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

Program EIR No. 2026-01
3091055.2
(ii) The Focused General Plan Update area encompasses the City of Brea and its SOI, which totals 14,481.9 acres with 8,249 acres within the City's incorporated limits and 6,232.9 acres within the SOI. The Brea Core Specific Plan area totals approximately 778.97 acres and is generally bound by Lambert Road to the north, Imperial Highway (SR-90) to the south, Berry Street to the west, and SR-57 and Associated Road to the east.
(iii) The City has prepared a Program EIR (PEIR) to analyze the environmental effects of the Project pursuant to the requirements of the California Environmental Quality Act (CEQA), Public Resources Code § 21000 et seq. The City circulated the Notice of Preparation of the PEIR for a 30-day public review with a comment period from February 12, 2026 to March 30, 2026; held a public scoping meeting to receive comments on the appropriate scope of the PEIR on September 4, 2025; and circulated the Draft PEIR for a 45-day public review with a comment period from August 25, 2025 to September 24, 2025.
(iv) The Final PEIR for the Project (State Clearinghouse No. 2025081123) consists of the Draft PEIR, public comments on the Draft PEIR, the City’s responses to those comments, and revisions to the Draft PEIR that clarified, amplified, or made insignificant modifications to the document and did not change it in any way that deprives the public of a meaningful opportunity to comment upon a substantial adverse environmental effect or a feasible way to mitigate or avoid such an effect. (v) Pursuant to Public Resources Code Section 21081 and CEQA Guidelines Section 15091 and 15093, the City has prepared CEQA Findings of Fact (FOF) Resolution No. 2026-XX

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Program EIR No. 2026-01
3091055.2
regarding the Final PEIR (CEQA Findings) and a Statement of Overriding Considerations (SOC), which is attached as Exhibit A to this Resolution. (vi) Pursuant to Public Resources Code Section 21081.6, the City has prepared a Mitigation Monitoring and Reporting Program (MMRP) for the Project, which is attached as Exhibit B to this Resolution.
(vii) On April 14, 2026, the Planning Commission held a duly noticed public hearing on the Project and the PEIR, during which it received and considered all evidence and testimony presented.
(viii) On April 28, 2026, the Planning Commission recommended that the City Council certify the Final PEIR and approve the Project. (ix) On June 2, 2026, the City Council held a noticed public hearing on the Project and the Final PEIR, during which it received and considered all evidence and testimony presented prior to adoption of this Resolution. (x) The documents and other material that constitute the record of the proceedings concerning the Project upon which this Resolution is based are kept by the City of Brea Community Development Department, located at 1 Civic Center Circle, Brea, California 92821.
(xi) All legal prerequisites to the adoption of this Resolution have occurred.

B. RESOLUTION:

NOW, THEREFORE, the City Council of the City of Brea does find, determine, and resolve as follows:

SECTION 1. All facts set forth above in Part A, Recitals, are true and correct.

Resolution No. 2026-XX

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Program EIR No. 2026-01
3091055.2
SECTION 2. This Resolution is based on facts set forth above, the entirety of the evidence presented at the above-referenced public hearing, including all written evidence and testimony presented during the hearing, and the independent judgment of the City Council.

SECTION 3. The City Council approves and adopts CEQA FOF and SOC set forth in Exhibit A and the MMRP found in Exhibit B, which are incorporated herein as though set forth in full. All mitigation measures described in the MMRP shall be binding upon the Project and the persons assigned in the MMRP to implement such measures.

SECTION 4. The City Council certifies as follows:
a. The Final PEIR for the Project has been completed in compliance with CEQA.
b. The Final PEIR for the Project was presented to the City Council and the City Council reviewed and considered the information contained in the Final PEIR prior to deciding whether to approve the Project.
c. The Final PEIR for the Project reflects the City’s independent judgment and analysis.

SECTION 5. City staff shall file a Notice of Determination regarding the Final PEIR with the County of Orange within five working days of final Project approval.

SECTION 6. The City Clerk shall certify to the adoption of this Resolution.

ADOPTED AND APPROVED this 2nd day of June 2026.

Ceilia Hupp, Mayor
Resolution No. 2026-XX

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Program EIR No. 2026-01
3091055.2
ATTEST: ___________________________
Victoria Popescu, City Clerk
I, Victoria Popescu, City Clerk of the City of Brea, do hereby certify that the foregoing Resolution was adopted at a regular meeting of the City Council of the City of Brea, held on the 2nd day of June 2026, by the following vote:

AYES: COUNCIL MEMBERS:

NOES: COUNCIL MEMBERS:

ABSENT: COUNCIL MEMBERS:

ABSTAIN: COUNCIL MEMBERS:

Dated: ___________________________
Victoria Popescu, City Clerk
BREA 2050: FOCUSED GENERAL PLAN UPDATE AND

BREA CORE SPECIFIC PLAN

CEQA FINDINGS OF FACT FOR THE

FINAL ENVIRONMENTAL IMPACT REPORT
SCH No. 2025081123
Prepared for:

City of Brea
Community Development Department, Planning Division
1 Civic Center Circle
Brea, California 92821
May 2026
Exhibit A to Resolution No. 2026-XX
FOF and SOC
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Findings of Fact 1 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Chapter 1.0 Introduction

1.1 Findings of Facts
The following California Environmental Quality Act (CEQA) Findings of Fact (Findings) and Statement of Overriding Considerations (SOC) are made for the Brea 2050: Focused General Plan Update and Brea Core Specific Plan (Proposed Project or Project). The environmental effects of the project are addressed in the Final Program Environmental Impact Report (PEIR) dated May 2026 (State Clearinghouse No. 2025081123), which is incorporated by reference herein.

California Public Resources Code Section 21081(a) and Section 15091(a) of the CEQA Guidelines require that no public agency shall approve or carry out a project for which an EIR has been certified identifying one or more significant effects on the environment unless such public agency makes one or more of the following findings:
1) Changes or alterations have been required in, or incorporated into, the project that mitigate or avoid the significant environmental effects on the environment; 2) Those changes or alterations are within the responsibility and jurisdiction of another public agency and have been, can, or should be adopted by that other agency; or 3) Specific economic, legal, social, technological, or other considerations, including considerations for the provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or alternatives identified in the EIR.

CEQA also requires that the Findings made pursuant to Section 15091 of the CEQA Guidelines be supported by substantial evidence in the record (CEQA Guidelines Section 15091[b]). Under CEQA, substantial evidence means enough relevant information has been provided (and reasonable inferences may be derived from this information) that a fair argument can be made to support a conclusion even though other conclusions might also be reached. Substantial evidence must include facts, reasonable assumptions predicated upon facts, and expert opinion supported by facts (CEQA Guidelines Section 15384).

CEQA further requires the decision-making agency to balance, as applicable, the economic, legal, social, technological, or other benefits of a proposed project against its unavoidable environmental effects when determining project approval. If the specific economic, legal, social, technological, or other benefits of a proposed project outweigh the unavoidable adverse environmental effects, the adverse environmental effects may be considered “acceptable” (Section 15093(a) of the CEQA Guidelines). When the lead agency approves a project which will result in the occurrence of significant effects which are identified in the Final EIR but are not avoided or substantially lessened, the agency shall state in writing the specific reasons to support its actions based on the Final EIR and/or other information in the record.

Exhibit A to Ordinance No. 127X
Program EIR No. 2026-01
Findings of Fact 2 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan The Findings of Fact and Statement of Overriding Considerations have been submitted to the City of Brea (City) for consideration by the decision-making body (City Council). They are provided to allow the public an opportunity to review the project applicant’s position on this matter and to review potential reasons for approving the project. It is the role of staff to independently evaluate the proposed Findings, and to make a recommendation to the decision maker regarding their legal adequacy. It is the exclusive discretion of the decision maker certifying the EIR to determine the adequacy of the proposed Findings.

1.2 Records of the Proceedings
For purposes of CEQA, the Record of Proceedings for the Proposed Project consists of the following documents and other evidence, at a minimum:
• The Notice of Preparation and all other public notices issued by the City in conjunction with the Proposed Project;
• All responses to the Notice of Preparation received by the City; • The Draft Program Environmental Impact Report (PEIR); • The Final PEIR;
• All written comments submitted by agencies or members of the public during the public review comment period on the Draft PEIR;
• All responses to the written comments included in the Final PEIR; • All written and oral public testimony presented during a noticed public hearing for the Project at which such testimony was taken;
• The Mitigation Monitoring and Reporting Program;
• The reports and technical memoranda included or referenced in any responses to comments in the Final PEIR;
• Matters of common knowledge to the City, including, but not limited to, Federal, State, and local laws and regulations;
• Any documents expressly cited in these Findings of Fact and Statement of Overriding Considerations; and
• Any other relevant materials required to be in the Record of Proceedings by Public Resources Code Section 21167.6(e).
• The Final EIR clarifies minor cartographic discrepancies pertaining to the depiction of city boundaries used in map figures. These graphical discrepancies do not alter the environmental analysis, significance conclusions, mitigation measures, or policy consistency determinations contained in the PEIR.

1.3 Custodian and Location of Records
The documents and other materials that constitute the Record of Proceedings for the City’s actions on the Project are located at the following location: Community Development Department Counter Findings of Fact 3 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan (Planning Division), 3rd floor, 1 Civic Center Circle, Brea, CA 92821. The Community Development Department is the custodian of the Project’s administrative record. Copies of the document that constitute the Record of Proceedings are and at all relevant times have been available upon request at the offices of the Community Development Department.

The Draft PEIR and the Final were placed on the City’s website at:
https://www.cityofbrea.gov/166/Projects-in-Process and https://brea.generalplan.org/. This information is provided in compliance with Public Resources Code Section 21081.6(a)(2) and CEQA Guidelines Section 15091(e).

Findings of Fact 4 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan This page intentionally left blank.

Findings of Fact 5 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Chapter 2.0 Project Summary

2.1 Project Objectives
The specific objectives for the Project are as follows:

1. Preserve, protect, and enhance the City’s small-town charm;

2. Continue to provide a community rich in amenities that meet the needs of current and future residents;

3. Accommodate a diverse range of housing development options and densities, ensuring that residents across income levels, age groups, and those with special needs can live within the community;

4. Advance economic development policies that support existing local businesses, attract new businesses, and promote job growth;

5. Encourage the long-term economic success of Downtown Brea and the community’s corridors as mixed-use activity nodes;

6. Balance jobs and housing to create an economically sustainable community with reduced impacts on the City’s transportation network;

7. Ensure new developments incorporate well-designed site planning, high-quality architecture, and functional outdoor spaces, while ensuring they are compatible with the surrounding setting in terms of land uses, scale, and aesthetics;

8. Preserve the natural environment, including open spaces, hillsides, and wildlife;

9. Maintain adequate, reliable, and essential public infrastructure and facilities, including transportation and utilities to support both existing and future development;

10. Maintain a Circulation Plan that fosters a safe and efficient roadway network by minimizing congestion and providing acceptable operation and level of service for vehicles at intersections and roadways;

11. Maintain and enhance the City’s active transportation network to facilitate walking, bicycling, and public transit, improving multimodal connectivity throughout the City;

12. Provide for a wide range of housing opportunities in close proximity to existing and future employment centers and transportation facilities, consistent with the need identified in the City's 2021-2029 Housing Element and local and regional jobs/housing balance policies including Southern California Association of Government’s Connect SoCal through regional programs such as the Sustainable Communities Program and related housing planning initiatives;

13. Support intensification and redevelopment within the Brea Core area through implementation and adoption of the Brea Core Specific Plan;

14. Provide a focused update to the 2003 Brea General Plan to comply with recent changes to State general plan and housing laws; and
Findings of Fact 6 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan

15. Facilitate future use streamlining provisions allowed under the California Environmental Quality Act by providing updated community-level environmental review.

2.2 Project Description

2.2.1 Project Location
The Proposed Project encompasses the City of Brea (City) and its Sphere of Influence (SOI). The City’s incorporated boundaries and the SOI together compose the Focused GPU planning area (Proposed Project area or Project area). Figure 2-1, Regional Location, of the Draft PEIR shows the Project area in a regional context, and Figure 2-2, City of Brea and Sphere of Influence, of the Draft PEIR illustrates the City’s planning boundaries, including the BCSP area. The City 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 Bernardin26o 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) and Valencia Avenue (SR-142) bisect 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 entire Project area encompasses 14,481.9 acres, with 8,249 acres within the incorporated limits of the City and 6,232.9 acres within the SOI.

The BCSP area totals approximately 778.97 acres and is generally bounded by Lambert Road to the north, Imperial Highway (SR-90) to the south, Berry Street to the west, and SR-57 and Associated Road to the east. Refer to Figure 2-5, Existing Brea Core Specific Plan Area, of the Draft PEIR.

2.2.2 Project Background
State law requires that every local jurisdiction adopt a comprehensive, long-term general plan, typically with a 20‑year horizon. A general plan represents the community’s view of its future and is often referred to as a blueprint for growth and development. State law requires that a general plan contain eight elements: land use, circulation, housing, open space, noise, safety, environmental justice, and conservation. General plans must be periodically updated to respond to new State laws, changing conditions, and emerging issues and opportunities. The purpose of the Proposed Project is to create a policy framework that articulates a vision for the City’s long-term physical form and development while preserving and enhancing the quality of life for the City’s residents.

In 2003, the City adopted the Brea General Plan (2003 Brea General Plan). The 2003 Brea General Plan comprises six chapters—Introduction, Community Development, Housing, Community Resources, Community Services, and Public Safety—that cover the required elements and additional topics of local relevance. Since 2003, the Housing chapter has been updated three times in compliance with California Housing Element law, with the most recent update adopted in August 2022 for the 6th Cycle Housing Element. No updates to the current Housing Element are expected Findings of Fact 7 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan to occur because of the Focused GPU or preparation of the BCSP. In addition, the Public Safety chapter was last amended in 2021 in conjunction with the 6th Cycle Housing Element, and the land use designation map has been periodically amended to accommodate specific projects. At the time of its preparation, the 2003 Brea General Plan was based on forecasting and projections with a horizon year of 2020. As such, it is no longer a visioning document for the community and is due for an update.

The City had planned to update the General Plan in 2020; however, this effort was delayed due to the world-wide COVID-19 pandemic.

2.2.3 Adopted 2003 Brea General Plan
The 2003 Brea General Plan identified the community’s vision for its collective future and establishes the fundamental framework to guide future decision-making about development, resource management, public safety, public services, and general community well-being. The 2003 Brea General Plan serves as a policy guide, balancing these interrelated factors to Brea’s community vision.

The 2003 Brea General Plan is comprised of five main chapters, excluding the Introduction chapter, that address general plan elements through various components: Community Development, Housing, Community Resources, Community Services, and Public Safety.

2.2.4 2017 Brea Envisions Community Strategic Plan
In 2017, the City of Brea adopted the 2017 Brea Envisions Community Strategic Plan (2017 Brea Envisions), establishing a long-term vision for community growth, quality of life, and sustainable development. It identifies core values, strategic goals, and initiatives to guide land use, transportation, housing, open space, public services, cultural amenities, and economic vitality. Developed through extensive community input, 2017 Brea Envisions reflects residents’ priorities for what Brea should be now and in the future. Serving as a strategic overlay to the General Plan and related implementation tools, 2017 Brea Envisions provides policy direction for coordinated growth and investment.

2.2.5 2020 Brea Connecting the Core Active Transportation Plan Following the adoption of 2017 Brea Envisions, the City began the effort to prepare a long-range plan for the heart of the City, coined the “Brea Core Plan” (Core Plan). As a first step, the 2020 Brea Connecting the Core Active Transportation Plan (2020 Brea Core ATP) was initiated to review the central core of the City, using Caltrans Sustainable Transportation Grant. Through this effort, the City looked at improving safety and access of major east–west corridors like Lambert Road and Imperial Highway and north−south corridors like Brea Boulevard and State College Boulevard. The grant helped fund community engagement efforts, collect data on existing conditions, develop Findings of Fact 8 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan plans for remedies to circulation and mobility challenges and to develop a plan for potential future improvements.

As a result, the 2020 Brea Core ATP was adopted in 2020, which identifies mobility challenges and recommends a toolbox of potential solutions to improve circulation within Brea's core. The community-driven 2020 Brea Core ATP developed a vision for a connected and safe transportation system for all, organized by three core elements, which are: (1) Provide access for people of all ages and abilities; (2) Focus on safety enhancements to the transportation network; and (3) Institute creative design solutions for places and streets.

2.2.6 General Plan Audit
In May 2023, the City conducted an audit of the 2003 General Plan. This audit comprehensively evaluated the topical content of each element, including existing goals, policies, and programs, for their currency and relevancy by examining the General Plan for its compliance with current State law and where it can be improved to incorporate new policies and programs that are in line with current best planning practice and examining each element for internal consistency with other elements.

Ultimately, this audit identified the needed modifications and areas for improvement and provided a list of recommendations to be used in the next General Plan Update.

2.2.7 Project Components
The Proposed Project involves the adoption and implementation of the Focused GPU for the City and its Sphere of Influence (SOI). The Focused GPU constitutes a comprehensive update to the City's existing 2003 Brea General Plan, ensuring its policies and programs align with current community needs, state mandates, and planning principles based on the General Plan Audit prepared in 2023. The Focused GPU includes comprehensive updates to all chapters of the 2003 Brea General Plan, which are now formally designated as “Elements,” instead of “Chapters.” The comprehensive list of the updated goals, policies, and implementation actions is provided in Appendix C, Brea 2050 General Plan: Goals, Policies, and Actions. Table 2-1, Proposed Land Use Summary, includes the existing conditions and the proposed Focused GPU land use summary. As detailed in Table ES-1, the Focused GPU would allow for additional housing units and nonresidential square footage across various land use categories within the incorporated City limits and SOI.

Table 2-1. Proposed Land Use Summary
GP
Designation
Existing Conditions Proposed General Plan Update Proposed Change Units Pop. NRSF Jobs Units Pop. NRSF Jobs Units Pop. NRSF Jobs Cemetery – – – – – – – – – – – –
General
Commerci
al
– – 285,349 690 – – 351,758 848 – – 66,409 158
Findings of Fact 9 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Table 2-1. Proposed Land Use Summary
GP
Designation
Existing Conditions Proposed General Plan Update Proposed Change Units Pop. NRSF Jobs Units Pop. NRSF Jobs Units Pop. NRSF Jobs General
Industrial1 – – 4,489,591 10,855 – – 5,178,449 12,478 – – 688,858 1,623 High
Density
Residential
2,556 7,285 – – 2,677 7,630 – – 121 345 – –
Hillside
Residential 127 361 – – 615 1,752 – – 488 1,391 – –
Light
Commerci
al1
– – 132,251 320 – – 135,153 326 – – 2,902 6
Light
Industrial – – 7,477,742 18,080 – – 10,481,374 25,256 – – 3,003,632 7,176 Low
Density
Residential
6,668 19,005 – – 6,775 19,310 – – 107 305 – –
Medium
Density
Residential
1 1,545 4,403 – – 1,575 4,489 – – 30 86 – –
Mixed Use
181 130 369 160,691 389 256 730 197,495 476 126 361 36,804 87 Mixed Use
50 1,692 4,823 1,752,420 4,237 2,727 7,772 5,047,309 12,162 1,035 2,949 3,294,889 7,925 Open
Space1 – – – – – – – – – – – –
Parcelized
ROW1 – – – – – – – – – – – –
Parks/Recr
eation – – 843,197 2,039 – – 974,932 2,349 – – 131,735 310 Public
Facilities – – 33,598 81 – – 76,502 184 – – 42,904 103
Recreation
al
Commerci
al
– – 49,657 120 – – 369,077 889 – – 319,420 769
Specific
Plan –
Birch Hills1
475 1,353 572,055 1,383 475 1,353 572,055 1,383 0 0 0 0 Specific
Plan – Brea
2651
– – – – 1,100 3,134 17,424 42 1,100 3,134 17,424 42
Specific
Plan –
Brea Core
(Proposed
)
1,417 4,040 5,113,863 12,365 4,752 13,542 6,379,588 15,373 3,335 9,502 1,265,725 3,008 Findings of Fact 10 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Table 2-1. Proposed Land Use Summary
GP
Designation
Existing Conditions Proposed General Plan Update Proposed Change Units Pop. NRSF Jobs Units Pop. NRSF Jobs Units Pop. NRSF Jobs Specific
Plan – Brea
Industrial1,
2 – – 570,000 1,378 – – 806,078 1,942 – – 236,078 564
Specific
Plan –
Olinda
Ranch1
622 1,773 – – 622 1,773 – – 0 0 – –
Specific
Plan –
Tomlinson
Park1
321 915 – – 321 915 – – 0 0 – –
Specific
Plan –
Tonner
Hills1
793 2,259 – – 793 2,259 – – 0 0 – –
City Limit
Total 16,345 46,585 21,480,414 51,937 22,688 64,660 30,587,193 73,709 6,343 18,075 9,106,779 21,772 Hillside
Residential
1 – – – – 1,048 2,987 – – 1,048 2,987 – –
Open
Space1 – – – – – – – – – – – –
Parks/Recr
eation1 – – – – – – – – – – – –
Public
Facilities1 – – – – – – – – – – – –
SOI Total – – – – 1,048 2,987 – – 1,048 2,987 – –
Grand
Total 16,345 46,585 21,480,414 51,937 23,736 67,647 30,587,193 73,709 7,391 21,062 9,106,779 21,772 Notes: NRSF = non-residential square feet; Pop = population; ROW = right-of-way; SOI = Sphere of Influence 1 These uses are consistent with the 2003 Brea General Plan, and no additional land uses beyond those identified in the 2003 Brea General Plan are proposed under the Focused General Plan Update. 2 Additional development potential exists within the Brea Industrial Specific Plan area under the existing/adopted Specific Plan; this development potential (beyond existing conditions) is reflected accordingly in the Proposed General Plan Update development potential totals.

Focused General Plan Update
The Focused GPU includes comprehensive updates to the Community Development, Community Resources (merged with Community Services element), and Public Safety Elements, and introduces two new Elements—Mobility and Economic Development—resulting in a total of five updated General Plan Elements as summarized below.

Findings of Fact 11 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Community Development Element
The Community Development Element serves as a comprehensive blueprint for the physical development of Brea and addresses the building blocks of the communitythe land use patterns and intensities, backbone infrastructure, and the visual character of public places and private development. The Community Development Element has been comprehensively updated to address the topics of land use planning, community design and placemaking, neighborhood preservation, hillside development infrastructure, and growth management. The topics of economic development and circulation, which were previously discussed in the 2003 General Plan, are no longer included in the Community Development Element and are instead addressed in the new Economic Development Element and Mobility Element, respectively.

Community Resources Element
The Community Resources Element recognizes Brea’s strong sense of community rooted in its commitment to providing exceptional amenities and inclusive services. The City’s parks, sports facilities, trails, open spaces, and cultural facilities offer places for residents and visitors to gather, play, and enjoy their lives. These resources, coupled with the City’s robust community services, foster connections among neighbors and create a welcoming environment where residents of all ages and backgrounds can thrive. The Community Resources Element has been comprehensively updated to address the topics of parks and trails, human services, open space, scenic vistas, biological resources, artistic, cultural and historical resources, and education services. The Community Resources Element has been merged with the Community Services Element of the 2003 Brea General Plan, and includes topics previously addressed in the Community Services Element of the 2003 General Plan.

Public Safety Element
The Public Safety Element addresses natural and human-caused hazards in Brea and the potential short and long-term risks to human life, property, and the economic and social disruption resulting from wildfires, earthquakes, landslides, floods, noise exposure, and other hazards. The Public Safety Element works in conjunction with the Brea Local Hazard Mitigation Plan and Emergency Operations Plan, which cover many similar topics including natural hazards and evacuation planning. The Public Safety Element has been comprehensively updated to address the topics of wildland fire, geologic and seismic hazards, flood hazards (including dam failure), hazardous materials, climate change and resiliency planning, emergency preparedness and response, and noise.

Mobility Element
The Mobility Element (also referred to as the Circulation Element), supports the provision of a safe, efficient, and adequate multimodal circulation system. This is a new Element and addresses the Findings of Fact 12 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan topics of regional circulation, local circulation, complete streets, pedestrian and bicycle facilities, and public transportation.

Economic Development Element
The Economic Development Element guides the City’s future policy decisions in service of supporting and strengthening the local economy. Although not required by law to be included in the General Plan, the Economic Development Element is included to recognize and promote economic vibrancy and resiliency as a central aspect of planning for Brea’s future. This is a new Element and addresses the topics of a diverse and resilient economy, a business-friendly environment, and workforce attraction and retention.

All five elements of the Focused GPU are generally organized to include introduction, existing conditions, and goals sections, with each goal supported by relevant policies and actions. The Focused GPU goals, policies, and actions are included in Appendix C to this PEIR.

Brea Core Specific Plan
The new BCSP encompasses approximately 778.97 acres and has been prepared to implement the values identified in 2017 Brea Envisions Community Strategic Plan and the goals, policies, and recommendations of the 2020 Brea Connecting the Core Active Transportation Plan. The BCSP establishes land uses, as shown on Figure 2-8, Proposed Brea Core Specific Plan Area Zoning; provides mobility recommendations and streetscape improvements; proposes infrastructure upgrades to support new development; and outlines implementation strategies.

The BCSP would allow for the development of 4,752 residential units and approximately 6,379,588 square feet of non-residential uses within the plan area, representing an increase of 3,335 residential units and approximately 1,265,725 square feet of non-residential uses compared to existing conditions.

2.2.8 Discretionary Actions
The Project requires the following discretionary actions:
• Adoption of the Brea 2050: Focused General Plan Update; • Adoption of the Brea Core Specific Plan;
• Adoption of a Citywide Zone Change and zoning ordinance text amendments; • Certification of PEIR;
• Adoption of Findings of Fact and Statement of Overriding Considerations (if required); • Adoption of the Mitigation Monitoring and Reporting Program; and • Adoption of any ordinances, guidelines, programs, actions, or other mechanisms that implement the Brea Focused General Plan Update and the Brea Core Specific Plan.

Findings of Fact 13 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan

2.2.9 Other Agency Approvals
Under CEQA, State and local agencies other than the lead agency that have discretionary authority over a project or aspects of a project are considered responsible agencies. No responsible agencies have been identified for the Proposed Project.

Findings of Fact 14 May 2026
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Findings of Fact 15 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Chapter 3.0 Environmental Review Process and Public
Participation
The lead agency approving the Project and conducting environmental review under CEQA (California Public Resources Code Section 21000 et seq.), and the CEQA Guidelines (California Code of Regulations, Title 14, Section 15000 et seq.), is the City of Brea. As lead agency, the City is primarily responsible for carrying out the Project, and undertook the following:
• Circulated a Notice of Preparation (NOP) to the Governor’s Office of Land Use and Climate Innovation (the “State Clearinghouse”), Responsible Agencies, Trustee Agencies, and other interested parties on August 25, 2025, for a 30-day review period between August 25, 2025, and September 24, 2023;
• The NOP was posted on the City’s website: https://www.cityofbrea.gov/166/Projects-inProcess and https://brea.generalplan.org/; • The NOP was posted at the Orange County Clerk’s office on August 25, 2025; • Held a publicly noticed EIR Scoping Meeting on September 4, 2025, at the City of Brea City Hall, Conference Center (2nd floor), 1 Civic Center Circle, Brea, California 92821, to solicit comments from the public on the environmental issue areas that should be analyzed in the EIR;
• Submitted a Notice of Availability (NOA) and Notice of Completion (NOC) and electronic copies of the Draft PEIR to the State Clearinghouse, on February 13, 2026; • Sent emails with proof of receipt and mailed, via certified mail, a copy of the NOA to all Responsible Agencies, Trustee Agencies, and other interested parties and organizations not included on the State Clearinghouse’s list of reviewing agencies, to inform recipients that the Draft PEIR was available for a 45-day review period from February 13, 2026, to March 31 8, 2026;
• The NOA was posted on the City’s website and at the Orange County Clerk’s office on February 12, 2026;
• Published the NOA in the Brea Star-Progress, which is the newspaper of general circulation in the area affected by the Project, on February 12, 2026; • The Draft PEIR was posted on the City’s website at:
https://www.cityofbrea.gov/166/Projects-in-Process and https://brea.generalplan.org/ during the public review period for the Draft PEIR;
Findings of Fact 16 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan • Prepared responses to comments on the Draft PEIR received during the 45-day comment period on the DEIR, which have been included in the Final PEIR; • Provided the Final PEIR, including individual responses to agencies that commented on the Draft PEIR in the Staff Report for Planning Commission on April 14, 2026; • Distributed the Final PEIR, including individual responses to agencies that commented on the Draft PEIR on May 19, 2026; and
• Held a City Council hearing on June 2, 2026.

Findings of Fact 17 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Chapter 4.0 Summary of Impacts
Section 15128 of the California Environmental Quality Act (CEQA) Guidelines requires that an EIR contain a brief statement disclosing the reasons why various possible significant effects of a project were found not to be significant and, therefore, would not be discussed in detail in the EIR.

The City of Brea reviewed the Project against the environmental issue areas in Appendix G of the CEQA Guidelines. The following environmental issue areas were determined to have potentially significant impacts, therefore, were addressed in Chapter 4 of the Final PEIR:
• Section 4.1, Aesthetics
• Section 4.2, Air Quality
• Section 4.3, Biological Resources
• Section 4.4, Cultural Resources
• Section 4.5, Energy
• Section 4.6, Geology and Soils (paleontological resources only) • Section 4.7, Greenhouse Gas Emissions
• Section 4.8, Hazards and Hazardous Materials
• Section 4.9, Hydrology and Water Quality
• Section 4.10, Land Use and Planning
• Section 4.11, Noise
• Section 4.12, Public Services
• Section 4.13, Transportation
• Section 4.14, Tribal Cultural Resources
• Section 4.15, Utilities and Service Systems
• Section 4.16, Wildfire
As detailed in Chapter 5, Effects Found Not to Be Significant, the City determined that the following environmental impact categories were not significantly affected by or did not affect the Proposed Project:
• Section 5.1, Agriculture and Forestry Resources
• Section 5.2, Geology and Soils (excluding paleontological resources) • Section 5.3, Mineral Resources
• Section 5.4, Population and Housing
• Section 5.5, Recreation
The Final PEIR concluded that the Project would have less than significant impacts and thus, not require mitigation measures with respect to the following issues:
• Section 4.1, Aesthetics
• Section 4.5, Energy
Findings of Fact 18 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan • Section 4.8, Hazards and Hazardous Materials
• Section 4.9, Hydrology and Water Quality
• Section 4.10, Land Use and Planning
• Section 4.12, Public Services
• Section 4.13, Transportation
• Section 4.16, Wildfire
Potentially significant impacts of the Project would be mitigated to below a level of significance with respect to the following issues:
• Section 4.3, Biological Resources
• Section 4.4, Cultural Resources
• Section 4.6, Geology and Soils (paleontological resources only) • Section 4.14, Tribal Cultural Resources
• Section 4.15, Utilities and Service Systems
The Final PEIR determined significant and unavoidable environmental impacts with respect to the following issue areas:
• Section 4.2, Air Quality
• Section 4.7, Greenhouse Gas Emissions
• Section 4.11, Noise

4.1 Findings for Environmental Effects Which Were Determined Not To Be Significant
Based on Chapter 5, Effects Found Not To Be Significant, of the PEIR, the City determined that the Proposed Project would have no impact or a less than significant impact on the following environmental topic areas, and that no mitigation measures are required. CEQA Guidelines Section 15091 requires that an EIR may not be certified for a project which has one or more significant environmental effects unless one of three possible findings is made for each significant effect.

Since the following environmental issue areas were determined to have no impact or a less than significant impact, no findings are required for these issue areas.

Agriculture and Forestry Resources (Section 5.1 of the PEIR) • Threshold AG-a. Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to nonagricultural use. • Threshold AG-b. Conflict with existing zoning for agricultural use, or a Williamson Act contract.

Findings of Fact 19 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan • Threshold AG-c. Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code, Section 12220(g)), timberland (as defined by Public Resources Code, Section 4526), or timberland zoned Timberland Production (as defined by Government Code, Section 51104(g)).
• Threshold AG-d. Result in the loss of forest land or conversion of forest land to nonforest use. • Threshold AG-e. Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to non-forest use.

Geology and Soils (Section 5.2 of the PEIR)
• Threshold GEO-a(i). Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault.
• Threshold GEO-a(ii). Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving strong seismic ground shaking. • Threshold GEO-a(iii). Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving seismic-related ground failure, including liquefaction.
• Threshold GEO-a(iv). Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving landslides. • Threshold GEO-b. Result in substantial soil erosion or the loss of topsoil. • Threshold GEO-c. Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the Proposed Project, and potentially result in on- or offsite landslide, lateral spreading, subsidence, liquefaction or collapse. • Threshold GEO-d. Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property.
• Threshold GEO-e. Have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater.

Mineral Resources (Section 5.3 of the PEIR)
• Threshold MIN-a. Result in the loss of availability of a known mineral resource that would be a value to the region and the residents of the State.

Findings of Fact 20 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan • Threshold MIN-b. Result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan.

Population and Housing (Section 5.4 of the PEIR)
• Threshold PH-a. Induce substantial unplanned population growth in an area, either directly or indirectly.
• Threshold PH-b. Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere.

Recreation (Section 5.5 of the PEIR)
• Threshold REC-a. Increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated.
• Threshold REC-b. Include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment.

