to provide the following draft technical report explaining the significance of worker trips required for construction of land use development projects with respect to the estimation of greenhouse gas (“ GHG”) emissions. The report will also discuss the potential for local hire requirements to reduce the length of worker trips, and consequently, reduced or mitigate the potential GHG impacts.

Worker Trips and Greenhouse Gas Calculations
The California Emissions Estimator Model (“ CalEEMod”) is a “ statewide land use emissions computer model designed to provide a uniform platform for government agencies, land use planners, and environmental professionals to quantify potential criteria pollutant and greenhouse gas (GHG) emissions associated with both construction and operations from a variety of land use projects.” 1CalEEMod quantifies construction- related emissions associated with land use projects resulting from off-road construction equipment; on-road mobile equipment associated with workers, vendors, and hauling; fugitive dust associated with grading, demolition, truck loading, and on-road vehicles traveling along paved and unpaved roads; and architectural coating activities; and paving. 2
The number, length, and vehicle class of worker trips are utilized by CalEEMod to calculate emissions associated with the on-road vehicle trips required to transport workers to and from the Project site during construction. 3 1 “ California Emissions Estimator Model.” CAPCOA, 2017, available at: http:// www. aqmd. gov/ caleemod/ home. 2 “ California Emissions Estimator Model.” CAPCOA, 2017, available at: http:// www. aqmd. gov/ caleemod/ home. 3 “ CalEEMod User’ s Guide.” CAPCOA, November 2017, available at: http:// www. aqmd. gov/ docs/ defaultsource/ caleemod/ 01_user- 39-s-guide2016- 3-2_15november2017. pdf?sfvrsn= 4, p. 34. 2 Specifically, the number and length of vehicle trips is utilized to estimate the vehicle miles travelled (“ VMT”) associated with construction. Then, utilizing vehicle- class specific EMFAC 2014 emission factors, CalEEMod calculates the vehicle exhaust, evaporative, and dust emissions resulting from construction- related VMT, including personal vehicles for worker commuting. 4
Specifically, in order to calculate VMT, CalEEMod multiplies the average daily trip rate by the average overall trip length ( see excerpt below):

VMTd = Average Daily Trip Rate i * Average Overall Trip Length i) n Where:
n = Number of land uses being modeled.” 5
Furthermore, to calculate the on-road emissions associated with worker trips, CalEEMod utilizes the following equation ( see excerpt below):

Emissionspollutant = VMT * EFrunning, pollutant
Where:

Emissionspollutant = emissions from vehicle running for each pollutant VMT = vehicle miles traveled
EFrunning, pollutant = emission factor for running emissions.” 6 Thus, there is a direct relationship between trip length and VMT, as well as a direct relationship between VMT and vehicle running emissions. In other words, when the trip length is increased, the VMT and vehicle running emissions increase as a result. Thus, vehicle running emissions can be reduced by decreasing the average overall trip length, by way of a local hire requirement or otherwise.

Default Worker Trip Parameters and Potential Local Hire Requirements As previously discussed, the number, length, and vehicle class of worker trips are utilized by CalEEMod to calculate emissions associated with the on-road vehicle trips required to transport workers to and from the Project site during construction. 7In order to understand how local hire requirements and associated worker trip length reductions impact GHG emissions calculations, it is important to consider the CalEEMod default worker trip parameters. CalEEMod provides recommended default values based on site- specific information, such as land use type, meteorological data, total lot acreage, project type and typical equipment associated with project type. If more specific project information is known, the user can change the default values and input projectspecific values, but the California Environmental Quality Act (“ CEQA”) requires that such changes be justified by substantial evidence. 8The default number of construction- related worker trips is calculated by multiplying the 4 “ Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at: http:// www. aqmd. gov/ docs/ defaultsource/ caleemod/ 02_appendix- a2016- 3-2.pdf?sfvrsn= 6, p. 14-15. 5 “ Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at: http:// www. aqmd. gov/ docs/ defaultsource/ caleemod/ 02_appendix- a2016- 3-2.pdf?sfvrsn= 6, p. 23. 6 “ Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at: http:// www. aqmd. gov/ docs/ defaultsource/ caleemod/ 02_appendix- a2016- 3-2.pdf?sfvrsn= 6, p. 15. 7 “ CalEEMod User’ s Guide.” CAPCOA, November 2017, available at: http:// www. aqmd. gov/ docs/ defaultsource/ caleemod/ 01_user- 39-s-guide2016- 3-2_15november2017. pdf?sfvrsn= 4, p. 34. 8 CalEEMod User Guide, available at: http:// www. caleemod. com/, p. 1, 9. 3 number of pieces of equipment for all phases by 1.25, with the exception of worker trips required for the building construction and architectural coating phases. 9Furthermore, the worker trip vehicle class is a 50/ 25/ 25 percent mix of light duty autos, light duty truck class 1 and light duty truck class 2, respectively.” 10 Finally, the default worker trip length is consistent with the length of the operational home-to-work vehicle trips.11 The operational home- to-work vehicle trip lengths are:

B]ased on the location and urbanization selected on the project characteristic screen. These values were supplied by the air districts or use a default average for the state. Each district ( or county) also assigns trip lengths for urban and rural settings” ( emphasis added). 12 Thus, the default worker trip length is based on the location and urbanization level selected by the User when modeling emissions. The below table shows the CalEEMod default rural and urban worker trip lengths by air basin (see excerpt below and Attachment A).13
Worker Trip Length by Air Basin
Air Basin Rural ( miles) Urban ( miles)
Great Basin Valleys 16.8 10.8
Lake County 16.8 10.8
Lake Tahoe 16.8 10.8
Mojave Desert 16.8 10.8
Mountain Counties 16.8 10.8
North Central Coast 17.1 12.3
North Coast 16.8 10.8
Northeast Plateau 16.8 10.8
Sacramento Valley 16.8 10.8
Salton Sea 14.6 11
San Diego 16.8 10.8
San Francisco Bay Area 10.8 10.8
San Joaquin Valley 16.8 10.8
South Central Coast 16.8 10.8
South Coast 19.8 14.7
Average 16.47 11.17
Minimum 10.80 10.80
Maximum 19.80 14.70
Range 9.00 3.90
9 “ CalEEMod User’ s Guide.” CAPCOA, November 2017, available at: http:// www. aqmd. gov/ docs/ defaultsource/ caleemod/ 01_user- 39-s-guide2016- 3-2_15november2017. pdf?sfvrsn= 4, p. 34. 10 “ Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at:
http:// www. aqmd. gov/ docs/ default- source/ caleemod/ 02_ appendix- a2016- 3-2.pdf?sfvrsn= 6, p. 15. 11 “ Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at:
http:// www. aqmd. gov/ docs/ default- source/ caleemod/ 02_ appendix- a2016- 3-2.pdf?sfvrsn= 6, p. 14. 12 “ Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at:
http:// www. aqmd. gov/ docs/ default- source/ caleemod/ 02_appendix- a2016- 3-2.pdf?sfvrsn= 6, p. 21. 13 “ Appendix D Default Data Tables.” CAPCOA, October 2017, available at: http:// www. aqmd. gov/ docs/ defaultsource/ caleemod/ 05_appendix- d2016- 3-2.pdf?sfvrsn= 4, p. D-84 – D-86. 4 As demonstrated above, default rural worker trip lengths for air basins in California vary from 10.8- to 19.8- miles, with an average of 16.47 miles. Furthermore, default urban worker trip lengths vary from 10.8- to 14.7- miles, with an average of 11.17 miles. Thus, while default worker trip lengths vary by location, default urban worker trip lengths tend to be shorter in length. Based on these trends evident in the CalEEMod default worker trip lengths, we can reasonably assume that the efficacy of a local hire requirement is especially dependent upon the urbanization of the project site, as well as the project location.

Practical Application of a Local Hire Requirement and Associated Impact To provide an example of the potential impact of a local hire provision on construction- related GHG emissions, we estimated the significance of a local hire provision for the Village South Specific Plan (“ Project”) located in the City of Claremont (“ City”). The Project proposed to construct 1,000 residential units, 100,000-SF of retail space, 45,000-SF of office space, as well as a 50-room hotel, on the 24-acre site. The Project location is classified as Urban and lies within the Los Angeles- South Coast County. As a result, the Project has a default worker trip length of 14.7 miles. 14 In an effort to evaluate the potential for a local hire provision to reduce the Project’ s construction- related GHG emissions, we prepared an updated model, reducing all worker trip lengths to 10 miles (see Attachment B). Our analysis estimates that if a local hire provision with a 10-mile radius were to be implemented, the GHG emissions associated with Project construction would decrease by approximately 17% see table below and Attachment C).

