Agenda packet — Cypress City Council, July 14, 2026 (part 3 of 9)

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State Agencies
S-1 California Department of Toxic Substances Control (DTSC) March 26, 2026 S-2 California Department of Transportation (Caltrans), District 12 April 30, 2026 Regional Agencies
R-1 South Coast Air Quality Management District (SCAQMD) April 30, 2026 Local Agencies
L-1 Orange County Sanitation District (OC San) April 14, 2026 L-2 Orange County Public Works (OCPW) April 17, 2026
L-3 City of Los Alamitos April 20, 2026
L-4 City of Garden Grove April 30, 2026
Individuals
I-1 Ernesto Muñoz April 20, 2026
I-2 George Pardon April 26, 2026
I-3 Unidentified Commenter ([email protected]) April 29, 2026 I-4 Ernest and Cheryl Hanaoka April 30, 2026

1.2 FORMAT OF RESPONSES TO COMMENTS
The following pages provide responses to each coded comment letter. The comment code number is provided in the upper right corner of the comment letter, and individual comments within the letter are numbered along the right-hand margin of the letter. The City’s responses to the comment letter immediately follow each letter and are referenced by the index numbers in the margins.

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2.0 RESPONSES TO COMMENTS
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2.1 MASTER RESPONSES
Several comments received during the public review period raised similar concerns over the proposed project’s consistency with the Cypress Town Center and Commons Specific Plan 3.0 (Specific Plan) and suggested implementation of a reduced development alternative in order to reduce or eliminate transportation impacts associated with implementation of the proposed project. In addition, several comments suggested that the proposed project construct an east-west through connection along Vessels Circle to reduce or eliminate transportation impacts, provide additional opportunities for alternative modes of transportation, and create redundancies for fire, police, and medical services. Master responses to these concerns/comments are provided below and referenced, as applicable, in the following response sections.

2.1.1 SPECIFIC PLAN CONSISTENCY
On November 5, 2024, the voters of the City of Cypress approved the current Specific Plan (i.e., Cypress Town Center and Commons Specific Plan 3.0) pursuant to “Measure S” as part of the Cypress Housing Element Implementation Project (Housing Implementation Project). The current Specific Plan superseded and replaced the 2018 Specific Plan. Prior to the voters' approval of Measure S, the City Council certified a Final Environmental Impact Report (SCH No. 2023040560) for the Housing Element Implementation Project (Housing Element Implementation Final EIR) that analyzed the environmental impacts associated with adding 676 residential units within the Specific Plan Area beyond the maximum number of residential units permitted under the 2018 Specific Plan.

The 2018 Specific Plan permitted a maximum of 1,250 residential units, so the increase of 676 units now allows a maximum of 1,926 residential units within the Specific Plan Area (including the 135 residential units previously developed as part of the Melia Project). As provided in Chapter 3.0, Project Description, the proposed project consists of the reasonably foreseeable buildout of a portion of the area governed by the Specific Plan that includes approximately 134 acres of land (Buildout Area) in the city. The proposed project also includes the approval of Vesting Tentative Tract Map No. 19247 (VTTM 19247).

The Draft EIR analyzed buildout of the Specific Plan within the Buildout Area at a “programmatic” level. According to State CEQA Guidelines Section 15168, a Program EIR may be prepared for a series of actions that are related geographically, as logical parts in a chain of contemplated actions, or in connection with the issuance of plans that govern the conduct of a continuing program (per Section 15168(a) of the State CEQA Guidelines). The Draft EIR evaluates environmental impacts at a programmatic level, based on the overall buildout scenario under the proposed project.

Development within the Buildout Area would occur on a project-by-project basis and the specific design and sequencing of those projects cannot be determined at this time.

The primary concern raised in comments related to the proposed project’s consistency with the Specific Plan is whether the proposed project would provide pedestrian and bicycle trails as contemplated in the Specific Plan. The Draft EIR addresses access and circulation (including pedestrian and bicycle) of the Buildout Area in several places as noted below.

As shown in Figure 3-5: Vesting Tentative Tract Map No. 19247, of the Draft EIR, the proposed project evaluated in the Draft EIR assumes the extension of Moody Street from Cerritos Avenue to S PECIFIC PLAN 3.0 B UILDOUT P ROJECT

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As discussed in Section 4.17, Transportation, of the Draft EIR, implementation of the proposed project would provide sidewalks along the project frontages and throughout the Buildout Area that would provide connections to existing pedestrian and bicycle facilities in the surrounding area.

Specifically, as discussed in Section 4.17 of the Draft EIR, the proposed project would include the addition of approximately 1 mile of bicycle facilities, connecting to the existing bicycle network. In addition, pedestrian access via sidewalks to the Buildout Area would be from Katella Avenue, Cerritos Avenue, Lexington Drive, and Vessels Circle, as extended. Additional pedestrian circulation improvements include sidewalks along the extension of Moody Street south of Cerritos Avenue.

These pathways, together with the existing pedestrian infrastructure on the surrounding streets, would ensure seamless integration with the broader pedestrian network consistent with the Specific Plan requirements. Additionally, as detailed in Mitigation Measure TRA-1, the proposed project would be required to implement feasible Transportation Demand Management (TDM) strategies to mitigate the proposed project’s Vehicle Miles Traveled (VMT) impact, which include constructing or improving bicycle facilities that would connect the proposed project to the existing regional bicycle network and improving the pedestrian network, including the construction of off-site sidewalks to improve sidewalk coverage and pedestrian access to the surrounding area.

In addition, as discussed in Chapter 3.0, future development within the Buildout Area may require the construction of private driveways, accessways and/or additional streets that would connect to the Moody Street and Vessels Circle extensions and existing public streets adjacent to the Buildout Area. However, because the proposed project is analyzed in the Draft EIR at the programmatic level and the specific future projects associated with implementation of the proposed project, including the specific accessways and internal roadway network beyond the main “backbone” roadways shown on Figure 3-5 of the Draft EIR, the specific locations and sizes cannot be determined at this time and would be determined during the design process of future development projects proposed within the Buildout Area.

Existing development in the Specific Plan area has incorporated dedicated pedestrian and bicycle trails, as contemplated by the Specific Plan, accented with new landscaping throughout the development and provides a connection to future pedestrian and bicycle trails developed on surrounding lots.

Future development projects associated with implementation of the proposed project would also be reviewed by the City on a project-by-project basis in order to ensure that the proposed development is consistent with the Specific Plan. Specifically, through the design review process,

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The proposed project would facilitate the implementation of the Specific Plan, and future development projects associated with implementation of the proposed project are required to submit a detailed site plan as part of the site plan review process that depicts the pedestrian pathways and bicycle trails that would be included in each development, consistent with the Specific Plan; therefore, the proposed project is considered consistent with the Specific Plan. However, it should be noted that although the Specific Plan includes the provision of pedestrian and bicycle trails within the Buildout Area, it does not require that these trails be public or dedicated to the City.

The Specific Plan requirements relate to providing pedestrian and bicycle trails may also be satisfied by providing private pedestrian and bicycle trails for use by residents that would connect to the City’s public pedestrian and bicycle network in the surrounding area.

2.1.2 REDUCED DEVELOPMENT ALTERNATIVE (30% REDUCTION)
Several comments received during the public review period suggested implementation of a reduced development alternative would reduce or eliminate transportation impacts associated with implementation of the proposed project, particularly VMT impacts. VMT measures the amount of driving a project is expected to generate compared to the regional average. It looks at the average number of miles people travel each day for activities like commuting, shopping, and errands. Under CEQA, VMT is used to evaluate a project’s impact on air quality and greenhouse gas emissions, since more travel generally results in more pollution. In addition, transportation impacts under CEQA are now evaluated based on a project’s effect on VMT as opposed to vehicle delay and Level of Service (LOS). This change came into effect on December 28, 2018, when the California Office of Administrative Law cleared the revised State CEQA Guidelines for use and removed vehicle delay and LOS from consideration under CEQA. In general, projects located near jobs, shops, and public transit tend to have lower VMT, while those in more auto-dependent areas tend to have higher VMT. Importantly, VMT does not measure traffic congestion or roadway conditions. It focuses on how far people travel, not how traffic flows, and is typically associated with a project’s location, not its density or scale.

As discussed in Section 4.17, Transportation, of the Draft EIR, the residential component of the proposed project would exceed the County's residential VMT significance thresholds under both existing and cumulative plus project conditions by 11.6 percent. As such, the proposed project would be required to implement feasible TDM strategies to mitigate the proposed project’s VMT impact, as detailed in Mitigation Measure TRA-1. However, implementation of Mitigation Measure TRA-1, which includes all feasible TDM strategies, would only reduce the proposed project’s residential VMT impact by 1.2 percent. As such, even with implementation of the identified TDM strategies, the proposed project’s residential VMT impact would remain significant, with a residential VMT impact of 10.4 percent over the significance threshold. Therefore, the proposed project’s VMT impact would be significant and unavoidable, as identified in the Draft EIR.