Findings of Fact 21 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Chapter 5.0 Findings Regarding Impacts
California Environmental Quality Act (CEQA) and the CEQA Guidelines require that the environmental impacts of a project be examined before a project is approved. Specifically, regarding Findings, CEQA Guidelines Section 15091 provides:
(a) No public agency shall approve or carry out a project for which an EIR has been certified that identifies one or more significant environmental effects of the project unless the public agency makes one or more written findings for each of those significant effects, accompanied by a brief explanation of the rationale for each finding. The possible findings are:
(1) Changes or alterations have been required in, or incorporated into, the project that avoid or substantially lessen the significant environmental effect as identified in the final EIR.
(2) Such changes or alterations are within the responsibility and jurisdiction of another public agency and not the agency making the finding. Such changes have been adopted by such other agency or can and should be adopted by such other agency.
(3) Specific economic, legal, social, technological, or other considerations, including provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or project alternatives identified in the final EIR.
(b) The findings required by subdivision (a) shall be supported by substantial evidence in the record.
(c) The findings in subdivision (a)(2) shall not be made if the agency making the findings has concurrent jurisdiction with another agency to deal with identified feasible mitigation measures or alternatives. The findings in subdivision (a)(3) shall describe the specific reasons for rejecting identified mitigation measures and project alternatives. (d) When making the findings required in subdivision (a)(1), the agency shall also adopt a program for monitoring and/or reporting on the changes that it has either required in the project or made a condition of approval to avoid or substantially lessen significant environmental effects. These measures must be fully enforceable through permit conditions, agreements, or other measures.
(e) The agency shall specify the location and custodian of the documents or other materials that constitute the record of the proceedings upon which its decision is based. (f) A statement made pursuant to Section 15093 does not substitute for the findings required by this section.

Findings of Fact 22 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan The “changes or alterations” referred to in CEQA Guidelines Section 15091(a)(1), which are required in, or incorporated into, the project that mitigate or avoid the significant environmental effects of a project, may include a variety of measures or actions as set forth in CEQA Guidelines Section 15370, including the following:
(a) Avoiding the impact altogether by not taking a certain action or parts of an action. (b) Minimizing impacts by limiting the degree or magnitude of the action and its implementation.
(c) Rectifying the impact by repairing, rehabilitating, or restoring the impacted environment. (d) Reducing or eliminating the impact over time by preservation and maintenance operations during the life of the action.
(e) Compensating for the impact by replacing or providing substitute resources or environments, including through permanent protection of such resources in the form of conservation easements.

Having received, reviewed, and considered the Final PEIR for the Proposed Project, as well as other information in the Record of Proceedings on this matter, the following Findings are hereby adopted by the City Council in its capacity as the lead agency decision maker. These Findings set forth the environmental basis for current and subsequent discretionary actions to be undertaken by the City for the implementation of the Proposed Project. These Findings are based on, and incorporate by reference, the analysis and conclusions contained in the Final Program Environmental Impact Report (Final PEIR), including the Draft PEIR and all appendices (collectively, the “PEIR”).

5.1 Environmental Impacts Not Requiring Mitigation
For those environmental impacts that were analyzed in the PEIR, the City determined, based upon the CEQA threshold criteria for significance, that the Proposed Project would have a less than significant impact to the following environmental topic areas, and that no mitigation measures were required. No substantial evidence was submitted to or identified by the City which indicated that that the Proposed Project would result in a significant impact related to the following:

5.1.1 Aesthetics
Finding: The Proposed Project would have a less than significant direct, indirect, and cumulative impact on the below listed thresholds of significance. Accordingly, no changes or alterations to the Proposed Project were required to avoid or substantially lessen any significant environmental impacts under those thresholds. The PEIR evaluated the following thresholds and found that no mitigation was required for the identified reasons:

Findings of Fact 23 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan

5.1.1.1 Threshold AES-a
Less Than Significant Impact: The Proposed Project would not have a substantial adverse effect on a scenic vista.

Facts in Support of Findings:

Focused General Plan Update
Implementation of the Focused GPU would accommodate future development primarily within already urbanized areas. Development on hillsides or near open space areas where scenic views could be impacted, implementation of goals and policies pertaining to scenic resources and Hillside development would minimize the extent of development in the hillsides and mitigate any adverse consequences associated with urbanization and 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. Additionally, corridor intensification would occur away from major scenic viewsheds. The Focused GPU goals, policies, and actions would support view preservation and compatibility, and with regulatory compliance with existing Brea City Code, impacts with regard to scenic vistas would be less than significant.

Brea Core Specific Plan
The BCSP area does not contain any scenic resources including dedicated open space, prominent ridgelines, view corridors, or scenic viewpoints. Existing views are predominantly limited by the urbanized context, flat terrain, and intervening development. No officially designated scenic resources or long-range public views are present. While redevelopment may alter local views or increase building mass in certain districts, these changes would not obstruct any protected scenic resources. As there are no designated scenic vistas within or adjacent to the BCSP area, effects on scenic vistas would be less than significant.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.1, Aesthetics.

5.1.1.2 Threshold AES-b
Less Than Significant Impact: The Proposed Project would not substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway.

Findings of Fact 24 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Facts in Support of Findings:

Focused General Plan Update and Brea Core Specific Plan The City of Brea contains no officially designated State Scenic Highways. State Route-57 within the City limits is eligible but not designated as a State Scenic Highways. Implementation of the Project does not propose development that would occur in proximity to an officially designated State scenic highway. Impacts would be less than significant.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.1, Aesthetics.

5.1.1.3 Threshold AES-c
Less Than Significant Impact: The Proposed Project would not substantially degrade the existing visual character or quality of public views of the site and its surroundings, nor conflict with applicable zoning and other regulations governing scenic quality.

Facts in Support of Findings:

Focused General Plan Update
The Project area is predominantly urbanized, and future development would occur within an established regulatory framework—including zoning, specific plans, and urban design policies— that ensures consistency with existing visual character and protection of scenic quality. In nonurbanized hillside and open space areas, the Project does not increase development potential beyond existing General Plan allowances and retains applicable hillside development standards, conservation policies, and viewshed protections. Implementation of the Focused GPU would not degrade the existing visual character or conflict with zoning or regulation for scenic quality. Impacts would be less than significant.

Brea Core Specific Plan
The BCSP further establishes comprehensive design standards and development regulations to ensure cohesive, high-quality urban design and compatibility with surrounding uses. Accordingly, implementation of implementation of the BCSP would not substantially degrade visual character or public views, nor conflict with applicable scenic quality regulations. Impacts would be less than significant.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.1, Aesthetics, and Appendix C, Brea 2050 General Plan: Goals, Policies, and Actions.

Findings of Fact 25 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan

5.1.1.4 Threshold AES-d
Less Than Significant Impact: The Proposed Project would not create a new source of substantial light or glare which would adversely affect day or nighttime views in the area.

Facts in Support of Findings:

Focused General Plan Update
Future development under the Project would introduce new lighting sources; however, all lighting would be subject to existing regulatory requirements and updated General Plan goals and policies governing fixture design, shielding, illumination levels, and light spillover. The Project would not introduce significant lighting increases in non-urbanized areas. A less than significant impact would occur.

Brea Core Specific Plan
The BCSP area is already characterized by high ambient nighttime lighting, additional lighting would not extend into previously dark or visually sensitive areas. Furthermore, the BCSP includes detailed lighting and design guidelines, requirements for fixture shielding, limits on glare, standards preventing light spillover onto adjacent neighborhoods, and policies promoting consistent, pedestrian-oriented illumination that supports safety without over-lighting the urban environment.

A less than significant impact would occur.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.1, Aesthetics.

5.1.1.5 Plans, Programs, and Policies
While no mitigation measures have been identified for the above-listed thresholds, the following existing plans, programs, and policies are identified in the Final PEIR as applicable to the Proposed Project.

PPP AE-1 Development projects will be designed and constructed so that it would not conflict with the intent of the Brea City Code, Chapter 20.206, Hillside Residential Zone. In accordance with Section 20.206.210(A), Other Regulations, Exterior Lighting, exterior lighting will be properly shielded to avoid glare and the spill of light to surrounding areas. Low-level lighting and the use of multiple low-profile fixtures will be used instead of fewer but taller fixtures. The project will be designed so that emphasis on exterior lighting is on safety and landscaping lighting as opposed to building. The project applicant will present descriptions of exterior lighting in the design guideline manual required by Brea City Code, Section 20.206.050.

Findings of Fact 26 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan PPP AE-2 The Brea Core Specific Plan area will be designed and developed to be consistent with the new zoning designations and development standards contained in the Brea City Code applicable to the Brea Core area, which establishes allowable land uses, building form, and site development standards, such as height, setbacks, parking, and objective design standards.

PPP BIO-2 Development implemented under the Proposed Project will be subject to the Brea City Code Chapter 20.74, Tree Preservation, and preserve and propagate the protected trees as defined therein.

5.1.2 Air Quality
Finding: The Project would have a less than significant direct, indirect, and cumulative impact on the below listed thresholds of significance. Accordingly, no changes or alterations to the Project were required to avoid or substantially lessen any significant environmental impacts under those thresholds. The PEIR evaluated the following impacts and found that no mitigation was required for the identified reasons:

5.1.2.1 Threshold AQ-c
Less than significant: The Proposed Project would not expose sensitive receptors to substantial pollutant concentrations.

Facts in Support of Findings:

Focused General Plan Update and Brea Core Specific Plan Carbon Monoxide (CO) Hotspots
Traffic data provided by Kittelson & Associates, Inc. (2025) includes buildout daily traffic volumes on area roadways.

According to the PEIR, the maximum average daily traffic (ADT) for the Proposed Project at buildout is 55,493 ADT on a roadway segment located within the BCSP area. The estimated peak-hour traffic volume is 5,549 vehicles, which does not exceed the screening threshold of 44,000 vehicles per hour at an intersection. Therefore, buildout of the Focused GPU and BCSP would not result in traffic volumes with the potential to create carbon monoxide (CO) hotspots.

Potential CO impacts discussed under Threshold AQ-b for the BCSP are primarily related to residential hearths and landscape equipment. Use of hearths and landscape equipment would occur intermittently across the entire BCSP. Unlike intersection emissions, emissions from these sources would not be concentrated in one area, and a hotspot would not occur. Therefore, potential CO impacts would be less than significant.

Findings of Fact 27 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Toxic Air Contaminants
Construction
Construction-related activities would result in short-term emissions of Diesel Particulate Matter (DPM) from off-road, heavy-duty diesel equipment exhaust. However, the Focused GPU and the BCSP are both policy documents and specific future construction activities under the Focused GPU and BCSP are currently unknown.

Health risks are generally evaluated over a 30‑year exposure period. Construction activities would be spread throughout the Project area and the duration of construction activities near any specific sensitive receptor would be temporary and short term. Additionally, with ongoing implementation of California Air Resources Board (CARB) requirements for cleaner fuels, off-road diesel engine retrofits, and new, low-emission diesel engine types, the DPM emissions from individual equipment would be substantially reduced over the years as construction continues in accordance with the Focused GPU and BCSP. Additionally, emissions of both fugitive dust and exhaust particulate matter combined are anticipated to be below South Coast Air Quality Management District (AQMD) thresholds for construction activities anticipated for the representative construction year (Table

4.2-7 and Table 4.2-9, of the PEIR). Therefore, impacts associated with temporary DPM emissions from construction under the Focused GPU and BCSP would be less than significant.

Operation
Potential impacts related to TAC exposure are site specific and would need to be addressed on a case-by-case basis. Incorporation of PPP AQ-2 that requires the preparation of a health risk evaluation for the development of new sensitive receptors near sources of TACs or new sources of TACs would ensure that impacts to new sensitive receptors are less than significant.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.2, Air Quality, and Appendix D1, Air Quality/GHG Data.

5.1.2.2 Threshold AQ-d
Less than significant: The Proposed Project would not result in other emissions (such as those leading to odors) adversely affecting a substantial number of people.

Facts in Support of Findings
Focused General Plan Update and Brea Core Specific Plan Construction
Construction associated with implementation of the Project could result in minor amounts of odor compounds associated with diesel heavy equipment exhaust. However, because the construction Findings of Fact 28 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan equipment would be operating at various locations throughout the Project area, and construction would not take place all at once, individual receptors would be exposed to minimal construction odor at any given time. As shown in Table 4.2-7 and Table 4.2-9 of the PEIR, construction emissions of SOX are not anticipated to exceed 1 pound per day during typical construction activities, which is well below the South Coast AQMD threshold of 150 pounds per day. As such, impacts associated with odors during construction would be less than significant.

Operation
The Project primarily proposes residential, commercial, and office uses, which are not typical sources of nuisance odors. Any new industrial or petroleum-related uses remain subject to South Coast AQMD Rule 402 (Nuisance Rule). The Proposed Project does not include changes to the operation of the Olinda Alpha Landfill or existing oil field regulations that would increase odor exposure. Therefore, Project operations would not result in other emissions (such as those leading to odors) adversely affecting a substantial number of people. Impacts would be less than significant.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.2, Air Quality, and Appendix D1, Air Quality/GHG Data.

5.1.2.3 Plans, Programs, and Policies
While no mitigation measures have been identified for the above-listed thresholds, the following existing plans, programs, and policies are identified in the Final PEIR as applicable to the Proposed Project.

PPP AQ-1 South Coast AQMD Rules. Development under the Focused General Plan Update and the Brea Core Specific Plan would be required to comply with all applicable South Coast AQMD rules which may include, but are not limited to, the following:
• Rule 402: Prohibits a person from discharging from any source whatsoever such quantities of air contaminants or other material which cause injury, detriment, nuisance, or annoyance to any considerable number of persons or to the public, or which endanger the comfort, repose, health or safety of any such persons or the public, or which cause, or have a natural tendency to cause, injury or damage to business or property.
• Rule 403: Governs emissions of fugitive dust during construction and operation activities. Compliance with this rule is achieved through the application of standard Best Management Practices.
• Rule 445: Prohibits permanently installed wood burning devices into any new development.

Findings of Fact 29 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan • Rule 1108: Governs the sale, use, and manufacturing of asphalt and limits the volatile organic compound (VOC) content in asphalt used in the South Coast Air Basin. This rule regulates the VOC content of asphalt used during construction. • Rule 1113: Serves to limit the VOC content of architectural coatings used on projects in the South Coast Air Basin. Any person who supplies, sells, offers for sale, or manufactures any architectural coating for use on projects in the South Coast Air Basin must comply with the current VOC standards set in this rule. • Rule 1303: Governs the permitting of re-located or new major emission sources, requiring Best Available Control Measures and setting significance limits for PM10 among other pollutants.
• Rule 1401: New Source Review of Toxic Air Contaminants, specifies limits for maximum individual cancer risk, cancer burden, and non-cancer acute and chronic hazard index from new permit units, relocations, or modifications to existing permit units, which emit toxic air contaminants.
• Rule 2305: The Warehouse Indirect Source Rule requires owners and operators associated with warehouses 100,000 square feet or larger to directly reduce NOX and particulate matter emissions, or to otherwise facilitate emission and exposure reductions of these pollutants in nearby communities.

PPP AQ-2 Siting of Sensitive Receptors and Toxic Air Contaminant Sources. Development under the Focused General Plan Update and the Brea Core Specific Plan would be required to incorporate land use planning practices consistent with the California Air Resources Board’s Air Quality and Land Use Handbook to reduce potential public exposure to toxic air contaminants (TACs).

Findings of Fact 30 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan • The results of an HRA would be used to inform land use planning and discretionary decision-making. Potentially significant health risks would be identified where an incremental cancer risk greater than 10 in one million or a chronic or acute hazard index greater than 1.0 is predicted.
• Where potentially significant health risks are identified, land use planning and design strategies would be considered to reduce exposure, which may include, but are not limited to, revised site planning, increased separation distances, enhanced building design features (such as sealed ventilation systems with high-efficiency filtration), operational controls, or alternative siting of the sensitive receptor or TAC-emitting use.

5.1.3 Biological Resources
Finding: The Proposed Project would have less than significant direct, indirect, and cumulative impacts on the below listed threshold of significance. Accordingly, no changes or alterations to the Proposed Project were required to avoid or substantially lessen any significant environmental impacts under those thresholds. The PEIR evaluated the following impacts and found that no mitigation was required for the identified reasons.

5.1.3.1 Threshold BIO-f
Less Than Significant: The Proposed Project would not conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or State habitat conservation plan.

Facts in Support of Findings
Focused General Plan Update and Brea Core Specific Plan The Project area is within the boundaries of the Orange County Transportation Authority’s M2 Habitat Conservation Plan/Natural Community Conservation Planning program. However, the Project is not subject to this HCP/NCCP or other regional conservation plan. The OCTA M2 HCP/NCCP is applicable to OCTA’s 12 freeway projects. Therefore, no impacts to local or regional conservation plans would occur from implementation of the Proposed Project, and no protection measures are required.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.3, Biological Resources (page 4.3-55), and Appendix E, Biological Resources Technical Report.

Findings of Fact 31 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan

5.1.4 Cultural Resources
Finding: The Proposed Project would have less than significant direct, indirect, and cumulative impacts on the below listed threshold of significance. Accordingly, no changes or alterations to the Proposed Project were required to avoid or substantially lessen any significant environmental impacts under those thresholds. The PEIR evaluated the following impacts and found that no mitigation was required for the identified reasons

5.1.4.1 Threshold CUL-a
Less Than Significant Impact: The Proposed Project would not cause a substantial adverse change in the significance of a historical resource pursuant to Section 15064.5.

Facts in Support of Findings
Focused General Plan Update
Future development projects would be required to undergo individual lead agency review at the time of project-level application submittal to determine if historical resources are present and if proposed activities would result in a substantial adverse change in the significance of such resources. The City, as the lead agency, is required to evaluate whether a resource meets the criteria for listing in the California Register of historical Resources, as outlined in Plans, Programs, and Policies (PPP) CUL-1.

Additionally, Brea City Code (BCC) Chapter 20.60, Historic Preservation, establishes procedures for identifying, evaluating, and protecting historical resources and provides a regulatory framework to avoid or minimize substantial adverse changes to such resources. This BCC chapter includes criteria for the designation of individual historical resources, and the plan review process for exterior alterations—including but not limited to restoration, rehabilitation, remodeling, additions, demolition, relocation, or subdivision of a designated historic resource—and provides performance guidelines (PPP CUL-2). Compliance with the existing regulatory requirements would reduce potential impacts to historical resources to a less-than-significant level at the program level.

Project-specific impacts would be evaluated during future discretionary review, at which time compliance with applicable regulations would be assessed. Impacts would be less than significant.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.4, Cultural Resources, and Appendix F1, Cultural Resources Data, and Appendix F2, Confidential Cultural Resources Data.

Brea Core Specific Plan
The BCSP itself does not propose any specific development projects, but approval of this planning document would permit future development projects consistent with the BCSP. Future individual development projects within the BCSP area would be required to undergo individual lead agency review at the time of project-level application submittal to determine if historically significant Findings of Fact 32 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan resources are present and if proposed activities would result in a substantial adverse change in the significance of such resources. CEQA Guidelines, Section 15064.5(a)(4), provides lead agencies with discretion to determine whether a resource is historically significant, even if it is not listed in, or eligible for listing in, a local or State register.

As discussed under the above Focused GPU, compliance with existing regulatory requirements as outlined in PPP CUL-1 and PPP CUL-2 would avoid or minimize substantial adverse changes to historical resources. Therefore, potential impacts to historical resources associated with implementation of the BCSP would be less than significant at the program level, with projectspecific impacts evaluated during future discretionary review.

5.1.4.2 Threshold CUL-c
Less Than Significant: The Proposed Project would not disturb any human remains, including those interred outside of dedicated cemeteries.

Facts in Support of Findings
Focused General Plan Update
Implementation of the Proposed Project would facilitate future site plan-level development projects within the Project area. Such projects could involve grading, excavation, and other grounddisturbing activities that have the potential to disturb previously unidentified human remains.

CEQA assigns special importance to human remains and establishes procedures to be used when Native American remains are discovered. CEQA Guidelines, Section 15064.5(e), lists steps to be followed in the event of the accidental discovery or recognition of any human remains in any location other than a dedicated cemetery. These requirements are part of existing regulatory requirements and outlined in California Health and Safety Code, Section 7050.5; Public Resources Code, Section 5097.98; and CEQA Guidelines, Section 15064.5. Although soil-disturbing activities associated with development in accordance with the Proposed Project could result in the discovery of human remains, compliance with existing law would ensure that significant impacts to human remains would be less than significant.

Findings of Fact 33 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Brea Core Specific Plan
The analysis above for the Focused GPU applies to the BCSP. Although soil-disturbing activities associated with development in accordance with the Proposed Project could result in the discovery of human remains, compliance with existing law would ensure that significant impacts to human remains would be less than significant.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.4, Cultural Resources, and Appendix F1, Cultural Resources Data and Appendix F2, Confidential Cultural Resources Data.

5.1.4.3 Plans, Programs, and Policies
While no mitigation measures have been identified for the above-listed thresholds, the following existing plans, programs, and policies are identified in the Final PEIR as applicable to the Proposed Project.

PPP CUL-1 California Environmental Quality Act (CEQA) & Historical Resources: Pursuant to the CEQA Public Resources Code (PRC), Section 21084.1, any project that may cause a substantial adverse change in the significance of an historical resource is a project that may have a significant effect on the environment. PRC, Section 5020.1(q) defines a “substantial adverse change” as demolition, destruction, relocation, or alteration such that the significance of the historical resource would be materially impaired. Historical resources are defined as “a resource listed or eligible for listing on the California Register of Historical Resources” (CRHR) (Public Resources Code, Section 5024.1; 14 California Code of Regulations, Section 15064.5). Under CEQA Guidelines, Section 15064.5(a), the term “historical resources” includes the following:
• A resource listed in, or determined to be eligible by the State Historical Resources Commission, for listing in the California Register of Historical Resources (PRC, Section 5024.1). This is regarded as a “Mandatory Resource”. • A resource included in a local register of historical resources, as defined in PRC Section 5020.1(k) or identified as significant in a historical resource survey meeting the requirements of PRC Section 5024.1(g), will be presumed to be historically or culturally significant. Public agencies must treat any such resource as significant unless the preponderance of evidence demonstrates that it is not historically or culturally significant. This is regarded as a “Presumptive Resource.” • Any object, building, structure, site, area, place, record, or manuscript which a lead agency determines to be historically significant or significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, military, or cultural annals of California may be considered to be a Findings of Fact 34 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan historical resource, provided the lead agency’s determination is supported by substantial evidence in light of the whole record. This is regarded as a “Discretionary Resource.”
Generally, a resource shall be considered by the lead agency to be “historically significant” if the resource meets the criteria for listing on the California Register of Historical Resources (PRC Section 5024.1) including the following:

1. Is associated with events that have made a significant contribution to the broad patterns of California’s history and cultural heritage;

2. Is associated with the lives of persons important in California’s past;

3. Embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual, or possesses high artistic values; or

4. Has yielded, or may be likely to yield, information important in prehistory or history.

The fact that a resource is not listed in, or determined to be eligible for listing in the California Register of Historical Resources, not included in a local register of historical resources (pursuant to PRC Section 5020.1(k), or identified in a historical resources survey (meeting the criteria in PRC Section 5024.1(g) does not preclude a lead agency from determining that the resource may be an historical resource as defined in PRC Sections 5020.1(j) or 5024.1.

PPP CUL-2 Brea City Code Chapter 20.60 Historic Preservation, as it applies to all objects and/or improvements listed in the Brea Historic Resources Register, will comply with all provisions contained therein as appropriate.

5.1.5 Energy
Finding: The Project would have less than significant direct, indirect, and cumulative impacts on the below listed threshold of significance. Accordingly, no changes or alterations to the Project were required to avoid or substantially lessen any significant environmental impacts under those thresholds. The PEIR evaluated the following impacts and found that no mitigation was required for the identified reasons

5.1.5.1 Threshold EN-a
Less Than Significant: The Proposed Project would not conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or State habitat conservation plan.

Findings of Fact 35 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Facts in Support of Findings
Focused General Plan Update
Construction
To limit wasteful and unnecessary energy consumption, future construction contractors are required to minimize nonessential idling of construction equipment in accordance with California Code of Regulations, Title 13, Article 4.8, Chapter 9, Section 2449. In addition, electricity may be available on individual construction sites through existing power lines and connections, which could minimize or avoid the use of less-efficient diesel generators. Furthermore, construction related trips would avoid unnecessary energy use because the Focused GPU area is already developed and served by an established roadway network. Overall, construction activities associated with land use developments accommodated under the Focused GPU would not result in energy use that is inefficient, wasteful, or unnecessary compared to similar development projects.

Therefore, construction-related energy impacts would be less than significant.

Operation
Electrical service to the Focused GPU area would continue to be provided by SCE through connections to existing off-site electrical lines and new on-site infrastructure. Natural gas would continue to be provided through Southern California Gas Company (SoCalGas). Future development would be required to comply with the applicable Building Energy Efficiency Standards and CALGreen. As these standards are updated triennially, it is anticipated that development to occur in later years would result in less energy consumption than similarly sized development in the near-term. Because these later year developments would be required to comply with the more efficient applicable energy efficiency regulations, development would not result in wasteful, inefficient, or unnecessary electricity and natural gas demands.

As shown in Table 4.5-4, of the PEIR, total fuel use is anticipated to decrease under buildout conditions. This decrease is anticipated to occur even though vehicle miles traveled (VMT) would increase compared to existing conditions (refer to Section 4.13, Transportation, of this PEIR) because fuel emissions standards are anticipated to continue to become increasingly stringent over time. Older, less fuel-efficient vehicles would be taken off the road over time. Thus, it is expected that operation-related fuel usage associated with the Proposed Project would not be any more inefficient, wasteful, or unnecessary than similar development projects. Therefore, impacts would be less than significant with respect to operation-related fuel usage.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.5, Energy, and Appendix D2, Energy Data.

Findings of Fact 36 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Brea Core Specific Plan
Construction
As with development under the Focused GPU, development under the BCSP would be required to minimize nonessential idling of construction equipment during construction in accordance with California Code of Regulations, Title 13, Article 4.8, Chapter 9, Section 2449. Due to the developed nature of the BCSP area, future electricity may be available on individual sites for use during construction to minimize or avoid the use of generators. The BCSP area is located adjacent to SR-90 and SR-57, minimizing inefficient fuel use by providing direct routes to various areas of the region.

Overall, it is expected that construction fuel associated with land use developments accommodated under the BCSP would not be any more inefficient, wasteful, or unnecessary than similar development projects. Therefore, impacts would be less than significant during construction under the BCSP.

Operation
As shown Table 4.5-6, BCSP Buildout (Year 2050) Energy Use, of the PEIR, electricity, natural gas, and fuel use associated development under the BCSP would increase compared to existing conditions. As with the Focused GPU, future development would be required to comply with the Building Energy Efficiency Standards and CALGreen, including updated future standards as applicable. Because development would be required to comply with the applicable energy efficiency regulations, development would not result in wasteful or inefficient electricity and natural gas demands. Therefore, the Proposed Project would not result in a significant impact related to electricity or natural gas.

As shown in Table 4.5-6, of the PEIR, 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 4.13-2, the BCSP result in less than significant VMT impacts because, similar to the Focused GPU, VMT per service population would decrease under the BCSP compared to future conditions without BCSP implementation. Thus, it is expected that operation-related fuel usage associated with the Proposed Project would not be any more inefficient, wasteful, or unnecessary than similar development projects. Therefore, impacts would be less than significant with respect to operation-related fuel usage.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.5, Energy, and Appendix D2, Energy Data.

5.1.5.2 Threshold EN-b
Less Than Significant: The Proposed Project would not conflict with or obstruct a State or local plan for renewable energy or energy efficiency.

Findings of Fact 37 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Facts in Support of Findings
Focused General Plan Update and Brea Core Specific Plan The Proposed Project will be served by Southern California Edison (SCE) and SCE is mandated by State law to meet Renewable Portfolio Standard (RPS) targets (e.g., 60 percent renewable energy by 2030 and 100 percent by 2045). The Proposed Project does not obstruct SCE's ability to achieve these targets and complies with CALGreen and Building Energy Efficiency Standards, including mandatory residential solar photovoltaic systems.

The Proposed Project aligns with State goals to transition away from natural gas. New development must adhere to increasingly stringent Title 24 standards, such as the 2025 Standards requiring "electric-ready" infrastructure and the use of heat pumps in single-family residences.

Growth under the Proposed Project will utilize vehicles subject to the Advanced Clean Cars Program and Federal fuel efficiency standards. Furthermore, As described in the VMT analysis (Section 4.13, Transportation, of the PEIR), the Proposed Project would be VMT-efficient compared to the 2003 General Plan and future No Project conditions, supporting State goals to improve air quality and increase fuel supply efficiency. Therefore, potential impacts related to fuel use goals would be less than significant.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.5, Energy, and Appendix D2, Energy Data.

5.1.5.3 Plans, Programs, and Policies
While no mitigation measures have been identified for the above-listed thresholds, the following existing plans, programs, and policies are identified in the Final PEIR as applicable to the Proposed Project.

PPP EN-1 New buildings are required to achieve the current California Building Energy Efficiency Standards (Title 24, Part 6) and California Green Building Standards Code (CALGreen) (Title 24, Part 11). The 2022 Building Energy Efficiency Standards were effective on January 1, 2023, and the 2025 Building Energy Efficiency Standards will become effective on January 1, 2026.

PPP EN-2 New buildings are required to adhere to the California Green Building Standards Code (CALGreen) requirement to provide bicycle parking for new non-residential buildings, or meet local bicycle parking ordinances, whichever is stricter (CALGreen Sections 5.106.4.1, 14.106.4.1, and 5.106.4.1.2).

PPP EN-3 California’s Green Building Standards Code (CALGreen) requires the recycling and/or salvaging for reuse at a minimum of 65 percent of the nonhazardous Findings of Fact 38 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan construction and demolition waste generated during most “new construction” projects (CALGreen Sections 4.408 and 5.408). Construction contractors are required to submit a Construction Waste Management Plan that identifies the construction and demolition waste materials to be diverted from disposal by recycling, reuse on the project, or salvaged for future use or sale and the amount (by weight or volume).

PPP EN-4 Construction activities are required to adhere to Title 13, Section 2499, of the California Code of Regulations, which requires that nonessential idling of construction equipment be restricted to five minutes or less.

5.1.6 Greenhouse Gas Emissions
Finding: The Proposed Project would have less than significant direct, indirect, and cumulative impacts on the below listed threshold of significance. Accordingly, no changes or alterations to the Proposed Project were required to avoid or substantially lessen any significant environmental impacts under those thresholds. The PEIR evaluated the following impacts and found that no mitigation was required for the identified reasons

5.1.6.1 Threshold GHG-b
Less Than Significant: The Proposed Project would not conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases (GHG).

Facts in Support of Findings
Focused General Plan Update and Brea Core Specific Plan 2022 CARB Scoping Plan
The Project aligns with the 2022 Scoping Plan’s focus on transportation electrification, VMT reduction, and building decarbonization. Project implementation supports these goals by prioritizing transit-oriented infill development and adhering to CALGreen EV parking requirements.

Furthermore, while AB 130 limits local "reach codes," all new construction must comply with the latest Building Energy Efficiency Standards (Title 24), which mandate energy-efficient designs and solar installations. The Proposed Project would not obstruct implementation of the CARB Scoping Plan, and impacts would be less than significant.

SCAG’s Regional Transportation Plan/Sustainable Communities Strategy The Project is consistent with the Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) by directing housing and job growth to "Priority Growth Areas" and the highly urbanized Findings of Fact 39 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Brea Core. This compact development pattern utilizes existing infrastructure and multimodal transit options, effectively reducing per-capita VMT and supporting regional GHG reduction targets.

Although the City does not regulate vehicle emissions directly, the Project’s Mobility Element encourages non-motorized travel and "complete streets." These local policies complement Federal and State vehicle efficiency standards, ensuring that mobile-source emissions—the largest contributor to the Project's GHG profile—decline over time. Therefore, the Proposed Project would not conflict with the Connect SoCal, and impacts would be less than significant Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.7, Greenhouse Gas Emissions, Section 4.13, Transportation, and Appendix D1, Air Quality/GHG Data.

5.1.6.2 Plans, Programs, and Policies
Compliance measures are uniformly applied regulations or requirements imposed by the approving agency based on the type of action proposed. Because these measures are standard requirements, they are not considered mitigation measures. The following existing plans, programs, and policies (PPPs) apply to development allowed under the Focused GPU and help reduce or avoid potential impacts related to greenhouse gas emissions:

PPP GHG-1 New buildings additions and alterations are required to comply with the California Building Energy Efficiency Code (Title 24, Part 6) and California Green Building Standards Code (CALGreen) (Title 24, Part 11) in effect at the time of permit application for plan check. The 2025 Building Energy Efficiency Code, California Energy Code, and the 2025 CALGreen became effective January 1, 2026.

PPP GHG-2 New buildings, additions and alterations to the existing buildings are required to adhere to the California Green Building Standards Code (CALGreen) requirement to provide bicycle parking and related facilities for new nonresidential buildings, or meet the Brea City Code bicycle parking and related facilities requirements, whichever is stricter.

PPP GHG-3 California’s Green Building Standards Code (CALGreen) requires the recycling and/or salvaging for reuse at minimum of 65 percent of the nonhazardous construction and demolition waste generated during most “new construction” projects, dditions, and alterations to the existing buildings (CALGreen secs. 4.408 and 5.408). Construction contractors are required to submit a construction waste management plan that identifies the construction and demolition waste materials Findings of Fact 40 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan to be diverted from disposal by recycling, reused on the project, or salvaged for future use or sale and the amount (by weight or volume).