Local Hire Provision Net Change
Without Local Hire Provision
Total Construction GHG Emissions ( MT CO2e) 3,623
Amortized Construction GHG Emissions ( MT CO2e/ year) 120.77 With Local Hire Provision
Total Construction GHG Emissions ( MT CO2e) 3,024
Amortized Construction GHG Emissions ( MT CO2e/ year) 100.80 Decrease in Construction- related GHG Emissions 17%
As demonstrated above, by implementing a local hire provision requiring 10 mile worker trip lengths, the Project could reduce potential GHG emissions associated with construction worker trips. More broadly, any local hire requirement that results in a decreased worker trip length from the default value has the potential to result in a reduction of construction- related GHG emissions, though the significance of the reduction would vary based on the location and urbanization level of the project site.

This serves as an example of the potential impacts of local hire requirements on estimated project-level GHG emissions, though it does not indicate that local hire requirements would result in reduced construction- related GHG emission for all projects. As previously described, the significance of a local hire requirement depends on the worker trip length enforced and the default worker trip length for the project’ s urbanization level and location.
14 “ Appendix D Default Data Tables.” CAPCOA, October 2017, available at: http:// www. aqmd. gov/ docs/ defaultsource/ caleemod/ 05_appendix- d2016- 3-2.pdf?sfvrsn= 4, p. D-85. 5 Disclaimer
SWAPE has received limited discovery. Additional information may become available in the future; thus, we retain the right to revise or amend this report when additional information becomes available. Our professional services have been performed using that degree of care and skill ordinarily exercised, under similar circumstances, by reputable environmental consultants practicing in this or similar localities at the time of service. No other warranty, expressed or implied, is made as to the scope of work, work methodologies and protocols, site conditions, analytical testing results, and findings presented. This report reflects efforts which were limited to information that was reasonably accessible at the time of the work, and may contain informational gaps, inconsistencies, or otherwise be incomplete due to the unavailability or uncertainty of information obtained or provided by third parties.

Sincerely,
Matt Hagemann, P.G., C.Hg.

Paul E. Rosenfeld, Ph.D.

Location Type Location Name
Rural H-W
miles)
Urban H-W
miles)
Air Basin Great Basin 16.8 10.8
Air Basin Lake County 16.8 10.8
Air Basin Lake Tahoe 16.8 10.8
Air Basin Mojave Desert 16.8 10.8
Air Basin Mountain 16.8 10.8
Air Basin North Central 17.1 12.3
Air Basin North Coast 16.8 10.8
Air Basin Northeast 16.8 10.8
Air Basin Sacramento 16.8 10.8
Air Basin Salton Sea 14.6 11
Air Basin San Diego 16.8 10.8
Air Basin San Francisco 10.8 10.8
Air Basin San Joaquin 16.8 10.8
Air Basin South Central 16.8 10.8
Air Basin South Coast 19.8 14.7
Air District Amador County 16.8 10.8
Air District Antelope Valley 16.8 10.8
Air District Bay Area AQMD 10.8 10.8
Air District Butte County 12.54 12.54
Air District Calaveras 16.8 10.8
Air District Colusa County 16.8 10.8
Air District El Dorado 16.8 10.8
Air District Feather River 16.8 10.8
Air District Glenn County 16.8 10.8
Air District Great Basin 16.8 10.8
Air District Imperial County 10.2 7.3
Air District Kern County 16.8 10.8
Air District Lake County 16.8 10.8
Air District Lassen County 16.8 10.8
Air District Mariposa 16.8 10.8
Air District Mendocino 16.8 10.8
Air District Modoc County 16.8 10.8
Air District Mojave Desert 16.8 10.8
Air District Monterey Bay 16.8 10.8
Air District North Coast 16.8 10.8
Air District Northern Sierra 16.8 10.8
Air District Northern 16.8 10.8
Air District Placer County 16.8 10.8
Air District Sacramento 15 10
Attachment A
Air District San Diego 16.
8 10.8
Air District San Joaquin 16.
8 10.8
Air District San Luis Obispo 13 13
Air District Santa Barbara 8.
3 8.3
Air District Shasta County 16.
8 10.8
Air District Siskiyou County 16.8 10.8
Air District South Coast 19.
8 14.7
Air District Tehama County 16.
8 10.8
Air District Tuolumne 16.
8 10.8
Air District Ventura County 16.
8 10.8
Air District Yolo/ Solano 15 10
County Alameda 10.
8 10.8
County Alpine 16.
8 10.8
County Amador 16.
8 10.8
County Butte 12.54 12.54
County Calaveras 16.
8 10.8
County Colusa 16.
8 10.8
County Contra Costa 10.
8 10.8
County Del Norte 16.
8 10.8
County El Dorado-Lake 16.
8 10.8
County El Dorado- 16.
8 10.8
County Fresno 16.
8 10.8
County Glenn 16.
8 10.8
County Humboldt 16.
8 10.8
County Imperial 10.
2 7.3
County Inyo 16.
8 10.8
County Kern-Mojave 16.
8 10.8
County Kern-San 16.
8 10.8
County Kings 16.
8 10.8
County Lake 16.
8 10.8
County Lassen 16.
8 10.8
County Los Angeles- 16.
8 10.8
County Los Angeles- 19.
8 14.7
County Madera 16.
8 10.
8 County Marin 10.
8 10.8
County Mariposa 16.
8 10.8
County Mendocino- 16.
8 10.8
County Mendocino- 16.
8 10.8
County Mendocino- 16.
8 10.8
County Mendocino- 16.
8 10.8
County Merced 16.
8 10.8
County Modoc 16.
8 10.8
County Mono 16.
8 10.8
County Monterey 16.
8 10.8
County Napa 10.
8 10.8
County Nevada 16.
8 10.8
County Orange 19.
8 14.7
County Placer-Lake 16.
8 10.8
County Placer-Mountain 16.
8 10.8
County Placer- 16.8 10.8
County Plumas 16.
8 10.8
County Riverside- 16.
8 10.8
County Riverside- 19.
8 14.7
County Riverside- Salton 14.
6 11
County Riverside-South 19.
8 14.7
County Sacramento 15 10
County San Benito 16.
8 10.8
County San Bernardino- 16.
8 10.8
County San Bernardino- 19.
8 14.7
County San Diego 16.
8 10.8
County San Francisco 10.
8 10.8
County San Joaquin 16.
8 10.8
County San Luis Obispo 13 13
County San Mateo 10.
8 10.8
County Santa Barbara- 8.
3 8.3
County Santa Barbara- 8.
3 8.3
County Santa Clara 10.
8 10.8
County Santa Cruz 16.
8 10.8
County Shasta 16.
8 10.8
County Sierra 16.
8 10.8
County Siskiyou 16.
8 10.8
County Solano- 15 10
County Solano-San 16.
8 10.8
County Sonoma-North 16.
8 10.8
County Sonoma-San 10.
8 10.8
County Stanislaus 16.
8 10.8
County Sutter 16.
8 10.8
County Tehama 16.
8 10.
8 County Trinity 16.
8 10.8
County Tulare 16.
8 10.8
County Tuolumne 16.
8 10.8
County Ventura 16.
8 10.8
County Yolo 15 10
County Yuba 16.
8 10.8
Statewide Statewide 16.
8 10.8
Air Basin Rural ( miles) Urban ( miles)
Great Basin Valleys 16.8 10.8
Lake County 16.8 10.8
Lake Tahoe 16.8 10.8
Mojave Desert 16.8 10.8
Mountain Counties 16.8 10.8
North Central Coast 17.1 12.3
North Coast 16.8 10.8
Northeast Plateau 16.8 10.8
Sacramento Valley 16.8 10.8
Salton Sea 14.6 11
San Diego 16.8 10.8
San Francisco Bay Area 10.8 10.8
San Joaquin Valley 16.8 10.8
South Central Coast 16.8 10.8
South Coast 19.8 14.7
Average 16.47 11.17
Mininum 10.80 10.80
Maximum 19.80 14.70
Range 9.00 3.90
Worker Trip Length by Air Basin

1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population General Office Building 45.00 1000sqft 1.03 45,000.00 0 High Turnover ( Sit Down Restaurant) 36.00 1000sqft 0.83 36,000.00 0 Hotel 50.00 Room 1.67 72,600.00 0
Quality Restaurant 8.00 1000sqft 0.18 8,000.00 0
Apartments Low Rise 25.00 Dwelling Unit 1.56 25,000.00 72 Apartments Mid Rise 975.00 Dwelling Unit 25.66 975, 000.00 2789 Regional Shopping Center 56.00 1000sqft 1.29 56,000.00 0

1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
9 Wind Speed ( m/s) 2.2 Precipitation Freq (Days) 33

1.3 User Entered Comments & Non-Default Data

1.0 Project Characteristics
Utility Company Southern California Edison
2028Operational Year
CO2 Intensity
lb/MWhr)
702.44 029CH4 Intensity 0.
lb/MWhr)
006N2O Intensity 0.
lb/MWhr)
Village South Specific Plan (Proposed)
Los Angeles- South Coast County, Annual
CalEEMod Version: CalEEMod. 2016. 3.2 PMPage 1 of 44 Date: 1/6/2021 1:52 Village South Specific Plan ( Proposed) - Los Angeles- South Coast County, Annual Attachment B
Project Characteristics - Consistent with the DEIR' s model.