Chapter 5.0, Alternatives, of the Draft EIR, included a discussion of three alternatives that could feasibly attain most of the basic objectives of the proposed project but that may avoid or S PECIFIC PLAN 3.0 B UILDOUT P ROJECT

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2 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\8_Final EIR and RTC\Specific Plan 3.0 Buildout Project_Final EIR RTC_fnl.docx «06/19/26» -6 substantially lessen any of the significant impacts of the proposed project, including the Reduced Development Alternative (30% Reduction). As provided in Chapter 5.0, the Reduced Development Alternative would facilitate the future development of 1,253 residential units and approximately 308,000 square feet of non-residential uses. This represents a decrease of 538 residential units and a decrease of approximately 132,000 square feet of non-residential uses as compared to the proposed project. An analysis of the potential environmental impacts of this alternative across all environmental issue areas was included in the Draft EIR and compared to the environmental impacts associated with the proposed project. The Draft EIR included a qualitative analysis of the VMT impacts of the reduced-density alternative. The results of the alternatives analysis determined that, while implementation of the Reduced Development Alternative would generally reduce or be similar to the proposed project’s impacts, impacts on air quality, cultural (historical) resources, and transportation (VMT) would continue to be significant and unavoidable.

Since preparation of the Draft EIR, a quantitative VMT assessment for the Reduced Development Alternative was conducted by Kimley-Horn and Associates, Inc. in order to further substantiate the alternative’s significant and unavoidable VMT impact determination. To calculate VMT for the Reduced Development Alternative, Orange County Transportation Analysis Model (OCTAM), Version

5.1 (OCTAM) was run for the cumulative plus alternative (2050) scenario, and calculations from the relevant OCTAM output files were completed to estimate the anticipated Home-Based VMT (for residential VMT) and Total Countywide VMT (for non-residential VMT) for the alternative’s Transportation Analysis Zone (TAZ). The City's threshold of significance for a project's VMT impact with respect to residential uses, based on the County Guidelines, is 13.21 VMT per capita (15 percent below the existing regional average). For non-residential uses, VMT is evaluated using a total VMT metric. Under this methodology, the project’s non-residential uses would result in a significant transportation impact if it would cause a net increase in total VMT greater than 0. Table B: Residential VMT Impacts Comparison, and Table C: Non-Residential VMT Impacts Comparison, below, provide a summary of the VMT analysis prepared for the Reduced Development Alternative and compares it to the proposed project’s VMT impacts.

Table B: Residential VMT Impacts Comparison
Analysis Scenario Proposed Project
Home-Based VMT/Capita
Reduced Development Alternative
Home-Based VMT/Capita
Significance Threshold
(15% Below Existing Regional Average) 13.21 13.21
Cumulative Plus Project (2050) 14.96 14.50
VMT in Excess of Significance Threshold 1.73 1.28
VMT % In Excess of Threshold 11.6% 8.8%
VMT % In Excess of Threshold (With
Mitigation) 10.4% 7.6%
Source: Kimley-Horn and Associates, Inc. (2026).

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Analysis Scenario Proposed Project
Total Countywide VMT
Reduced Development Alternative
Total Countywide VMT
Significance Threshold
(Net Increase in Total VMT) > 0 >0
Cumulative Plus Project (2050) Without
Retail 157,660,001 157,584,513
Cumulative Plus Project (2050) With
Retail 157,643,286 157,553,522
Net Change in VMT With Retail (2050) -16,715 -30,991
Source: Kimley-Horn and Associates, Inc. (2026).

As shown in Table C, the Reduced Development Alternative’s non-residential VMT would be below the County’s significance threshold for non-residential uses, resulting in a less than significant nonresidential VMT impact, similar to the proposed project. However, because the Reduced Development Alternative would exceed the residential significance threshold even with implementation of the same mitigation as the proposed project, as shown in Table B, the Reduced Development Alternative’s residential component would result in a significant and unavoidable VMT impact, similar to the proposed project. As such, transportation (VMT) impacts associated with the Reduced Development Alternative would continue to be significant and unavoidable. As such, implementation of a reduced development alternative, as suggested by several commenters, would not actually reduce or eliminate transportation impacts associated with implementation of the proposed project, particularly VMT impacts.

In addition, implementation of the Reduced Development Alternative would not meet the project objectives to the same extent as the proposed project. Specifically, while the Reduced Development Alternative would facilitate development of 1,253 residential units within the Buildout Area, which would help meet the significant unmet demand for housing in the city and the project vicinity, the Reduced Development Alternative would result in 538 fewer residential units than the proposed project. As such, the Reduced Development Alternative would not satisfy project objectives related to providing much need housing in the city to the same extent as the proposed project. Further, the Reduced Development Alternative would not develop the Buildout Area consistent with the City’s Housing Element and the voter-approved Specific Plan as it would not develop the site with 1,791 residential units and up to 440,000 square feet of non-residential development.

2.1.3 VESSELS CIRCLE THROUGH CONNECTION
Several comments received during the public review period questioned why Vessels Circle is not proposed to extend through the Buildout Area to terminate at Lexington Drive, providing an eastwest through connection. These comments suggested that this through connection would improve traffic flow, avoid the proposed project’s significant and unavoidable VMT impact, provide opportunities for alternative modes of transportation (pedestrian and bike mobility), and improve potential public health, safety, and welfare concerns.

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2 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\8_Final EIR and RTC\Specific Plan 3.0 Buildout Project_Final EIR RTC_fnl.docx «06/19/26» -8 The proposed project consists of the reasonably foreseeable buildout of the voter-approved Specific Plan, which did not include the provision of an east-west through connection through the Buildout Area. As provided in Chapter 3.0, Project Description, of the Draft EIR, the proposed project evaluated in the Draft EIR assumes the extension of Moody Street from Cerritos Avenue to Katella Avenue, as well as the extension of Vessels Circle from its current western terminus to intersect with the Moody Street extension, consistent with the voter-approved Specific Plan. The Moody Street extension would traverse the Buildout Area, passing adjacent to Lots 3, 4, 13, and 14 in VTTM 19247, and create a central north-south corridor, while the extension of Vessels Circle within Lot C would, among other things, provide access to Lots 10 and 11 in VTTM 19247. Accordingly, the Vessels Circle extension is proposed to result in a new terminus at Moody Street and would not create an east-west through connection from Moody Street to Lexington Drive through the Buildout Area. This proposal is consistent with the “backbone” circulation network provided in the Specific Plan.

As discussed above, VMT measures the amount of driving a project is expected to generate compared to the regional average and looks at the average number of miles people travel each day for activities like commuting, shopping, and errands. In general, projects located near jobs, shops, and public transit tend to have lower VMT, while those in more auto-dependent areas tend to have higher VMT. Importantly, VMT does not measure traffic congestion or roadway conditions. It focuses on how far people travel, not how traffic flows. While construction of an east-west Vessels Circle through connection to Lexington Drive would nominally reduce VMT associated with vehicles traveling east and west of the Buildout Area as vehicles would not have to drive around the Buildout Area, based on existing peak hour traffic volumes taken for the Lexington Drive/Cerritos Avenue, Lexington Drive/Katella Avenue, Walker Street/Katella Avenue, and Walker Street/Cerritos Avenue intersections, there is little demand for vehicle trips traveling east and west through the Buildout Area and most vehicles are traveling to and from farther locations. Accordingly, the minor reduction in VMT associated with vehicles traveling east and west of the Buildout Area would not result in any meaningful VMT reduction associated with buildout of the proposed project and would not change the overall VMT conclusions presented in the VMT Memo and Draft EIR. Therefore, because a Vessels Circle east-west through connection to Lexington Drive would not substantially reduce the distance people are traveling to and from the Buildout Area, modifying the proposed project to include a Vessels Circle east-west through connection to Lexington Drive would not reduce or avoid the proposed project’s significant and unavoidable VMT impact. This proposal also was not contemplated in the Specific Plan and construction of a new east-west connection would not be permitted under the existing Specific Plan. An amendment to the Specific Plan would be required, which necessitates another voter-approval, similar to the Measure S approval process.

In addition, as previously discussed, because the proposed project is analyzed in the Draft EIR at the programmatic level, the specific future projects associated with implementation of the proposed project, including the specific accessways and internal roadway network beyond the main “backbone” roadways shown on Figure 3-5 of the Draft EIR, cannot be determined at this time.

Future development projects associated with implementation of the proposed project would be reviewed by the City on a project-by-project basis in order to ensure that the proposed development is consistent with the Specific Plan. Specifically, through the design review process, future development projects would be required to submit a detailed site plan that depicts the

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Further, as discussed in Section 4.17, Transportation, of the Draft EIR, implementation of the proposed project would provide sidewalks along the project frontages and throughout the Buildout Area that would provide connections to existing pedestrian and bicycle facilities in the surrounding area. Specifically, as discussed in Section 4.17 of the Draft EIR, the proposed project is assumed to include the addition of approximately 1 mile of bicycle facilities, connecting to the existing bicycle network. In addition, pedestrian access via sidewalks to the Buildout Area would be from Katella Avenue, Cerritos Avenue, Lexington Drive, and Vessels Circle, as extended. Additional pedestrian circulation improvements include sidewalks along the extension of Moody Street south of Cerritos Avenue. These pathways, together with the existing pedestrian infrastructure on the surrounding streets, would ensure seamless integration with the broader pedestrian network, effectively linking the Buildout Area with nearby amenities and transit options.