PPP GHG-4 Construction activities are required to adhere to Title 13 California Code of Regulations Section 2499, which requires that nonessential idling of construction equipment is restricted to five consecutive minutes or less.

PPP GHG-5 New buildings are required to adhere to the Brea City Code Title 14, Sustainable Provisions pertaining to water efficient landscaping requirements, small residential rooftop solar energy system, and electric vehicle charging and hydrogen-fueling stations.

PPP GHG-6 Building Life Cycle Assessment: Effective July1, 2024, projects consisting of newly constructed building(s) with a combined floor area of 100,000 square feet or greater shall comply with either Section 5.409.2 or 5.409.3. Alteration(s) to existing building(s) where the combined altered floor area is 100,000 square feet or greater comply with either section 5.105.2, 5,409.2 or 5.409.3. Addition(s) to existing building(s) where the total floor area combined with the existing building(s) is 100,000 square feet or greater shall comply with either section 5.105.2, 5,409.2 or

5.409.3. Effective January 1, 2026, the combined floor area shall be 50,000 square feet or greater.

5.1.7 Hazards and Hazardous Materials
Finding: The Proposed Project would have less than significant direct, indirect, and cumulative impacts on the below listed threshold of significance. Accordingly, no changes or alterations to the Proposed Project were required to avoid or substantially lessen any significant environmental impacts under those thresholds. The PEIR evaluated the following impacts and found that no mitigation was required for the identified reasons.

5.1.7.1 Threshold HAZ-a
Less Than Significant: The Proposed Project would not create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials.

Facts in Support of Findings:

Focused General Plan Update and Brea Core Specific Plan Hazardous materials and waste would be managed and used in accordance with all applicable Federal, State, and local laws and regulations (refer to Section 4.8.1.1, Regulatory Setting, and Section 4.8.3, Plans, Programs, and Policies). This includes handling of any soils with potential for asbestos containing materials (ACMs) and lead-based paint contamination in accordance with Findings of Fact 41 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Division of Occupational Safety and Health (DOSH), better known as Cal/OSHA requirements and release reporting, initial abatement, and corrective actions for any unauthorized release of hazardous materials with oversight from the Regional Water Quality Control Board (RWQCB), Department of Toxic Substances and Control (DTSC), Brea Fire Department, Brea Building & Safety Division, South Coast AQMD, Orange County Health Care Agency (OCHCA) Environmental Health Division, and other regulatory agencies, as necessary. In addition, disposal of any contaminated material would be in accordance with State and County regulations including the OCHCA Environmental Health Division Certified Unified Program Agency (CUPA) requirements. These regulations are intended to address proper transport of hazardous materials, as well as methods to address accidental spills, to avoid impacts to people and the environment. With regulatory compliance, hazardous impacts to the public and the environment would be less than significant.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.8, Hazards and Hazardous Materials.

5.1.7.2 Threshold HAZ-b
Less Than Significant: The Proposed Project would not create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment.

Facts in Support of Findings
Focused General Plan Update and Brea Core Specific Plan Demolition and Construction Activities
The handling, use, transport, and disposal of hazardous materials by the construction phase of the Proposed Project would comply with regulations of several agencies—the U.S. Environmental Protection Agency (USEPA), OSHA, Cal/OSHA, and U.S. Department of Transportation. Construction projects typically maintain supplies on site for containing and cleaning small spills of hazardous materials. Pursuant to the Code of Federal Regulations, Title 29, Part 1910.1200, the property owner/developer for each project would ensure training for project construction workers on the proper use, storage, and disposal of hazardous materials would occur. Therefore, impacts would be less than significant.

Operation
All operational activities would be required to adhere to Federal, State, and local regulations for the management and disposal of hazardous materials. For instance, businesses that handle hazardous materials such as hazardous waste or substances at reportable quantities are required to submit a Hazardous Materials Business Plan to the California Environmental Reporting System. The CUPA then verifies this information and provides it to agencies that are responsible for the protection of Findings of Fact 42 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan public health and the environment. Therefore, conformance with all applicable Federal, State, and local regulations would ensure impacts would be less than significant.

Hazardous Materials Sites
For development on or near sites identified in the GeoTracker or EnviroStor databases, remediation is mandated through the building permit process. Compliance with site-specific remediation plans overseen by the DTSC, RWQCB, or OCHCA ensures that contaminated soil or groundwater is addressed prior to occupancy. With implementation of existing regulatory requirements, impacts would be less than significant.

Oil and Gas
To address Brea’s history of petroleum extraction, the Project requires compliance with the City’s Combustible Soil-Gas Ordinance. Any development within 300 feet of a petroleum reservoir boundary must undergo comprehensive soil-gas testing and install mandatory mitigation systems (such as passive or active venting and methane alarms) as required by the Brea Fire Code. With the implementation of existing regulatory requirements, impacts would be less than significant.

Aboveground and Underground Storage Tanks
The removal of any aboveground storage tanks or underground storage tanks (USTs) shall be conducted in accordance with the regulations of OCHCA Environmental Health Division, which serves as the designated CUPA. The OCHCA Environmental Health Division implements State and Federal regulations for the Aboveground Storage Tank Program and Underground Storage Tank Program. Furthermore, any UST removals will be conducted in accordance with the California UST Regulations (23 CCR Chapter 16).

Asbestos-Containing Material and Lead-Based Paint
During the demolition of older structures, mandatory compliance with SCAQMD Rule 1403 and Cal/OSHA standards ensures the safe testing, handling, and disposal of Asbestos-Containing Materials (ACM) and Lead-Based Paint (LBP). With implementation of existing regulatory requirements, the Project would have less than significant impacts related to ACM and LBP.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.8, Hazards and Hazardous Materials.

5.1.7.3 Threshold HAZ-c
Less Than Significant: The Proposed Project would not emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school.

Findings of Fact 43 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Facts in Support of Findings
Focused General Plan Update
The siting of new public schools is strictly governed by the California Department of Education and the DTSC. These agencies ensure that schools are not located near hazardous sites unless comprehensive remediation has occurred. The City’s permitting process prevents the placement of incompatible hazardous land uses near sensitive receptors like private schools. Furthermore, childcare facilities are regulated under Title 22 (CCR) by the California Department of Social Services, which mandates licensing to ensure safety from environmental hazards.

Overall, implementation of existing applicable regulatory requirements would ensure that future development consistent with the Focused GPU would have less than significant hazardous materials impacts on schools. Therefore, implementation of the Project would not result in an impact associated with hazardous emissions or handling of hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school. Impacts would be less than significant.

Brea Core Specific Plan
Laurel Elementary School is within the BCSP. However, existing State land use control requirements by the California Department of Education and the DTSC would ensure that hazardous materials handling is not permitted at levels that would adversely affect these sensitive receptors. With continued compliance with existing regulatory requirements, development under the BCSP would not result in hazardous emissions or the handling of hazardous materials at levels that would adversely affect nearby schools. Impacts would be less than significant.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.8, Hazards and Hazardous Materials.

5.1.7.4 Threshold HAZ-d
Less Than Significant: The Proposed Project would not be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment.

Facts in Support of Findings
Focused General Plan Update and Brea Core Specific Plan The PEIR identifies several GeoTracker and EnviroStor sites within the City. For any new development or redevelopment on these listed sites, the DTSC, RWQCB, and OCHCA require cleanup and remediation through the standard grading and building permit process. Additionally, compliance with the CUPA and PPP HAZ-3 ensures that businesses handling significant quantities of hazardous Findings of Fact 44 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan materials maintain Risk Management Plans and submit Hazardous Materials Business Emergency Plans (HMBEP) to the California Environmental Reporting System (CERS). Implementation of all applicable Federal, State, and local regulations reduce the potential for hazardous conditions related to accidental release of hazardous materials or disturbance of hazardous materials sites.

With implementation of existing regulatory requirements, impacts would be less than significant.

Oil and Gas
For projects on or adjacent to former oil fields, the City’s Combustible Soil-Gas Ordinance and the Brea Fire Code mandate soil-gas testing and the installation of methane mitigation systems (e.g., alarms and passive/active venting). With the implementation of existing regulatory requirements, impacts would be less than significant.

Aboveground and Underground Storage Tanks
The removal of any aboveground storage tanks or USTs are required to be conducted in accordance with the regulations of OCHCA Environmental Health Division, which serves as the designated CUPA. The OCHCA Environmental Health Division implements State and Federal regulations for the Aboveground Storage Tank Program and Underground Storage Tank Program. Furthermore, any UST removals will be conducted in accordance with the California UST Regulations (23 CCR Chapter 16). With the implementation of existing regulatory requirements, impacts would be less than significant.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.8, Hazards and Hazardous Materials.

5.1.7.5 Threshold HAZ-e
Less Than Significant: The Proposed Project is not located within two miles of a public airport or public use airport and would not result in a safety hazard or excessive noise for people residing or working in the Project area.

Facts in Support of Findings:

Focused General Plan Update and Brea Core Specific Plan The City is not located within an airport land use plan or within 2 miles of a public airport or public use airport. Impacts would be less than significant.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.8, Hazards and Hazardous Materials.

Findings of Fact 45 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan

5.1.7.6 Threshold HAZ-f
Less Than Significant: The Proposed Project would not impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan.

Facts in Support of Findings:

Focused General Plan Update
All development would be required to go through the City’s development review and permitting process and comply with all applicable design and safety standards and regulations in the California Building Code, California Fire Code, and BCC to ensure that project development does not interfere with the provision of local emergency services (provision of adequate access roads to accommodate emergency response vehicles, adequate numbers/locations of fire hydrants, etc.).

Future development would be required to comply with these updated policies and all related City regulations. Impacts would be less than significant.

Brea Core Specific Plan
All construction and operational activities under the BCSP would be required to follow applicable City and Brea Fire Department requirements, including emergency access standards, construction safety measures, and provisions for sufficient fire protection infrastructure. Development would also undergo the City’s standard development review and permitting process to ensure adherence to the California Building Code and BCC. With compliance with these established regulatory requirements and emergency access standards, development under the BCSP would not obstruct emergency response routes or conflict with emergency evacuation operations. Therefore, implementation of the BCSP would not impair or physically interfere with an adopted emergency response or evacuation plan. Impacts would be less than significant.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.8, Hazards and Hazardous Materials.

5.1.7.7 Threshold HAZ-g
Less Than Significant: The Proposed Project would not expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires.

Facts in Support of Findings
Focused General Plan Update and Brea Core Specific Plan Focused General Plan Update
Findings of Fact 46 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Portions of the City are in high and very high Fire Hazard Severity Zones (FHSZs) in both Local and State Responsibility Areas. Impacts associated with wildland fires are discussed in detail in Section

4.16, Wildfire, of the PEIR. As described therein, with the implementation of existing regulatory requirements (PPP PS-1 through PPP PS-6, and PPP TRA-2), implementation of the Proposed Project would not expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires, and the impact would be less than significant.

Brea Core Specific Plan
There are no high or very high FHSZs in the BCSP area. Implementation of the Proposed Project would not expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires, and the impact would be less than significant.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.8, Hazards and Hazardous Materials, and Section 4.16, Wildfire.

5.1.7.8 Plans, Programs, and Policies
While no mitigation measures have been identified for the above-listed thresholds, the following existing plans, programs, and policies are identified in the PEIR as applicable to the Proposed Project.

PPP HAZ-1 Transportation of Hazardous Waste. Hazardous materials and hazardous wastes will be transported to and/or from the project developed under the Focused General Plan Update and the Brea Core Specific Plan in compliance with applicable State and Federal requirements, including the U.S. Department of Transportation regulations listed in the Code of Federal Regulations (Title 49, Hazardous Materials Transportation Act); California Department of Transportation standards; and the California Occupational Safety and Health Administration standards.

PPP HAZ-2 Resource Conservation and Recovery Act. Hazardous waste generation, transportation, treatment, storage, and disposal will be conducted in compliance with the Subtitle C of the Resource Conservation and Recovery Act (Code of Federal Regulations, Title 40, Part 263), including the management of nonhazardous solid wastes and underground tanks storing petroleum and other hazardous substances.

PPP HAZ-3 Certified Unified Program Agency. Development under the Focused General Plan Update and the Brea Core Specific Plan will be designed and constructed in accordance with the regulations of the Orange County Health Care Agency Environmental Health Department (OCHCA-EHD), which serves as the designated Certified Unified Program Agency. OCHCA-EHD implements State and Federal regulations for the following programs: (1) Hazardous Waste Generator Program, Findings of Fact 47 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan (2) Hazardous Materials Release Response Plans and Inventory Program, (3) California Accidental Release Prevention, (4) Aboveground Storage Tank Program, and (5) Underground Storage Tank Program.

PPP HAZ-4 California UST Regulations. Underground storage tank (UST) repairs and/or removals will be conducted in accordance with the California UST Regulations (California Code of Regulations, Title 23, Chapter 16). Any unauthorized release of hazardous materials will require release reporting, initial abatement, and corrective actions that will be completed with oversight from the Regional Water Quality Control Board, Department of Toxic Substances Control, Brea Fire Department, Brea Building & Safety Division, Orange County Heath Agency, South Coast Air Quality Management District, and/or other regulatory agencies, as necessary. Use of existing USTs will also have to be conducted (i.e., used, maintained and monitored) in accordance with the California UST Regulations (Title 23, Chapter 16 of the California Code of Regulations).

PPP HAZ-5 Asbestos-Containing Materials and Lead-Based Paints. Demolition activities that have the potential to expose construction workers and/or the public to asbestoscontaining materials or lead-based paint are required to be conducted in accordance with applicable regulations, including, but not limited to:
• South Coast Air Quality Management District’s Rule 1403 • California Health and Safety Code (Section 39650 et seq.) • California Code of Regulations (Title 8, Section 1529) • California Occupational Safety and Health Administration regulations (California Code of Regulations, Title 8, Section 1529 [Asbestos] and Section 1532.1 [Lead]) • Code of Federal Regulations, Title 40, Part 61 (asbestos); Title 40, Part 763 (asbestos); and Title 29, Part 1926 (asbestos and lead) PPP HAZ-6 Removal of Hazardous Materials. The removal of hazardous materials, such as polychlorinated biphenyls (PCBs), mercury-containing light ballast, and mold, will be completed in accordance with applicable regulations pursuant to 40 Code of Federal Regulations (CFR) 761 (PCBs), 40 CFR 273 (mercury-containing light ballast), and 29 CFR 1926 (molds) by workers with the hazardous waste operations and emergency response training, as outlined in 29 CFR Section 1910.120 and 8 California Code of Regulations, Section 5192.

PPP HAZ-7 Removal of Utility Lines and Pipelines. New construction, excavations, and/or new utility lines within 10 feet of or crossing existing high-pressure pipelines, natural gas/petroleum pipelines, or electrical lines greater than 60,000 volts will comply with the California Code of Regulations, Title 8, Section 1541.

Findings of Fact 48 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan PPP HAZ-8 Design and Safety. Development will comply with the requirements of the Brea City Code, Title 8, Health, Safety, and Welfare, and all applicable design and safety standards and regulations in the California Building Standards Code of Regulations Title 24. All construction documents shall be submitted for review to the Brea Building & Safety Division.

PPP HAZ-9 Brea Local Hazard Mitigation Plan. The City of Brea will comply with the Local Hazard Mitigation Plan by implementing the mitigation action items identified in Table 5-3, Mitigation Actions Implementation Plan, of the Local Hazard Mitigation Plan. These actions address topics such as Emergency Preparedness Activities, Multiple Hazards, Earthquake Hazards, Wildland/Urban Fires, Human-Caused Hazards (Hazardous Materials, Active Shooter/Terrorism), Severe Weather (Windstorm, Extreme Heat, Winter Storm), Geologic Hazards (Landslide, Soil Erosion), and Flooding (including Dam Failure).

PPP PS-2 Development Fees. Development under the Focused General Plan Update and the Brea Core Specific Plan will be required to pay the latest adopted Development Fees (e.g., Fire Department plan check and inspection fees, fire service connection fees, dispatch impact fees, and fire impact fees), as applicable.

PPP PS-5 Fire Safety Standards. For each new development facilitated under the Focused General Plan Update and the Brea Core Specific Plan, fire plans shall be submitted and reviewed by the Brea Fire Department to ensure compliance with fire safety and emergency response standards.

PPP PS-6 Fuel Modification Standards. All development under the Focused General Plan Update will be designed, built, and operated in accordance with the Brea Fire Department’s Very High Fire Hazard Severity Zone–Fuel Modification requirements, if applicable.

This plan will include such elements as the location of any potential partial lane closures within the public right-of-way, hours during which lane closures (if any) would not be allowed, local traffic detours (if any) that may require rerouting of traffic through the public right-of-way, and protective devices and traffic controls (such as barricades, cones, flag persons, lights, warning beacons, temporary traffic signals, warning signs). The project applicant will be required to comply with the City-approved plan measures, including any specific regulations for construction activities and traffic control in the public right-of-way.

Findings of Fact 49 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan The new or updated general plan goals and policies related to hazards and hazardous materials are included as Appendix C, Brea 2050 General Plan: Goals, Policies, and Actions, to the Program Environmental Impact Report (PEIR).

5.1.8 Hydrology and Water Quality
Finding: The Project would have less than significant direct, indirect, and cumulative impacts on the below listed threshold of significance. Accordingly, no changes or alterations to the Project were required to avoid or substantially lessen any significant environmental impacts under those thresholds. The PEIR evaluated the following impacts and found that no mitigation was required for the identified reasons.

5.1.8.1 Threshold HYD-a
Less Than Significant: The Proposed Project would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality.

Facts in Support of Findings
Focused General Plan Update and Brea Core Specific Plan Construction
Future development is mandated to comply with the National Pollutant Discharge Elimination System (NPDES) Construction General Permit. For sites over one acre, a Stormwater Pollution Prevention Plan (SWPPP) must be implemented using Best Management Practices (BMPs) to control erosion and prevent the discharge of construction-related pollutants. Small sites (under one acre) are subject to mandatory City water quality protection measures included in grading and building permits. Therefore, impacts would be less than significant.

Post-Construction and Operation
New development and significant redevelopment must adhere to Brea City Code Chapter 13.32 and the Drainage Area Management Plan (DAMP). Projects adding over 5,000 square feet of impervious surface are required to prepare a Water Quality Management Plan (WQMP) that utilizes Low Impact Development (LID) techniques to mimic natural hydrologic patterns and treat runoff before it leaves the site. Therefore, operation of the Proposed Project would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality and impacts would be less than significant.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.9, Hydrology and Water Quality.

Findings of Fact 50 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan

5.1.8.2 Threshold HYD-b
Less Than Significant: The Proposed Project would not substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the Proposed Project may impede sustainable groundwater management of the basin.

Facts in Support of Findings
Focused General Plan Update
The Project focuses on the redevelopment of existing urbanized areas. Because these sites are currently largely impervious, redevelopment, combined with modern low impact development and landscaping requirements, including Chapter 13.32 of the BCC and the DAMP could actually increase localized groundwater infiltration compared to existing conditions. Furthermore, while the Project overlies the La Habra Groundwater Basin, construction and operation will not involve direct groundwater extraction. Compliance with existing regulatory requirements would ensure that construction and operation of the Proposed Project do not substantially decrease groundwater supplies or interfere substantially with groundwater recharge. Impacts would be less than significant.

Brea Core Specific Plan
The BCSP area overlies the La Habra groundwater basin. The BCSP area is fully developed with existing residential and commercial/industrial uses with associated large areas dedicated to surface parking. For the same reasons discussed above for the Focused GPU, construction and operation of the BCSP would not substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the Proposed Project may impede sustainable groundwater management of the basin. Impacts would be less than significant.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.9, Hydrology and Water Quality.

5.1.8.3 Threshold HYD-c
Less Than Significant: The Proposed Project would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would result in substantial erosion or siltation on- or off-site; substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or offsite; create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff; and impede or redirect flood flow.

Findings of Fact 51 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Facts in Support of Findings
Focused General Plan Update
Erosion and Siltation
Mandatory compliance with NPDES permits during construction and WQMP/LID requirements post-construction ensures that runoff flow rates and velocities are controlled to prevent on-site or off-site erosion and siltation. Impacts would be less than significant.

Stormwater Drainage and Localized Flooding
Future development compliance with existing storm water management regulations and the continued master planning for the Citywide drainage system would ensure that buildout of the Project area would not substantially increase the rate or amount of surface runoff in a manner which would result in flooding on or off site, or exceed the capacity of the drainage system.

Therefore, impacts would be less than significant.

Redirection of Flood Flows
Refer to discussion under Impact Finding: Threshold HYD-d.

Brea Core Specific Plan
Erosion and Siltation
The analysis above for the Focused GPU applies to the BCSP. Mandatory compliance with stormwater flow controls during site design review of future development would minimize the potential to increase erosion and siltation on- and off-site. Impacts would be less than significant.

Stormwater Drainage and Localized Flooding
Future project-specific stormwater management plans, preliminary or final, would be required consistent with Chapter 13.32 of the BCC and DAMP. Therefore, the Proposed Project would not substantially increase the rate or amount of surface runoff in a manner which would result in flooding on or off site, or exceed the capacity of the drainage system. Therefore, impacts would be less than significant.

Redirection of Flood Flows
Refer to discussion under Impact Finding: Threshold HYD-d.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.9, Hydrology and Water Quality.

Findings of Fact 52 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan

5.1.8.4 Threshold HYD-d
Less Than Significant: The Proposed Project would not risk release of pollutants due to Project inundation by being in flood hazard, tsunami, or seiche zones.

Facts in Support of Findings
Focused General Plan Update
Future development within Federal Emergency Management Agency (FEMA)-designated flood zones (associated with Brea Creek and Fullerton Creek) must comply with BCC Title 18, Floodplain Management, which regulates design to minimize flood risk. Future projects will address inundation risk through the development review process. Impacts related to flood hazard or seiche zones would be less than significant.

Brea Core Specific Plan
Redevelopment facilitated by the BCSP would be located in developed areas already subject to potential dam inundation. Future development would address dam inundation as part of the development review process to inform design as necessary to minimize adverse risk in the unlikely event of a dam breach.

No bodies of water capable of producing a seiche are located within or immediately adjacent to the BCSP area.

Therefore, impacts related to flood hazard or seiche zones would be less than significant.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.9, Hydrology and Water Quality.

5.1.8.5 Threshold HYD-e
Less Than Significant: The Proposed Project would not conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan.

Facts in Support of Findings
Focused General Plan Update
Water Quality Control Plan
The Project is subject to the Santa Ana River Basin Plan. Compliance with NPDES requirements, the City’s Water Quality Ordinance (BCC 13.32), and LID standards ensures that both construction and operational activities do not interfere with the water quality objectives established by the RWQCB.

As described under Threshold HYD-a, construction and operation of future development within the Findings of Fact 53 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Project area would comply with the NPDES Construction General Permit, Chapter 13.32 of the BCC, and DAMP. With implementation of these regulations during future project design, construction, and operation, the Proposed Project would not obstruct the Basin Plan. Impacts would be less than significant.

Sustainable Groundwater Management Plan
Refer to Impact Finding: Threshold HYD-b. The Proposed Project would not conflict with the applicable sustainable groundwater management plan. Impacts would be less than significant.

Brea Core Specific Plan
Water Quality Control Plan
The analysis above for the Focused GPU applies to the BCSP. As described under Threshold HYD a, construction and operation of future development within the BCSP area would comply with the NPDES Construction General Permit, Chapter 13.32 of the BCC and DAMP. With implementation of these regulations during future project design, construction, and operation, the Proposed Project would not obstruct the Basin Plan. Impacts would be less than significant.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.9, Hydrology and Water Quality.

5.1.8.6 Plans, Programs, and Policies
While no mitigation measures have been identified for the above-listed thresholds, the following existing plans, programs, and policies are identified in the FEIR as applicable to the Proposed Project.

PPP HYD-1 Compliance with the following State, regional, and local regulations concerning grading, stormwater, and water quality control will be required. • National Pollutant Discharge Elimination System General Construction Permit.

Notice of Intent and Storm Water Pollution Prevention Plan Requirements • State Water Resources Control Board General Industrial Activities Storm Water Permit
• Santa Ana Regional Water Quality Control Board Waste Discharge Permits and Water Quality Certifications
• Orange County Municipal Separate Storm Sewer Systems Permit Findings of Fact 54 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan • Orange County Model Water Quality Management Plan and Technical Guidance Document

5.1.9 Land Use and Planning
Finding: The Project would have less than significant direct, indirect, and cumulative impacts on the below listed threshold of significance. Accordingly, no changes or alterations to the Proposed Project were required to avoid or substantially lessen any significant environmental impacts under those thresholds. The PEIR evaluated the following impacts and found that no mitigation was required for the identified reasons.

5.1.9.1 Threshold LU-a
Less Than Significant: The Proposed Project would not physically divide an established community.

Facts in Support of Findings
Focused General Plan Update
The proposed land use and zoning changes would facilitate future redevelopment within already highly developed parts of the City. No aspect of the Proposed Project would physically divide an established community. The proposed Project includes provisions that would directly address land use connectivity, compatibility, and encroachment of new development on existing neighborhoods and land uses. Therefore, the Proposed Project would not result in an impact regarding the division of an established community.

Brea Core Specific Plan
As with the Focused GPU, the proposed land use and zoning changes would facilitate future redevelopment within already highly developed parts of the City for the BCSP. No aspect of the BCSP would physically divide an established community. The BCSP includes provisions that would directly address land use connectivity, compatibility, and encroachment of new development on existing neighborhoods and land uses. Therefore, the BCSP would not result in an impact regarding the division of an established community.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.10, Land Use and Planning.

5.1.9.2 Threshold LU-b
Less Than Significant: The Proposed Project would not cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect.

Findings of Fact 55 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Facts in Support of Findings
Focused General Plan Update
As discussed in Table 4.10-1, Consistency with Applicable 2024–2050 SCAG RTP/SCS Goals, of the PEIR, the Focused GPU would not conflict with the goals of the RTP/SCS. The goals and policies as identified within Appendix C, Brea 2050 General Plan: Goals, Policies, and Actions, would help to mitigate or avoid environmental effects due to implementation of the Proposed Project. These modifications would not remove or adversely alter portions of the BCC that were adopted to mitigate an environmental effect. Subsequent development and infrastructure projects would be required to be consistent with all applicable policies, standards, and regulations, including land use plans, policies, and regulations adopted to mitigate environmental effects by the City, as well as those adopted by agencies with jurisdiction over components of future development project. The Focused GPU would have a less than significant impact.

Brea Core Specific Plan
The BCSP focuses new housing and commercial development in existing commercial corridors and in proximity to transit; prioritizing local serving businesses; fostering land use development patterns and densities and streetscapes that promote a more active pedestrian environment; and improving the variety of travel choices for residents such as walking, biking, and public transit. The BCSP would also be consistent with RTP/SCS and State goals through emphasis on design and reduction in vehicle miles traveled. Furthermore, as with the Focused GPU, these modifications would not remove or adversely alter portions of the Brea City Code that were adopted to mitigate an environmental effect. Subsequent development and infrastructure projects would be required to be consistent with all applicable policies, standards, and regulations, including land use plans, policies, and regulations adopted to mitigate environmental effects by the City, as well as those adopted by agencies with jurisdiction over components of future development project. Impacts would be less than significant.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.10, Land Use and Planning.

5.1.10 Noise
Finding: The Project would have less than significant direct, indirect, and cumulative impacts on the below threshold of significance. Accordingly, no changes or alterations to the Project were required to avoid or substantially lessen any significant environmental impacts under those thresholds. The PEIR evaluated the following impacts and found that no mitigation was required for the identified reasons.

Findings of Fact 56 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan

5.1.10.1 Threshold NOI-c:

No Impact: The Project area is not located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, exposure of people residing or working in the Project area to excessive noise levels.

Facts in Support of Findings
Focused General Plan Update and Brea Core Specific Plan There are no public airports or private airstrips within the City. The City is not located within an airport land use plan or within 2 miles of a public airport or public use airport. No impact would occur.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.11, Noise.

5.1.11 Public Services
Finding: The Project would have less than significant direct, indirect, and cumulative impacts on the below threshold of significance. Accordingly, no changes or alterations to the Project were required to avoid or substantially lessen any significant environmental impacts under those thresholds. The PEIR evaluated the following impacts and found that no mitigation was required for the identified reasons.

5.1.11.1 Threshold PS-a(i)
Less Than Significant: The Proposed Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered fire protection facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives.

Facts in Support of Findings
Focused General Plan Update
All future development would be reviewed by Brea Fire Department for compliance with BCC Chapter

16.04, Brea Fire Code, California Building Code, California Health and Safety Code, and other existing regulatory requirements as discussed in Section 4.12.1.1 and Section 4.12.1.3, of the PEIR. Additionally, the City would evaluate fire service needs periodically through deployment analysis, staffing assessments, and ongoing Standards of Coverage and Community Risk Assessment work.

Development Fees, including Dispatch Impact Fees, Fire Impact Fees, Plan Check and Inspection Fees, and Fire Service Connection Fees may need to be re-evaluated and updated to ensure that Findings of Fact 57 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan new development contributes its fair share toward the facilities, staffing, and apparatus needed to support Citywide growth.

Brea Core Specific Plan
Given its highly urbanized setting, strong existing emergency service coverage, and compliance with regulatory requirements as discussed in Section 4.12.1.1 and Section 4.12.1.3, of the PEIR., impacts related to fire protection facilities under the BCSP would be less than significant.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.12, Public Services.

5.1.11.2 Plans, Programs, and Policies
While no mitigation measures have been identified for the above-listed thresholds, the following existing plans, programs, and policies are identified in the PEIR as applicable to the Proposed Project.

PPP PS-1 Fire Regulations. New buildings developed under the Focused General Plan Update and the Brea Core Specific Plan are required to meet the fire regulations outlined in California Health and Safety Code (Sections 13000 et seq.).

PPP PS-3 Brea Fire Code. All development developed under the Focused General Plan Update and the Brea Core Specific Plan will be designed, built, and operated in accordance with the City of Brea’s City Code, Chapter 15.08, Building Code, and Chapter 16.04, Brea Fire Code.

PPP PS-4 Site and Design Review. The Brea Fire Department will require approval of Fire Plan Check for Site Plan and Emergency Access. Additional design features to address the Brea Fire Department’s requirements will be incorporated as conditions of approval for development under the Focused General Plan Update and the Brea Core Specific Plan.

Findings of Fact 58 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan PPP PS-6 Fuel Modification Standards. All development under the Focused General Plan Update will be designed, built, and operated in accordance with the Brea Fire Department’s Very High Fire Hazard Severity Zone–Fuel Modification requirements, if applicable.

PPP TRA-2 Traffic Control and Staging. A site-specific construction worksite staging and traffic control plan within the public right-of-way will be prepared and submitted to the City of Brea for review and approval prior to the start of any construction work. This plan will include such elements as the location of any potential partial lane closures within the public right-of-way, hours during which lane closures (if any) would not be allowed, local traffic detours (if any) that may require rerouting of traffic through the public right-of-way, and protective devices and traffic controls (such as barricades, cones, flag persons, lights, warning beacons, temporary traffic signals, warning signs).

The project applicant will be required to comply with the City-approved plan measures, including any specific regulations for construction activities and traffic control in the public right-of-way.

The new or updated general plan goals and policies related to public services are included as Appendix C, Brea 2050 General Plan: Goals, Policies, and Actions, to the PEIR.

5.1.11.3 Threshold PS-a(ii)
The Proposed Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered police protection facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives.

Facts in Support of Findings
Focused General Plan Update and Brea Core Specific Plan Any future construction or expansion of police facilities would be subject to discretionary approval and project-level review under CEQA and would be required to comply with all applicable federal, State, and local laws and regulations, including payment of Dispatch Impact Fees. With adherence to the City’s development review process and applicable regulatory requirements, impacts related to the provision of new or physically altered police protection facilities would be less than significant.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.12, Public Services.

Findings of Fact 59 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan

5.1.11.4 Plans, Programs, and Policies
While no mitigation measures have been identified for the above-listed thresholds, the following existing plans, programs, and policies are identified in the PEIR as applicable to the Project.

PPP PS-8 As part of the project review process, the Brea Police Department will recommend the following project design features to improve security on project sites. • Provide individual mailboxes rather than gang mailboxes to reduce mail theft vulnerability.
• All common areas should be properly lit to increase surveillance and discourage unwanted activities.
• All trail/park areas should include connectivity for potential future surveillance camera locations.
• Provide the maximum amount of off-street.

PPP PS-9 The project applicant will consult with the Brea Police Department on street addressing and signage, particularly in high density areas.

PPP PS-10 The project applicant is required to pay dispatch impact fees and all other development impact and/or special assessment fees as deemed applicable by the City of Brea.

PPP PS-2 and PPP TRA-2 will also apply.

The new or updated general plan goals and policies related to public services are included as Appendix C to the PEIR.

5.1.11.5 Threshold PS-a(iii)
The Proposed Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered schools, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives.

Facts in Support of Findings
Focused General Plan Update and Brea Core Specific Plan The program under Senate Bill 50 has been found by the legislature to constitute “full and complete mitigation of the impacts of any legislative or adjudicative act on the provision of adequate school facilities.” The fees authorized for collection by Brea Olinda Unified School District and other applicable school districts are therefore deemed full and adequate mitigation of impacts on those districts.