Land Use - See SWAPE comment regarding residential and retail land uses.

Construction Phase - See SWAPE comment regarding individual construction phase lengths.

Demolition - Consistent with the DEIR' s model. See SWAPE comment regarding demolition.

Vehicle Trips - Saturday trips consistent with the DEIR' s model. See SWAPE comment regarding weekday and Sunday trips.

Woodstoves - Woodstoves and wood- burning fireplaces consistent with the DEIR' s model. See SWAPE comment regarding gas fireplaces.

Energy Use -
Construction Off- road Equipment Mitigation - See SWAPE comment on construction- related mitigation.

Area Mitigation - See SWAPE comment regarding operational mitigation measures.

Water Mitigation - See SWAPE comment regarding operational mitigation measures.

Table Name Column Name Default Value New Value
tblFireplaces FireplaceWoodMass 1,019.20 0.00
tblFireplaces FireplaceWoodMass 1,019.20 0.00
tblFireplaces NumberWood 1.25 0.00
tblFireplaces NumberWood 48.75 0.00
tblVehicleTrips ST_TR 7.16 6.17
tblVehicleTrips ST_TR 6.39 3.87
tblVehicleTrips ST_TR 2.46 1.39
tblVehicleTrips ST_TR 158.37 79.82
tblVehicleTrips ST_TR 8.19 3.75
tblVehicleTrips ST_TR 94.36 63.99
tblVehicleTrips ST_TR 49.97 10.74
tblVehicleTrips SU_TR 6.07 6.16
tblVehicleTrips SU_TR 5.86 4.18
tblVehicleTrips SU_TR 1.05 0.69
tblVehicleTrips SU_TR 131.84 78.27
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2.0 Emissions Summary
tblVehicleTrips SU_TR 5.95 3.20
tblVehicleTrips SU_TR 72.16 57.65
tblVehicleTrips SU_TR 25.24 6.39
tblVehicleTrips WD_ TR 6.59 5.83
tblVehicleTrips WD_ TR 6.65 4.13
tblVehicleTrips WD_ TR 11.03 6.41
tblVehicleTrips WD_ TR 127.15 65.80
tblVehicleTrips WD_ TR 8.17 3.84
tblVehicleTrips WD_ TR 89.95 62.64
tblVehicleTrips WD_ TR 42.70 9.43
tblWoodstoves NumberCatalytic 1.25 0.00
tblWoodstoves NumberCatalytic 48.75 0.00
tblWoodstoves NumberNoncatalytic 1.25 0.00
tblWoodstoves NumberNoncatalytic 48.75 0.00
tblWoodstoves WoodstoveDayYear 25.00 0.00
tblWoodstoves WoodstoveDayYear 25.00 0.00
tblWoodstoves WoodstoveWoodMass 999.60 0.00
tblWoodstoves WoodstoveWoodMass 999.60 0.00
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2.1 Overall Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2. 5
Exhaust
PM2. 5
PM2. 5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year tons/ yr MT/ yr
2021 0.1713 1.8242 1.1662 2.4000e0030.4169 0.0817 0.4986 0.1795 0.0754 0.2549 0.0000 213. 1969 213. 1969 0.0601 0.0000 214. 6993 2022 0.6904 4.1142 6.1625 0.0189 1.3058 0.1201 1.4259 0.3460 0.1128 0.4588 0.0000 1,721. 682 6 1,721. 682
6 0.1294 0.0000 1,724. 918
7 2023 0.6148 3.3649 5.6747 0.0178 1.1963 0.0996 1.2959 0.3203 0.0935 0.4138 0.0000 1,627. 529 5 1,627. 529
5 0.1185 0.0000 1,630. 492
5 2024 4.1619 0.1335 0.2810 5.9000e0040.0325 6.4700e0030.0390 8.6300e0036.0400e0030.0147 0.0000 52.9078 52.9078 8.0200e0030.0000 53.1082 Maximum 4.1619 4.1142 6.1625 0.0189 1.3058 0.1201 1.4259 0.3460 0.1128 0.4588 0.0000 1,721. 682 6 1,721. 682
6 0.1294 0.0000 1,724. 918
7 Unmitigated Construction
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2.1 Overall Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2. 5
Exhaust
PM2. 5
PM2. 5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year tons/ yr MT/ yr
2021 0.1713 1.8242 1.1662 2.4000e0030.4169 0.0817 0.4986 0.1795 0.0754 0.2549 0.0000 213. 1967 213. 1967 0.0601 0.0000 214. 6991 2022 0.6904 4.1142 6.1625 0.0189 1.3058 0.1201 1.4259 0.3460 0.1128 0.4588 0.0000 1,721. 682 3 1,721. 682
3 0.1294 0.0000 1,724. 918
3 2023 0.6148 3.3648 5.6747 0.0178 1.1963 0.0996 1.2959 0.3203 0.0935 0.4138 0.0000 1,627. 529 1 1,627. 529
1 0.1185 0.0000 1,630. 492
1 2024 4.1619 0.1335 0.2810 5.9000e0040.0325 6.4700e0030.0390 8.6300e0036.0400e0030.0147 0.0000 52.9077 52.9077 8.0200e0030.0000 53.1082 Maximum 4.1619 4.1142 6.1625 0.0189 1.3058 0.1201 1.4259 0.3460 0.1128 0.4588 0.0000 1,721. 682 3 1,721. 682
3 0.1294 0.0000 1,724. 918
3 Mitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2. 5
Exhaust
PM2. 5
PM2. 5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Quarter Start Date End Date Maximum Unmitigated ROG + NOX ( tons/ quarter) Maximum Mitigated ROG + NOX ( tons/ quarter) 1 9-1-2021 11-30-2021 1.4103 1.4103
2 12-1-2021 2-28-2022 1.3613 1.3613
3 3-1-2022 5-31-2022 1.1985 1.1985
4 6-1-2022 8-31-2022 1.1921 1.1921
5 9-1-2022 11-30-2022 1.1918 1.1918
6 12-1-2022 2-28-2023 1.0774 1.0774
7 3-1-2023 5-31-2023 1.0320 1.0320
8 6-1-2023 8-31-2023 1.0260 1.0260
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2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2. 5
Exhaust
PM2. 5
PM2. 5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/ yr MT/ yr
Area 5.1437 0.2950 10.3804 1.6700e0030.0714 0.0714 0.0714 0.0714 0.0000 220. 9670 220. 9670 0.0201 3.7400e003222. 5835 Energy 0.1398 1.2312 0.7770 7.6200e0030.0966 0.0966 0.0966 0.0966 0.0000 3,896. 073 2 3,896. 073
2 0.1303 0.0468 3,913. 283
3 Mobile 1.5857 7.9962 19.1834 0.0821 7.7979 0.0580 7.8559 2.0895 0.0539 2.1434 0.0000 7,620. 498 6 7,620. 498
6 0.3407 0.0000 7,629. 016
2 Waste 0.0000 0.0000 0.0000 0.0000 207. 8079 0.0000 207. 8079 12.2811 0.0000 514. 8354 Water 0.0000 0.0000 0.0000 0.0000 29.1632 556. 6420 585. 8052 3.0183 0.0755 683. 7567 Total 6.8692 9.5223 30.3407 0.0914 7.7979 0.2260 8.0240 2.0895 0.2219 2.3114 236. 9712 12,294. 18 07 12,531. 15
19 15.7904 0.1260 12,963. 47
51 Unmitigated Operational
9 9-1-2023 11-30-2023 1.0265 1.0265
10 12-1-2023 2-29-2024 2.8857 2.8857
11 3-1-2024 5-31-2024 1.6207 1.6207
Highest 2.8857 2.8857
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2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2. 5
Exhaust
PM2. 5
PM2. 5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/ yr MT/ yr
Area 5.1437 0.2950 10.3804 1.6700e0030.0714 0.0714 0.0714 0.0714 0.0000 220. 9670 220. 9670 0.0201 3.7400e003222. 5835 Energy 0.1398 1.2312 0.7770 7.6200e0030.0966 0.0966 0.0966 0.0966 0.0000 3,896. 073 2 3,896. 073
2 0.1303 0.0468 3,913. 283
3 Mobile 1.5857 7.9962 19.1834 0.0821 7.7979 0.0580 7.8559 2.0895 0.0539 2.1434 0.0000 7,620. 498 6 7,620. 498
6 0.3407 0.0000 7,629. 016
2 Waste 0.0000 0.0000 0.0000 0.0000 207. 8079 0.0000 207. 8079 12.2811 0.0000 514. 8354 Water 0.0000 0.0000 0.0000 0.0000 29. 1632 556. 6420 585. 8052 3.0183 0.0755 683. 7567 Total 6.8692 9.5223 30.3407 0.0914 7.7979 0.2260 8.0240 2.0895 0.2219 2.3114 236. 9712 12,294. 18 07 12,531. 15
19 15.7904 0.1260 12,963. 47
51 Mitigated Operational