Additionally, as detailed in Mitigation Measure TRA-1, the proposed project would be required to implement feasible TDM strategies to mitigate the proposed project’s VMT impact, which include constructing or improving bicycle facilities that would connect the proposed project to the existing regional bicycle network and improving the pedestrian network, including the construction of offsite sidewalks to improve sidewalk coverage and pedestrian access to the surrounding area. All future development facilitated by the proposed project would be required to comply with the requirements of Mitigation Measure TRA-1 related to providing and improving bicycle and pedestrian facilities, as well as City policies regarding bicycle parking and other infrastructure. In addition, the proposed project would not include features that would disrupt existing or planned bicycle or pedestrian facilities. Therefore, the proposed project would improve pedestrian and bicycle mobility in the Buildout Area and in the surrounding area and would help further the City’s goals of promoting alternative transportation.

As discussed in Section 4.15, Public Services, of the Draft EIR, based on communication with the Orange County Fire Authority (OCFA) and Cypress Police Department (CPD), implementation of the proposed project would not result in any significant impacts related to fire, police protection, or emergency services. In addition, all future projects implemented in accordance with the proposed project would be required to adhere to all OCFA and CPD requirements, including providing adequate fire flow/structure protection to the properties, hydrants spaced to meet the minimums identified in the fire code, and providing adequate access for emergency vehicles.

Further, all future development projects would be required to obtain City approval of building plans prior to issuance of building permits and would be required to demonstrate during the development review process that law enforcement providers would be able to provide adequate police protection services. In addition, through the City budgetary process a portion of development impact fees would be directed to the CPD, as deemed necessary. The development impact fees have been adopted by the City and are updated periodically following the preparation of a nexus study to confirm that the impact fees are in alignment with the costs required to complete new capital improvements to serve the new development. Future development would also be required to S PECIFIC PLAN 3.0 B UILDOUT P ROJECT

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Overall, implementation of the proposed project, which does not currently include an east-west Vessels Circle through connection to Lexington Drive, would be consistent with City goals related to encouraging alternative modes of transportation and improving pedestrian and bicycle connections, and does not result in any potentially significant impacts related to public health, safety and welfare.

In addition, the provision of an east-west Vessels Circle through connection to Lexington Drive would not reduce the proposed project’s significant and unavoidable VMT impact.

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2.2 STATE AGENCIES
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SENT VIA ELECTRONIC MAIL
March 26, 2026
Alicia Velasco
Planning Director
City of Cypress
5275 Orange Avenue
Cypress, CA 90630
[email protected]
RE: DRAFT ENVIRONMENTAL IMPACT REPORT FOR THE SPECIFIC PLAN 3.0 BUILDOUT PROJECTDATED MARCH 17, 2026, STATE CLEARINGHOUSE NUMBER 2025040377
Dear Alicia Velasco,
The Department of Toxic Substances Control (DTSC) reviewed the Draft Environmental Impact Report (DEIR) for the Specific Plan 3.0 Buildout Project (Project). The proposed Project consists of the reasonably foreseeable buildout of a portion of the area governed by the Cypress Town Center and Commons Specific Plan 3.0 (Specific Plan) that includes approximately 134 acres of land in the city. The proposed Project includes the approval of Vesting Tentative Tract Map No. 19247 which includes lots with a total land area of approximately 151.6 acres. The proposed Project evaluated in this Draft EIR includes 1,791 residential units and 440,000 square feet of non-residential uses that could occur within the Buildout Area.

According to the Phase I Environmental Site Assessment conducted by Partner Engineering and Science, Inc. (Partner), Historical Recognized Environmental Conditions, Controlled Recognized Environmental Conditions, and Business Environmental Risks were detected on the Project site and Partner recommended that Comment Letter S-1
S-1-1
S-1-2
Alicia Velasco
March 26, 2026

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an Operation and Maintenance (O&M) Program should be implemented.

DTSC recommends and requests consideration of the following comments

1. Since the proposed Project includes residential development, DTSC recommends that the City of Cypress enter into a voluntary agreement to address any existing contamination on the property or receive oversight from a self-certified local agency, DTSC, or the Regional Water Quality Control Board. If entering into one of DTSC’s voluntary agreements, please note DTSC uses a single standard Request for Lead Agency Oversight Application for all agreement types. Please apply for DTSC oversight using this link: Request for Agency Oversight Application. Submittal of the online application includes an agreement to pay costs incurred during agreement preparation. If you have any questions about the application portal, please contact the relevant Regional Brownfield Coordinator for your Project.

2. DTSC recommends all imported soil/fill material be tested to ensure all COCs meet screening levels as outlined in DTSC's Preliminary Endangerment Assessment Guidance Manual. Furthermore, DTSC advises referencing the DTSC Information Advisory Clean Imported Fill Material Fact Sheet if importing soil/fill is necessary. To minimize the possibility of introducing contaminated soil/fill material, there should be documentation of the origins of the soil/fill material and, if applicable, sampling be conducted to ensure that the imported soil/fill material is suitable for the intended land use. The sampling should include analysis based on the source of the soil/fill and knowledge of prior land use.

DTSC appreciates the opportunity to comment on the DEIR for the Specific Plan 3.0 Buildout Project. Thank you for your assistance in protecting California’s people and environment from the harmful effects of toxic substances. If you have any questions or would like clarification on DTSC’s comments, please respond to this letter or via email for additional guidance.

S-1-2 cont.

S-1-3
S-1-4
S-1-5
Alicia Velasco
March 26, 2026

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Sincerely,
Tamara Purvis
Associate Environmental Planner
HWMP - Permitting Division – CEQA Unit
Department of Toxic Substances Control
[email protected]
cc: (via email)
Governor’s Office of Land Use and Climate Innovation
State Clearinghouse
[email protected]
Los Alamitos Race Course
Project Applicant
[email protected]
Ryan Bensley
Principal / Consultant
LSA Associates, Inc. / Consulting Firm
[email protected]
Dave Kereazis
Associate Environmental Planner
HWMP-Permitting Division – CEQA Unit
Department of Toxic Substances Control
[email protected]
Scott Wiley
Analyst II
HWMP - Permitting Division – CEQA Unit
Department of Toxic Substances Control
[email protected]
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2.2.1 CALIFORNIA DEPARTMENT OF TOXIC SUBSTANCES CONTROL (DTSC) Letter Code: S-1
Date: March 26, 2026
Response to Comment S-1-1
This comment provides introductory remarks and summarizes the proposed project.

The City acknowledges this comment. Because the comment does not contain any substantive comments or questions about the environmental analysis or conclusions contained in the Draft EIR, no further response is required.

Response to Comment S-1-2
This comment summarizes the conclusions and recommendations provided in the Phase I Environmental Site Assessment (ESA) prepared for the proposed project. Specifically, this comment states that the Phase I ESA identified historical recognized environmental conditions (HREC), controlled recognized environmental conditions (CREC), and business environmental risks (BER) within the Buildout Area and recommends an Operation and Maintenance (O&M) Program be implemented.

The results of the Phase I ESA prepared for the proposed project were summarized and discussed in Section 4.9, Hazards and Hazardous Materials, of the Draft EIR. In addition, as provided in Section

4.9, future development facilitated by the proposed project would be required to implement Mitigation Measure HAZ-1. Mitigation Measure HAZ-1 requires implementation of the recommendations provided in the Phase I ESA, including preparation and implementation of an O&M Plan to safely manage the asbestos containing materials (ACMs) and lead based paint (LBP) associated with the existing buildings within the Buildout Area. Mitigation Measure HAZ-1 also requires providing a copy of the Draft EIR to the Orange County Health Care Agency (OCHCA) to notify them of the proposed change in land use facilitated by the proposed project. As such, the proposed project would implement the recommendations provided in the Phase I ESA.

Response to Comment S-1-3
This comment recommends that, because the proposed project includes residential uses, the City enter into a voluntary agreement to address any existing contamination within the Buildout Area or receive oversight from a self-certified local agency, DTSC, or the Regional Water Quality Control Board (RWQCB).