Furthermore, cumulative school projects require discretionary actions and would be required to Findings of Fact 60 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan demonstrate compliance with CEQA prior to project approval. The Proposed Project would not combine with areawide growth to result in cumulatively considerable impacts to school services.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.12, Public Services.

5.1.11.6 Plans, Programs, and Policies
While no mitigation measures have been identified for the above-listed thresholds, the following existing plans, programs, and policies are identified in the PEIR as applicable to the Project.

PPP PS-11 Development Impact Fees. Pursuant to Assembly Bill 2926, new development is required to pay development impact fees to assist in providing school facilities to serve students generated by new development.

PPP PS-12 School Facilities Impact Fee. Pursuant to Senate Bill 50, new development is required to offset the costs associated with increasing school capacity, where the funds collected go to acquiring school sites, constructing new school facilities, and modernizing existing school facilities.

5.1.11.7 Threshold PS-a(iv)
The Proposed Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered parks, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives.

Facts in Support of Findings
Focused General Plan Update and Brea Core Specific Plan Future projects would be required to meet the City’s standards and overall would result in continuing to balance the ratio of parkland per City residents. The Proposed Project is required to pay Park Development Fees pursuant to Brea City Code Section 18.64.080 (PPP PS-13). Therefore, impacts to parks would be less than significant.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.12, Public Services.

5.1.11.8 Plans, Programs, and Policies
While no mitigation measures have been identified for the above-listed thresholds, the following existing plans, programs, and policies are identified in the PEIR as applicable to the Project.

Findings of Fact 61 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan PPP PS-13 Park Development Fees. The project is required to comply with Brea City Code Section 18.64.080 that establishes the subdivision regulations for the provision of park and recreational facilities through land dedication, installation of improvements, payment of in-lieu fee thereof, or a combination. Where applicable, new development is required to fund park development and improvements through the payment of Park Development Fees.

5.1.11.9 Threshold PS-a(v)
The Proposed Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered other public facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives.

Facts in Support of Findings
Focused General Plan Update and Brea Core Specific Plan Future development consistent with the Proposed Project would result in additional library space to accommodate the increased demands. Library facilities improvements would be funded through a combination of state grants and dedicated property taxes, It is anticipated that any new library facilities necessitated would under their own CEQA review prior to approval. . Future development consistent with the Focused GPU would not result in a substantial adverse physical impact related to the need for other public facilities including libraries, and impacts would be less than significant.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.12, Public Services.

5.1.12 Transportation
Finding: The Project would have less than significant direct, indirect, and cumulative impacts on the below threshold of significance. Accordingly, no changes or alterations to the Project were required to avoid or substantially lessen any significant environmental impacts under those thresholds. The PEIR evaluated the following impacts and found that no mitigation was required for the identified reasons.

5.1.12.1 Threshold TRA-a
Less Than Significant: The Proposed Project would not conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities.

Findings of Fact 62 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Facts in Support of Findings
Focused General Plan Update and Brea Core Specific Plan Roadways
As land use projects are approved and developed within the City, 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 Focused GPU 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
The Mobility Element developed as part of the Focused GPU contains policies that support access to and the performance of public transit, bicycle, and pedestrian facilities. Policies in the Mobility Element promote multimodal access, connectivity, safety, and transit-supportive 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 Focused GPU’s impacts related to roadways, transit, bicycle, and pedestrian facilities would be considered less than significant.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.13, Transportation, and Appendix H, Transportation Impact Analysis.

5.1.12.2 Threshold TRA-b
Less Than Significant: The Proposed Project would not conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b).

Facts in Support of Findings
Focused General Plan Update
Citywide VMT per Service Population Analysis
Findings of Fact 63 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan As shown in Table 4.13-1, Citywide VMT per Service Population Analysis, of the PEIR, 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.

Also, as shown in Table 4.13-2, Link-Level Boundary Citywide VMT per Service Population Threshold, 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.

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

As shown in Table 4.13-3, VMT per Service Population Threshold for the Brea Core Specific Plan, VMT per SP would decrease with the Project. Impacts would be less than significant.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.13, Transportation, and Appendix H, Transportation Impact Analysis.

5.1.12.3 Threshold TRA-c
Less Than Significant: The Proposed Project would not substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment).

Facts in Support of Findings
Focused General Plan Update
The Focused GPU is a programmatic level document and 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 as part of the Focused GPU are generally similar to existing and surrounding uses and thereby are compatible with the existing uses and in the surrounding area.

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. Refer to Appendix C, Brea 2050 General Plan: Goals, Policies, and Actions, of the PEIR. Therefore, the Focused GPU’s impacts Findings of Fact 64 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan related to geometric design and incompatible use hazards would be considered less than significant.

Brea Core Specific Plan
Increased hazards due to geometric design features are typically assessed at the project-level. The BCSP does not propose any site-specific projects within its boundaries. Individual projects within the BCSP would be reviewed by the City during the development review and permitting process for consistency with the BCSP’s circulation system to ensure that they would not result in hazardous geometric design features.

Planned improvements to the pedestrian, transit, and bicycle networks—such as new crosswalks and off-street bike lanes—are intended to enhance safety. These facilities will be designed in accordance with the California Manual on Uniform Traffic Control Devices (CA MUTCD) and the Caltrans Construction Manual to prevent the introduction of sharp curves or dangerous conflict points. All improvements within the public right-of-way must adhere to standard traffic safety practices, ensuring that the transition from current conditions to the buildout of the Specific Plan does not create hazardous conditions for motorists, cyclists, or pedestrians.

Therefore, implementation of the BCSP would not substantially increase the potential for traffic hazards, and impacts related to design features or incompatible uses would be less than significant.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.13, Transportation, and Appendix H, Transportation Impact Analysis.

5.1.12.4 Threshold TRA-d
Less Than Significant: The Proposed Project would not result in inadequate emergency access.

Facts in Support of Findings
Focused General Plan Update
The Focused GPU is a programmatic level documents without any site-specific projects. The Focused GPU establishes a comprehensive framework for public safety through the coordination of the Mobility Element and the Public Safety Element. Some of the key policies mandate the maintenance of a connected and resilient street network that ensures clear evacuation paths and reliable access for emergency responders. Refer to Appendix C, Brea 2050 General Plan: Goals, Policies, and Actions, of the PEIR.

In addition, the new Mobility Element is supported by the updated Public Safety Element, which outlines strategies to mitigate risks associated with natural hazards, including wildfires, floods, and Findings of Fact 65 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan earthquakes, working in conjunction with the Brea Local Hazard Mitigation Plan (LHMP) and Emergency Operations Plan (EOP).

Future development is required to adhere to the latest Brea Fire and Building Codes, ensuring that site-specific designs—especially in Very High Fire Hazard Severity Zones (VHFHSZs)—incorporate mandatory fire protection plans and fuel modification.

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 City Code. The Focused GPU 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 Focused GPU would not result in inadequate emergency access or conflict with adopted emergency response and circulation policies. Therefore, the Focused GPU’s impacts related to emergency access would be considered less than significant.

Brea Core Specific Plan
Emergency accessibility is typically assessed at the project level. The BCSP does not propose any site-specific development projects. As individual sites are developed and undergo City development review and permitting process, internal circulation system within the site and connection with the City’s street system would be reviewed to ensure that neither on-site designs nor the interaction with City streets would result in inadequate emergency access. The Brea Fire Department would also review individual projects for adequate provision of emergency access, water, and accessibility.

Individual projects within the BCSP would also be subject to building plan check for site plan and emergency access to ensure that appropriate fire safety features have been incorporated to reduce project impacts. Therefore, impacts would be less than significant, and the BCSP is not anticipated to result in inadequate emergency access.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.13, Transportation, and Appendix H, Transportation Impact Analysis.

5.1.12.5 Plans, Programs, and Policies
While no mitigation measures have been identified for the above-listed thresholds, the following existing plans, programs, and policies are identified in the FEIR as applicable to the Project.

PPP TRA-1 Each project applicant in the City of Brea is required to pay development impact fees to the City of Brea pursuant to the City’s Assembly Bill 1600 Transportation Improvement Nexus Program (Ordinance 996). Based on a transportation Findings of Fact 66 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan improvement nexus program study conducted in 2011, the City Council adopted Resolution 2011-096, which updated the impact fees, effective February 4, 2012.

Fair-share fees offset or mitigate the cumulative traffic impacts caused by new development. The program ensures all future development in the City of Brea contributes on a fair-share basis.

5.1.13 Utilities and Service Systems
Finding: The Project would have less than significant direct, indirect, and cumulative impacts on the below threshold of significance. Accordingly, no changes or alterations to the Project were required to avoid or substantially lessen any significant environmental impacts under those thresholds. The PEIR evaluated the following impacts and found that no mitigation was required for the identified reasons.

5.1.13.1 Threshold UTL-b
The Project would have sufficient water supplies available to serve the Project and reasonably foreseeable future development during normal, dry and multiple dry years.

Facts in Support of Findings
Focused General Plan Update and Brea Core Specific Plan Table 4.15-6, Demand and Supply in Normal, Single Dry, and Multiple Dry Years, of the PEIR compares the existing supply with demand associated with the implementation of the Proposed Project within the 20-year planning horizon. As shown, there is sufficient supply in normal, single dry, and multiple dry years to meet projected water demand for the Focused GPU, including the BCSP.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.15, Utilities and Service Systems, and Appendix M, Water Supply Assessment.

Findings of Fact 67 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan

5.1.13.2 Threshold UTL-c
The Project would not result in a determination by the wastewater treatment provider which serves or may serve the Project that it has adequate capacity to serve the Project’s projected demand in addition to the provider’s existing commitments.

Facts in Support of Findings
Focused General Plan Update
New development constructed pursuant to the Focused GPU would increase wastewater generation.

Orange County Sanitation District (OCSD) provides ongoing analysis of the sewer system within its jurisdiction, ensuring the long-term functionality of OCSD facilities. Therefore, there is adequate capacity to serve the Proposed Project’s projected demand in addition to the provider’s existing commitments. Impacts would be less than significant.

Brea Cores Specific Plan
The BCSP would increase flows to the OCSD Fullerton–Brea Trunk Sewer/Interceptor and the OCSD Rolling Hills Sub-Trunk/Santa Ana River Interceptor. However, OCSD provides ongoing analysis of the sewer system within its jurisdiction, ensuring the long-term functionality of OCSD facilities. Therefore, there is adequate capacity to serve the Proposed Project’s projected demand in addition to the provider’s existing commitments. Impacts would be less than significant.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.15, Utilities and Service Systems, and Appendix K, Sanitary System Utility Study.

5.1.13.3 Threshold UTL-d
The Proposed Project would not generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals.

Facts in Support of Findings
Focused General Plan Update and Brea Core Specific Plan Waste from future development within the Focused GPU, including wastes from BCSP would be transported to the Olinda Alpha Landfill, which has the capacity to serve residents and businesses in Brea. There’s adequate local infrastructure to accommodate the Proposed Project, and the Proposed Project would not impair the attainment of solid waste reduction goals.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.15, Utilities and Service Systems.

Findings of Fact 68 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan

5.1.13.4 Threshold UTL-e
The Proposed Project would not comply with federal, state, and local management and reduction statutes and regulations related to solid waste.

Facts in Support of Findings
Focused General Plan Update and Brea Core Specific Plan Future development pursuant to the Focused GPU would be required to comply with Section 4.408 of the 2022 California Green Building Code Standards, BCC, and requirements of SB 341, AB 1826, and all applicable Federal, State, and local statutes and regulations related to solid waste disposal.

Therefore, impacts would be less than significant.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.15, Utilities and Service Systems.

5.1.13.5 Plans, Programs, and Policies
While no mitigation measures have been identified for the above-listed thresholds, the following existing plans, programs, and policies are identified in the FEIR as applicable to the Project.

PPP UTL-1 Development projects are required to comply with the following existing regulations as applicable.
• California Energy Code (Title 24, Part 6) and California Green Building Standards Code (CALGreen) (Title 24, Part 11).
• California Plumbing Code(Title 24, Part 5), a set of plumbing code requirements that establishes energy and water efficiency standards for new construction, additions, and alterations to existing buildings.
• SB 610 (Chapter 643, Statutes of 2001) and SB 221 (Chapter 642, Statutes of 2001). • California Green Building Standards Code, Chapter 5, Nonresidential Mandatory Measures, Division 5.3, Water Efficiency and Conservation. • California Green Building Standards Code, Chapter 4, Residential Mandatory Measures, Division 4.3, Water Efficiency and Conservation. • Energy Efficiency Standards for Residential and Nonresidential Buildings (24 CCR Part 6)
• California’s Appliance Efficiency Regulations (CCR Title 20, Parts 1600–1608) • Senate Bill 1383 (Short-Lived Climate Pollutant Reduction Strategy) and Assembly Bill (AB) 341/AB 1826 (commercial recycling/organics).
• Orange County Municipal Separate Storm Sewer Systems Permit • Orange County Model Water Quality Management Plan and Technical Guidance Document
Findings of Fact 69 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan • Orange County Drainage Area Management Plan. New Development/ Significant Redevelopment Program
• County of Orange/Orange County Flood Control District Local Implementation Plan PPP UTL-2 All new development projects are required to pay the City of Brea’s latest adopted Water Connections Fees, Water Impact Fees, Sewer Connection Fees, and Sewer Impact Fees, with the exception of:
• Alterations to an existing building;
• Reconstruction (within two years), when a building has been destroyed by fire, wind, earthquakes, vandalism, or other natural or man-made disasters; • Additions to a single-family or multiple-family residence; and • Construction of public schools.

5.1.14 Wildfire
Finding: The Proposed Project would have less than significant direct, indirect, and cumulative impacts on the below threshold of significance. Accordingly, no changes or alterations to the Proposed Project were required to avoid or substantially lessen any significant environmental impacts under those thresholds. The PEIR evaluated the following impacts and found that no mitigation was required for the identified reasons.

5.1.14.1 Threshold WILD-a
Less Than Significant: The Proposed Project would not substantially impair an adopted emergency response plan or emergency evacuation plan.

Facts in Support of Findings
Focused General Plan Update
All construction activities would be performed according to Brea Fire Department’s standards and regulations. Development facilitated by the Project would be required to provide the necessary onand off-site access and circulation for emergency vehicles and services during the construction and operation phases. The development facilitated by the Focused GPU would be required to go through the City’s development review and permitting process and incorporate all applicable design and safety standards and regulations in the California Building Code, California Fire Code, and BCC Section 16.04 to ensure that Project development does not interfere with the provision of local emergency services (provision of adequate access roads to accommodate emergency response vehicles, adequate numbers/locations of fire hydrants, etc.).

Brea Core Specific Plan
The BCSP is not located in or near SRAs or lands classified as Very High FHSZs.

Findings of Fact 70 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.16, Wildfire.

5.1.14.2 Threshold WILD-b
The Project would not, due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose Project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire.

Facts in Support of Findings
Focused General Plan Update
he Focused GPU guides land uses away from the most hazardous areas where feasible and requires new development to adhere to fire-resilient design standards, including defensible space, fire-resistant building materials, and coordination with the Orange County Fire Authority (OCFA) for fuel modification (PPP PS-6), emergency access, and evacuation planning. These policies, along with project-level fire plans required during discretionary development approvals (PPP PS-5), help to minimize the potential for uncontrolled wildfire spread and limit occupant exposure to smoke and pollutants. While the plan cannot eliminate wildfire risk entirely, its policies ensure that future development is designed and managed to reduce fire hazard potential and protect public safety.

Brea Core Specific Plan
The BCSP is not located in or near State Responsibility Areas (SRAs) or lands classified as Very High FHSZs.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.16, Wildfire.

5.1.14.3 Threshold WILD-c
The Proposed Project would not result in the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment.

Facts in Support of Findings
Focused General Plan Update
The Focused GPU includes policies that guide infrastructure planning and construction to minimize environmental impacts, such as requiring compliance with applicable City, OCFA, and State regulations, implementing erosion control measures during construction, avoiding or mitigating impacts to sensitive habitats, and maintaining natural vegetation where feasible. Additionally, all Findings of Fact 71 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan utility installations must comply with fire safety regulations, including standards for electrical equipment and fuel management around power lines, which help reduce the potential for infrastructure-related fire ignition.

Future development, particularly located in or near State Responsibility Areas (SRAs) or Very High Fire Hazard Safety Zones (FHSZ) in Local Responsibility Areas, would be required to comply with existing regulations developed by the State (e.g., CFC, CBC, PRC), County (e.g., Local Hazard Mitigation Plan), and City Code (Chapter 15.08, Building Code, of the BCC and Chapter 16.04, Brea Fire Code) which include various provisions for siting, construction, occupancy, and protection of development as it relates to wildfire hazards and reducing wildfire risks, wildfire exposure, and the uncontrolled spread of wildfires.

Brea Core Specific Plan
The BCSP is not located in or near SRAs or lands classified as Very High FHSZs.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.16, Wildfire.

5.1.14.4 Threshold WILD-d
Expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes.

Facts in Support of Findings
Focused General Plan Update
All potential future development within wildfire-prone areas in the City would also be required to comply with CFC, CBC, PRC, and other State and local regulations addressing the development and design of habitable structures to safeguard public health and reduce fire hazards. The Proposed Project would also be subject to stormwater management regulations as discussed in Section 4.9, Hydrology and Water Quality, of the PEIR, and with BCC Chapter 20.276 pertaining to the Flood Hazard Overlay Zoning District in the City.

Brea Core Specific Plan
The BCSP is not located in or near SRAs or lands classified as Very High FHSZs.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.16, Wildfire.

Findings of Fact 72 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan

5.1.14.5 Plans, Programs, and Policies
While no mitigation measures have been identified for the above-listed thresholds, the following existing plans, programs, and policies are identified in the FEIR as applicable to the Project.

PPP TRA-2 Traffic Control and Staging. A site-specific construction worksite staging and traffic control plan within the public right-of-way will be prepared and submitted to the City for review and approval prior to the start of any construction work. This plan will include such elements as the location of any potential partial lane closures within the public right-of-way, hours during which lane closures (if any) would not be allowed, local traffic detours (if any) that may require rerouting of traffic through the public right-of-way, and protective devices and traffic controls (such as barricades, cones, Findings of Fact 73 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan flag persons, lights, warning beacons, temporary traffic signals, warning signs). The project applicant will be required to comply with the City-approved plan measures, including any specific regulations for construction activities and traffic control in the public right-of-way.

The new or updated general plan goals and policies related to wildfire are included as Appendix C, Brea 2050 General Plan: Goals, Policies, and Actions, to the Program Environmental Impact Report (PEIR).

5.2 Findings Regarding Direct, Indirect, or Cumulative
Significant or Potentially Significant Effects
The following Findings address the direct, indirect, and cumulative environmental effects of the Proposed Project that are identified as significant or potentially significant. These Findings are based on, and incorporate by reference, the analysis and conclusions contained in the PEIR, including the Draft PEIR and all appendices (collectively, the “PEIR”).

Pursuant to California Public Resources Code Section 21081 and CEQA Guidelines Section 15091, the City Council finds that changes or alterations have been required in, or incorporated into, the Proposed Project that avoid or substantially lessen identified significant environmental effects.

Such findings are referred to herein as “Finding 1.”
The City Council has reviewed and considered the PEIR and the entire administrative record for the Proposed Project in making these Findings.

Pursuant to California Public Resources Code Section 21081 and CEQA Guidelines Section 15091, where responsibility for implementing mitigation measures lies with another public agency, and such measures have been or can and should be adopted by that agency, the City would make a finding pursuant to subdivision (a)(2) (“Finding 2”). However, based on the analysis in the PEIR, no such circumstances apply; therefore, Finding 2 is not adopted for any impact.

Consistent with CEQA Guidelines Section 15126.2, the PEIR identifies any significant impacts that cannot be avoided, even with implementation of feasible mitigation measures.

Pursuant to California Public Resources Code Section 21081 and CEQA Guidelines Section 15091, for impacts that remain significant and unavoidable, the City Council finds that specific economic, legal, social, technological, or other considerations—including the provision of employment opportunities—make infeasible additional mitigation measures or alternatives. This determination is referred to herein as “Finding 3.”.

Findings of Fact 74 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan

5.2.1 Air Quality

5.2.1.1 Threshold AQ-a
The Proposed Project could conflict with or obstruct implementation of the applicable air quality plan.

Finding: Pursuant to CEQA Guidelines Section 15091(a)(3), the City finds that the Project could conflict with or obstruct implementation of the applicable air quality plan. Although Mitigation Measure MM AQ-1 would reduce the Project’s air quality impacts, it would not reduce this impact to a less-than-significant level. Therefore, the impact would remain significant and unavoidable.

Approval of the Project requires adoption of a Statement of Overriding Considerations pursuant to CEQA Guidelines Section 15093.

Facts in Support of Findings:

The following facts support the above finding and are based on the PEIR, which is incorporated herein by reference:

Focused General Plan Update
Consistency Criterion 1. As demonstrated under Threshold AQ-b in the PEIR, Project construction and operational emissions would exceed applicable regional thresholds for criteria pollutants.

Although Mitigation Measure MM AQ-1 would reduce emissions, exceedances could still occur, and certain emission sources (e.g., mobile and area sources) are not fully within the City’s regulatory authority. As a result, the Project could contribute to existing air quality violations or delay attainment of applicable standards.

Consistency Criterion 2. The Project would accommodate development intensity beyond that assumed in the applicable Air Quality Management Plan (AQMP) growth forecasts. Although the Project promotes compact, mixed-use development consistent with regional planning objectives, the increase in development potential exceeds the assumptions used in the AQMP emissions inventory and forecasts.

Because the Project does not satisfy one or both AQMP consistency criteria, it would conflict with or obstruct implementation of the applicable air quality plan.

Brea Core Specific Plan
Consistency Criterion 1. As concluded below in Threshold AQ-b, the BCSP would not exceed the South Coast AQMD thresholds during construction or operation. Therefore, the BCSP would not conflict with Consistency Criterion 1.

Findings of Fact 75 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Consistency Criterion 2. Similar to the Focused GPU, the BCSP would accommodate additional residential and non-residential development beyond what is currently planned for the area under the 2003 General Plan. Growth would primarily be in the mixed-use category, consistent with regional goals for compact, mixed-use development. However, because growth would occur beyond the current air quality forecast for the AQMP, the BCSP would not be consistent with Consistency Criterion 2.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.2, Air Quality, and Appendix D1, Air Quality/GHG Data.

Mitigation Measures
MM AQ-1 Site-Specific Air Quality Analysis and Best Management Practices. Prior to the issuance of a grading or construction permit for individual development projects that are not exempt from California Environmental Quality Act (CEQA), and in conjunction with any required CEQA review, future project applicants shall submit to the City of Brea Planning Division documentation that the project is consistent with the South Coast Air Quality Management District (South Coast AQMD) mass daily significance thresholds and localized significance thresholds (LSTs) for criteria air pollutant emissions during construction. A project-specific Air Quality Analysis quantifying the potential air emissions of project construction shall be prepared by a qualified air quality professional. This Air Quality Analysis shall demonstrate that criteria air pollutant emissions are below the South Coast AQMD mass daily significance thresholds and LSTs. If the Air Quality Analysis cannot demonstrate that the project is below the South Coast AQMD thresholds before mitigation, the project applicant shall implement practices to reduce VOC and NOX emissions to the extent necessary to reduce emissions to below South Coast AQMD thresholds. Best management practices may include, but are not limited to:
• Use equipment with engines that meet, at a minimum, the Tier 4 Final California Emissions Standards, or electric-powered equipment.
• Use architectural coatings that meet “Super-Compliant” VOC standards (as defined in South Coast AQMD Rule 1113) and California Green Building Standards Code (CALGreen) requirements under the mandatory measures, or pre-coated materials such as bathroom stall dividers, and metal awnings.
• Minimize idling time either by shutting equipment off when not in use or reducing the time of idling to 5 minutes. Provide clear signage that posts this requirement for workers at the entrances to the site and at construction offices/trailers. • Maintain all construction equipment in proper working condition according to manufacturer’s specifications. The equipment must be checked by a certified mechanic and determined to be running in proper condition before it is operated.

Findings of Fact 76 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan The project applicant shall provide documentation to the City of Brea detailing the measures that would be implemented and that mitigated emissions would be below South Coast AQMD thresholds. Measures shall be included in project construction documents, and contractors and subcontractors shall implement the applicable South Coast AQMD measures.

5.2.1.2 Threshold AQ-b
The Proposed Project could result in a cumulatively considerable net increase of any criteria pollutant for which the Project region is non-attainment under an applicable Federal or State.

Finding: Pursuant to CEQA Guidelines Section 15091(a)(3), the City finds that the Project could result in a cumulatively considerable net increase of any criteria pollutant. Although Mitigation Measure MM AQ-1 would reduce the Project’s air quality impacts, it would not reduce this impact to a less-than-significant level. Therefore, the impact would remain significant and unavoidable.

Approval of the Project requires adoption of a Statement of Overriding Considerations pursuant to CEQA Guidelines Section 15093.

Facts in Support of Findings:

The following facts support the above finding and are based on the PEIR, which is incorporated herein by reference.

Focused General Plan Update
The Project was evaluated using regional thresholds established by the South Coast Air Quality Management District for criteria pollutants for which the South Coast Air Basin is in nonattainment (including VOC, NOx, PM₁₀, and PM₂.₅).

Construction
Buildout of development under the Project would generate construction-related emissions that could exceed applicable regional thresholds for VOC and NOx. While Mitigation Measure MM AQ-1 would require project-level analysis and implementation of best management practices, the specific timing, intensity, and equipment associated with future construction are not known at the program level. Therefore, it cannot be demonstrated that emissions would be reduced below applicable thresholds.

Operation
Long-term operation of development under the Project would increase emissions from mobile, area, and energy sources. As shown in the PEIR, operational emissions could exceed regional Findings of Fact 77 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan thresholds for VOC and particulate matter due to increases in vehicle trips, consumer product use, and other emission sources associated with planned growth.

Exceedance of applicable regional thresholds is considered cumulatively considerable because the Project is located within a nonattainment air basin and would contribute to regional pollutant burdens. Although mitigation would reduce emissions, it would not ensure that all future projects consistent with the Project would avoid exceeding applicable thresholds. Accordingly, the Project’s contribution to cumulative air quality impacts would remain cumulatively considerable.

Health impacts of Criteria Air Pollutants
Consistent with Sierra Club v. County of Fresno (2018) 6 Cal.5th 502, the PEIR qualitatively evaluates the relationship between criteria pollutant emissions and potential health effects. Due to the programmatic nature of the Project and the regional formation characteristics of certain pollutants (e.g., ozone), precise quantification of localized health impacts is not feasible at this stage. Such analysis would be conducted, as appropriate, at the project level.

Future individual projects would need to compare project emissions to the localized significance thresholds (LSTs) to determine if a potential localized impact would occur. This impact would be potentially significant.

Brea Core Specific Plan
Construction
As shown in Table 4.2-9, Estimated Brea Core Specific Plan Maximum Daily Construction Emissions (pounds/day), of the PEIR, construction emissions estimates indicate that development allowed under the BCSP would not result in significant air emissions during individual phases of construction.

The BCSP’s contribution to Focused GPU emissions is evaluated below in Section 4.2.5.2, Cumulative Threshold AQ-b.

Operation
As shown in Table 4.2-10, Net Change in BCSP Operational Emissions, of the PEIR, operational emissions for buildout of the BCSP would have the potential to exceed the South Coast AQMD threshold for VOC and particulate matter emissions, primarily due to the potential increase in the use of hearths and consumer products from increased development, followed by landscape equipment and mobile emissions. Therefore, direct impacts would be potentially significant.

Health impacts of Criteria Air Pollutants
Findings of Fact 78 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan As with the Focused GPU analysis, specifics of individual future projects are unknown, and future individual projects would need to compare project emissions to the LSTs and project-specific analysis would be required to determine if localized impacts would occur. This impact would be potentially significant.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.2, Air Quality, and Appendix D1, Air Quality/GHG Data.

5.2.1.3 Cumulative Impact Determination
Threshold AQ-a
Finding: Pursuant to CEQA Guidelines Section 15130, the City finds, in accordance with CEQA Guidelines Section 15091(a)(3), that the Project’s contribution to cumulative air quality impacts is cumulatively considerable. Although Mitigation Measure MM AQ-1 would reduce the Project’s contribution, it would not reduce the impact to a less-than-significant level. Therefore, the Project would result in a significant and unavoidable cumulative air quality impact.

Approval of the Project requires adoption of a Statement of Overriding Considerations pursuant to CEQA Guidelines Section 15093.

Facts in Support of Findings
Focused General Plan Update and Brea Core Specific Plan As set forth in the PEIR, the Project would not be consistent with the 2022 Air Quality Management Plan because it could generate emissions exceeding applicable regional thresholds and accommodate growth beyond AQMP assumptions. Such inconsistency indicates a conflict with regional strategies for attaining air quality standards in a nonattainment basin. Although Mitigation Measure MM AQ-1 would reduce emissions, it would not ensure consistency with the AQMP or reduce impacts to a less than significant level. Accordingly, the impact is significant and unavoidable.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.2, Air Quality, and Appendix D1, Air Quality/GHG Data.

Threshold AQ-b
Finding: Pursuant to CEQA Guidelines Section 15130, the City finds, in accordance with CEQA Guidelines Section 15091(a)(3), that the Project’s contribution to cumulative air quality impacts is cumulatively considerable. Although Mitigation Measure MM AQ-1 would reduce the Project’s contribution, it would not reduce the impact to a less-than-significant level. Therefore, the Project would result in a significant and unavoidable cumulative air quality impact.

Findings of Fact 79 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Approval of the Project requires adoption of a Statement of Overriding Considerations pursuant to CEQA Guidelines Section 15093.

Facts in Support of Findings:

Focused General Plan Update and Brea Core Specific Plan As demonstrated in the PEIR, construction and operational emissions associated with the Project could exceed applicable regional thresholds established by the South Coast Air Quality Management District for criteria pollutants in a nonattainment air basin. Consistent with South Coast AQMD guidance, exceedance of these thresholds constitutes a cumulatively considerable contribution to regional air quality impacts. Although Mitigation Measure MM AQ-1 would reduce emissions, it would not ensure that emissions would be reduced below applicable thresholds.

Accordingly, the impact is significant and unavoidable.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.2, Air Quality, and Appendix D1, Air Quality/GHG Data.

5.2.1.4 Plan, Programs, and Policies
While no mitigation measures have been identified for the above-listed thresholds, the following existing plans, programs, and policies are identified in the Final PEIR as applicable to the Proposed Project.

Refer to PPP AQ-1 and PPP AQ-2 in Section 5.1.2.3.

5.2.1.5 Mitigation Measures
MM AQ-1 Site-Specific Air Quality Analysis and Best Management Practices. Prior to the issuance of a grading or construction permit for individual development projects that are not exempt from California Environmental Quality Act (CEQA), and in conjunction with any required CEQA review, future project applicants shall submit to the City of Brea Planning Division documentation that the project is consistent with the South Coast Air Quality Management District (South Coast AQMD) mass daily significance thresholds and localized significance thresholds (LSTs) for criteria air pollutant emissions during construction. A project-specific Air Quality Analysis quantifying the potential air emissions of project construction shall be prepared by a qualified air quality professional. This Air Quality Analysis shall demonstrate that criteria air pollutant emissions are below the South Coast AQMD mass daily significance thresholds and LSTs. If the Air Quality Analysis cannot demonstrate that the project is below the South Coast AQMD thresholds before mitigation, the project applicant shall implement practices to reduce VOC and NOX emissions to the extent necessary to reduce Findings of Fact 80 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan emissions to below South Coast AQMD thresholds. Best management practices may include, but are not limited to:
• Use equipment with engines that meet, at a minimum, the Tier 4 Final California Emissions Standards, or electric-powered equipment.
• Use architectural coatings that meet “Super-Compliant” VOC standards (as defined in South Coast AQMD Rule 1113) and California Green Building Standards Code (CALGreen) requirements under the mandatory measures, or pre-coated materials such as bathroom stall dividers, and metal awnings.
• Minimize idling time either by shutting equipment off when not in use or reducing the time of idling to 5 minutes. Provide clear signage that posts this requirement for workers at the entrances to the site and at construction offices/trailers. • Maintain all construction equipment in proper working condition according to manufacturer’s specifications. The equipment must be checked by a certified mechanic and determine to be running in proper condition before it is operated.

The project applicant shall provide documentation to the City of Brea detailing the measures that would be implemented and that mitigated emissions would be below South Coast AQMD thresholds. Measures shall be included in project construction documents, and contractors and subcontractors shall implement the applicable South Coast AQMD measures.

5.2.2 Biological Resources

5.2.2.1 Threshold BIO-a
The Proposed Project could 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.

Finding: Pursuant to CEQA Guidelines Section 15091(a)(1), the City finds that, while the Project could result in potentially significant impacts to special-status species, implementation of Mitigation Measures MM BIO-1 through MM BIO-7 would reduce these impacts to a less-thansignificant level. No significant and unavoidable impacts would occur.

Facts in Support of Findings
Focused General Plan Update and Brea Core Specific Plan As described in the PEIR, the Project area contains a range of habitats that may support specialstatus plant and wildlife species. Future development facilitated by the Project could result in direct impacts (e.g., habitat removal) and indirect impacts (e.g., disturbance, lighting, and edge effects).

Findings of Fact 81 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Due to the programmatic nature of the Project, the precise location and extent of impacts on sensitive species are not known at this time and would be evaluated at the project level.