3.0 Construction Detail
Construction Phase
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2. 5
Exhaust
PM2. 5
PM2. 5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 CalEEMod Version: CalEEMod. 2016. 3.2 PMPage 7 of 44 Date: 1/6/2021 1:52 Village South Specific Plan ( Proposed) - Los Angeles- South Coast County, Annual Phase
Number
Phase Name Phase Type Start Date End Date Num Days
Week
Num Days Phase Description
1 Demolition Demolition 9/1/2021 10/12/2021 5 30
2 Site Preparation Site Preparation 10/13/2021 11/9/2021 5 20 3 Grading Grading 11/10/2021 1/11/2022 5 45
4 Building Construction Building Construction 1/12/2022 12/12/2023 5 500 5 Paving Paving 12/13/2023 1/30/2024 5 35
6 Architectural Coating Architectural Coating 1/31/2024 3/19/2024 5 35 OffRoad Equipment
Residential Indoor: 2,025, 000; Residential Outdoor: 675, 000; Non- Residential Indoor: 326, 400; Non- Residential Outdoor: 108, 800; Striped Parking Area: 0 (Architectural Coating – sqft)
Acres of Grading ( Site Preparation Phase): 0
Acres of Grading ( Grading Phase): 112. 5
Acres of Paving: 0
CalEEMod Version: CalEEMod. 2016. 3.2 PMPage 8 of 44 Date: 1/6/2021 1:52 Village South Specific Plan ( Proposed) - Los Angeles- South Coast County, Annual Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor Demolition Concrete/ Industrial Saws 1 8.00 81 0.73
Demolition Excavators 3 8.00 158 0.38
Demolition Rubber Tired Dozers 2 8.00 247 0.40
Site Preparation Rubber Tired Dozers 3 8.00 247 0.40
Site Preparation Tractors/ Loaders/ Backhoes 4 8.00 97 0.37 Grading Excavators 2 8.00 158 0.38
Grading Graders 1 8.00 187 0.41
Grading Rubber Tired Dozers 1 8.00 247 0.40
Grading Scrapers 2 8.00 367 0.48
Grading Tractors/ Loaders/ Backhoes 2 8.00 97 0.37
Building Construction Cranes 1 7.00 231 0.29
Building Construction Forklifts 3 8.00 89 0.20
Building Construction Generator Sets 1 8.00 84 0.74
Building Construction Tractors/ Loaders/ Backhoes 3 7.00 97 0.37 Building Construction Welders 1 8.00 46 0.45
Paving Pavers 2 8.00 130 0.42
Paving Paving Equipment 2 8.00 132 0.36
Paving Rollers 2 8.00 80 0.38
Architectural Coating Air Compressors 1 6.00 78 0.48
Trips and VMT
CalEEMod Version: CalEEMod. 2016. 3.2 PMPage 9 of 44 Date: 1/6/2021 1:52 Village South Specific Plan ( Proposed) - Los Angeles- South Coast County, Annual

3.2 Demolition - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2. 5
Exhaust
PM2. 5
PM2. 5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/ yr MT/ yr
Fugitive Dust 0.0496 0.0000 0.0496 7.5100e0030.0000 7.5100e0030.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off- Road 0.0475 0.4716 0.3235 5.8000e0040.0233 0.0233 0.0216 0.0216 0.0000 51. 0012 51. 0012 0.0144 0.0000 51. 3601 Total 0.0475 0.4716 0.3235 5.8000e0040.0496 0.0233 0.0729 7.5100e0030.0216 0.0291 0.0000 51.0012 51.0012 0.0144 0.0000 51.3601 Unmitigated Construction On- Site

3.1 Mitigation Measures Construction
Phase Name Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
Demolition 6 15.00 0.00 458.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT Site Preparation 7 18.00 0.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT Grading 8 20.00 0.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT Building Construction 9 801.00 143.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT Paving 6 15.00 0.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT Architectural Coating 1 160.00 0.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT CalEEMod Version: CalEEMod. 2016. 3.2 PMPage 10 of 44 Date: 1/6/2021 1:52 Village South Specific Plan ( Proposed) - Los Angeles- South Coast County, Annual

3.2 Demolition - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2. 5
Exhaust
PM2. 5
PM2. 5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/ yr MT/ yr
Hauling 1.9300e0030.0634 0.0148 1.8000e0043.9400e0031.9000e0044.1300e0031.0800e0031.8000e0041.2600e0030.0000 17.4566 17.4566 1.2100e0030.0000 17.4869 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 9.7000e0047.5000e0048.5100e0032.0000e0052.4700e0032.0000e0052.4900e0036.5000e0042.0000e0056.7000e0040.0000 2.2251 2.2251 7.0000e0050.0000 2.2267 Total 2.9000e0030.0641 0.0233 2.0000e0046.4100e0032.1000e0046.6200e0031.7300e0032.0000e0041.9300e0030.0000 19.6816 19.6816 1.2800e0030.0000 19.7136 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2. 5
Exhaust
PM2. 5
PM2. 5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/ yr MT/ yr
Fugitive Dust 0.0496 0.0000 0.0496 7.5100e0030.0000 7.5100e0030.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off- Road 0.0475 0.4716 0.3235 5.8000e0040.0233 0.0233 0.0216 0.0216 0.0000 51. 0011 51. 0011 0.0144 0.0000 51. 3600 Total 0.0475 0.4716 0.3235 5.8000e0040.0496 0.0233 0.0729 7.5100e0030.0216 0.0291 0.0000 51. 0011 51. 0011 0.0144 0.0000 51. 3600 Mitigated Construction On-Site
CalEEMod Version: CalEEMod. 2016. 3.2 PMPage 11 of 44 Date: 1/6/2021 1:52 Village South Specific Plan ( Proposed) - Los Angeles- South Coast County, Annual

3.3 Site Preparation - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2. 5
Exhaust
PM2. 5
PM2. 5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/ yr MT/ yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 7.7000e0046.0000e0046.8100e0032.0000e0051.9700e0032.0000e0051.9900e0035.2000e0041.0000e0055.4000e0040.0000 1.7801 1.7801 5.0000e0050.0000 1.7814 Total 7.7000e0046.0000e0046.8100e0032.0000e0051.9700e0032.0000e0051.9900e0035.2000e0041.0000e0055.4000e0040.0000 1.7801 1.7801 5.0000e0050.0000 1.7814 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2. 5
Exhaust
PM2. 5
PM2. 5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/ yr MT/ yr
Fugitive Dust 0.1807 0.0000 0.1807 0.0993 0.0000 0.0993 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off- Road 0.0389 0.4050 0.2115 3.8000e0040.0204 0.0204 0.0188 0.0188 0.0000 33. 4357 33. 4357 0.0108 0.0000 33. 7060 Total 0.0389 0.4050 0.2115 3.8000e0040.1807 0.0204 0.2011 0.0993 0.0188 0.1181 0.0000 33.4357 33.4357 0.0108 0.0000 33.7060 Mitigated Construction On-Site
CalEEMod Version: CalEEMod. 2016. 3.2 PMPage 13 of 44 Date: 1/6/2021 1:52 Village South Specific Plan ( Proposed) - Los Angeles- South Coast County, Annual