As discussed above and in Section 4.9, Hazards and Hazardous Materials, of the Draft EIR, the Phase I ESA identified the presence of a CREC, a HREC, and a BER in association with the Buildout Area. The identified HREC was associated with a 2,000-gallon, two-compartment underground storage tank (UST) used for gasoline and diesel fuel located in the former golf course maintenance area near Lexington Drive, which was removed in March 2004. Due to the removal of the UST, regulatory oversight and closure, limited impacts below risk thresholds, and subsequent redevelopment of the site, the former UST is considered an HREC and no longer presents a hazardous environmental condition associated with the Buildout Area. The potential BER is associated with the age of the S PECIFIC PLAN 3.0 B UILDOUT P ROJECT

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2 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\8_Final EIR and RTC\Specific Plan 3.0 Buildout Project_Final EIR RTC_fnl.docx «06/19/26» -18 buildings on site, which may include ACMs or LBP. The identified CREC was related to the historical removal of four USTs—two 10,000-gallon, one 2,000-gallon, and one 1,000-gallon—that had been used to store gasoline and diesel for maintenance vehicles. These tanks were removed in 1988 under the oversight of the OCHCA. By 1996, OCHCA granted regulatory case closure, confirming that remaining contamination levels were below thresholds of concern. The closure requires notification of OCHCA if a change in land use is proposed.

The Draft EIR prescribed Mitigation Measure HAZ-1, requires implementation of the recommendations provided in the Phase I ESA, including preparation and implementation of an O&M Plan to safely manage the suspect ACMs and LBP associated with the existing buildings within the Buildout Area and the notification of the OCHCA as required in the case closure summary from 1996 for the CREC due to the proposed project’s change in land use. In compliance with Mitigation Measure HAZ-1, a copy of the Draft EIR and the NOC was provided to OCHCA as part of the public review process. The implementation of the recommendations provided in the Phase I ESA, as required by Mitigation Measure HAZ-1, would reduce potential impacts associated with the release of hazardous materials into the environment through reasonably foreseeable upset and accident conditions to less than significant. In addition, no active recognized environmental conditions (REC) were identified within the Buildout Area, and no additional subsurface investigations were recommended. The City has not received any correspondence from OCHCA in response to the NOP and Draft EIR.

Although there is no evidence of existing contamination within the Buildout Area that would create a significant hazard to the public or the environment based on the results of the Phase I ESA, the City will consider entering into a voluntary agreement with a self-certified local agency, DTSC, or the RWQCB as part of the development process.

Response to Comment S-1-4
This comment recommends that all imported soil/fill material be tested to ensure all chemicals of concern (COCs) meet screening levels as outlined in DTSC's Preliminary Endangerment Assessment Guidance Manual. This comment also advises referencing the DTSC Information Advisory Clean Imported Fill Material Fact Sheet if importing soil/fill is necessary, documenting of the origins of the soil/fill material, and, if applicable, conducting sampling to ensure that the imported soil/fill material is suitable for the intended land use.

Development within the Buildout Area facilitated by the proposed project would occur on a projectby-project basis and the specific design and sequencing of those projects cannot be determined at this time. Future construction would include grading and excavation activities that could require the import of soil/fill material. Consistent with DTSC’s guidance, future development under the proposed project would be required to test all imported soil and fill material or source soil and fill material from a provider that is able to certify that the soil has been tested and meets established safety standards in order to minimize the possibility of introducing contaminated soil and fill material to the project site, consistent with standard construction practices.

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This comment provides concluding remarks and contact information.

The City acknowledges this comment and looks forward to future communications with DTSC regarding development of the proposed project.

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“Improving lives and communities through transportation.” DISTRICT 12
1750 East 4th Street, Suite 100 | SANTA ANA, CA 92705
(657) 328-6000 | FAX (657) 328-6522 TTY 711
https://dot.ca.gov/caltrans-near-me/district-12
April 30, 2026
Ms. Alicia Velasco
Planning Director
City of Cypress
5275 Orange Avenue
Cypress, California 90630
File: LDR/CEQA
SCH: 2025040377
12-ORA-2025-03062
I-605, PM R1.441
I-405, PM 20.812
SR 22, PM R1.104
SR 39, PM 11.211
Dear Ms. Velasco,
Thank you for including the California Department of Transportation (Caltrans) in the review of the Draft Environmental Impact Report (DEIR) for the Specific Plan

3.0 Buildout Project (Project). The proposed Project includes the approval of Vesting Tentative Tract Map No. 19247 (VTTM 19247). The land subject to VTTM 19247 is greater than the Specific Plan Area because VTTM 19247 includes Lots 8 and 9, which are part of the existing Grace Church property and include approximately 17.55 acres of land located outside the area governed by the Specific Plan. The environmental analyses in this DEIR do not consider future development of Lots 8 and 9. The development scenario evaluated in the DEIR will include 1,791 residential units and 480,000 square feet of non-residential uses.

VTTM 19247 includes 14 numbered lots. The proposed project includes residential development on Lots 2 through 4, 7, and 10 through 14, non-residential development on Lots 10 through 14, and the development of park and recreational improvements on Lots 1, 5 and 6.

Regional vehicular access to the Project area is provided by Interstates (I-) 605 and I-405, which are approximately 1.5 miles to the west and 2.1 miles to the south, respectively; State Route (SR) 39, approximately 2.7 miles to the east; and SR 22, approximately 2 miles to the south. I-605, I-405, SR 39, and SR 22 are under the ownership and operation of Caltrans, which acts as a commenting agency for this project. Accordingly, Caltrans has provided the following feedback:

Comment Letter S-2
S-2-1
S-2-2
City of Cypress
April 30, 2026

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“Improving lives and communities through transportation.”

1. On May 5th, 2025, the Caltrans District 12 Branch of Local Development Review (LDR)-Climate Change-Transit Planning submitted a letter to City of Cypress that included the following comment: “Analysis and discussion of the 95% vehicle queue is being requested. This is due to the additional trips on the off-ramp(s) that lead to the site and/or left-turn lane to onramp that came from the site at Valley View Street interchange. If there is an overflow to the adjacent lane(s), there is a potential cause of safety concerns.” The comment is not included in Table 2.A (Notice of Preparation Agency Comments Received) of the DEIR. Please revise the table to include the comment. In addition, to ensure that any potential safety concern is addressed, please address the comment.

2. Analysis and discussion of the 95% vehicle queue is being requested. This is due to the additional trips on the I-605 off-ramp(s) that lead to the site and/or right and left-turn lanes to on-ramp that came from the site at Katella Ave and W Cerritos Ave. If there is an overflow to the adjacent lane(s), there is a potential cause of safety concerns.

3. The Traffic Study for: Cypress Specific Plan 3.0 Buildout indicates that the Project would generate approximately 21,041 vehicle trips daily, with 1,019 trips in the morning peak hour and 1,418 trips in the evening peak hours. In addition, figure 6A and 6B shows the percentage of traffic distribution direction toward state facilities. For I-605 and Cerritos ramps, I-605 and Katella Ramps, and SR 22 and Valley View Street Ramps, please demonstrate whether the project-related traffic effect is considered deficient or not under the Highway Capacity Manual (HCM) methodology and per Caltrans Guidelines.

4. Please ensure that Caltrans is informed of any subsequent bids or future phases of development associated with this Specific Plan.

5. Caltrans supports local developments that are consistent with State planning priorities intended to promote equity, strengthen the economy, protect the environment, and promote public and health safety. This can be achieved by promoting smart growth principles in projects which provide a diversity of housing choices and destinations accessible by active transportation (i.e. bicycle and pedestrian) and transit users.

S-2-3
S-2-4
S-2-5
S-2-6
S-2-7
City of Cypress
April 30, 2026

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“Improving lives and communities through transportation.”

6. Caltrans recommends outlining the expected number of units that will be made affordable and the income levels of the affordable units in support of the final 2014-2021 Regional Housing Needs Assessment (RHNA) adopted by Southern California Association of Governments (SCAG), which identified the 2021-2029 future housing need for City of Cypress as 3,936 units, including 1,807 lower-income units.

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

8. Caltrans supports measures to unbundle residential parking costs from property costs to decrease vehicle ownership and incentivize the use of public transit, resulting in a reduction of Vehicle Miles Traveled (VMT) and GHG emissions. For additional guidance, please refer to CAPCOA Handbook Strategy T-16.

9. Caltrans encourages the design of Complete Streets that include highquality pedestrian, bicycle, and transit facilities that are safe and comfortable for users of all ages and abilities. Improvements may include providing secure bicycle parking, pedestrian-oriented LED lighting, wayfinding signage, and comfortable connections to nearby active transportation and/or transit facilities. Complete Streets improvements also promote regional connectivity, improve air quality, reduce congestion, promote improved first-/last-mile connections, and increase safety for all modes of transportation. Continue to incorporate Complete Streets in project development.

10. The project is adjacent or close to several existing bike facilities: Class I bike lanes on Walker Street; Class II bike lanes on Moody Street and Walker Street; and Class III bike lanes on Cerritos Avenue. Caltrans S-2-8
S-2-9
S-2-10
S-2-11
S-2-12
City of Cypress
April 30, 2026

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“Improving lives and communities through transportation.” therefore recommends the inclusion of secure and functional short-term bike parking. Short-term bike parking at public locations should be placed in visible areas that are close to main destinations and should be installed at least 24” away from walls and other objects (e.g. trash cans, plants, etc.). With the increasing popularity of electric bikes and cargo/utility bikes, bike parking should also be designed to accommodate different styles, sizes, and weights of bikes (e.g. cargo bike, bike with trailer, adult tricycle, etc.). For additional guidance on bicycle parking best practices, see the “Essentials of Bike Parking” guidance created by the Association of Pedestrian and Bicycle Professionals (link to online PDF:
https://www.apbp.org/Publications).