Mitigation Measures MM BIO-1 through MM BIO-7 require pre-construction biological surveys, identification of sensitive resources, avoidance and minimization measures, and compliance with applicable federal and state regulations. These measures ensure that where sensitive species are present, impacts would be avoided or minimized and reduced through standard regulatory compliance and project-specific mitigation. With implementation of these measures, impacts to special-status species would be reduced to a less-than-significant level.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.3, Biological Resources, and Appendix E, Biological Resources Technical Report.

5.2.2.2 Threshold BIO-b
The Proposed Project could have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Game or U.S. Fish and Wildlife Service.

Finding: Pursuant to CEQA Guidelines Section 15091(a)(1), the City finds that, while the Project could result in potentially significant impacts to riparian habitat or other sensitive natural community, implementation of Mitigation Measures MM BIO-3 through BIO-5, would reduce these impacts to a less-than-significant level. No significant and unavoidable impacts would occur.

Facts in Support of Findings
Focused General Plan Update
The PEIR identifies that sensitive vegetation communities, including riparian and other natural communities, may occur within the Project area and could be affected by future development.

Direct impacts could result from vegetation removal or disturbance, while indirect impacts could include changes in hydrology, erosion, and edge effects. The Project requires site-specific biological surveys to identify sensitive communities prior to development and to determine the extent of potential impacts. Mitigation Measures MM BIO-3 through MM BIO-5 require avoidance and minimization of impacts to sensitive communities and compliance with applicable regulatory requirements. Certain areas within the Project (e.g., previously developed or highly disturbed lands) do not support sensitive communities, which limits the potential for impacts. With implementation of mitigation and regulatory compliance, impacts to sensitive natural communities would be reduced to a less than significant level.

Findings of Fact 82 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Brea Core Specific Plan
Implementation of BCSP would not result in a substantial adverse effect on any riparian and other natural communities. Therefore, no direct impacts would occur.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.3, Biological Resources, and Appendix E, Biological Resources Technical Report.

5.2.2.3 Threshold BIO-c
The Proposed Project could have a substantial adverse effect on State or Federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means.

Finding: Pursuant to CEQA Guidelines Section 15091(a)(1), the City finds that, while the Project could result in potentially significant impacts to wetlands, implementation of Mitigation Measures MM BIO-1, and MM BIO-8 and MM BIO-9, would reduce these impacts to a less-than-significant level. No significant and unavoidable impacts would occur.

Facts in Support of Findings
Focused General Plan Update and Brea Core Specific Plan The PEIR identifies aquatic resources within the Project area that may be subject to federal and state jurisdiction. Future development could result in direct impacts (e.g., fill or removal) or indirect impacts (e.g., changes in hydrology or water quality) to these resources. Mitigation requires sitespecific delineation of jurisdictional waters where present and compliance with applicable permitting requirements. Required permits and mitigation measures would ensure avoidance, minimization, and, where necessary, compensation for impacts to jurisdictional resources.

Compliance with stormwater regulations and best management practices would reduce indirect impacts related to erosion and runoff. With implementation of mitigation and regulatory compliance, impacts to wetlands and other jurisdictional waters would be reduced to a less than significant level.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.3, Biological Resources, and Appendix E, Biological Resources Technical Report.

5.2.2.4 Threshold BIO-d
The Proposed Project could interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites.

Findings of Fact 83 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Finding: Pursuant to CEQA Guidelines Section 15091(a)(1), the City finds that, while the Project could result in potentially significant impacts to wildlife movement, migratory corridors, or nursery sites, implementation of Mitigation Measures MM BIO-1 and MM BIO-3 through MM BIO-6, would reduce these impacts to a less-than-significant level. No significant and unavoidable impacts would occur.

Facts in Support of Findings
Focused General Plan Update and Brea Core Specific Plan As described in the PEIR, portions of the Project area may function as wildlife movement corridors or provide habitat connectivity between larger habitat areas. Development could result in fragmentation, barriers to movement, or disturbance that could affect wildlife movement and use of nursery sites. The Project requires project-specific biological surveys to identify wildlife corridors and habitat linkages prior to development, particularly in northeast portion of the Project area.

Mitigation measures require avoidance and minimization of impacts, as well as project-level evaluation to ensure that connectivity is maintained where present. Compliance with applicable regulations and implementation of best management practices would reduce indirect impacts such as lighting, noise, and human disturbance. With implementation of mitigation, impacts to wildlife movement and habitat connectivity would be reduced to a less than significant level.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.3, Biological Resources, and Appendix E, Biological Resources Technical Report.

5.2.2.5 Threshold BIO-e
The Proposed Project could conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance.

Finding: Pursuant to CEQA Guidelines Section 15091(a)(1), the City finds that, while the Project could result in potentially significant impacts related to local policies or ordinances protecting biological resources, implementation of Mitigation Measures MM BIO-1 through BIO-9 would reduce these impacts to a less-than-significant level. No significant and unavoidable impacts would occur.

Facts in Support of Findings
Focused General Plan Update and Brea Core Specific Plan The PEIR identifies that impacts to biological resources could result in potential conflicts with applicable local policies and ordinances. The Project includes policies and regulatory requirements that support the protection of biological resources, including habitat conservation and maintenance of ecological functions. Mitigation Measures MM BIO-1 through MM BIO-9 require Findings of Fact 84 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan identification of resources, avoidance and minimization, and compliance with applicable regulations and permitting requirements. Implementation of these measures ensures consistency with applicable local policies and ordinances protecting biological resources. With implementation of mitigation and compliance with existing regulatory frameworks, impacts would be reduced to a less than significant level.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.3, Biological Resources, and Appendix E, Biological Resources Technical Report.

5.2.2.6 Cumulative Impact Determination
Threshold BIO-a
Finding: Pursuant to CEQA Guidelines Section 15130, the City finds, in accordance with CEQA Guidelines Section 15091(a)(1), that the Project’s contribution to cumulative impacts would not be cumulatively considerable. Therefore, cumulative impacts related to special status biological resources would be less than significant with implementation of Mitigation Measures MM BIO-1 through MM BIO-7, and no significant and unavoidable impacts would occur.

Facts in Support of Findings
Focused General Plan Update and Brea Core Specific Plan Cumulative projects within the vicinity of the Project area would have the potential to result in impacts to sensitive plant and wildlife species, including loss of habitat. However, with implementation of Mitigation Measures MM BIO-1 through MM BIO-7, impacts would be reduced to a less-than-significant level.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.3, Biological Resources, and Appendix E, Biological Resources Technical Report.

Threshold BIO-b
Finding: Pursuant to CEQA Guidelines Section 15130, the City finds, in accordance with CEQA Guidelines Section 15091(a)(1), that the Project’s contribution to cumulative impacts would not be cumulatively considerable. Therefore, cumulative impacts related to riparian habitat or other sensitive natural community would be less than significant with implementation of Mitigation Measures MM BIO-1, MM BIO-3, MM BIO-4 and MM BIO-5, and no significant and unavoidable impacts would occur.

Findings of Fact 85 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Facts in Support of Findings
Focused General Plan Update and Brea Core Specific Plan Cumulative projects in the vicinity of the Proposed Project area would have the potential to result in impacts associated with riparian habitat and other sensitive natural communities through direct and indirect loss or degradation. However, individual project’s contribution to impacts on riparian habitat and other sensitive natural communities would not be cumulatively considerable with implementation of Mitigation Measures MM BIO-1, MM BIO-3, MM BIO-4 and MM BIO-5.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.3, Biological Resources, and Appendix E, Biological Resources Technical Report.

Threshold BIO-c
Finding: Pursuant to CEQA Guidelines Section 15130, the City finds, in accordance with CEQA Guidelines Section 15091(a)(1), that the Project’s contribution to cumulative impacts would not be cumulatively considerable. Therefore, cumulative impacts related to wetlands would be less than significant with implementation of Mitigation Measures MM BIO-1, MM BIO-8, and MM BIO-9, and no significant and unavoidable impacts would occur.

However, applicable projects in the City and in the SOI, and in surrounding cities and counties, are required to comply with existing regulatory requirements and obtain applicable permits from the U.S. Army Corps of Engineers, RWQCB, and California Department of Fish and Wildlife. Therefore, the Proposed Project would not result in cumulatively considerable impacts with implementation of Mitigation Measures MM BIO-1, MM BIO-8, and MM BIO-9.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.3, Biological Resources, and Appendix E, Biological Resources Technical Report.

Threshold BIO-d
Finding: Pursuant to CEQA Guidelines Section 15130, the City finds, in accordance with CEQA Guidelines Section 15091(a)(1), that the Project’s contribution to cumulative impacts would not be cumulatively considerable. Therefore, cumulative impacts related to wildlife species or migratory wildlife corridors would be less than significant with implementation of Mitigation Measures MM BIO-1, MM BIO-3, MM BIO-4, MM BIO-5 and MM BIO-6, and no significant and unavoidable impacts would occur.

Findings of Fact 86 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Facts in Support of Findings
Focused General Plan Update and Brea Core Specific Plan Cumulative projects located within the vicinity of the Proposed Project area would have the potential to result in a cumulative impact associated with wildlife movement corridors and habitat linkages. However, individual projects facilitated by the Proposed Project would be required to implement project-specific mitigation measures (MM BIO-1, MM BIO-3, MM BIO-4, MM BIO-5 and MM BIO-6) to reduce impacts to wildlife corridors or habitat linkages to below a level of significance. Therefore, the Proposed Project would not contribute to a cumulatively significant impact with mitigation.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.3, Biological Resources, and Appendix E, Biological Resources Technical Report.

Threshold BIO-e
Finding: Pursuant to CEQA Guidelines Section 15130, the City finds, in accordance with CEQA Guidelines Section 15091(a)(1), that the Project’s contribution to cumulative impacts would not be cumulatively considerable. Therefore, cumulative impacts related to conflict with local policies or ordinances protecting biological resources would be less than significant with implementation of Mitigation Measures MM BIO-1 through BIO-9, and no significant and unavoidable impacts would occur.

Facts in Support of Findings
Focused General Plan Update and Brea Core Specific Plan Cumulative projects located in the vicinity of the Proposed Project area would have the potential to result in a cumulative impact associated with conflicts with local policies or ordinances. However, the Proposed Project’s contribution would not be cumulatively considerable with implementation of Mitigation Measures MM BIO-1 through BIO-9.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.3, Biological Resources, and Appendix E, Biological Resources Technical Report.

5.2.2.7 Plans, Programs, and Policies
While no mitigation measures have been identified for the above-listed thresholds, the following existing plans, programs, and policies are identified in the Final PEIR as applicable to the Proposed Project.

PPP BIO-1 Potential direct/indirect impacts to common and sensitive bird and raptor species will require compliance with the CFGC, Section 3503. Construction outside the nesting Findings of Fact 87 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan season (between September 16 and January 14) does not require pre-removal nesting bird surveys. If construction is proposed between January 15 and September 15, a qualified biologist must conduct a nesting bird survey(s) no more than 7 days prior to initiation of grading to document the presence or absence of nesting birds within or directly adjacent (100 feet) to the project site. The survey(s) will focus on identifying any raptors and/or bird nests that are directly or indirectly affected by construction activities. If active nests are documented, species-specific measures shall be prepared by a qualified biologist and implemented to prevent abandonment of the active nest.

At a minimum, grading in the vicinity of a nest shall be postponed until the young birds have fledged. The perimeter of the nest-setback zone shall be fenced or adequately demarcated with stakes and flagging at 20-foot intervals, and construction personnel and activities restricted from the area. A survey report by a qualified biologist verifying that no active nests are present, or that the young have fledged, shall be submitted to the City of Brea for review and approval prior to initiation of grading in the nest-setback zone. The qualified biologist shall serve as a construction monitor during periods when construction activities occur near active nest areas to ensure that no inadvertent impacts on these nests occur. A final monitoring report of the findings, prepared by a qualified biologist, shall be submitted to the City of Brea documenting compliance with the CFGC. Any nest permanently vacated for the season would not warrant protection pursuant to the CFGC.

PPP BIO-2 Development implemented under the Proposed Project will be subject to the BCC Chapter 20.74, Tree Preservation, and preserve and propagate the protected trees as defined therein.

PPP BIO-3 Development implemented under the Proposed Project is required to remove, plant, replace, and maintain street trees in accordance with the BCC Chapter 12.20, Street Trees.

PPP BIO-4 Development implemented under the Proposed Project is required to comply with the California Building Code and all other applicable laws, rules, and regulations governing grading in the City of Brea.

PPP BIO-5 Development implemented under the Proposed Project will implement Design Guidelines and Development Regulations and Standards. All subsequent development within the Project area is required to conform with the provisions discussed in the design and development sections.

Findings of Fact 88 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan

5.2.2.8 Mitigation Measures
Sensitive Plant
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.
• 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 Findings of Fact 89 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan 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 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 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 Findings of Fact 90 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan 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-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 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 options:
a. Compensatory mitigation for temporary impacts to sensitive habitats shall be satisfied through the acquisition of mitigation bank credits via a resource agencyapproved 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
b. 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, 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 Findings of Fact 92 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan 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.

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.

Findings of Fact 93 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan 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.

Sensitive Wildlife Species
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 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 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.

Findings of Fact 94 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan b. Resource Marking/Protection. Prior to site disturbance within the future sitespecific 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 chainlink 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. 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 Findings of Fact 95 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan 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 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 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 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 Findings of Fact 96 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific 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 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 Findings of Fact 97 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan 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 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 May 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 Findings of Fact 98 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan 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 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. i. 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 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 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 Findings of Fact 99 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan 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.

Aquatic Resources
MM BIO-8 Aquatic Resources Delineation. If potentially jurisdictional aquatic resources are identified during pre-project/activity surveys pursuant to Mitigation Measure MM BIO-1, a qualified biologist shall conduct a formal aquatic resources delineation following the methods outlined in the 1987 U.S. Army Corps of Engineers Wetland Delineation Manual and applicable Regional Supplement to the U.S. Army Corps of Engineers Wetland Delineation Manual to map the extent of wetlands and nonwetland waters, determine jurisdiction, and assess potential impacts. The results of the delineation shall be presented in an aquatic resources delineation report. The aquatic resources delineation report shall be used in consultation with the U.S.

Army Corps of Engineers, Regional Water Quality Control Board, and California Department of Fish and Wildlife for necessary authorization or permit, as described in Mitigation Measure MM BIO-9.

MM BIO-9 Potentially Jurisdictional Aquatic Resources Permitting. Temporary and permanent impacts to the wetland and non-wetland waters potentially under the jurisdiction of the U.S. Army Corps of Engineers, Regional Water Quality Control Board, and California Department of Fish and Wildlife, shall be authorized by the U.S. Army Corps of Engineers, Regional Water Quality Control Board, and California Department of Fish and Wildlife, as applicable. Approved temporary and permanent impacts to the potentially Federal and State jurisdictional aquatic resources in the project area require compensatory mitigation through proposed on- or off-site habitat restoration, creation, or enhancement to the satisfaction of the U.S. Army Corps of Engineers, Regional Water Quality Control Board, and California Department of Fish and Wildlife to achieve a no-net loss of Federal and State jurisdictional wetland and non-wetland waters.

5.2.3 CULTRUAL RESOURCES

5.2.3.1 Threshold CUL-b
The Proposed Project could cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5.

Finding: Pursuant to CEQA Guidelines Section 15091(a)(1), the City finds that, while the Project could result in potentially significant impacts to archaeological resources, implementation of Findings of Fact 100 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Mitigation Measures MM CUL-1 through CUL-5 would reduce these impacts to a less-thansignificant level. No significant and unavoidable impacts would occur.

Facts in Support of Findings
Focused General Plan Update
As described in the PEIR, the Project is a program-level planning document that does not directly authorize ground-disturbing activities but would facilitate future development that could involve excavation and grading. Archaeological resources may be present within the Project area, including both recorded and previously unidentified resources, and may occur at or below the surface in both undeveloped and previously disturbed areas. Future development activities could result in disturbance or destruction of archaeological resources, particularly where prior disturbance has been limited or where resources are buried.

Due to the programmatic nature of the Project, the specific location, extent, and significance of archaeological resources cannot be fully determined at this time and must be evaluated at the project level. Mitigation Measures MM CUL-1 through MM CUL-5 require cultural resources assessments, pre-construction surveys, monitoring where appropriate, and procedures for the identification, evaluation, and treatment of archaeological resources, including inadvertent discoveries. These measures ensure compliance with applicable regulatory requirements and provide for avoidance, minimization, or appropriate treatment of archaeological resources. With implementation of mitigation, impacts to archaeological resources would be reduced to a less than significant level.

Brea Core Specific Plan
The analysis above for the Focused GPU applies to the BCSP. The BCSP itself does not propose any specific development projects; however, future development projects could adversely affect known or unknown archaeological resources, and impacts would be less than significant with implementation of Mitigation Measures MM CUL-1 through MM CUL-5.

5.2.3.2 Cumulative Impact Determination
Threshold CUL-b
The Proposed Project could cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5.

Findings of Fact 101 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Finding: Pursuant to CEQA Guidelines Section 15130, the City finds, in accordance with CEQA Guidelines Section 15091(a)(1), that the Project’s contribution to cumulative impacts would not be cumulatively considerable. Therefore, cumulative impacts related to archaeological resources would be less than significant with implementation of Mitigation Measures MM CUL-1 through MM CUL-5, and no significant and unavoidable impacts would occur.

The City hereby makes Finding 1 and determines that this impact is Less Than Significant with implementation of Mitigation Measures MM CUL-1 through MM CUL-5, as described below. No significant and unavoidable impacts would remain.

Facts in Support of Findings
Focused General Plan Update and Brea Core Specific Plan Archaeological resources are typically site-specific; however, cumulative impacts may occur through the incremental loss of resources from multiple development projects over time. The Project does not directly approve site-specific development but would facilitate future discretionary projects that could involve ground disturbance. Future projects would be subject to project-level environmental review and compliance with applicable laws and regulations governing archaeological resources, including California Public Resources Code Section 21083.2 and CEQA Guidelines Section 15064.5. Mitigation Measures MM CUL-1 through MM CUL-5 require identification, evaluation, and treatment of archaeological resources at the project level, including implementation of avoidance and minimization measures where feasible. Impacts would be addressed through required mitigation and regulatory compliance on a project-by-project basis, and the Project’s incremental contribution to cumulative impacts would not be cumulatively considerable. Accordingly, cumulative impacts to archaeological resources would be less than significant with mitigation.

5.2.3.3 Plans, Programs, and Policies
While no mitigation measures have been identified for the above-listed thresholds, the following existing plans, programs, and policies are identified in the Final PEIR as applicable to the Proposed Project.

PPP CUL-3 All construction activities will be conducted in accordance with Section 7050.5 of the California Health and Safety Code regarding the potential discovery of human remains. In the event of discovery or recognition of any human remains in any location other than a dedicated cemetery, there shall be no further excavation or Findings of Fact 102 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan disturbance of the site or any nearby area reasonably suspected to overlie adjacent remains until the County Coroner has been contacted. If applicable, the Native American Heritage Commission will be responsible for designating the most likely descendant (MLD), as required by Section 5097.98 of the California Public Resources Code. If the landowner rejects the recommendations of the MLD, the burial location would be determined in compliance with California Public Resources Code, Section 5097.98.

5.2.3.4 Mitigation Measures
Archaeological Resources
MM CUL-1 Archaeological Resources Assessment. Prior to the commencement of projects not exempt under California Environmental Quality Act (CEQA) involving grounddisturbing activities (including grading, excavation, trenching, boring, or demolition extending below existing grade) in areas that have not been previously developed or includes unpaved areas, the project proponent shall provide an Archaeological Resources Assessment as part of project-level CEQA review prepared by a qualified archaeologist. The assessment shall be prepared under the supervision of an archaeologist meeting the Secretary of the Interior’s professional qualifications standards in prehistoric and/or archaeology.

The assessment shall include:
• A California Historical Resources Information System records search at the South Central Coastal Information Center;
• A review of the Native American Heritage Commission Sacred Lands File; and • Evaluation of previous cultural resources investigations and recorded resources within and adjacent to the project site.

MM CUL-2 Inadvertent Discovery. If archaeological resources are encountered during ground disturbing activities, work in the immediate area shall cease and an archaeologist meeting the Secretary of the Interior’s professional qualifications standards in prehistoric and/or archaeology shall be contacted immediately to evaluate the find(s).

If the discovery proves to be significant as determined by the qualified archeologist, procedures outlined in Mitigation Measure MM CUL-6 shall be implemented.

MM CUL-3 Evaluation and Mitigation of Significant Archaeological Resources. If potentially significant archaeological resources are identified under Mitigation Measure MM CUL-1 or MM CUL-2, and avoidance is not feasible, a Phase II Testing and Evaluation Program shall be conducted to determine resource significance prior to ground disturbance. Phase II investigations shall be conducted by a qualified archaeologist Findings of Fact 103 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan and in coordination with affiliated California Native American Tribes, where applicable.

If archaeological resources are determined to be significant or unique and cannot be avoided, appropriate site-specific mitigation shall be implemented, which may include a Phase III Data Recovery Program. Data recovery shall be conducted in accordance with the Office of Historic Preservation’s guidelines, including Archaeological Resource Management Reports: Recommended Contents and Format and Guidelines for Archaeological Research Designs.

MM CUL-4 Construction Monitoring in High-Sensitivity Areas. If the Archaeological Resources Assessment identifies the project site as highly sensitive for archaeological resources, a qualified archaeologist and a Native American monitor, approved by a California Native American Tribe identified by the Native American Heritage Commission as culturally affiliated, shall monitor all ground-disturbing activities in sensitive areas.

Prior to construction, the archaeologist shall conduct a worker environmental awareness training addressing the identification and protection of archaeological resources. The Native American monitor shall be invited to participate.

If archaeological materials are discovered, work shall cease in the vicinity of the discovery until the resources are evaluated by the qualified archaeologist, in coordination with the Native American monitor and affiliated Tribe(s), as appropriate. The treatment and disposition of materials shall be determined through Tribal consultation and may include curation, repatriation, or reinterment.

MM CUL-5 On-Call Archaeological Monitoring in Moderate-Sensitivity Areas. If the Archaeological Resources Assessment identifies the project site as having moderate sensitivity, a qualified archaeologist shall be retained on an on-call basis. Preconstruction training shall be provided to construction personnel regarding procedures for unanticipated discoveries.

If archaeological resources are encountered, construction shall halt in the immediate area, and the on-call archaeologist shall evaluate the discovery and initiate Tribal consultation, where applicable. Appropriate treatment and disposition of materials shall be determined in consultation with affiliated Tribe(s).

Findings of Fact 104 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan

5.2.4 GEOLOGY AND SOILS

5.2.4.1 Impact Finding: Threshold GEO-f
The Proposed Project could directly or indirectly destroy a unique paleontological resource or site or unique geologic feature.

Finding: Pursuant to CEQA Guidelines Section 15091(a)(1), the City finds that, while the Project could result in potentially significant impacts to paleontological resources, implementation of Mitigation Measures MM GEO-1 would reduce these impacts to a less-than-significant level. No significant and unavoidable impacts would occur.

Facts in Support of Findings
Focused General Plan Update
Ground-disturbing activities—particularly in previously undeveloped areas or in locations where future projects may require deeper excavation than historic development—could disturb or destroy known or previously unrecorded paleontological resources. The presence or absence of paleontological resources cannot be confirmed until site-specific geologic investigations are conducted and the extent of ground disturbance is known. With implementation of Mitigation Measures MM GEO-1, impacts would be reduced to a less-than-significant level.

Brea Core Specific Plan
As discussed in the PEIR, the BCSP area is underlain by geologic units that could yield paleontological resources during grading and excavation activities. However, the BCSP area is largely developed and the potential for discovering or destroying previously unrecovered paleontological resources is low. Furthermore, with implementation of Mitigation Measures MM GEO-1, impacts would be reduced to a less-than-significant level.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.6, Geology and Soils.

5.2.4.2 Cumulative Impact Determination
Threshold GEO-f
The Proposed Project would not directly or indirectly destroy a unique paleontological resource or site or unique geologic feature.

Finding: Pursuant to CEQA Guidelines Section 15130, the City finds, in accordance with CEQA Guidelines Section 15091(a)(1), that the Project’s contribution to cumulative impacts would not be cumulatively considerable. Therefore, cumulative impacts related to paleontological resources Findings of Fact 105 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan would be less than significant with implementation of Mitigation Measure MM GEO-1, and no significant and unavoidable impacts would occur.

Facts in Support of Findings
Focused General Plan Update and Brea Core Specific Plan As discussed in the PEIR, the buildout of the Focused GPU, including the buildout of the BCSP, could result in potentially significant impacts to paleontological resources, and implementation of Mitigation Measure MM GEO-1 would also reduce impacts on paleontological resources to lessthan-significant levels.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.6, Geology and Soils.

5.2.4.3 Mitigation Measures
MM GEO-1 Prior to issuance of a grading permit for any project that would involve grounddisturbing activities greater than current foundations present on a given site underlain by Quaternary (Pleistocene and Holocene) terrestrial deposits or older geologic units, or within areas identified as having high or undetermined paleontological sensitivity, the project proponent shall retain a qualified professional paleontologist meeting the qualifications of the Society of Vertebrate Paleontology to conduct an evaluation to determine the paleontological sensitivity of the geologic units affected by the project and whether ground-disturbing activities would result in a significant impact to paleontological resources according to current Society of Vertebrate Paleontology guidelines. The evaluation shall be submitted to the City of Brea Community Development Department for review and approval.

If evaluation determines that the project has the potential to impact paleontological resources, the City of Brea shall require implementation of paleontological mitigation measures recommended by the qualified professional paleontologist to reduce potential impacts to paleontological resources to a less-than-significant level. These measures may include but not be limited to implementation of a Worker Environmental Awareness Program, on-site paleontological monitoring, and fossil salvage and treatment plans, if applicable. If paleontological resources are discovered during excavation and/or construction activities, construction shall stop within 25 feet of the find, and the qualified professional paleontologist shall be consulted to determine whether the resource requires further study. The paleontologist shall make recommendations to the City of Brea to protect the discovered resources. Any paleontological resources recovered shall be provided Findings of Fact 106 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan for curation at a local curation facility such as the Dr. John D. Cooper Archaeological and Paleontological Center or other appropriate repository. The City of Brea Community Development Department shall review and approve the qualified professional paleontologist’s findings and recommendation.

5.2.5 Greenhouse Gas Emissions

5.2.5.1 Threshold GHG-a
The Proposed Project could generate greenhouse gas (GHG) emissions, either directly or indirectly, that may have a significant impact on the environment.

Finding: Pursuant to CEQA Guidelines Section 15091(a)(3), the City finds that the Project could generate GHG emissions that may have a significant impact on the environment. Although Mitigation Measure MM GHG-1 would reduce the Project’s air quality impacts, it would not reduce this impact to a less-than-significant level. Therefore, the impact would remain significant and unavoidable.

Approval of the Project requires adoption of a Statement of Overriding Considerations pursuant to CEQA Guidelines Section 15093.

Facts in Support of Findings
Focused General Plan Update
As described in the PEIR, the Project is a program-level land use plan that would facilitate future development, resulting in both construction and operational GHG emissions. Construction activities would generate GHG emissions from equipment use, material transport, and site preparation; however, operational emissions would represent the primary long-term source of GHG emissions.

Operational emissions associated with buildout of the Project would exceed applicable thresholds established by the South Coast Air Quality Management District, including both the bright-line threshold and efficiency metrics, primarily due to increases in mobile and energy-related emissions associated with planned growth. Mobile emissions represent the largest source of GHG emissions and are largely influenced by factors outside the City’s control, including regional travel behavior and statewide regulatory programs.

The Project would not result in a substantial increase in per capita vehicle miles traveled; however, total emissions would increase due to population and employment growth. Statewide measures and regulations (e.g., renewable energy standards, vehicle emission standards, and energy efficiency requirements) would reduce GHG emissions over time; however, the extent of reductions attributable to these programs cannot be assured at the project level.

Findings of Fact 107 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Mitigation Measure MM GHG-1 would require incorporation of feasible GHG reduction strategies at the project level; however, because the specific design and intensity of future development are not known, emissions reductions cannot be fully quantified, and mitigation would not ensure consistency with applicable thresholds. No additional feasible mitigation measures are available to further reduce GHG emissions to a less than significant level. Accordingly, the Project’s GHG emissions impact would remain significant and unavoidable.

Brea Core Specific Plan
As described in the PEIR, the BCSP is a plan-level document that would facilitate future development, resulting in both construction and operational GHG emissions. Construction activities associated with buildout of the BCSP would generate GHG emissions from equipment use, material transport, and site preparation. Operational emissions associated with BCSP buildout would include mobile sources, energy consumption (electricity and natural gas), water and wastewater conveyance, and solid waste generation.

As demonstrated in the PEIR, buildout of the BCSP would result in a net increase in GHG emissions compared to existing conditions that exceeds applicable thresholds established by the South Coast Air Quality Management District, including both bright-line and efficiency-based thresholds. Mobile emissions would represent the largest source of GHG emissions and are largely outside the City’s regulatory control. While future development projects under the BCSP would be subject to projectlevel CEQA review and may incorporate design features to reduce emissions, the Project-level reductions cannot be assured at the program level. Although the BCSP would not result in a substantial increase in per capita vehicle miles traveled, total GHG emissions would increase due to planned growth.

The BCSP contributes to overall emissions associated with the broader Project area, and when considered in combination with development under the Focused GPU, emissions would exceed applicable thresholds. Mitigation Measure MM GHG-1 would reduce emissions; however, because the details of future development are not known, the extent of reductions cannot be fully quantified, and impacts would not be reduced to a less than significant level. No additional feasible mitigation measures are available to further reduce GHG emissions. Accordingly, GHG impacts associated with the BCSP would be significant and unavoidable.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.7, Air Quality, and Appendix D1, Air Quality/GHG Data.

Findings of Fact 108 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan

5.2.5.2 Cumulative Impact Determination
Threshold GHG-a:

The Proposed Project could generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment.

Finding: Pursuant to CEQA Guidelines Section 15130, the City finds, in accordance with CEQA Guidelines Section 15091(a)(3), that the Project’s contribution to cumulative GHG emissions impacts is cumulatively considerable. Although Mitigation Measure MM GHG-1 would reduce the Project’s contribution, it would not reduce the impact to a less-than-significant level. Therefore, the Project would result in a significant and unavoidable cumulative GHG emissions impact.

Approval of the Project requires adoption of a Statement of Overriding Considerations pursuant to CEQA Guidelines Section 15093.

Facts in Support of Findings:

Focused General Plan Update and Brea Core Specific Plan GHG emissions contribute to global climate change, and their impacts are inherently cumulative in nature. The Project would facilitate long-term development that would result in a net increase in GHG emissions compared to existing conditions.

As demonstrated in the PEIR, Project-related emissions would exceed applicable thresholds, indicating a significant contribution to cumulative GHG emissions. Although Mitigation Measure MM GHG-1 would reduce emissions, the extent of reduction cannot be fully quantified at the program level, and emissions would not be reduced below applicable thresholds. Because the Project would result in emissions above established thresholds and contribute to a global cumulative impact, its incremental contribution is considered cumulatively considerable.

Accordingly, cumulative GHG impacts would be significant and unavoidable.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.7, Air Quality, and Appendix D1, Air Quality/GHG Data.

5.2.5.3 Plans, Programs, and Policies
Refer to PPP GHG-1 through PPP GHG-5 in Section 5.1.6.2.

5.2.5.4 Mitigation Measures
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) Findings of Fact 109 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan 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
− 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
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.

Findings of Fact 110 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan − 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
• 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
Findings of Fact 111 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan − Expand urban tree planting
− Create new vegetated spaces
− Install permeable surfaces

5.2.6 Noise

5.2.6.1 Threshold NOI-a
The Proposed Project could result in generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies.

Finding: Pursuant to CEQA Guidelines Section 15091(a)(1) and 15091(a)(3), the City finds that, while the Project could result in potentially significant impacts to temporary ambient noise levels during construction, implementation of Mitigation Measure MM NOI-1 would reduce these impacts to a less-than-significant level; and the City further finds that permanent increase in ambient noise levels during operation could increase ambient noise levels associated with roadway traffic under the Focused GPU, which cannot be reduced to a less-than-significant level despite implementation of Mitigation Measure MM NOI-2 and compliance with applicable plans and regulations. Therefore, operational noise impacts would remain significant and unavoidable.

Approval of the Project requires adoption of a Statement of Overriding Considerations pursuant to CEQA Guidelines Section 15093.

Facts in Support of Findings:

Focused General Plan Update
Construction
The Focused GPU could generate substantial temporary increase in ambient noise. However, compliance with the City of Brea Noise Control Ordinance and implementation of Mitigation Measure MM NOI-1, which requires standard construction noise controls (e.g., equipment mufflers, staging, and shielding where feasible), would reduce temporary construction noise impacts to a less-than-significant level.

Operation
Operation noise from the Focused GPU would be subject to regulatory controls such as the Brea Noise Control Ordinance, State regulations, and standard building and design requirements.

Because these sources must comply with applicable noise standards, and because noisegenerating activities would not typically occur simultaneously at levels that would combine to exceed applicable limits, operational noise from stationary and area sources would be less than Findings of Fact 112 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan significant. However, implementation of the Focused GPU would result in potentially significant direct impacts related to permanent increases in vehicle noise, even with implementation of Mitigation Measure MM NOI-2 and existing regulatory requirements. Vehicle noise reduction measures would not necessarily be feasible in all circumstances throughout the City, and impacts would remain significant and unavoidable.