3.4 Grading - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2. 5
Exhaust
PM2. 5
PM2. 5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/ yr MT/ yr
Fugitive Dust 0.1741 0.0000 0.1741 0.0693 0.0000 0.0693 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off- Road 0.0796 0.8816 0.5867 1.1800e0030.0377 0.0377 0.0347 0.0347 0.0000 103. 5405 103. 5405 0.0335 0.0000 104. 3776 Total 0.0796 0.8816 0.5867 1.1800e0030.1741 0.0377 0.2118 0.0693 0.0347 0.1040 0.0000 103. 5405 103. 5405 0.0335 0.0000 104. 3776 Unmitigated Construction On- Site
CalEEMod Version: CalEEMod. 2016. 3.2 PMPage 14 of 44 Date: 1/6/2021 1:52 Village South Specific Plan ( Proposed) - Los Angeles- South Coast County, Annual

3.4 Grading - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2. 5
Exhaust
PM2. 5
PM2. 5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/ yr MT/ yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 1.6400e0031.2700e0030.0144 4.0000e0054.1600e0033.0000e0054.2000e0031.1100e0033.0000e0051.1400e0030.0000 3.7579 3.7579 1.1000e0040.0000 3.7607 Total 1.6400e0031.2700e0030.0144 4.0000e0054.1600e0033.0000e0054.2000e0031.1100e0033.0000e0051.1400e0030.0000 3.7579 3.7579 1.1000e0040.0000 3.7607 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2. 5
Exhaust
PM2. 5
PM2. 5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/ yr MT/ yr
Fugitive Dust 0.1741 0.0000 0.1741 0.0693 0.0000 0.0693 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off- Road 0.0796 0.8816 0.5867 1.1800e0030.0377 0.0377 0.0347 0.0347 0.0000 103. 5403 103. 5403 0.0335 0.0000 104. 3775 Total 0.0796 0.8816 0.5867 1.1800e0030.1741 0.0377 0.2118 0.0693 0.0347 0.1040 0.0000 103. 5403 103. 5403 0.0335 0.0000 104. 3775 Mitigated Construction On-Site
CalEEMod Version: CalEEMod. 2016. 3.2 PMPage 15 of 44 Date: 1/6/2021 1:52 Village South Specific Plan ( Proposed) - Los Angeles- South Coast County, Annual

3.4 Grading - 2022
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2. 5
Exhaust
PM2. 5
PM2. 5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/ yr MT/ yr
Fugitive Dust 0.0807 0.0000 0.0807 0.0180 0.0000 0.0180 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off- Road 0.0127 0.1360 0.1017 2.2000e0045.7200e0035.7200e0035.2600e0035.2600e0030.0000 19. 0871 19. 0871 6.1700e0030.0000 19. 2414 Total 0.0127 0.1360 0.1017 2.2000e0040.0807 5.7200e0030.0865 0.0180 5.2600e0030.0233 0.0000 19.0871 19.0871 6.1700e0030.0000 19.2414 Unmitigated Construction On- Site
CalEEMod Version: CalEEMod. 2016. 3.2 PMPage 16 of 44 Date: 1/6/2021 1:52 Village South Specific Plan ( Proposed) - Los Angeles- South Coast County, Annual

3.4 Grading - 2022
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2. 5
Exhaust
PM2. 5
PM2. 5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/ yr MT/ yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 2.8000e0042.1000e0042.4400e0031.0000e0057.7000e0041.0000e0057.7000e0042.0000e0041.0000e0052.1000e0040.0000 0.6679 0.6679 2.0000e0050.0000 0.6684 Total 2.8000e0042.1000e0042.4400e0031.0000e0057.7000e0041.0000e0057.7000e0042.0000e0041.0000e0052.1000e0040.0000 0.6679 0.6679 2.0000e0050.0000 0.6684 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2. 5
Exhaust
PM2. 5
PM2. 5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/ yr MT/ yr
Fugitive Dust 0.0807 0.0000 0.0807 0.0180 0.0000 0.0180 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off- Road 0.0127 0.1360 0.1017 2.2000e0045.7200e0035.7200e0035.2600e0035.2600e0030.0000 19. 0871 19. 0871 6.1700e0030.0000 19. 2414 Total 0.0127 0.1360 0.1017 2.2000e0040.0807 5.7200e0030.0865 0.0180 5.2600e0030.0233 0.0000 19.0871 19.0871 6.1700e0030.0000 19.2414 Mitigated Construction On-Site
CalEEMod Version: CalEEMod. 2016. 3.2 PMPage 17 of 44 Date: 1/6/2021 1:52 Village South Specific Plan ( Proposed) - Los Angeles- South Coast County, Annual

3.5 Building Construction - 2022
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2. 5
Exhaust
PM2. 5
PM2. 5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/ yr MT/ yr
Off-Road 0.2158 1.9754 2.0700 3.4100e0030.1023 0.1023 0.0963 0.0963 0.0000 293. 1324 293. 1324 0.0702 0.0000 294. 8881 Total 0.2158 1.9754 2.0700 3.4100e0030.1023 0.1023 0.0963 0.0963 0.0000 293. 1324 293. 1324 0.0702 0.0000 294. 8881 Unmitigated Construction On- Site
CalEEMod Version: CalEEMod. 2016. 3.2 PMPage 18 of 44 Date: 1/6/2021 1:52 Village South Specific Plan ( Proposed) - Los Angeles- South Coast County, Annual

3.5 Building Construction - 2022
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2. 5
Exhaust
PM2. 5
PM2. 5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/ yr MT/ yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0527 1.6961 0.4580 4.5500e0030.1140 3.1800e0030.1171 0.0329 3.0400e0030.0359 0.0000 441. 9835 441. 9835 0.0264 0.0000 442. 6435 Worker 0.4088 0.3066 3.5305 0.0107 1.1103 8.8700e0031.1192 0.2949 8.1700e0030.3031 0.0000 966. 8117 966. 8117 0.0266 0.0000 967. 4773 Total 0.4616 2.0027 3.9885 0.0152 1.2243 0.0121 1.2363 0.3278 0.0112 0.3390 0.0000 1,408. 795 2 1,408. 795
2 0.0530 0.0000 1,410. 120
8 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2. 5
Exhaust
PM2. 5
PM2. 5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/ yr MT/ yr
Off-Road 0.2158 1.9754 2.0700 3.4100e0030.1023 0.1023 0.0963 0.0963 0.0000 293. 1321 293. 1321 0.0702 0.0000 294. 8877 Total 0.2158 1.9754 2.0700 3.4100e0030.1023 0.1023 0.0963 0.0963 0.0000 293. 1321 293. 1321 0.0702 0.0000 294. 8877 Mitigated Construction On-Site
CalEEMod Version: CalEEMod. 2016. 3.2 PMPage 19 of 44 Date: 1/6/2021 1:52 Village South Specific Plan ( Proposed) - Los Angeles- South Coast County, Annual

3.5 Building Construction - 2023
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2. 5
Exhaust
PM2. 5
PM2. 5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/ yr MT/ yr
Off-Road 0.1942 1.7765 2.0061 3.3300e0030.0864 0.0864 0.0813 0.0813 0.0000 286. 2789 286. 2789 0.0681 0.0000 287. 9814 Total 0.1942 1.7765 2.0061 3.3300e0030.0864 0.0864 0.0813 0.0813 0.0000 286. 2789 286. 2789 0.0681 0.0000 287. 9814 Unmitigated Construction On- Site
CalEEMod Version: CalEEMod. 2016. 3.2 PMPage 20 of 44 Date: 1/6/2021 1:52 Village South Specific Plan ( Proposed) - Los Angeles- South Coast County, Annual

