Agenda packet — Brea City Council, June 2, 2026 (part 14 of 19)

O1-6 The comment requests that the letter and all attachments be included in the administrative record for the 2050 General Plan Update and Draft PEIR. The comment letter, including all attachments, as well as responses to comments, are included in the Final PEIR and will be part of the administrative record.

O1-7 The comment states that any future redevelopment of Sycamore’s properties should follow a process similar to the Brea 265 Project and provides a description of that project and its planning process. The comment does not address the adequacy of the PEIR or raise environmental issues. No response is required.

O1-8 The comment asserts that conditions similar to those of the Brea 265 Project exist on Sycamore’s properties and recommends that the City recognize that future annexation or redevelopment proposals may be more appropriately addressed through a sitespecific planning process rather than through strict application of the Hillside Residential designation. The comment pertains to planning policy considerations and does not address environmental issues or the adequacy of the PEIR. The comment has been forwarded to the decision makers, and no further response is required.

O1-9 The comment cites goals and policies from the 2050 General Plan Update and the 2021–2029 Housing Element that, in the commenter’s view, support flexible, sitespecific planning approaches. The comment further asserts that the Brea 265 Project demonstrates that annexation with a specific plan is an effective mechanism to accommodate housing in constrained hillside areas. The comment does not address environmental issues or the adequacy of the PEIR. The comment has been forwarded to the decision makers, and no further response is required.

O1-10 The comment recommends designation of a “Future Specific Plan” land use category for the CA-57 North Property and Carbon Canyon Property, including the Olinda Drive Property, in the 2050 General Plan Update. The comment does not address environmental issues or the adequacy of the PEIR. The comment has been forwarded to the decision makers, and no further response is required.

O1-11 The comment states that the 2050 General Plan Update should not predetermine development potential through rigid land use designations and should instead recognize PEIR 2-47 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR that properties such as the CA-57 North Property and Carbon Canyon Property— characterized by previously disturbed areas and varying environmental sensitivities— are more appropriately addressed through a comprehensive, site-specific planning process. The comment pertains to planning policy and potential annexation considerations and does not address environmental issues or the adequacy of the PEIR.

The comment has been forwarded to the decision makers, and no further response is required.

O1-12 The comment describes the Olinda Drive Property, stating that it has been identified for residential development since 1996–1998. The comment also notes that Sycamore is in the process of granting the City approximately 1,000 square feet of surface land for construction and operation of an Activated Snorkel Station heli-hydrant for wildfire protection. The comment does not address environmental issues or the adequacy of the PEIR. The comment has been forwarded to the decision makers, and no further response is required.

O1-13 The comment requests that the City include a Specific Plan, Future Specific Plan, or equivalent overlay designation in the 2050 General Plan Update for the Olinda Drive Property, the CA-57 North Property, and other parcels within the Carbon Canyon Property, or, at a minimum, avoid precluding the use of a comprehensive planning framework for these lands. The comment does not address environmental issues or the adequacy of the PEIR. The comment has been forwarded to the decision makers, and no further response is required.

O1-14 The comment asserts that the 2050 GPU appears to carry forward land use assumptions derived from the City’s 2003 Brea General Plan without sufficient re-evaluation of existing site conditions, infrastructure, or long-term planning objectives. And further states that maintaining these legacy assumptions for the Hillside Residential designation for the CA-57 North Property and the Carbon Canyon Property constraints the City’s ability to plan effectively for future growth, and encourages the City to review these legacy designations and evaluate based on accurate and current information.

The comment is correct in describing that all sites currently designated as Hillside Residential would remain Hillside Residential, with the exception of sites within adopted Specific Plans under the Brea 2050. Specific Plans each have been assigned their appropriate Specific Plan designation. While preparing the Focused General Plan Update, the City reviewed its current General Plan, including the Hillside Residential land use designation and process for determining allowable density within that designation. The City determined that the designation and process remain valid and PEIR 2-48 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR will continue to be included in the Community Development Element of the Focused General Plan Update. Comments pertain to policy planning for the Brea 2050, and not to the scope of the Draft PEIR. Under CEQA, the primary purpose of an EIR is to identify and analyze the potential physical environmental effects of the Proposed Project. The comment does not address environmental issues or the adequacy of the PEIR. The comment has been forwarded to the decision makers, and no further response is required.

O1-15 The comment asserts that the Draft PEIR Figures 2-4, Current Zoning, and 2-7, Proposed General Plan Land Use Designations, do not fully or clearly depict the Carbon Canyon Property, including certain Sycamore-owned remnant parcels, and recommends that the figures be revised to more accurately distinguish these holdings from surrounding lands.

The figures referenced in the Draft PEIR are intended to provide a generalized, citywide depiction of existing zoning and proposed land use designations for the City and its Sphere of Influence. As program-level exhibits, they are not intended to depict parcel-level boundaries, ownership, or detailed site-specific conditions. CEQA Guidelines Section 15168, Program EIR, recognizes that a program EIR appropriately evaluates broad policy-level actions and need not include the level of detail required for site-specific analysis. Similarly, CEQA Guidelines Section 15146 provides that the level of detail in an EIR should correspond to the level of specificity of the underlying plan, with later environmental review addressing more detailed, site-specific information.

Consistent with these provisions, individualized parcel information is not separately delineated at the scale presented in Figures 2-4 and 2-7. More detailed, parcel-specific zoning information is available through the City’s official mapping resources on its website. In addition, the finalized General Plan land use designations will be made available through the City’s mapping tools following adoption of the Brea 2050.

O1-16 The Biological Resources Technical Report (BRTR) and the Draft PEIR do not use Connectivity Rank data to assess impacts to biological resources. Refer to Response to Comment O1-18 regarding the mapping sources used in the BRTR and the Draft PEIR, and to Response to Comment O1-19 regarding the programmatic nature of the Draft PEIR, which does not require parcel-specific or site-verified data for all properties. The BRTR and the Draft PEIR did not rely on Figure CR-3 of the 2050 GPU; therefore, no changes related to the Connectivity Rank of Irreplaceable and Essential Corridors are required.

PEIR 2-49 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR O1-17 The comment asserts that the Draft PEIR Figure 4.1-1, Scenic Resources, inaccurately depicts a scenic view corridor extending into the CA-57 North Property from the SR57 corridor, given this property’s existing industrial character. The comment requests that the scenic resource arrow extending into the CA-57 North Property to be removed.

Figure 4.1-1 is intended to provide a program-level, illustrative overview of general viewing directions and visual relationships within and surrounding the Planning Area, rather than to delineate mapped or designated scenic corridors or to characterize the visual quality of specific parcels. The arrows shown on the figure identify potential viewer vantage directions from publicly accessible corridorssuch as Brea Canyon Road and the SR-57 corridor, consistent with the programmatic nature of the PEIR. They do not constitute a determination that the underlying lands are themselves scenic resources, and do not imply that all areas within the arrow paths currently have high scenic value. Note that Brea Canyon Road is identified in the Brea 2050 GPU as a visually important corridor that functions as a gateway connecting the City to the San Gabriel Valley. In addition, the SR-57 corridor between Imperial Highway and SR-60 is recognized as eligible scenic highway under the California Scenic Highway Program, although not officially designated. The inclusion of generalized view arrows along these corridors appropriately discloses the potential for viewer exposure to surrounding landscapes. The comment’s characterization of the CA-57 North Property as developed with industrial uses does not invalidate the depiction of a viewing direction across that area, as the figure does not assign scenic value to that property.

The comment also question the arrow appearing to extent largely into Los Angeles County beyond the City’s jurisdictional planning area and asserts that if the City seeks to identify regional views beyond its jurisdiction, it should be made the intent explicit or delete.

The Draft PEIR appropriately considers visual conditions as experienced by viewers traveling through the Planning area, which may include viewsheds that extend beyond the City’s jurisdictional limits. CEQA does not constrain the analysis of visual impacts strictly to jurisdictional boundaries where the environmental effect.

The comment further questions the adequacy of the Draft PEIR’s aesthetics analysis and suggests that scenic resource determinations for the Sycamore properties should be deferred to a future, site-specific planning process. The Draft PEIR evaluates impacts at a programmatic level of detail appropriate to a GPU and acknowledges that future development under the GPU will be subject to project-level review and, where applicable, more detailed visual impact analysis and design considerations to address site-specific conditions. No substantive revisions to the analysis are required.

PEIR 2-50 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR O1-18 The comment questions the accuracy of vegetation mapping used in the 2050 GPU and the Draft PEIR, asserting that the vegetation mapping relies on outdated sources, including a 1992 Jones & Stokes study and data prepared for the Natural Community Conservation Planning program, and may overstate the extent of undisturbed habitat conditions on the CA-57 North Property. The comment also requests clarification regarding data sources and methodology and questions the adequacy of the biological resources analysis. Figure 4.3-2, Vegetation Communities and Land Cover Types, of the Draft PEIR used this source. Vegetation mapping presented in Figure 4.3-2 is based on the best available regional and publicly accessible data sources. In the absence of comprehensive, site-specific vegetation mapping prepared using standardized classification systems (e.g., Holland or Manual of California Vegetation) across the entire PEIR Project area, the analysis relied on datasets available through the California Department of Fish and Wildlife’s Biogeographic Information and Observation System (BIOS), including data originally derived from the Jones & Stokes (1992) survey for the Nature Reserve of Orange County, with last update in BIOS on March 28, 20416.

This dataset from the basis for historic files with Orange County Parks GIS. These data represent the most comprehensive, consistently available baseline dataset for the broader area and have been incorporated into County and regional GIS databases.

CEQA Guidelines Section 15125 requires that an EIR describe the physical environmental conditions in the vicinity of the project as they exist at the time the notice of preparation is published, using the best available information. For a Program EIR, CEQA Guidelines Section 15168 recognizes that the analysis is appropriately conducted at a broad, programmatic level and may rely on regional data sources rather than site-specific surveys. Consistent with CEQA Guidelines Sections 15144 and 15145, an EIR is not required to resolve all uncertainty, but must reflect a good-faith effort at full disclosure based on available information. Also, CEQA Guidelines Section 15146 provides that the level of detail in an EIR should correspond to the level of specificity of the underlying plan, with later environmental review addressing more detailed, site-specific information.

The vegetation mapping presented in Figure 4.3-2 is intended to provide a generalized, program-level depiction of vegetation communities and land cover types across the City and its Sphere of Influence. It is not intended to represent site-specific conditions or to definitively characterize the presence or absence of sensitive biological resources on individual properties. As such, localized disturbances associated with oil and gas operations, grading, or other activities may not be fully reflected at the mapping scale used.

PEIR 2-51 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR Also note that the Draft PEIR’s biological resources analysis does not rely solely on Figure 4.3-2 to determine site-specific biological conditions or impacts. Instead, Mitigation Measure MM BIO-1 (Pre-Project/Activity Biological Resources Survey/Habitat Assessment) requires that, prior to approval of future discretionary projects, applicants conduct site-specific biological surveys by a qualified biologist for all areas not classified as “Urban/Developed.” This mitigation measure requires updated vegetation mapping (if not conducted within the previous three years) using accepted classification systems (e.g., Manual of California Vegetation), evaluation of sensitive resources, and identification of appropriate avoidance, minimization, and mitigation measures. The results must be documented in a biological technical report and are subject to City review and approval as part of subsequent CEQA compliance.

Therefore, through implementation of MM BIO-1, any discrepancies between program-level mapping and actual site conditions—including areas that are more disturbed than depicted or that support sensitive biological resources—will be identified and addressed at the appropriate project-specific stage. Additional mitigation measures (MM BIO-2 through MM BIO-7) would further ensure that potential impacts to biological resources are avoided or reduced to less than significant levels.

While the comment expresses concern regarding the age of certain underlying datasets, the Draft PEIR appropriately relies on the best available regional data for programlevel analysis and incorporates enforceable mitigation to ensure that site-specific conditions are accurately evaluated prior to development. The biological resources analysis therefore provides an adequate basis for decision-making under CEQA. No revisions to the Draft PEIR are required.

O1-19 The comment asserts that certain figures and overlays in the Draft PEIR are unsupported, outdated, or inaccurate as applied to Sycamore’s properties, and recommends that the City revise such figures where they extend beyond adopted regulatory maps or are used to draw parcel-level conclusions. The comment further states that generalized mapping should not substitute for site-specific analysis.

The City acknowledges that certain figures in the Draft PEIR incorporate multiple data sources, including adopted regulatory maps (e.g., fire hazard severity zones, critical habitat designations) as well as other publicly available datasets used to inform program-level environmental analysis. As explained in Response to Comment O1-15, these figures are intended to provide a generalized, planning-level depiction of environmental constraints and conditions across the City and its Sphere of Influence.

They are not intended to establish parcel-specific conditions, ownership, or definitive resource boundaries.

PEIR 2-52 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR The Draft PEIR does not rely on these figures to make parcel-level determinations regarding the presence or absence of environmental resources on specific properties, including Sycamore’s holdings. Rather, the analysis appropriately relies on adopted regulatory maps prepared by agencies with jurisdiction and statutory authority, as well as other best available data, to identify potential environmental issues at a programmatic level. Where City-prepared figures are included, they are used for illustrative and analytical purposes consistent with the scale of the Program EIR and are supported by the underlying data sources cited in the document.

CEQA Guidelines Sections 15146 and 15168 recognize that a Program EIR evaluates broad policy-level decisions using information commensurate with that level of planning, and does not require parcel-specific or site-verified data for all properties. In addition, CEQA Guidelines Section 15144 provides that an EIR is not required to be exhaustive, but rather must reflect a good-faith effort at full disclosure, and Section 15151 establishes that adequacy is determined under a “rule of reason.” Consistent with these standards, the level of detail and use of mapping in the Draft PEIR are appropriate for the programmatic nature of the analysis.

Also note that the Draft PEIR expressly contemplates that site-specific environmental conditions will be evaluated at the time of future discretionary projects. As described in Chapter 4 and the applicable mitigation measures (e.g., MM BIO-1 and related measures), future development proposals will be subject to project-level CEQA review, including site-specific technical studies, field surveys, and updated mapping where warranted. This subsequent review will verify actual on-site conditions and ensure that any potential environmental impacts are appropriately identified and mitigated based on current, parcel-level information.

The use of generalized or conservative mapping at the program level does not predetermine site-specific environmental conditions, constrain future land use decisions, or substitute for required project-level analysis. Rather, it ensures that potential environmental considerations are disclosed at a broad level while preserving the ability to refine and verify conditions during subsequent review. Therefore, the Draft PEIR does not substitute generalized mapping for site-specific analysis, but instead appropriately tiers program-level analysis with future project-level review, consistent with CEQA. No revisions to the Draft PEIR are required.

O1-20 The comment asserts that Community Resources Element Figure CR-1, Parks, Recreation Facilities and Open Space, is internally inconsistent because it identifies portions of the Carbon Canyon Property and the Olinda Drive Property as “Other Recreation,” while those properties are designated as Hillside Residential in the 2050 PEIR 2-53 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR GPU Land Use Map. The comment requests revision of Figure CR-1 by removing Sycamore’s lands from the Other Recreation classification. The comment further contends that this internal inconsistency and that the environmental effects of such classification were not analyzed in the Draft PEIR.

Figure CR-1 is meant to represent the City’s existing parks, recreation facilities, and open spaces, and Other Areas for Recreation generally describes special use facilities to serve the needs of its community members, including the Brea Community Center, Brea Senior Center, and Chino Hills. There has been a mapping error on Figure CR-1 for the GPU. However, the City’s adopted and proposed land use designations are established through the General Plan Land Use Map, which identifies the subject properties as Hillside Residential, and the Draft PEIR used the General Plan’s Land Use Map for the analysis. Figure CR-1 does not modify, supersede, or conflict with the underlying land use designation analyzed in the Draft PEIR. However, for consistency, Figure CR-1 for the 2050 GPU has been updated to accurately reflect the current and proposed land use designation for the Carbon Canyon Property.

The Draft PEIR evaluates environmental impacts based on the proposed land use designations and overall development assumptions of the 2050 GPU, not on a figure illustrating existing recreational facilities and land uses on GPU’s Community Resources Element. Therefore, the identification of areas as “Other Recreation” on Figure CR-1 does not represent a reclassification of land use and does not introduce new or different environmental impacts beyond those analyzed in the Draft PEIR.

CEQA requires a good-faith effort at full disclosure and analysis under a rule of reason (CEQA Guidelines Sections 15144 and 15151). The Draft PEIR satisfies these standards by analyzing impacts at a programmatic level based on the proposed land use framework. The comment does not identify any substantial evidence demonstrating that the environmental analysis is inadequate. Therefore, no revisions to the Draft PEIR are required. The comment is noted, and no further response is necessary.

O1-21 The comment states that the Focused GPU and the PEIR describes the SOI, including Sycamore’s properties as “undeveloped” hillside open space, which is not supported by parcel-specific documentation. The comment further states that a misleading or incomplete baseline and project description undermines informed public review and comment and warrants clarification or correction in the Final PEIR.

The GPU is a policy document and it acknowledges the historic and current oil production operations in various chapters of the General Plan. Comments pertaining to the content and refinement of General Plan’s characterization of certain properties within the Planning area do not affect the adequacy of the PEIR. As the characterization PEIR 2-54 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR of Sycamore’s properties in the Draft PEIR, the description of the City’s SOI in the Draft PEIR is intended to provide a generalized depiction and proposed land use designations for the City, not a parcel-level review. CEQA Guidelines Section 15168 recognizes that a program EIR appropriately evaluates broad policy-level actions and need not include the level of detail required for site-specific analysis. Similarly, CEQA Guidelines Section 15146 provides that the level of detail in an EIR should correspond to the level of specificity of the underlying plan, with later environmental review addressing more detailed, site-specific information.

However, in response to the comment, the following revisions to the PEIR have been made. These changes are informational purposes only and do not represent new substantial information that require recirculation of the Draft PEIR. Changes to the Draft PEIR text are shown in underlined text for additions and strikeout for deletions.

Much of the SOI north of the City is sparsely developed and includes hillside residential areas, including current and past oil and gas fields, public facilities (such as the Olinda Alpha Landfill), parks and recreation areas, open space, and vacant parcels. These areas border the County of Los Angeles.” (Draft PEIR, page 2-12)
The incorporated City of Brea is a largely developed suburban/urban community. The existing land use pattern is mixed and includes established residential neighborhoods, a concentrated downtown and mall/commercial core, industrial and business parks, civic and institutional uses, parks and open space, and transportation corridors. Most of the developed area is located west of Valencia Avenue, while the eastern portion consists primarily of residential neighborhoods, with large undeveloped foothills and canyons to the east and north. The SOI area west of SR-57 also includes oil fields with an extensive network of production infrastructure, including tank facilities, processing facilities, service roads, and power lines, and SOI area north of Carbon Canyon Road includes portions that previously supported oil and gas exploration and production activities. There is currently no development within the sphere of influence area, and only residential uses are permitted on approximately 34 percent of the total sphere of influence acreage under the current 2003 General Plan. The remaining 4,050 acres (66 percent) are designated for open space, parks/recreation, and public facilities, with no residential or non-residential development potential. Therefore, buildout of the Project area would largely come from redevelopment of already existing developed areas that contribute to urban storm water runoff. (Draft PEIR page 4.9-28) PEIR 2-55 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR As described previously, the Project area is largely developed and buildout of the Project area would largely come from redevelopment of already existing developed areas (i.e., infill development). However, buildout would result in new development in previously undeveloped areas, primarily in the eastern portion of the City and its sphere of influence, and areas of current and historic oil and gas production activities, which could result in an increase in storm water runoff quantities. Redevelopment would also alter existing drainage of any given infill site that would affect the existing storm water drainage system.” (Draft PEIR page 4.9-32) The comment also states that the Draft PEIR does not include a breakdown of the calculations or describe the specific parcel-by-parcel methodology show in in the Draft PEIR Table 2-1, Existing and 2003 Brea General Plan Land Use Summary, and asserts that a transparent explanation is needed. As explained above, pursuant to CEQA Guidelines Sections 15168 and 15146, the Draft PEIR is a program EIR and specific parcel-by-parcel methodology is not required. Also, as shown in Table 2-1, no existing units and populations were assumed for the 2,096 acres of the Hillside Residential designation in the Sphere of Influence. A total of 1,048 units and 2,987 population have been provided for informational purposes for the existing 2003 Brea General Plan, and are not the existing baseline condition for the area. Provided information is sufficient for a program-level review, and no revisions to the PEIR is required.

O1-22 The commenter asserts that inconsistencies between Figure CR-3 of the proposed Brea 2050 and the Draft PEIR (based on the Biological Resources Technical Report [BRTR]) undermine the reliability of the biological baseline and impact analysis.

However, this assertion is not supported because the figures referenced by the commenter were prepared for different purposes and rely on different source datasets, and therefore are not required to be identical or directly comparable. Figure CR-3 in the Brea 2050 is a policy-oriented planning exhibit intended to illustrate regional habitat connectivity at a conceptual level to inform long-term conservation goals and land use policy and to comply with Assembly Bill 1889 and Senate Bill 1425. As disclosed in the Brea 2050, Figure CR-3 incorporates multiple data sources, including:
(1) “Connectivity Rank” mapping derived from the California Department of Fish and Wildlife’s (CDFW) Areas of Conservation Emphasis (ACE) (2024) dataset; and (2) “Major Wildlife Movement Corridors” derived from the Parklands and Wildlife Corridors Map (Santa Monica Mountains Conservancy et al., 1999), which is also reflected in the City’s 2003 General Plan. These datasets are regional, composite, and planning-focused in nature.

PEIR 2-56 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR In contrast, Section 4.3, Biological Resources of the Draft PEIR based on the BRTR rely on currently accepted, science-based datasets used for environmental impact analysis, including the CDFW California Essential Habitat Connectivity Project (CEHCP). The CEHCP framework is widely recognized as an appropriate and standardized tool for evaluating habitat connectivity at the programmatic level under CEQA. As such, the BRTR appropriately uses CEHCP data to identify natural landscape blocks, linkages, and barriers for purposes of establishing the environmental baseline and evaluating potential impacts. The selection of these datasets reflects standard professional practice for CEQA analysis and ensures consistency with current regulatory guidance and methodologies.

In addition, the commenter’s assertion that the absence of the GPU-mapped corridor in the BRTR “undermines the biological baseline” is incorrect. CEQA requires that an EIR describe the physical environmental conditions in the vicinity of the project to establish a baseline (CEQA Guidelines, Section 15125), but it does not require that all policy exhibits or conceptual planning maps be replicated within technical analyses.

The Draft PEIR provides a sufficient and meaningful baseline by relying on up-to-date, scientifically supported datasets (e.g., CEHCP) and by qualitatively describing wildlife movement and habitat linkages in the Planning Area. The fact that Figure CR-3 includes additional or differently categorized connectivity information for policy purposes does not invalidate the baseline used for impact analysis.

The Draft PEIR and BRTR explicitly acknowledge the programmatic nature of the analysis, consistent with CEQA Guidelines, Section 15168. The level of detail provided is appropriate for a Program EIR evaluating broad land use designations rather than site-specific development. As stated in the Draft PEIR, project-level impacts to wildlife movement, corridors, and habitat connectivity will be evaluated in subsequent environmental review when specific development proposals are advanced and sitespecific information becomes available. At that stage, more refined data sources, field surveys, and localized analyses will be used, as appropriate.

There is no requirement under CEQA that all maps included in a General Plan document and its associated EIR use identical datasets or depict identical features, particularly where those maps serve distinct functions (policy development vs. environmental analysis). The Draft PEIR does not rely on Figure CR-3 for its impact conclusions, nor does any perceived difference in mapping alter the significance determinations or mitigation framework presented in the document.

For the reasons stated above, the Draft PEIR provides an adequate and legally sufficient baseline and impact analysis for biological resources. The commenter has not identified PEIR 2-57 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR any new significant information or substantial change in the project that would warrant recirculation of the Draft PEIR pursuant to CEQA Guidelines, Section 15088.5.

O1-23 The comment states that several of the corridors depicted in the Focused GPU Figure CR-3 extend beyond the City’s jurisdictional planning authority and should be clarified to avoid implying the existence of a formally designated wildlife corridor where the Draft PEIR and the BRTR do not identify. The wildlife corridors depicted in Figure CR-3 is from the Parklands and Wildlife Corridors Map - Santa Monica Conservancy, Wildlife Corridor Conservation Authority, Puente Hills Landfill Native Habitat Preservation Authority, and Dreamline Cartography; March 1999, which is also included in the City's 2003 General Plan. Figure CR-3 is included as part of the policy making and should be reviewed and considered on future land use decisions as it sets the policy vision. The wildlife corridors included in Figure CR-3 have been a component of the City’s planning framework since the 2003 Brea General Plan. And its inclusion in the Focused GPU is intended to reflect regional ecological connectivity and provide a policy-level framework for long-term conservation goals. It is not intended to serve as a site-specific delineation of jurisdictional biological resources. As stated in the comment, the BRTR and Draft PEIR did not utilize these specific regional depictions to delineate corridors. However, the Draft PEIR analysis remains adequate as it focuses on the potential for the GPU's policies to affect biological movement generally in a programmatic level pursuant to CEQA Guidelines Sections 15168 and 15146. Additionally, to ensure that future land use decisions are based on existing conditions rather than conceptual mapping, Mitigation Measure MM BIO-1 has been modified to explicitly require a site-specific evaluation of local and regional wildlife movement corridors for applicable future projects. See Section 3, Revisions to the Draft PEIR for the revised MM BIO-1.

O1-24 2050 GPU Figure CR-3’s Connectivity Rank is based on the California Department of Fish and Wildlife’s Areas of Conservation Emphasis (ACE) data. The ACE map is meant to assist in making informed decisions and does not replace the need for site specific or project specific evaluations. The absence of the ACE layer on Figure 9 of the BRTR does not diminish or affect the assessment of the Puente-Chino Hills area.

As quoted in the comment, the BRTR states that the Puente-Chino Hills area functions as a vital corridor for wildlife. This statement is not negated by the absence of the ACE map layer in Figure 9 of the BRTR (Figure 4.3-5 of the Draft PEIR). The ACE map provides a policy-level analysis based on map-based data but is not the sole basis for making determinations regarding wildlife corridors or their value. Clear identification or mapping of the same corridor as the ACE map in the BRTR is not necessary and this fact does not diminish the adequacy of the BRTR analysis. Additionally, Mitigation Measure MM BIO-1 has been strengthened to expand MM BIO-1 to more clearly PEIR 2-58 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR require evaluation of both local and regional wildlife movement corridors.

Furthermore, the Brea 2050 Community Resources Element includes a goal to preserve and maintain open space for nature, resource management, recreation, and scenic enjoyment (Goal CR-3). The City has also added Action CR-3e, which is intended to avoid development impacts on identified or potential wildlife corridors to the maximum extent feasible based on site-specific biological surveys. Where avoidance is not feasible, Action CR-3e requires implementation of project design features such as minimum corridor widths, wildlife-permeable fencing, lighting designed to minimize spillover, and/or wildlife crossing structures. The modified Brea 2050 General Plan:

Goals, Policies, and Actions are included as Attachment B to the Final EIR.

As revised, MM BIO-1, MM BIO-6, and the Community Resources Element Action CR-3e now explicitly requires that site-specific biological resources surveys include an evaluation of potential local and regional wildlife movement corridors, as well as an assessment of corridor function and value using best available scientific information, including agency habitat connectivity maps and site-specific field observations. This ensures that wildlife movement considerations are identified early in project planning and integrated into environmental review and project design. See Section 3, Revisions to the Draft PEIR, for the modified mitigation measures.

Changes to the Draft PEIR text are shown in underlined text for additions and strikeout for deletions.

MM BIO-1 Pre-project/Activity Biological Resources Survey/Habitat Assessment. For project sites within vegetation communities and land covers other than “Urban/Developed,” as shown on Figure 4.3-2, Vegetation Communities and Land Cover Types, of this Program Environmental Impact Report for the Brea 2050: Focused General Plan Update and Brea Core Specific Plan, the following requirements shall apply.

PEIR 2-59 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR • Aerial photographs (historic and current) showing grading, building footprints, paving, and landscaped areas over time to support ornamental status, existing landscape plans.
• Photographic documentation consisting of georeferenced or dated photographs.
• Landscaping plans or as-built drawings demonstrating that vegetation was intentionally planted as part of site development. • Field survey results prepared by a qualified biologist confirming that existing plant species are ornamental and non-native.

Within the future site-specific project areas exhibiting native vegetation, a site-specific biological resources survey shall be conducted during the project design phase.

The biological resources survey and habitat assessment shall be conducted by a qualified biologist and shall include but not be limited to the following:
• An analysis of available literature and biological databases, such as the California Natural Diversity Database, to determine sensitive biological resources that have been reported historically from the Proposed Project vicinity.
• A review of current land use and land ownership within the project vicinity.
• An assessment and mapping of vegetation communities present within the project vicinity. If vegetation community mapping has not been conducted on the site in the previous three years, updated vegetation mapping shall be conducted by a qualified biologist as part of the project planning and environmental review process.

Vegetation communities shall be mapped according to the Manual of California Vegetation at the alliance level, and a crosswalk table with Holland vegetation communities shall be provided.
• A general assessment of the potential for aquatic resources, including wetlands and riparian habitats, to occur on site. • An evaluation of potential local and regional wildlife movement corridors and an assessment of functions and value retention using online wildlife agency habitat connectivity maps and on site evaluations.
• A focused habitat assessment to determine if the project site supports vegetation communities that may provide habitat for plant or wildlife species, to be conducted by a qualified biologist, to PEIR 2-60 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR determine the potential for sensitive plant or wildlife species to occur in or adjacent to the project site.
• If the project site supports sensitive vegetation communities, the project proponent shall implement the following weed control methods to minimize the establishment and spread of non-native and invasive weed species in the project site during construction activities:
− Seeds and plant materials used for revegetation shall be certified weed-free.
− Straw materials, such as those used for erosion control, shall be certified weed-free.
• The results of the biological survey shall be presented in a biological technical report. The survey report shall map and describe the location and extent of observed sensitive resources, including sensitive vegetation communities, regional wildlife movement corridors, plant, and wildlife species within the areas of potential direct and indirect effects for each project area, direct and indirect impacts associated with construction and operation of a project, and the need for further survey, monitoring, or mitigation, including measures pursuant to Mitigation Measures MM BIO-2, MM BIO-3, MM BIO-4, MM BIO-5, MM BIO6, and MM BIO-7 of this Program Environmental Impact Report. The biological technical report shall be submitted to and approved by the City of Brea prior to issuance of grading permits. The report shall incorporate applicable mitigation measures (MM BIO-2 through MM BIO-9) to reduce any potentially significant impacts to biological resources.

MM BIO-6 Focused Sensitive Wildlife Species Surveys. If recommended by the Biological Resources Survey/Habitat Assessment prepared pursuant to Mitigation Measure MM BIO-1, prior to any site disturbance, including grading, vegetation clearing, or fuel modification, focused surveys for future site-specific development shall be conducted, as applicable, in suitable habitat, to determine presence/absence of sensitive wildlife species within the proposed survey area. If sensitive wildlife species or their habitat are present or potentially present based on biological surveys, the following measures shall be implemented.
a. Crotch’s Bumble Bee. Habitat assessment surveys for California Endangered Species Act (CESA) candidate bumble bee species, with a PEIR 2-61 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR focus on Crotch’s bumble bee, followed the California Department of Fish and Wildlife (CDFW) methodology from the Survey
Considerations for CESA Candidate Bumble Bee Species dated June 6, 2023 (CDFW Survey Considerations) (CDFW 2023). If no Crotch’s bumble bees are found during the focused surveys, but the habitat assessment identified suitable nesting, foraging, or overwintering habitat on the project site, recommendations outlined in the CDFW Survey Considerations will be followed, including recommendations that a biological monitor be on site during vegetation or ground-disturbing activities that take place during any of the Queen and Gyne Flight Period and Colony Active Period. If Crotch’s bumble bees are observed, project proponents may propose site-specific measures to avoid take, or consult with CDFW to obtain an Incidental Take Permit (ITP) if take of CESAprotected bumble bees may occur during project activities. b. Western Spadefoot and Monarch Butterfly. If western spadefoot or monarch butterfly become listed prior to implementation of future sitespecific development projects, focused surveys and consultation with the U.S. Fish and Wildlife Service (USFWS) would be necessary. c. Western Burrowing Owl. If suitable habitat for western burrowing owl is present (annual grassland and agricultural land), a qualified biologist shall conduct focused surveys of the site and a 500-foot buffer, as access allows. If no burrowing owls are identified, no further measures are necessary. If burrowing owls are detected, active burrows shall be avoided using buffers outlined in the Staff Report on Burrowing Owl Mitigation, dated March 7, 2012, issued by CDFW. If avoidance is not possible, the qualified biologist shall consult with CDFW. No direct disturbance to burrowing owls or their occupied habitat shall occur without appropriate authorization from CDFW.
d. Least Bell’s Vireo. If suitable habitat for least Bell’s vireo is present and clearing, grubbing, grading, or other construction activities may occur between March 15 and September 15, the breeding season of the least Bell’s vireo, a qualified biologist shall conduct focused surveys for the presence of the least Bell’s vireo of the site and areas of potentially suitable habitat within 300 feet or that would be subject to construction noise levels exceeding 60 A-weighted decibels or to the ambient noise level if it already exceeds 60 A-weighted decibel hourly average. If present, measures to minimize noise impacts (such as temporary noise walls/berms) may be required. Noise levels from construction activities PEIR 2-62 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR during the avian breeding season should not exceed 60 decibels (dBA Leq; or the ambient noise level if they already exceed 60 dBA Leq) at the edge of the occupied habitat. If complete avoidance is not feasible, the qualified biologist shall consult with USFWS. No direct harm to the species shall be allowed without appropriate authorization from USFWS. e. Southwestern Willow Flycatcher. If suitable habitat for southwestern willow flycatcher is present and clearing, grubbing, grading, or other construction activities may occur between April 15 through September 15, the breeding season of the southwestern willow flycatcher, a qualified biologist shall conduct focused surveys for the presence of the southwestern willow flycatcher of the site and areas of potentially suitable habitat within 500 feet. If the species is determined to be present, consultation per Endangered Species Act with USFWS would be necessary and no activities would occur until authorized by USFWS. No direct harm to the species shall be allowed without appropriate authorization from USFWS.
f. Sensitive Bat Species. If suitable roosting habitat (e.g., riparian habitat, snags, wooden buildings, bridges, etc.) for sensitive bat species is present, a qualified biologist shall conduct subsequent focused surveys no less than 14 days prior to removal or disturbance of vegetation or buildings. The survey shall consist of visual and/or acoustic methods as deemed appropriate by the qualified biologist. If no bats are detected, no further measures are necessary. If bat species are detected during surveys, a site-specific plan shall be developed by the qualified biologist.