Brea Core Specific Plan
Construction
The BCSP could generate substantial temporary increase in ambient noise. However, compliance with the City of Brea Noise Control Ordinance and implementation of Mitigation Measure MM NOI1 would reduce temporary construction noise impacts to a less than significant level.

Operation
Operation noise from the BCSP would be subject to local and State regulatory controls and impacts would be less than significant. Also, as demonstrated in the PEIR, permanent vehicle noise from implementation of the BCSP would not have the potential to result in a direct permanent increase in noise levels above the threshold on any study area segments. Therefore, operational noise impacts from BCSP would be less than significant without mitigation.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.11, Noise, and Appendix G, Noise Data.

5.2.6.2 Threshold NOI-b
The Proposed Project could result in the generation of excessive groundborne vibration or groundborne noise levels.

Finding: Pursuant to CEQA Guidelines Section 15091(a)(1), the City finds that the Project could result in potentially significant groundborne vibration and noise impacts during construction.

However, implementation of Mitigation Measure MM NOI-3 would reduce these impacts to a lessthan-significant level.

The City further finds that operational groundborne vibration and noise impacts would be less than significant without mitigation due to compliance with applicable regulations. No significant and unavoidable impacts would occur.

Facts in Support of Findings
Focused General Plan Update and Brea Core Specific Plan Construction
Findings of Fact 113 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Construction activities associated with future development could generate groundborne vibration from heavy equipment such as graders, loaders, and vibratory rollers. Groundborne vibration attenuates with distance and is influenced by site-specific factors such as soil conditions and building characteristics.

As shown in Table 4.11-10, Vibration Source Levels for Typical Construction Equipment, of the PEIR, a potential impact would occur if future typical construction activities would occur within 100 feet of an adjacent occupied land use or 165 feet if a vibratory roller would be required. Because future project locations, construction methods, and distances to sensitive receptors are not known at the program level, it cannot be ensured that vibration levels would remain below thresholds.

Therefore, construction-related groundborne vibration impacts are potentially significant. However, Mitigation Measure MM NOI-3 requires site-specific evaluation and implementation of vibration control measures (e.g., setbacks, alternative equipment, and monitoring), and with implementation of MM NOI-3, construction vibration impacts would be reduced to a less-than-significant level.

Operation
Operation of future land uses, including industrial uses, could generate groundborne vibration from mechanical equipment or operational activities. However, such uses are subject to Brea City Code Section 20.20.040, which limits vibration to 0.003 in/sec at the property line, consistent with the City’s significance threshold. This regulatory standard is well below levels associated with structural damage (e.g., 0.12 in/sec per Federal Transit Administration guidance). Compliance with the existing regulatory requirement, operational groundborne vibration and noise impacts would be less than significant without mitigation.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.11, Noise, and Appendix G, Noise Data.

5.2.6.3 Cumulative Impact Determination
Threshold NOI-a
The Proposed Project could result in generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies.

Finding: Pursuant to CEQA Guidelines Section 15130, the City finds, in accordance with CEQA Guidelines Section 15091(a)(3), that the Project’s contribution to cumulative noise impacts is cumulatively considerable. Although Mitigation Measure MM NOI-1 and MM NOI-2 would reduce the Project’s contribution, it would not reduce the impact to a less-than-significant level. Therefore, the Project would result in a significant and unavoidable cumulative noise impact.

Findings of Fact 114 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Approval of the Project requires adoption of a Statement of Overriding Considerations pursuant to CEQA Guidelines Section 15093.

Facts in Support of Findings:

Focused General Plan Update and Brea Core Specific Plan Cumulative noise impacts are primarily driven by regional increases in traffic volumes. The Focused GPU and BCSP, in combination with other reasonably foreseeable development, would increase roadway traffic and associated noise levels.

The PEIR demonstrated that cumulative traffic noise increases would exceed applicable thresholds on certain roadway segments, including segments of Lambert Road and Rose Drive (Table 4.11-8, Existing Plus Future Focused GPU Buildout (2050) Traffic Noise Levels). While the Focused GPU alone would not exceed thresholds in all cases, the incremental contribution of the BCSP results in exceedances, indicating a cumulatively considerable contribution. Although MM NOI-2 would require feasible noise attenuation, physical and practical constraints limit the effectiveness of such measures. Therefore, the Project’s contribution to cumulative traffic noise would remain cumulatively considerable and significant.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.11, Noise, and Appendix G, Noise Data.

Threshold NOI-b
The Proposed Project would not result in generation of excessive groundborne vibration or groundborne noise levels during construction with implementation of mitigation.

Finding: Pursuant to CEQA Guidelines Section 15091(a)(1), the City finds that, while the Project could result in potentially significant groundborne vibration and noise impacts during construction, implementation of Mitigation Measures MM NOI-3 would reduce these impacts to a less-thansignificant level. The City further finds that groundborne vibration or groundborne noise level increase during operation would be less than significant without mitigation. No significant and unavoidable impacts would occur.

Facts in Support of Findings
Focused General Plan Update and Brea Core Specific Plan Cumulative groundborne vibration impacts would occur if multiple projects collectively generated vibration levels that exceed applicable thresholds at sensitive receptors. However, constructionrelated vibration is highly localized and temporary and would be required to implement vibration management practices such as Mitigation Measure MM NOI-3; which would further reduce groundborne vibration to adjacent uses. Therefore, the Proposed Project’s incremental Findings of Fact 115 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan contribution to cumulative vibration impacts would not be cumulatively considerable, and cumulative impacts would be less than significant.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.8, Noise, and Appendices C (Air Quality/GHG) and H (Noise).

5.2.6.4 Plans, Programs, and Policies
PPP NOI-1 Residential development must comply with the California Building Code , Title 24, Part 2, Volume 1, Chapter 12, Interior Environment, Section 1207.11.2, Allowable Interior Noise Levels, and Section 1206.5 Acoustical Control. Residential and nonresidential development must comply with the City’s land use compatibility limits as shown in Table 4.11-2, Noise/Land Use Compatibility. Before the issuance of a grading or construction permit for individual development projects that are not exempt from CEQA, and in conjunction with any required California Environmental Quality Act (CEQA) review, where development is proposed in an area where exterior noise would exceed the land use compatibility limits, the project applicants shall submit an Acoustical Study prepared by a certified acoustical engineer.

Exterior noise may also be used to screen for potential interior noise impacts. The following screening levels may be applied to determine whether exterior noise would require preparation of an Acoustical Study:
• If existing roadways segments serving the project have an average daily traffic above 1,160, an Acoustical Study is required for new noise sensitive receptors. • If existing roadways segments serving the project have an average daily traffic of 1,800 or higher, an Acoustical Study is required for commercial uses.

The project applicant shall include design measures that may include acoustical paneling or walls, compliance with CBC Section 1206 and/or CALGreen Section

5.507.4 as applicable to ensure that interior noise levels do not exceed 45 dBA CNEL for residential uses. If it is necessary for windows to be able to remain closed to ensure that interior noise levels meet the interior standard, the design for these land uses shall include ventilation with an air conditioning system to provide a habitable interior environment with the windows closed. Final construction documents shall incorporate special design measures in the construction of the land uses.

PPP NOI-2 Nonresidential development must comply with the California Building Code, Title 24, and California Green Building Standards Administrative Code, Part 11, CALGreen Chapter 5, Nonresidential Mandatory Measures, Section 5.507 Environmental Comfort.

Findings of Fact 116 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan PPP NOI-3 Development projects will be constructed in accordance with Brea City Code (BCC) Section 8.20, Noise Control, of the BCC, which generally prohibits construction, repair, remodeling, or grading of any real property between the hours of 7:00 pm and 7:00 am on weekdays, including Saturday, or at any time on Sunday or a Federal holiday.

PPP NOI-4 Project stationary sources will comply with the City of Brea’s exterior noise standards in Brea City Code, Section 8.20.050 (refer to Table 4.11-3, City of Brea Exterior Noise Standards, of this Program Environmental Impact Report [PEIR]).

PPP NOI-5 Project vibration levels will comply with the City of Brea’s vibration standard of

0.003 in/sec root-mean-square (equivalent to 70 VdB) in Brea City Code Section

20.20.040.

Their signatures shall confirm receipt and understanding of this information. • The location and design of recycling and refuse storage facilities shall mitigate nuisances when residential uses might be impacted.
• Residential dwelling units shall be designed to be sound attenuated against present and future project noise. New projects or new nonresidential uses in existing projects shall provide an acoustical analysis report, by an acoustical engineer, describing the acoustical design features of the structure required to satisfy the exterior and interior noise standards.

The new or updated general plan goals and policies related to noise are included as Appendix C, Brea 2050 General Plan: Goals, Policies, and Actions, to this PEIR.

5.2.6.5 Mitigation Measures
MM NOI-1 Construction Noise Best Practices. Prior to any construction activity, such as grading, site preparation, or issuance of building permits, a note shall be provided on the construction plans indicating that during construction activities, the project applicant shall be responsible for requiring contractors to implement the following measures to limit construction-related noise to a performance standard of 80 A- Findings of Fact 117 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan weighted decibel equivalent continuous sound level at the property line of the nearest sensitive receptor:
• Brea City Code, Section 8.20.070, limits construction activity to the daytime hours between 7:00 a.m. and 7:00 p.m. on Monday through Saturday. Construction is not allowed on Sundays and Federal holidays.
• During the entire active construction period, equipment and trucks used for the project construction shall use the best available noise control techniques (e.g., improved mufflers, use of intake silencers, ducts, engine enclosures, and acoustically attenuating shields or shrouds), wherever feasible. • Require that impact tools (e.g., jack hammers and hoe rams) be hydraulically or electrically powered wherever possible. Where the use of pneumatic tools is unavoidable, an exhaust muffler on the compressed air exhaust shall be used along with external noise jackets on the tools.
• Stationary equipment such as generators and air compressors shall be located as far as feasible from nearby noise-sensitive uses.
• Stockpiling shall be located as far as feasible from nearby noise-sensitive receptors.
• Construction traffic shall be limited—to the extent feasible—to approved haul routes established by the City of Brea.
• Signs shall be posted at the job site entrance(s), within the on-site construction zones, and along queueing lanes (if any) to reinforce the prohibition of unnecessary engine idling. All other equipment shall be turned off if not in use for more than 5 minutes.
• During the entire active construction period and to the extent feasible, the use of noise-producing signals, including horns, whistles, alarms, and bells, shall be for safety warning purposes only. The construction manager shall use smart backup alarms, which automatically adjust the alarm level based on the background noise level, or switch off back-up alarms and replace with human spotters in compliance with all safety requirements and laws.
• Erect temporary noise barriers, where feasible, when construction noise is predicted to exceed the noise standards after other measures have been considered, or occur at nighttime, or when the anticipated construction duration is greater than is typical (e.g., 2 years or more).

Findings of Fact 118 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan • Greater than 1.5 A-weighted decibel increase for ambient noise environments of 65 A-weighted decibel Community Noise Equivalent Level and higher. • Greater than 3.0 A-weighted decibel increase for ambient noise environments of 60 to 64 A-weighted decibel Community Noise Equivalent Level. • Greater than 5.0 A-weighted decibel increase for ambient noise environments of less than 60 A-weighted decibel Community Noise Equivalent Level.

A project that would potentially exceed the above thresholds shall complete a sitespecific Noise Technical Study to determine if the project would result in a significant increase in traffic noise. This Noise Technical Study shall be prepared by a qualified acoustical analyst. The following screening levels may be applied to determine whether a Noise Technical Study is required:2 • If existing roadway segments serving the project have an average daily traffic below 1,800, a Noise Technical Study is required if the project would potentially double segment average daily traffic.
• If existing roadway segments serving the project have an average daily traffic of 1,800 or higher, a Noise Technical Study is required if the project would generate more than 750 average daily traffic.

If a significant increase in vehicle noise level is identified as a result of individual project implementation, the project shall incorporate buffers or other noise reduction measures to the extent feasible to reduce noise levels at affected sensitive receptors to a normally acceptable noise level. Reduction measures that shall be considered include but are not limited to alternative road design, reduced speeds, alternative paving, building retrofits to provide additional noise attenuation, and setbacks or buffers before berms and walls. The noise reduction measures shall be designed by a qualified acoustical engineer. Where noise reduction measures in the public right-of-way are infeasible, the project applicant shall conduct outreach to potentially affected sensitive receptors to determine the feasibility of noise reduction measures on private property, including a noise barrier or building retrofits. Based on affected receptor response, a qualified acoustical engineer shall determine the feasibility of a noise barrier on private property and/or the extent of required building retrofits. The project applicant shall submit plans to the City of Brea Community Development Department for review and approval before the start of any construction. These plans shall demonstrate that the 2 Based on the study area segments, a roadway with 1,800 average daily traffic or higher has the potential to exceed 65 Aweighted decibels and be subject to the 1.5 A-weighted decibel increase thresholds. A more than 750 average daily traffic increase has the potential to result in a 1.5 A-weighted decibel Community Noise Equivalent Level increase. Roadway segment with below 1,800 average daily traffic would generally not generate noise levels above 65 A-weighted decibel Community Noise Equivalent Level and would be subject to the 3 A-weighted decibel Community Noise Equivalent Level or 5 A-weighted decibel Community Noise Equivalent Level thresholds. A doubling of roadway volume typically results in a 3 A-weighted decibel Community Noise Equivalent Level increase in noise level (Caltrans 2013a).

Findings of Fact 119 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan proposed noise reduction measures would reduce traffic noise exposure at sensitive receptors to the extent feasible.

5.2.7 Tribal Cultural Resources

5.2.7.1 Threshold TCR-a
The Proposed Project could cause a substantial adverse change in the significance of a Tribal Cultural Resource, defined in Public Resources Code, Section 21074, as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American Tribe, and that is: (1) listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code, Section 5020.1(k); or (2) a resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code, Section 5024.1.

In applying the criteria set forth in subdivision (c) of Public Resources Code, Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American Tribe.

Finding: Pursuant to CEQA Guidelines Section 15091(a)(1), the City finds that, while the Project could result in potentially significant impacts to tribal cultural resources, implementation of Mitigation Measures MM TCR-1 and MM TCR-2 would reduce these impacts to a less-thansignificant level. No significant and unavoidable impacts would occur.

Findings of Fact 120 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Facts in Support of Findings:

Focused General Plan Update and Brea Core Specific Plan Site-specific evaluation based on an individual development proposal would be necessary to fully evaluate impacts to TCRs. Future discretionary projects implemented under the Focused GPU would be required to comply with applicable CEQA requirements, including compliance with SB 18 and AB 52 consultation, and provide appropriate mitigation, as applicable. Implementation of Mitigation Measures MM TCR-1, MM TCR-2, and PPP CUL-3 would reduce potential adverse impacts to TCRs to a less-than-significant level by requiring monitoring by a qualified Tribal monitor during applicable ground-disturbing activities and establishing minimum measures to follow in the event of discovery of TCRs, including treatment measures. Therefore, impacts would be reduced to less than significant, and no significant and unavoidable impacts would remain.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Section 4.14, Tribal Cultural Resources, and Appendix F1, Cultural Resources Data, and Appendix F2, Confidential Cultural Resources Data.

5.2.7.2 Plans, Programs, and Policies
See PPP CUL-3.

5.2.7.3 Mitigation Measures
MM TCR-1 Provision of Tribal Monitor. Prior to commencement of any ground-disturbing activities for qualifying development projects in which the potential exists for Tribal Cultural Resources to be present based on record searches or tribal knowledge, the project applicant shall coordinate with all interested State-recognized Tribes in concurrence with the City of Brea as the California Environmental Quality Act (CEQA) lead agency. A copy of the executed contract shall be submitted to the City of Brea Community Development Department prior to the issuance of any permit necessary to commence a ground-disturbing activity.
• The Tribal monitor will only be present on-site during the construction phases that involve ground-disturbing activities. Ground-disturbing activities are defined by the Consulting Tribe as activities that may include, but are not limited to, pavement removal, potholing or augering, grubbing, tree removals, boring, grading, excavation, drilling, and trenching. The Tribal monitor shall complete daily monitoring logs describing construction activities, locations, soil conditions, and any cultural materials identified. The monitoring shall end when all ground-disturbing activities are completed, or when the qualified archaeologist and/or Tribal monitor determines that all remaining ground-disturbing activities have little to no potential for impacting Tribal Cultural Resources.

Findings of Fact 121 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan • Upon discovery of any Tribal Cultural Resources, construction activities shall cease in the immediate vicinity of the find (not less than the surrounding 100 feet) until the find can be assessed. All Tribal Cultural Resources unearthed by project activities shall be evaluated by the qualified archaeologist and Tribal monitor. If the resources are Native American in origin, the Consulting Tribe will retain Tribal Cultural Resources in the form and/or manner the Consulting Tribe deems appropriate, for educational, cultural and/or historic purposes. • If human remains and/or grave goods are discovered or recognized at the projects site, all ground disturbance shall immediately cease within 100 feet of discovery, and the county coroner shall be notified per Public Resources Code (PRC), Section 5097.98, and Health and Safety Code Section 7050.5. Human remains and grave/burial goods shall be treated alike per PRC Section 5097.98(d)(1) and (2).
• Work may continue on other parts of the project site while evaluation and, if necessary, mitigation takes place (CEQA Guidelines, Section 15064.5(f)). • If a non-Native American resource is determined by the qualified archaeologist to constitute as a “historical resource” or “unique archaeological resource,” time allotment and funding sufficient to allow for implementation of avoidance measures, or appropriate mitigation, must be available. The treatment plan established for the resources shall be in accordance with CEQA Guidelines, Section 15064.5(f) for historical resources and PRC Section 21074(b) for unique archaeological resources.

MM TCR-2 Discovery of Cultural Resources (Not Native American in Origin): Prior to commencement of any ground-disturbing activity at the project site, the project applicant shall retain an archaeologist meeting the Secretary of the Interior’s Professional Qualifications Standards for Archaeology (National Park Service [NPS] 1983). If cultural resources that are not Native American in origin are encountered during ground-disturbing activities, construction activities shall cease in the immediate vicinity of the find (not less than the surrounding 100 feet) until the find can be assessed. If the discovery proves to be significant as determined by the site archaeologist, additional work such as data recovery excavation may be warranted and shall be reported to the City of Brea Community Development Department.

5.2.8 Utilities and Service Systems

5.2.8.1 Threshold UTL-a
The Proposed Project could require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or Findings of Fact 122 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan telecommunications facilities, the construction or relocation of which could cause significant environmental effects.

Finding: Pursuant to CEQA Guidelines Section 15091(a)(1), the City finds that, while the Project could result in potentially significant impacts to water and sewer systems, implementation of Mitigation Measure MM UTL-1 would reduce these impacts to a less-than-significant level. No significant and unavoidable impacts would occur.

Facts in Support of Findings:

Focused General Plan Update
Impacts from the Focused GPU were addressed at a programmatic level. The City’s 2021 Water Master Plan, 2021 Sewer Master Plan, and 2013 Mast Plan of Drainage were prepared to address growth anticipated under the 2003 General Plan. These master plans identify existing and projected system deficiencies and recommend improvements needed to maintain adequate levels of service. The Focused GPU includes goals and actions that reinforce the City’s commitment to providing adequate water, wastewater, and storm drain capacity as growth occurs.

All individual development projects would undergo the City’s development review process and would be required to fund or construct necessary infrastructure improvements consistent with the City’s Capital Improvement Program (CIP), which includes upgrades to water, sewer, storm drain, and other public facilities.

For water system, until project-level fire flow testing and hydraulic modeling are completed, impacts on water supply and distribution facilities are considered potentially significant. However, with implementation of Mitigation Measure MM UTL-1 that requires project-specific evaluation and appropriate water facilities improvements, impacts would be reduced to a less-than-significant level.

For sewer system, future development in accordance with Focused GPU could result in deficient sewer facilities. However, with implementation of Mitigation Measure MM UTL-1 that requires project-specific evaluation and appropriate sewer facilities improvement, impacts would be reduced to a less-than-significant level.

For drainage system, future development compliance with existing stormwater management regulations (e.g., NPDES Construction General Permit and implementation of BMPs and low-impact development measures, as required under a Water Quality Management Plan), along with continued master planning for the Citywide drainage system, would ensure that buildout of the Proposed Project area does not substantially increase the rate or amount of surface runoff such that it would exceed the capacity of the drainage system. Therefore, impacts would be less than significant.

Findings of Fact 123 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan For electric, natural gas, and telecommunication, SCE, SoCalGas, and various franchised telecommunications providers are established utility providers with the capacity and operational mechanisms to serve anticipated growth within the Proposed Project area. Impacts would be less than significant.

Brea Core Specific Plan
For water systems, Table 4.15-2, Water Supply Analysis, of the PEIR, summarizes the existing MDD and incremental MDD increase associated with BCSP land uses. As shown, there is sufficient supply available to meet the projected higher demand. Additionally, Table 4.15-3, Water Storage Analysis (Zone 750), of the PEIR, shows that the system has sufficient storage capacity to accommodate the BCSP land uses. However, Mitigation Measure MM UTL-1 is required to assess the contribution of individual development projects within the BCSP area. With implementation of MM UTL-1, impacts would be less than significant.

5.2.8.2 Plans, Programs, and Policies
Refer to PPP UTL-1, PPP UTL-2, and PPP HYD-1.

5.2.8.3 Mitigation Measures
MM UTL-1 Water and Sewer Infrastructure Improvements. Prior to approval of any discretionary development permit or issuance of building permits, the project for individual projects shall demonstrate compliance with the City of Brea’s Water Master Plan, and Sewer Master Plan, as well as all applicable improvement and design requirements of the City of Brea Public Works Department and the City’s Capital Improvement Program (CIP).

As part of the development application review process, the applicant shall retain a qualified licensed civil engineer to evaluate existing water and sewer system conditions serving the project site. If the evaluation identifies any capacity deficiencies or facility constraints, the applicant shall prepare and submit the appropriate system testing and modeling (e.g., water flow testing, water hydraulic modeling, sewer capacity modeling and capacity analysis) to the Public Works Department for review and approval. The modeling shall identify the specific infrastructure upgrades, improvements, and associated costs required to ensure adequate service capacity and compliance with City design standards.

The applicant shall construct, or fund the construction of, all improvements identified through the approved modeling and required by the Public Works Department prior to occupancy or in accordance with a timing and phasing plan approved by the City. No development shall be permitted to proceed unless all Findings of Fact 124 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan required improvements or fair-share contributions are secured through conditions of approval, improvement plans, or a development agreement.

5.3 Findings Regarding Alternatives (Public Resources Code Section 21081 and CEQA Guidelines Section 15091[a][1])
In accordance with Section 15126.6(a) of the CEQA Guidelines, an EIR must contain a discussion of “a range of reasonable alternatives to a project, or the location of a project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of the alternatives.” Section 15126.6(f) further states that "the range of alternatives in an EIR is governed by the 'rule of reason' that requires the EIR to set forth only those alternatives necessary to permit a reasoned choice." Thus, the following discussion focuses on project alternatives that are capable of eliminating significant environmental impacts or substantially reducing them compared to the Project, even if the alternative would impede the attainment of some Project objectives, or would be more costly. In accordance with Section 15126.6(f)(1), the factors that may be taken into account when addressing the feasibility of alternatives include: (1) site suitability; (2) economic viability; (3) availability of infrastructure; (4) general plan consistency; (5) other plans or regulatory limitations; (6) jurisdictional boundaries; and (7) whether the proponent can reasonably acquire, control or otherwise have access to the alternative site. “Feasible” is defined in Section 15364 of the CEQA Guidelines to mean “capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, legal, social, and technological factors.” The California Public Resources Code (Section 21081 and CEQA Guidelines Section 15019[a][3]) also provides that “other” considerations may form the basis for a finding of infeasibility. Case law makes clear that a mitigation measure or alternative can be deemed infeasible on the basis of its failure to meet project objectives or on related public policy grounds.

Pursuant to CEQA Guidelines, Section 15126.6(b), alternatives to the project include those that avoid or substantially lessen any significant effects of the project, even if these alternatives would impede to some degree the attainment of the project objectives or would be more costly.

If there are no feasible project alternatives, the lead agency must adopt a Statement of Overriding Considerations with regard to the project pursuant to CEQA Guidelines, Section 15093. If there is a feasible alternative to the project, the lead agency must decide whether it is environmentally superior to the proposed project. The lead agency must consider in detail only those alternatives that could feasibly attain most of the basic objectives of the project; however, the lead agency must consider alternatives capable of eliminating significant environmental impacts even if these alternatives would impede to some degree the attainment of project objectives (CEQA Guidelines, Section 15126.6[f]).

Findings of Fact 125 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan These Findings contrast and compare the alternatives where appropriate to demonstrate that the selection of the preferred alternative as the project has substantial environmental, planning, fiscal, and other benefits. In rejecting certain alternatives, the City has examined the project objectives and weighed the ability of the various alternatives to meet the objectives. The objectives considered by the City are set forth in Section 2.1, Project Objectives, in this Findings and in PEIR Section 2.2, Project Objectives.

The PEIR examined a range of reasonable alternatives to determine whether they could meet the project objectives while avoiding or substantially lessening one or more of the proposed project’s significant impacts. These Findings also considered the feasibility of each alternative. In determining the feasibility of alternatives, the City considered whether the alternatives could be accomplished in a successful manner within a reasonable period of time in light of economic, environmental, social, and technological factors (CEQA Guidelines, Sections 15126(d)(5)(A), 15364).

The PEIR analyzed three alternatives to the proposed project: (1) No Project/Existing 2003 Brea General Plan Alternative; (2) Proposed General Plan but No Brea Core Specific Plan Alternative; and (3) Reduced Intensity Alternative. Detailed information and analysis concerning these alternatives is in PEIR Chapter 7, Alternatives to the Proposed Project.

This section of the Findings summarizes these alternatives and their feasibility and effectiveness in avoiding or substantially lessening any of the significant impacts associated with the Proposed Project.

5.3.1.1 Alternative 1: No Project/Existing 2003 Brea General Plan Alternative
The discussion of the No Project/Existing 2003 Brea General Plan Alternative must examine the existing conditions and reasonably foreseeable future conditions that would exist if the Proposed Project were not approved (CEQA Guidelines, Section 15126.6[e]). The Alternative 1: No Project Alternative/Existing 2003 Brea General Plan is defined as a continuation of existing conditions and conditions that are reasonably expected to occur in the event that the Proposed Project is not implemented. Under Alternative 1, the Proposed Project would not be adopted, and the land use intensity increases and comprehensive updates to the existing 2003 Brea General Plan and the BCSP would not occur. Instead, Alternative 1 assumes the buildout of the existing 2003 Brea General Plan in accordance with existing land use designations. Therefore, no BCSP adoption would occur. As shown in Table 5-1, Alternative 1: No Project/Existing General Plan Compared to the Proposed Project, of the PEIR, this alternative would result in 20,335 housing units (net increase of 3,990 housing units), and 57,954 population (net increase of 11,369 population), 28,476,908 square feet of non-residential area (net increase of 6,996,494 square feet) and 68,624 jobs (net increase of 16,687 jobs) compared to existing conditions; and result in 3,401 fewer housing units (14.33 percent), 9,693 fewer residents (14.33 percent), and 5,085 fewer jobs (6.9 percent) when compared to the Proposed Project.

Findings of Fact 126 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Ability to Reduce Impacts
As discussed in Section 7.4.1, of the PEIR, Alternative 1 would not eliminate the significant and unavoidable impacts that would occur with the Proposed Project. Environmental issue areas related to Land Use and Planning and Transportation would be greater with Alternative 1 when compared to the Proposed Project. Alternative 1 would result in reduced impacts for the following environmental topic areas when compared to the Proposed Project: Aesthetics, Air Quality, Cultural Resources, Energy, Geology and Soils (Paleo Only), Greenhouse Gas Emissions, Hazards and Hazardous Materials, Hydrology and Water Quality, Noise, Public Services, Tribal Cultural Resources, and Utilities and Service Systems. Alternative 1 would result in similar impacts to the Proposed Project in the following environmental topic areas: Biological Resources and Wildfire.

Ability to Achieve Project Objectives
As discussed in Section 7.4.1, of the PEIR, Alternative 1 would partially achieve the Project objectives.

Finding
The City finds that Alternative 1 is infeasible because although it is environmentally superior to the Proposed Project, significant and unavoidable impacts pertaining to air quality, GHG emissions, and noise would still remain, and the project objectives will only be partially achieved.

In making this determination, the City finds that when compared to the alternatives described and evaluated in the PEIR, the Proposed Project, as mitigated, provides a reasonable balance between satisfying the Project objectives and reducing potential environmental impacts to an acceptable level. For the potentially significant impacts that cannot be avoided or mitigated to a level below significance, the City adopts the Statement of Overriding Considerations in Section 6 of this Findings document pursuant to CEQA Guidelines, Section 15093.

This alternative is intended to meet the requirements of CEQA Guidelines Section 15126.6(e) for evaluation of a no project alternative.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Chapter 7.0, Alternatives.

5.3.1.2 Alternative 2: Proposed General Plan but No Brea Core Specific Plan Alternative
The Alternative 2: Proposed General Plan but No Brea Core Specific Plan Alternative would eliminate the BCSP project from the Proposed Project. Under Alternative 2, the Focused GPU would be adopted but the land use increased proposed under BCSP would not be included. Instead, the units under the current 2003 Brea General Plan would be assumed within the BCSP area. The Findings of Fact 127 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan proposed goals, policies, and actions of the Focused GPU would not change and be implemented, but none of the BCSP goals and policies would be implemented.

As shown in Table 5-2, Alternative 2: Buildout Projections Compared to the Proposed Project, of the PEIR, this alternative would result in 21,445 housing units (net decrease of 2,291 housing units), and 61,118 population (net decrease of 6,529 residents), 30,295,247 square feet of non-residential (net decrease of 291,946 square feet), and 73,005 jobs (net decrease of 704 jobs) compared to the Proposed Project. The purpose of this alternative is to potentially reduce the severity of potential impacts to air quality, GHG emissions, and noise, as overall development of residential and nonresidential would be less than what could be developed with the Proposed Project.

Ability to Reduce Impacts
As discussed in Section 7.4.2, of the PEIR, Alternative 2 would not eliminate the significant and unavoidable impacts that would occur with the Proposed Project. Environmental issue areas related to Land Use and Planning and Transportation would be greater with Alternative 2 when compared to the Proposed Project. Alternative 2 would result in reduced impacts for the following environmental topic areas when compared to the Proposed Project: Aesthetics, Air Quality, Cultural Resources, Energy, Geology and Soils (Paleo Only), Greenhouse Gas Emissions, Hazards and Hazardous Materials, Hydrology and Water Quality, Noise, Public Services, Tribal Cultural Resources, and Utilities and Service Systems. Alternative 2 would result in similar impacts to the Proposed Project in the following environmental topic areas: Biological Resources and Wildfire.

Ability to Achieve Project Objectives
As discussed in Section 7.4.2, of the PEIR, Alternative 2 would partially achieve the Project objectives.

Finding
The City finds that Alternative 2 is infeasible because although it is environmentally superior to the Proposed Project, significant and unavoidable impacts pertaining to air quality, GHG emissions, and noise would still remain, and the project objectives will only be partially achieved.

Reference: These Findings incorporate by reference the information and analysis included in PEIR Chapter 7.0, Alternatives.

Findings of Fact 128 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan

5.3.1.3 Alternative 3: Reduced Intensity Alternative
The Alternative 3: Reduced Intensity Alternative would reduce the overall intensity of the Proposed Project by 30 percent, including the BCSP development intensity. As shown in Table 5-3, Alternative 3: Buildout Projections Compared to the Proposed Project, of the PEIR, this alternative would result in 16,615 housing units (net decrease of 7,121 housing units), and 47,353 population (net decrease of 20,294 residents), 21,411,035 square feet of non-residential (net decrease of 9,176,158 square feet), and 51,596 jobs (net decrease of 22,113 jobs) compared to the Proposed Project. The proposed goals, policies, and actions of the Focused GPU would not change and be implemented.

The purpose of this alternative is to potentially reduce the severity of potential impacts to air quality, GHG emissions, and noise, as overall development of residential and non-residential would be less than what could be developed with the Proposed Project.

Ability to Reduce Impacts
As discussed in Section 7.4.3, of the PEIR, Alternative 3 would not eliminate the significant and unavoidable impacts that would occur with the Proposed Project. Environmental issue areas related to Land Use and Planning and Transportation would be greater with Alternative 3 when compared to the Proposed Project. Alternative 3 would result in reduced impacts for all other environmental topic areas when compared to the Proposed Project: Aesthetics, Air Quality, Biological Resources, Cultural Resources, Energy, Geology and Soils (Paleo Only), Greenhouse Gas Emissions, Hazards and Hazardous Materials, Hydrology and Water Quality, Noise, Public Services, Tribal Cultural Resources, Utilities and Service Systems, and Wildfire.

Ability to Achieve Project Objectives
As discussed in Section 7.4.3, of the PEIR, Alternative 3 would partially achieve the Project objectives.

Finding
The City finds that Alternative 3 is infeasible because although it is environmentally superior to the Proposed Project, significant and unavoidable impacts pertaining to air quality, GHG emissions, and noise would still remain, and the project objectives will only be partially achieved.

Findings of Fact 129 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Reference: These Findings incorporate by reference the information and analysis included in PEIR Chapter 7.0, Alternatives.