3.5 Building Construction - 2023
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2. 5
Exhaust
PM2. 5
PM2. 5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/ yr MT/ yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0382 1.2511 0.4011 4.3000e0030.1113 1.4600e0030.1127 0.0321 1.4000e0030.0335 0.0000 417. 9930 417. 9930 0.0228 0.0000 418. 5624 Worker 0.3753 0.2708 3.1696 0.0101 1.0840 8.4100e0031.0924 0.2879 7.7400e0030.2957 0.0000 909. 3439 909. 3439 0.0234 0.0000 909. 9291 Total 0.4135 1.5218 3.5707 0.0144 1.1953 9.8700e0031.2051 0.3200 9.1400e0030.3292 0.0000 1,327. 336 9 1,327. 336
9 0.0462 0.0000 1,328. 491
6 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2. 5
Exhaust
PM2. 5
PM2. 5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/ yr MT/ yr
Off-Road 0.1942 1.7765 2.0061 3.3300e0030.0864 0.0864 0.0813 0.0813 0.0000 286. 2785 286. 2785 0.0681 0.0000 287. 9811 Total 0.1942 1.7765 2.0061 3.3300e0030.0864 0.0864 0.0813 0.0813 0.0000 286. 2785 286. 2785 0.0681 0.0000 287. 9811 Mitigated Construction On-Site
CalEEMod Version: CalEEMod. 2016. 3.2 PMPage 21 of 44 Date: 1/6/2021 1:52 Village South Specific Plan ( Proposed) - Los Angeles- South Coast County, Annual

3.6 Paving - 2023
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2. 5
Exhaust
PM2. 5
PM2. 5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/ yr MT/ yr
Off-Road 6.7100e0030.0663 0.0948 1.5000e0043.3200e0033.3200e0033.0500e0033.0500e0030.0000 13.0175 13.0175 4.2100e0030.0000 13.1227 Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 6.7100e0030.0663 0.0948 1.5000e0043.3200e0033.3200e0033.0500e0033.0500e0030.0000 13. 0175 13. 0175 4.2100e0030.0000 13. 1227 Unmitigated Construction On- Site
CalEEMod Version: CalEEMod. 2016. 3.2 PMPage 22 of 44 Date: 1/6/2021 1:52 Village South Specific Plan ( Proposed) - Los Angeles- South Coast County, Annual

3.6 Paving - 2023
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2. 5
Exhaust
PM2. 5
PM2. 5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/ yr MT/ yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 3.7000e0042.7000e0043.1200e0031.0000e0051.0700e0031.0000e0051.0800e0032.8000e0041.0000e0052.9000e0040.0000 0.8963 0.8963 2.0000e0050.0000 0.8968 Total 3.7000e0042.7000e0043.1200e0031.0000e0051.0700e0031.0000e0051.0800e0032.8000e0041.0000e0052.9000e0040.0000 0.8963 0.8963 2.0000e0050.0000 0.8968 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2. 5
Exhaust
PM2. 5
PM2. 5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/ yr MT/ yr
Off-Road 6.7100e0030.0663 0.0948 1.5000e0043.3200e0033.3200e0033.0500e0033.0500e0030.0000 13.0175 13.0175 4.2100e0030.0000 13.1227 Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 6.7100e0030.0663 0.0948 1.5000e0043.3200e0033.3200e0033.0500e0033.0500e0030.0000 13. 0175 13. 0175 4.2100e0030.0000 13. 1227 Mitigated Construction On-Site
CalEEMod Version: CalEEMod. 2016. 3.2 PMPage 23 of 44 Date: 1/6/2021 1:52 Village South Specific Plan ( Proposed) - Los Angeles- South Coast County, Annual

3.6 Paving - 2024
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2. 5
Exhaust
PM2. 5
PM2. 5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/ yr MT/ yr
Off-Road 0.0109 0.1048 0.1609 2.5000e0045.1500e0035.1500e0034.7400e0034.7400e0030.0000 22.0292 22.0292 7.1200e0030.0000 22.2073 Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0109 0.1048 0.1609 2.5000e0045.1500e0035.1500e0034.7400e0034.7400e0030.0000 22.0292 22.0292 7.1200e0030.0000 22.2073 Unmitigated Construction On- Site
CalEEMod Version: CalEEMod. 2016. 3.2 PMPage 24 of 44 Date: 1/6/2021 1:52 Village South Specific Plan ( Proposed) - Los Angeles- South Coast County, Annual

3.6 Paving - 2024
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2. 5
Exhaust
PM2. 5
PM2. 5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/ yr MT/ yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 5.9000e0044.1000e0044.9200e0032.0000e0051.8100e0031.0000e0051.8200e0034.8000e0041.0000e0054.9000e0040.0000 1.4697 1.4697 4.0000e0050.0000 1.4706 Total 5.9000e0044.1000e0044.9200e0032.0000e0051.8100e0031.0000e0051.8200e0034.8000e0041.0000e0054.9000e0040.0000 1.4697 1.4697 4.0000e0050.0000 1.4706 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2. 5
Exhaust
PM2. 5
PM2. 5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/ yr MT/ yr
Off-Road 0.0109 0.1048 0.1609 2.5000e0045.1500e0035.1500e0034.7400e0034.7400e0030.0000 22.0292 22.0292 7.1200e0030.0000 22.2073 Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0109 0.1048 0.1609 2.5000e0045.1500e0035.1500e0034.7400e0034.7400e0030.0000 22. 0292 22. 0292 7.1200e0030.0000 22. 2073 Mitigated Construction On-Site
CalEEMod Version: CalEEMod. 2016. 3.2 PMPage 25 of 44 Date: 1/6/2021 1:52 Village South Specific Plan ( Proposed) - Los Angeles- South Coast County, Annual

3.7 Architectural Coating - 2024
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2. 5
Exhaust
PM2. 5
PM2. 5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/ yr MT/ yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0101 6.9900e0030.0835 2.8000e0040.0307 2.3000e0040.0309 8.1500e0032.2000e0048.3700e0030.0000 24.9407 24.9407 6.1000e0040.0000 24.9558 Total 0.0101 6.9900e0030.0835 2.8000e0040.0307 2.3000e0040.0309 8.1500e0032.2000e0048.3700e0030.0000 24.9407 24.9407 6.1000e0040.0000 24.9558 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2. 5
Exhaust
PM2. 5
PM2. 5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/ yr MT/ yr
Archit. Coating 4.1372 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off- Road 3.1600e0030.0213 0.0317 5.0000e0051.0700e0031.0700e0031.0700e0031.0700e0030.0000 4.4682 4.4682 2.5000e0040.0000 4.4745 Total 4.1404 0.0213 0.0317 5.0000e0051.0700e0031.0700e0031.0700e0031.0700e0030.0000 4.4682 4.4682 2.5000e0040.0000 4.4745 Mitigated Construction On-Site
CalEEMod Version: CalEEMod. 2016. 3.2 PMPage 27 of 44 Date: 1/6/2021 1:52 Village South Specific Plan ( Proposed) - Los Angeles- South Coast County, Annual

4.0 Operational Detail - Mobile

4.1 Mitigation Measures Mobile

3.7 Architectural Coating - 2024
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2. 5
Exhaust
PM2. 5
PM2. 5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/ yr MT/ yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0101 6.9900e0030.0835 2.8000e0040.0307 2.3000e0040.0309 8.1500e0032.2000e0048.3700e0030.0000 24.9407 24.9407 6.1000e0040.0000 24.9558 Total 0.0101 6.9900e0030.0835 2.8000e0040.0307 2.3000e0040.0309 8.1500e0032.2000e0048.3700e0030.0000 24.9407 24.9407 6.1000e0040.0000 24.9558 Mitigated Construction Off-Site
CalEEMod Version: CalEEMod. 2016. 3.2 PMPage 28 of 44 Date: 1/6/2021 1:52 Village South Specific Plan ( Proposed) - Los Angeles- South Coast County, Annual ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2. 5
Exhaust
PM2. 5
PM2. 5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/ yr MT/ yr
Mitigated 1.5857 7.9962 19.1834 0.0821 7.7979 0.0580 7.8559 2.0895 0.0539 2.1434 0.0000 7,620. 498 6 7,620. 498
6 0.3407 0.0000 7,629. 016
2 Unmitigated 1.5857 7.9962 19.1834 0.0821 7.7979 0.0580 7.8559 2.0895 0.0539 2.1434 0.0000 7,620. 498 6 7,620. 498
6 0.3407 0.0000 7,629. 016
2 4.2 Trip Summary Information