The plan may include, as determined by the qualified biologist, delaying removal of roost habitat until after the maternity roosting period and exclusion of bats from roosting habitat prior to removal of habitat. The qualified biologist shall consult with CDFW prior to implementing any exclusion activities.
g. Southwestern Pond Turtle. If suitable habitat for southwestern pond turtle is present pursuant to Mitigation Measure MM BIO-1, site-specific measures shall be implemented to avoid impacts, as developed in consultation with a qualified biologist. Measures shall focus on avoiding habitat destruction, protecting individuals during construction, and managing habitat to increase survival though preconstruction surveys, exclusion fencing, biological monitoring, and habitat restoration.

Depending on the measures selected, plan approval and conference with PEIR 2-63 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR the U.S. Fish and Wildlife Service may be required if the action is likely to jeopardize the species’ existence during construction activities. h. Mountain Lion. If suitable habitat for mountain lion is present pursuant to Mitigation Measure MM BIO-1, site-specific measures shall be implemented to minimize habitat loss and fragmentation to improve habitat connectivity and avoid take. These measures shall be developed in consultation with a qualified biologist and may include measures described in the City of Brea General Plan Community Resources Element Policy CR-3e. If presence is established, Resource Agency consultation shall be required to obtain an incidental take permit. gi. Other Sensitive Species. Prior to any demolition work, construction, or grading activities within the future site-specific project areas, preconstruction surveys for other sensitive wildlife species, such as reptiles, may be required to determine presence/absence of sensitive wildlife species within the proposed survey area.

O1-25 The commenter raises concerns regarding (1) the reliance on existing information and absence of field surveys in the Biological Resources Technical Report (BRTR), (2) the adequacy of the baseline characterization under CEQA Guidelines Section 15125, and (3) an asserted inconsistency between the 2050 GPU mapping and the BRTR/PEIR analysis with respect to wildlife corridors and habitat connectivity.

The comment is noted; however, it does not identify a deficiency in the PEIR under CEQA. The PEIR is a program-level environmental review document prepared pursuant to CEQA Guidelines Sections 15168. As such, it appropriately evaluates environmental impacts at a broad, programmatic level based on reasonably available information, and does not require parcel-level or project-specific field surveys. CEQA recognizes that a program EIR may rely on existing data, regional studies, and literature review to characterize environmental conditions and identify potential constraints, with the understanding that site-specific environmental review will occur at the time individual development projects are proposed.

Consistent with this framework, the BRTR relied on accepted, state-recognized data sources, including but not limited to the California Department of Fish and Wildlife (CDFW) databases (e.g., California Natural Diversity Database), the California Essential Habitat Connectivity Project, and other regional conservation planning documents. These sources represent the best available scientific information at a regional scale and are routinely used in CEQA analyses to establish baseline conditions for programmatic documents. The purpose of the BRTR at this stage is to identify the PEIR 2-64 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR potential for biological resources and constraints across the Project Area, not to confirm the precise location or condition of resources on individual sites.

Future development projects, tiering from the PEIR would be required to implement mitigation measures as applicable, where assessments have been examined at a sufficient level of detail in the property environmental impact report to enable those effects to be mitigated or avoided by site specific revision, the imposition of conditions, or by other means in connection with the approval of the later project (CEQA Guidelines Section 15152(f)(B)).

The PEIR provides a sufficient and appropriate baseline for a program-level analysis.

The baseline need not be established through field surveys where the document evaluates a large planning area involving long-term land use policies rather than a specific development footprint. Courts have recognized that the level of detail required in an EIR is commensurate with the level of specificity of the underlying project (Rio Vista Farm Bureau Center v. County of Solano [1992]). The court held that an EIR on a General Plan need not be as detailed as an EIR on the specific construction projects that might follow and that the degree of specificity required in an EIR will correspond to the degree of specific involved in the underlying activity (CEQA Guidelines Section 15146). The Proposed Project is a policy document, and site-specific field survey can be deferred to the project-level CEQA document when specific development is actually proposed.

The PEIR’s use of existing mapping, database records, and regional analyses provides an adequate basis to evaluate potential impacts, identify program-level mitigation measures, and inform future decision-making.

O1-26 To the extent there are differences in mapping resolution or methodology, these are inherent in the use of datasets developed for different scales and purposes, and do not affect the validity of the PEIR’s impact analysis. The PEIR appropriately recognizes the programmatic nature and limitations of the analysis. As stated in the BRTR and PEIR, the identification of biological resources reflects potential conditions based on available data, and site-specific verification. Refer to the Draft PEIR Section 4.3.1.2, Existing Conditions, Methodology. Therefore, no additional acknowledgment of the limitations is required. Future development would be subject to project-level environmental review and will be required to rely on updated biological surveys and more precise analysis, including protocol surveys, jurisdictional delineations, and focused studies, consistent with CEQA and applicable regulatory requirements as specific in Mitigation Measures MM BIO-1 through MM BIO-9. Subsequent environmental review will tier from the PEIR and incorporate project-level analysis PEIR 2-65 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR based on current, site-specific information pursuant to CEQA Guidelines Section 15152 and 15183.

O1-27 As discussed in Response to Comment O1-25, the PEIR provides an adequate and legally sufficient evaluation of biological resources and wildlife connectivity at the program level appropriate for an EIR. Although the reference to an “inconsistency” between the GPU mapping and the BRTR, is acknowledged, it should be noted that they serve two difference purposes and do not need to be consistent. The mapping used in the GPU is intended to serve as a high-level planning and policy tool to illustrate generalized areas of habitat linkage and regional connectivity. In contrast, the BRTR and PEIR analyses rely on state-recognized and standardized datasets (e.g., CDFW and the California Essential Habitat Connectivity Project) to ensure consistency, methodological rigor, and applicability across the entire Project area. The use of these different sources does not represent a deficiency or internal inconsistency; rather, it reflects the use of multiple complementary datasets serving different purposes. The GPU mapping provides a broad, conceptual depiction of regional connectivity to inform policy direction; and the BRTR/PEIR analysis applies widely accepted scientific datasets to evaluate potential environmental impacts under CEQA. Therefore, no revision to the impact analysis is required.

O1-28 The comment asks that the City implement revisions described in the comment letter to the 2050 GPU and facilitate the use of a future specific plan framework for Sycamore’s properties as conclusion. As discussed in Response Comments O1-1 through O1-27, these comments do not pertain to adequacy of the PEIR and no revisions to the Draft PEIR are required. The comment is noted, and no further response is necessary.

O1-29 The comment asks that the City correct the 2050 GPU and Draft PEIR errors and deficiencies identified in the comment letter as a conclusion. As discussed in Response Comments O1-1 through O1-27, while minor edits have been made to the Draft PEIR.

However, no new significant information or substantial change in the project that would warrant recirculation of the Draft PEIR pursuant to CEQA Guidelines, Section 15088.5, have been identified.

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Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR Letter O2. Edward T. Schexnayder, Shute, Mihaly & Weinberger LLP on behalf of Hills for Everyone, March 30, 2026
O2-1 The comment provides an introduction and indicates that Hills for Everyone is a nonprofit organization that has been working to protect preserve, and restore the environmental resources and natural environs of the Puente-Chino Hills and surrounding areas since 1978. The comment is acknowledged, and no response is required.

O2-2 The comment states that a letter dated September 24, 2025, on the Notice of Preparation for the Draft PEIR was submitted on behalf of Hills For Everyone regarding policy direction that should be included in the GPU as well as suggestions on issues that should be evaluated in the PEIR. However, this letter was not summarized in Table 1- 1, NOP Comments Summary, or reflected in the “Areas of Controversy” section of the Draft PEIR.

The City acknowledges that the September 24, 2025, NOP comment letter from Hills For Everyone was received but was inadvertently excluded from Appendix B and the associated summary table in the Draft PEIR. The Final PEIR has been revised to include the full text of this comment letter as Attachment F, Omitted Notice of Preparation Comment Letters and to incorporate a summary of the comments in Table 1-1, NOP Comments Summary for completeness of the administrative record (see Section 3, Revisions to the Draft PEIR). The environmental issues raised by the commenter have been addressed at a programmatic level in the PEIR, and the comment does not identify any specific deficiency in the adequacy of the environmental analysis.

O2-3 The comment describes the Proposed Project by indicating the land use changes in numbers. The comment further states that under Assembly Bill 130, many projects that conform with the General Plan land use designations and associated zoning will be exempt from further CEQA review, therefore, it is imperative that the PEIR thoroughly and properly analyze and, mitigate for, the potential environmental impacts of the development allowed under the 2050 General Plan Update (GPU) and Brea Core Specific Plan (BCSP), and that the 2050 GPU include policies and implementation actions that can serve to reduce the environmental impacts of future development through measures that be taken either proactively or in coordination with future projects. Comments are acknowledged. However, they do not identify any specific deficiency in the adequacy of the environmental analysis. Comments have been forwarded to the decisions makers for consideration.

O2-4 The comment indicates general support for the GPU and urges the City to adopt policies consistent with its 2024 Community Vision Plan, particularly Guiding Principles PEIR 2-86 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR related to climate resilience and connection to nature. The comment highlights the City’s historical commitment to open space, habitat conservation, and regional efforts (e.g., wildlife corridors and preservation initiatives), and recommends that the GPU include policies and programs that reinforce these values and prior investments. The commenter also highlights the City’s past efforts to preserve open space and support regional conservation initiatives.

The comment provides input regarding policy direction and recommends that the GPU incorporate goals and policies consistent with the City’s Community Vision Plan, including principles related to resilience, open space, and habitat conservation. These comments address the formulation of General Plan policies and community visioning considerations rather than the adequacy of the environmental analysis contained in the PEIR. As such, the comments do not raise issues concerning the sufficiency of the PEIR under CEQA. The City acknowledges the comment and will forward them to decisionmakers for consideration. No changes to the Draft PEIR are required in response to this comment.

O2-5 The comment states that Hills for Everyone provided commented on the Notice of Preparation for the City include goals and policies pertaining to four key categories to discourage development in hillside within the Sphere of Influence (SOI), emphasize fire and wildlife protection, prioritize wildlife corridors and habitat connectivity, and supporting urban greening and climate resiliency. The comment provides an introduction to specific additional actions or revisions for several General Plan Elements and no specific comments are provided. No response is required.

O2-6 The comment provides policy direction in the Community Development Element and Urban Design Framework that was included as Appendix A to the GPU. The comment further asserts that the GPU should consider making preservation an economically rational choice for property owner, and proposed revising the GPU to add additional actions. The actions included establishing objective design criteria for development in the Hillside Residential General Plan land use designation and the Hillside Residential Zoning District; Define thresholds for permitting development on parcels in Brea’s Sphere of Influence (SOI) that are designated Hillside Residential; Establish a mapped Conservation Priority Overlay for hillside SOI parcels; and establishing a Transfer of Development Rights (TDR) program.

These comments address the formulation of General Plan policies and community visioning considerations rather than the adequacy of the environmental analysis contained in the PEIR. As such, the comments do not raise issues concerning the sufficiency of the PEIR under CEQA. Pursuant to CEQA Guidelines Section 15088, PEIR 2-87 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR the City provides responses to comments on environmental issues raised regarding the adequacy of the Draft PEIR. Comments that pertain to policy preferences, land use planning considerations, or the content of the GPU itself are noted for consideration by City decision-makers but do not require revisions to the environmental analysis in the PEIR. The City acknowledges the commenter’s recommendations and will forward them to decision-makers for consideration during the GPU adoption process. No changes to the Draft PEIR are required in response to this comment.

O2-7 The comment provides policy direction in the Community Resources Element. It states that one of the concerns with the Brea Fire Department’s fuel modification zone requirement — a minimum distance of 170 feet beyond the construction boundary of any property on which a new structure can be built, within the designated High Fire Hazard and Very High Fire Hazard Severity Zones — is that it is applied as a blanket rule without biological review. The comment further asserts that the current fuel modification requirements should distinguish between different habitat types:
specifically, thinning standards for chaparral (which has evolved with fire) should differ from clearing standards for coastal sage scrub (which provides habitat for the California gnatcatcher and other listed species). The comment argues that coastal sage scrub should be retained to the greatest degree possible, as the current standard is not scientifically based.

The commenter raises concerns regarding fuel modification standards described in the Focused GPU, including recommendations for more site-specific, habitat-sensitive approaches and the incorporation of additional policies related to fire-resistant landscaping and biological resource protection.

These comments pertain to the content and refinement of General Plan policies and implementation measures, rather than the adequacy of the environmental analysis in the Draft PEIR. It should be noted that the actual standard is a minimum distance of 200 feet, not 170 feet; the GPU contains a typographical error. The PEIR evaluates, at a programmatic level, the potential environmental impacts associated with implementation of the GPU, including impacts related to biological resources and wildfire in Draft PEIR Section 4.3, Biological Resources, and Section 4.16, Wildfire, respectively, and identifies applicable regulatory requirements and mitigation measures where appropriate. The level of detail in the PEIR is commensurate with the programmatic nature of the GPU, and site-specific design features, such as fuel modification strategies and landscaping palettes, would be developed and evaluated at the project level, where more detailed information is available. The comment’s assertion that a blanket rule causes unnecessary disturbance does not invalidate the PEIR’s impact conclusions, since the actual impact would be addressed at the project- PEIR 2-88 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR level. The extent of biological resources impacts that takes into account habitat types would be assessed through implementation of Mitigation Measure MM BIO-1. Also note that assuming the minimum 200 feet would be a reasonable assumption under CEQA. No new substantially significant impact that was not addressed in the PEIR would occur and the analysis is legally sufficient. Additionally, any future development on hillside properties would be subject to project-level CEQA review. AB 130 as mentioned in the introduction (Comment O2-3) applies to qualifying infill residential projects in urban areas, therefore, hillside residential properties in the City’s SOI would not qualify. At that stage, the City’s Biological Resources Mitigation Measures (e.g., MM-BIO-1) would require site-specific surveys.

Pursuant to CEQA Guidelines Section 15088, the responses are focused on environmental issues related to the adequacy of the Draft PEIR. The commenter’s recommendations regarding revisions to GPU policies and standards do not identify deficiencies in the impact analysis presented in the Draft PEIR. Therefore, no changes to the environmental analysis are required.

The City acknowledges the commenter’s recommendations and will forward them to decision-makers for consideration as part of the GPU policy development and adoption process.

O2-8 The comment states the GPU does not appear to comply with Assembly Bill 1889, which requires adoption of a wildlife connectivity element, or to ensure that wildlife connectivity goals, policies, and actions are included in other elements. The GPU, as proposed for adoption, meets the statutory requirements of AB 1889 by integrating wildlife connectivity goals into the broader planning framework rather than as a standalone element, which is a permissible approach under Government Code Section 65300.5. Specifically, the General Plan Update addresses the following topics:
• Identification of Connectivity Areas: The Plan acknowledges Brea is bordered by Tonner Canyon, a significant natural wildlife corridor, and Sonome Canyon.

Figure CR-3 specifically illustrates these corridors.
• Remediation of Barriers: The Plan identifies major infrastructure barriers, such as Carbon Canyon Road, which bisects the Sonome Canyon corridor. To remediate this, Action CR-5d commits to seeking funding for wildlife corridor improvements, including dry wedges, culverts, and overcrossings in highpriority locations. • Development Standards for Connectivity: Action CR-3e specifically requires development projects to avoid identified or potential wildlife corridors to the PEIR 2-89 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR maximum extent feasible and to provide project design features that preserve connectivity and support wildlife movement where avoidance is not feasible.

This action has been added to further the Community Resources Element’s Goal CR-3 to preserve and maintain open space for nature, resource management, recreation, and scenic enjoyment. Action CR-5b also requires the City to assess development proposal for potential impacts to significant natural resources pursuant to CEQA and associated State and Federal regulations and require appropriate mitigation measures based on site-specific habitat assessment prior to any site disturbance (Mitigation Measure MM BIO-1). Where additional impacts are identified, MM BIO-2 through MM BIO-9 have been incorporated to reduce impacts to a less than significant level. Additional GPU policies and actions that support wildlife corridor connectivity includes Policy CD-2.15 that supports the use of wildlife friendly design features in new development and public improvements; CR-3.2 that supports conservation of sensitive species, plant communities, and wildlife habitats to the maximum extent feasible; Policy CR-3.3 that supports conserving sensitive hillside, ridgelines, canyons, and open space areas, and protecting wildlife corridors and habitat connectivity; Action CR-3b that requires to reassess the City’s Hillside Zoning Ordinance to minimize the encroachment of new development near areas of open space, especially sensitive areas; Policy CR-5.7 that encourages the preservation of critical wildlife corridors during the development review process, and Action PS-1j that mandates inter-agency coordination following wildfires to assess impacts on movement areas.
• Consultation with Experts: Consistent with AB 1889’s consultation goals, the Plan references active collaboration with the Wildlife Corridor Conservation Authority (WCCA) to ensure proper planning and maintenance of the habitat bridge between the Puente and Chino Hills. Consultation also occurred between the City of Brea and Hillsides for Everyone as part of the Focused General Plan Update process.
• Wildlife-Friendly Features: The GPU includes various policies and actions that are wildlife-friendly some of the policies include, but are not limited to: Policy CD-1.4 that supports preserving open space wherever possible and to the extent feasible, particularly in hillside areas; Policy CD 1.8 that supports sustainable development practices to reduce environmental impacts and support long-term community sustainability; Policy D-1.13 that supports responsible Hillside development with site design that protect natural landforms, preserve natural and biological resources; Policy CD-2.4 that promotes environmentally PEIR 2-90 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR responsive design; Policy CD-2.13 that preserves the scenic beauty of Brea’s hillside; Policy CD-2.15 that supports the use of wildlife friendly design features in new development and public improvements, such as strategies that promote bird safety, light mitigation, permeability, and ecological landscaping, especially for projects located within or adjacent to the wildland-urban interface to minimize human-wildlife conflicts and protect local biodiversity; and Policy CD-4.6 supports preserving natural fire breaks through designated Open Space land use.

Furthermore, the following modifications were made to the Focused GPU to further minimize and avoid impacts to wildlife:
• Added Policy CD-1.13, Responsible Hillside Development • Expanded CD-2.4 Sustainable Design.
• Added Policy CD-4.8, Clustered Development
• Added Action CD-4c, Hillside Fire Resistant Development Standards • Added CD-4d, Exploring and analyze the feasibility of a Transfer of Development Rights (TDR)
• Added Policy CD-5.10, Infrastructure Extension
• Expanded CR-3.1 Open Space Preservation.
• Expanded Policy CR-3.3 Hillside Preservation.
• Expanded Action CR-3b to consider the unique impacts of fire hazards in hillside areas.
• Added Action CR-3e, to avoid development impacts to identified or potential wildlife corridors to the maximum extent feasible.
• Expanded Policy 5.4 and 5.5 to protect landscaping and incorporate sustainable landscaping.
• Expanded Policy CR-5.9, Outdoor lighting.
• Expanded Action CR-5e to evaluate the potential of a Dark Sky, Lights Out, or other similar regulatory mechanism to reduce light pollution and minimize impacts on wildlife species.
• Expanded Action CR-5f, Tree Ordinance
• Added Action CR-5g, Subdivisions and Wildlife Movement • Added Action PS-5.11, Nature Based Solutions
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Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR The modified Draft PEIR Appendix C, Brea 2050 General Plan: Goals, Policies, and Actions, document is included as Attachment B to this Final PEIR. The City notes the commenter’s recommendations regarding AB 1889. However, because this comment focuses on policy language and does not identify a specific deficiency in the PEIR’s impacts analysis or mitigation measures, no further changes to the PEIR are required.

O2-9 The comment asserts that GPU Community Resources Element Figure CR-3, Wildlife Corridor Map, should be updated with more local information on major wildlife movement corridors. The comment also states that Figure CR-3 is missing where wildlife cross a road is critically important and missing from the map and should be reflected on Focused GPU Figure CR-3.

These comments pertain to the requirements of General Plan, rather than the adequacy of the environmental analysis in the Draft PEIR. The PEIR evaluates, at a programmatic level, the potential environmental impacts associated with implementation of the GPU, including impacts related to biological resources in Draft PEIR Section 4.3, Biological Resources. Absence of more local information on major movement corridor or wildlife crossing do not diminish or affect the assessment of the Project area.

O2-10 The comment states that the GPU should also clearly demonstrate compliance with Senate Bill 1425, which mandates GPU to include plans and programs that address equitable access to open space, climate resilience and other benefits coordinated with the Safety Element, and to preserve and enhance natural ecosystems, and provides specific actions identify these items. Specifically, the General Plan addresses the following topics:
• Equitable Access to Open Space: The Plan explicitly designates one SB 535 Disadvantaged Community (DAC) and eight AB 1550 Low-Income Communities. Policies like CR-1.2 and CR-1.6 prioritize funding and the development of recreational amenities in these underserved areas to ensure equitable distribution.
• Climate Resilience: The Public Safety Element addresses climate-driven hazards, while Goal PS-5 focuses on community resilience to severe weather and adverse health effects. Policy CR-1.3 also considers physical barriers like SR-57 and Imperial Highway when evaluating service area access, ensuring open spaces remain accessible.
• Rewilding Opportunities: The Plan includes Policy CR-3.5, which specifically directs the City to explore “rewilding” opportunities and ecological restoration projects aimed at increasing biodiversity.

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Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR In response to the comment, the following modifications were made to the Focused GPU:
• Added Policy CD-1.13, Responsible Hillside Development • Added Policy CD-4.8, Clustered Development
• Added Action CD-4c, Hillside Fire Resistant Development Standards • Added Policy CD-5.10, Infrastructure Extension
• Expanded Action CR-5f, Tree Ordinance
• Added Action CR-5g, Subdivisions and Wildlife Movement • Added Action PS-5.11, Nature Based Solutions
The modified Appendix C, Brea 2050 General Plan: Goals, Policies, and Actions, document is included as Attachment B to this Final PEIR.

These comments address the content of the Focused GPU in compliance with SB 1425, focusing on planning policies and actions rather than the adequacy of the environmental analysis contained in the PEIR. As such, the comments do not raise issues concerning the sufficiency of the PEIR under CEQA. Pursuant to CEQA Guidelines Section 15088, the City provides responses to comments on environmental issues raised regarding the adequacy of the Draft PEIR. Comments that pertain to policy preferences, land use planning considerations, or the content of the GPU itself are noted for consideration by decision-makers but do not require revisions to the environmental analysis in the PEIR.

The City acknowledges the commenter’s recommendations and will forward them to decision-makers for consideration during the GPU adoption process. No changes to the Draft PEIR are required in response to this comment.

O2-11 The comment provides policy direction in the Public Safety Element and provides additional action items to be included in the General Plan as they relate to adopting a Heat and Air Quality Improvement Plan with certain contents. The comment addresses the formulation of General Plan planning actions rather than the adequacy of the environmental analysis contained in the PEIR. As such, the comment does not raise issues concerning the sufficiency of the PEIR under CEQA. Pursuant to CEQA Guidelines Section 15088, the City provides responses to comments on environmental issues raised regarding the adequacy of the Draft PEIR. Comments that pertain to policy preferences, land use planning considerations, or the content of the GPU itself are noted for consideration by decision-makers but do not require revisions to the environmental analysis in the PEIR. The City acknowledges the commenter’s recommendations and will forward them to decision-makers for consideration during PEIR 2-93 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR the GPU adoption process. No changes to the Draft PEIR are required in response to this comment.

O2-12 The comment asserts that the PEIR must adopt legally adequate, enforceable mitigation measures at the time of project approval and cannot defer mitigation where effectiveness is uncertain. The comment states that several mitigation measures, particularly with respect to wildlife connectivity and hillside habitat areas lack sufficient specificity and performance standards. The comment recommends revisions to mitigation measures to strengthen clarity, enforceability, and ecological effectiveness. Recommendations provided by the commenter have been reviewed and incorporated where appropriate to further clarify and strengthen mitigation measures.

Mitigation Measures MM BIO-1, through MM BIO-7 have been modified. See Responses to Comment O2-13 through O2-16, and Section 3, Revisions to the Draft PEIR for revised mitigation measures. The revised Biological Resources Technical Report (BRTR) with revisions to the mitigation measures is included as Attachment D to this Final PEIR.

O2-13 The comment states that mitigation measures requiring pre-construction biological surveys (MM BIO-1, -2, -3, -6, and -7) should be revised to establish minimum survey protocols and should also specifically require that surveys be conducted prior to any site disturbance, require that survey results be documented in a report submitted to and approved by the City prior to issuance of grading permits, and, where sensitive resources are identified, the measures should require mandatory avoidance and minimization to the maximum extent feasible, rather than leaving such determinations to later discretionary judgment.

The specific types of surveys are addressed based on the presence or potential presence of sensitive resources. The biological resources survey is required prior to the issuance of any clearing, grading, or construction permits for individual development projects that are not exempt from CEQA, unless acceptable documentation is presented PEIR 2-94 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR demonstrating that that the project site does not contain native vegetation, sensitive plants, or undisturbed soils. Focused species surveys are jurisdictional delineations are triggered by the findings of the general biological survey.

Seasonal timing requirements tied to species detectability are provided for mitigation measures for specific species, when appropriate (i.e., when required to occur during the breeding season; this does not apply to western burrowing owl). Otherwise, they are described as having to follow survey protocols.

Mitigation measures to reduce impacts to sensitive resources to less than significant have been put in place; mandatory avoidance is not required. Pursuant to comment, the following modifications were made to Mitigation Measure MM BIO-1 through MM BIO-3, and MM BIO-5 through MM BIO-7 to strengthen pre-construction survey requirements and timing. These changes strengthen the existing mitigation measures and do not constitute significant new impact or information that require recirculation.

Changes to the DEIR text are shown in underlined text for additions and strikeout for deletions.

Examples of acceptable documentation include, but are not limited to, the following:
• Aerial photographs (historic and current) showing grading, building footprints, paving, and landscaped areas over time to support ornamental status, existing landscape plans.

PEIR 2-95 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR • Photographic documentation consisting of georeferenced or dated photographs.
• Landscaping plans or as-built drawings demonstrating that vegetation was intentionally planted as part of site development. • Field survey results prepared by a qualified biologist confirming that existing plant species are ornamental and non-native.

Within the future site-specific project areas exhibiting native vegetation, a site-specific biological resources survey shall be conducted during the project design phase.

PEIR 2-96 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR • If the project site supports sensitive vegetation communities, the project proponent shall implement the following weed control methods to minimize the establishment and spread of non-native and invasive weed species in the project site during construction activities:
− Seeds and plant materials used for revegetation shall be certified weed-free.
− Straw materials, such as those used for erosion control, shall be certified weed-free.
• The results of the biological survey shall be presented in a biological technical report. The survey report shall map and describe the location and extent of observed sensitive resources, including sensitive vegetation communities, regional wildlife movement corridors, plant, and wildlife species within the areas of potential direct and indirect effects for each project area, direct and indirect impacts associated with construction and operation of a project, and the need for further survey, monitoring, or mitigation, including measures pursuant to Mitigation Measures MM BIO-2, MM BIO-3, MM BIO-4, MM BIO-5, MM BIO6, and MM BIO-7 of this Program Environmental Impact Report. The biological technical report shall be submitted to and approved by the City of Brea prior to issuance of grading permits. The report shall incorporate applicable mitigation measures (MM BIO-2 through MM BIO-9) to reduce any potentially significant impacts to biological resources.

MM BIO-2 Focused Sensitive Plant Species Surveys. If recommended by the Biological Resources Survey/Habitat Assessment prepared pursuant to Mitigation Measure MM BIO-1, prior to any site disturbance, including grading, vegetation clearing, or fuel modification, focused surveys for future site-specific development shall be conducted, as applicable, in suitable habitat, to determine presence/absence of sensitive plant species on the project site. Focused sensitive plant surveys shall be conducted during the species’ specific blooming periods to determine presence/absence. If sensitive plant species are mapped within any proposed construction, access, or staging areas, these species shall be quantified and flagged, and these areas shall be modified to avoid direct impacts to mapped sensitive plant species. If significant impacts to these species are unavoidable, the impact on these species shall be reduced to a less than significant level through implementation of one or a PEIR 2-97 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR combination of the following actions, in accordance with a Conceptual Restoration Plan or acquisition of mitigation credits, reviewed and approved by the City of Brea:
• Impacted plants shall be salvaged and relocated to suitable habitat in an on-site restoration area, if possible. If relocation to a restoration area is not practical, the plants shall be relocated off-site to an appropriate location determined by a qualified biologist. • Seeds from impacted plants shall be collected for use at a local offsite location, as applicable. • Off-site habitat that supports the species impacted shall be enhanced or supplemented with seed collected on site.
• Comparable habitat at an approved off-site location shall be determined by a qualified biologist and preserved for relocation, enhancement, or transplant of the impacted sensitive plants.

Mitigation that involves relocation, enhancement, or transplant of sensitive plants shall include all the following:
• Conceptual planting plan prepared by a qualified biologist including grading, planting specifications, and, if appropriate, temporary irrigation.
• Planting specifications and fencing and signage to discourage unauthorized access of the planting site.
• Monitoring program prepared by a qualified biologist with clearly stated goals and objectives and well-defined performance standards that result in no net loss of sensitive plant resources. Final success criteria shall be determined based on quality, quantity, and species of plant impacted and in consultation with California Department of Fish and Wildlife and U.S. Fish and Wildlife Service depending on the status of the species. The monitoring program will include measures for adaptive management detailing remedial actions if success criteria are not met in the monitoring time frame. Remedial actions may include, but are not limited to, supplemental water, replanting, and herbivore deterrents/protections.

PEIR 2-98 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR Vegetation communities and land cover types will be verified in the field during the required biological survey and will be mapped for impact analysis. Any direct impacts to sensitive vegetation communities require mitigation to comply with California Department of Fish and Wildlife authorizations, as well as the ratios defined in any State or Federal permit(s) issued for the project.

PEIR 2-99 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR • When proposed mitigation involves habitat enhancement, restoration or creation, the Habitat Mitigation and Monitoring Plan shall include all of the following information:
• Conceptual planting plan including planting zones, grading, and irrigation.
• Seed mix/planting palette.
• Planting specifications.
• Monitoring program prepared by a qualified biologist including success criteria that ensure no net loss of sensitive vegetation communities. Final success criteria shall be determined based on quality, quantity, and type of habitat impacted and in consultation with CDFW. The monitoring program shall include measures for adaptive management plan detailing remedial actions if success criteria are not met in the monitoring time frame. Remedial actions may include, but are not limited to, supplemental water, replanting, and herbivore deterrents/protections.

For mitigation that involves habitat acquisition, the Habitat Mitigation and Monitoring Plan shall include all the following:
• Location of proposed acquisition.
• Description of the biological resources to be acquired, including support for the conclusion that the acquired habitat mitigates for the specific maintenance impact.
• Documentation that the mitigation area would be adequately preserved and maintained in perpetuity through conservation easements or similar mechanisms.

The identification of mitigation site credits shall be provided to the City of Brea and shall include the following:
• Location of approved mitigation site.
• Description of the mitigation credits to be acquired, including substantial evidence that the acquired habitat mitigates for the specific maintenance impact.
• Documentation of the credits that are associated with a mitigation bank, which has been approved by the appropriate resource agencies.
• Documentation in the form of a current mitigation credit ledger.

PEIR 2-100 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR MM BIO-5: Qualified Monitoring Biologist. If recommended by the Biological Resources Survey/Habitat Assessment prepared pursuant to Mitigation Measure MM BIO-1, a qualified monitoring biologist shall be retained to implement required monitoring. The qualified monitoring biologist shall be responsible for the following monitoring and reporting tasks:
a. Biological Construction Mitigation/Monitoring Exhibit. Prior to the start of 2-100 onstruction site disturbance, including grading, vegetation clearing, or fuel modification, within the future sitespecific project areas that have potential to contain sensitive biological resources, the qualified monitoring biologist shall submit a Biological Construction Mitigation/Monitoring Exhibit, which includes limits of work, proposed monitoring schedule, bird, focused sensitive species, or other wildlife surveys/survey schedules (including general bird nesting and U.S. Fish and Wildlife Service protocol), timing of surveys, bird construction avoidance areas/noise buffers/barriers, other impact avoidance areas, and any subsequent requirements determined by the qualified monitoring biologist. The Biological Construction Mitigation/Monitoring Exhibit shall include the construction site plan, written and graphic depiction of the project’s biological mitigation/monitoring program, and a schedule for construction activities. Where the potential for impacts to biological resources is limited (e.g., construction within a footprint that consists entirely of previously developed or disturbed lands), the Biological Construction Mitigation/Monitoring Exhibit may be limited to a pre- and post-maintenance verification inspection by a qualified biologist. For highly sensitive resource areas with documented sensitive biological and aquatic resources present, full-time biological monitors may be required, as determined by a qualified biologist. The Biological Construction Mitigation/Monitoring Exhibit shall be approved by the City of Brea prior to the start of construction.
b. Resource Marking/Protection. Prior to the start of construction activitiessite disturbance within the future site-specific project area, the qualified monitoring biologist shall supervise the placement of orange construction fencing or similar visible marker, staking, or flagging along the limits of the construction area adjacent to sensitive biological habitats, as shown on the Biological Construction Mitigation/Monitoring Exhibit to ensure crews remain PEIR 2-101 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR within the approved construction limits. These demarcations shall not be required for areas with existing barriers, such as chain-link fencing, along the limits or facilities that are within or adjacent to developed and non-sensitive habitat areas. This task shall include flagging plant specimens and delineating buffers to protect sensitive biological resources (e.g., habitats, sensitive plant and wildlife species, including nesting birds) prior to construction. c. Cover Trenches. The qualified monitoring biologistshall oversee the construction site so that cover and escape routes for wildlife from excavated areas shall be provided daily. All trenches, holes, and excavations during construction shall be covered at night as directed by the monitoring biologist with plywood, metal plates, or other means, and if plastic sheeting is used, the edges must be covered with soils such that small wildlife cannot access the excavated hole.

Soil piles shall be covered at night to prevent wildlife from burrowing in. The edges of the sheeting shall be weighed down by sandbags. These areas may also be fenced to prevent wildlife from gaining access. Exposed trenches, holes, and excavations shall be inspected twice daily (i.e., each morning and before sealing the exposed area) by the qualified monitoring biologist to monitor for wildlife entrapment. Excavations shall provide an earthen ramp to allow for a wildlife escape route. The qualified monitoring biologist shall verify that the contractor has covered all steep-walled trenches or excavations prior to the end of construction daily. If wildlife species are encountered within any trenches or excavated areas, the qualified monitoring biologist shall remove them, if possible, or provide them with a means of escape (e.g., a ramp or sloped surface at no greater than a 30-degree angle) and allow the species to disperse. In addition, the qualified monitoring biologist shall provide training to construction personnel to increase awareness of the possible presence of wildlife beneath vehicles and equipment and to use best judgment to avoid killing or injuring wildlife (refer to Mitigation Measure BIO-5e).
d. Structure and Tree Clearance. Prior to the issuance of any permit to allow for the removal or demolition of trees and existing structures within the survey area (particularly any ornamental trees and existing buildings in the developed land areas), the qualified monitoring biologist shall conduct clearance surveys to flush out PEIR 2-102 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR any wildlife species nesting, roosting, or otherwise occupying the trees or structures. If wildlife species are encountered within any of the trees or structures (outside the general bird nesting season), the qualified monitoring biologist shall remove them, if possible, or provide them with a means of escape and allow the species to disperse. If tree-roosting bats are suspected, slow removal by gently pushing the tree over with heavy equipment is required. e. Pre-Construction Meeting/Education. Prior to the start of any construction activity site disturbance where the site plan for the construction area indicates that significant impacts to biological resources may occur, as determined by a qualified biologist, a preconstruction meeting shall be held on site with the following in attendance: City of Brea representative (project planner and building inspector), the construction contractor (if applicable), and the qualified monitoring biologist. At this meeting, the qualified monitoring biologist shall identify and discuss the construction protocols that apply to the proposed activities and the sensitive nature of the adjacent habitat with appropriate project personnel.