5.3.2 Environmentally Superior Alternative
CEQA requires the identification of an environmentally superior alternative. Section 15126.6(e)(2) of the CEQA Guidelines states that, if the No Project Alternative is the environmentally superior alternative, then the EIR shall also identify an environmentally superior alternative among the other alternatives.

Of the alternatives analyzed, the environmentally superior alternative is Alternative 3: Reduced Intensity Alternative, has been identified as the environmentally superior alternative. As shown in PEIR Table 7-5, Summary of Alternatives Impacts Compared to the Proposed Project, Alternative 3 would have less impacts under 14 of the environmental topic areas and greater impacts under two of the environmental topic areas. Although Alternative 3 would reduce significant and unavoidable impacts pertaining to air quality, GHG emissions, and noise, it would not be to the degree to eliminate the significant and unavoidable impacts. Also, it would only partially meet project objectives, therefore, only partially achieve the associated benefits.

CEQA does not require the City to choose the environmentally superior alternative. Instead, CEQA requires the City to consider environmentally superior alternatives, weigh those considerations against the environmental impacts of the proposed Project, and make findings that the benefits of those considerations outweigh the harm.

Findings of Fact 130 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Chapter 6.0 Statement of Overriding Considerations
The Program Environmental Impact Report (PEIR) identifies that even with the implementation of all feasible mitigation measures and compliance with existing Plans, Programs, and Policies (PPPs), the Proposed Project would have a significant, unavoidable environmental impact on the following area, which is described in detail in Chapter 4, Environmental Analysis, in the PEIR:
• Air quality
• GHG emissions
• Noise
The City has adopted all feasible mitigation measures regarding the significant, unavoidable environmental impacts. Although in some instances the mitigation measures may substantially lessen the unavoidable environmental impact, adoption of the mitigation measures will not fully avoid the impact. In addition, the City has analyzed a reasonable range of alternatives to the proposed project. Based on this analysis, the City has determined that none of these alternatives would avoid these significant and unavoidable impacts or fully meet the objectives of the Project or are feasible and environmentally preferable to the Project as approved.

Therefore, pursuant to California Environmental Quality Act (CEQA) Guidelines, Sections 15043 and 15093, the City must adopt a Statement of Overriding Considerations to approve the Proposed Project. A Statement of Overriding Considerations allows a lead agency to determine that specific economic, social, or other expected benefits of a project outweigh its potential unavoidable, significant environmental risks. The City has weighed the benefits of the Proposed Project against its potentially significant environmental risks in determining whether to approve the Proposed Project.

The City finds that the Project’s benefits are grounded in and derived from (1) the project objectives identified in the Program EIR, (2) the adopted goals and policies of the Brea 2050: Focused General Plan Update, and (3) Brea Core Specific Plan. These objectives and policies were developed through a comprehensive public planning process and reflect the City’s long-term vision for land use, housing, mobility, economic development, environmental protection, and community character.

The Proposed Project represents the implementation of this policy framework and provides substantial economic, social, environmental, and legal benefits.

The City is required to balance the benefits of the proposed project against its unavoidable environmental risks. Pursuant to CEQA Guidelines, Section 15093, based on the analysis contained in the Final PEIR, the Findings of Fact, and the entire administrative record, the City hereby finds that the Proposed Project would result in substantial public benefits, including but not limited to the following, and that each of the following benefits is sufficient on its own to justify adoption of the Proposed Project.

Findings of Fact 131 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan A. Sustainable Land Use and Environmental Protection
• Compact Urban Form: The Project promotes compact, infill development within the Brea Core and other strategic urbanized areas. By prioritizing growth in areas already served by existing infrastructure, the Project avoids unnecessary expansion into sensitive undeveloped lands.
• Natural Resource Stewardship: The Project supports the preservation of wildlife corridors, habitat connectivity, and open space. It further regulates development in hillside areas to ensure orderly growth that is consistent with environmental protection standards.
• VMT Reduction: By fostering a land use pattern that integrates housing, jobs, and services, the Project supports long-term reductions in per-capita Vehicle Miles Traveled (VMT), directly addressing regional sustainability goals.

B. Housing Diversity and Community Quality of Life
• Housing Production and Affordability: The Project facilitates a wide range of housing types and densities. This expansion of mixed-use residential opportunities is essential for meeting local and regional housing mandates and enhancing the diversity of Brea’s housing market.
• Placemaking and Design: Through high-quality urban design and enhanced community placemaking policies, the Project improves the overall aesthetic and functional quality of life for residents and visitors.

C. Economic Vitality and Revitalization
• Revitalization of the Brea Core: The BCSP creates a framework for a vibrant, mixeduse environment that attracts investment and modernizes key commercial corridors to meet contemporary market needs.
• Job Creation and Economic Growth: The Proposed Project streamlines development in the BCSP area and implements goals and policies that recognize and promote economic vibrancy and resiliency as central aspects of planning for Brea’s future, thereby fostering economic expansion and creating diverse new employment opportunities within the City.

D. Mobility and Infrastructure Reliability
• Enhanced Multimodal Connectivity: The Project implements policies that enhance walkability, bikeability, and access to transit, providing residents with viable alternatives to single-occupant vehicle travel.
• Coordinated Infrastructure Growth: The Project ensures that essential public services and infrastructure improvements (water, sewer, and drainage) are strictly coordinated with new development to maintain high service levels.

E. Public Safety and Resilience
• Wildfire Risk Management: The Focused GPU incorporates updated Public Safety Element policies specifically designed to manage and mitigate risks associated with Findings of Fact 132 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan the Wildland-Urban Interface (WUI), particularly in vulnerable areas such as areas near Carbon Canyon Road.

The City Council has considered the administrative record and the PEIR and has weighed the benefits of the Proposed Project against the unavoidable environmental impacts related to air quality, GHG emissions, and noise. Each benefit listed above is determined to be an independent ground for overriding the Project’s significant and unavoidable impacts. The City Council finds that the economic, social, and planning benefits of the Proposed Project are central to the City's future and provide sufficient justification for the approval of the Proposed Project.

Findings of Fact 133 May 2026
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Mitigation Monitoring and Reporting Program
Mitigation Monitoring and Reporting Program 1 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Mitigation Monitoring and Reporting Program

1.1 Introduction

1.1.1 Purpose of Mitigation Monitoring and Reporting Program In accordance with the California Environmental Quality Act (CEQA), California Public Resources Code (PRC), Section 21000 et seq.), the City of Brea (City), prepared a Program Environmental Impact Report (PEIR) (State Clearinghouse No. 2025081123) for the Brea 2050:

Focused General Plan Update and Brea Core Specific Plan (Proposed Project or Project) dated February 2026. The Mitigation Monitoring and Reporting Program (MMRP) has been prepared in conformance with Section 21081.6 of the Public Resources Code. Section 21081.6 states:
(a) When making findings required by paragraph (1) of subdivision (a) of Section 21081 or when adopting a mitigated negative declaration pursuant to paragraph (2) of subdivision (c) of Section 21080, the following requirements shall apply:
(1) The public agency shall adopt a reporting or monitoring program for the changes made to the project or conditions of project approval, adopted in order to mitigate or avoid significant effects on the environment. The reporting or monitoring program shall be designed to ensure compliance during project implementation. For those changes which have been required or incorporated into the project at the request of a responsible agency or a public agency having jurisdiction by law over natural resources affected by the project, that agency shall, if so requested by the lead or responsible agency, prepare and submit a proposed reporting or monitoring program.
(2) The lead agency shall specify the location and custodian of the documents or other material which constitute the record of proceedings upon which its decision is based.

1.1.2 Environmental Impacts
Impacts Considered No Impact or Less Than Significant
Based on Chapter 5, Effects Found Not To Be Significant, of the PEIR, the City determined that the Proposed Project would have no impact or a less than significant impact on the following environmental topic areas, and that no mitigation measures are required:
• Agriculture and Forestry Resources: Thresholds AG-a, AG-b, AG-c, AG-d, and AG-e.

Exhibit B to Ordinance No. 127X
Program EIR No. 2026-01
Mitigation Monitoring and Reporting Program
Mitigation Monitoring and Reporting Program 2 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan • Geology and Soils: Thresholds GEO-a(i), GEO-a(ii), GEO-a(iii), GEO-a(vi), GEO-b, GEO-c, GEO-d, and GEO-e.
• Mineral Resources: Thresholds MIN-a and MIN-b.
• Population and Housing: Thresholds PH-a and PH-b.
• Recreation: Thresholds REC-a and REC-b.

Less Than Significant
The PEIR identified various thresholds from the CEQA Guidelines across multiple environmental categories that would not be significantly impacted by the project, as discussed in Chapter 4, Environmental Analysis. Therefore, these topics did not require mitigation. Impacts to the following environmental resources were found to be less than significant impact • Aesthetics: Thresholds AES-a, AES-b, AES-c, and AES-d. • Air Quality: Thresholds AQ-c and AQ-d.
• Biological Resources: Threshold BIO-f.
• Cultural Resources: Thresholds CUL-a and CUL-c.
• Energy: Thresholds EN-a and EN-b.
• Greenhouse Gas Emissions: Threshold GHG-b.
• Hazards and Hazardous Materials: Thresholds HAZ-a, HAZ-b, HAZ-c, HAZ-d, HAZ-e, HAZ-f, and HAZ-g.
• Hydrology and Water Quality: Thresholds HYD-a, HYD-b and c, HYD-d, and HYD-e. • Land Use: Thresholds LU-a and LU-b.
• Noise: Threshold NOI-c.
• Public Services: Thresholds PS-a(i), PS-a(ii), PS-a(iii), PS-a(iv), and PS-a(v). • Transportation: Thresholds TRA-a, TRA-b, TRA-c, and TRA-d. • Utilities and Service Systems: Thresholds UTL-b, UTL-c, UTL-d, and UTL-e. • Wildfire: Thresholds WILD-a, WILD-b, WILD-c, and WILD-d.

Mitigation Monitoring and Reporting Program
Mitigation Monitoring and Reporting Program 3 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Potentially Significant Adverse Impacts That Can Be Mitigated, Avoided, or Substantially Lessened
The PEIR concluded that the Proposed Project could result in one or more potentially significant impacts in the following topic areas:
• Biological Resources: Thresholds BIO-a, BIO-b, and BIO-c, BIO-d, and BIO-e. • Cultural Resources: Threshold CUL-b.
• Geology and Soils: Threshold GEO-f.
• Noise: Threshold NOI-b.
• Tribal Cultural Resources: Threshold TCR-a.
• Utilities and Service Systems: Threshold UTL-a.

Unavoidable Significant Adverse Impacts
The PEIR identifies that even with the implementation of all feasible mitigation measures and compliance with existing Plans, Programs, and Policies (PPPs), the Proposed Project would have significant and unavoidable environmental impacts on the following areas:
• Air Quality: Thresholds AQ-a and AQ-b.
• GHG Emissions: Threshold GHG-a.
• Noise: Threshold NOI-a.

Mitigation Monitoring and Reporting Program
Mitigation Monitoring and Reporting Program 4 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan

1.2 Categorized Mitigation Measures/Matrix
Mitigation Measures (MM) have been categorized in matrix format, as shown in Table 1, Mitigation Monitoring and Reporting Requirements. The mitigation measures were included in the Draft Program Environmental Impact Report (PEIR), with minor modifications in the Final PEIR, and are applicable to the Proposed Project. The matrix identifies the environmental factor, specific mitigation measures, schedule, and responsible monitor. The mitigation matrix will serve as the basis for scheduling the implementation of and compliance with all mitigation measures.

Mitigation Monitoring and Reporting Program
Mitigation Monitoring and Reporting Program 5 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Table 1. Mitigation Monitoring and Reporting Requirements Mitigation Measure
Responsible for
Implementation Timing
Responsible
for
Monitoring
Monitor
(Signature
Required)
(Date of
Compliance)
Section 4.2, Air Quality
MM AQ-1 Site-Specific Air Quality Analysis and Best Management Practices. Prior to the issuance of a grading or construction permit for individual development projects that are not exempt from California Environmental Quality Act (CEQA), and in conjunction with any required CEQA review, future project applicants shall submit to the City of Brea Planning Division documentation that the project is consistent with the South Coast Air Quality Management District (South Coast AQMD) mass daily significance thresholds and localized significance thresholds (LSTs) for criteria air pollutant emissions during construction. A project-specific Air Quality Analysis quantifying the potential air emissions of project construction shall be prepared by a qualified air quality professional. This Air Quality Analysis shall demonstrate that criteria air pollutant emissions are below the South Coast AQMD mass daily significance thresholds and LSTs. If the Air Quality Analysis cannot demonstrate that the project is below the South Coast AQMD thresholds before mitigation, the project applicant shall implement practices to reduce VOC and NOX emissions to the extent necessary to reduce emissions to below South Coast AQMD thresholds. Best management practices may include, but are not limited to:
• Use equipment with engines that meet, at a minimum, the Tier 4 Final California Emissions Standards, or electric-powered equipment.
• Use architectural coatings that meet “Super-Compliant” VOC standards (as defined in South Coast AQMD Rule 1113) and California Green Building Standards Code (CalGreen)
requirements under the mandatory measures, or pre-coated materials such as bathroom stall dividers, and metal awnings. • Minimize idling time either by shutting equipment off when not in use or reducing the time of idling to 5 minutes. Provide clear Owner/Developer Prior to the
issuance of a
grading or
construction
permit for
individual
development
projects
Brea Community
Development
Department
Exhibit B to Resolution No. 2026-XX
MMRP
Mitigation Monitoring and Reporting Program
Mitigation Monitoring and Reporting Program 6 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Table 1. Mitigation Monitoring and Reporting Requirements Mitigation Measure
Responsible for
Implementation Timing
Responsible
for
Monitoring
Monitor
(Signature
Required)
(Date of
Compliance)
signage that posts this requirement for workers at the entrances to the site and at construction offices/trailers.
• Maintain all construction equipment in proper working condition according to manufacturer’s specifications. The equipment must be checked by a certified mechanic and determined to be running in proper condition before it is operated.

Section 4.2, Biological Resources
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.

Owner/Developer and
Project Biologist
Prior to the
issuance of any
construction or
clearing, grading,
or construction
permits for
individual
development
projects
Brea Community
Development
Department
Mitigation Monitoring and Reporting Program
Mitigation Monitoring and Reporting Program 7 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Table 1. Mitigation Monitoring and Reporting Requirements Mitigation Measure
Responsible for
Implementation Timing
Responsible
for
Monitoring
Monitor
(Signature
Required)
(Date of
Compliance)
• 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.

Mitigation Monitoring and Reporting Program
Mitigation Monitoring and Reporting Program 8 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Table 1. Mitigation Monitoring and Reporting Requirements Mitigation Measure
Responsible for
Implementation Timing
Responsible
for
Monitoring
Monitor
(Signature
Required)
(Date of
Compliance)
• 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 onsite 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 non-native 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 Mitigation Monitoring and Reporting Program
Mitigation Monitoring and Reporting Program 9 May 2026
Brea 2050: Focused General Plan Update and Brea Core Specific Plan Table 1. Mitigation Monitoring and Reporting Requirements Mitigation Measure
Responsible for
Implementation Timing
Responsible
for
Monitoring
Monitor
(Signature
Required)
(Date of
Compliance)
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 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 offsite 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.

Owner/Developer and
Project Biologist
Prior to site
disturbance,
including grading,
vegetation
clearing, or fuel
modification for
individual
development
projects
Brea Community
Development
Department
Mitigation Monitoring and Reporting Program
Mitigation Monitoring and Reporting Program 10 May 2026 Brea 2050: Focused General Plan Update and Brea Core Specific Plan Table 1. Mitigation Monitoring and Reporting Requirements Mitigation Measure
Responsible for
Implementation Timing
Responsible
for
Monitoring
Monitor
(Signature
Required)
(Date of
Compliance)
• 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.

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.

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 groundtruth and/or update vegetation communities. Vegetation communities Owner/Developer and
Project Biologist
Prior to any
vegetation
clearing or
ground-disturbing
activities
Brea Community
Development
Department
Mitigation Monitoring and Reporting Program
Mitigation Monitoring and Reporting Program 11 May 2026 Brea 2050: Focused General Plan Update and Brea Core Specific Plan Table 1. Mitigation Monitoring and Reporting Requirements Mitigation Measure
Responsible for
Implementation Timing
Responsible
for
Monitoring
Monitor
(Signature
Required)
(Date of
Compliance)
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.

Mitigation shall be fulfilled through one of the following options:
a. 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 offsite 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
b. 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, 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 Mitigation Monitoring and Reporting Program
Mitigation Monitoring and Reporting Program 12 May 2026 Brea 2050: Focused General Plan Update and Brea Core Specific Plan Table 1. Mitigation Monitoring and Reporting Requirements Mitigation Measure
Responsible for
Implementation Timing
Responsible
for
Monitoring
Monitor
(Signature
Required)
(Date of
Compliance)
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.

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.

Mitigation Monitoring and Reporting Program
Mitigation Monitoring and Reporting Program 13 May 2026 Brea 2050: Focused General Plan Update and Brea Core Specific Plan Table 1. Mitigation Monitoring and Reporting Requirements Mitigation Measure
Responsible for
Implementation Timing
Responsible
for
Monitoring
Monitor
(Signature
Required)
(Date of
Compliance)
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.

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 Owner/Developer and
Project Biologist
Prior to site
disturbance,
including grading,
vegetation
clearing, or fuel
modification for
individual
development
projects
Brea Community
Development
Department
Mitigation Monitoring and Reporting Program
Mitigation Monitoring and Reporting Program 14 May 2026 Brea 2050: Focused General Plan Update and Brea Core Specific Plan Table 1. Mitigation Monitoring and Reporting Requirements Mitigation Measure
Responsible for
Implementation Timing
Responsible
for
Monitoring
Monitor
(Signature
Required)
(Date of
Compliance)
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.

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 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 surveys, bird construction avoidance areas/noise buffers/barriers, other impact avoidance areas, and any Owner/Developer and
Project Biologist
Prior to site
disturbance,
including grading,
vegetation
clearing, or fuel
modification for
individual
development
projects
Brea Community
Development
Department
Mitigation Monitoring and Reporting Program
Mitigation Monitoring and Reporting Program 15 May 2026 Brea 2050: Focused General Plan Update and Brea Core Specific Plan Table 1. Mitigation Monitoring and Reporting Requirements Mitigation Measure
Responsible for
Implementation Timing
Responsible
for
Monitoring
Monitor
(Signature
Required)
(Date of
Compliance)
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 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 fencing, along the limits or facilities that are within or adjacent to developed and nonsensitive 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.

Mitigation Monitoring and Reporting Program
Mitigation Monitoring and Reporting Program 16 May 2026 Brea 2050: Focused General Plan Update and Brea Core Specific Plan Table 1. Mitigation Monitoring and Reporting Requirements Mitigation Measure
Responsible for
Implementation Timing
Responsible
for
Monitoring
Monitor
(Signature
Required)
(Date of
Compliance)
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.

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 Mitigation Monitoring and Reporting Program
Mitigation Monitoring and Reporting Program 17 May 2026 Brea 2050: Focused General Plan Update and Brea Core Specific Plan Table 1. Mitigation Monitoring and Reporting Requirements Mitigation Measure
Responsible for
Implementation Timing
Responsible
for
Monitoring
Monitor
(Signature
Required)
(Date of
Compliance)
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 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 representatives (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.

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 Mitigation Monitoring and Reporting Program
Mitigation Monitoring and Reporting Program 18 May 2026 Brea 2050: Focused General Plan Update and Brea Core Specific Plan Table 1. Mitigation Monitoring and Reporting Requirements Mitigation Measure
Responsible for
Implementation Timing
Responsible
for
Monitoring
Monitor
(Signature
Required)
(Date of
Compliance)
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.

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 site-specific development shall be conducted, as applicable, in suitable habitat, to determine Owner/Developer and
Project Biologist
Prior to site
disturbance,
including grading,
vegetation
clearing, or fuel
modification for
Brea Community
Development
Department
Mitigation Monitoring and Reporting Program
Mitigation Monitoring and Reporting Program 19 May 2026 Brea 2050: Focused General Plan Update and Brea Core Specific Plan Table 1. Mitigation Monitoring and Reporting Requirements Mitigation Measure
Responsible for
Implementation Timing
Responsible
for
Monitoring
Monitor
(Signature
Required)
(Date of
Compliance)
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 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 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 individual
development
projects
Mitigation Monitoring and Reporting Program
Mitigation Monitoring and Reporting Program 20 May 2026 Brea 2050: Focused General Plan Update and Brea Core Specific Plan Table 1. Mitigation Monitoring and Reporting Requirements Mitigation Measure
Responsible for
Implementation Timing
Responsible
for
Monitoring
Monitor
(Signature
Required)
(Date of
Compliance)
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 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 Mitigation Monitoring and Reporting Program
Mitigation Monitoring and Reporting Program 21 May 2026 Brea 2050: Focused General Plan Update and Brea Core Specific Plan Table 1. Mitigation Monitoring and Reporting Requirements Mitigation Measure
Responsible for
Implementation Timing
Responsible
for
Monitoring
Monitor
(Signature
Required)
(Date of
Compliance)
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.

Mitigation Monitoring and Reporting Program
Mitigation Monitoring and Reporting Program 22 May 2026 Brea 2050: Focused General Plan Update and Brea Core Specific Plan Table 1. Mitigation Monitoring and Reporting Requirements Mitigation Measure
Responsible for
Implementation Timing
Responsible
for
Monitoring
Monitor
(Signature
Required)
(Date of
Compliance)
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.
i. 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 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 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 Owner/Developer and
Project Biologist
Prior to site
disturbance,
including grading,
vegetation
clearing, or fuel
modification for
individual
development
projects
Brea Community
Development
Department
Mitigation Monitoring and Reporting Program
Mitigation Monitoring and Reporting Program 23 May 2026 Brea 2050: Focused General Plan Update and Brea Core Specific Plan Table 1. Mitigation Monitoring and Reporting Requirements Mitigation Measure
Responsible for
Implementation Timing
Responsible
for
Monitoring
Monitor
(Signature
Required)
(Date of
Compliance)
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.

MM BIO-8 Aquatic Resources Delineation. If potentially jurisdictional aquatic resources are identified during pre-project/activity surveys pursuant to mitigation measure MM BIO-1, a qualified biologist shall conduct a formal aquatic resources delineation following the methods outlined in the 1987 U.S. Army Corps of Engineers Wetland Delineation Manual and applicable Regional Supplement to the U.S. Army Corps of Engineers Wetland Delineation Manual to map the extent of wetlands and non-wetland waters, determine jurisdiction, and assess potential impacts. The results of the delineation shall be presented in an aquatic resources delineation report. The aquatic resources delineation report shall be used in consultation with the U.S. Army Corps of Engineers, Regional Water Quality Control Board, and California Department of Fish and Wildlife for necessary authorization or permit, as described in mitigation measure MM BIO-9.

Owner/Developer and
Project Biologist
Prior to site
disturbance,
including grading,
vegetation
clearing, or fuel
modification for
individual
development
projects
containing
aquatic resources
Brea Community
Development
Department
MM BIO-9 Potentially Jurisdictional Aquatic Resources Permitting.

Temporary and permanent impacts to the wetland and non-wetland waters potentially under the jurisdiction of the U.S. Army Corps of Engineers, Regional Water Quality Control Board, and California Department of Fish and Wildlife, shall be authorized by the U.S. Army Corps of Engineers, Regional Water Quality Control Board, and California Department of Fish and Wildlife, as applicable. Approved Owner/Developer and
Project Biologist
Prior to site
disturbance,
including grading,
vegetation
clearing, or fuel
modification for
individual
Brea Community
Development
Department
Mitigation Monitoring and Reporting Program
Mitigation Monitoring and Reporting Program 24 May 2026 Brea 2050: Focused General Plan Update and Brea Core Specific Plan Table 1. Mitigation Monitoring and Reporting Requirements Mitigation Measure
Responsible for
Implementation Timing
Responsible
for
Monitoring
Monitor
(Signature
Required)
(Date of
Compliance)
temporary and permanent impacts to the potentially Federal and State jurisdictional aquatic resources in the project area require compensatory mitigation through proposed on- or off-site habitat restoration, creation, or enhancement to the satisfaction of the U.S.

Army Corps of Engineers, Regional Water Quality Control Board, and California Department of Fish and Wildlife to achieve a no-net loss of Federal and State jurisdictional wetland and non-wetland waters. development
projects
containing
aquatic resources
Section 4.4, Cultural Resources
MM CUL-1 Archaeological Resources Assessment. Prior to the commencement of projects not exempt under California
Environmental Quality Act (CEQA) involving ground-disturbing activities (including grading, excavation, trenching, boring, or demolition extending below existing grade) in areas that have not been previously developed or includes unpaved areas, the project proponent shall provide an Archaeological Resources Assessment as part of project-level CEQA review prepared by a qualified archaeologist., The assessment shall be prepared under the supervision of an archaeologist meeting the Secretary of the Interior’s professional qualifications standards in prehistoric and/or archaeology.

The assessment shall include:
• A California Historical Resources Information System records search at the South Central Coastal Information Center; • A review of the Native American Heritage Commission Sacred Lands File; and
• Evaluation of previous cultural resources investigations and recorded resources within and adjacent to the project site.

Owner/Developer and
Project Archaeologist
Prior to projects
involving grounddisturbing
activities
(including
grading,
excavation,
trenching, boring,
or demolition
extending below
existing grade)
Brea Community
Development
Department
MM CUL-2 Inadvertent Discovery. If archaeological resources are encountered during ground disturbing activities, work in the immediate area shall cease and an archaeologist meeting the Secretary of the Interior’s Owner/Developer and
Project Archaeologist
Prior to projects
involving grounddisturbing
Brea Community
Development
Department
Mitigation Monitoring and Reporting Program
Mitigation Monitoring and Reporting Program 25 May 2026 Brea 2050: Focused General Plan Update and Brea Core Specific Plan Table 1. Mitigation Monitoring and Reporting Requirements Mitigation Measure
Responsible for
Implementation Timing
Responsible
for
Monitoring
Monitor
(Signature
Required)
(Date of
Compliance)
professional qualifications standards in prehistoric and/or archaeology shall be contacted immediately to evaluate the find(s). If the discovery proves to be significant as determined by the qualified archeologist, procedures outlined in Mitigation Measure MM CUL-6 shall be implemented.
activities
(including
grading,
excavation,
trenching, boring,
or demolition
extending below
existing grade)
MM CUL-3 Evaluation and Mitigation of Significant Archaeological Resources. If potentially significant archaeological resources are identified under Mitigation Measure MM CUL-1 or MM CUL-2, and avoidance is not feasible, a Phase II Testing and Evaluation Program shall be conducted to determine resource significance prior to ground disturbance. Phase II investigations shall be conducted by a qualified archaeologist and in coordination with affiliated California Native American Tribes, where applicable.

Data recovery shall be conducted in accordance with the Office of Historic Preservation’s guidelines, including Archaeological Resource Management Reports: Recommended Contents and Format and Guidelines for Archaeological Research Designs.

Owner/Developer and
Project Archaeologist
Prior to projects
involving grounddisturbing
activities
(including
grading,
excavation,
trenching, boring,
or demolition
extending below
existing grade)
Brea Community
Development
Department
MM CUL-4 Construction Monitoring in High-Sensitivity Areas. If the Archaeological Resources Assessment identifies the project site as highly sensitive for archaeological resources, a qualified archaeologist and a Native American monitor, approved by a California Native American Tribe identified by the Native American Heritage Commission as culturally affiliated, shall monitor all ground-disturbing activities in sensitive areas.

Owner/Developer and
Project Archaeologist
Prior to projects
involving grounddisturbing
activities
(including
grading,
excavation,
trenching, boring,
Brea Community
Development
Department
Mitigation Monitoring and Reporting Program
Mitigation Monitoring and Reporting Program 26 May 2026 Brea 2050: Focused General Plan Update and Brea Core Specific Plan Table 1. Mitigation Monitoring and Reporting Requirements Mitigation Measure
Responsible for
Implementation Timing
Responsible
for
Monitoring
Monitor
(Signature
Required)
(Date of
Compliance)
Prior to construction, the archaeologist shall conduct a worker environmental awareness training addressing the identification and protection of archaeological resources. The Native American monitor shall be invited to participate.

If archaeological materials are discovered, work shall cease in the vicinity of the discovery until the resources are evaluated by the qualified archaeologist, in coordination with the Native American monitor and affiliated Tribe(s), as appropriate. The treatment and final disposition of materials shall be determined through Tribal consultation and may include curation, repatriation, or reinterment. or demolition
extending below
existing grade)
MM CUL-5 On-Call Archaeological Monitoring in Moderate-Sensitivity Areas.

If the Archaeological Resources Assessment identifies the project site as having moderate sensitivity, a qualified archaeologist shall be retained on an on-call basis. Pre-construction training shall be provided to construction personnel regarding procedures for unanticipated discoveries.

Appropriate treatment and disposition of materials shall be determined in consultation with affiliated Tribe(s).

Owner/Developer and
Project Archaeologist
Prior to projects
involving grounddisturbing
activities
(including
grading,
excavation,
trenching, boring,
or demolition
extending below
existing grade)
Brea Community
Development
Department
Section 4.6, Geology and Soils (paleontological resources only) MM GEO-1 Prior to issuance of a grading permit for any project that would involve ground-disturbing activities greater than current foundations present on a given site, underlain by Quaternary (Pleistocene and Holocene) terrestrial deposits or older geologic units, or within areas identified as having high or undetermined paleontological sensitivity the project proponent shall retain a qualified professional paleontologist meeting the qualifications of the Society of Vertebrate Paleontology to conduct an evaluation to determine the paleontological sensitivity of the Owner/Developer and
Project Paleontologist
Prior to issuance
of a grading
permit for
individual project
involving grounddisturbing
activities greater
than current
Brea Community
Development
Department
Mitigation Monitoring and Reporting Program
Mitigation Monitoring and Reporting Program 27 May 2026 Brea 2050: Focused General Plan Update and Brea Core Specific Plan Table 1. Mitigation Monitoring and Reporting Requirements Mitigation Measure
Responsible for
Implementation Timing
Responsible
for
Monitoring
Monitor
(Signature
Required)
(Date of
Compliance)
geologic units affected by the project and whether ground-disturbing activities would result in a significant impact to paleontological resources according to current Society of Vertebrate Paleontology guidelines. The evaluation shall be submitted to the City of Brea Community Development Department for review and approval.

These measures may include but not be limited to implementation of a Worker Environmental Awareness Program, on-site paleontological monitoring, and fossil salvage and treatment plans, if applicable. If paleontological resources are discovered during excavation and/or construction activities, construction shall stop within 25 feet of the find, and the qualified professional paleontologist shall be consulted to determine whether the resource requires further study. The paleontologist shall make recommendations to the City of Brea to protect the discovered resources. Any paleontological resources recovered shall be provided for curation at a local curation facility such as the Dr. John D. Cooper Archaeological and Paleontological Center or other appropriate repository. The City of Brea Community Development Department shall review and approve the qualified professional paleontologist’s findings and recommendation. foundations
present on a
given site,
underlain by
Quaternary
(Pleistocene and
Holocene)
terrestrial
deposits or older
geologic units, or
within areas
identified as
having high or
undetermined
paleontological
sensitivity
Section 4.7, Greenhouse Gas Emissions
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 multiOwner/Developer Prior to the issuance of a
grading or
construction
permit for
individual
Brea Community
Development
Department
Mitigation Monitoring and Reporting Program
Mitigation Monitoring and Reporting Program 28 May 2026 Brea 2050: Focused General Plan Update and Brea Core Specific Plan Table 1. Mitigation Monitoring and Reporting Requirements Mitigation Measure
Responsible for
Implementation Timing
Responsible
for
Monitoring
Monitor
(Signature
Required)
(Date of
Compliance)
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
development
projects
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.

Mitigation Monitoring and Reporting Program
Mitigation Monitoring and Reporting Program 29 May 2026 Brea 2050: Focused General Plan Update and Brea Core Specific Plan Table 1. Mitigation Monitoring and Reporting Requirements Mitigation Measure
Responsible for
Implementation Timing
Responsible
for
Monitoring
Monitor
(Signature
Required)
(Date of
Compliance)
– 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 rideshare 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.

Mitigation Monitoring and Reporting Program
Mitigation Monitoring and Reporting Program 30 May 2026 Brea 2050: Focused General Plan Update and Brea Core Specific Plan Table 1. Mitigation Monitoring and Reporting Requirements Mitigation Measure
Responsible for
Implementation Timing
Responsible
for
Monitoring
Monitor
(Signature
Required)
(Date of
Compliance)
– 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
• 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:

Mitigation Monitoring and Reporting Program
Mitigation Monitoring and Reporting Program 31 May 2026 Brea 2050: Focused General Plan Update and Brea Core Specific Plan Table 1. Mitigation Monitoring and Reporting Requirements Mitigation Measure
Responsible for
Implementation Timing
Responsible
for
Monitoring
Monitor
(Signature
Required)
(Date of
Compliance)
– 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
Section 4.11, Noise
MM NOI-1 Construction Noise Best Practices. Prior to any construction activity, such as grading, site preparation, or issuance of building permits, a note shall be provided on the construction plans indicating that during construction activities, the project applicant shall be responsible for requiring contractors to implement the following measures to limit construction-related noise to a performance standard of 80 A-weighted decibel equivalent continuous sound level at the property line of the nearest sensitive receptor:
• Brea City Code, Section 8.20.070, limits construction activity to the daytime hours between 7:00 a.m. and 7:00 p.m. on Monday through Saturday. Construction is not allowed on Sundays and Federal holidays.
• During the entire active construction period, equipment and trucks used for the project construction shall use the best available noise control techniques (e.g., improved mufflers, use of intake silencers, ducts, engine enclosures, and acoustically attenuating shields or shrouds), wherever feasible.
• Require that impact tools (e.g., jack hammers and hoe rams) be hydraulically or electrically powered wherever possible. Where the use of pneumatic tools is unavoidable, an exhaust muffler on the compressed air exhaust shall be used along with external noise jackets on the tools.