11.During construction, please ensure that appropriate detours and safety measures are in place that prioritize mobility, access, and safety for all modes of transportation, including bicyclists, pedestrians, and transit users.

12.Orange County Transportation Authority (OCTA) Route 50 runs along Katella Avenue and currently has existing bus stops near Lexington Drive, Siboney Street, Winners Circle, and Walker Street in the vicinity of the Buildout Area. Route 50 provides transportation to/from the Cities of Orange and Long Beach via Katella Avenue. OCTA Route 123 runs along Valley View Street. Caltrans encourages collaboration with OCTA to increase transit frequency to reduce waiting and overall travel times, which improves the user experience and increases the attractiveness of transit service. This results in a mode shift from single occupancy vehicles to transit, which reduces VMT and associated Greenhouse Gas (GHG) emissions. For additional guidance, please refer to the California Air Pollution Control Officers Association (CAPCOA) Handbook Strategy T-26.

13.Please consider providing improvements to the nearest bus stops in each direction, such as bus shelters and other amenities. The developer could also consider adopting nearby bus stops for ongoing cleaning and maintenance to make it safer and more comfortable to ride transit. For additional guidance, please refer to CAPCOA Handbook Strategy T-46.

14.Please consider providing transit subsidies to residents as an incentive to increase transit ridership, resulting in a reduction of VMT and GHG S-2-12
cont.

S-2-13
S-2-14
S-2-15
S-2-16
City of Cypress
April 30, 2026

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“Improving lives and communities through transportation.” emissions. For additional guidance, please refer to CAPCOA Handbook Strategy T-9.

15. The Draft EIR should quantify project generated truck activity, including daily/peak hour truck trips by class, delivery schedules, staging behavior, and loading/unloading profiles.

16.Please evaluate whether the State Highway System (SHS) on-/off-ramps serving the project area have adequate storage capacity to prevent truck queues from spilling back into the mainline or onto local streets, and whether signal timing at ramp terminals provides sufficient clearance for heavy vehicles. Sight distance at driveways and intersections must remain unobstructed to ensure safe truck ingress/egress.

17. The Final EIR should include a detailed analysis of internal circulation, including how trucks will navigate separate areas for processing, loading, staging, and employee/customer parking. Clear separation of functions reduces conflict risk and improves operational efficiency.

18.If on-street loading or curbside deliveries are proposed, please ensure freight-only spaces do not intrude into bicycle lanes or travel lanes, loading ramps do not block pedestrian pathways, delivery windows avoid peak commute hours, and enforcement mechanisms are in place.

19. The Final EIR should also address truck turning radii, internal posted speed limits, height clearances, and potential conflicts with vulnerable road users. For locations with high pedestrian/bicycle activity, additional safety treatments (e.g., marked crossings, lighting, sight line improvements) should be considered.

20.Projects in the buildout should include zero or near zero emissions infrastructure, such as electric charging stations for passenger vehicles and Zero Emission Vehicle(ZEV) Trucks.

21.If the project area overlaps with Assembly Bill (AB) 617 communities or high scoring CalEnviroScreen tracts, the Final EIR should describe how community identified concerns (noise, air quality, mobility barriers) will be S-2-16
cont.

S-2-17
S-2-18
S-2-19
S-2-20
S-2-21
S-2-22
S-2-23
City of Cypress
April 30, 2026

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“Improving lives and communities through transportation.” mitigated to less than significant levels where feasible. Consider measures such as urban greening (e.g., green walls), enhanced buffer zones, dedicated truck routes to avoid sensitive land uses, and air and noise reduction strategies.

22.Project plans and traffic control plans must be stamped and signed by a licensed engineer. For all plans, including traffic control plans, Caltrans Right-of-Way (R/W) lines should be clearly labeled, which include existing and proposed (if there are any changes to Caltrans R/W), the north arrow, the edge of pavement, and edge of the sidewalk, if applicable. When submitting the application, please include final Environmental Clearance Documentation, relevant design details including design exception approvals and construction and drainage plans, traffic control plans, traffic management plan and traffic impact study if proposed traffic delay of 30 minutes above normal recurring traffic delay is anticipated, any Caltrans R/W certifications if needed, maintenance agreement as needed, shoring plans for any excavation 5-feet or more, ADA certification, and any letter of authorizations.

Caltrans’ mission is to improve lives and communities through transportation.

Please continue to coordinate with Caltrans for any future developments that could potentially impact State transportation facilities. If you have any questions, please do not hesitate to contact Arlo Phan at [email protected].

Sincerely,
Cole Iwamasa (on Behalf of Scott Shelley)
Office Chief
Division of Transportation Planning
Caltrans, District 12
S-2-23
cont.

S-2-24
S-2-25

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S PECIFIC PLAN 3.0 B UILDOUT P ROJECT

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2.2.2 CALIFORNIA DEPARTMENT OF TRANSPORTATION (CALTRANS), DISTRICT 12 Letter Code: S-2
Date: April 30, 2026
Response to Comment S-2-1
This comment provides introductory remarks and summarizes the proposed project evaluated in the Draft EIR.

Response to Comment S-2-2
This comment states that because regional vehicular access to the Buildout Area is provided by Interstate (I-) 605, I-405, State Route (SR-) 39, and SR-22, which are owned and operated by Caltrans, Caltrans has provided comment on the proposed project and Draft EIR.

The City acknowledges this comment. The responses to the specific comments provided by Caltrans are provided in Response to Comment S-2-3 through Response to Comment S-2-24, below.

Response to Comment S-2-3
This comment states that the letter sent by Caltrans District 12 on May 5, 2025, in response to the NOP prepared for the proposed project, which requested analysis and discussion of the 95 percent vehicle queue, was not included in Table 2.A: Notice of Preparation Agency Comments Received, of the Draft EIR, and requested the comment letter be added and addressed.

As provided in Section 3.0, Errata, of this Final EIR, Table 2.A: Notice of Preparation Agency Comments Received, of the Draft EIR has been updated to include the NOP comment letter from Caltrans. It should be noted that although this NOP comment letter was not included in Table 2.A of the Draft EIR, this letter was summarized and discussed in Section 4.17, Transportation, of the Draft EIR.

Refer to Response to Comment S-2-4, below, for the discussion of the 95 percent vehicle queue and potential safety concerns.

Response to Comment S-2-4
This comment requests the analysis and discussion of the 95 percent vehicle queue and the potential safety concerns if there is an overflow to adjacent lane(s).

In response to the NOP released in April 2025 for the proposed project, Caltrans requested that the Draft EIR include an analysis and discussion of the 95 percent vehicle queue due to the additional trips on the State on/off-ramps that lead to and from the Buildout Area, including at the SR22/Valley View Street interchange. Based on the anticipated number of vehicles that would use these on/off-ramps, as provided by the Traffic Study prepared for the proposed project, this analysis S PECIFIC PLAN 3.0 B UILDOUT P ROJECT

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2 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\8_Final EIR and RTC\Specific Plan 3.0 Buildout Project_Final EIR RTC_fnl.docx «06/19/26» -30 was determined not to be warranted in order to conclude that traffic safety impacts, including substantially increasing hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses, would be less than significant. As such, the Draft EIR did not include the queuing analysis.

Nonetheless, in response to Caltrans’ scoping comments as well as similar comments included in its Draft EIR comment letter requesting a 95 percent queuing analysis, Kimley Horn Associates prepared the Caltrans 95% Vehicle Queue Analysis (95% Vehicle Queue Analysis)1 which was sent to Caltrans on April 30, 2026 to address the concerns raised by the commenter. As described above, the queuing analysis is not required under CEQA because the proposed project’s contribution to traffic volumes on nearby on/off-ramps would be limited and have a less than significant impact related to traffic safety (e.g., geometric design, incompatible uses, etc.). The queuing analysis is also not required under a VMT analysis. The results of the analysis indicate the following:
• Westbound left and right vehicle queues on the SR-22 Westbound Off-ramp for the Build-Out 2038 and Build-Out 2038 Plus Project would be contained with the existing storage capacity during both peak hours. The proposed project would add approximately two vehicles to the westbound right-turn movement during the PM peak hour.
• Northbound right-turn vehicle queues at the Valley View Street/Bolsa Chica Road intersection at Garden Grove Boulevard would exceed the pocket storage for the Build-Out 2038 and Build-Out 2038 Plus Project conditions; however, the fourth through lane is a drop lane that becomes the right-turn pocket and there is sufficient lane storage to accommodate the turn movement queue. The proposed project would not add vehicles to this movement. • Southbound left-turn vehicle queues at the Valley View Street/Bolsa Chica Road intersection at Garden Grove Boulevard would exceed the pocket storage for the Build-Out 2038 and Build-Out 2038 Plus Project conditions by approximately a half-length of a passenger vehicle. However, the dual turn pocket opening would be sufficient to accommodate this queue exceedance. The proposed project would add approximately one vehicle.
• Westbound left and right vehicle queues on the SR-22 Westbound Off-ramp for the Build-Out 2038 and Build-Out 2038 Plus Project would exceed the pocket storage for the Build-Out 2038 and Build-Out 2038 Plus Project. However, the westbound lanes become drop lanes into both the left and right-turn pockets and there is approximately 700 feet to the next intersection to accommodate the anticipated vehicle queues. The proposed project would add approximately one vehicle in the PM peak hour and would not add vehicles to the westbound left-turn movement.