At the pre-construction meeting, the qualified monitoring biologist shall submit to the City of Brea representatives and construction contractor a copy of the Biological Construction Mitigation/Monitoring Exhibit that identifies areas to be protected, fenced, and monitored. This data shall include all buffer limits, if applicable.

This may include but not be limited to explanations of the bird and wetland buffers, the flag system for removal of invasive species or retention of sensitive plants, and clarification of acceptable access routes/methods and staging areas.
f. Biological Monitoring and Reporting. The qualified monitoring biologist with stop work authority shall inspect/monitor the project construction area in accordance with the approved Biological Construction Mitigation/Monitoring Exhibit. This may be limited to pre- and post-maintenance inspections, weekly visits, or full-time PEIR 2-103 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR monitoring, as determined by the qualified monitoring biologist and the City of Brea.

The qualified monitoring biologist shall document monitoring events via a Consultant Site Visit Record. This record shall be sent to the City of Brea project manager each month. However, if weekly reports are submitted as part of a separate agency permit requirement, these reports may be forwarded to the City of Brea in place of Consultant Site Visit Record submittals.

If no deviations from the construction site plan occur during maintenance, no additional documentation is required. However, if deviations from the site plan do occur, such as unanticipated impacts to sensitive vegetation communities or unanticipated discharge of pollutants, a Final Monitoring Report shall be prepared within 3 months following the completion of mitigation monitoring detailing maintenance and monitoring that occurred, and any remedial or compensatory measures taken.

MM BIO-6 Focused Sensitive Wildlife Species Surveys. If recommended by the Biological Resources Survey/Habitat Assessment prepared pursuant to Mitigation Measure MM BIO-1, prior to any site disturbance, including grading, vegetation clearing, or fuel modification, focused surveys for future site-specific development shall be conducted, as applicable, in suitable habitat, to determine presence/absence of sensitive wildlife species within the proposed survey area. If sensitive wildlife species or their habitat are present or potentially present based on biological surveys, the following measures shall be implemented.
a. Crotch’s Bumble Bee. Habitat assessment surveys for California Endangered Species Act (CESA) candidate bumble bee species, with a focus on Crotch’s bumble bee, followed the California Department of Fish and Wildlife (CDFW) methodology from the Survey Considerations for CESA Candidate Bumble Bee Species dated June 6, 2023 (CDFW Survey Considerations) (CDFW 2023). If no Crotch’s bumble bees are found during the focused surveys, but the habitat assessment identified suitable nesting, foraging, or overwintering habitat on the project site, recommendations outlined in the CDFW Survey Considerations will be followed, including recommendations that a biological monitor be on site during PEIR 2-104 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR vegetation or ground-disturbing activities that take place during any of the Queen and Gyne Flight Period and Colony Active Period. If Crotch’s bumble bees are observed, project proponents may propose site-specific measures to avoid take, or consult with CDFW to obtain an Incidental Take Permit (ITP) if take of CESA-protected bumble bees may occur during project activities.
b. Western Spadefoot and Monarch Butterfly. If western spadefoot or monarch butterfly become listed prior to implementation of future site-specific development projects, focused surveys and consultation with the U.S. Fish and Wildlife Service (USFWS) would be necessary.
c. Western Burrowing Owl. If suitable habitat for western burrowing owl is present (annual grassland and agricultural land), a qualified biologist shall conduct focused surveys of the site and a 500-foot buffer, as access allows. If no burrowing owls are identified, no further measures are necessary. If burrowing owls are detected, active burrows shall be avoided using buffers outlined in the Staff Report on Burrowing Owl Mitigation, dated March 7, 2012, issued by CDFW. If avoidance is not possible, the qualified biologist shall consult with CDFW. No direct disturbance to burrowing owls or their occupied habitat shall occur without appropriate authorization from CDFW.
d. Least Bell’s Vireo. If suitable habitat for least Bell’s vireo is present and clearing, grubbing, grading, or other construction activities may occur between March 15 and September 15, the breeding season of the least Bell’s vireo, a qualified biologist shall conduct focused surveys for the presence of the least Bell’s vireo of the site and areas of potentially suitable habitat within 300 feet or that would be subject to construction noise levels exceeding 60 A-weighted decibels or to the ambient noise level if it already exceeds 60 Aweighted decibel hourly average. If present, measures to minimize noise impacts (such as temporary noise walls/berms) may be required. Noise levels from construction activities during the avian breeding season should not exceed 60 decibels (dBA Leq; or the ambient noise level if they already exceed 60 dBA Leq) at the edge of the occupied habitat. If complete avoidance is not feasible, the qualified biologist shall consult with USFWS. No direct harm to the species shall be allowed without appropriate authorization from USFWS.

PEIR 2-105 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR e. Southwestern Willow Flycatcher. If suitable habitat for southwestern willow flycatcher is present and clearing, grubbing, grading, or other construction activities may occur between April 15 through September 15, the breeding season of the southwestern willow flycatcher, a qualified biologist shall conduct focused surveys for the presence of the southwestern willow flycatcher of the site and areas of potentially suitable habitat within 500 feet. If the species is determined to be present, consultation per Endangered Species Act with USFWS would be necessary and no activities would occur until authorized by USFWS. No direct harm to the species shall be allowed without appropriate authorization from USFWS.
f. Sensitive Bat Species. If suitable roosting habitat (e.g., riparian habitat, snags, wooden buildings, bridges, etc.) for sensitive bat species is present, a qualified biologist shall conduct subsequent focused surveys no less than 14 days prior to removal or disturbance of vegetation or buildings. The survey shall consist of visual and/or acoustic methods as deemed appropriate by the qualified biologist.

If no bats are detected, no further measures are necessary. If bat species are detected during surveys, a site-specific plan shall be developed by the qualified biologist. The plan may include, as determined by the qualified biologist, delaying removal of roost habitat until after the maternity roosting period and exclusion of bats from roosting habitat prior to removal of habitat. The qualified biologist shall consult with CDFW prior to implementing any exclusion activities.
g. Southwestern Pond Turtle. If suitable habitat for southwestern pond turtle is present pursuant to Mitigation Measure MM BIO-1, sitespecific measures shall be implemented to avoid impacts, as developed in consultation with a qualified biologist. Measures shall focus on avoiding habitat destruction, protecting individuals during construction, and managing habitat to increase survival though preconstruction surveys, exclusion fencing, biological monitoring, and habitat restoration. Depending on the measures selected, plan approval and conference with the U.S. Fish and Wildlife Service may be required if the action is likely to jeopardize the species’ existence during construction activities.
h. Mountain Lion. If suitable habitat for mountain lion is present pursuant to Mitigation Measure MM BIO-1, site-specific measures PEIR 2-106 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR shall be implemented to minimize habitat loss and fragmentation to improve habitat connectivity and avoid take. These measures shall be developed in consultation with a qualified biologist and may include measures described in the City of Brea General Plan Community Resources Element Policy CR-3e. If presence is established, Resource Agency consultation shall be required to obtain an incidental take permit.
gi. Other Sensitive Species. Prior to any demolition work, construction, or grading activities within the future site-specific project areas, preconstruction surveys for other sensitive wildlife species, such as reptiles, may be required to determine presence/absence of sensitive wildlife species within the proposed survey area.

The survey report shall map and describe the location and extent of observed sensitive bird species that would be impacted within the areas of potential effect for each project area. If no nesting birds are documented within the individual activity area, construction shall be allowed to proceed. If nesting birds cannot be completely avoided, a no-disturbance buffer shall be established around the active nest, the size of which will be determined by the qualified monitoring biologist based on species of bird and specific construction activities to take place. The size of the buffer can be reduced in consultation with California Department of Fish and Wildlife. Any work within the buffer shall be avoided until the nest is inactive, as determined by the qualified monitoring biologist.

PEIR 2-107 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR O2-14 The comment asserts that where impacts to sensitive habitats may occur, mitigation measures should be revised to include 1) quantifiable mitigation ratios; 2) clear requirements on mitigation lands location; and 3) metrics for evaluating the success.

Success criteria and mitigation ratios for permanent impacts require consultation with the California Department of Fish and Wildlife; therefore, a fixed, quantifiable mitigation ratio is not provided, except for a minimum ratio of 1:1. In addition, metrics for evaluating the success of restoration efforts vary by habitat type and ecological function and, as such, are not established at the programmatic level. In response to comments, Mitigation Measure MM BIO-3 has been revised for clarity. As modified, MM BIO-3 requires mitigation at a minimum ratio of 1:1 and, to the extent feasible, to be located within the same ecological region and be functionally equivalent or of superior habitat value. Refer to Response to Comments O2-13 and Section 3, Revisions to the Draft PEIR, for the revised mitigation measure.

O2-15 The comment recommends that Mitigation Measure MM BIO-1 be revised to include more specific and enforceable requirements related to the identification, avoidance, and minimization of impacts to wildlife movement and connectivity corridors, including design standards and performance criteria.

Pursuant to comment, additional clarity regarding the evaluation and protection of wildlife movement corridors has been provided to further strengthen the mitigation measure. The Draft PEIR has been revised to expand MM BIO-1 to more clearly require evaluation of both local and regional wildlife movement corridors and the Brea 2050 has been updated to include a more robust policy action related to wildlife connectivity.

As revised, MM BIO-1 now explicitly requires that site-specific biological resources surveys include an evaluation of potential local and regional wildlife movement corridors, as well as an assessment of corridor function and value using best available scientific information, including agency habitat connectivity maps and site-specific field observations. This ensures that wildlife movement considerations are identified early in project planning and integrated into environmental review and project design.

Additionally, as discussed in Response to Comment O2-12, policy Action CR-3e was added to the Community Resources Element to avoid development impacts on identified or potential wildlife corridors to the maximum extent feasible based on sitespecific biological surveys. The modified Brea 2050 General Plan: Goals, Policies, and Actions are included as Attachment B to the Final EIR.

The Draft PEIR appropriately establishes program-level mitigation measures that define performance standards and require site-specific analysis and design during PEIR 2-108 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR subsequent project-level review pursuant to CEQA Guidelines Section 15168. The revisions to MM BIO-1 and the addition of policy Action CR-3e do not constitute “significant new information” requiring recirculation under CEQA Guidelines Section 15088.5 because they clarify, strengthen, and add mitigation measures that further reduce potential impacts, without identifying new or more severe significant effects or depriving the public of a meaningful opportunity to comment. No further revisions are required.

O2-16 The comment recommends that mitigation measures be strengthened by reducing reliance on phrases such as “if determined necessary” or “as appropriate,” incorporating clearer triggers for implementation, and including defined performance standards, monitoring, reporting, and adaptive management provisions to ensure longterm effectiveness.

The City acknowledges the importance of clearly defined mitigation triggers, performance standards, and implementation requirements. T As described in Mitigation Measure (MM) BIO-1, all discretionary projects subject to CEQA review are required to prepare a Biological Resources Survey/Habitat Assessment where native vegetation or other qualifying conditions are present. This survey functions as the primary trigger for determining the applicability and scope of subsequent mitigation measures, including MM BIO-4. Because biological conditions (e.g., habitat type, species presence, disturbance history, and ecological function) vary substantially across the Planning Area, the use of site-specific surveys to trigger and tailor mitigation is consistent with CEQA Guidelines Sections 15126.4(a)(1)(B) and 15168, which allow for deferred, performance-based mitigation in program EIRs where detailed design is more appropriately addressed at the project level.

In response to the comment, MM BIO-4, Habitat Restoration for Temporary Impacts, has been revised to include preparation and City approval of a Revegetation Plan that establishes clear, enforceable performance standards and implementation requirements. Language for monitoring, reporting, and corrective action when success criteria are not met was added to MM BIO-4. Detailed success criteria and corrective actions vary depending on habitat type and ecological function and are not addressed at a programmatic level. MM BIO-4 has been modified to include the preparation of a Revegetation Plan. See end of this response for the revised mitigation measure.

With respect to the recommendation to further standardize triggers and minimum actions across all mitigation measures, the City notes that biological resource impacts are inherently site-specific and depend on variables such as habitat type, species presence, and the nature and extent of disturbance. Accordingly, establishing uniform, PEIR 2-109 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR prescriptive triggers at the program level would not be appropriate or effective across the range of conditions contemplated under the General Plan Update.

Instead, the PEIR establishes clear performance-based standards and requires that mitigation measures be refined and applied based on the results of site-specific biological surveys conducted pursuant to MM BIO-1. This approach is consistent with CEQA Guidelines Sections 15168 and 15126.4(a)(1)(B), which allow program EIRs to defer the precise formulation of mitigation measures where (1) specific performance standards are identified and (2) subsequent environmental review ensures implementation.

In addition, CEQA requires that mitigation measures maintain a reasonable nexus and proportionality to identified impacts. In the absence of project-specific design details and site conditions, it would be speculative and potentially infeasible to prescribe uniform ongoing monitoring requirements or adaptive management actions at this stage. Therefore, the PEIR appropriately requires that monitoring, reporting, and adaptive management measures be developed and tailored at the project level, where impact pathways and resource sensitivities can be accurately identified and addressed.

This framework ensures that mitigation measures remain enforceable, impact-specific, and effective, while maintaining consistency with CEQA requirements for programmatic environmental review.

Changes to the DEIR text are shown in underlined text for additions and strikeout for deletions.

Habitat restoration and erosion control treatments shall be installed within these short-term impact areas. A Revegetation Plan shall be prepared and shall include site preparation specifications, a plant palette, installation procedures, development of reasonable success criteria, appropriate monitoring and reporting protocols, implementation timelines, and contingency measures and adaptive management in the event of restoration failure. The Revegetation Plan shall be submitted to and approved by the City of Brea. Habitat revegetation shall feature native species that are typical of the area, and PEIR 2-110 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR associated erosion control best management practices shall include silt fence and microplastic- and weed-free straw fiber rolls, where appropriate. The revegetation areas shall be monitored and maintained by a qualified biologist or restoration specialist for 25 months to ensure adequate establishment and sustainability of the plantings/seedings.

Where a project activity involves potential disturbance of non-native invasive plant species (as identified by the California Invasive Plant Council), these plants shall be entirely removed immediately, where feasible, and the removal shall be monitored by the qualified monitoring biologist to ensure that dispersal of propagules (e.g., seeds and stems) are avoided or minimized. Where removal of plant roots is not feasible (e.g., where erosive flows are predicted), aboveground plant material shall be fully removed and monitored by the qualified monitoring biologist. Where aboveground plant material cannot be removed (e.g., due to limited access), herbicides shall be applied by a licensed pest control advisor, using chemicals permitted as safe within aquatic environments.

O2-17 The comment indicates that corrections should be made to PEIR Figure 4.3-5 (Wildlife Corridor-NCCPs Map), the Shell/Metropolitan Water District HCP and the Orange County Transportation Authority NCCP/HCP. The OCTA NCCP/HCP has been added to the Draft PEIR Figure 4.3-5, Wildlife Corridor/NCCPs. However, information on the Shell/MWD HCP is limited and appears to be a project specific HCP. Also, based on the figure provided by the commenter, it appears to be completely outside of the City’s Planning area. As such, it will not be added to Figure 4.3-5. The revised Figure

4.3-5, Wildlife Corridors/NCCPs, is included as Attachment E to this Response to Comments. These changes do not represent inadequacies of the Draft PEIR.

O2-18 This is conclusion to the letter further emphasizing that implementing the policy suggestions and mitigation measure revisions in the comment letter will serve to ameliorate those effects and provide a benefit to all of Brea. Responses to comments contained in the letter have been provided above (O2-1 through O2-17) and no further response is required.

O2-19 The comment requests to be notified of the release of the Final GPU/BCSP and the Final PEIR, and provide all notices for any hearings, staff reports, briefings, meetings, and other events related to the Project. The City acknowledges the request for notification. Pursuant to Public Resources Code (PRC) Section 21092.2 and CEQA Guidelines Section 15088, the City will provide a written response to all public PEIR 2-111 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR agencies that commented on the Draft PEIR at least 10 days prior to certifying the PEIR. Furthermore, the City will include Hills For Everyone and the firm on the project’s official notification list for future public notices as required by law. Staff reports and internal briefings are made available to the public via the City’s website in accordance with the Brown Act and local procedures.

PEIR 2-112 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR Letter O3. Mark Strom, March 25, 2026 (2 pages)
PEIR
2-113 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR PEIR 2-114 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR Letter O3. Mark Strom, March 25, 2026
O3-1 The comment states that it specifically relates to the land use designation for the 34- acre site at the southeast corner of Birch Street and Kraemer Boulevard (the Beckman Site). The comment claims that this site was identified as a primary Opportunity Site in the 6th Cycle Housing Element and the Draft PEIR, with a Mixed Use 50 land use designation and a capacity of 1,700 dwelling units.

This claim is only partially correct. The GPU and the Draft PEIR designates this site as Mixed Use 50 that allows for 6.1- to 50 dwelling units per acre. Although a maximum 50 dwelling units per acre for 34 acres would yield 1,700 dwelling units, the Draft PEIR provides an analysis of what could reasonably occur, not what each individual parcel could be developed at its maximum capacity. The overall increase in residential units under the Mixed Use 50 designation is 1,035 units, along with 3,294,889 square feet of non-residential area. More importantly, the Re-Adopted and Certified 6th Cycle Housing Element (2021–2029) does not identify this site as an Opportunity Site with 1,700 units to meet the City’s Regional Housing Needs Allocation.

It should be noted that CEQA Guidelines Section 15168 (Program EIR) recognizes that a program EIR appropriately evaluates broad policy-level actions and need not include the level of detail required for site-specific analysis. Similarly, CEQA Guidelines Section 15146 provides that the level of detail in an EIR should correspond to the level of specificity of the underlying plan, with later environmental review addressing more detailed, site-specific information. Consistent with these CEQA requirements, sitespecific analysis is not required in a programmatic EIR.

O3-2 The comment asserts that the PEIR is flawed because it fails to account for the Economic Development Agreement approved by the City Council to develop this site into a 165,000-square-foot Costco warehouse instead of residential uses. As stated in Response to Comment O3-1, the Beckman Site is not identified as a primary Opportunity Site, and site-specific analysis is not required under CEQA Guidelines Sections 15168 and 15146.

O3-3 The comment asserts that the City is in violation of Senate Bill 166 due to a net loss of 1,420 housing units. The GPU does not include updates to the 6th Cycle Housing Element. The contents of the 6th Cycle Housing Element, including compliance with Senate Bill 166 (No Net Loss), are not being reviewed as part of the Proposed Project.

Furthermore, as stated in Response to Comment O3-1, the Beckman Site is not identified as a primary Opportunity Site in the adopted Housing Element. The PEIR 2-115 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR commenter’s claim of a net loss of 1,420 housing units is not substantiated. No further response regarding replacement housing sites for the Beckman Site is warranted.

O3-4 The comment asserts that the PEIR does not accurately analyze the impacts of a bigbox retail warehouse combined with low-density residential uses, rendering the PEIR’s cumulative impact analysis invalid.

CEQA Guidelines Section 15168, Program EIR recognizes that a program EIR appropriately evaluates broad policy-level actions and need not include the level of detail required for site-specific analysis. Similarly, CEQA Guidelines Section 15146 provides that the level of detail in an EIR should correspond to the level of specificity of the underlying plan, with later environmental review addressing more detailed, sitespecific information. Consistent with these provisions, the PEIR adequately evaluates the project as described in Chapter 2, Project Description, which designates the Beckman Site as Mixed Use 50. The Draft PEIR further discloses on Section 4.2.4.3, Threshold AQ-c, that, based on California Air Resources Board siting recommendations, a detailed Health Risk Assessment is required for proposed sensitive receptors within 1,000 feet of a warehouse distribution center, among other recommendations. Since specific project details (including location and use) are not known at this time, the Draft PEIR identifies the potential for future facilities to expose sensitive receptors to toxic air contaminants (TACs) and for new sensitive receptors to be located within screening distances of TAC sources. Preparation of a project-level health risk assessment would ensure impacts are reduced to a less-than-significant level.

Section 4.11, Noise, also addresses potential noise impacts to sensitive receptors. As discussed under Section 4.11.4.1, Threshold NOI-a, new sensitive receptor development under the GPU would be subject to PPP NOI-1, which requires acoustical studies demonstrating compliance with applicable noise standards. All future projects must comply with the Brea Noise Control Ordinance; therefore, noise impacts are considered less than significant, both individually and cumulatively.

Traffic impacts associated with the Mixed Use 50 designation include both residential and non-residential uses, reflecting an increase of 1,035 units and 3,294,889 square feet of non-residential space. The Draft PEIR adequately evaluates both components. No further response is required.

O3-5 The comment asserts that the Housing Element Update could be decertified if the 1,700 units attributed to the Beckman Site are lost due to a long-term agreement for retail warehouse development. Refer to Response to Comment O3-3.

PEIR 2-116 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR O3-6 The comment questions why the PEIR uses a 1,700-unit capacity assumption for environmental modeling of the Beckman Site. As explained above, the PEIR does not conduct site-specific analysis and instead evaluates an overall increase of 1,035 units and 3,294,889 square feet of non-residential space under the Mixed Use 50 designation.

No inadequacy has been identified; therefore, no further response is required.

O3-7 The comment requests that the Final PEIR be revised to reflect the actual planned use of the Beckman Site and to explain the loss of 1,420 units without increasing density in existing residential neighborhoods. As discussed in Responses to Comments O3-1 through O3-6, revisions to the Draft PEIR are not warranted. No further response is required.

PEIR 2-117 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR Letter O4. Aaron Black, March 30, 2026 (1 page)
PEIR 2-118 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR Letter O4. Aaron Black, March 30, 2026
O4-1 This is an introduction about the commenter and no response is required.

O4-2 The comments assert that certain housing programs and policies be included in the Brea 2050. Under CEQA, the primary purpose of an EIR is to identify and analyze the potential physical environmental effects of the Proposed Project. The selection and adoption of specific General Plan policies are matters of policy consideration by the City’s decision makers, and outside the purview of the scope of this PEIR. The comment does not address environmental issues or the adequacy of the PEIR. The comment has been forwarded to the decision makers, and no further response is required.

PEIR 2-119 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR Letter O5. Bev Perry, March 31, 2026 (1 page)
PEIR 2-120 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR Letter O5. Bev Perry, March 31, 2026
O5-1 The comment asks that the Shute, Mihaly & Weinberger letter of 9/24/25 on behalf of Hills For Everyone submitted to the Notice of Preparation to be included as part of the Areas of Controversy in the PEIR. This letter has been included in Section 3, Revisions to the Draft PEIR, as part of modification to Table 1-1, NOP Comments Summary.

Comments have been addressed in the Draft EIR. The summary of comments included in the 6/24/25 on behalf of Hills for Everyone and responses are provided in Table 1- 1, and there were no issues that were not addressed and needed to be included as part of the Areas of Controversy of the Draft PEIR.

O5-2 The commenter is concerned the Focused GPU allows for development of 1,663 units in the 3,325 acres with the Hillside Residential designation subject to hillside development policies. The comment questions why the GPU does not point out that the City would allow a Transfer of Development Rights program to allow converting hillside density right. The GPU does not increase the existing Hillside Residential density. Development density allowed under the current Hillside Residential density remains.

Comments pertain to policy planning for the Brea 2050, and not to the scope of the Draft PEIR. Under CEQA, the primary purpose of an EIR is to identify and analyze the potential physical environmental effects of the Proposed Project. The selection and adoption of specific General Plan policies are matters of policy consideration by the City’s decision makers, and outside the purview of the scope of this PEIR.

Additionally, the following new policy was added to the GPU’s Community Development Element Hillside Development Goal CD-4 to minimize the extent of development in the hillside.
• Policy CD-4.8, Clustered Development. Incentivize clustered development within hillside areas by directing new development to previously disturbed or less environmentally sensitive areas to preserve natural landforms, open space, and visual character.

Comments on the content and policy direction recommendations to the GPU are noted and will be provided to City decision-makers for consideration. However, such recommendations do not constitute evidence of a deficiency in the PEIR’s environmental analysis. No further response is required.

O5-3 The commenter states that the GPU doesn’t appear to comply with AB 1889 and requests to develop a stand-alone Wildlife Connectivity Element. The GPU, as proposed for adoption, meets the statutory requirements of AB 1889 by integrating PEIR 2-121 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR wildlife connectivity goals into the broader planning framework rather than as a standalone element, which is a permissible approach under Government Code Section 65300.5. Specifically, the General Plan Update addresses the following topics:
• Identification of Connectivity Areas: The Plan acknowledges Brea is bordered by Tonner Canyon, a significant natural wildlife corridor, and Sonome Canyon.

Figure CR-3 specifically illustrates these corridors.
• Remediation of Barriers: The Plan identifies major infrastructure barriers, such as Carbon Canyon Road, which bisects the Sonome Canyon corridor. To remediate this, Action CR-5d commits to seeking funding for wildlife corridor improvements, including dry wedges, culverts, and overcrossings in highpriority locations. • Development Standards for Connectivity: Action CR-3e specifically requires development projects to avoid identified or potential wildlife corridors to the maximum extent feasible and to provide project design features that preserve connectivity and support wildlife movement where avoidance is not feasible.

PEIR 2-122 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR • Consultation with Experts: Consistent with AB 1889’s consultation goals, the Plan references active collaboration with the Wildlife Corridor Conservation Authority (WCCA) to ensure proper planning and maintenance of the habitat bridge between the Puente and Chino Hills. Consultation also occurred between the City of Brea and Hillsides for Everyone as part of the Focused General Plan Update process.
• Wildlife-Friendly Features: The GPU includes various policies and actions that are wildlife-friendly some of the policies include, but are not limited to: Policy CD-1.4 that supports preserving open space wherever possible and to the extent feasible, particularly in hillside areas; Policy CD 1.8 that supports sustainable development practices to reduce environmental impacts and support long-term community sustainability; Policy D-1.13 that supports responsible Hillside development with site design that protect natural landforms, preserve natural and biological resources; Policy CD-2.4 that promotes environmentally responsive design; Policy CD-2.13 that preserves the scenic beauty of Brea’s hillside; Policy CD-2.15 that supports the use of wildlife friendly design features in new development and public improvements, such as strategies that promote bird safety, light mitigation, permeability, and ecological landscaping, especially for projects located within or adjacent to the wildland-urban interface to minimize human-wildlife conflicts and protect local biodiversity; and Policy CD-4.6 supports preserving natural fire breaks through designated Open Space land use.

PEIR 2-123 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR • Expanded Action CR-3b to consider the unique impacts of fire hazards in hillside areas.
• Added Action CR-3e, to avoid development impacts to identified or potential wildlife corridors to the maximum extent feasible.
• Expanded Policy 5.4 and 5.5 to protect landscaping and incorporate sustainable landscaping.
• Expanded Policy CR-5.9, Outdoor lighting.
• Expanded Action CR-5e to evaluate the potential of a Dark Sky, Lights Out, or other similar regulatory mechanism to reduce light pollution and minimize impacts on wildlife species.
• Expanded Action CR-5f, Tree Ordinance
• Added Action CR-5g, Subdivisions and Wildlife Movement • Added Action PS-5.11, Nature Based Solutions
The modified Draft PEIR Appendix C, Brea 2050 General Plan: Goals, Policies, and Actions, document is included as Attachment B to this Final PEIR. The City acknowledges the commenter’s recommendations regarding AB 1889. However, because this comment focuses on policy language and does not identify a specific deficiency in the PEIR’s impacts analysis or mitigation measures, no further changes to the PEIR are required.

PEIR 2-124 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR Letter O6. Joseph Harijanto, March 6, 2026 (1 page)
PEIR 2-125 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR Letter O6. Joseph Harijanto, March 6, 2026
O6-1 The comment recommends that security considerations, including Crime Prevention Through Environmental Design (CPTED) principles, be more explicitly incorporated into the Specific Plans and that a comprehensive security strategy be developed in coordination with qualified professionals and local law enforcement.

The comment does not identify a specific deficiency in the adequacy of the Draft PEIR under CEQA, but instead provides recommendations regarding planning and design features of the Brea 265 Specific Plan, which is understood to refer to the Brea Core Specific Plan. Comments on the content, policy direction, or design preferences of the Specific Plan are noted and will be provided to City decision-makers for consideration; however, such recommendations do not constitute evidence of a deficiency in the PEIR’s environmental analysis.

The comment does not identify a specific physical environmental impacts pertaining to CPTED design considerations that has not been analyzed in the Draft PEIR.

Nonetheless, the Draft PEIR acknowledges the role of project design and regulatory review in addressing safety considerations. As described in Section 4.12.2.3, Plans, Programs, and Policies, future discretionary development projects will be subject to project-level review, including review by the Brea Police Department, which evaluates site design features to promote safety and security. This review process inherently incorporates principles consistent with CPTED, such as visibility, access control, and territorial reinforcement, as appropriate for each project.

In addition, the Brea Core Specific Plan includes guiding principles related to enhancing quality of life, health, wellness, and safety through the built environment, which provide a framework for incorporating safety considerations into future development.

The Draft PEIR adequately evaluates the environmental impacts of the proposed plans in accordance with CEQA. The comment raises planning and design recommendations that do not identify a CEQA deficiency, and no revisions to the PEIR are required.

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PEIR 3-1 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR Section 3 Revisions to the Draft PEIR

3.1 Introduction
This section contains revisions to the Draft PEIR based upon additional or revised information required to prepare a response to a specific comment. This section also includes additional mitigation measures to fully respond to commenter concerns as well as provide additional clarification to mitigation requirements included in the Draft PEIR. The provision of these modified mitigation measures does not alter any impact significance conclusions as disclosed in the Draft PEIR. Notice of Preparation comment letters from the following agencies and interested parties/organizations were inadvertently omitted from the Draft PEIR. Therefore, they have been added to Table 1-1, NOP Comments Summary, as shown below, and to Appendix B, Notice of Preparation Comment Letters. These letters are included as Attachment F to the Final PEIR.  South Coast Air Quality Management District
 Hills for Everyone
 Bev Perry
 Glenn Parker
Changes made to the Draft PEIR are identified here in strikeout text to indicate deletions and in underlined to signify additions.

3.2 Draft PEIR Revisions
Pages ES-10 through 30, Executive Summary, Table ES-2. Summary of Environmental Impacts and Mitigation Measures, Section 4.3, Biological Resources.

PEIR 3-2 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR Table ES-2. Summary of Environmental Impacts and Mitigation Measures Impact
Level of Significance
Before Mitigation Mitigation Measure
Level of Significance
After Mitigation
Section 4.3, Biological Resources
Threshold BIO-a: Have a
substantial adverse effect, either
directly or through habitat
modifications, on any species
identified as a candidate, sensitive,
or special status species in local or
regional plans, policies, or
regulations, or by the California
Department of Fish and Game or
U.S. Fish and Wildlife Service.

Focused General Plan Update
Potentially significant.

Brea Core Specific Plan
Potentially significant.

MM BIO-1 Pre-project/Activity Biological Resources
Survey/Habitat Assessment. For project sites within
vegetation communities and land covers other than
“Urban/Developed,” as shown on Figure 4.3-2,
Vegetation Communities and Land Cover Types, of
this Program Environmental Impact Report for the
Brea 2050: Focused General Plan Update and Brea
Core Specific Plan, the following requirements shall
apply.

Prior to any site disturbance, including grading,
vegetation clearing, or fuel modification and prior to
the issuance of any construction or clearing, grading,
or construction permits for individual development
projects that are not exempt from California
Environmental Quality Act (CEQA), and in conjunction
with any required CEQA review, the future project
applicant shall submit one or more documents to the
City of Planning Division for review and approval,
demonstrating that the project site does not contain
native vegetation, sensitive plants, or undisturbed
soils. Examples of acceptable documentation include,
but are not limited to, the following:
• Aerial photographs (historic and current)
showing grading, building footprints, paving, and
landscaped areas over time to support
ornamental status, existing landscape plans
• Photographic documentation consisting of
georeferenced or dated photographs.
• Landscaping plans or as-built drawings
demonstrating that vegetation was intentionally
planted as part of site development.

Less than significant.

PEIR 3-3 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR Table ES-2. Summary of Environmental Impacts and Mitigation Measures Impact
Level of Significance
Before Mitigation Mitigation Measure
Level of Significance
After Mitigation
• Field survey results prepared by a qualified
biologist confirming that existing plant species
are ornamental and non-native.

Within the future site-specific project areas exhibiting native vegetation, a site-specific biological resources survey shall be conducted during the project design
phase.

The biological resources survey and habitat
assessment shall be conducted by a qualified
biologist and shall include but not be limited to the
following:
• An analysis of available literature and biological
databases, such as the California Natural
Diversity Database, to determine sensitive
biological resources that have been reported
historically from the proposed project vicinity.
• A review of current land use and land ownership
within the project vicinity.
• An assessment and mapping of vegetation
communities present within the project vicinity. If
vegetation community mapping has not been
conducted on the site in the previous three
years, updated vegetation mapping shall be
conducted by a qualified biologist as part of the
project planning and environmental review
process. Vegetation communities shall be
mapped according to the Manual of California
Vegetation at the alliance level, and a crosswalk
table with Holland vegetation communities shall
be provided.
• A general assessment of the potential for
aquatic resources, including wetlands and
riparian habitats, to occur on site.

PEIR 3-4 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR Table ES-2. Summary of Environmental Impacts and Mitigation Measures Impact
Level of Significance
Before Mitigation Mitigation Measure
Level of Significance
After Mitigation
• An evaluation of potential local and regional
wildlife movement corridors and an assessment
of functions and value retention using online
wildlife agency habitat connectivity maps and
on-site evaluations.
• A focused habitat assessment to determine if the
Project area supports vegetation communities
that may provide habitat for plant or wildlife
species, to be conducted by a qualified biologist,
to determine the potential for sensitive plant or
wildlife species to occur in or adjacent to the
project area.
• If the project area supports sensitive vegetation
communities, the project proponent shall
implement the following weed control methods to
minimize the establishment and spread of nonnative and invasive weed species in the planning area during construction activities:
- Seeds and plant materials used for
revegetation shall be certified weed free.
- Straw materials, such as those used for
erosion control, shall be certified weed free.