4.3 Trip Type Information
Average Daily Trip Rate Unmitigated Mitigated
Land Use Weekday Saturday Sunday Annual VMT Annual VMT
Apartments Low Rise 145.75 154.25 154.00 506,227 506,227 Apartments Mid Rise 4,026.75 3,773.25 4075. 50 13,660,065 13,660,065 General Office Building 288.45 62.55 31.05 706, 812 706,812 High Turnover ( Sit Down Restaurant) 2,368.80 2,873.52 2817. 72 3,413, 937 3,413,937 Hotel 192.00 187.50 160.00 445, 703 445,703
Quality Restaurant 501.12 511.92 461.20 707,488 707,488 Regional Shopping Center 528.08 601.44 357.84 1,112,221 1,112,221 Total 8,050.95 8,164.43 8,057.31 20,552,452 20,552,452
CalEEMod Version: CalEEMod. 2016. 3.2 PMPage 29 of 44 Date: 1/6/2021 1:52 Village South Specific Plan ( Proposed) - Los Angeles- South Coast County, Annual Miles Trip % Trip Purpose %
Land Use H-W or C-W H-S or C-C H-O or C-NW H-W or C-W H-S or C-C H-O or C-NW Primary Diverted Pass- by Apartments Low Rise 14.70 5.90 8.70 40.20 19.20 40.60 86 11 3 Apartments Mid Rise 14.70 5.90 8.70 40.20 19.20 40.60 86 11 3 General Office Building 16.60 8.40 6.90 33.00 48.00 19.00 77 19 4 High Turnover ( Sit Down
Restaurant)

16.60 8.40 6.90 8.50 72.50 19.00 37 20 43
Hotel 16.60 8.40 6.90 19.40 61.60 19.00 58 38 4
Quality Restaurant 16.60 8.40 6.90 12.00 69.00 19.00 38 18 44 Regional Shopping Center 16.60 8.40 6.90 16.30 64.70 19.00 54 35 11

5.0 Energy Detail

5.1 Mitigation Measures Energy

4.4 Fleet Mix
Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH Apartments Low Rise 0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 Apartments Mid Rise 0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 General Office Building 0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 High Turnover (Sit Down
Restaurant)

0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 Hotel 0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 Quality Restaurant 0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 Regional Shopping Center 0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 Historical Energy Use: N
CalEEMod Version: CalEEMod. 2016. 3.2 PMPage 30 of 44 Date: 1/6/2021 1:52 Village South Specific Plan ( Proposed) - Los Angeles- South Coast County, Annual ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2. 5
Exhaust
PM2. 5
PM2. 5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/ yr MT/ yr
Electricity
Mitigated

0.0000 0.0000 0.0000 0.0000 0.0000 2,512. 646
5 2,512. 646
5 0.1037 0.0215 2,521. 635
6 Electricity
Unmitigated

0.0000 0.0000 0.0000 0.0000 0.0000 2,512. 646
5 2,512. 646
5 0.1037 0.0215 2,521. 635
6 NaturalGas
Mitigated

0.1398 1.2312 0.7770 7.6200e0030.0966 0.0966 0.0966 0.0966 0.0000 1,383. 426 7 1,383. 426
7 0.0265 0.0254 1,391. 647
8 NaturalGas
Unmitigated

0.1398 1.2312 0.7770 7.6200e0030.0966 0.0966 0.0966 0.0966 0.0000 1,383. 426 7 1,383. 426
7 0.0265 0.0254 1,391. 647
8 CalEEMod Version: CalEEMod. 2016. 3.2 PMPage 31 of 44 Date: 1/6/2021 1:52 Village South Specific Plan ( Proposed) - Los Angeles- South Coast County, Annual

1.30613e
007

0.0704 0.6018 0.2561 3.8400e0030.0487 0.0487 0.0487 0.0487 0.0000 696. 9989 696. 9989 0.0134 0.0128 701. 1408 General Office
Building
468450 2.5300e0030.0230 0.0193 1.4000e0041.7500e0031.7500e0031.7500e0031.7500e0030.0000 24.9983 24.9983 4.8000e0044.6000e00425.1468 High Turnover ( Sit
Down Restaurant)

8.30736e
006

0.0448 0.4072 0.3421 2.4400e0030.0310 0.0310 0.0310 0.0310 0.0000 443. 3124 443. 3124 8.5000e0038.1300e003445. 9468 Hotel 1.74095e
006

9.3900e0030.0853 0.0717 5.1000e0046.4900e0036.4900e0036.4900e0036.4900e0030.0000 92. 9036 92. 9036 1.7800e0031.7000e00393. 4557 Quality
Restaurant

1.84608e
006

9.9500e0030.0905 0.0760 5.4000e0046.8800e0036.8800e0036.8800e0036.8800e0030.0000 98.5139 98.5139 1.8900e0031.8100e00399.0993 Regional
Shopping Center
91840 5.0000e0044.5000e0033.7800e0033.0000e0053.4000e0043.4000e0043.4000e0043.4000e0040.0000 4.9009 4.9009 9.0000e0059.0000e0054.9301 Total 0.1398 1.2312 0.7770 7.6200e0030.0966 0.0966 0.0966 0.0966 0.0000 1,383. 426 8 1,383. 426
8 0.0265 0.0254 1,391. 647
8 Unmitigated
CalEEMod Version: CalEEMod. 2016. 3.2 PMPage 32 of 44 Date: 1/6/2021 1:52 Village South Specific Plan ( Proposed) - Los Angeles- South Coast County, Annual

1.30613e
007

8.30736e
006

0.0448 0.4072 0.3421 2.4400e0030.0310 0.0310 0.0310 0.0310 0.0000 443. 3124 443. 3124 8.5000e0038.1300e003445. 9468 Hotel 1.74095e
006

9.3900e0030.0853 0.0717 5.1000e0046.4900e0036.4900e0036.4900e0036.4900e0030.0000 92. 9036 92. 9036 1.7800e0031.7000e00393. 4557 Quality
Restaurant

1.84608e
006

9.9500e0030.0905 0.0760 5.4000e0046.8800e0036.8800e0036.8800e0036.8800e0030.0000 98.5139 98.5139 1.8900e0031.8100e00399.0993 Regional
Shopping Center
91840 5.0000e0044.5000e0033.7800e0033.0000e0053.4000e0043.4000e0043.4000e0043.4000e0040.0000 4.9009 4.9009 9.0000e0059.0000e0054.9301 Total 0.1398 1.2312 0.7770 7.6200e0030.0966 0.0966 0.0966 0.0966 0.0000 1,383. 426 8 1,383. 426
8 0.0265 0.0254 1,391. 647
8 Mitigated
CalEEMod Version: CalEEMod. 2016. 3.2 PMPage 33 of 44 Date: 1/6/2021 1:52 Village South Specific Plan ( Proposed) - Los Angeles- South Coast County, Annual

5.3 Energy by Land Use - Electricity
Electricity
Use
Total CO2 CH4 N2O CO2e
Land Use kWh/ yr MT/ yr
Apartments Low
Rise
106010 33.7770 1.3900e0032.9000e00433.8978
Apartments Mid
Rise

3.94697e
006
1,257. 587
9 0.0519 0.0107 1,262. 086
9 General Office
Building
584550 186. 2502 7.6900e0031.5900e003186. 9165
High Turnover ( Sit
Down Restaurant)

6.1 Mitigation Measures Area

6.0 Area Detail

5.3 Energy by Land Use - Electricity
Electricity
Use
Total CO2 CH4 N2O CO2e
Land Use kWh/ yr MT/ yr
Apartments Low
Rise
106010 33.7770 1.3900e0032.9000e00433.8978
Apartments Mid
Rise

3.94697e
006
1,257. 587
9 0.0519 0.0107 1,262. 086
9 General Office
Building
584550 186. 2502 7.6900e0031.5900e003186. 9165
High Turnover ( Sit
Down Restaurant)