Overall, because the 95% Vehicle Queue Analysis determined that the vehicle queues with implementation of the proposed project could be adequately accommodated by the existing lane configurations, implementation of the proposed project would not result in potential safety concerns due to an overflow to adjacent lanes. Therefore, the 95% Vehicle Queue Analysis confirms that traffic safety impacts with implementation of the proposed project, including substantially 1 Kimley-Horn and Associates, Inc. 2026. Caltrans 95% Vehicle Queue Analysis. April 30.

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In addition, as discussed in Section 4.17, Transportation, of the Draft EIR, except as otherwise provided in the Specific Plan, all roadway improvements in and around the Buildout Area shall be designed and constructed in accordance with Chapter 25, Article 5, Public Improvements, of the City’s Municipal Code and applicable Public Works Design Standards, which establish minimum requirements for street widths, curb return radii, intersection design, and driveway access. Except as otherwise provided in the Specific Plan, driveway design and access control shall also comply with the City’s Municipal Code, Appendix I (Zoning), Chapter 3.14 – Off-Street Parking and Loading, which regulates driveway width, location, and spacing to prevent hazardous conflicts between vehicular and pedestrian movements. In addition, except as otherwise provided in the Specific Plan, all final site and roadway improvement plans shall conform to the City’s Public Works Design Criteria Manual, which incorporates California Manual on Uniform Traffic Control Devices (CA MUTCD) standards for intersection control, sight distance, and geometric design. Further, all final improvement and site access plans shall be subject to review and approval by the City’s Public Works prior to issuance of building permits. Compliance with these requirements and design standards would ensure that new roadway and driveway improvements avoid sharp curves, unsafe intersection geometry, and visual obstructions, thereby maintaining safe and efficient circulation within and adjacent to the Buildout Area. For these reasons, the proposed project's impact related to a substantial increase in hazards due to a design feature or incompatible use would be less than significant, as provided in the Draft EIR.

Response to Comment S-2-5
This comment is related to the Traffic Study prepared for the proposed project and requests that potential deficiencies under the Highway Capacity Manual (HCM) methodology and/or the Caltrans Guidelines be demonstrated for the I-605 and Cerritos Avenue ramps, the I-605 and Katella Avenue ramps, and the SR-22 and Valley View Street ramps.

The City acknowledges this comment. As previously discussed, transportation impacts under CEQA are evaluated based on a project’s effect on VMT, not LOS. The Traffic Study is only referenced in the Draft EIR as it relates to the anticipated number of daily vehicle trips associated with full buildout of the proposed project. No analysis contained in the Traffic Study is included in the Draft EIR, and the Traffic Study is provided on the City’s website for informational purposes only. Because the comment does not contain any substantive comments or questions about the environmental analysis or conclusions contained in the Draft EIR, no further response is required.

Response to Comment S-2-6
This comment requests that Caltrans be informed of any subsequent bids or future phases of development associated with implementation of the Specific Plan.

The City will continue to inform and coordinate with Caltrans regarding future development of the Buildout Area associated with implementation of the proposed project. Because the comment does not contain any substantive comments or questions about the environmental analysis or conclusions contained in the Draft EIR, no further response is required.

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This comment states that Caltrans supports local developments that are consistent with State planning priorities intended to promote equity, strengthen the economy, protect the environment, and promote public and health safety, which can be achieved by promoting smart growth principles in projects which provide a diversity of housing choices and destinations accessible by active transportation (i.e. bicycle and pedestrian) and transit users.

As discussed in Chapter 3.0, Project Description, of the Draft EIR, the Specific Plan includes six land use districts that permit housing at a range of densities, which allows for the development of various housing typologies. Specifically, the Specific Plan’s Mixed-Use (Town Center/HDR) District permits higher-density residential development with a maximum density of 30 dwelling units per gross acre.

The Mixed-Use (Town Center/MDR) District allows for medium-density residential development with a maximum density of 15 dwelling units per acre. The Specific Plan also includes a Residential District that allows a mix of attached and detached single family residential uses as well as two other land use districts that would allow medium density residential development. Therefore, the proposed project would provide for a variety of residential densities and housing typologies.

In addition, as discussed in Section 4.17, Transportation, of the Draft EIR, implementation of the proposed project would provide sidewalks along the project frontages and throughout the Buildout Area that would provide connections to existing pedestrian and bicycle facilities in the surrounding area. Specifically, the proposed project is assumed to include the addition of approximately 1 mile of bicycle facilities, connecting to the existing bicycle network. In addition, pedestrian access via sidewalks to the Buildout Area would be from Katella Avenue, Cerritos Avenue, Lexington Drive, and Vessels Circle, as extended. Additional pedestrian circulation improvements include sidewalks along the extension of Moody Street south of Cerritos Avenue. These pathways, together with the existing pedestrian infrastructure on the surrounding streets, would ensure seamless integration with the broader pedestrian network, effectively linking the Buildout Area with nearby amenities and transit options.

Additionally, as detailed in Mitigation Measure TRA-1, the proposed project would be required to implement feasible TDM strategies to mitigate the proposed project’s VMT impact, which include constructing or improving bicycle facilities that would connect the proposed project to the existing regional bicycle network and improving the pedestrian network, including the construction of offsite sidewalks to improve sidewalk coverage and pedestrian access to the surrounding area. All future development facilitated by the proposed project would also be required to comply with City policies regarding bicycle parking and other infrastructure. In addition, the proposed project would not include features that would disrupt existing or planned bicycle or pedestrian facilities, and the Buildout Area is located in proximity to transit service provided by the Orange County Transportation Authority (OCTA) along Katella Avenue and Valley View Street. OCTA Route 50 runs along Katella Avenue, with existing bus stops located near Lexington Drive, Siboney Street, Winners Circle, and Walker Street in the vicinity of the Buildout Area. Therefore, the proposed project would improve pedestrian and bicycle mobility in the Buildout Area and in the surrounding area and would help further the City’s goals of promoting alternative transportation.

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Response to Comment S-2-8
This comment recommends that the expected number of affordable units and the income levels for the affordable units be outlined for the proposed project.

The Draft EIR analyzed buildout of the Specific Plan within the Buildout Area at a “programmatic” level. According to Section 15168 of State CEQA Guidelines, a Program EIR may be prepared for a series of actions that are related geographically, as logical parts in a chain of contemplated actions, or in connection with the issuance of plans that govern the conduct of a continuing program (per Section 15168(a)). If a later activity is found to be within the scope of the Program EIR, no further environmental documents would be required.

Because the proposed project is analyzed in the Draft EIR at the programmatic level, the specific future projects associated with implementation of the proposed project, including the specific number of affordable (low income), moderate (medium income), or market rate units that would be constructed within the Buildout Area, cannot be determined at this time. However, future development projects associated with implementation of the proposed project would be reviewed by the City on a project-by-project basis in order to ensure that the proposed development application specifies the income levels for proposed residential units.

Response to Comment S-2-9
This comment states that Caltrans supports collaboration with local agencies to work towards a safe, functional, interconnected, multi-modal transportation network integrated through applicable “smart growth” type land use planning and policies.

The City acknowledges this comment and will continue to coordinate with Caltrans regarding future development of the Buildout Area associated with implementation of the proposed project. Because the comment does not contain any substantive comments or questions about the environmental analysis or conclusions contained in the Draft EIR, no further response is required.

Response to Comment S-2-10
This comment states that Caltrans supports measures to unbundle residential parking costs from property costs to decrease vehicle ownership and incentivize the use of public transit, resulting in a reduction of VMT and GHG emissions.

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This comment states that Caltrans encourages the design of Complete Streets that include highquality pedestrian, bicycle, and transit facilities that are safe and comfortable for users of all ages and abilities.

Although the City does not currently have a Complete Streets requirement for new development, future development projects associated with implementation of the proposed project would consider the incorporation of Complete Streets design. Because the comment does not contain any substantive comments or questions about the environmental analysis or conclusions contained in the Draft EIR, no further response is required.

Response to Comment S-2-12
This comment states that because the Buildout Area is in proximity to several existing bike facilities, including Class I bike lanes on Walker Street, Class II bike lanes on Moody Street and Walker Street, and Class III bike lanes on Cerritos Avenue, Caltrans recommends the inclusion of secure and functional short-term bike parking.