The results of the biological survey shall be presented in a biological technical report. The survey report shall map and describe the location and extent of observed
sensitive resources, including sensitive vegetation
communities, regional wildlife movement corridors,
plant, and wildlife species within the areas of potential direct and indirect effects for each project area, direct and indirect impacts associated with construction and
operation of a project, and the need for further survey, monitoring, or mitigation, including measures pursuant
to mitigation measures MM BIO-2, MM BIO-3, MM
BIO-4, MM BIO-5, MM BIO-6, and MM BIO-7 of this
Program Environmental Impact Report. The biological
PEIR 3-5 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR Table ES-2. Summary of Environmental Impacts and Mitigation Measures Impact
Level of Significance
Before Mitigation Mitigation Measure
Level of Significance
After Mitigation
technical report shall be submitted to and approved by
the City of Brea prior to issuance of grading permits.

The report shall incorporate applicable mitigation
measures (MM BIO-2 through MM BIO-9) to reduce
any potentially significant impacts to biological
resources.

MM BIO-2 Focused Sensitive Plant Species Surveys. If
recommended by the Biological Resources
Survey/Habitat Assessment prepared pursuant to
Mitigation Measure MM BIO-1, prior to any site
disturbance, including grading, vegetation clearing, or fuel modification, focused surveys for future sitespecific development shall be conducted, as applicable, in suitable habitat, to determine
presence/absence of sensitive plant species on the
project site. Focused sensitive plant surveys shall be
conducted during the species’ specific blooming
periods to determine presence/absence. If sensitive
plant species are mapped within any proposed
construction, access, or staging areas, these species
shall be quantified and flagged, and these areas shall
be modified to avoid direct impacts to mapped
sensitive plant species. If significant impacts to these species are unavoidable, the impact on these species
shall be reduced to a less than significant level
through implementation of one or a combination of
the following actions, in accordance with a
Conceptual Restoration Plan or acquisition of
mitigation credits, reviewed and approved by the City
of Brea:
• Impacted plants shall be salvaged and relocated
to suitable habitat in an on-site restoration area,
if possible. If relocation to a restoration area is
not practical, the plants shall be relocated off-
PEIR 3-6 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR Table ES-2. Summary of Environmental Impacts and Mitigation Measures Impact
Level of Significance
Before Mitigation Mitigation Measure
Level of Significance
After Mitigation
site to an appropriate location determined by a
qualified biologist.
• Seeds from impacted plants shall be collected
for use at a local off-site location, as applicable.
• Off-site habitat that supports the species
impacted shall be enhanced or supplemented
with seed collected on site.
• Comparable habitat at an approved off-site
location shall be determined by a qualified
biologist and preserved for relocation,
enhancement, or transplant of the impacted
sensitive plants.

Final success criteria shall be determined based
on quality, quantity, and species of plant
impacted and in consultation with California
Department of Fish and Wildlife and U.S. Fish
and Wildlife Service depending on the status of
the species. The monitoring program will include
measures for adaptive management detailing
remedial actions if success criteria are not met in
PEIR 3-7 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR Table ES-2. Summary of Environmental Impacts and Mitigation Measures Impact
Level of Significance
Before Mitigation Mitigation Measure
Level of Significance
After Mitigation
the monitoring time frame. Remedial actions
may include, but are not limited to, supplemental
water, replanting, and herbivore
deterrents/protections.

MM BIO-3 Sensitive Vegetation Communities Impacts
Mitigation. If recommended by the Biological
Resources Survey/Habitat Assessment prepared
pursuant to Mitigation Measure MM BIO-1, prior to
any site disturbance, including grading, vegetation
clearing, or fuel modification, a biological survey shall be conducted to ground-truth and/or update
vegetation communities. Vegetation communities and
land cover types will be verified in the field during the required biological survey and will be mapped for
impact analysis. Any direct impacts to sensitive
vegetation communities require mitigation to comply
with California Department of Fish and Wildlife
authorizations, as well as the ratios defined in any
State or Federal permit(s) issued for the proposed
project
Potential direct permanent impacts to sensitive
vegetation communities resulting from project
implementation shall be mitigated prior to any
vegetation clearing or ground-disturbing activities
within the site-specific areas. Mitigation shall be
provided at a minimum of 1:1 and to the extent
feasible located in the same ecological region or
watershed, and functionally equivalent or superior in
habitat value. Mitigation shall be fulfilled through one of the following three options:
a. Vegetation communities and land cover types will
be verified in the field during the required
biological survey and will be mapped for impact
analysis;
PEIR 3-8 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR Table ES-2. Summary of Environmental Impacts and Mitigation Measures Impact
Level of Significance
Before Mitigation Mitigation Measure
Level of Significance
After Mitigation
ba. Compensatory mitigation for temporary impacts
to sensitive habitats shall be satisfied through the
acquisition of mitigation bank credits via a
resource agency-approved mitigation site within
the site’s specific watershed or by acquisition of
other off-site mitigation credits to be identified
and selected in coordination with CDFW. Prior to
implementation of project construction impacts
(e.g., vegetation clearing or ground-disturbing
activities) that would require compensatory
mitigation, documentation demonstrating the
availability of mitigation credits (i.e., credit ledger) at the approved mitigation site must be submitted
to the City of Brea for confirmation; or
cb. If credits are not available at a resource agencyapproved mitigation site within the site’s specific watershed or through other off-site mitigation
credits, implementation of habitat creation,
restoration, enhancement, or preservation shall
occur through a Habitat Mitigation and Monitoring
Plan developed by a qualified biologist. Under
this option, a Habitat Mitigation and Monitoring
Plan shall be provided and prepared to achieve
no net loss of the resource, be timed in relation to
project impacts, and comply with Federal and
State mitigation requirements.

When proposed mitigation involves habitat
enhancement, restoration or creation, the Habitat
Mitigation and Monitoring Plan shall include all of the following information:
• Conceptual planting plan including planting
zones, grading, and irrigation.
• Seed mix/planting palette.
• Planting specifications.

PEIR 3-9 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR Table ES-2. Summary of Environmental Impacts and Mitigation Measures Impact
Level of Significance
Before Mitigation Mitigation Measure
Level of Significance
After Mitigation
• Monitoring program prepared by a qualified
biologist including success criteria that ensure
no net loss of sensitive vegetation
communities. Final success criteria shall be
determined based on quality, quantity, and
type of habitat impacted and in consultation
with CDFW. The monitoring program shall
include measures for adaptive management
plan detailing remedial actions if success
criteria are not met in the monitoring time
frame. Remedial actions may include, but are
not limited to, supplemental water, replanting,
and herbivore deterrents/protections.

For mitigation that involves habitat acquisition, the
Habitat Mitigation and Monitoring Plan shall include
all the following:
• Location of proposed acquisition.
• Description of the biological resources to be
acquired, including support for the conclusion
that the acquired habitat mitigates for the
specific maintenance impact.
• Documentation that the mitigation area would
be adequately preserved and maintained in
perpetuity through conservation easements or
similar mechanisms.

PEIR 3-10 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR Table ES-2. Summary of Environmental Impacts and Mitigation Measures Impact
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Before Mitigation Mitigation Measure
Level of Significance
After Mitigation
• Documentation of the credits that are
associated with a mitigation bank, which has
been approved by the appropriate resource
agencies.
• Documentation in the form of a current
mitigation credit ledger.

MM BIO-4 Habitat Restoration for Temporary Impacts. If
recommended by the Biological Resources
Survey/Habitat Assessment prepared pursuant to
Mitigation Measure MM BIO-1, temporary impact
areas shall be restored to pre-construction
topographic contours and conditions, including the
revegetation of native plant communities, where
appropriate, following disturbance and prior to Project completion. Habitat restoration and erosion control
treatments shall be installed within these short-term
impact areas. A Revegetation Plan shall be prepared
and shall include site preparation specifications, a
plant palette, installation procedures, development of
reasonable success criteria, appropriate monitoring
and reporting protocols, implementation timelines,
and contingency measures and adaptive
management in the event of restoration failure. The
Revegetation Plan shall be submitted to and
approved by the City of Brea. Habitat revegetation
shall feature native species that are typical of the
area, and associated erosion control best
management practices shall include silt fence and
microplastic- and weed-free straw fiber rolls, where
appropriate. The revegetation areas shall be
monitored and maintained by a qualified biologist or
restoration specialist for 25 months to ensure
adequate establishment and sustainability of the
plantings/seedings.

PEIR 3-11 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR Table ES-2. Summary of Environmental Impacts and Mitigation Measures Impact
Level of Significance
Before Mitigation Mitigation Measure
Level of Significance
After Mitigation
Where a project activity involves potential disturbance of non-native invasive plant species (as identified by
the California Invasive Plant Council), these plants
shall be entirely removed immediately, where
feasible, and the removal shall be monitored by the
qualified monitoring biologist to ensure that dispersal of propagules (e.g., seeds and stems) are avoided or
minimized. Where removal of plant roots is not
feasible (e.g., where erosive flows are predicted),
aboveground plant material shall be fully removed
and monitored by the qualified monitoring biologist.

Where aboveground plant material cannot be
removed (e.g., due to limited access), herbicides shall be applied by a licensed pest control advisor, using
chemicals permitted as safe within aquatic
environments.

MM BIO-5 Qualified Monitoring Biologist. If recommended by the Biological Resources Survey/Habitat Assessment
prepared pursuant to Mitigation Measure MM BIO-1,
a qualified monitoring biologist shall be retained to
implement required monitoring. The qualified
monitoring biologist shall be responsible for the
following monitoring and reporting tasks.
a. Biological Construction Mitigation/Monitoring
Exhibit. Prior to the start of construction site
disturbance, including grading, vegetation
clearing, or fuel modification, within the future
site-specific project areas that have potential to
contain sensitive biological resources, the
qualified monitoring biologist shall submit a
Biological Construction Mitigation/Monitoring
Exhibit, which includes limits of work, proposed
monitoring schedule, bird, focused sensitive
species, or other wildlife surveys/survey
schedules (including general bird nesting and
PEIR 3-12 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR Table ES-2. Summary of Environmental Impacts and Mitigation Measures Impact
Level of Significance
Before Mitigation Mitigation Measure
Level of Significance
After Mitigation
U.S. Fish and Wildlife Service protocol), timing of
surveys, bird construction avoidance areas/noise
buffers/barriers, other impact avoidance areas,
and any subsequent requirements determined by
the qualified monitoring biologist. The Biological
Construction Mitigation/Monitoring Exhibit shall
include the construction site plan, written and
graphic depiction of the proposed project’s
biological mitigation/monitoring program, and a
schedule for construction activities. Where the
potential for impacts to biological resources is
limited (e.g., construction within a footprint that
consists entirely of previously developed or
disturbed lands), the Biological Construction
Mitigation/Monitoring Exhibit may be limited to a
pre- and post-maintenance verification inspection
by a qualified biologist. For highly sensitive
resource areas with documented sensitive
biological and aquatic resources present, full-time
biological monitors may be required, as
determined by a qualified biologist. The Biological
Construction Mitigation/Monitoring Exhibit shall be
approved by the City of Brea prior to the start of
construction.
b. Resource Marking/Protection. Prior to the start
of construction activities site disturbance within
the future site-specific project area, the qualified
monitoring biologist shall supervise the placement
of orange construction fencing or similar visible
marker, staking, or flagging along the limits of the
construction area adjacent to sensitive biological
habitats, as shown on the Biological Construction
Mitigation/Monitoring Exhibit to ensure crews
remain within the approved construction limits.

These demarcations shall not be required for
areas with existing barriers, such as chain-link
PEIR 3-13 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR Table ES-2. Summary of Environmental Impacts and Mitigation Measures Impact
Level of Significance
Before Mitigation Mitigation Measure
Level of Significance
After Mitigation
fencing, along the limits or facilities that are within or adjacent to developed and non-sensitive
habitat areas. This task shall include flagging
plant specimens and delineating buffers to protect
sensitive biological resources (e.g., habitats,
sensitive plant and wildlife species, including
nesting birds) prior to construction.
c. Cover Trenches. The qualified monitoring
biologist shall oversee the construction site so
that cover and escape routes for wildlife from
excavated areas shall be provided daily. All
trenches, holes, and excavations during
construction shall be covered at night as directed
by the monitoring biologist with plywood, metal
plates, or other means, and if plastic sheeting is
used, the edges must be covered with soils such
that small wildlife cannot access the excavated
hole. Soil piles shall be covered at night to
prevent wildlife from burrowing in. The edges of
the sheeting shall be weighed down by sandbags.

These areas may also be fenced to prevent
wildlife from gaining access. Exposed trenches,
holes, and excavations shall be inspected twice
daily (i.e., each morning and before sealing the
exposed area) by the qualified monitoring
biologist to monitor for wildlife entrapment.

If wildlife species are encountered within any
trenches or excavated areas, the qualified
monitoring biologist shall remove them, if
possible, or provide them with a means of escape
(e.g., a ramp or sloped surface at no greater than
PEIR 3-14 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR Table ES-2. Summary of Environmental Impacts and Mitigation Measures Impact
Level of Significance
Before Mitigation Mitigation Measure
Level of Significance
After Mitigation
a 30-degree angle) and allow the species to
disperse. In addition, the qualified monitoring
biologist shall provide training to construction
personnel to increase awareness of the possible
presence of wildlife beneath vehicles and
equipment and to use best judgment to avoid
killing or injuring wildlife (refer to Mitigation
Measure BIO-5e).
d. Structure and Tree Clearance. Prior to the
issuance of any permit to allow for the removal or
demolition of trees and existing structures within
the survey area (particularly any ornamental trees
and existing buildings in the developed land
areas), the qualified monitoring biologist shall
conduct clearance surveys to flush out any
wildlife species nesting, roosting, or otherwise
occupying the trees or structures. If wildlife
species are encountered within any of the trees or
structures (outside the general bird nesting
season), the qualified monitoring biologist shall
remove them, if possible, or provide them with a
means of escape and allow the species to
disperse. If tree-roosting bats are suspected, slow
removal by gently pushing the tree over with
heavy equipment is required.
e. Pre-Construction Meeting/Education. Prior to
the start of any construction activity site
disturbance where the site plan for the
construction area indicates that significant
impacts to biological resources may occur, as
determined by a qualified biologist, a preconstruction meeting shall be held on site with the following in attendance: City of Brea
representatives (project planner and building
inspector), the construction contractor (if
PEIR 3-15 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR Table ES-2. Summary of Environmental Impacts and Mitigation Measures Impact
Level of Significance
Before Mitigation Mitigation Measure
Level of Significance
After Mitigation
applicable), and the qualified monitoring biologist.

At this meeting, the qualified monitoring biologist
shall identify and discuss the construction
protocols that apply to the proposed activities and
the sensitive nature of the adjacent habitat with
appropriate project personnel.

At the pre-construction meeting, the qualified
monitoring biologist shall submit to the City of
Brea representatives and construction contractor
a copy of the Biological Construction
Mitigation/Monitoring Exhibit that identifies areas
to be protected, fenced, and monitored. This data
shall include all buffer limits, if applicable.

Prior to the start of construction activities, the
qualified monitoring biologist shall meet with the
construction contractor and crew and conduct an
on-site educational session regarding the need to
avoid impacts outside the approved construction
footprint and to protect sensitive plants and
wildlife that may occur at the specific facility. This
may include but not be limited to explanations of
the bird and wetland buffers, the flag system for
removal of invasive species or retention of
sensitive plants, and clarification of acceptable
access routes/methods and staging areas
f. Biological Monitoring and Reporting. The
qualified monitoring biologist with stop work
authority shall inspect/monitor the project
construction area in accordance with the
approved Biological Construction
Mitigation/Monitoring Exhibit. This may be limited
to pre- and post-maintenance inspections, weekly
visits, or full-time monitoring, as determined by
the qualified monitoring biologist and the City of
Brea.

The qualified monitoring biologist shall document
PEIR 3-16 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR Table ES-2. Summary of Environmental Impacts and Mitigation Measures Impact
Level of Significance
Before Mitigation Mitigation Measure
Level of Significance
After Mitigation
monitoring events via a Consultant Site Visit
Record. This record shall be sent to the City of
Brea project manager each month. However, if
weekly reports are submitted as part of a
separate agency permit requirement, these
reports may be forwarded to the City of Brea in
place of Consultant Site Visit Record submittals.

If no deviations from the construction site plan
occur during maintenance, no additional
documentation is required. However, if deviations
from the site plan do occur, such as unanticipated
impacts to sensitive vegetation communities or
unanticipated discharge of pollutants, a final
monitoring report shall be prepared within three
months following the completion of mitigation
monitoring detailing maintenance and monitoring
that occurred, and any remedial or compensatory
measures taken.

MM BIO-6 Focused Sensitive Wildlife Species Surveys. If recommended by the Biological Resources
Survey/Habitat Assessment prepared pursuant to
Mitigation Measure MM BIO-1, prior to any site
disturbance, including grading, vegetation clearing, or fuel modification, focused surveys for future sitespecific development shall be conducted, as applicable, in suitable habitat, to determine
presence/absence of sensitive wildlife species within
the proposed survey area. If sensitive wildlife species or their habitat are present or potentially present
based on biological surveys, the following measures
shall be implemented.
a. Crotch’s bumble bee. Habitat assessment
surveys for California Endangered Species Act
(CESA) candidate bumble bee species, with a
focus on Crotch’s bumble bee, followed the
PEIR 3-17 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR Table ES-2. Summary of Environmental Impacts and Mitigation Measures Impact
Level of Significance
Before Mitigation Mitigation Measure
Level of Significance
After Mitigation
California Department of Fish and Wildlife
(CDFW) methodology from the Survey
Considerations for CESA Candidate Bumble Bee
Species dated June 6, 2023 (CDFW Survey
Considerations) (CDFW 2023). If no Crotch’s
bumble bees are found during the focused
surveys, but the habitat assessment identified
suitable nesting, foraging, or overwintering habitat
on the project site, recommendations outlined in
the CDFW Survey Considerations will be
followed, including recommendations that a
biological monitor be on site during vegetation or
ground-disturbing activities that take place during
any of the Queen and Gyne Flight Period and
Colony Active Period. If Crotch’s bumble bees are
observed, project proponents may propose sitespecific measures to avoid take, or consult with CDFW to obtain an incidental take permit if take
of CESA-protected bumble bees may occur
during project activities.
b. Western spadefoot and Monarch butterfly. If
western spadefoot or monarch butterfly become
listed prior to implementation of future sitespecific development projects, focused surveys and consultation with the U.S. Fish and Wildlife
Service (USFWS) would be necessary.
c. Western burrowing owl. If suitable habitat for
western burrowing owl is present (annual
grassland and agricultural land), a qualified
biologist shall conduct focused surveys of the site
and a 500-foot buffer, as access allows. If no
burrowing owls are identified, no further
measures are necessary. If burrowing owls are
detected, active burrows shall be avoided using
buffers outlined in the Staff Report on Burrowing
PEIR 3-18 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR Table ES-2. Summary of Environmental Impacts and Mitigation Measures Impact
Level of Significance
Before Mitigation Mitigation Measure
Level of Significance
After Mitigation
Owl Mitigation, dated March 7, 2012, issued by
CDFW. If avoidance is not possible, the qualified
biologist shall consult with CDFW. No direct
disturbance to burrowing owls or their occupied
habitat shall occur without appropriate
authorization from CDFW.
d. Least Bell’s vireo. If suitable habitat for least
Bell’s vireo is present and clearing, grubbing,
grading, or other construction activities may occur
between March 15 and September 15, the
breeding season of the least Bell’s vireo, a
qualified biologist shall conduct focused surveys
for the presence of the least Bell’s vireo of the site
and areas of potentially suitable habitat within 300
feet or that would be subject to construction noise
levels exceeding 60 A-weighted decibels or to the
ambient noise level if it already exceeds 60 Aweighted decibel hourly average. If present, measures to minimize noise impacts (such as
temporary noise walls/berms) may be required.

Noise levels from construction activities during
the avian breeding season should not exceed 60
decibels (dBA Leq; or the ambient noise level if
they already exceed 60 dBA Leq) at the edge of
the occupied habitat. If complete avoidance is not
feasible, the qualified biologist shall consult with
USFWS. No direct harm to the species shall be
allowed without appropriate authorization from
USFWS.
e. Southwestern willow flycatcher. If suitable
habitat for southwestern willow flycatcher is
present and clearing, grubbing, grading, or other
construction activities may occur between April 15
through September 15, the breeding season of
the southwestern willow flycatcher, a qualified
PEIR 3-19 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR Table ES-2. Summary of Environmental Impacts and Mitigation Measures Impact
Level of Significance
Before Mitigation Mitigation Measure
Level of Significance
After Mitigation
biologist shall conduct focused surveys for the
presence of the southwestern willow flycatcher of
the site and areas of potentially suitable habitat
within 500 feet. If the species is determined to be
present, consultation per Endangered Species
Act with USFWS would be necessary and no
activities would occur until authorized by USFWS.

No direct harm to the species shall be allowed
without appropriate authorization from USFWS.
f. Sensitive Bat Species. If suitable roosting
habitat (e.g., riparian habitat, snags, wooden
buildings, bridges, etc.) for sensitive bat species
is present, a qualified biologist shall conduct
subsequent focused surveys no less than 14 days
prior to removal or disturbance of vegetation or
buildings. The survey shall consist of visual
and/or acoustic methods as deemed appropriate
by the qualified biologist. If no bats are detected,
no further measures are necessary. If bat species
are detected during surveys, a site-specific plan
shall be developed by the qualified biologist. The
plan may include, as determined by the qualified
biologist, delaying removal of roost habitat until
after the maternity roosting period and exclusion
of bats from roosting habitat prior to removal of
habitat. The qualified biologist shall consult with
CDFW prior to implementing any exclusion
activities.
g. Southwestern Pond Turtle. If suitable habitat for
southwestern pond turtle is present pursuant to
Mitigation Measure MM BIO-1, site-specific
measures shall be implemented to avoid impacts,
as developed in consultation with a qualified
biologist. Measures shall focus on avoiding
habitat destruction, protecting individuals during
PEIR 3-20 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR Table ES-2. Summary of Environmental Impacts and Mitigation Measures Impact
Level of Significance
Before Mitigation Mitigation Measure
Level of Significance
After Mitigation
construction, and managing habitat to increase
survival though preconstruction surveys,
exclusion fencing, biological monitoring, and
habitat restoration. Depending on the measures
selected, plan approval and conference with the
U.S. Fish and Wildlife Service may be required if
the action is likely to jeopardize the species’
existence during construction activities.
h. Mountain Lion. If suitable habitat for mountain
lion is present pursuant to Mitigation Measure MM
BIO-1, site-specific measures shall be
implemented to minimize habitat loss and
fragmentation to improve habitat connectivity and
avoid take. These measures shall be developed
in consultation with a qualified biologist and may
include measures described in the City of Brea
General Plan Community Resources Element
Policy CR-3e. If presence is established,
Resource Agency consultation shall be required
to obtain an incidental take permit.
gi. Other Sensitive Species. Prior to any demolition
work, construction or grading activities within the
future site-specific project areas, pre-construction
surveys for other sensitive wildlife species, such
as reptiles, may be required to determine
presence/absence of sensitive wildlife species
within the proposed survey area.

MM BIO-7 Focused Nesting Bird Surveys. Project activities that may directly (e.g., vegetation removal, clearing
and grubbing, building demolition) or indirectly affect (noise, light, or ground vibration) nesting raptors and other protected bird species shall be timed to avoid
the nesting season (January 15 through September
15). If project activities occur within the nesting
season, prior to any site disturbance, including
PEIR 3-21 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR Table ES-2. Summary of Environmental Impacts and Mitigation Measures Impact
Level of Significance
Before Mitigation Mitigation Measure
Level of Significance
After Mitigation
grading, vegetation clearing, or fuel modification, the qualified monitoring biologist shall conduct focused
surveys for birds in suitable habitat to determine
presence/absence. Surveys shall occur within seven
(7) days prior to any construction or grading activities or site disturbance within the future site-specific
project areas. Focused sensitive bird surveys shall be
conducted during the species’ specific nesting
seasons to determine presence/absence within the
development footprint plus a buffer, if recommended
by the qualified monitoring biologist (refer to
mitigation measure MM BIO-5). The survey report
shall map and describe the location and extent of
observed sensitive bird species that would be
impacted within the areas of potential effect for each
project area. If no nesting birds are documented
within the individual activity area, construction shall be allowed to proceed. If nesting birds cannot be
completely avoided, a no-disturbance buffer shall be
established around the active nest, the size of which
will be determined by the qualified monitoring
biologist based on species of bird and specific
construction activities to take place. The size of the
buffer can be reduced in consultation with California
Department of Fish and Wildlife. Any work within the
buffer shall be avoided until the nest is inactive, as
determined by the qualified monitoring biologist.

Page ES-35 through 38. Table ES-2. Summary of Environmental Impacts and Mitigation Measures Section 4.7, Greenhouse Gas Emissions
Threshold GHG-a: Generate
greenhouse gas emissions, either
directly or indirectly, that may have
Focused General Plan Update
Potentially significant.

MM GHG-1GHG Reduction Plan for Future Development. As part of the development review process for individual
development projects that are not exempt from CEQA,
Significant and
unavoidable.

PEIR 3-22 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR a significant impact on the
environment.

Brea Core Specific Plan
Potentially significant (Cumulative
Only)
the Brea Community Development Department shall
require a greenhouse gas (GHG) emissions technical
analysis prepared by a qualified environmental
professional for all projects exceeding 190 singlefamily dwelling units, 360 multi-family dwelling units, or 56,000 square feet of non-residential square footage.[1] If the GHG technical analysis shows that constructionor operational-related GHG emissions project will meet or exceed the South Coast Air Quality Management
District Interim California Environmental Quality Act
GHG Tier 3 Significance Threshold of 3,000 metric ton
carbon dioxide equivalent (MT CO2e) and per capita
threshold of 1.5 MT CO2e per service population, a
GHG reduction plan shall be prepared to reduce GHG
emissions to below the applicable threshold. The GHG
reduction plan shall include potential mitigation
measures from the California Air Pollution Control
Officers Association Handbook for Analyzing
Greenhouse Gas Emission Reductions, Assessing
Climate Vulnerabilities, and Advancing Health and
Equity. Mitigation measures shall be selected based on
the nature of the project and characteristics of the
GHG emission source(s). Potential measures include,
but are not limited to the following:
• Transportation and Land Use: Mobile GHG
emissions can be mitigated through project site
location and design, including:
− Prioritizing infill development with high
destination accessibility
− Improving destination accessibility
− Orient project toward transit, bicycle, or
pedestrian facility
− Locate project near bike path/bike lane
− Provide bike parking, especially near transit
− Provide traffic calming measures to encourage
pedestrian/bicycle activity
− Create urban non-motorized zones
− Construct or improve bicycle and pedestrian
facilities
PEIR 3-23 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR − Provide first and last mile services to connect
project to existing transit or community
services, such as a shuttle program
− Implement preferential parking permit program
for ride-share participants
− Provide electric vehicle infrastructure beyond
California Green Building Standards Code
(CALGreen) requirements
− Provide end-of-trip bicycle facilities
− Implement a school pool program
− Implement telecommute and/or alternative
work schedule program
− Implement commute trip reduction programs
− Implement paid parking
− Replace traffic controls with roundabout where
appropriate
− Incorporate park-and-ride lots
− Designate zero emissions delivery zones
− Electrify loading docks
− Install hydrogen fueling infrastructure for
projects that include a fleet fueling component
• Green Building Measures: Building design
beyond CALGreen requirements can reduce
GHG emissions from energy and water use.

Some strategies include:
− Install whole house fans.
− Install energy-saving lighting, heating, cooling
systems, and appliances.
− Design buildings with passive environmental
controls to maximize natural heating and
cooling.
− Install electric vehicle charging stations to
support clean transportation.
− Provide on-site renewable energy generation
systems and storage
− Install electric heat pumps
− Implement yard equipment exchange program
− Provide electric yard equipment compatibility,
such as outdoor outlets
PEIR 3-24 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR − Install green or cool roofs
− Provide high efficiency outdoor lighting
− Install cool pavement
− Eliminate the use of natural gas
− Use reclaimed non-potable water for
landscaping
− Use gray water
− Require low-flow fixtures
− Design water efficient landscaping
− Participate in waste diversion programs
• Project Construction: GHG emissions from
construction can be reduced through sustainable
practices such as the following:
− Recycle demolished construction material
beyond CALGreen requirements.
− Source wood materials from urban wood
reuse program
− Use local and sustainable building materials
− Use local construction contractors
− Use cleaner-fuel equipment
• Natural/Working Lands: Support carbon
sequestration, reduce urban heat island impact,
and improve access to local food sources
through practices such as the following:
− Make public space available for establishment
of a local farmers market
− Establish areas available for community
gardens
− Expand urban tree planting
− Create new vegetated spaces
− Install permeable surfaces
PEIR 3-25 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR [1] Consistent with SCAQMD methodology for the screening levels in Table 3-3 of the Interim CEQA GHG Significance Threshold Draft Guidance Document (SCAQMD 2008), 190 single-family residential units, 360 multi-family residential units, or 56,000 SF of retail development would generate approximately 3,000 MT CO2e annually, assuming default CalEEMod assumptions for Year 2025. See Appendix D1 for calculation details.

PEIR 3-26 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR

Page 1 ends

Table 1-1. NOP Comments Summary
Commenting
Agency Date Comment Summary
Responses/ PEIR Sections
Where Issues Addressed
California
Department of
Transportation
(Caltrans)
September 22,
2025
• Caltrans recognizes there is a strong link
between transportation and land use.

Development can have a significant impact on
traffic and congestion on State transportation
facilities. In particular, the pattern of land use
can affect both local vehicle miles traveled and
the number of trips. Caltrans supports
collaboration with local agencies to work
towards a safe, functional, interconnected, multimodal transportation network integrated through applicable “smart growth” type land use planning
and policies.

Comment acknowledged and
no response is needed.
• Encourage the use of transit among future
residents, visitors, and workers of the proposed
areas of developments. Increasing multimodal
transportation will lead to a reduction to
congestion, Vehicle Miles Traveled and improve
air quality.

Comment acknowledged and
no response is needed.
• Caltrans supports the integration of the 2020
Core Active Transportation Plan into the new
BCSP and encourages objectives of infill, mixeduse, and live/work development.

Comment acknowledged and
no response is needed.
• Caltrans supports the City’s plan to implement
high-quality Complete Streets that are safe and
accessible for people of all ages and abilities.

Caltrans also encourages the City to use safety
measures such as physically separated
sidewalks and bike lanes, pedestrian-oriented
LED lighting, high-visibility continental crosswalk
striping, raised crosswalks, ADA curb ramps,
refuge islands, wayfinding signage, and safe
connections to existing and proposed bicycle
facilities. These improvements will also promote
regional connectivity, improve air quality, reduce
congestion, promote improved first-/last-mile
connections, and increase safety for all modes
of transportation.

See Section 4.13,
Transportation.
• During any future construction, please ensure
that appropriate detours and safety measures
are in place that prioritize the mobility, access,
and safety of bicyclists, pedestrians, and transit
users.

See Section 4.13,
Transportation.
• Future projects should not present adverse
impacts to the overall transportation system
including traffic circulation and the local State.

Highway Systems (SHS). If future developments
disrupt or impede traffic circulation or the local
Comment acknowledged. The
Proposed Project involves
policy and planning
documents and does not
PEIR 3-27 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR Table 1-1. NOP Comments Summary
Commenting
Agency Date Comment Summary
Responses/ PEIR Sections
Where Issues Addressed
State Highway System, Caltrans will request a
Traffic Impact Analysis (TIA) of these assets.
involve development projects
at this time.
• When analyzing future proposed projects,
please note potential short-and long-term traffic
impacts with respect to regional vehicle miles
traveled (VMT’s), please use the Governor’s
Office of Planning and Research Guidance to
identify VMT related impacts.

See Section 4.13,
Transportation.
• Coordination with Caltrans is needed if future
impact analysis leads to findings of significance
on State facilities,
Comment acknowledged and
no response is needed.
• Any work performed within Caltrans right-of-way
(R/W) will require discretionary review and
approval by Caltrans and an encroachment
permit will be required for any work within the
Caltrans R/W prior to construction.

Comment acknowledged and
no response is needed.
• Project plans and traffic control plans submitted
to Caltrans must be stamped and signed by a
licensed engineer. Final Environmental
Clearance Documentation, and other relevant
design documentation will need to be provided
when submitting the application to Caltrans.

The Proposed Project
involves policy and planning
documents and does not
involve development projects
at this time.
• Requests to submit all applications and
associated documents/plans via email.

No response is needed.

Native American
Heritage
Commission
August 26,
2025.
• Protocol for evaluation of cultural and historic
resources.
• Tribal consultation requirements under
Assembly Bill 52 and Senate Bill 18.

Section 4.4 Cultural
Resources, and Section 4.14
Tribal Cultural Resources
California
Department of
Forestry & Fire
Protection (Cal
FIRE)
September 8,
2025.
• Requests a meeting with the City to discuss the
CAL FIRE Land Use Planning Program and the
related changes to Government Code Section
65302 as it pertains to the Safety Element and
the Local Hazard Mitigation Plan.

The comment is specific to
the Safety Element being
updated as part of the
Focused General Plan Update
and the related Local Hazard
Mitigation Plan. No comments
related to the scope of the
PEIR were included. No
response is needed.

California
Geological
Survey (CGS)
September 23,
2025.
• Acknowledges that the CGS received the Notice
of Preparation.

No response is needed.
• Advised that CGS has prepared Earthquake
Zone of Required Investigation Maps for the
Project area and the PEIR should address these
zones with respect to the Proposed Project.

See Section 5.2, Geology and
Soils, in Chapter 5, Effects
Found Not to be Significant.
• Asks to refer to CGS maps and reports related
to mineral land classifications as necessary.

See Section 5.3, Mineral
Resources, in Chapter 5,
Effects Found Not to be
Significant.

PEIR 3-28 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR Table 1-1. NOP Comments Summary
Commenting
Agency Date Comment Summary
Responses/ PEIR Sections
Where Issues Addressed
South Coast Air
Quality
Management
District
September 24,
2025
• Recommends that the lead agency reply on the
guidance provided in the South Coast AQMD’s
CEQA Air Quality Handbook and website1 when
preparing the air quality and greenhouse gas
analyses. It also recommends that the California
Air Pollution Control Officers Association’s
California Emissions Estimator Model
(CalEEMod) software is used to quantify
emissions of air pollutants from typical land use
development project.

See Section 4.2, Air Quality.
• Recommends that analyses rely on South Coast
AQMD’s adopted thresholds for determining
whether the Proposed Project’s air quality and
greenhouse gas impacts are significant.

See Section 4.2, Air Quality.
• Requests to identify any potential adverse air
quality and greenhouse gas impacts that could
occur from all phases of the Proposed Project
and all air pollutant sources related to the
Proposed Project, including construction,
operation, and overlapping construction and
operational activities.

See Section 4.2, Air Quality.
• Indicates that the use of new stationary and
portable sources will require air permits from
South Coast AQMD, and also provides
additional provisions related to air permits South
Coast AQMD’s role as a responsible agency.