1.58904e
006
506. 3022 0.0209 4.3200e003508. 1135
Hotel 550308 175. 3399 7.2400e0031.5000e003175. 9672
Quality
Restaurant
353120 112. 5116 4.6500e0039.6000e004112. 9141
Regional
Shopping Center
756000 240. 8778 9.9400e0032.0600e003241. 7395
Total 2,512. 646
5 0.1037 0.0215 2,521. 635
6 Mitigated
CalEEMod Version: CalEEMod. 2016. 3.2 PMPage 35 of 44 Date: 1/6/2021 1:52 Village South Specific Plan ( Proposed) - Los Angeles- South Coast County, Annual ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2. 5
Exhaust
PM2. 5
PM2. 5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/ yr MT/ yr
Mitigated 5.1437 0.2950 10.3804 1.6700e0030.0714 0.0714 0.0714 0.0714 0.0000 220. 9670 220. 9670 0.0201 3.7400e003222. 5835 Unmitigated 5.1437 0.2950 10.3804 1.6700e0030.0714 0.0714 0.0714 0.0714 0.0000 220. 9670 220. 9670 0.0201 3.7400e003222. 5835

6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2. 5
Exhaust
PM2. 5
PM2. 5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory tons/ yr MT/ yr
Architectural
Coating

0.4137 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Consumer
Products

7.1 Mitigation Measures Water

7.0 Water Detail

0.4137 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Consumer
Products

4.3998 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Hearth 0.0206 0.1763 0.0750 1.1200e0030.0143 0.0143 0.0143 0.0143 0.0000 204. 1166 204. 1166 3.9100e0033.7400e003205. 3295 Landscaping 0.3096 0.1187 10.3054 5.4000e0040.0572 0.0572 0.0572 0.0572 0.0000 16.8504 16.8504 0.0161 0.0000 17.2540 Total 5.1437 0.2950 10. 3804 1.6600e0030.0714 0.0714 0.0714 0.0714 0.0000 220. 9670 220. 9670 0.0201 3.7400e003222. 5835 Mitigated
CalEEMod Version: CalEEMod. 2016. 3.2 PMPage 37 of 44 Date: 1/6/2021 1:52 Village South Specific Plan ( Proposed) - Los Angeles- South Coast County, Annual Total CO2 CH4 N2O CO2e
Category MT/ yr
Mitigated 585. 8052 3.0183 0.0755 683. 7567
Unmitigated 585. 8052 3.0183 0.0755 683. 7567
CalEEMod Version: CalEEMod. 2016. 3.2 PMPage 38 of 44 Date: 1/6/2021 1:52 Village South Specific Plan ( Proposed) - Los Angeles- South Coast County, Annual

7.2 Water by Land Use
Indoor/ Out
door Use
Total CO2 CH4 N2O CO2e
Land Use Mgal MT/ yr
Apartments Low
Rise

1.62885 /

1.02688

10.9095 0.0535 1.3400e00312.6471
Apartments Mid
Rise

63. 5252 /

40.0485
425. 4719 2.0867 0.0523 493. 2363
General Office
Building

7.99802 /

4.90201

53.0719 0.2627 6.5900e00361.6019
High Turnover ( Sit
Down Restaurant)

10.9272 /

0.697482

51.2702 0.3580 8.8200e00362.8482
Hotel 1.26834 /

0.140927

6.1633 0.0416 1.0300e0037.5079
Quality
Restaurant

2.42827 /

0.154996

11.3934 0.0796 1.9600e00313.9663
Regional
Shopping Center

4.14806 /

2.54236

27.5250 0.1363 3.4200e00331.9490
Total 585. 8052 3.0183 0.0755 683. 7567
Unmitigated
CalEEMod Version: CalEEMod. 2016. 3.2 PMPage 39 of 44 Date: 1/6/2021 1:52 Village South Specific Plan ( Proposed) - Los Angeles- South Coast County, Annual

8.1 Mitigation Measures Waste

7.2 Water by Land Use
Indoor/ Out
door Use
Total CO2 CH4 N2O CO2e
Land Use Mgal MT/ yr
Apartments Low
Rise

1.62885 /

1.02688

10.9095 0.0535 1.3400e00312.6471
Apartments Mid
Rise

63. 5252 /

40.0485
425. 4719 2.0867 0.0523 493. 2363
General Office
Building

7.99802 /

4.90201

53.0719 0.2627 6.5900e00361.6019
High Turnover ( Sit
Down Restaurant)

10.9272 /

0.697482

51.2702 0.3580 8.8200e00362.8482
Hotel 1.26834 /

0.140927

6.1633 0.0416 1.0300e0037.5079
Quality
Restaurant

2.42827 /

0.154996

11.3934 0.0796 1.9600e00313.9663
Regional
Shopping Center

4.14806 /

2.54236

27.5250 0.1363 3.4200e00331.9490
Total 585. 8052 3.0183 0.0755 683. 7567
Mitigated

8.0 Waste Detail
CalEEMod Version: CalEEMod. 2016. 3.2 PMPage 40 of 44 Date: 1/6/2021 1:52 Village South Specific Plan ( Proposed) - Los Angeles- South Coast County, Annual Total CO2 CH4 N2O CO2e
MT/ yr
Mitigated 207. 8079 12.2811 0.0000 514. 8354
Unmitigated 207. 8079 12.2811 0.0000 514. 8354
Category/ Year
CalEEMod Version: CalEEMod. 2016. 3.2 PMPage 41 of 44 Date: 1/6/2021 1:52 Village South Specific Plan ( Proposed) - Los Angeles- South Coast County, Annual

8.2 Waste by Land Use
Waste
Disposed
Total CO2 CH4 N2O CO2e
Land Use tons MT/ yr
Apartments Low
Rise

11.5 2.3344 0.1380 0.0000 5.7834
Apartments Mid
Rise
448. 5 91. 0415 5.3804 0.0000 225. 5513
General Office
Building

41.85 8.4952 0.5021 0.0000 21.0464
High Turnover ( Sit
Down Restaurant)
428. 4 86.9613 5.1393 0.0000 215. 4430
Hotel 27. 38 5.5579 0.3285 0.0000 13. 7694
Quality
Restaurant

7.3 1.4818 0.0876 0.0000 3.6712
Regional
Shopping Center

58.8 11.9359 0.7054 0.0000 29.5706
Total 207. 8079 12.2811 0.0000 514. 8354
Unmitigated
CalEEMod Version: CalEEMod. 2016. 3.2 PMPage 42 of 44 Date: 1/6/2021 1:52 Village South Specific Plan ( Proposed) - Los Angeles- South Coast County, Annual

8.2 Waste by Land Use
Waste
Disposed
Total CO2 CH4 N2O CO2e
Land Use tons MT/ yr
Apartments Low
Rise

11.5 2.3344 0.1380 0.0000 5.7834
Apartments Mid
Rise
448. 5 91. 0415 5.3804 0.0000 225. 5513
General Office
Building

41.85 8.4952 0.5021 0.0000 21.0464
High Turnover ( Sit
Down Restaurant)
428. 4 86.9613 5.1393 0.0000 215. 4430
Hotel 27.38 5.5579 0.3285 0.0000 13.7694
Quality
Restaurant

7.3 1.4818 0.0876 0.0000 3.6712
Regional
Shopping Center

58.8 11.9359 0.7054 0.0000 29.5706
Total 207. 8079 12.2811 0.0000 514. 8354
Mitigated

9.0 Operational Offroad
Equipment Type Number Hours/ Day Days/Year Horse Power Load Factor Fuel Type

10.0 Stationary Equipment
Fire Pumps and Emergency Generators
Equipment Type Number Hours/ Day Hours/ Year Horse Power Load Factor Fuel Type CalEEMod Version: CalEEMod. 2016. 3.2 PMPage 43 of 44 Date: 1/6/2021 1:52 Village South Specific Plan ( Proposed) - Los Angeles- South Coast County, Annual

11.0 Vegetation
Boilers
Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type User Defined Equipment
Equipment Type Number
CalEEMod Version: CalEEMod. 2016. 3.2 PMPage 44 of 44 Date: 1/6/2021 1:52 Village South Specific Plan ( Proposed) - Los Angeles- South Coast County, Annual

1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
9 Wind Speed ( m/s) 2.2 Precipitation Freq (Days) 33

1.3 User Entered Comments & Non-Default Data

1.0 Project Characteristics
Utility Company Southern California Edison
2028Operational Year
CO2 Intensity
lb/MWhr)
702.44 029CH4 Intensity 0.
lb/MWhr)
006N2O Intensity 0.
lb/MWhr)
Village South Specific Plan (Proposed)
Los Angeles- South Coast County, Summer
CalEEMod Version: CalEEMod. 2016. 3.2 PMPage 1 of 35 Date: 1/6/2021 1:54 Village South Specific Plan ( Proposed) - Los Angeles- South Coast County, Summer Project Characteristics - Consistent with the DEIR' s model.