As discussed in Section 4.17, Transportation, of the Draft EIR, all future development associated with implementation of the proposed project would be required to comply with City policies regarding bicycle parking and other infrastructure. Accordingly, secure and functional short-term bike parking would be provided as part of future development. However, because the specific future projects associated with implementation of the proposed project cannot be determined at this time, the specific number and location of short-term bike parking also cannot be determined at this time. As part of the design review process for future development projects, these projects would be required to submit a detailed site plan that depicts the locations of short-term bike parking that would be included in each development, consistent with the Specific Plan and City requirements.

Response to Comment S-2-13
This comment requests that appropriate detours and safety measures are in place during construction that prioritize mobility, access, and safety for all modes of transportation, including bicyclists, pedestrians, and transit users.

As discussed in Section 4.17, Transportation, of the Draft EIR, temporary delays in traffic may occur during construction activities associated with implementation of the proposed project due to oversized vehicles traveling at lower speeds on the surrounding roadways turning into the Buildout Area. In addition, construction activities may require temporary road or lane closures in the vicinity of the Buildout Area. However, traffic generated by construction activity would be limited in duration and a Transportation Construction Plan (TCP) for construction activities associated with each development project within the Buildout Area would be submitted to the City of Cypress Public Works Department for review and approval. The TCP would include safety measures that prioritize mobility, access, and safety for all modes of transportation, including bicyclists, pedestrians, and transit users. Therefore, this request from Caltrans would be implemented during future construction activities and construction traffic impacts would be less than significant, as identified in the Draft EIR.

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This comment encourages collaboration with OCTA to increase transit frequency in the vicinity of the Buildout Area to reduce waiting and overall travel times.

As discussed in Section 4.17, Transportation, of the Draft EIR, the City’s General Plan Circulation Element contains Policy CIR-2.6, which requires the City to respond to increases in demand for additional bus service through interaction with OCTA and other available resources. Consistent with this policy, the City continually assesses ridership demand and coordinates with OCTA in order to address any potential service deficiencies in service. OCTA has also recently completed the 2024 Orange County Transit Vision Master Plan,2 which aims to integrate, enhance, and expand multimodal transportation services throughout the County and is currently developing the Directions 2050 plan3 to update OCTA’s Long-Range Transportation Plan (LRTP). Directions 2050 will look ahead to 2050 and outline strategies to ensure that the County’s transportation system remains efficient, safe, balanced, and sustainable, and addresses the provision of transit services.

OCTA’s Fiscal Year (FY) 2025-2026 budget also highlights increased transit service, including adding more bus service to meet rising demand, and investments in transit infrastructure.4 Therefore, the City is already coordinating with OCTA regarding improving transit services. Further, as discussed in Section 4.17 of the Draft EIR, implementation of the proposed project would not interfere with implementation of these transit planning documents, including the specific actions to address the growing need for expanded transit service.

Response to Comment S-2-15
This comment requests the consideration of providing improvements to the nearest bus stops in each direction or adopting nearby bus stops for ongoing cleaning and maintenance.

As discussed above and in Section 4.17, Transportation, of the Draft EIR, implementation of the proposed project would not result in any significant impacts related to transit services and no improvements to bus stops are currently proposed. Future project developers associated with implementation of the proposed project may consider the provision of bus stop improvements or the adoption of the nearby bus stops.

Response to Comment S-2-16
This comment requests the consideration of providing transit subsidies as an incentive to increase transit ridership.
2 Orange County Transportation Authority (OCTA). 2025a. 2024 Orange County Transit Vision Master Plan.

May. 3 Orange County Transportation Authority (OCTA). 2025c. OCTA Seeks Public Input to Help Shape Orange County’s Transportation Future. October 3. Website: https://www.octa.net/news/news-releases/octaseeks-public-input (accessed October 2025). 4 Orange County Transportation Authority (OCTA). 2025b. OCTA Approves $1.74 Billion Balanced Budget for FY 2025-26. June 6. Website: https://www.octa.net/news/news-releases/octa-approves-174-billionbalanced-budget-for-fy-2025-26 (accessed October 2025).

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2 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\8_Final EIR and RTC\Specific Plan 3.0 Buildout Project_Final EIR RTC_fnl.docx «06/19/26» -36 As discussed above and in Section 4.17, Transportation, of the Draft EIR, implementation of the proposed project would not result in any significant impacts related to transit services and no transit subsidies for future occupants are currently proposed. Future project developers associated with implementation of the proposed project may consider the provision of transit subsidies for future occupants.

Response to Comment S-2-17
This comment states that the Draft EIR should quantify project-generated truck activities, including daily/peak hour truck trips by class, delivery schedules, staging behavior, and loading/unloading profiles.

As previously discussed, because the proposed project is analyzed in the Draft EIR at the programmatic level, the specific future projects associated with implementation of the proposed project cannot be determined at this time. The Draft EIR assumes the construction of up to 440,000 square feet of non-residential development, which could include retail, commercial, office, or other similar uses. However, because the specific future projects and non-residential uses cannot be determined at this time, the specific delivery schedules, staging behavior, and loading/unloading profiles also cannot be determined at this time. In addition, although some of these uses may include some light delivery activities, the proposed uses do not typically generate a significant number of truck trips.

In addition, future development projects associated with implementation of the proposed project would be reviewed by the City on a project-by-project basis in order to ensure that project operations would not result in disruptions of public roadways due to delivery staging behavior or loading/unloading activities that go beyond what was analyzed in the Draft EIR. Specifically, through the design review process, future development projects would be required to submit a detailed site plan that depicts delivery truck routes and loading/unloading area, if necessary, consistent with City requirements.

Response to Comment S-2-18
This comment requests the evaluation of whether the State Highway System (SHS) on-/off-ramps serving the project area have adequate storage capacity to prevent truck queues from spilling back into the mainline or onto local streets, and whether signal timing at ramp terminals provides sufficient clearance for heavy vehicles.

The City acknowledges this comment. As previously discussed in the Response to Comment S-2-4, the 95% Vehicle Queue Analysis completed for the proposed project determined that the vehicle queues at the Valley View Street/Bolsa Chica Road and Garden Grove Boulevard intersection and the SR-22 Westbound off-ramp with implementation of the proposed project could be adequately accommodated by the existing lane configurations and that implementation of the proposed project would not result in potential safety concerns due to an overflow to adjacent lanes. Therefore, traffic safety impacts with implementation of the proposed project, including substantially increasing hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses, would remain less than significant, as provided in the Draft EIR. Given that the

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Response to Comment S-2-19
This comment states that the Final EIR should include a detailed analysis of internal circulation, including how trucks will navigate separate areas for processing, loading, staging, and employee/customer parking.

As previously discussed, because the proposed project is analyzed in the Draft EIR at the programmatic level, the specific future projects associated with implementation of the proposed project, including the specific internal circulation improvements beyond the main “backbone” roadways and how trucks would navigate separate areas for processing, loading, staging, and employee/customer parking, cannot be determined at this time. However, future development projects associated with implementation of the proposed project would be reviewed by the City on a project-by-project basis in order to ensure that the proposed development complies with City requirements relating to circulation improvements and that project operations would not result in disruptions of public roadways due to loading and staging activities. Specifically, through the design review process, future development projects would be required to submit a detailed site plan that depicts delivery truck routes, loading/unloading areas, and employee/customer parking, consistent with City requirements.

Response to Comment S-2-20
This comment states that if on-street loading or curbside deliveries are proposed, they should be designed to ensure that freight-only spaces do not intrude into bicycle lanes or travel lanes, loading ramps do not block pedestrian pathways, delivery windows avoid peak commute hours, and enforcement mechanisms are in place.

As discussed above, because the proposed project is analyzed in the Draft EIR at the programmatic level, the specific future projects associated with implementation of the proposed project, including the specific internal circulation improvements and locations of loading or curbside deliveries zones, cannot be determined at this time. However, future development projects associated with implementation of the proposed project would be reviewed by the City on a project-by-project basis in order to ensure that the proposed development complies with City requirements relating to circulation improvements. Specifically, through the design review process, future development projects would be required to submit a detailed site plan that depicts delivery truck routes and loading/unloading areas to ensure that freight-only spaces do not intrude into bicycle lanes or travel lanes, loading ramps do not block pedestrian pathways, delivery windows avoid peak commute hours, and enforcement mechanisms are in place.

Response to Comment S-2-21
This comment states that the Final EIR should address truck turning radii, internal posted speed limits, height clearances, and potential conflicts with vulnerable road users. This comment also states that additional safety treatments (e.g., marked crossings, lighting, sight line improvements) should be considered in locations with high pedestrian/bicycle activity.

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2 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\8_Final EIR and RTC\Specific Plan 3.0 Buildout Project_Final EIR RTC_fnl.docx «06/19/26» -38 The proposed project is analyzed in the Draft EIR at the programmatic level. The specific future projects associated with implementation of the proposed project, including the specific internal circulation improvements, cannot be determined at this time. Future development projects associated with implementation of the proposed project would be reviewed by the City on a projectby-project basis in order to ensure that the proposed development complies with City requirements relating to truck turning radii, internal posted speed limits, height clearances, and potential conflicts with vulnerable road users.