No specific development
projects are being proposed
as part of the Proposed
Project, and no air permits are
necessary at this
programmatic stage.
• Recommends that the California Air Resources
Board (CARB) Air Quality and Land Use
Handbook: A Community Health Perspective,
Strategy to Reduce Air Pollution Exposure Near
High-Volume Roadways, and the South Coast
AQMD Guidance Document for Addressing Air
Quality Issues in General Plans and Local
Planning, be consulted and applied to minimize
air quality impacts.

EIR does not include any
specific references to the
South Coast AQMD Guidance
Document for Addressing Air
Quality Issues in General
Plans and Local Planning.

This is a guidance document
for preparing the plan, not
evaluating impacts in the EIR.
• Indicates that in the event that the Proposed
Project results in significant adverse air quality
impacts, all feasible mitigation measures beyond
what is required by law need to be utilized to
minimize these impacts. Any impacts resulting
from mitigation measures must also be
analyzed.

See Section 4.2, Air Quality.
• Indicates that Many strategies are available to
reduce health risk exposures, including, but not
limited to, building filtration systems with MERV
13 or better, or in some cases, MERV 15 or
better is recommended; building design,
See Section 4.2, Air Quality.

Note that Significant impacts
to sensitive receptors related
to health risks were not
identified, therefore, the
PEIR 3-29 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR Table 1-1. NOP Comments Summary
Commenting
Agency Date Comment Summary
Responses/ PEIR Sections
Where Issues Addressed
orientation, location; vegetation barriers or
landscaping screening, etc
suggested filtration measure
was not included.

Hills for Everyone September 24,
2025
• Asserts that the growth proposed under the
Proposed Project should be focused in the
already-developed areas of the City and the
environmental impacts of the growth must be
disclosed now.
• Indicates that many projects that conform with
the General Plan land use designations and
associated zoning will be exempt from further
CEQA review under Assembly Bill 130,
therefore, the General Plan EIR’s analysis
environmental impacts of the development
allowed under the GPU and BCSP.
• Indicates that the EIR must ensure that the
CEQA analysis and the Project are aligned and
that the Project Description is stable and
comprehensive to allow a full understanding of
the Project’s anticipated impacts for both the
GPU and BCSP. It further states that Project
Description and accompanying land use maps
and tables should clearly indicate the changes
between current and proposed land use
designations and quantify what those changes
mean in terms of development potential and
provide a clear list (including Assessor Parcel
Numbers and addresses) of all parcels whose
General Plan land use designations are
proposed to change.

See Chapter 2, Project
Description. Also, it should be
noted that the figures in
Chapter 2 of the Draft PEIR
are intended to provide a
generalized, citywide
depiction of existing zoning
and proposed land use
designations for the City and
its Sphere of Influence. As
program-level exhibits, they
are not intended to depict
parcel-level boundaries,
ownership, or detailed sitespecific conditions. CEQA
Guidelines Section 15168,
Program EIR, recognizes that
a program EIR appropriately
evaluates broad policy-level
actions and need not include
the level of detail required for
site-specific analysis.

Similarly, CEQA Guidelines
Section 15146 provides that
the level of detail in an EIR
should correspond to the level
of specificity of the underlying
plan, with later environmental
review addressing more
detailed, site-specific
information. Consistent with
these provisions,
individualized parcel
information, including APNs
are not separately delineated
PEIR 3-30 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR Table 1-1. NOP Comments Summary
Commenting
Agency Date Comment Summary
Responses/ PEIR Sections
Where Issues Addressed
at the scale presented in
Chapter 2 figures. More
detailed, parcel-specific
zoning information is available
through the City’s official
mapping resources on its
website.
• Indicates that an EIR must provide enough
analysis and detail about environmental impacts
and make a good faith effort at full disclosure of
environmental impacts, including cumulative
impacts.

The Chapters 4 and 5 of the
Draft PEIR make a good faith
effort at full disclosure of
environmental impacts,
including cumulative impacts
corresponding to the level of
specificity required for a
programmatic EIR pursuant to
CEQA Guidelines Section
15146 and 15168.
• Indicates that an EIR analyze a range of
reasonable alternatives.

See Chapter 7, Project
Alternatives.
• Provides description of the 2024 Community
Vision Plan, including key guiding principles
pertaining to resiliency for future generations
and connection to nature. The comment
suggests that the GPU is the City’s opportunity
to adopt policies that align with these guiding
principles and provides a list of potential policies
to be reconsidered in the GPU relating to the
following:
 Limit Hillside Development Within the
Brea Sphere of Influence
 Establish Fire-Safe and WildlifeProtective Standards for Development on the City’s Urban Edge
 Update the General Plan to Comply with
Assembly Bill 1889 and Senate Bill 1425.
 Support Urban Greening and Climate
Resilience.

Comments pertain to policy
planning for the Brea 2050,
and not to the scope of the
Draft PEIR. Under CEQA, the
primary purpose of an EIR is
to identify and analyze the
potential physical
environmental effects of the
Proposed Project. The
selection and adoption of
specific General Plan policies
are matters of policy
consideration by the City’s
decision makers, and outside
the purview of the scope of
this PEIR.

Bev Perry September 24,
2025
• States that the commenter would like to see the
PEIR focus on the lack of transportation options
for areas east of SR-57. The comment further
states that the Orange County Transportation
Authority has very little bus service for this area
and the City should think ahead and work with
OCTA on the new routes and stops in this area.

The comment also wants to make sure that bike
lanes are included throughout the City.

See Section 4.13,
Transportation, and Appendix
H, Section 4.13 properly
disclose the existing transit
options and bike lane in areas
east of SR-57. These
comments pertain to policy
planning for the Brea 2050
and not to the scope of the
Draft PEIR. Brea 2050
PEIR 3-31 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR Table 1-1. NOP Comments Summary
Commenting
Agency Date Comment Summary
Responses/ PEIR Sections
Where Issues Addressed
includes Mobility Element,
which addresses policies and
actions that are consistent
with applicable federal, state,
and local roadway design and
safety standards. Under
CEQA, the primary purpose of
an EIR is to identify and
analyze the potential physical
environmental effects of the
Proposed Project. The
selection and adoption of
specific General Plan policies
are matters of policy
consideration by the City’s
decision makers, and outside
the purview of the scope of
this PEIR.
• States that impacts of new development in the
GPU and BCSP will have city-wide implications
for transportation, therefore the City should
evaluate alternatives and mitigations to lessen
or avoid those transportation impacts.

See Section 4.13,
Transportation.

Glen Parker September 24,
2025
• States that the commenter fully endorse the
comments made by Bev Perry and also states
that the commenter would like to see bike lanes
be upgraded for safety.

These comments pertain to
policy planning for the Brea
2050 and not to the scope of
the Draft PEIR. Brea 2050
includes Mobility Element,
which addresses policies and
actions that are consistent
with applicable federal, state,
and local roadway design and
safety standards. Under
CEQA, the primary purpose of
an EIR is to identify and
analyze the potential physical
environmental effects of the
Proposed Project. The
selection and adoption of
specific General Plan policies
are matters of policy
consideration by the City’s
decision makers, and outside
the purview of the scope of
this PEIR.

PEIR 3-32 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR

Page 2 ends

Uses.

The City’s SOI encompasses territory outside the City’s incorporated boundaries that represents the probable future area for City services and potential annexation. Much of the SOI north of the City is sparsely developed and includes hillside residential areas, including current and past oil and gas fields, public facilities (such as the Olinda Alpha Landfill), parks and recreation areas, open space, and vacant parcels. These areas border the County of Los Angeles.

Page 2 ends

Plan.

Land Use: Establishes land uses for the BCSP. Mixed Use 18 absorbs the former Mixed Use II designation, and would allow mixed use up to 18 dwelling units per acre. Mixed Use 50 would allow up to 50 dwelling units per acre, which is the result of consolidating Mixed Use I and Mixed use II.

Page 3 ends

Services and Utilities.
• Drainage System – City of Brea and Orange County Flood Control District

Page 4 ends

The Focused GPU’s Community Resources Element Goal CR-4, Scenic Resources, seeks to create aA community where visual resources reflect Brea’s natural beauty and help guide responsible development, and Community Development Goal CD-4, Hillside Development, seeks to mMinimize the extent of development in the hillsides and mitigate any adverse consequences associated with urbanization, and these goals, along with their associated policies and actions, would support protecting scenic resources in Brea while accommodating growth in a controlled manner. Specific policies and actions are included in Appendix C, Brea 2050 General Plan: Goals, Policies, and Actions, of this PEIR.

Page 4 ends

Further, the Focused GPU’s Community Resources Element Goal CR-4, Scenic Resources, seeks to create aA community where visual resources reflect Brea’s natural beauty and help guide responsible development, and Community Development Goal CD-4, Hillside Development, seeks to mMinimize the extent of development in the hillsides and mitigate any adverse consequences associated with urbanization, and these goals, along with their associated policies and actions, would support protecting scenic resources in Brea while accommodating growth in a controlled manner. Specific policies and actions are included in Appendix C, Brea 2050 General Plan: Goals, Policies, and Actions, of this PEIR. Impacts would be less than significant.

PEIR 3-33 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR

Page 4 ends

Relevant supporting goals, policies, and actions related to visual character or quality from the Focused GPU are included in the Community Development Element, Goal CD-2 Community Design and Placemaking, Goal CD-3, Neighborhood Preservation, and Goal CD-4, Hillside Development. Goal CD-2 seeks to create a visually appealing and cohesive community that emphasizes high-quality design, celebrates Brea’s distinct character, and fosters a strong sense of place through well-designed spaces, architecture, and streetscapes; Goal CD-3 seeks to preserve the safety and tranquility of established residential neighborhoods that contribute to the quality of life in Brea, while fostering opportunities for social interaction and enhancing community connections; and Goal CD-4 seeks to minimize the extent of development in the hillsides and mitigate any adverse consequences associated with urbanization. Specific policies and actions are included in Appendix C, Brea 2025 General Plan: Goals, Policies, and Actions, of this PEIR.

Page 4 ends

Policy CR-5.9 that aims to protect local character, enhance visual safety, and mitigate the harmful effects of light intrusion and pollution, below, from the Focused GPU’s Community Resources Element is relevant in reducing light impacts. See Appendix C, Brea 2050 General Plan: Goals, Policies, and Actions, of this PEIR for the policy language.:
• Policy CR-5.9 Outdoor Lighting. Mitigate the harmful effects of light pollution.

Page 4 ends

Source: Refer to Appendix D1 for model output.

Page 4 ends

Source: Refer to Appendix D1 for model output. Mobile emissions are 23 percent of mobile emissions in Table 4.2-4.

Page 4 ends

AQ-b.

Detailed assumptions and modeling datasheets are provided in Appendix D1. Estimated maximum daily construction emissions are provided in Table 4.2-7, Estimated Focused GPU Maximum Daily Construction Emissions (pounds/day).

Page 4 ends

4.2-7.

Sources: Refer to Appendix D1 for model output.

PEIR 3-34 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR

Page 4 ends

4.2-8.

Source: Refer to Appendix D1 for model output.

Page 4 ends

4.2-9.

Source: Refer to Appendix D1 for model output.

Page 4 ends

4.2-9.

Source: Refer to Appendix D1 for model output.

Page 4 ends

Table 4.3-3. Sensitive Wildlife Species Documented in the Proposed Project Area Species Status
Scientific Name Common Name Federal/State
Invertebrates
Bombus crotchii Crotch’s bumble bee None/CCE
Danaus plexippus Monarch butterfly FPT/None
Reptiles
Actinemys pallida Southwestern pond turtle FPT/SSC
Crotalus ruber Red-diamond rattlesnake None/SSC
Phrynosoma blainvillii Blainville’s (coast) horned lizard None/SSC Salvadora hexalepis virgultea Coast patch-nosed snake None/SSC Spea hammondii Western spadefoot toad FPT/SSC
Birds
Aimophila ruficeps canescens Southern California rufous-crowned sparrow
None/WL
Ammodramus savannarum Grasshopper sparrow None/SSC
Aquila chrysaetos Golden Eagle BGEPA/CFP, WL
Athene cunicularia Western burrowing owl None/CCE, SSC
Campylorhynchus brunneicapillus
sandiegensis Coastal cactus wren BCC/SSC
Empidonax traillii extimus Southwestern willow flycatcher FE/SE Eremophila alpestris actia California horned lark None/WL Icteria virens Yellow-breasted chat None/SSC
Polioptila californica californica Coastal California gnatcatcher FT/SSC Setophaga petechia Yellow warbler None/SSC
Vireo bellii pusillus Least Bell’s vireo FE/CE
PEIR 3-35 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR Table 4.3-3. Sensitive Wildlife Species Documented in the Proposed Project Area Species Status
Scientific Name Common Name Federal/State
Mammals
Eumops perotis californicus Western mastiff bat None/SSC Nyctinomops femorosaccus Pocketed free-tailed bat None/SSC Puma concolor1 mountain lion -central coast & southern
California None/CT
Sources: CDFW 2025a, 2025b; USFWS 2025b.

Notes: BCC = Federal bird of conservation concern; BGEPA = Federal bald and golden eagle protection act; CCE = California candidate endangered; CE = California endangered; CFP= California fully protected; CT = California Endangered; FE = Federally endangered; FPT = Federally proposed threatened; FT= Federally threatened; SSC = CDFW species of special concern; WL = CDFW watch list.
1 Puma Concolor was officially added to the list on February 12, 2026.

Page 4 ends

Mammals
Pocketed Free-Tailed Bat (Nyctinomops femorosaccus)
Pocketed free-tailed bat (Nyctinomops femorosaccus) is a California Species of Special Concern, distributed in the southwestern United States, Mexico, and Central America. It inhabits pinyonjuniper woodlands, desert scrub, desert succulent scrub, desert riparian areas, desert washes, alkali desert scrub, Joshua tree habitats, and palm oases, roosting in rock crevices, caverns, or buildings (Zeiner et al. 1988–1990). Within the Proposed Project area, suitable habitat includes rocky cliffs, crevices, caverns, and urban/developed areas with bridges, buildings, or tunnels suitable for roosting. The species has been documented in the central portion of the Proposed Project area, with a record from 1989.

Mountain Lion (Puma concolor)
Mountain Lion (Puma concolor) is a California threatened species distributed in the western United States, Mexico, Central America and South America. In California, Central Coast and Southern California distinct population segments are state threatened. It occurs in a variety of habitats including riparian woodland, forest, scrub, chaparral, grassland and desert habitats; wherever mule deer occur. Canyons may serve as long distance movement corridors. Habitat and/or terrain that provides sufficient cover is necessary for hunting, resting and denning. Suitable Habitat in the Project area includes riparian forest/scrub, coastal scrub, chaparral, cismontane woodland, annual grassland.

Page 4 ends

Wildlife Corridor/NCCPs.

PEIR 3-36 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR Figure 4.3-5, Wildlife Corridor/NCCPs has been updated to include the boundaries for the Orange County Transportation Authority NCCP/HCP. Refer to Attachment E, Revised Figures to Draft PEIR.

Page 4 ends

Prior to any site disturbance, including grading, vegetation clearing, or fuel modification and prior to the issuance of any clearing, grading, or construction permits for individual development projects that are not exempt from California Environmental Quality Act (CEQA), and in conjunction with any required CEQA review, the future project applicant shall submit one or more documents to the City of Planning Division for review and approval, demonstrating that the project site does not contain native vegetation, sensitive plants, or undisturbed soils. Examples of acceptable documentation include, but are not limited to, the following:
• Aerial photographs (historic and current) showing grading, building footprints, paving, and landscaped areas over time to support ornamental status, existing landscape plans.
• Photographic documentation consisting of georeferenced or dated photographs.
• Landscaping plans or as-built drawings demonstrating that vegetation was intentionally planted as part of site development.
• Field survey results prepared by a qualified biologist confirming that existing plant species are ornamental and non-native.

Within the future site-specific project areas exhibiting native vegetation, a sitespecific biological resources survey shall be conducted during the project design phase.

PEIR 3-37 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR • A review of current land use and land ownership within the project vicinity. • An assessment and mapping of vegetation communities present within the project vicinity. If vegetation community mapping has not been conducted on the site in the previous three years, updated vegetation mapping shall be conducted by a qualified biologist as part of the project planning and environmental review process. Vegetation communities shall be mapped according to the Manual of California Vegetation at the alliance level, and a crosswalk table with Holland vegetation communities shall be provided. • A general assessment of the potential for aquatic resources, including wetlands and riparian habitats, to occur on site.
• An evaluation of potential local and regional wildlife movement corridors and an assessment of functions and value retention using online wildlife agency habitat connectivity maps and on-site evaluations. • A focused habitat assessment to determine if the project site supports vegetation communities that may provide habitat for plant or wildlife species, to be conducted by a qualified biologist, to determine the potential for sensitive plant or wildlife species to occur in or adjacent to the project site.
• If the project site supports sensitive vegetation communities, the project proponent shall implement the following weed control methods to minimize the establishment and spread of non-native and invasive weed species in the project site during construction activities:
− Seeds and plant materials used for revegetation shall be certified weedfree. − Straw materials, such as those used for erosion control, shall be certified weed-free.
• The results of the biological survey shall be presented in a biological technical report. The survey report shall map and describe the location and extent of observed sensitive resources, including sensitive vegetation communities, regional wildlife movement corridors, plant, and wildlife species within the areas of potential direct and indirect effects for each project area, direct and indirect impacts associated with construction and operation of a project, and the need for further survey, monitoring, or mitigation, including measures pursuant to Mitigation Measures MM BIO-2, MM BIO-3, MM BIO-4, MM BIO-5, MM BIO-6, and MM BIO-7 of this Program Environmental Impact Report. The biological technical report shall be submitted to and approved by the City of Brea prior to issuance of grading permits. The report shall PEIR 3-38 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR incorporate applicable mitigation measures (MM BIO-2 through MM BIO-9) to reduce any potentially significant impacts to biological resources.

MM BIO-2 Focused Sensitive Plant Species Surveys. If recommended by the Biological Resources Survey/Habitat Assessment prepared pursuant to Mitigation Measure MM BIO-1, prior to any site disturbance, including grading, vegetation clearing, or fuel modification, focused surveys for future site-specific development shall be conducted, as applicable, in suitable habitat, to determine presence/absence of sensitive plant species on the project site. Focused sensitive plant surveys shall be conducted during the species’ specific blooming periods to determine presence/absence. If sensitive plant species are mapped within any proposed construction, access, or staging areas, these species shall be quantified and flagged, and these areas shall be modified to avoid direct impacts to mapped sensitive plant species. If significant impacts to these species are unavoidable, the impact on these species shall be reduced to a less than significant level through implementation of one or a combination of the following actions, in accordance with a Conceptual Restoration Plan or acquisition of mitigation credits, reviewed and approved by the City of Brea:
• Impacted plants shall be salvaged and relocated to suitable habitat in an onsite restoration area, if possible. If relocation to a restoration area is not practical, the plants shall be relocated off-site to an appropriate location determined by a qualified biologist.
• Seeds from impacted plants shall be collected for use at a local off-site location, as applicable.
• Off-site habitat that supports the species impacted shall be enhanced or supplemented with seed collected on site.
• Comparable habitat at an approved off-site location shall be determined by a qualified biologist and preserved for relocation, enhancement, or transplant of the impacted sensitive plants.

Mitigation that involves relocation, enhancement, or transplant of sensitive plants shall include all the following:
• Conceptual planting plan prepared by a qualified biologist including grading, planting specifications, and, if appropriate, temporary irrigation. • Planting specifications and fencing and signage to discourage unauthorized access of the planting site.
• Monitoring program prepared by a qualified biologist with clearly stated goals and objectives and well-defined performance standards that result in no net loss of sensitive plant resources. Final success criteria shall be PEIR 3-39 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR determined based on quality, quantity, and species of plant impacted and in consultation with California Department of Fish and Wildlife and U.S. Fish and Wildlife Service depending on the status of the species. The monitoring program will include measures for adaptive management detailing remedial actions if success criteria are not met in the monitoring time frame.

Remedial actions may include, but are not limited to, supplemental water, replanting, and herbivore deterrents/protections.

Potential direct permanent impacts to sensitive vegetation communities resulting from project implementation shall be mitigated prior to any vegetation clearing or ground-disturbing activities within the site-specific areas. Mitigation shall be provided at a minimum of 1:1 and to the extent feasible located in the same ecological region or watershed, and functionally equivalent or superior in habitat value. Mitigation shall be fulfilled through one of the following three options:
a. Vegetation communities and land cover types will be verified in the field during the required biological survey and will be mapped for impact analysis;
ba. Compensatory mitigation for temporary impacts to sensitive habitats shall be satisfied through the acquisition of mitigation bank credits via a resource agency-approved mitigation site within the site’s specific watershed or by acquisition of other off-site mitigation credits to be identified and selected in coordination with CDFW. Prior to implementation of project construction impacts (e.g., vegetation clearing or ground-disturbing activities) that would require compensatory mitigation, documentation demonstrating the availability of mitigation credits (i.e., credit ledger) at the approved mitigation site must be submitted to the City of Brea for confirmation; or
cb. If credits are not available at a resource agency-approved mitigation site within the site’s specific watershed or through other off-site mitigation credits, PEIR 3-40 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR implementation of habitat creation, restoration, enhancement, or preservation shall occur through a Habitat Mitigation and Monitoring Plan developed by a qualified biologist. Under this option, a Habitat Mitigation and Monitoring Plan shall be provided and prepared to achieve no net loss of the resource, be timed in relation to project impacts, and comply with Federal and State mitigation requirements.
• When proposed mitigation involves habitat enhancement, restoration or creation, the Habitat Mitigation and Monitoring Plan shall include all of the following information:
• Conceptual planting plan including planting zones, grading, and irrigation.
• Seed mix/planting palette.
• Planting specifications.
• Monitoring program prepared by a qualified biologist including success criteria that ensure no net loss of sensitive vegetation communities. Final success criteria shall be determined based on quality, quantity, and type of habitat impacted and in consultation with CDFW. The monitoring program shall include measures for adaptive management plan detailing remedial actions if success criteria are not met in the monitoring time frame. Remedial actions may include, but are not limited to, supplemental water, replanting, and herbivore deterrents/protections.

The identification of mitigation site credits shall be provided to the City of Brea and shall include the following:
• Location of approved mitigation site.

PEIR 3-41 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR • Description of the mitigation credits to be acquired, including substantial evidence that the acquired habitat mitigates for the specific maintenance impact.
• Documentation of the credits that are associated with a mitigation bank, which has been approved by the appropriate resource agencies.
• Documentation in the form of a current mitigation credit ledger.

MM BIO-4: Habitat Restoration for Temporary Impacts. If recommended by the Biological Resources Survey/Habitat Assessment prepared pursuant to Mitigation Measure MM BIO-1, temporary impact areas shall be restored to pre-construction topographic contours and conditions, including the revegetation of native plant communities, where appropriate, following disturbance and prior to project completion. Habitat restoration and erosion control treatments shall be installed within these short-term impact areas. A Revegetation Plan shall be prepared and shall include site preparation specifications, a plant palette, installation procedures, development of reasonable success criteria, appropriate monitoring and reporting protocols, implementation timelines, and contingency measures and adaptive management in the event of restoration failure. The Revegetation Plan shall be submitted to and approved by the City of Brea. Habitat revegetation shall feature native species that are typical of the area, and associated erosion control best management practices shall include silt fence and microplastic- and weed-free straw fiber rolls, where appropriate. The revegetation areas shall be monitored and maintained by a qualified biologist or restoration specialist for 25 months to ensure adequate establishment and sustainability of the plantings/seedings.

MM BIO-5: Qualified Monitoring Biologist. If recommended by the Biological Resources Survey/Habitat Assessment prepared pursuant to Mitigation Measure MM BIO-1, a qualified monitoring biologist shall be retained to implement required monitoring.

The qualified monitoring biologist shall be responsible for the following monitoring and reporting tasks:
a. Biological Construction Mitigation/Monitoring Exhibit. Prior to the start of construciton site disturbance, including grading, vegetation clearing, or fuel modification, within the future site-specific project areas that have potential to contain sensitive biological resources, the qualified monitoring biologist shall submit a Biological Construction Mitigation/Monitoring Exhibit, which includes limits of work, proposed monitoring schedule, bird, focused sensitive species, or other wildlife surveys/survey schedules (including general bird nesting and U.S. Fish and Wildlife Service protocol), timing of PEIR 3-42 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR surveys, bird construction avoidance areas/noise buffers/barriers, other impact avoidance areas, and any subsequent requirements determined by the qualified monitoring biologist. The Biological Construction Mitigation/Monitoring Exhibit shall include the construction site plan, written and graphic depiction of the project’s biological mitigation/monitoring program, and a schedule for construction activities.

Where the potential for impacts to biological resources is limited (e.g., construction within a footprint that consists entirely of previously developed or disturbed lands), the Biological Construction Mitigation/Monitoring Exhibit may be limited to a pre- and postmaintenance verification inspection by a qualified biologist. For highly sensitive resource areas with documented sensitive biological and aquatic resources present, full-time biological monitors may be required, as determined by a qualified biologist. The Biological Construction Mitigation/Monitoring Exhibit shall be approved by the City of Brea prior to the start of construction.
b. Resource Marking/Protection. Prior to the start of construction activitiessite disturbance within the future site-specific project area, the qualified monitoring biologist shall supervise the placement of orange construction fencing or similar visible marker, staking, or flagging along the limits of the construction area adjacent to sensitive biological habitats, as shown on the Biological Construction Mitigation/Monitoring Exhibit to ensure crews remain within the approved construction limits. These demarcations shall not be required for areas with existing barriers, such as chain-link fencing, along the limits or facilities that are within or adjacent to developed and non-sensitive habitat areas. This task shall include flagging plant specimens and delineating buffers to protect sensitive biological resources (e.g., habitats, sensitive plant and wildlife species, including nesting birds) prior to construction.
c. Cover Trenches. The qualified monitoring biologist shall oversee the construction site so that cover and escape routes for wildlife from excavated areas shall be provided daily. All trenches, holes, and excavations during construction shall be covered at night as directed by the monitoring biologist with plywood, metal plates, or other means, and if plastic sheeting is used, the edges must be covered with soils such that small wildlife cannot access the excavated hole. Soil piles shall be covered at night to prevent wildlife from burrowing in. The edges of the sheeting shall be weighed down by sandbags. These areas may also be fenced to prevent wildlife from gaining PEIR 3-43 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR access. Exposed trenches, holes, and excavations shall be inspected twice daily (i.e., each morning and before sealing the exposed area) by the qualified monitoring biologist to monitor for wildlife entrapment.

Excavations shall provide an earthen ramp to allow for a wildlife escape route. The qualified monitoring biologist shall verify that the contractor has covered all steep-walled trenches or excavations prior to the end of construction daily. If wildlife species are encountered within any trenches or excavated areas, the qualified monitoring biologist shall remove them, if possible, or provide them with a means of escape (e.g., a ramp or sloped surface at no greater than a 30-degree angle) and allow the species to disperse. In addition, the qualified monitoring biologist shall provide training to construction personnel to increase awareness of the possible presence of wildlife beneath vehicles and equipment and to use best judgment to avoid killing or injuring wildlife (refer to Mitigation Measure BIO-5e).
d. Structure and Tree Clearance. Prior to the issuance of any permit to allow for the removal or demolition of trees and existing structures within the survey area (particularly any ornamental trees and existing buildings in the developed land areas), the qualified monitoring biologist shall conduct clearance surveys to flush out any wildlife species nesting, roosting, or otherwise occupying the trees or structures. If wildlife species are encountered within any of the trees or structures (outside the general bird nesting season), the qualified monitoring biologist shall remove them, if possible, or provide them with a means of escape and allow the species to disperse. If tree-roosting bats are suspected, slow removal by gently pushing the tree over with heavy equipment is required.
e. Pre-Construction Meeting/Education. Prior to the start of any construction activity site disturbance where the site plan for the construction area indicates that significant impacts to biological resources may occur, as determined by a qualified biologist, a pre-construction meeting shall be held on site with the following in attendance: City of Brea representative (project planner and building inspector), the construction contractor (if applicable), and the qualified monitoring biologist. At this meeting, the qualified monitoring biologist shall identify and discuss the construction protocols that apply to the proposed activities and the sensitive nature of the adjacent habitat with appropriate project personnel.

At the pre-construction meeting, the qualified monitoring biologist shall submit to the City of Brea representatives and construction contractor a copy of the PEIR 3-44 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR Biological Construction Mitigation/Monitoring Exhibit that identifies areas to be protected, fenced, and monitored. This data shall include all buffer limits, if applicable.

Prior to the start of construction activities, the qualified monitoring biologist shall meet with the construction contractor and crew and conduct an on-site educational session regarding the need to avoid impacts outside the approved construction footprint and to protect sensitive plants and wildlife that may occur at the specific facility. This may include but not be limited to explanations of the bird and wetland buffers, the flag system for removal of invasive species or retention of sensitive plants, and clarification of acceptable access routes/methods and staging areas.
f. Biological Monitoring and Reporting. The qualified monitoring biologist with stop work authority shall inspect/monitor the project construction area in accordance with the approved Biological Construction Mitigation/Monitoring Exhibit. This may be limited to pre- and postmaintenance inspections, weekly visits, or full-time monitoring, as determined by the qualified monitoring biologist and the City of Brea.

If no burrowing owls are identified, no further measures are necessary. If burrowing owls are detected, active burrows shall be avoided using buffers outlined in the Staff Report on Burrowing Owl Mitigation, dated March 7, 2012, issued by CDFW. If avoidance is not possible, the qualified biologist shall consult with CDFW. No direct disturbance to burrowing owls or their occupied habitat shall occur without appropriate authorization from CDFW. d. Least Bell’s Vireo. If suitable habitat for least Bell’s vireo is present and clearing, grubbing, grading, or other construction activities may occur between March 15 and September 15, the breeding season of the least Bell’s vireo, a qualified biologist shall conduct focused surveys for the presence of the least Bell’s vireo of the site and areas of potentially suitable habitat within 300 feet or that would be subject to construction noise levels exceeding 60 A-weighted decibels or to the ambient noise level if it already exceeds 60 A-weighted decibel hourly average. If present, measures to PEIR 3-46 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR minimize noise impacts (such as temporary noise walls/berms) may be required. Noise levels from construction activities during the avian breeding season should not exceed 60 decibels (dBA Leq; or the ambient noise level if they already exceed 60 dBA Leq) at the edge of the occupied habitat. If complete avoidance is not feasible, the qualified biologist shall consult with USFWS. No direct harm to the species shall be allowed without appropriate authorization from USFWS.
e. Southwestern Willow Flycatcher. If suitable habitat for southwestern willow flycatcher is present and clearing, grubbing, grading, or other construction activities may occur between April 15 through September 15, the breeding season of the southwestern willow flycatcher, a qualified biologist shall conduct focused surveys for the presence of the southwestern willow flycatcher of the site and areas of potentially suitable habitat within 500 feet.

If the species is determined to be present, consultation per Endangered Species Act with USFWS would be necessary and no activities would occur until authorized by USFWS. No direct harm to the species shall be allowed without appropriate authorization from USFWS.
f. Sensitive Bat Species. If suitable roosting habitat (e.g., riparian habitat, snags, wooden buildings, bridges, etc.) for sensitive bat species is present, a qualified biologist shall conduct subsequent focused surveys no less than 14 days prior to removal or disturbance of vegetation or buildings. The survey shall consist of visual and/or acoustic methods as deemed appropriate by the qualified biologist. If no bats are detected, no further measures are necessary. If bat species are detected during surveys, a sitespecific plan shall be developed by the qualified biologist. The plan may include, as determined by the qualified biologist, delaying removal of roost habitat until after the maternity roosting period and exclusion of bats from roosting habitat prior to removal of habitat. The qualified biologist shall consult with CDFW prior to implementing any exclusion activities. g. Southwestern Pond Turtle. If suitable habitat for southwestern pond turtle is present pursuant to Mitigation Measure MM BIO-1, site-specific measures shall be implemented to avoid impacts, as developed in consultation with a qualified biologist. Measures shall focus on avoiding habitat destruction, protecting individuals during construction, and managing habitat to increase survival though preconstruction surveys, exclusion fencing, biological monitoring, and habitat restoration.

Depending on the measures selected, plan approval and conference with the U.S. Fish and Wildlife Service may be required if the action is likely to jeopardize the species’ existence during construction activities.

PEIR 3-47 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR h. Mountain Lion. If suitable habitat for mountain lion is present pursuant to Mitigation Measure MM BIO-1, site-specific measures shall be implemented to minimize habitat loss and fragmentation to improve habitat connectivity and avoid take. These measures shall be developed in consultation with a qualified biologist and may include measures described in the City of Brea General Plan Community Resources Element Policy CR3e. If presence is established, Resource Agency consultation shall be required to obtain an incidental take permit.
gi. Other Sensitive Species. Prior to any demolition work, construction, or grading activities within the future site-specific project areas, preconstruction surveys for other sensitive wildlife species, such as reptiles, may be required to determine presence/absence of sensitive wildlife species within the proposed survey area.

MM BIO-7: Focused Nesting Bird Surveys. Project activities that may directly (e.g., vegetation removal, clearing and grubbing, building demolition) or indirectly affect (noise, light, or ground vibration) nesting raptors and other protected avian species shall be timed to avoid the nesting season (January 15 through September 15). If project activities occur within the nesting season, prior to any site disturbance, including grading, vegetation clearing, or fuel modification, the qualified monitoring biologist shall conduct focused surveys for birds in suitable habitat to determine presence/absence. Surveys shall occur within seven (7) days prior to any construction or grading activities or site disturbance within the future site-specific project areas. Focused sensitive bird surveys shall be conducted during the species’ specific nesting seasons to determine presence/absence within the development footprint plus a buffer, if recommended by the qualified monitoring biologist (refer to Mitigation Measure MM BIO-5). The survey report shall map and describe the location and extent of observed sensitive bird species that would be impacted within the areas of potential effect for each project area. If no nesting birds are documented within the individual activity area, construction shall be allowed to proceed. If nesting birds cannot be completely avoided, a no-disturbance buffer shall be established around the active nest, the size of which will be determined by the qualified monitoring biologist based on species of bird and specific construction activities to take place. The size of the buffer can be reduced in consultation with California Department of Fish and Wildlife. Any work within the buffer shall be avoided until the nest is inactive, as determined by the qualified monitoring biologist.