Owner/Developer Prior to any
construction
activity, such as
grading, site
preparation, or
issuance of
building permits
Brea Community
Development
Department
Mitigation Monitoring and Reporting Program
Mitigation Monitoring and Reporting Program 32 May 2026 Brea 2050: Focused General Plan Update and Brea Core Specific Plan Table 1. Mitigation Monitoring and Reporting Requirements Mitigation Measure
Responsible for
Implementation Timing
Responsible
for
Monitoring
Monitor
(Signature
Required)
(Date of
Compliance)
• Stationary equipment such as generators and air compressors shall be located as far as feasible from nearby noise-sensitive uses.
• Stockpiling shall be located as far as feasible from nearby noisesensitive receptors. • Construction traffic shall be limited—to the extent feasible—to approved haul routes established by the City of Brea.
• Signs shall be posted at the job site entrance(s), within the onsite construction zones, and along queueing lanes (if any) to reinforce the prohibition of unnecessary engine idling. All other equipment shall be turned off if not in use for more than five minutes.
• During the entire active construction period and to the extent feasible, the use of noise-producing signals, including horns, whistles, alarms, and bells, shall be for safety warning purposes only. The construction manager shall use smart back-up alarms, which automatically adjust the alarm level based on the background noise level, or switch off back-up alarms and replace with human spotters in compliance with all safety requirements and laws.
• Erect temporary noise barriers, where feasible, when
construction noise is predicted to exceed the noise standards after other measures have been considered, or occur at
nighttime, or when the anticipated construction duration is greater than is typical (e.g., two years or more).

MM NOI-2 Roadway Noise Measures. Before the approval of building permits, project applicants for future development projects proposed as a result of the Focused General Plan Update shall evaluate whether projects would have the potential to exceed any of the following Owner/Developer Before the
approval of
building permits
Brea Community
Development
Department
Mitigation Monitoring and Reporting Program
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Responsible for
Implementation Timing
Responsible
for
Monitoring
Monitor
(Signature
Required)
(Date of
Compliance)
thresholds based on the Brea General Plan Community Noise and Land Use Compatibility standards:
• Greater than 1.5 A-weighted decibel increase for ambient noise environments of 65 A-weighted decibel Community Noise
Equivalent Level and higher.
• Greater than 3.0 A-weighted decibel increase for ambient noise environments of 60 to 64 A-weighted decibel Community Noise Equivalent Level.
• Greater than 5.0 A-weighted decibel increase for ambient noise environments of less than 60 A-weighted decibel Community Noise Equivalent Level.

A project that would potentially exceed the above thresholds shall complete a site-specific Noise Technical Study to determine if the project would result in a significant increase in traffic noise. This Noise Technical Study shall be prepared by a qualified acoustical analyst.

The following screening levels may be applied to determine whether a Noise Technical Study is required:
• If existing roadway segments serving the project have an average daily traffic below 1,800, a Noise Technical Study is required if the project would potentially double segment average daily traffic
• If existing roadway segments serving the project have an average daily traffic of 1,800 or higher, a Noise Technical Study is required if the project would generate more than 750 average daily trips
If a significant increase in vehicle noise level is identified as a result of individual project implementation, the project shall incorporate buffers or other noise reduction measures to the extent feasible to reduce noise levels at affected sensitive receptors to a normally acceptable noise level. Reduction measures that shall be considered include but Mitigation Monitoring and Reporting Program
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Responsible for
Implementation Timing
Responsible
for
Monitoring
Monitor
(Signature
Required)
(Date of
Compliance)
are not limited to alternative road design, reduced speeds, alternative paving, building retrofits to provide additional noise attenuation, and setbacks or buffers before berms and walls. The noise reduction measures shall be designed by a qualified acoustical engineer. Where noise reduction measures in the public right-of-way are infeasible, the project applicant shall conduct outreach to potentially affected sensitive receptors to determine the feasibility of noise reduction measures on private property, including a noise barrier or building retrofits. Based on affected receptor response, a qualified acoustical engineer shall determine the feasibility of a noise barrier on private property and/or the extent of required building retrofits. The project applicant shall submit plans to the City of Brea Community Development Department for review and approval before the start of any construction. These plans shall demonstrate that the proposed noise reduction measures would reduce traffic noise exposure at sensitive receptors to the extent feasible.

MM NOI-3 Vibration Best Management Practices. Prior to the start of construction activities requiring a Building Permit that involve typical construction equipment within 100 feet of the property line of occupied neighboring uses or within 165 feet of the property line of occupied neighboring uses with the use of a vibratory roller (or equivalent), the project applicant shall identify best management practices to be implemented by the construction contractor to minimize vibration levels in accordance with the Brea City Code, Section 20.20.040, limit to ground vibration. The best management practices shall be included in project construction documents, including the Grading Plans and contract with the construction contractor. Practices may include but not be limited to the following:
• Use only properly maintained equipment with vibratory isolators • Operate equipment as far from sensitive receptors as possible Use rubber-tired vehicles as opposed to tracked vehicles Owner/Developer Prior to the start
of construction
activities requiring
a Building Permit
that involve
typical
construction
equipment within
100 feet of the
property line of
occupied
neighboring uses
or within 165 feet
of the property
line of occupied
neighboring uses
Brea Community
Development
Department
Mitigation Monitoring and Reporting Program
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Responsible for
Implementation Timing
Responsible
for
Monitoring
Monitor
(Signature
Required)
(Date of
Compliance)
with the use of a
vibratory roller
MM TCR-1 Provision of Tribal Monitor. Prior to commencement of any grounddisturbing activities for qualifying development projects in which the potential exists for Tribal Cultural Resources to be present based on record searches or tribal knowledge, the project applicant shall coordinate with all interested State-recognized Tribes in concurrence with the City of Brea as the California Environmental Quality Act (CEQA) lead agency. A copy of the executed contract shall be submitted to the City of Brea Community Development Department prior to the issuance of any permit necessary to commence a grounddisturbing activity. • The Tribal monitor will only be present on-site during the construction phases that involve ground-disturbing activities.

Ground-disturbing activities are defined by the Consulting Tribe as activities that may include, but are not limited to, pavement removal, potholing or augering, grubbing, tree removals, boring, grading, excavation, drilling, and trenching. The Tribal monitor shall complete daily monitoring logs describing construction activities, locations, soil conditions, and any cultural materials identified. The monitoring shall end when all ground-disturbing activities are completed, or when the qualified archaeologist and/or Tribal monitor determines that all remaining grounddisturbing activities have little to no potential for impacting Tribal Cultural Resources.
• Upon discovery of any Tribal Cultural Resources, construction activities shall cease in the immediate vicinity of the find (not less than the surrounding 100 feet) until the find can be assessed. All Tribal Cultural Resources unearthed by project activities shall be evaluated by the qualified archaeologist and Tribal monitor. If the resources are Native American in origin, Owner/Developer Prior to
commencement
of any grounddisturbing
activities
Brea Community
Development
Department
Mitigation Monitoring and Reporting Program
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Responsible for
Implementation Timing
Responsible
for
Monitoring
Monitor
(Signature
Required)
(Date of
Compliance)
the Consulting Tribe will retain Tribal Cultural Resources in the form and/or manner the Consulting Tribe deems appropriate, for educational, cultural and/or historic purposes.
• If human remains and/or grave goods are discovered or recognized at the projects site, all ground disturbance shall immediately cease within 100 feet of discovery, and the county coroner shall be notified per Public Resources (PRC), Code Section 5097.98, and Health and Safety Code, Section 7050.5.

Human remains and grave/burial goods shall be treated alike per PRC Section 5097.98(d)(1) and (2).
• Work may continue on other parts of the project site while evaluation and, if necessary, mitigation takes place (CEQA Guidelines, Section 15064.5(f)).
• If a non-Native American resource is determined by the qualified archaeologist to constitute as a “historical resource” or “unique archaeological resource,” time allotment and funding sufficient to allow for implementation of avoidance measures, or appropriate mitigation, must be available. The treatment plan established for the resources shall be in accordance with CEQA Guidelines Section 15064.5(f) for historical resources and PRC Section 21074(b) for unique archaeological resources.

MM TCR-2 Discovery of Cultural Resources (Not Native American in Origin):

Prior to commencement of any ground-disturbing activity at the project site, the project applicant shall retain an archaeologist meeting the Secretary of the Interior’s Professional Qualifications Standards for Archaeology (National Park Service [NPS] 1983). If cultural resources that are not Native American in origin are encountered during ground-disturbing activities, construction activities shall cease in the immediate vicinity of the find (not less than the surrounding 100 feet) until the find can be assessed. If the discovery proves to be significant as determined by the site archaeologist, additional work Owner/Developer Prior to
commencement
of any grounddisturbing
activities
Brea Community
Development
Department
Mitigation Monitoring and Reporting Program
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Responsible for
Implementation Timing
Responsible
for
Monitoring
Monitor
(Signature
Required)
(Date of
Compliance)
such as data recovery excavation may be warranted and shall be reported to the City of Brea Community Development Department.

Section 4.15, Utilities and Service Systems
MM UTL-1 Water and Sewer Infrastructure Improvements. Prior to approval of any discretionary development permit or issuance of building permits, the project applicant for individual projects shall demonstrate compliance with the City of Brea’s Water Master Plan, and Sewer Master Plan, as well as all applicable improvement and design requirements of the City of Brea Public Works Department and the City’s Capital Improvement Program (CIP).

The applicant shall construct, or fund the construction of, all improvements identified through the approved modeling and required by the Public Works Department prior to occupancy or in accordance with a timing and phasing plan approved by the City. No development shall be permitted to proceed unless all required improvements or fairshare contributions are secured through conditions of approval, improvement plans, or a development agreement.

Owner/Developer Prior to approval
of any
discretionary
development
permit or
issuance of
building permits
City of Brea Public
Works Department
Mitigation Monitoring and Reporting Program
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1.3 Plans, Programs, and Policies
Plans, programs, and policies (PPPs) are shown in Table 2, Mitigation Monitoring and Reporting Requirements. The PPPs were included in the Draft Program Environmental Impact Report (PEIR), with minor modifications in the Final PEIR, and are applicable to the Proposed Project. Compliance measures are uniformly applied regulations or requirements imposed by the approving agency based on the type of action proposed. Because these measures are standard requirements, they are not considered mitigation measures.

Table 2. Plans, Programs, and Policies

4.1 Aesthetics
PPP AES-1 Development projects will be designed and constructed so that it would not conflict with the intent of the Brea City Code, Chapter 20.206, Hillside Residential Zone. In accordance with Section 20.206.210(A), Other Regulations, Exterior Lighting, exterior lighting will be properly shielded to avoid glare and the spill of light to surrounding areas. Low-level lighting and the use of multiple low-profile fixtures will be used instead of fewer but taller fixtures. The project will be designed so that emphasis on exterior lighting is on safety and landscaping lighting as opposed to building. The project applicant will present descriptions of exterior lighting in the design guideline manual required by Brea City Code, Section 20.206.050.

PPP AES-2 The Brea Core Specific Plan area will be designed and developed to be consistent with the new zoning designations and development standards contained in the Brea City Code applicable to the Brea Core area, which establishes allowable land uses, building form, and site development standards, such as height, setbacks, parking, and objective design standards.

4.2 Air Quality
PPP AQ-1 South Coast AQMD Rules. Development under the Focused General Plan Update and the Brea Core Specific Plan would be required to comply with all applicable South Coast AQMD rules which may include, but are not limited to, the following:
• Rule 402: Prohibits a person from discharging from any source whatsoever such quantities of air contaminants or other material which cause injury, detriment, nuisance, or annoyance to any considerable number of persons or to the public, or which endanger the comfort, repose, health or safety of any such persons or the public, or which cause, or have a natural tendency to cause, injury or damage to business or property. • Rule 403: Governs emissions of fugitive dust during construction and operation activities. Compliance with this rule is achieved through the application of standard Best Management Practices.
• Rule 445: Prohibits permanently installed wood burning devices into any new development. • Rule 1108: Governs the sale, use, and manufacturing of asphalt and limits the volatile organic compound (VOC) content in asphalt used in the South Coast Air Basin. This rule regulates the VOC content of asphalt used during construction. • Rule 1113: Serves to limit the VOC content of architectural coatings used on projects in the South Coast Air Basin. Any person who supplies, sells, offers for sale, or manufactures any architectural coating for use on projects in the South Coast Air Basin must comply with the current VOC standards set in this rule.
• Rule 1303: Governs the permitting of re-located or new major emission sources, requiring Best Available Control Measures and setting significance limits for PM10 among other pollutants.

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• Rule 1401: New Source Review of Toxic Air Contaminants, specifies limits for maximum individual cancer risk, cancer burden, and non-cancer acute and chronic hazard index from new permit units, relocations, or modifications to existing permit units, which emit toxic air contaminants. • Rule 2305: The Warehouse Indirect Source Rule requires owners and operators associated with warehouses 100,000 square feet or larger to directly reduce NOX and particulate matter emissions, or to otherwise facilitate emission and exposure reductions of these pollutants in nearby communities.

This would include, but not be limited to, the following:
• Proposed sensitive receptors and facilities that emit TACs would be evaluated for proximity to existing or planned TAC sources, including major roadways, dry-cleaning facilities, gasoline dispensing facilities, automotive repair facilities, commercial or drive-through facilities, and similar uses, using the screening distances identified in the CARB Air Quality and Land Use Handbook. • Sensitive receptors would include, but not be limited to, daycare centers, schools, hospitals, medical facilities, retirement homes, residential care facilities, and other land uses that may accommodate individuals who are particularly vulnerable to air quality–related health effects. • Where a proposed sensitive receptor or TAC-emitting facility is located within applicable CARB screening distances of a TAC source or sensitive receptor, discretionary land use review would require preparation of a Health Risk Assessment (HRA), or equivalent health risk evaluation, by a qualified air quality professional, consistent with CARB and applicable local air district guidance. • The results of an HRA would be used to inform land use planning and discretionary decision-making. Potentially significant health risks would be identified where an incremental cancer risk greater than 10 in one million or a chronic or acute hazard index greater than 1.0 is predicted. • Where potentially significant health risks are identified, land use planning and design strategies would be considered to reduce exposure, which may include, but are not limited to, revised site planning, increased separation distances, enhanced building design features (such as sealed ventilation systems with high-efficiency filtration), operational controls, or alternative siting of the sensitive receptor or TAC-emitting use.

4.3 Biological Resources
PPP BIO-1 Potential direct/indirect impacts to common and sensitive bird and raptor species will require compliance with the CFGC, Section 3503. Construction outside the nesting season (between September 16 and January 14) does not require pre-removal nesting bird surveys. If construction is proposed between January 15 and September 15, a qualified biologist must conduct a nesting bird survey(s) no more than 7 days prior to initiation of grading to document the presence or absence of nesting birds within or directly adjacent (100 feet) to the project site. The survey(s) will focus on identifying any raptors and/or bird nests that are directly or indirectly affected by construction activities. If active nests are documented, species-specific measures shall be prepared by a qualified biologist and implemented to prevent abandonment of the active nest. At a minimum, grading in the vicinity of a nest shall be postponed until the young birds have fledged. The perimeter of the nestsetback zone shall be fenced or adequately demarcated with stakes and flagging at 20-foot intervals, and construction personnel and activities restricted from the area. A survey report by a qualified biologist verifying that no active nests are present, or that the young have fledged, shall be submitted to the City of Brea for review and approval prior to initiation of grading in the nest-setback zone. The qualified biologist shall serve as a construction monitor during periods when construction activities occur near active nest areas to ensure that no inadvertent impacts on these nests occur. A final monitoring report of the findings, prepared by a qualified Mitigation Monitoring and Reporting Program
Mitigation Monitoring and Reporting Program 40 May 2026 Brea 2050: Focused General Plan Update and Brea Core Specific Plan Table 2. Plans, Programs, and Policies
biologist, shall be submitted to the City of Brea documenting compliance with the CFGC. Any nest permanently vacated for the season would not warrant protection pursuant to the CFGC.

PPP BIO-2 Development implemented under the Proposed Project will be subject to the BCC Chapter 20.74, Tree Preservation, and preserve and propagate the protected trees as defined therein.

PPP BIO-3 Development implemented under the Proposed Project is required to remove, plant, replace, and maintain street trees in accordance with the BCC Chapter

12.20, Street Trees.

4.4 Cultural Resources
PPP CUL-1 California Environmental Quality Act (CEQA) & Historical Resources: Pursuant to the CEQA Public Resources Code (PRC), Section 21084.1, any project that may cause a substantial adverse change in the significance of a historical resource is a project that may have a significant effect on the environment. PRC, Section 5020.1(q) defines a “substantial adverse change” as demolition, destruction, relocation, or alteration such that the significance of the historical resource would be materially impaired. Historical resources are defined as “a resource listed or eligible for listing on the California Register of Historical Resources” (CRHR) (Public Resources Code, Section 5024.1; 14 California Code of Regulations, Section 15064.5). Under CEQA Guidelines, Section 15064.5(a), the term “historical resources” includes the following:
• A resource listed in, or determined to be eligible by the State Historical Resources Commission, for listing in the California Register of Historical Resources (PRC, Section 5024.1). This is regarded as a “Mandatory Resource”. • A resource included in a local register of historical resources, as defined in PRC Section 5020.1(k) or identified as significant in a historical resource survey meeting the requirements of PRC Section 5024.1(g), will be presumed to be historically or culturally significant. Public agencies must treat any such resource as significant unless the preponderance of evidence demonstrates that it is not historically or culturally significant. This is regarded as a “Presumptive Resource.” • Any object, building, structure, site, area, place, record, or manuscript which a lead agency determines to be historically significant or significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, military, or cultural annals of California may be considered to be a historical resource, provided the lead agency’s determination is supported by substantial evidence in light of the whole record. This is regarded as a “Discretionary Resource.”
Generally, a resource shall be considered by the lead agency to be “historically significant” if the resource meets the criteria for listing on the California Register of Historical Resources (PRC Section 5024.1) including the following:

1. Is associated with events that have made a significant contribution to the broad patterns of California’s history and cultural heritage;

2. Is associated with the lives of persons important in California’s past;

3. Embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual, or possesses high artistic values; or
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4. Has yielded, or may be likely to yield, information important in prehistory or history.

4.5 Energy
PPP EN-1 New buildings are required to achieve the current California Building Energy Efficiency Standards (Title 24, Part 6) and California Green Building Standards Code (CALGreen) (Title 24, Part 11). The 2022 Building Energy Efficiency Standards were effective on January 1, 2023, and the 2025 Building Energy Efficiency Standards will become effective on January 1, 2026.

PPP EN-2 New buildings are required to adhere to the California Green Building Standards Code (CALGreen) requirement to provide bicycle parking for new nonresidential buildings, or meet local bicycle parking ordinances, whichever is stricter (CALGreen Sections 5.106.4.1, 14.106.4.1, and 5.106.4.1.2).

PPP EN-3 California’s Green Building Standards Code (CALGreen) requires the recycling and/or salvaging for reuse at a minimum of 65 percent of the nonhazardous construction and demolition waste generated during most “new construction” projects (CALGreen Sections 4.408 and 5.408). Construction contractors are required to submit a Construction Waste Management Plan that identifies the construction and demolition waste materials to be diverted from disposal by recycling, reuse on the project, or salvaged for future use or sale and the amount (by weight or volume).

4.7 Greenhouse Gas Emissions
PPP GHG-1 New buildings additions and alterations are required to comply with the California Building Energy Efficiency Code (Title 24, Part 6) and California Green Building Standards Code (CALGreen) (Title 24, Part 11) in effect at the time of permit application for plan check. The 2025 Building Energy Efficiency Code, California Energy Code, and the 2025 CALGreen became effective January 1, 2026.

Construction contractors are required to submit a construction waste management plan that identifies the construction and demolition waste materials to be diverted from disposal by recycling, reused on the project, or salvaged for future use or sale and the amount (by weight or volume).

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PPP GHG-6 Building Life Cycle Assessment: Effective July1, 2024, projects consisting of newly constructed building(s) with a combined floor area of 100,000 square feet or greater shall comply with either Section 5.409.2 or 5.409.3. Alteration(s) to existing building(s) where the combined altered floor area is 100,000 square feet or greater comply with either section 5.105.2, 5,409.2 or 5.409.3. Addition(s) to existing building(s) where the total floor area combined with the existing building(s) is 100,000 square feet or greater shall comply with either section 5.105.2, 5,409.2 or 5.409.3. Effective January 1, 2026, the combined floor area shall be 50,000 square feet or greater.

4.8 Hazards and Hazardous Materials
PPP HAZ-1 Transportation of Hazardous Waste. Hazardous materials and hazardous wastes will be transported to and/or from the project developed under the Focused General Plan Update and the Brea Core Specific Plan in compliance with applicable State and Federal requirements, including the U.S. Department of Transportation regulations listed in the Code of Federal Regulations (Title 49, Hazardous Materials Transportation Act); California Department of Transportation standards; and the California Occupational Safety and Health Administration standards.

PPP HAZ-3 Certified Unified Program Agency. Development under the Focused General Plan Update and the Brea Core Specific Plan will be designed and constructed in accordance with the regulations of the Orange County Health Care Agency Environmental Health Department (OCHCA-EHD), which serves as the designated Certified Unified Program Agency. OCHCA-EHD implements State and Federal regulations for the following programs: (1) Hazardous Waste Generator Program, (2) Hazardous Materials Release Response Plans and Inventory Program, (3) California Accidental Release Prevention, (4) Aboveground Storage Tank Program, and (5) Underground Storage Tank Program.

PPP HAZ-5 Asbestos-Containing Materials and Lead-Based Paints. Demolition activities that have the potential to expose construction workers and/or the public to asbestos-containing materials or lead-based paint are required to be conducted in accordance with applicable regulations, including, but not limited to:
• South Coast Air Quality Management District’s Rule 1403 • California Health and Safety Code (Section 39650 et seq.) • California Code of Regulations (Title 8, Section 1529) • California Occupational Safety and Health Administration regulations (California Code of Regulations, Title 8, Section 1529 [Asbestos] and Section 1532.1 [Lead]) • Code of Federal Regulations, Title 40, Part 61 (asbestos); Title 40, Part 763 (asbestos); and Title 29, Part 1926 (asbestos and lead) PPP HAZ-6 Removal of Hazardous Materials. The removal of hazardous materials, such as polychlorinated biphenyls (PCBs), mercury-containing light ballast, and mold, will be completed in accordance with applicable regulations pursuant to 40 Code of Federal Regulations (CFR) 761 (PCBs), 40 CFR 273 (mercury-containing light ballast), and 29 CFR 1926 (molds) by workers with the hazardous waste operations and emergency response training, as outlined in 29 CFR Section 1910.120 and 8 California Code of Regulations, Section 5192.

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PPP HAZ-7 Removal of Utility Lines and Pipelines. New construction, excavations, and/or new utility lines within 10 feet of or crossing existing high-pressure pipelines, natural gas/petroleum pipelines, or electrical lines greater than 60,000 volts will comply with the California Code of Regulations, Title 8, Section 1541.

PPP HAZ-8 Design and Safety. Development will comply with the requirements of the Brea City Code, Title 8, Health, Safety, and Welfare, and all applicable design and safety standards and regulations in the California Building Standards Code of Regulations Title 24. All construction documents shall be submitted for review to the Brea Building & Safety Division.

4.9 Hydrology and Water Quality
PPP HYD-1 Compliance with the following State, regional, and local regulations concerning grading, stormwater, and water quality control will be required. • National Pollutant Discharge Elimination System General Construction Permit. Notice of Intent and Storm Water Pollution Prevention Plan Requirements • State Water Resources Control Board General Industrial Activities Storm Water Permit • Santa Ana Regional Water Quality Control Board Waste Discharge Permits and Water Quality Certifications • Orange County Municipal Separate Storm Sewer Systems Permit • Orange County Model Water Quality Management Plan and Technical Guidance Document • Orange County Drainage Area Management Plan - New Development/ Significant Redevelopment Program • Orange County Hydrology Manual and 1996 Addendum
• Orange County Water District Groundwater Replenishment Program • County of Orange/Orange County Flood Control District Local Implementation Plan 2019 • City of Brea Master Plan of Drainage

4.11 Noise
PPP NOI-1 Residential development must comply with the California Building Code , Title 24, Part 2, Volume 1, Chapter 12, Interior Environment, Section 1207.11.2, Allowable Interior Noise Levels, and Section 1206.5 Acoustical Control. Residential and non-residential development must comply with the City’s land use compatibility limits as shown in Table 4.11-2, Noise/Land Use Compatibility. Before the issuance of a grading or construction permit for individual development projects that are not exempt from CEQA, and in conjunction with any required California Environmental Quality Act (CEQA) review, where development is proposed in an area where exterior noise would exceed the land use compatibility limits, the project applicants shall submit an Acoustical Study prepared by a certified acoustical engineer. Exterior noise may also be used to screen for potential interior noise impacts. The following screening levels may be applied to determine whether exterior noise would require preparation of an Acoustical Study:
• If existing roadways segments serving the project have an average daily traffic above 1,160, an Acoustical Study is required for new noise sensitive receptors. • If existing roadways segments serving the project have an average daily traffic of 1,800 or higher, an Acoustical Study is required for commercial uses.

The project applicant shall include design measures that may include acoustical paneling or walls, compliance with CBC Section 1206 and/or CALGreen Section 5.507.4 as applicable to ensure that interior noise levels do not exceed 45 dBA CNEL for residential uses. If it is necessary for windows to be able to remain closed to ensure that Mitigation Monitoring and Reporting Program
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interior noise levels meet the interior standard, the design for these land uses shall include ventilation with an air conditioning system to provide a habitable interior environment with the windows closed. Final construction documents shall incorporate special design measures in the construction of the land uses.

PPP NOI-3 Development projects will be constructed in accordance with Brea City Code (BCC) Section 8.20, Noise Control, of the BCC, which generally prohibits construction, repair, remodeling, or grading of any real property between the hours of 7:00 pm and 7:00 am on weekdays, including Saturday, or at any time on Sunday or a Federal holiday.

PPP NOI-5 Project vibration levels will comply with the City of Brea’s vibration standard of 0.003 in/sec root-mean-square (equivalent to 70 VdB) in Brea City Code Section

20.20.040.

PPP NOI-6 Residential development in mixed-use zones must comply with the noise-related operational standards in Brea City Code, Section 20.258.030.H:
• Residents, whether owners or tenants, of a mixed-use development project shall be notified in writing before taking up residence that they will be living in an urban type of environment and that the noise levels may be higher than a typical residential area. • The covenants, conditions, and restrictions of a mixed-use project shall require that the residents acknowledge their receipt of the written noise notification. Their signatures shall confirm receipt and understanding of this information. • The location and design of recycling and refuse storage facilities shall mitigate nuisances when residential uses might be impacted. • Residential dwelling units shall be designed to be sound attenuated against present and future project noise. New projects or new nonresidential uses in existing projects shall provide an acoustical analysis report, by an acoustical engineer, describing the acoustical design features of the structure required to satisfy the exterior and interior noise standards.

4.12 Public Services
PPP PS-1 Fire Regulations. New buildings developed under the Focused General Plan Update and the Brea Core Specific Plan are required to meet the fire regulations outlined in California Health and Safety Code (Sections 13000 et seq.).

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PPP PS-6 Fuel Modification Standards. All development under the Focused General Plan Update will be designed, built, and operated in accordance with the Brea Fire Department’s Very High Fire Hazard Severity Zone–Fuel Modification requirements, if applicable.

PPP PS-8 As part of the project review process, the Brea Police Department will recommend the following project design features to improve security on project sites. • Provide individual mailboxes rather than gang mailboxes to reduce mail theft vulnerability. • All common areas should be properly lit to increase surveillance and discourage unwanted activities. • All trail/park areas should include connectivity for potential future surveillance camera locations. • Provide the maximum amount of off-street.

PPP PS-9 The project applicant will consult with the Brea Police Department on street addressing and signage, particularly in high density areas.

PPP PS-10 The project applicant is required to pay dispatch impact fees and all other development impact and/or special assessment fees as deemed applicable by the City of Brea.

PPP PS-13 Park Development Fees. The project is required to comply with Brea City Code Section 18.64.080 that establishes the subdivision regulations for the provision of park and recreational facilities through land dedication, installation of improvements, payment of in-lieu fee thereof, or a combination. Where applicable, new development is required to fund park development and improvements through the payment of Park Development Fees.

4.13 Transportation
PPP TRA-1 Each project applicant in the City of Brea is required to pay development impact fees to the City of Brea pursuant to the City’s Assembly Bill 1600 Transportation Improvement Nexus Program (Ordinance 996). Based on a transportation improvement nexus program study conducted in 2011, the City Council adopted Resolution 2011- 096, which updated the impact fees, effective February 4, 2012. Fair-share fees offset or mitigate the cumulative traffic impacts caused by new development. The program ensures all future development in the City of Brea contributes on a fair-share basis.

The project applicant will be required to comply with the City-approved plan measures, including any specific regulations for construction activities and traffic control in the public right-of-way.

4.15 Utilities and Service Systems
PPP UTL-1 Development projects are required to comply with the following existing regulations as applicable. • California Energy Code (Title 24, Part 6) and California Green Building Standards Code (CALGreen) (Title 24, Part 11). • California Plumbing Code(Title 24, Part 5), a set of plumbing code requirements that establishes energy and water efficiency standards for new construction, additions, and alterations to existing buildings.

Mitigation Monitoring and Reporting Program
Mitigation Monitoring and Reporting Program 46 May 2026 Brea 2050: Focused General Plan Update and Brea Core Specific Plan Table 2. Plans, Programs, and Policies
• SB 610 (Chapter 643, Statutes of 2001) and SB 221 (Chapter 642, Statutes of 2001). • California Green Building Standards Code, Chapter 5, Nonresidential Mandatory Measures, Division 5.3, Water Efficiency and Conservation. • California Green Building Standards Code, Chapter 4, Residential Mandatory Measures, Division 4.3, Water Efficiency and Conservation. • Energy Efficiency Standards for Residential and Nonresidential Buildings (24 CCR Part 6) • California’s Appliance Efficiency Regulations (CCR Title 20, Parts 1600–1608) • Senate Bill 1383 (Short-Lived Climate Pollutant Reduction Strategy) and Assembly Bill (AB) 341/AB 1826 (commercial recycling/organics). • Orange County Municipal Separate Storm Sewer Systems Permit • Orange County Model Water Quality Management Plan and Technical Guidance Document • Orange County Drainage Area Management Plan. New Development/ Significant Redevelopment Program
• County of Orange/Orange County Flood Control District Local Implementation Plan PPP UTL-2 All new development projects are required to pay the City of Brea’s latest adopted Water Connections Fees, Water Impact Fees, Sewer Connection Fees, and Sewer Impact Fees, with the exception of:
• Alterations to an existing building;
• Reconstruction (within two years), when a building has been destroyed by fire, wind, earthquakes, vandalism, or other natural or man-made disasters; • Additions to a single-family or multiple-family residence; and • Construction of public schools.

ATTACHMENT B
RESOLUTION NO. 2026-XX

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF BREA

CERTIFYING A FINAL PROGRAM ENVIRONMENTAL IMPACT REPORT FOR THE BREA 2050: FOCUSED GENERAL PLAN UPDATE AND BREA CORE

SPECIFIC PLAN PROJECT AND ADOPTING CALIFORNIA

ENVIRONMENTAL QUALITY ACT FINDINGS OF FACT, STATEMENT OF

OVERRIDING CONSIDERATIONS, AND MITIGATION MONITORING AND

REPORTING PROGRAM REGARDING THE SAME
A. RECITALS:
(i) The City of Brea has prepared the Brea 2050: Focused General Plan Update, Brea Core Specific Plan, and implementing materials including: Program Environmental Impact Report (EIR) No. 2026-01, General Plan Amendment (GPA) No. 202601, Specific Plan (SP) No. 2026-01, Zoning Ordinance Text Amendment (ZOTA) 2026-01, and Zone Change (ZC) No. 2026-01. The proposed Project consists of the adoption and implementation of a Focused General Plan Update for the City and its Sphere of Influence (SOI), comprehensively updating the 2003 General Plan into six elements: Community Development, Community Resources, Public Safety, Mobility, Economic Development, and Housing. The Project also includes adoption of the Brea Core Specific Plan to implement the community vision established in the 2017 Brea Envisions initiative and goals and policies of the 2020 Brea Core Active Transportation Plan. Additionally, the Project includes amendments to the Zoning Code, Title 20 of the Brea City Code (BCC), to ensure consistency with the updated General Plan and Specific Plan, including reclassification of existing mixed-use zoning districts; updates to various chapters of the Zoning Code, specifically amending Chapters 20.04, 20.11, and

20.258; and zone changes to implement the proposed land use designations (collectively, the “Project”).

Resolution No. 2026-XX

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Brea City CouncilJune 2, 2026

Brea City Council
June 2, 2026