PEIR 3-48 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR

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The City’s updated General Plan Community Resources Element Goal CR-6 envisions a community that preserves, protects, and celebrates artistic, cultural, and historic resources that define Brea’s identity, policies also includes the following goals, policies, and actions related to historical preservation in the Community Resources Element and Community Development Element Goal CD-2 envisions creating a visually appealing and cohesive community that emphasizes high-quality design, celebrates Brea’s distinct character, and fosters a strong sense of place through well-designed spaces, architecture, and streetscapes. These key goals, along with policies such as CR-6.4 and CD-2.12 that aims to evaluate the condition of historical buildings, the costs of rehabilitation, and the feasibility of preservation or conservation alternatives when considering the demolition or movement of historic structures and ensure that new development respects the City’s historic heritage and architecture and is designed to be consistent with the local context and key physical and architectural characteristics of its surrounding neighborhood, and actions such as CR-6b, CR-6c, and CR-6e, that seeks to research all types of possible funding sources and financial assistance to help promote, preserve, and restore historical resources, add resources that meet the City’s Historic Preservation Ordinance, and work with the Brea Museum and Historical Society to increase awareness of Brea’s historic resources and the importance of their preservation, would work together to reduce impacts related to historical resources. Specific goals, policies, and actions are included in Appendix C, Brea 2050 General Plan: Goals, Policies, and Actions.
• Goal CR-6: Artistic, Cultural, and Historic Resources. A community that preserves, protects, and celebrates resources that define Brea's identity. − Policy CR-6.4. Historic Resources: Evaluate conditions and rehabilitation, costs before considering demolition.
− Action CR-6b. Research funding (tax incentives, grants) for historical resources restoration.
− Action CR-6c. Add resources that meet the Historic Preservation Ordinance to registers.
− Action CR-6e. Work with the Historical Society to increase awareness of preservation.
− Policy CD-2.12: Historic Preservation. Respect historic heritage and architectural local context.

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GEO-f.

As shown in Table 4.5-6, total fuel use is anticipated to increase under buildout conditions because the BCSP would increase development density in the BCSP area. However, as discussed under Impact Section 4.13.4.2, Threshold TRA-b-2, the BCSP result in less than significant VMT PEIR 3-49 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR impacts because, similar to the Focused GPU, VMT per service population would decrease under the BCSP compared to future conditions without BCSP implementation.

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Threshold EN-a.

Paleontological resources consist of the fossilized remains or traces of prehistoric plant and animal life (excluding humans). These resources are nonrenewable and are protected under the California Public Resources Code, Section 5097.5. The Focused GPU includes Policy CR-6.5.2, Archaeological and Paleontological Resources, which calls for evaluating the significance of any discovered archaeological or paleontological resources based on cultural relevance, physical condition, economic factors, feasibility, and other key considerations.

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Conditions, City of Brea Emissions.

Model default assumptions for the existing land use mix were assumed except for the Citywide VMT obtained from the City of Brea Focused General Plan Update and Brea Core Specific Plan:

Transportation Analysis (Appendix H, VMT and Transportation Impact AnalysisAssessment) prepared by Kittelson & Associates, Inc. (2025).

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Emissions, Table 4.7-2.

Source: Refer to Appendix D1 for model output.

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Specific Plan Emissions, Table 4.7-3.

Source: Refer to Appendix D1 for model output.

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Threshold GHG-a.

Detailed assumptions and modeling datasheets are provided in Appendix D1 to this PEIR.

Estimated annual construction emissions are 3,606 MT CO2e as shown in Table 4.7-4, Estimated Focused GPU Greenhouse Gas Emissions.

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Threshold GHG-a, Table 4.7-4
Source: Refer to Appendix D1 for model output.

PEIR 3-50 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR

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Impacts, Threshold GHG-a.

Detailed assumptions and modeling datasheets are provided in Appendix D1 to this PEIR.

Estimated annual construction emissions are 594 MT CO2e as shown in Table 4.7-45, Estimated Brea Core Specific Plan Greenhouse Gas Emissions.

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MM GHG-1
MM GHG-1 GHG Reduction Plan for Future Development. As part of the development review process for individual development projects that are not exempt from CEQA, the Brea Community Development Department shall require a greenhouse gas (GHG) emissions technical analysis prepared by a qualified environmental professional for all projects exceeding 190 single-family dwelling units, 360 multi-family dwelling units, or 56,000 square feet of non-residential square footage.1 If the GHG technical analysis shows that construction- or operational-related GHG emissions project will meet or exceed the South Coast Air Quality Management District Interim California Environmental Quality Act GHG Tier 3 Significance Threshold of 3,000 metric ton carbon dioxide equivalent (MT CO2e) and per capita threshold of 1.5 MT CO2e per service population, a GHG reduction plan shall be prepared to reduce GHG emissions to below the applicable threshold. The GHG reduction plan shall include potential mitigation measures from the California Air Pollution Control Officers Association Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity.

Mitigation measures shall be selected based on the nature of the project and characteristics of the GHG emission source(s). Potential measures include, but are not limited to the following:
• Transportation and Land Use: Mobile GHG emissions can be mitigated through project site location and design, including:
− Prioritizing infill development with high destination accessibility − Improving destination accessibility
− Orient project toward transit, bicycle, or pedestrian facility − Locate project near bike path/bike lane
− Provide bike parking, especially near transit
− Provide traffic calming measures to encourage pedestrian/bicycle activity − Create urban non-motorized zones
1 Consistent with SCAQMD methodology for the screening levels in Table 3-3 of the Interim CEQA GHG Significance Threshold Draft Guidance Document (SCAQMD 2008), 190 single-family residential units, 360 multi-family residential units, or 56,000 SF of retail development would generate approximately 3,000 MT CO2e annually, assuming default CalEEMod assumptions for Year 2025. See Appendix D for calculation details.

PEIR 3-51 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR − Construct or improve bicycle and pedestrian facilities − Provide first and last mile services to connect project to existing transit or community services, such as a shuttle program
− Implement preferential parking permit program for ride-share participants − Provide electric vehicle infrastructure beyond California Green Building Standards Code (CALGreen) requirements
− Provide end-of-trip bicycle facilities
− Implement a school pool program
− Implement telecommute and/or alternative work schedule program − Implement commute trip reduction programs
− Implement paid parking
− Replace traffic controls with roundabout where appropriate − Incorporate park-and-ride lots
− Designate zero emissions delivery zones
− Electrify loading docks
− Install hydrogen fueling infrastructure for projects that include a fleet fueling component
• Green Building Measures: Building design beyond CALGreen requirements can reduce GHG emissions from energy and water use. Some strategies include:
− Install whole-house fans.
− Install energy-saving lighting, heating, cooling systems, and appliances. − Design buildings with passive environmental controls to maximize natural heating and cooling.
− Install electric vehicle charging stations to support clean transportation. − Provide on-site renewable energy generation systems and storage − Install electric heat pumps
− Implement yard equipment exchange program
− Provide electric yard equipment compatibility, such as outdoor outlets − Install green or cool roofs
− Provide high efficiency outdoor lighting
− Install cool pavement
− Eliminate the use of natural gas
− Use reclaimed non-potable water for landscaping
− Use gray water
− Require low-flow fixtures
− Design water efficient landscaping
− Participate in waste diversion programs
PEIR 3-52 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR • Project Construction: GHG emissions from construction can be reduced through sustainable practices such as the following:
− Recycle demolished construction material beyond CALGreen requirements − Source wood materials from urban wood reuse program
− Use local and sustainable building materials
− Use local construction contractors
− Use cleaner-fuel equipment
• Natural/Working Lands: Support carbon sequestration, reduce urban heat island impact, and improve access to local food sources through practices such as the following:
− Make public space available for establishment of a local farmers market − Establish areas available for community gardens
− Expand urban tree planting
− Create new vegetated spaces
− Install permeable surfaces
5 Consistent with SCAQMD methodology for the screening levels in Table 3-3 of the Interim CEQA GHG Significance Threshold Draft Guidance Document (SCAQMD 2008), 190 single-family residential units, 360 multifamily residential units, or 56,000 SF of retail development would generate approximately 3,000 MT CO2e annually, assuming default CalEEMod assumptions for Year 2025. See Appendix D1 for calculation details.

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Environmental Impacts, Threshold HAZ-b.

As described in Section 4.8.1.2, Existing Conditions, there are a number of hazardous sites identified by GeoTracker and EnviroStor within the City of Brea (DTSC 2025; SWRCB 2025; Table 4.8-2; Table 4.8-3).

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Environmental Impacts, Threshold HAZ-d.

As described in Section 4.8.1.2, Existing Conditions, there are 16 hazardous sites identified by GeoTracker and 27 sites identified by EnviroStor within the City of Brea, not including completed/closed cases or permitted USTs (DTSC 2025; SWRCB 2025;Table 4.8-2; Table 4.8-3).

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Cumulative Impacts, Cumulative Threshold HAZ-f.

As described in Section 4.8.4.5, Threshold HAZ-6f, implementation of the Proposed Project would not interfere with implementation of an emergency response or evacuation plan. Therefore, the Project would not contribute to a cumulative impact related to emergency response or evacuation plans.

PEIR 3-53 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR

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Significance Before Mitigation
Environmental impacts related to Thresholds HAZ-1a through HAZ-7g would be less than significant with compliance with all applicable regulatory requirements as outlined in PPP HAZ1 through PPP HAZ-9 and applicable Focused GPU goals, policies, and actions (refer to Appendix C, Brea 2050 General Plan: Goals, Policies, and Actions).

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Impacts, Threshold HYD-d.

Potential dam inundation is shown on Figure 4.9-45. Breach of Carbon Canyon Dam presents the largest potential inundation area, encompassing a small portion of the Project area and neighboring jurisdictions to the south. Diemer No. 8 and the Orange County Reservoir also presents inundation risk within the Project area.

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Environmental Impacts, Threshold HYD-d.

Most of the BCSP area does not lie within a FEMA Special Flood Hazard Area and is designated as Zone X. Zone X are identified areas with minimal flood risk. There are two areas along the Brea Canyon Channel and Fullerton Creek that are designated as Zone AE and are subject to flooding by the 1 percent annual chance flood, as shown on Figure 4.9-64. All future development within an established Flood Hazard Overlay Zoning District would be subject to full compliance with all standards of Division II, Floodplain Management, of the BCC. Enforcement of floodplain management is achieved through the development review process as part of plan review and permit approval.

The BCSP area is located downstream of the Orange County Reservoir. Potential dam inundation is shown on Figure 4.9-45. The Orange County Reservoir presents an inundation risk within the BCSP area.

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The existing General Plan land use designation categories are shown in Table 2-1, Existing and Adopted 2003 Brea General Plan Land Use Summary, Chapter 2, Project Description, of this PEIR. Dominant categories are summarized below.

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Impacts.

The incorporated City of Brea is a largely developed suburban/urban community. The existing land use pattern is mixed and includes established residential neighborhoods, a concentrated downtown and mall/commercial core, industrial and business parks, civic and institutional uses, parks and open space, and transportation corridors. Most of the developed area is located west of PEIR 3-54 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR Valencia Avenue, while the eastern portion consists primarily of residential neighborhoods, with large undeveloped foothills and canyons to the east and north. The SOI area west of SR-57 also includes oil fields with an extensive network of production infrastructure, including tank facilities, processing facilities, service roads, and power lines, and SOI area north of Carbon Canyon Road includes portions that previously supported oil and gas exploration and production activities. There is currently no development within the sphere of influence area, and only residential uses are permitted on approximately 34 percent of the total sphere of influence acreage under the current 2003 General Plan. The remaining 4,050 acres (66 percent) are designated for open space, parks/recreation, and public facilities, with no residential or non-residential development potential.

Therefore, buildout of the Project area would largely come from redevelopment of already existing developed areas that contribute to urban storm water runoff.

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Impacts.

As described previously, the Project area is largely developed and buildout of the Project area would largely come from redevelopment of already existing developed areas (i.e., infill development). However, buildout would result in new development in previously undeveloped areas, primarily in the eastern portion of the City and its sphere of influence, and areas of current and historic oil and gas production activities, which could result in an increase in storm water runoff quantities. Redevelopment would also alter existing drainage of any given infill site that would affect the existing storm water drainage system.

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Furthermore, the Focused GPU Public Safety Element Goal PS-1 seeks Wildland Fire Abatement:

A a community that is minimally impacted by wildland and urban fires through implementation of proactive fire hazard abatement strategies; Goal PS-6 Emergency Management: A seeks a City that is well-prepared for response and management to minimize disaster impacts; Community Development Element Goal CD-4 Hillside Development: seeks to Mminimize the extent of development in the hillsides and mitigate adverse consequences of urbanization; and Goal CD-5 Infrastructure: seeks to Pprovide sufficient levels of water, sewer, and storm drain service throughout the community., Some of the fire-protection policies and actions include coordinating with service providers to ensure the resilience of critical facilities (PS 6.1); maintaining proper communication protocols and procedures among emergency service providers (PS 6.3); educating the community for emergency response, including secure evacuation routes (PS 6.4); participating in automatic and mutual aid agreements with adjacent service providers (PS 6.5); working with the Fire Department and Police Department to define minimum standards (PS 6.6); prepare and maintain comprehensive five-year strategic plans for both the Fire and Police Departments (PS 6e); preparing and periodically updating technical studies; evaluate public safety impacts of new development using standard methodologies (PS 6f); periodically reviewing emergency shelters PEIR 3-55 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR (PS 6.7); linking emergency services with local hazard mitigation programs (PS 6.8); regularly coordinating with the City’s major institutions, schools, employers, and homeowner’s associations (PS 6.9); maintaining and regularly updating a mass communications system (PS 6.11); maintaining a proactive public safety system through recurring five year cycle (PS 6.12); regularly practicing implementation of the City’s Emergency Operations Plan (PS-6a); regularly review County and State emergency response procedures (PS 6b); implementing the City of Brea’s Local Hazard Mitigation Plan (PS-6c); publishing and maintaining a Public Safety Impact Methodology Manua (PS 6h); adopting public safety Service Level Objectives (SLOs) for both Fire and Police Departments (PS 6i); preparing annual reports on the adopted SLOs by the Fire and Police Department (PS 6j); requiring phased development of major developments (PS 6k); requiring fairshare developments (PS 6l); maintaining consistency between various plans; and maintaining standardizes public safety data and annual scorecard (PS 6n). These goals and associated policies and actions that would support in providing adequate fire protection services within the City (refer to Appendix C, Brea 2050 General Plan: Goals, Policies, and Actions). In particular, the following policies and action items as part of Goal PS-6 Emergency Preparedness would help reduce fire services impacts:
• Policy PS-6.1: Critical Facilities. Coordinate to ensure the resilience of lifeline infrastructure. • Policy PS-6.3: Communication. Maintain proper protocols among all emergency service providers.
• Policy PS-6.4: Education. Prepare the community for efficient response and evacuation. • Policy PS-6.5: Automatic and Mutual Aid. Participate in aid agreements with adjacent providers.
• Policy PS-6.6: Evacuation Routes. Work with Fire/Police to define standards and assessment ranges.
• Policy PS-6.7: Emergency Shelters. Periodically review supply and equipment availability. • Policy PS-6.8: Collaboration. Link emergency services with mitigation programs. • Policy PS-6.9: Institutions. Coordinate response procedures with major employers and schools.
• Policy PS-6.11: Warning Systems. Maintain and upgrade mass communications systems. • Policy PS-6.12: Strategic Readiness. Maintain proactive, data-driven planning through recurring five-year cycles.
• Action PS-6a: Regularly practice implementation of the Emergency Operations Plan. • Action PS-6b: Coordinate local response procedures with county and State plans. • Action PS-6c: Continue implementing the Brea Local Hazard Mitigation Plan. • Action PS-6e: Prepare five-year strategic plans for both Fire and Police Departments. • Action PS-6f: Update technical studies for Fire Department five-year plans. • Action PS-6g: Evaluate public safety impacts of new development using standard methodologies.

PEIR 3-56 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR • Action PS-6h: Publish a Public Safety Impact Methodology Manual. • Action PS-6i: Adopt Department Service Level Objectives (SLOs). • Action PS-6j: Provide annual reports on adopted SLOs. • Action PS-6k: Require phasing for major developments to prevent response degradation. • Action PS-6l: Require fair-share contributions to mitigate public safety impacts. • Action PS-6m: Maintain consistency between strategic plans and the General Plan/CIP. • Action PS-6n: Maintain standardized public safety data and publish an annual scorecard.

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Furthermore, as discussed in Section 4.12.1.4 for fire protection and emergency services, policies and actions identified as part of Public Safety Element Goal PS-6 that envisions a City that is well prepared for emergency response and disaster managementto Emergency Management, include coordinating with service providers to ensure the resilience of critical facilities; maintaining proper communication protocols and procedures among emergency service providers; educating the community for emergency response, including secure evacuation routes; participating in automatic and mutual aid agreements with adjacent service providers; working with the Fire Department and Police Department to define minimum standards; prepare and maintain comprehensive five-year strategic plans for both the Fire and Police Departments; preparing and periodically updating technical studies; evaluate public safety impacts of new development using standard methodologies; adopting public safety Service Level Objectives (SLOs) for both Fire and Police Departments; preparing annual reports on the adopted SLOs by the Fire and Police Department; requiring phased development of major developments; requiring fairshare developments; maintaining consistency between various plans; and maintaining standardizes public safety data and annual scorecard. These goals, policies, and actions of the Focused GPU Public Safety Element would help reduce police services impacts (refer to Appendix C, Brea 2050 General Plan:

Goals, Policies, and Actions). In particular the following policies and action are related to police services:
• Policy PS-6.3: Communication. Maintain proper protocols among all emergency service providers.
• Policy PS-6.4: Education. Prepare the community for efficient response and evacuation. • Policy PS-6.5: Automatic and Mutual Aid. Participate in aid agreements with adjacent providers.
• Policy PS-6.6: Evacuation Routes. Work with Fire/Police to define standards and assessment ranges.
• Action PS-6e: Prepare five-year strategic plans for both Fire and Police Departments. • Action PS-6f: Update technical studies for Fire Department five-year plans. • Action PS-6g: Evaluate public safety impacts of new development using standard methodologies.

PEIR 3-57 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR • Action PS-6h: Publish a Public Safety Impact Methodology Manual. • Action PS-6i: Adopt Department Service Level Objectives (SLOs). • Action PS-6j: Provide annual reports on adopted SLOs. • Action PS-6k: Require phasing for major developments to prevent response degradation. • Action PS-6l: Require fair-share contributions to mitigate public safety impacts. • Action PS-6m: Maintain consistency between strategic plans and the General Plan/CIP. • Action PS-6n: Maintain standardized public safety data and publish an annual scorecard.

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Cumulative Threshold PS-a(ii).

As discussed in Section 4.12.2.4 for individual impact, the Focused GPU Public Safety Element includes actions associated with Goal PS-6, Emergency Management, that aims for require periodic strategic planning, technical studies, service level objective adoption and reporting, development phasing, and fair-share contribution frameworks, which provide an adaptive planning and implementation framework to ensure that police services are evaluated and addressed as development occurs, without committing to specific facilities or improvements at this time.

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City of Brea Focused General Plan Update and Brea Core Specific Plan: Transportation and Vehicle Miles Traveled (VMT) Impact Analysis, Kittelson & Associates, January April 2026 (Appendix H)

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Existing Conditions.

OCTA is the major transit agency serving Orange County, with services including fixed-route buses and paratransit. It provides approximately 6051 fixed bus routes, including local, community, express (Bravo!)rapid, and StationLink services on a countywide basis. OCTA bus network spans most of Orange County, connecting major cities, employment centers, transit hubs, and points of interest. OCTA provides connections to other municipalities and the rest of the region through transit nodes and other intermodal hubs. Systemwide, buses generally operate on 15 to 30- minute intervals during peak hours, with less frequent service during off-peak times and on weekends.

Currently, there are four OCTA bus routes that operate within the City2 :
• Route 57 which operates between Brea and Newport Beach. • Route 59 which operates between AnaheimBrea and Irvine 2 Orange County Transportation Authority, “Routes and Schedules”, last accessed December 2025. https://www.octa.net/gettingaround/bus/oc-bus/routes-and-schedules/routes-and-schedules PEIR 3-58 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR • Route 129, a community route that operates between La Habra, Brea and AnaheimBuena Park.
• Route 143, which operates from La Habra to Brea.

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Bikeway Network.

Figure 4.13-1, Existing Bikeway Network, has been updated to correct boundary delineation. Refer to Attachment E, Revised Figures to Draft PEIR, of this Response to Comments.

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Environmental Impacts, Threshold TRA-a.

The updated Mobility Element identifies Goal M-1 which aims to maintain an effective regional transportation network; Goal M-2 which aims to provide a safe local circulation system that facilities the efficient flow of traffic and goods throughout the City; and Goal M-3, which aims to provide a safe and convenient transportation network accessible for all transportation modes and users. These goals incorporates policies that guide roadway operations, safety, design, and goods movement, in particular, policies and actions include coordinating with various federal, state, regional, and local agencies to develop a transportation network that balances traffic flow and multi-modal needs; working with regional partners to plan for emerging transportation modes and technologies; providing roadway design requirements for roadways; maintaining acceptable vehicular level of service; discouraging the flow of non-local traffic through neighborhoods; applying creative traffic management strategiesto minimize vehicular congestion; maintaining and updating a designated local truck route network; implementing best complete streets practices; identifying and addressing gaps in travel facilities serving vehicles, bicyclists, pedestrians, transit riders, and other uses; monitoring and evaluating the development of new mobility technologies and improvements to facilitate a transportation network that accommodates all modes and users; and supporting safe, pleasant, and comfortable roadway design principles (refer to Appendix C, Brea 2050 General Plan: Goals, Policies, and Actions). Key supporting policies include:
• Policy M-1.2 Inter-Agency Coordination. Engage with Federal Highway Administration (FHWA), the Southern California Association of Governments (SCAG), and Orange County Transportation Authority (OCTA) for balanced multi-modal planning. • Policy M-1.4 Emerging Technology. Plan with regional partners for new transportation modes. • Policy M-2.1 Roadway Requirements. Design roads for all modes/users and maintain according to best practices.
• Policy M-2.2 Level of Service. Strive to maintain acceptable level of service along City facilities per Transportation Impact Analysis (TIA) Guidelines. • Policy M-2.3 Non-Local Traffic. Discourage regional traffic from passing through neighborhoods.

PEIR 3-59 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR • Policy M-2.4. Traffic Management. Apply creative strategies to minimize congestion at schools and drive-throughs.
• Policy M-2.8. Truck Route Network. Maintain, and update local routes to reduce community impacts.
• Policy M-3.1 Complete Streets Principles. Implement best practices for all road users. • Policy M-3.5 New Mobility Technologies. Monitor and implement tech that aids all transportation modes.
• Policy M-3.7 Roadway Design Principles. Support design that create safe, comfortable pedestrian experiences.

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Threshold TRA-a.

The Mobility Element developed as part of the Focused GPU identifies Goal M-3, which aims to provide a safe and convenient transportation network accessible for all transportation modes and users, and Goal M-4, which aims to develop extensive networks of public bikeway and community pedestrian facilities that enable and encourage non-motorized travel. These goals contains policies that support access to and the performance of public transit, bicycle, and pedestrian facilities such as considering and implementing best complete streets practices to facilitate travel and enhance safety for all road users regardless of travel mode; implementing curb zone changes to best match the needs of adjacent land uses and to facilitate non-motorized transportation choices; supporting roadway design principles that create a safe, pleasant, and comfortable experience for all road users; using traffic calming methods; requiring new development projects to dedicate land for public improvements; developing and maintaining a comprehensive and integrated system of bikeways; providing safe, attractive, and accessible bicycle and pedestrian facilities and making connectivity improvements; and planning neighborhood streets, pedestrian walks, and bicycle paths as a system of fully connected routes. The actual goals and policies are included in Appendix C, Brea 2050 General Plan: Goals, Policies, and Actions. These policies include:
• Policy M-3.1 Complete Streets Principles. Implement best practices for all road users. • Policy M-3.6 Curb Management. Adjust curb zones to match land use needs and nonmotorized choices. • Policy M-3.7 Roadway Design Principles. Support designs that create safe, comfortable pedestrian experiences.
• Policy M-3.8 Traffic Calming. Use context-sensitive methods to balance auto, transit, and pedestrian needs.
• Policy M-3.9 New Development – Multi-Modal Facilities. Require land dedication for sidewalks and bike lanes.
• Policy M-4.1 System of Bikeways. Develop a comprehensive system for commuting and recreation.

PEIR 3-60 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR • Policy M-4.3 Pedestrian Connections. Provide safe routes to Downtown and major activity centers.
• Policy M-4.7 Bicycle, Pedestrian, and Connectivity Improvements. Provide secure bike parking and lighting.
• Policy M-4.10 Bicycle and Pedestrian Connectivity. Plan neighborhood routes as a fully connected system.

Pages 4.13-22 and 23, 4th paragraph. Section 4.13.4.3, Transportation, Environmental Impacts, Threshold TRA-c.

In addition, the new Mobility Element developed as part of the Focused GPU contains policies in support of roadway network safety and reducing design hazards., including: The policies such as M 1.4, M 2.1, M 2.8, M 3.1, M 3.5, and M 3.9 that aim to work with regional partners to plan for emerging transportation modes and technologies, provide roadway design requirements, maintain and update local truck routes, implement best complete streets practices for all road users, monitor and evaluate the development of new mobility technologies, and require new development to dedicate land for public improvements. The actual goals and policies are included in Appendix C, Brea 2050 General Plan: Goals, Policies, and Actions.
• Policy M-1.4 Emerging Technology. Plan with regional partners for new transportation modes. • Policy M-2.1 Roadway Requirements. Design roads for all modes/users and maintain according to best practices.
• Policy M-2.8 Truck Route Network. Maintain, and update local routes to reduce community impacts.
• Policy M-3.1 Complete Streets Principles. Implement best practices for all road users. • Policy M-3.5 New Mobility Technologies. Monitor and implement tech that aids all transportation modes.
• Policy M-3.9 New Development – Multi-Modal Facilities. Require land dedication for sidewalks and bike lanes.

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Threshold TRA-c.

Relevant supporting policies from the new Mobility Element include Policy M-1.2 that aim to engage various government agencies to develop a transportation network that balances traffic flow and multi-modal needs; Policy M-2.7 that aims to incorporate necessary improvements to and perform maintenance on evacuation routes, and Policy M-3.9 that requires land dedication for public improvements such as roadways, wider sidewalks, and /or bicycle lanes.: The actual goals and policies are included in Appendix C, Brea 2050 General Plan: Goals, Policies, and Actions.

PEIR 3-61 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR • Policy M-1.2 Inter-Agency Coordination. Engage with Federal Highway Administration (FHWA), the Southern California Association of Governments (SCAG), and Orange County Transportation Authority (OCTA) for balanced multi-modal planning. • Policy M-2.7 Evacuation Routes. Maintain and improve routes consistent with Public Safety planning.
• Policy M-3.9 New Development – Multi-Modal Facilities. Require land dedication for sidewalks and bike lanes.

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Threshold TRA-d.

Focused GPU’s key Public Safety Element policies and programs that support emergency and public safety issues include Policy PS-1.3 requiring all development in High Fire Hazard Severity Zones (HFHSZ) and Very High Fire Hazard Severity Zones (VHFHSZ) meet Fire Hazard Severity Zone standards, PS-1.5 minimizing new residential development in VHFHSZs, PS-1.9 coordinating with the Fire Department to identify and maintaining fire hazard reduction projects; PS-1.10 requiring various project design features such as requiring ongoing brush management, fuel management/modification, defensible space, fire-resistant landscaping, visible home and street addressing and signage for new development in HFHSZ and VHFHSZ; PS-1.14 requiring sufficient ingress/egress access points in all new development; Policy PS-1.15 educating community members on fire hazards, fire safety measures and various local, regional, State, and Federal assistance programs; Policy PS-1.19 maintaining mutual aid agreements with the State, County, and neighboring jurisdictions including for disaster response and evacuation assistance; PS-6.5 continuing to participate in automatic and mutual aid agreements with adjacent service providers; PS-6.6 working with the Fire Department and Police Department to define minimum standards for evacuation of residential areas; PS-6.8 linking emergency services with local hazard mitigation programs; PS-6.10 continuing to support volunteer service programs for emergency preparedness and disaster relief; and PS-6.11 maintaining and regularly upgrading a mass communications system to effectively notify people during disasters and emergencies; and PS6.12 maintaining a proactive, data-driven public safety system through recurring five-year strategic planning that aligns resources, facilities, staffing, and technology with community risk and growth.

The entire text of the policies are found in Appendix C, Brea 2050 General Plan: Goals, Policies, and Actions, as revised.
• Policy PS-1.3 City Standards. Require development in FHSZs to meet designated standards. • Policy PS-1.5 Development in VHFHSZs. Minimize new residential development in VHFHSZs.
• Policy PS-1.6 Fire Protection Plans. Require adequate plans and emergency access for VHFHSZ projects.

PEIR 3-62 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR • Policy PS-1.9 Fire Hazard Reduction Projects. Maintain community fire breaks and road clearance.
• Policy PS-1.10 Standards for New Development. Require brush management and visible signage/addressing.
• Policy PS-1.14 Access. Require sufficient ingress/egress for firefighting activities. • Policy PS-1.15 Education. Educate community on fire safety, focusing on at-risk populations. • Policy PS-1.17 Fire and Building Codes. Require compliance with current California Codes. • Policy PS-1.18 Critical Facilities. Locate new essential facilities outside of VHFHSZs when feasible.
• Policy PS-1.19 Mutual Aid. Maintain disaster response agreements with state and county partners.
• Policy PS-6.5 Automatic and Mutual Aid. Participate in aid agreements with adjacent providers.
• Policy PS-6.6 Evacuation Routes. Work with Fire/Police to define standards and assessment ranges.
• Policy PS-6.8 Collaboration. Link emergency services with mitigation programs. • Policy PS-6.10 Volunteer Service. Support programs like CERT training. • Policy PS-6.11 Warning Systems. Maintain and upgrade mass communications systems.

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This section evaluates the potential for impacts on utilities and service systems resulting from implementation of the proposed Brea 2050: Focused General Plan Update (Brea 2050 or Focused GPU) and Brea Core Specific Plan (BCSP) (together referred to as the Proposed Project or Project).

The Focused GPU does not propose specific construction project, therefore, no project-specific utilities technical studies have been prepared for the Focused GPU, and a project-level technical study is required to validate the programmatic assumptions. Impacts from the Focused GPU are addressed at a programmatic level based on the City’s Water Master Plan, Sewer Master Plan, Master Plan of Drainages, and Urban Water Management Plan. Impacts from the BCSP are addressed in part based on the following technical reports, which have been prepared in compliance with Government Code Section 65451 pertaining to content of a specific plan:

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Conditions, Focused General Plan Update, Water Supply.

The City’s water supply includes imported groundwater and surface water, as well as its own groundwater supply. The City is physically located above the La Habra Groundwater Basin, but imports most of its water from the adjacent Main San Gabriel Basin, provided by CDWC. The City also pumps groundwater from the La Habra Groundwater Basin, which provides non-potable water from one well for agricultural purposes only. As needed, the City may import surface water PEIR 3-63 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR from the Colorado River and State Water Project provided by MWD via Metropolitan Municipal Water District of Orange County.

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Conditions, Brea Core Specific Plan, Water.

The BCSP area is served by the City’s public water system, which receives imported water from the CDWC and the Metropolitan Municipal Water District of Orange County. The BCSP area lies within the City’s Pressure Zone 515, which is supplied by the Berry Street Pump Station— pumping from the Berry Street Reservoir—and by pressure-reducing valves connected to higherpressure zones. Figure 4.15-6, Water System within the Brea Core Specific Plan Area, illustrates the existing water infrastructure serving the area.

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4.15-6, Water System within the Brea Core Specific Plan Area.

Figure 4.15-6, Water System within the Brea Core Specific Plan Area, has been updated to better delineate the western boundary of the Brea Core Specific Plan. See Attachment E, Revised Figures to Draft PEIR, of this Response to Comments.

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4.15-7, Sewer System within the Brea Core Specific Plan Area.

Figure 4.15-7, Sewer System within the Brea Core Specific Plan Area, has been updated to better delineate the western boundary of the Brea Core Specific Plan. See Attachment E, Revised Figures to Draft PEIR, of this Response to Comments.

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Environmental Impacts, Threshold UTL-a
The BCSP area is served by the City’s public water system, which receives imported water from the CDWC and the Metropolitan Municipal Water District of Orange County. The BCSP area lies

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Impacts, Threshold UTL-b.

As shown in Table 4.15-3, Water Storage Analysis (Zone 750), existing storage requirements for the BCSP area is 16.48 mg, which increases slightly to 16.598 mg with future demand from implementation of the BCSP.

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Impacts, Threshold UTL-c.

Based on the analysis, at full buildout, land uses within the BCSP are projected to increase the City’s overall ADWF 0.32380753 mgd or by approximately 23.64.6 percent. This increase corresponds to approximately a 3.94.2 percent increase in flows to the OCSD Fullerton–Brea PEIR 3-64 April 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Final PEIR Trunk Sewer/Interceptor and a 15.34.9 percent increase in flows to the OCSD Rolling Hills SubTrunk/Santa Ana River Interceptor.

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Ryan Chapman, PE, City Engineer
Dave Roseman, PE, City Traffic Engineer
Jessica Newton, Senior Planner
Attachment A. Revised Appendix H, Transportation and Vehicle Miles Traveled (VMT) Impact Analysis
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April 2026

CITY OF BREA FOCUSED

GENERAL PLAN UPDATE AND
BREA CORE SPECIFIC PLAN:

TRANSPORTATION AND VEHICLE

MILES TRAVELED (VMT)

IMPACT ANALYSIS

BREA, CA
Oakland, California
Inside front cover.

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City of Brea Focused General
Plan Update and Brea Core
Specific Plan: Transportation
and Vehicle Miles Traveled
(VMT) Impact Analysis
Brea, CA
Prepared for:

De Novo Planning Group
180 East Main Street, Suite 108
Tustin, CA 92780
Prepared by:

Kittelson & Associates, Inc.
750 The City Drive South, Suite 410
Orange, CA 92868
Project Principal:

Tim Erney
Senior Principal Planner
Project Number 29637
April 2026
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CONTENTS
Executive Summary ........................................................................................................................ 2 Significant Transportation Impacts............................................................................................ 2 Introduction..................................................................................................................................... 4 Project Description...................................................................................................................... 4 Existing Conditions .......................................................................................................................... 6 Roadway Network ...................................................................................................................... 6 Transit Service .............................................................................................................................. 8 Bicycle Facilities......................................................................................................................... 11 Pedestrian Facilities................................................................................................................... 13 Freight/Goods Movement........................................................................................................ 19 Regulatory Setting ........................................................................................................................ 22 State Regulations ...................................................................................................................... 22 Regional Regulations................................................................................................................ 24 Local Regulations and Plans.................................................................................................... 26 Transportation Impact Analysis ................................................................................................... 30 Analysis Scenarios, Methodologies, and Modeling Approach ............................................ 30 Existing Vehicle Miles Traveled.................................................... Error! Bookmark not defined.

Significant Impact Thresholds................................................................................................... 31 Item 1: VMT ................................................................................................................................ 32 Item 2: Transit, Roadway, Bicycle, and Pedestrian Facilities................................................. 34 Item 3: Geometric Design and Incompatible Use Hazards .................................................. 36 Item 4: Emergency Access....................................................................................................... 37 Conclusions ................................................................................................................................... 40 Significant Transportation Impacts............................................. Error! Bookmark not defined.

City of Brea Focused General Plan Update And Brea Code Specific Plan: Transportation and Vehicle Miles Traveled (VMT) Impact Analysis
April 2026
Kittelson & Associates

LIST OF FIGURES
Figure 1: Existing Transit Service in Brea....................................................................................................................10 Figure 2: Existing Bikeway Network...........................................................................................................................12 Figure 3: 2003 General Plan Focus Areas and Brea Core......................................................................................14 Figure 4: Sidewalk Gaps in Brea Core Area ............................................................................................................18 Figure 5: Existing Truck Routes...................................................................................................................................20

LIST OF TABLES
Table 1: Transit Service in Brea....................................................................................................................................9 Table 2: Brea City Shuttle and Van Service...............................................................................................................9 Table 3: Existing Truck Routes....................................................................................................................................19 Table 4: Citywide VMT per Service Population Analysis.........................................................................................32 Table 5: Link-Level Boundary Citywide VMT per Service Population Threshold...................................................33 Table 6: VMT per Service Population Threshold for the Brea Core Specific Plan ................................................33

APPENDICES
Appendix 1 — VMT Technical Data
Section 1 — Executive Summary
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EXECUTIVE SUMMARY
The City of Brea is in the northeastern corner of Orange County, where the boundaries of Orange, Los Angeles, and San Bernardino Counties converge. The City is bordered by unincorporated Orange County land and the Los Angeles County line to the north; Chino Hills State Park and the San Bernardino County line to the east; the Cities of Yorba Linda, Placentia, and Fullerton to the south; and the City of La Habra to the west. The Orange Freeway (State Route [SR] 57) bisects the City from north to south. The three major east–west roadways are Imperial Highway (SR 90), Carbon Canyon Road (SR 142), and Lambert Road The City is preparing the Focused General Plan Update, which will introduce a Mobility Element (replacing the existing Circulation Element) addressing active transportation, complete streets, automobile and truck traffic, intersection and roadway vehicular level of service (LOS) operations, and transit options for communities reliant on public transportation. The Focused General Plan will serve the City through 2050.

The Plan proposes a mix of uses. Within the planning, buildout of the proposed General Plan Land Use Element could yield a total of up to 23,736 housing units, a population of 67,647 people, approximately

30.59 million square feet of non-residential square footage, and 73,709 jobs. This represents development growth above existing development conditions of approximately 7,390 new housing units, 21,062 people,

9.1 million square feet of new non-residential square footage, and 21,772 jobs.

Kittelson & Associates (“Kittelson”) has prepared a transportation analysis of the Plan. Below is a summary of results of the transportation analysis conducted for the Plan, including any significant impact findings and recommended improvements.

SIGNIFICANT TRANSPORTATION IMPACT

FINDINGS
The California Environmental Quality Act (CEQA) transportation impact analysis of the General Plan Update determined that impacts would be less than significant for the following topics:
 Vehicle miles traveled (VMT)
 Transit, roadway, bicycle, and pedestrian facilities
 Geometric design and incompatible use hazards
 Emergency access
Section 2 — Introduction
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INTRODUCTION
This report documents the California Environmental Quality Act (CEQA) transportation assessments for the Brea Focused General Plan Update and Brea Core Specific Plan, and summarizes the methodology, findings, and conclusions of the analysis.

PROJECT DESCRIPTION
The City of Brea is 12.4 square miles in northern Orange County, California. The city is bordered by the City of La Habra to the west, the City of Fullerton to the southwest, the City of Placentia to the south, Yorba Linda to the east, and Daimond Bar to the north. The City is preparing the Focused General Plan Update, which will introduce a Mobility Element (replacing the existing Circulation Element) addressing active transportation, complete streets, automobile and truck traffic, intersection and roadway vehicular level of service (LOS) operations, and transit options for communities reliant on public transportation. The Focused General Plan will serve the City through 2050.

Note that this study examines citywide buildout estimates that represent a hypothetical scenario of development in the City. Based on historical development patterns in Brea, it is likelier that development would occur at levels lower than the buildout estimate, due to factors such as standards governing density and floor area ratio, and physical factors such as topography.

Section 3 — Existing Conditions
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EXISTING CONDITIONS
This section summarizes existing mobility conditions in the City of Brea related to vehicles, transit, bicycles, pedestrians, freight/goods movement, and traffic operations.

ROADWAY NETWORK
The roadway network in the City contains three state routes: State Route 57 (SR 57), Imperial Highway (SR 90), and Carbon Canyon Road-Valencia Avenue (SR 142). These routes, along with other significant roadways, in the City, are described below.

STATE ROUTE 57 FREEWAY
State Route 57 (SR 57) is a facility under Caltrans’ jurisdiction that serves as a significant north-west linkage between Los Angeles County and Orange County, connecting with Interstate 5 (I-5) and State Route 22 (SR-22) to the south and Interstate 210 (I-210), Interstate 10 (I-10) and State Route 60 (SR 60) to the north.

Within Brea, SR 57 is a 12-lane freeway with six lanes in each direction with a speed limit of 65 miles per hour.

In Brea, SR 57 has interchanges at Lambert Road, Imperial Highway, and Tonner Canyon Road.

IMPERIAL HIGHWAY
Imperial Highway (SR 90) is classified as a major arterial within Brea, carrying significant vehicle volumes in an east-west direction. Imperial Highway primarily supports through-traffic with access to multiple residential and commercial destinations. With a speed limit of 40 miles per hour, it features two to three travel lanes on each side of the street, primarily divided by a center turn lane. All major intersections along Imperial Highway have pedestrian crosswalks and pedestrian signal heads; in addition, sidewalks are provided along the corridor. Additionally, Imperial Highway is designated as a Smart Street within the MPAH. A “Smart Street” includes various traffic-carrying capacity enhancements to facilitate traffic flow. In particular, modifications to Imperial Highway included restriping from four to six lanes, modification of medians at intersections, addition of bus pads and turnouts, and re-timed traffic signals to improve coordination.1 These modifications help to address traffic congestion and improve operations on the road.

CARBON CANYON ROAD
Carbon Canyon Road (SR 142) is under Caltrans’ jurisdiction and is classified as a primary arterial from Valencia Avenue to Brea Hills Avenue, and as a collector from Brea Hills Avenue east to the city and county boundary. The roadway travels in the east-west direction and provides direct access to Olinda Village and cities to the east such as Chino Hills, Chino, and Eastvale. The roadway is rural in character, with one lane in each direction and no center divider. The roadway does not offer consistent pedestrian crosswalks as there is little pedestrian demand.

VALENCIA AVENUE
Also classified as SR 142, Valencia Avenue is under Caltrans’ jurisdiction between Lambert Road / Carbon Canyon Road and Imperial Highway (SR 90). This portion is classified as a primary arterial. The roadway travels in the north-south direction and provides a link between northeast and southeast Brea, as well as to the City of Placentia in the south. Valencia Avenue is a four-lane divided roadway for much of its length and features continuous sidewalks along the east side of the roadway, with sporadic sidewalks on its west side. The roadway includes pedestrian crosswalks at every signalized intersection. 1 OCTA, “Destination 2035”, Detailed Year 2035 Baseline Project List, 2010 City of Brea Focused General Plan Update And Brea Code Specific Plan: Transportation Impact Analysis April 2026 Existing Conditions
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BREA BOULEVARD
Brea Boulevard is classified as a primary arterial crossing the City in the north-south direction. This roadway accommodates a combination of uses, including commercial and mixed-use areas with a speed limit of 40 miles per hour. It features two travel lanes on each side of a median along with a left-turn lane at multiple locations. On-street parking spaces are available in most parts of this roadway. All major intersections along Brea Boulevard have pedestrian crosswalks and pedestrian signal heads; in addition, there are sidewalks along the corridor.

LAMBERT ROAD
Lambert Road is classified as a major arterial crossing the city in the east-west direction. This roadway primarily supports through-traffic with a speed limit of 40 miles per hour. It features two to three travel lanes on each side of the street alternating between a median and a center turn lane. Several intersections along Lambert Road have pedestrian crosswalks and pedestrian signal heads; in addition, there are sidewalks along the corridor.

OTHER KEY ROADWAYS
Other arterial roadways in Brea include State College Boulevard, Central Avenue, Puente Street, and Birch Street. Collector streets include Elm Street, Palm Street, Whittier Avenue, Sante Fe Road, and Placentia Avenue.

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TRANSIT SERVICE
Public transit service in Brea is provided by fixed-route bus service operated by Orange County Transportation Authority (OCTA) and Foothill Transit, plus local services provided by the City of Brea. All bus routes that run operate within the City provide service to the Brea Mall Transit Center, located off State College Boulevard between Imperial Highway and Lambert Road.

OCTA is the major transit agency serving Orange County, with services including fixed-route buses and paratransit. It provides approximately 51 fixed bus routes, including local, community, rapid, and StationLink services on a countywide basis. OCTA bus network spans most of Orange County, connecting major cities, employment centers, transit hubs, and points of interest. OCTA provides connections to other municipalities and the rest of the region through transit nodes and other intermodal hubs. Systemwide, buses generally operate on 15 to 30-minute intervals during peak hours, with less frequent service during off-peak times and on weekends.

Currently, there are four OCTA bus routes that operate within the City of Brea2:
/ Route 57 which operates between Brea and Newport Beach. / Route 59 which operates between Brea and Irvine
/ Route 129, a community route that operates between Brea and Buena Park. / Route 143, which operates from La Habra to Brea.

In addition, OCTA's ACCESS paratransit service serves those with disabilities.

Foothill Transit operates a fleet of over 300 buses throughout Southern California’s San Gabriel Valley and Pomona Valley. Within Brea, Foothill Transit operates one route, typically on a one-hour schedule:
/ Route 286 which runs between Pomona and Brea.3
In addition to the routes provided by OCTA and Foothill Transit, the City of Brea provides local transportation services. The City offers free shuttle transportation for seniors, providing rides to the Senior Center and scheduled shopping trips. The shuttle operates Monday to Friday, requiring applicants to be 60+ years old and Brea residents. Reservations for rides must be made one business day in advance. The shuttle offers morning pick-ups between 8:15 AM and 10:00 AM. and return options after lunch. Scheduled shopping trips to various stores are available on specific days. Additionally, a new van service called “Seniors on the Go!” operates Tuesday to Friday offering rides for personal errands and community visits within Orange County for a small fee.4
2 Orange County Transportation Authority, “Routes and Schedules”, last accessed April 2026. https://www.octa.net/getting-around/bus/oc-bus/routes-and-schedules/routes-and-schedules 3 Foothill Transit, “Schedules and Maps”, last accessed May 2024. https://www.foothilltransit.org/buslines/timetables
4 City of Brea, “Transportation”, last accessed December 2025. https://www.cityofbrea.gov/1105/Transportation
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Table 1 and Table 2 summarize the transit service in Brea and Figure 1 illustrates the routes.

Table 1: Transit Service in Brea
Route Route Type Operator Route Description
OCTA Route 57
Brea- Newport
Beach
Local Fixed
Route
OCTA Travels from Brea to Newport Beach via State
College Boulevard / Bristol Street.

OCTA Route 59
Brea - Irvine
Local Fixed
Route
OCTA Travels from Brea to Irvine, stopping at the Brea
Mall Area, via Birch Street / Kraemer Boulevard /
Glassell Street / Grand Avenue / Von Karman
Avenue.

OCTA Route 129
Brea – Buena Park
Community
Route
OCTA Travels from Brea and Buena Park via Artesia
Boulevard / Beach Boulevard / La Habra Boulevard
/ Brea Boulevard / Birch Street.

OCTA Route 143
La Habra - Brea
Community
Route
OCTA Travels from La Habra to Brea via Whittier
Boulevard / Harbor Boulevard / Brea Boulevard /
Birch Street.

Foothill Route 286
Brea - Pomona
Community
Route
Foothill
Transit
Travels from Brea to Pomona via Diamond Bar
Boulevard / W Mission Boulevard / S Garey Avenue.

Sources: OCTA, and Foothill Transit (information accessed April 2026) Table 2: Brea City Shuttle and Van Service
Route Route Type Operator Route Description
Brea Senior Center
Shuttle
City Shuttle City of Brea Free shuttle transportation from the Senior Center to pre-scheduled shopping. Monday to Friday.

Local Scheduled
Shopping Trips
City Shuttle City of Brea Mondays, 12:45 PM – Walmart Shopping First Wednesday of the month 12:45 PM –
Ralphs/Rite Aid Shopping
Third Wednesday of the month, 12:45 PM –
Albertsons/Trader Joe’s Shopping
Seniors on the Go! City Van
Service
City of Brea For $2 one way and with a ride reservation, with a cap of 5 miles, this service can take Brea residents
ages 60 and over where they need to go.

Operates Tuesday to Friday from 9:00 AM to 12:30
PM.

Source: City of Brea (information accessed May 2024)
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Figure 1: Existing Transit Service in Brea
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BICYCLE FACILITIES
The California Department of Transportation (Caltrans) classifies and defines bicycle facilities. Caltrans designates four classes of bicycle facilities: Classes I, II, III, and IV. The illustration below illustrates and describes the bicycle facility classifications.

Existing bikeways in the City are shown in Figure 2.

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Figure 2: Existing Bikeway Network
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PEDESTRIAN FACILITIES
Throughout the City pedestrian facilities include crosswalks, pedestrian crossing signals, lighting, street trees, and curb ramps. The pedestrian network is comprised of sidewalks and multi-use paths, allowing residents to walk to their destination along dedicated paths and reducing conflicts with other travel modes. Routes to major destinations, such as schools and public facilities, attract youth and are important within the pedestrian network. Throughout the City, opportunities exist to improve sidewalk connectivity, installing pedestrian crossings, and maintaining consistency with pedestrian amenities.

Sidewalks are generally included on most roadways within the City; however, there are gaps in some of the industrial areas of Brea. At locations where sidewalks are provided, the City’s Municipal Code requires sidewalks to be a minimum of 4 feet wide in residential areas, and a minimum of 5 feet wide in a commercial or industrial area, with additional ADA, curb-ramp and curb requirements.

The following is an overview of the typical pedestrian facilities across the City, separated by the surrounding land uses and land use patterns. This examination encompasses a diverse array of areas, providing information on the accessibility and infrastructure designed to facilitate pedestrian movements throughout these specific locales. This section describes pedestrian facilities along roadways, summarized within the City’s focus areas as defined in the 2003 Brea General Plan and as proposed through the new Brea Core Specific Plan, which are listed below and shown in Figure 3. / Northwest Neighborhoods
/ Carbon Canyon and Olinda Village
/ Hillsides and Unincorporated Brea
/ Southeast Brea
/ Brea Core Area (which includes portions of Historic Brea and Downtown Brea delineated in the 2003 General Plan
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Figure 3: 2003 General Plan Focus Areas and Brea Core
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NORTHWEST NEIGHBORHOODS
The northwest area of Brea contains a mix of residential neighborhoods, including several senior housing developments. Most of the homes were built between the 1950s and 1970s, with some newer tracts built in the 1980s and 1990s. The neighborhoods typically feature sidewalks on both sides of the roadway, with occasional sections that lack sidewalks. Pedestrian amenities are provided along the sidewalks such as curb ramps. Streetlights can be found throughout the area and are consistently spaced throughout.

Puente Street Candlewood Street

CARBON CANYON AND OLINDA VILLAGE
Carbon Canyon and Olinda Village have less developed pedestrian infrastructure. Olinda Village is a distinct residential neighborhood within Carbon Canyon. The rural character of the area, together with the development constraints imposed by topography, geologic conditions, and the configuration of Carbon Canyon Road limit land use opportunities within Carbon Canyon. The majority of Carbon Canyon Road does not contain sidewalks and crosswalks. Pedestrian travel occurs along the paved roadway shoulder or unpaved sections. Although there are few pedestrian crossings and signage in rural areas, the rural setting lacks sufficient streetlights and pedestrian-friendly lighting.

Olinda Village Carbon Canyon Road
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HILLSIDES AND UNINCORPORATED BREA
The hillsides and unincorporated Brea area refer to pockets of land where the uses are currently undeveloped and include some areas north of Lambert Road up to the Los Angeles County border.

Roadways in these areas do not contain sidewalks or crosswalks, with limited pedestrian demand.

Brea Canyon Road Valencia Ave

SOUTHEAST BREA
Southeast Brea includes the former oil-use related and agricultural properties that have since transitioned to residential uses. Many of these residences are part of La Floresta, a master-planned community. La Floresta has a well-developed pedestrian network with complete sidewalk connectivity, landscaping, crosswalks, and curb ramps.

La Floresta Street Terrazo Drive
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BREA CORE AREA
In the Brea Core Area specifically, sidewalks exist along the majority of roadways. Few gaps in the sidewalks currently exist, such as portions of Lambert Road, Berry Road, and State College Boulevard, as highlighted in Figure 4. These gaps are small and typically occur in industrial areas that tend to have lower pedestrian demand, and some gaps occur only along one side of the street, with sidewalk connectivity available on the other side. In addition, several streets that encircle the Brea Mall are missing sidewalks. Similarly, there are gaps in lighting and crossing infrastructure in the Plan Area, as many sidewalks do not provide pedestrian buffers, such as street trees and landscaping, which improve perceived safety.

Within the Brea Core Area, multiple intersections have high visibility crosswalks, including most intersections along Imperial Highway, indicating a unique place and high pedestrian volumes.

Poplar Avenue Birch Street
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Figure 4: Sidewalk Gaps in Brea Core Area
Source: Kittelson and Associates, 2024
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FREIGHT/GOODS MOVEMENT
Freight and goods movement utilize several of the major routes in the City’s network. As illustrated in Figure 5, trucks move along Central Avenue, State College Boulevard, Imperial Highway, Lambert Road, Birch Street, Puente Street, Berry Street, Brea Boulevard, and Valencia Avenue. Certain roads are classified as restricted truck routes, which prohibit trucks exceeding a maximum gross weight of 6,000 pounds from accessing from 8:00 PM to 6:00 AM. Carbon Canyon Road, east of Valenica Avenue, is restricted to trucks with four axles or fewer.

One of the largest generators of truck activity on streets within Brea is the Olinda Alpha Landfill, located in the northeast of the City. The 565-acre landfill processes nearly 7,000 tons per day, and is a significant generator of commercial and public disposal truck trips.5 Access to the Olinda Alpha Landfill is provided via Valencia Avenue, north of Lambert Road. In addition, the western portion of the City south of Central Avenue and west of Tamarack Avenue, as well as the southeast corner of the City south of Birch Street and east of Kraemer Boulevard have goods movement activities generated by the warehousing, light industrial, and logistic uses.

The Surface Transportation Assistance Act (STAA) of 1982 defines a network of state facilities as truck routes which accommodate large trucks. SR 57, which runs through Brea, is a STAA-designated truck route. In addition, the City of Brea also designates multiple other roads as truck routes. These routes are described in Table 3.

Table 3: Existing Truck Routes
On Road From Road To Road Direction
of Travel
SR 57 Freeway Southern City Boundary Northern City
Boundary
N/S
Brea Boulevard Southern City Boundary Northern City
Boundary
N/S
Puente Street Southern City Boundary Whitter Avenue N/S Berry Street Imperial Highway Central Avenue N/S
Kraemer Boulevard Southern City Boundary Imperial Highway N/S Valencia Avenue Southern City Boundary Northern City
Boundary
N/S
State College Boulevard Brea Boulevard Southern City
Boundary
N/S
Nasa Street/Enterprise Street/Ranger
Street/Voyager Avenue
Valencia Avenue Birch Street N/S/E/W
Imperial Highway Western City Boundary Eastern City Boundary E/W Lambert Road Western City Boundary State College
Boulevard
E/W
Central Avenue Western City Boundary Brea Boulevard E/W Carbon Canyon Road Valencia Avenue Eastern City Boundary E/W Birch Street Voyager Avenue Valencia Avenue E/W
Source: City of Brea, Truck Route Map
5 OC Landfills, “Olinda Landfill”, https://oclandfills.com/landfills/olinda-landfill City of Brea Focused General Plan Update And Brea Code Specific Plan: Transportation Impact Analysis April 2026 Existing Conditions
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Figure 5: Existing Truck Routes
Section 4 — Regulatory Setting
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REGULATORY SETTING
This section summarizes applicable federal, state, regional, and local plans pertinent to the City of Brea. This information provides a context for the transportation impact discussion related to the project’s consistency with applicable policies, plans, laws, and regulations.

STATE REGULATIONS

CALIFORNIA DEPARTMENT OF TRANSPORTATION
The California Department of Transportation (Caltrans) manages the operation of state highways and is the primary state agency responsible for transportation issues. One of its duties is the construction and maintenance of the state highway system. Caltrans approves the planning, design, and construction of improvements for all state-controlled facilities within the City. Freeway segments, freeway ramps and intersections associated with freeway on- and off-ramps fall under Caltrans jurisdiction.

State highways in the City include State Route (SR) 57, the City’s main north/south limited access thruway, Imperial Highway (SR 90), which runs east/west across the southern section of the City, and SR 142, which runs northwest to San Bernardino County along Valencia Avenue and Carbon Canyon Road.

Caltrans has developed procedures to determine if state-controlled facilities require improvements. For projects that may physically affect facilities under its administration, Caltrans requires encroachment permits before any construction work may be undertaken. For projects that would not physically affect facilities but may influence traffic flow and operational deficiencies at such facilities, Caltrans may recommend measures to address adverse effects from traffic caused by such projects. Caltrans also prepares comprehensive planning documents, including Corridor System Management Plans and Transportation Concept Reports, which are long-range planning documents that establish a planning concept for state facilities.

Caltrans updated its guidance in 2020 to include metrics to evaluate transportation impacts based on vehicle miles traveled (VMT) and no longer sets a minimum acceptable level of service (LOS) for its facilities.

Based on the Caltrans Vehicle Miles Traveled-Focused Transportation Impact Study Guide, Caltrans has transitioned from LOS performance standards to VMT to identify significant impacts. “For land use projects and plans, automobile delay is no longer considered a significant impact on the environment under CEQA (SB 743, 2013). Caltrans review of land use projects and plans is focused on a VMT metric, consistent with changes to the CEQA Guidelines (California Code of Regulations Section 15064.3(b)(1)). This VMT-focused TISG provides a foundation for review of how lead agencies apply the VMT metric to CEQA project analysis.

Beyond or in addition to the use of the VMT metric, determining how the State Highway System may otherwise be affected by a land use project may still be necessary at times, particularly as it relates to the safety of the traveling public. Additional future guidance will include the basis for requesting transportation impact analysis that is not based on VMT. This guidance will include a simplified safety analysis approach that reduces risks to all road users and focuses on multi-modal conflict analysis as well as access management issues. With this guidance the Department will transition away from requesting LOS or other vehicle operations analyses of land use projects.” Note that LOS analyses may be required by Caltrans for local operational assessments (e.g., to support a queueing analysis at ramp terminus intersections).

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ASSEMBLY BILL 32, SENATE BILL 32, AND SENATE BILL 375
Assembly Bill (AB) 32, also known as the Global Warming Solutions Act of 2006, committed California to reducing greenhouse gas (GHG) emissions to 1990 levels by 2020. In 2016, SB 32 added a new target:
reducing statewide emissions to 40 percent below 1990 levels by 2030.

SB 375 provides guidance for curbing emissions from cars and light trucks to help California comply with AB

32. There are five major components to SB 375:
/ Air Resources Board (ARB) will guide the adoption of GHG emission targets to be met by each Metropolitan Planning Organization (MPO) in the state.
/ MPOs are required to create a Sustainable Communities Strategy (SCS) that provides a plan for meeting these regional targets. The SCS must be consistent with the Regional Transportation Plan (RTP). / Regional housing elements and transportation plans must be synchronized on eight-year schedules.

Also, the SCS and Regional Housing Needs Assessment (RHNA) must be consistent with each other. / CEQA is streamlined for preferred development types such as mixed-use projects and transit-oriented developments (TODs) if they meet specific requirements. / MPOs must use transportation and air emission modeling methodologies consistent with California Transportation Commission (CTC) guidelines.

CALIFORNIA COMPLETE STREETS ACT OF 2008 (AB 1358)
Originally passed in 2008, California’s Complete Streets Act took effect in 2011 and requires local jurisdictions to plan for land use transportation policies that reflect a “complete streets” approach to mobility. “Complete streets” comprises a suite of policies and street design guidelines which provide for the needs of all road users, including pedestrians, bicyclists, transit operators and riders, children, the elderly, and the disabled. From 2011 onward, any local jurisdiction—county or city—that undertakes a substantive update of the circulation element of its general plan must consider “complete streets” and incorporate corresponding policies and programs. In 2010, OPR released guidelines for compliance with this legislation which provide direction on how circulation elements can best plan for a variety of travel modes such as transit, walking, bicycling, and freight.

On December 7, 2021, Caltrans announced a new policy for all new transportation projects it funds or oversees to include “complete street” features that provide safe and accessible options for people walking, biking, and taking transit. This policy will expand the availability of sustainable transportation options to help meet the State’s climate, health, and equity goals.

SENATE BILL 743
Senate Bill (SB) 743, which was signed into law on September 27, 2013 and became mandatory on July 2, 2020, fundamentally changed transportation impact analysis as part of California Environmental Quality Act (CEQA). In its Technical Advisory on Evaluating Transportation Impacts in CEQA, the California Governor’s Office of Planning and Research (OPR) provided recommendations for jurisdictions to implement SB 743-compliant transportation analyses. OPR’s recommendations are not binding and lead agencies ultimately have the discretion to set or apply their own significance thresholds, provided they are based on substantial evidence. CEQA Guidelines Section 15064.3 describes how transportation impacts are to be analyzed under SB 743. It states that in general, transportation impacts are best measured by evaluating the project’s vehicle miles traveled. For land use projects, vehicle miles travelled (VMT) exceeding an applicable threshold of significance may indicate a significant impact.

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In October 2020, Brea adopted a resolution that conforms with SB 743, transitioning to a VMT-based method of identifying transportation impacts for CEQA compliance and committing to meet requirements of all future revisions to CEQA, consistent with the guidance provided by the State. The City of Brea Transportation Impact Assessment (TIA) guidelines require a VMT analysis to be conducted for land use projects as deemed necessary by the City and applies to projects that have the potential to increase the baseline VMT for the City of Brea.6
SENATE BILL 99, ASSEMBLY BILL 101
The California Active Transportation Program (ATP), established by Senate Bill 99 and Assembly Bill 101 in 2013, aims to promote active modes of transportation like biking and walking. It combines various federal and state transportation programs such as the Transportation Alternatives Program, Bicycle Transportation Account, and State Safe Routes to School into one cohesive initiative. The goal is to elevate California as a frontrunner in active transportation efforts.

REGIONAL REGULATIONS

SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS (SCAG)
Founded in 1965, the Southern California Association of Governments (SCAG) is a Joint Powers Authority comprising local governments and agencies addressing regional issues. Designated both as a Metropolitan Planning Organization (MPO) under federal law and as a Regional Transportation Planning Agency and a Council of Governments under state law, SCAG covers six counties and 191 cities over 38,000 square miles.

SCAG develops long-range regional transportation plans, housing allocations, and contributes to air quality management plans.

On April 4, 2024, SCAG’s Regional Council adopted Connect SoCal (2024 – 2050 Regional Transportation Plan/Sustainable Communities Strategy) for federal transportation conformity purposes only. Connect SoCal outlines more than $750 billion in transportation system investments through 2050.

SCAG created the SoCal Transportation Safety Resource Hub to assist local jurisdictions in advancing transportation safety and meeting annual safety targets. It serves as a centralized source for SCAG's safety programs, data, reports, and resources. The hub includes:
/ Regional transportation safety goals and targets summary / Overview of SCAG's existing transportation safety conditions / Interactive map of SCAG's Regional High Injury Network (HIN) with downloadable data / Resources for local jurisdictions to develop their own HIN / Opportunities to engage in SCAG's ongoing safety efforts / Access to data, tools, funding, and resources from SCAG and other organizations. 6 City of Brea, “Traffic Impact Analysis Guidelines – for Vehicle Miles Travelled and Level of Service Assessment”, 2020.

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ORANGE COUNTY TRANSPORTATION AUTHORITY
The Orange County Transportation Authority (OCTA) coordinates transportation planning efforts throughout Orange County and programs funding for project implementation. OCTA leads the following ongoing planning efforts:
/ OCTA oversees Measure M2, the countywide sales tax measure to fund transportation improvements.

Also known as OC GO, this program includes freeway, streets and roads, transit, and environmental projects to help relieve congestion, improve street conditions, expand transit services, synchronize traffic signals, reduce transportation costs for seniors and people with disabilities, and reduce transportation-related air and water pollution.
/ OCTA prepares the Congestion Management Program (CMP), which identifies strategies to address congestion on the County’s CMP network; which includes State highways and principal arterials. CMP Guidelines require analysis of the CMP network in order to measure congestion and to determine how local governments meet CMP standards and requirements. There are four CMP intersections in the City:
o State Route (SR) 57 northbound ramps / Imperial Highway (SR 90) o SR 57 southbound ramps / Imperial Highway
o State College Boulevard / Imperial Highway
o Valencia Avenue / Imperial Highway
/ OCTA administers the Master Plan of Arterial Highways (MPAH), which was established in 1956 to ensure that the County’s regional arterial highway network would be planned, developed, and preserved in order to supplement the freeway system. The MPAH defines the intended functions and carrying capacities of regional roads in the County. In order to be eligible for Measure M2 (also known as OC Go) funding, a city’s General Plan Circulation Element must be consistent with the MPAH; specifically, local Circulation Elements must maintain an equivalent number of minimum through lanes on each arterial highway that is included as part of the MPAH.
/ OCTA’s Long Range Transportation Plan (LRTP) is a long-range policy document that assesses the County’s long-term transportation system and identifies regional projects in the County, which address future population, housing, and employment needs. The LRTP also serves as the County’s local input to SCAG’s broader RTP/SCS for Southern California. OCTA also plans, manages, and operates local transit service within Orange County.

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LOCAL REGULATIONS AND PLANS
All roadways within the City are under the jurisdiction of the City, with the exception of Imperial Highway (SR 90), SR 57, and Carbon Canyon Road / Valencia Avenue (SR 142) which are under Caltrans’ jurisdiction.7
2003 BREA GENERAL PLAN
The Brea General Plan, adopted in 2003, articulates the collective vision of the community for its future and establishes a foundational framework for guiding decisions on development, resource management, public safety, public services, and community well-being. Crafted through collaboration among residents, businesses, educators, and officials, the plan reflects the values and aspirations of Brea. The General Plan Annual Progress Report offers a yearly update on the implementation of its elements, covering activities from January to December. It highlights ongoing projects and programs aimed at enhancing Brea's appeal as a desirable place to live, work, and enjoy leisure activities. The General Plan emphasizes preserving the City's unique natural and aesthetic attributes while adapting to regional growth and evolving community needs. It serves as a policy compass, aligning actions with Brea's overarching vision of making Brea a great place to live, work, learn, and play while respecting natural resources, fostering economic vitality, and enhancing quality of life.

The existing City of Brea General Plan identifies the following goals and visions related to mobility.8 / To improve access to transportation, including accessible public transportation to Northwest neighborhoods;
/ To Improve transportation, pedestrian, and visual connections between Downtown and the rest of the community;
/ To provide for an extensive, integrated, and safe bicycle, hiking, and pedestrian network throughout the community, and to make Brea a pedestrian-friendly community; / To ensure convenient alternative transportation modes allow for an integrated approach to addressing traffic problems;
/ To maintain an effective regional transportation network; / To provide a safe and efficient circulation system that meets the needs of the community; and / To promote the use of alternative transportation modes such as transit, bicycling, and walking.

The current Brea General Plan makes reference to a Growth Management Element, which requires traffic LOS standards. The general target standard is LOS D for intersections and recognizes that lower LOS standards for certain intersections in urbanized areas may be appropriate if such affected roadways carry a high proportion of regional traffic.
7 City of Brea, “Traffic”, accessed May 2024, https://www.ci.brea.ca.us/1139/Traffic 8 City of Brea, “General Plan”, 2003 City of Brea Focused General Plan Update And Brea Code Specific Plan: Transportation Impact Analysis April 2026 Regulatory Setting
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CITY OF BREA CONNECTING THE CORE|ACTIVE TRANSPORTATION
PLAN (2017)
The Brea Connecting the Core Active Transportation Plan (ATP) was developed as phase one of the Brea Core Specific Plan effort, to study cyclist and pedestrian safety along major corridors and to explore ways to improve the safety and experience for cyclists and pedestrians within Brea’s Core Area. The plan identified mobility challenges and proposed solutions to encourage walking and biking, emphasizing access for all, safety enhancements, and creative design solutions. The plan was funded through a grant from Caltrans and was completed in 2020. The Brea Connecting the Core Active Transportation Plan will allow staff to pursue grant funding for pedestrian and bicycle improvements in the Brea Core Area.

The plan will also serve as a component to help update the General Plan and the Brea Core Specific Plan with respect to circulation, urban design, and bikeways. Major components of the ATP include:
/ Three core elements with goals and policies for each:
 Provide access for all users
 Focus on safety enhancements
 Institute creative design solutions
/ A toolbox of improvements outlining facility types to improve multimodal transportation infrastructure. / A detailed set of improvement options for ten (10) corridors in the Brea Core Area included opportunities and recommendations for potential improvements. / Steps to implement the ATP including pursuit of funding, regional coordination, environmental review, community outreach, and improvement designs.9
The preparation of the new Specific Plan for the Brea Core Area will help to implement the City’s long-term vision for this unique area of the City by providing specific direction for development. The Brea Core Specific Plan will incorporate recommendations from the Connecting the Core ATP in order to improve the safety and experience of cyclist and pedestrians in the area, and will build upon findings in the ATP report to address improvements to streets, sidewalks, and public spaces. The plan will evaluate and establish land use designation, zoning regulations, and design guidelines for future change to existing uses and new development. The plan provides an opportunity to continue the Brea Envisions conversation and dig deeper into the community’s values and vision for the heart of the City.

BREA CAPITAL IMPROVEMENT PROGRAM (CIP)
Brea’s Public Works Department plans, designs, and implements capital projects to improve and preserve community assets. The goals of the CIP are to enhance the community's quality of life, ensure a safe environment, and improve transportation, utilities, and City facilities. The CIP budget plan is both a planning and implementation document. The current seven-year CIP includes the appropriation of funds for Fiscal Year (FY) 2025-26 and FY 2026-27 with a planning horizon through 2032. The remaining five years of the CIP are not a commitment of funds but used as a long-range planning tool for subsequent investments in the City's infrastructure. There are currently 72 projects in the current 7-year CIP budget plan estimated at nearly $112 million. The CIP categories include Street Improvements, Storm Drain Improvements, Traffic Safety Enhancements, Water Improvements, Sewer Improvements, Facility Improvements, and Golf Course Improvements. Programmed transportation-related improvements include roadway rehabilitation; interchange, street and intersection improvements; traffic signal equipment upgrades; traffic signal synchronization; traffic calming improvements; and sidewalk replacement and installation. 9 City of Brea, “Brea Connecting the Core Active Transportation Plan”, January 2020.

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CITY OF BREA TRANSPORTATION IMPACT ANALYSIS GUIDELINES (2020) State and federal laws require the correlation between General Plan Land Use Element building intensities and the Circulation Element transportation network capacities. The City of Brea established Transportation Impact Analysis (TIA) Guidelines to outline the specific steps for complying with the new CEQA expectations for VMT analysis and the applicable general plan consistency requirements. A TIA is required by the City of Brea so that the impact of proposed land use modifications and development on the existing and future circulation system can be adequately assessed, and to ensure that the CEQA and relevant CMP laws and guidelines are met.10 The City's TIA Guidelines require LOS analysis outside of CEQA to determine if a new development project would result in congestion and be inconsistent with the LOS goals in the General Plan.

As part of the North Orange County Collaborative, Brea released the North Orange County Collaborative (NOCC+) Traffic Study Screening Tool in 2020.11 The tool assessed a project’s need for further VMT analysis based on three screenings for Transit Priority Areas (TPA), Low VMT Areas, and Project Types. The City has designated the Brea Mall Transit Center as a TPA. Low VMT Areas are defined as Traffic Analysis Zones [TAZs] lower than 15% of the citywide average. As of 2020, the City of Brea General Plan buildout VMT was calculated to be 29.9 VMT per service population.12
It should be noted that CEQA requirements change as the CEQA Guidelines are periodically updated and/or legal opinions are rendered that change how analysis is completed. As such, the City of Brea will continually review their guidelines for applicability, and consultants should contact the City to ensure that they are applying the most recent guidelines for project impact assessment.13 10 California Governor’s Office of Planning Research, “Technical Advisory on Evaluating Transportation Impacts in CEQA”, December 2018. 11 City of Brea, “Transportation Impact Analysis (TIA) Guidelines”, September 2020; NOCC+ is based on data from 2020 and utilizes OCTAM version 5. As such, it may require updates to align with current best practices, the latest version of OCTAM, and subsequent legal rulings. 12 Ibid.
13 Ibid.

Section 5 — Transportation Impact Analysis
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TRANSPORTATION IMPACT ANALYSIS
This transportation impact analysis assesses Brea’s transportation system relative to the State’s CEQA guidelines.

ANALYSIS SCENARIOS, METHODOLOGIES, AND

MODELING APPROACH
This section summarizes the approach to the transportation analyses, including VMT, based on discussions with City staff and consistent with the City of Brea Transportation Impact Analysis Guidelines.14

ANALYSIS SCENARIOS
As part of this study, the following scenarios were developed and analyzed:
 Baseline Conditions – This scenario represents existing conditions at the time of the Notice of Preparation.
 Baseline Plus Project Conditions – This scenario represents the updated General Plan’s land uses being added to the City’s TAZs.
 General Plan No Buildout (2050) – This scenario represents the land uses, densities, and circulation network in the City with the current General Plan.
 General Plan Buildout (2050) Conditions – This scenario represents the buildout land uses, densities, and circulation network changes in the City as defined by the proposed General Plan Update.

The General Plan Buildout (2050) condition incorporates citywide buildout estimates that represent a hypothetical scenario of development in the City required for CEQA. Based on historical development patterns in Brea, it is likelier that development would occur at levels lower than the buildout estimate, due to factors such as standards governing density and floor area ratio, and physical factors such as topography.

ANALYSIS METHODOLOGIES
The appropriate metrics, methodologies, and standards for the analysis were developed based on the City’s guidelines and in consultation with City staff.

CEQA VMT Analysis
Senate Bill 743 (SB 743) was signed into law in September 2013. It required changes to the CEQA Guidelines regarding the analysis of transportation impacts. Historically, CEQA transportation analyses of individual projects determined impacts in the circulation system in terms of roadway delay and/or capacity at specific locations. SB 743 changes included the elimination of auto delay, level of service (LOS), and other similar measures of vehicular capacity or traffic congestion as a basis for determining significant impacts and identified vehicle miles traveled (VMT) as the most appropriate metric to evaluate a project’s significant transportation impacts. Since the bill has gone into effect (July 1, 2020), automobile delay, as measured by “level of service” and other similar metrics, no longer constitute a significant environmental effect under CEQA.

In September 2020, the City of Brea prepared its Transportation Impact Analysis (TIA) Guidelines. These serve as the City’s transportation analysis guidelines and include methodologies and criteria for evaluating VMT 14 City of Brea, “Transportation Impact Analysis (TIA) Guidelines”, 2020 City of Brea Focused General Plan Update And Brea Core Specific Plan: Transportation and Vehicles Miles Traveled (VMT) Impact Analysis
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impacts. The City requires the analysis of citywide VMT per service population (residents + employees) to determine VMT impacts.

The specific thresholds to determine potential VMT impacts are detailed below:
 A project would result in a significant project-generated VMT impact if either of the following conditions are satisfied:
o The baseline or cumulative project-generated VMT per service population exceeds the City of Brea General Plan Buildout VMT per service population, or  The project’s effect on VMT would be considered significant if it resulted in either of the following conditions to be satisfied:
o The baseline or cumulative link-level boundary Citywide VMT per service population increases under the plus project condition compared to the no project condition.

MODELING APPROACH
The Orange County Traffic Analysis Model (OCTAM) is used to forecast VMT metrics for cities in Orange County. OCTAM is a conventional travel demand forecasting model that is similar in structure to most other current models used for traffic forecasting. It uses land use, socioeconomic, and network data to estimate travel patterns, roadway traffic volumes, and performance measures.

The travel demand model land use inputs (socioeconomic data) are aggregated at the transportation analysis zone (TAZ) level. A TAZ is a geographic area used in the model which contains the trip-generating inputs for that area. Population-related inputs include numbers of households by type, which are further stratified by six combinations of unit types and vehicle ownership. Non-residential inputs include building area for 14 employment categories, numbers of students for three types of schools, and acres of recreation (these categories are simplified for the buffer areas outside the Brea City limits).

Travel demand to and from areas outside of the model area are not estimated based on specific land uses, but are instead represented by base year (2024) and projected (2050) traffic volumes on the gateway roads at the model area boundary.

To account for the change in permitted land uses between the current 2003 General Plan and this proposed Focused General Plan Update, the total population and employment were determined for each TAZ that is within the city limits and provided to OCTA for coding into OCTAM. From the model, OCTA provided VMT statistics for the city’s TAZs.

SIGNIFICANT IMPACT THRESHOLDS

VMT IMPACTS
For the purposes of this transportation impact analysis, at least one of the following criteria must be met to determine that there is a significant VMT impact, per the City of Brea Transportation Impact Analysis Guidelines:
 The baseline OR cumulative project-generated VMT per service population exceeds the City of Brea General Plan Buildout VMT per service population.
 The baseline OR cumulative link-level boundary Citywide VMT per service population increases under the plus project condition compared to the no project condition.

This impact analysis is based on citywide total VMT per service population (residents + employees).

OTHER TRANSPORTATION IMPACTS
In addition to VMT, additional transportation-related impact criteria are as follows:
 The project conflicts with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities.  The project substantially increases hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment).  The project results in inadequate emergency access.

ITEM 1: VMT

EXISTING VEHICLE MILES TRAVELED
The existing VMT was estimated based on outputs generated by OCTAM for current Brea conditions.

Consistent with the City’s guidelines, two types of VMT were determined15:
 Total VMT: This calculation represents the total daily VMT that starts and/or ends within a boundary (such as the City of Brea) but does not include VMT that travels through an area without starting or stopping there. VMT starting or ending within the City is not truncated at City boundaries.  VMT per Service Population: This calculation represents the VMT for all trips that originate or end within an area, divided by that area’s service population (residents + employees). VMT starting or ending within the City is not truncated at City boundaries.

At the city level, existing total daily VMT is 1,168,996 and existing VMT per service population is 31.6.16 2050 GENERAL PLAN BUILDOUT VEHICLE MILES TRAVELED
For the purpose of this analysis, the horizon year is considered 2050, and the project is defined as the buildout of the proposed General Plan Update.

VMT per service population (SP) represents all trips that originate or end within the area, divided by the city’s service population (residents + employees). The technical data received from OCTA determining the VMT per SP is included in the Appendix.

The City of Brea General Plan Buildout VMT per service population (i.e., with the current General Plan) is

31.1. Table 4 shows the VMT per SP in the baseline project-generated and cumulative project-generated scenario and compares to the current Buildout amounts. As shown, the VMT per service populations in both the Baseline plus Project and Cumulative plus Project scenarios do not exceed the City of Brea General Plan Buildout VMT per service population. Therefore, there would not be a significant VMT impact for this threshold.

Table 4: Citywide VMT per Service Population Analysis
Scenario VMT per SP1 Exceeds Brea Buildout VMT
per SP (31.1)?
Baseline Plus Project 29.8 No
Cumulative Plus Project 30.0 No 1 VMT per SP is determined from dividing the OD VMT by the sum of the population and employment in the Baseline Project-Generated model run scenario and the Cumulative Project-Generated model run scenario. 15 City of Brea, “Transportation Impact Analysis (TIA) Guidelines”, 2020 16 Note the base year received and analyzed from OCTA was 2019.

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Link-level boundary citywide VMT per SP represents the total daily VMT that starts and/or ends within the City but does not include VMT that travels through the area without starting or stopping there, divided by the area’s service population (residents + employees). The technical data determining the link-level boundary citywide VMT per SP is included in the Appendix.

Table 5 shows the link-level boundary citywide VMT per service population in the baseline plus project and cumulative plus project scenarios. As shown, the VMT per service populations in both scenarios do not exceed the link-level VMT per service population in the respective no-project scenarios. Therefore, there would not be significant VMT impact for this threshold.

Table 5: Link-Level Boundary Citywide VMT per Service Population Threshold Scenario No Project
(VMT per SP)
Plus Project
(VMT per SP)
Plus-Project VMT/SP
Exceeds Respective NoProject VMT/SP?
Baseline 12.7 11.0 No
Cumulative 12.3 11.2 No
Overall, the General Plan Update’s VMT impacts would be considered less than significant.

Brea Core Specific Plan Area
As the Brea Core Specific Plan Area is a subset of the overall General Plan, a separate Core Area VMT analysis is not required. However, for informational purposes, the Core Area’s VMT per SP, based on the overall citywide VMT, was determined.

To estimate Core Area’s VMT, the proportion of the VMT that was attributable to the Core Area was identified. Using OCTAM data, the model Traffic Analysis Zones (TAZs) that were partially or completely within the Core Area, and the proportion of land uses within each TAZ, were identified. From this data, the percentage of the citywide ADT that would be generated by trips to, from, and within in the Core Area for the Cumulative No Build (i.e., with the current General Plan) and Future 2050 Plus Project scenarios were estimated. For the VMT analysis, the total VMT for each TAZ was determined and the VMT per service population was calculated based on the net change in population and employment for the portion of the TAZ within the Core Area. This data was used to determine the total VMT and VMT per service population as shown in Table 6. The technical analysis is included in the Appendix. As shown in the table, the VMT per SP would decrease with the Project.

Table 6: VMT per Service Population Threshold for the Brea Core Specific Plan Scenario VMT Service Population VMT Per Service
Population
Cumulative No Project
(Current Plan) 728,870 20,292 35.9
Cumulative Plus Project 900,121 28,654 31.4
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ITEM 2: TRANSIT, ROADWAY, BICYCLE, AND

PEDESTRIAN FACILITIES
A significant project impact would occur if the project conflicts with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities. Each of these modes and facilities is reviewed for impacts below.

ROADWAYS
As land use projects throughout the City are approved and developed, the City will continue to monitor conditions at vehicular facilities to determine the appropriate timing and/or level of improvement along those facilities. In addition, the City can request project-specific circulation analyses once specific land use development projects are undergoing their review and approval processes.

The updated Mobility Element of Brea’s General Plan incorporates policies that guide roadway operations, safety, design, and goods movement. Key supporting policies include:
 M-1.2 Inter-Agency Coordination. Engage in federal, State, and regional planning efforts with Federal Highway Administration (FHWA), the Southern California Association of Governments (SCAG), Orange County Transportation Authority (OCTA), Orange County, adjacent cities, and other jurisdictions, as appropriate, to develop a transportation network that balances traffic flow and multi-modal needs.
 M-1.4 Emerging Technology. Work with regional partners to plan for emerging transportation modes and technologies.
 M-2.1 Roadway Requirements. Require roadways to:
o Be designed to be consistent with applicable federal, State, and local design and safety standards.
o Meet the needs of multiple transportation modes and users, including children, seniors, and people with disabilities.
o Be compatible with the streetscape and surrounding land uses. o Be maintained in accordance with best practices.
 M-2.2 Level of Service. Strive to maintain acceptable vehicular level of service at City intersections, per the City of Brea Transportation Impact Analysis (TIA) Guidelines.  M-2.3 Non-Local Traffic. Discourage the flow of non-local traffic through neighborhoods.  M-2.4. Traffic Management. Apply creative traffic management strategies to maintain efficient and orderly traffic flow, minimize vehicular congestion in areas with unique users (such as schools, and businesses with drive-through access) and other special situations.  M-2.8. Truck Route Network. Maintain, and update as needed, a designated local truck route network that facilitates access to business and shopping centers while reducing commercial vehicle effects on the community.
 M-3.1 Complete Streets Principles. Consider and implement best complete streets practices to facilitate travel and enhance safety for all road users regardless of travel mode.  M-3.5 New Mobility Technologies. Monitor and evaluate the development of new mobility technologies and the considerations for implementation of improvements to facilitate a transportation network that accommodates all modes and users.  M-3.7 Roadway Design Principles. Support roadway design principles that create a safe, pleasant, and comfortable experience for all road users including pedestrians and bicyclists.

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The General Plan Update would not be inconsistent with or in conflict with any adopted program, plan, ordinance, or policy addressing roadway operations, design, or performance. The Mobility Element establishes a policy framework that is consistent with applicable federal, state, and local roadway design and safety standards, including the City of Brea Transportation Impact Analysis (TIA) Guidelines, and provides direction to maintain acceptable roadway operations while accommodating multiple transportation modes. The General Plan Update outlines policies to guide future improvements and requires that roadway conditions be evaluated through project-specific circulation analyses at the time of development. Through continued monitoring of roadway conditions, inter-agency coordination, and implementation of traffic management strategies, the City would ensure that future development occurs in a manner consistent with adopted roadway plans and standards and would not result in conflicts with the circulation system.

TRANSIT, BICYCLE, AND PEDESTRIAN
In addition to proposed roadway classifications, the updated Mobility Element references and incorporates the City’s bicycle and pedestrian plans, which direct efforts to improve non-motorized accessibility and connectivity throughout the City.

The General Plan Update also proposes development within existing and future high-quality transit areas, which can encourage less driving and more transit, bike-to-transit, and walk-to-transit trips.

The Mobility Element developed as part of the General Plan Update contains policies that support access to and the performance of public transit, bicycle, and pedestrian facilities. These policies include:
 M-3.1 Complete Streets Principles. Consider and implement best complete streets practices to facilitate travel and enhance safety for all road users regardless of travel mode.  M-3.6 Curb Management. Seek to implement curb zone changes to best match the needs of adjacent land uses and to facilitate non-motorized transportation choices while minimizing the effects to roadway conditions and on-street parking.
 M-3.7 Roadway Design Principles. Support roadway design principles that create a safe, pleasant, and comfortable experience for all road users including pedestrians and bicyclists.  M-3.8 Traffic Calming. Use traffic calming methods within residential areas as needed to create a pedestrian-friendly circulation system, while accommodating local street patterns where feasible.

Balance accommodations for automobiles, transit, bicycles, and pedestrians in the design of new streets and streetscape improvements.
 M-3.9 New Development – Multi-Modal Facilities. Require new development projects to accommodate vehicles (including emergency vehicles), pedestrians, and bicycles through the dedication of land for public improvements such as roadways, wider sidewalks, and/or bicycle lanes, as appropriate and warranted by the project.
 M-4.1 System of Bikeways. Develop and maintain a comprehensive and integrated system of bikeways that promotes cycling for commuting and recreation.  M-4.3 Pedestrian Connections. Provide for safe and convenient pedestrian connections to and from Downtown, other commercial districts, neighborhoods, and major activity centers within the City.
 M-4.7 Bicycle, Pedestrian, and Connectivity Improvements. Provide safe, attractive, and accessible bicycle and pedestrian facilities—such as secure bicycle parking, pedestrian-scale lighting, and landscaping—and to make improvements that enhance connectivity to key destinations like schools, parks, workplaces, and shopping areas that serve residents’ daily needs where feasible.
 M-4.10 Bicycle and Pedestrian Connectivity. Plan neighborhood streets, pedestrian walks, and bicycle paths as a system of fully connected routes throughout the City.

City of Brea Focused General Plan Update And Brea Core Specific Plan: Transportation and Vehicles Miles Traveled (VMT) Impact Analysis
April 2026 Transportation Impact Analysis
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The General Plan Update would not be inconsistent with or in conflict with any adopted program, plan, ordinance, or policy addressing the circulation system. The Mobility Element is an updated policy framework that incorporates and builds upon the City’s existing transit, bicycle, and pedestrian goals and objectives. Policies in the Mobility Element promote multimodal access, connectivity, safety, and transitsupportive land use patterns, and do not propose actions that would degrade or preclude implementation of planned roadway, transit, bicycle, or pedestrian facilities. Development in high-quality transit areas and the requirement for multimodal accommodations in new development are consistent with State and local complete streets and sustainable transportation policies, and would not conflict with adopted circulation standards or performance objectives.

Therefore, the General Plan Update’s impacts related to roadways, transit, bicycle, and pedestrian facilities would be considered less than significant.

ITEM 3: GEOMETRIC DESIGN AND INCOMPATIBLE

USE HAZARDS
A significant project impact would occur if the project substantially increases hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment).

Note, the General Plan Update is a programmatic level document; increased hazards due to geometric design features are typically assessed at the project level. As individual sites are developed and undergo City review and approval, the City can require site plan, access, and circulation analysis to ensure that neither on-site designs nor the interaction with City streets will result in hazardous geometric design features.

The types of uses included within the City of Brea as part of the General Plan Update are generally similar to existing and surrounding uses and thereby are compatible with the existing uses in the Plan area and in the surrounding area.

In addition, the Mobility Element developed as part of the General Plan Update contains policies in support of roadway network safety and reducing design hazards, including:
 M-1.4 Emerging Technology. Work with regional partners to plan for emerging transportation modes and technologies.
 M-2.1 Roadway Requirements. Require roadways to:
o Be designed to be consistent with applicable federal, State, and local design and safety standards.
o Meet the needs of multiple transportation modes and users, including children, seniors, and people with disabilities.
o Be compatible with the streetscape and surrounding land uses. o Be maintained in accordance with best practices.
 M-2.8 Truck Route Network. Maintain, and update as needed, a designated local truck route network that facilitates access to business and shopping centers while reducing commercial vehicle effects on the community.
 M-3.1 Complete Streets Principles. Consider and implement best complete streets practices to facilitate travel and enhance safety for all road users regardless of travel mode.  M-3.5 New Mobility Technologies. Monitor and evaluate the development of new mobility technologies and the considerations for implementation of improvements to facilitate a transportation network that accommodates all modes and users.  M-3.9 New Development – Multi-Modal Facilities. Require new development projects to accommodate vehicles (including emergency vehicles), pedestrians, and bicycles through the dedication of land for public improvements such as roadways, wider sidewalks, and/or bicycle lanes, as appropriate and warranted by the project.

Therefore, the General Plan Update’s impacts related to geometric design and incompatible use hazards would be considered less than significant.

City of Brea Focused General Plan Update And Brea Core Specific Plan: Transportation and Vehicles Miles Traveled (VMT) Impact Analysis
April 2026 Transportation Impact Analysis
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ITEM 4: EMERGENCY ACCESS
A significant project impact would occur if the results in inadequate emergency access. Note that the General Plan Update is a programmatic level document; emergency accessibility is typically assessed at the project level. As individual sites are developed and undergo City review and approval, the City can require site plan, access, and circulation analysis to ensure that neither on-site designs nor the interaction with City streets will result in inadequate emergency access.

In Brea, emergency access and public safety are addressed through the General Plan, including within the Mobility Element. The Mobility Element provides a framework to ensure that development and transportation planning support adequate emergency response capabilities.

The Mobility Element supports emergency access through roadway design, traffic management, and multimodal system planning that ensures access for emergency vehicles and clear evacuation paths. The Element emphasizes maintaining a connected and resilient street network that accommodates all users, including emergency responders, even in high-density or transit-oriented areas.

Relevant supporting policies include:
 M-1.2 Inter-Agency Coordination. Engage in federal, State, and regional planning efforts with Federal Highway Administration (FHWA), the Southern California Association of Governments (SCAG), Orange County Transportation Authority (OCTA), Orange County, adjacent cities, and other jurisdictions, as appropriate, to develop a transportation network that balances traffic flow and multi-modal needs.
 M-2.7 Evacuation Routes. Incorporate necessary improvements to and perform maintenance on evacuation routes consistent with the Public Safety Element, and according to applicable requirements identified in regional and local plans.
 M-3.9 New Development – Multi-Modal Facilities. Require new development projects to accommodate vehicles (including emergency vehicles), pedestrians, and bicycles through the dedication of land for public improvements such as roadways, wider sidewalks, and/or bicycle lanes, as appropriate and warranted by the project.

In addition, the Mobility Element is supported by the General Plan’s Public Safety Element, which outlines strategies to mitigate risks associated with natural hazards, including wildfires, floods, and earthquakes.

Key Safety Element policies and programs include:
 PS-1.19 Mutual Aid. Maintain mutual aid agreements with the State, County, and neighboring jurisdictions including for disaster response and evacuation assistance.  PS-1.20 Public Information. Continue annual public information programs that explain the City’s Emergency Preparedness Program and other emergency preparedness strategies, including defensible space and evacuative routes, focusing on the most vulnerable communities such as those in the Very High Fire Hazard Severity Zones.
 PS-3.4 Education. Educate the community regarding flood prevention information and notify residents and motorists of impending flood hazards and evacuation procedures.  PS-4.3 Transport. Limit the transport of hazardous waste and materials to designated routes.  PS-6.5 Automatic and Mutual Aid. Continue to participate in automatic and mutual aid agreements with adjacent service providers to ensure efficient and adequate resources, facilities, and support services during and after emergencies.
 PS-6.6 Emergency Evacuation Routes and Access. Work with the Fire Department and Police Department to define minimum standards for evacuation of residential areas, particularly in HFHSZs and VHFHSZs, and to maintain, update, and regularly exercise emergency access, protocols, and evacuation routes to assess their effectiveness under a range of emergency scenarios. If areas with inadequate evacuation routes are identified, develop appropriate mitigation measures, improvement plans, or education programs to ensure safe evacuation.

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 PS-6.8 Collaboration. Strengthen emergency services preparedness and response by linking emergency services with local hazard mitigation programs and enhancing public education on a regional scale.
 PS-6.9 Institutions. Regularly coordinate with the City’s major institutions, schools, employers, and homeowners’ associations regarding emergency response procedures.  PS-6.11 Warning Systems. Maintain and regularly upgrade a mass communications system to effectively notify people during disasters and emergencies by using current communication technologies.
 PS-6.12 Strategic Readiness. Maintain a proactive, data-driven public safety system through recurring five-year strategic planning that aligns resources, facilities, staffing, and technology with community risk and growth.

The General Plan Update would not be inconsistent with or in conflict with any adopted program, plan, ordinance, or policy addressing emergency access and response. The Mobility Element and Public Safety Element collectively establish policies that ensure roadway design, circulation planning, and development review processes maintain adequate access for emergency vehicles and evacuation needs. These policies are consistent with applicable local and regional requirements, including roadway standards, evacuation route planning, and fire safety regulations codified in the Brea Municipal Code. The General Plan Update does not propose physical changes that would obstruct emergency access, and emergency access adequacy is evaluated and enforced through subsequent project-level review. Implementation of the General Plan Update would not result in inadequate emergency access or conflict with adopted emergency response and circulation policies.

Therefore, the General Plan Update’s impacts related to emergency access would be considered less than significant.

Section 6 — Conclusions
City of Brea Focused General Plan Update And Brea Core Specific Plan: Transportation and Vehicle Miles Traveled (VMT) Impact Analysis
April 2026 Conclusions

CONCLUSIONS
The California Environmental Quality Act (CEQA) transportation impact analysis of the General Plan Update determined that impacts would be less than significant for the following topics:
 Vehicle miles traveled (VMT)
 Transit, roadway, bicycle, and pedestrian facilities
 Geometric design and incompatible use hazards
 Emergency access
Appendix 1 — VMT
Technical Data
OCTA TAZs WITHIN CITY LIMITS
Baseline Scenario
TAZ Time Period OD VMT POPULATION EMPLOYMENT SERVICE POP 2 Daily 49,502 1,877 110 1,987
3 Daily 80,599 2,235 589 3,422
4 Daily 64,730 2,268 200 2,959
8 Daily 1,163 30 6 36
10 Daily 53,998 2,696 234 2,930
11 Daily 41,677 1,482 479 3,774
12 Daily 52,451 2,019 562 2,581
13 Daily 84,294 16 3,273 3,289
14 Daily 190,310 3,378 3,289 6,667
15 Daily 53,877 82 2,067 2,149
16 Daily 36,101 0 1,055 1,055
17 Daily 24,234 5 1,003 1,008
18 Daily 38,898 347 974 1,321
19 Daily 39,193 17 1,044 1,061
20 Daily 212,347 410 4,064 4,474
21 Daily 29,094 1,119 184 1,944
22 Daily 89,584 3,371 609 4,248
23 Daily 137,090 1,972 2,836 5,731
24 Daily 287,265 3,539 4,655 10,041
25 Daily 146,635 2,046 2,889 4,935
26 Daily 438,075 1,251 7,434 9,135
27 Daily 63,935 1,467 1,015 2,482
29 Daily 61,782 2,208 441 2,649
30 Daily 54,254 2,292 260 3,107
31 Daily 21,202 989 179 1,852
32 Daily 3,537 9 118 127
33 Daily 61,032 574 901 1,475
34 Daily 113,843 1,530 1,029 2,721
35 Daily 261,906 0 6,400 6,400
36 Daily 78,746 2,496 713 3,209
39 Daily 32,230 1,470 164 1,634
TOTALS 2,903,584 43,195 48,776 91,971
VMT 2,903,584
Service Population 91,971
VMT per SP 31.6
Baseline Plus Project Scenario
TAZ Time Period OD VMT POPULATION EMPLOYMENT SERVICE POP 2 Daily 56,299 2,233 0 2,233
3 Daily 85,287 2,666 262 2,928
4 Daily 82,845 2,910 184 3,094
8 Daily 27,123 790 0 790
10 Daily 56,113 2,754 13 2,767
11 Daily 9,328 203 0 203
12 Daily 50,063 2,196 743 2,939
13 Daily 127,118 0 6,994 6,994
14 Daily 190,672 3,210 5,523 8,733
15 Daily 46,280 0 2,273 2,273
16 Daily 66,289 0 3,724 3,724
17 Daily 72,280 0 3,843 3,843
18 Daily 56,620 546 2,243 2,789
19 Daily 33,832 0 1,684 1,684
20 Daily 169,706 1,786 1,849 3,635
21 Daily 41,960 1,230 315 1,545
22 Daily 79,230 2,349 595 2,944
23 Daily 177,395 1,739 4,795 6,534
24 Daily 177,477 3,787 1,357 5,144
25 Daily 141,519 3,989 1,716 5,705
26 Daily 260,936 4,840 3,331 8,171
27 Daily 89,131 2,107 887 2,994
29 Daily 69,006 2,488 434 2,922
30 Daily 42,228 1,825 109 1,934
31 Daily 28,935 1,824 168 1,992
32 Daily 141,634 2,030 1,309 3,339
33 Daily 90,404 1,172 746 1,918
34 Daily 46,786 2,287 3 2,290
35 Daily 768,632 2,174 14,300 16,474
36 Daily 273,169 2,911 3,973 6,884
39 Daily 12,058 465 51 516
TOTALS 3,570,351 56,511 63,424 119,935
VMT 3,570,351
Service
Population 119,935
VMT per SP 29.8
2050 General Plan No Buildout (City of Brea with the current General Plan VMT) TAZ Time Period OD VMT POPULATION EMPLOYMENT SERVICE POP 2 Daily 53,747 1,798 113 1,911
3 Daily 87,032 2,113 695 2,808
4 Daily 68,792 2,241 222 2,463
8 Daily 1,254 28 7 35
10 Daily 57,391 2,513 233 2,746
11 Daily 42,066 1,433 527 1,960
12 Daily 52,393 1,841 620 2,461
13 Daily 92,024 16 3,690 3,706
14 Daily 203,152 3,733 3,488 7,221
15 Daily 84,762 516 2,878 3,394
16 Daily 36,445 0 1,158 1,158
17 Daily 26,785 5 1,199 1,204
18 Daily 41,393 532 1,035 1,567
19 Daily 43,228 17 1,291 1,308
20 Daily 216,425 432 4,320 4,752
21 Daily 31,282 1,096 196 1,292
22 Daily 92,835 3,340 623 3,963
23 Daily 150,641 1,797 3,228 5,025
24 Daily 284,833 3,560 4,480 8,040
25 Daily 144,934 2,958 2,628 5,586
26 Daily 428,343 1,281 7,635 8,916
27 Daily 66,647 1,541 1,040 2,581
29 Daily 60,607 2,013 432 2,445
30 Daily 55,437 2,089 287 2,376
31 Daily 54,213 2,509 314 2,823
32 Daily 51,250 1,724 55 1,779
33 Daily 69,072 523 1,030 1,553
34 Daily 119,757 1,438 1,096 2,534
35 Daily 259,658 0 7,115 7,115
36 Daily 106,321 3,121 817 3,938
39 Daily 34,082 1,417 164 1,581
TOTALS 3,116,801 47,625 52,616 100,241
VMT 3,116,801
Service Population 100,241
VMT per SP 31.1
2050 General Plan Buildout (City of Brea with the proposed General Plan VMT) TAZ Time Period OD VMT POPULATION EMPLOYMENT SERVICE POP 2 Daily 62,076 2,233 0 2,233
3 Daily 89,031 2,666 262 2,928
4 Daily 86,958 2,910 184 3,094
8 Daily 28,330 790 0 790
10 Daily 62,554 2,754 13 2,767
11 Daily 9,124 203 0 203
12 Daily 51,594 2,196 743 2,939
13 Daily 122,950 0 6,994 6,994
14 Daily 191,390 3,210 5,523 8,733
15 Daily 47,295 0 2,273 2,273
16 Daily 62,909 0 3,724 3,724
17 Daily 70,036 0 3,843 3,843
18 Daily 55,668 546 2,243 2,789
19 Daily 32,687 0 1,684 1,684
20 Daily 171,121 1,786 1,849 3,635
21 Daily 42,664 1,230 315 1,545
22 Daily 80,815 2,349 595 2,944
23 Daily 177,133 1,739 4,795 6,534
24 Daily 182,122 3,787 1,357 5,144
25 Daily 145,152 3,989 1,716 5,705
26 Daily 264,930 4,840 3,331 8,171
27 Daily 90,724 2,107 887 2,994
29 Daily 71,324 2,488 434 2,922
30 Daily 44,460 1,825 109 1,934
31 Daily 32,833 1,824 168 1,992
32 Daily 141,726 2,030 1,309 3,339
33 Daily 91,808 1,172 746 1,918
34 Daily 51,478 2,287 3 2,290
35 Daily 755,388 2,174 14,300 16,474
36 Daily 273,790 2,911 3,973 6,884
39 Daily 12,759 465 51 516
TOTALS 3,602,829 56,511 63,424 119,935
VMT 3,602,829
Service
Population 119,935
VMT per SP 30.0
Link-Level VMT
Scenario Total VMT Population Employment Link-Level VMT/SP Baseline 1,168,966 43,195 48,776 12.7
Baseline ProjectGenerated 1,314,010 56,511 63,424 11.0 Cumulative 1,235,653 47,625 52,616 12.3
Cumulative ProjectGenerated 1,343,583 56,511 63,424 11.2 Brea Core Specific Plan Analysis
Baseline
SP
Factor TAZ OD VMT Specific PlanOD VMT Population Specific Plan Pop Employment Specific PlanEmployment

1.00 18 38,897 38,897 347 347 974 974

0.36 20 212,346 76,179 410 147 4,064 1,457

0.02 22 89,584 1,554 3,371 58 609 10

0.86 23 137,089 117,601 1,972 1,691 2,836 2,432

0.69 25 146,635 101,647 2,046 1,418 2,889 2,002

0.39 26 438,075 172,199 1,251 491 7,434 2,922

0.25 27 63,934 15,918 1,467 365 1,015 252

0.44 33 61,031 26,902 574 253 901 397
Total 550,902 4,772 10,450
VMT / SP 36.2
2050 No-Project
SP
Factor TAZ OD VMT Specific PlanOD VMT Population Specific Plan Pop Employment Specific PlanEmployment

1.00 18 41,392 41,392 532 532 1,035 1,035

0.54 20 216,424 116,275 432 232 4,320 2,320

0.04 22 92,835 3,554 3,340 127 623 23

0.92 23 150,641 139,292 1,797 1,661 3,228 2,984

0.81 25 144,933 117,619 2,958 2,400 2,628 2,132

0.62 26 428,343 265,369 1,281 793 7,635 4,730

0.27 27 6,6647 18,251 1,541 422 1,040 284

0.39 33 69,072 27,113 523 205 1,030 404
Total 728,870 6,375 13,916
VMT / SP 35.9
2050 Project-Generated
SP
Factor TAZ OD VMT
Specific Plan
OD VMT Population
Specific Plan
Pop Employment
Specific Plan
Employment

0.99 18 55,668 55,665 546 545 2,243 2,242

0.99 20 171,121 171,098 1,786 1,785 1,849 1,848

0.06 22 80,815 4,567 2,349 132 595 33

0.76 23 177,132 134,596 1,739 1,321 4,795 3,643

0.99 25 145,151 145,146 3,989 3,988 1,716 1,715

0.99 26 264,930 264,903 4,840 4,839 3,331 3,330

0.57 27 90,724 52,112 2,107 1,210 887 509

0.78 33 91,808 72,031 1,172 919 746 585
Total 900,121 14,744 13,910
VMT / SP 31.4
Specific Plan (SP) Factor represents the proportion of land uses within each TAZ that would be located within the Brea Core Specific Plan Area. This was calculated based on the service population of all parcels within the TAZ, divided by the total service population of the TAZ.

Attachment B. Revised Appendix C: Brea 2050 General Plan: Goals, Policies, and Actions
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Brea 2050 Public Hearing Draft General Plan Goals Policies and Actions (April 2026, Version 2)

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Brea City CouncilJune 2, 2026

Brea City Council
June 2, 2026