However, except as otherwise provided in the Specific Plan, all roadway improvements in and around the Buildout Area shall be designed and constructed in accordance with Chapter 25, Article 5, Public Improvements, of the City’s Municipal Code and applicable Public Works Design Standards, which establish minimum requirements for street widths, curb return radii, intersection design, and driveway access. Except as otherwise provided in the Specific Plan, driveway design and access control shall also comply with the City’s Municipal Code, Appendix I (Zoning), Chapter 3.14 – OffStreet Parking and Loading, which regulates driveway width, location, and spacing to prevent hazardous conflicts between vehicular and pedestrian movements. In addition, except as otherwise provided in the Specific Plan, all final site and roadway improvement plans shall conform to the City’s Public Works Design Criteria Manual, which incorporates California Manual on Uniform Traffic Control Devices (CA MUTCD) standards for intersection control, sight distance, and geometric design. Further, all final improvement and site access plans shall be subject to review and approval by the City’s Public Works prior to issuance of building permits. Compliance with these requirements and design standards would ensure that new roadway and driveway improvements avoid sharp curves, unsafe intersection geometry, and visual obstructions, thereby maintaining safe and efficient circulation within and adjacent to the Buildout Area. For these reasons, the proposed project's impact related to a substantial increase in hazards due to a design feature or incompatible use would be less than significant, as provided in the Draft EIR.

Response to Comment S-2-22
This comment states that future projects within the Buildout Area should include zero or near zero emissions infrastructure, such as electric charging stations for passenger vehicles and Zero Emission Vehicle (ZEV) trucks.

As discussed in Section 4.8, Greenhouse Gas Emissions, of the Draft EIR, Mitigation Measure AIR-1 would require future development facilitated by the proposed project provide enhanced electric vehicle charging infrastructure that meets the requirements of the latest version of the CALGreen Code Tier 2 Voluntary Standards, consistent with the California Air Resources Board’s (CARB) Scoping Plan guidance.

Response to Comment S-2-23
This comment states that if the project area overlaps with Assembly Bill (AB) 617 communities or high scoring CalEnviroScreen tracts, the Final EIR should describe how community identified concerns (noise, air quality, mobility barriers) will be mitigated to less than significant levels where feasible. This comment also suggested measures to achieve this, including urban greening (e.g., green walls), enhanced buffer zones, dedicated truck routes to avoid sensitive land uses, and air and noise reduction strategies.

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P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\8_Final EIR and RTC\Specific Plan 3.0 Buildout Project_Final EIR RTC_fnl.docx «06/19/26» 2-39 According to the California Environmental Health Screening Tool (CalEnviroScreen 5.0),5 the Buildout Area and the areas located directly east and west of the Buildout Area are scored at 55.88, meaning that they are around the 56th percentile statewide for all CalEnviroScreen 5.0 considerations. This indicates moderate cumulative environmental and socioeconomic burden relative to other California communities. Areas located directly north of the Buildout Area are scored at 49.11 and areas located directly south are scored at 41.9, meaning they are around 49th and 42nd percentile statewide for all CalEnviroScreen 5.0 considerations. This indicates a lower than average cumulative environmental and socioeconomic burden relative to other California communities. Accordingly, the Buildout Area and surrounding area are not high scoring CalEnviroScreen tracts. In addition, the South Coast Air Quality Management District (SCAQMD) does not designate any specific AB 617 communities within the City of Cypress.6
Response to Comment S-2-24
This comment states that project plans and traffic control plans must be stamped and signed by a licensed engineer, and all Caltrans Right-of-Way (R/W) lines should be clearly labeled. This comment also provides the requirements for submitting the application to Caltrans.

All future project plans and traffic control plans shall be stamped and signed by a licensed engineer.

Because the comment does not contain any substantive comments or questions about the environmental analysis or conclusions contained in the Draft EIR, no further response is required.

Response to Comment S-2-25
This comment provides concluding remarks and contact information.

The City acknowledges this comment and looks forward to future coordination with Caltrans regarding development of the proposed project.
5 State of California, Office of Environmental Health Hazard Assessment (OEHHA). CalEnviroScreen 5.0, The California Environmental Health Screening Tool. Website: https://experience.arcgis.com/experience/ 8c5c5c91ebb8481a8a3d92c897faf8ed/page/Overall-Results#data_s=id%3AdataSource_87-19bb33ab09elayer-3%3A4829 (accessed May 2026). 6 South Coast Air Quality Management District (SCAQMD). AB 617 Community Air Initiatives. Website:
https://www.aqmd.gov/nav/about/initiatives/environmental-justice/ab617-134# (accessed May 2026).

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2.3 REGIONAL AGENCIES
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Summary of Proposed Project Information in the Draft EIR Based on the Draft EIR, the Proposed Project consists of the development of approximately 134 acres within the Cypress Town Center and Commons Specific Plan 3.0 area, including 1,791 residential units, non-residential uses (440,000 square feet), and 18.2 acres of park and recreational improvements. The project also includes 112 attached townhomes on Lot 14, which totals 7.33 acres. Based on a review of aerial photographs, South Coast AQMD staff found that the nearest sensitive receptor (e.g., single-family residential uses) is located 10 feet east of the Lot 14 site. The Proposed Project is located at 4961 Siboney Street in Cypress.

South Coast AQMD Comments
Overlapping Construction and Operational Activities
Even though the Proposed Project consists of approximately a total of 134 acres of land over the course of 12-year construction, the Draft EIR does not analyze the scenario of overlapping between the construction and operational activities. Therefore, South Coast AQMD staff recommends that the Lead Agency revise the air quality analysis section to consider the overlapping construction and operation. The estimated overlapped emissions should then be compared to South Coast AQMD’s regional air quality CEQA operational thresholds to determine their level of significance, which should be included in the Final EIR. If the overlapped emissions analysis is not included in the Final EIR, the Lead Agency should provide reasons for not having them supported by substantial evidence in the record.

Air Quality Mitigation Measures for NOx and PM Emissions from Construction Comment Letter R-1
R-1-1
R-1-2
R-1-3
Alicia Velasco, Planning Director 2 April 30, 2026
Given the long-range plan of the Proposed Project from (project duration: 2026-2038), Tier 2 technology is not the cleanest technology when construction occurs later for individual projects.

According to the CARB’s Strategies for Reducing Emissions from Off-Road Construction Equipment, the implementation of off-road Tier 5 starting in 2027 or 2028 and the Governor’s Executive Order in September 2020 requires CARB to develop and propose a full transition to Zero Emission (ZE) by 2035.14 Considering the scope of the project, it is crucial to ensure that the levels of construction emissions, specifically NOx and PM10, remain below significant thresholds during the construction period for each proposed individual project. Moving towards achieving this goal, where feasible, involves opting for electric engines instead of diesel-fueled engines for the construction equipment. This proactive choice not only aligns with environmental concerns but also demonstrates a commitment to minimizing the project's environmental footprint. The abatement of NOx can also be pursued by enforcing greener constructions, such as limiting the usage of older engines in favor of adopting the latest available technologies or even incorporating exhaust retrofits such as cutting-edge exhaust aftertreatment techniques.

Additionally, several other resources to assist the Lead Agency with identifying additional potential mitigation measures for the Proposed Project are included in the South Coast AQMD’s CEQA Air Quality Handbook15 for both operational and construction emissions.

Emission Reductions from Health Risk Strategies
South Coast AQMD is concerned about the potential public health impacts of sitting existing and new sensitive populations within the proximity of existing air pollution sources (e.g., freeway, railroad). For this reason, prior to approving this Proposed Project as well as any future development projects, the Lead Agency is recommended to consider the impacts of air pollutants on people who will live in the new project area and provide effective mitigation. Additionally, South Coast AQMD suggests that the Lead Agency review and apply the guidance provided in:
1) the California Air Resources Board (CARB) Air Quality Land Use and Handbook: A Community Health Perspective1 which provides criteria for evaluating and reducing air pollution impacts associated with new projects involving land use decisions; and 2) CARB’s technical advisory which contains strategies to reduce air pollution exposure near high-volume roadways.2 Many strategies are available for residential receptors to reduce being exposed to particulate matter, including, but not limited to, HVAC systems equipped with filters rated at a minimum efficiency reporting value (MERV) 13 or higher air filtration capabilities. In some cases, MERV 15 or better is recommended, for building design, orientation, location, vegetation barriers, landscaping screening, etc. Enhanced filtration units are capable of reducing exposure. However, enhanced filtration systems have limitations. For example, filters rated MERV 13 or higher are able to screen out greater than or equal to 50% of DPM3but they have no ability to filter out volatile organic compound (VOC) emissions. Also, in a study that South Coast AQMD conducted to investigate filters rated at MERV 13 or better in classrooms,45a cost burden is 1 California Air Resources Board (CARB), Air Quality Land Use and Handbook: A Community Health Perspective, April 2005. Available at: https://ww2.arb.ca.gov/sites/default/files/2023-05/Land%20Use%20Handbook_0.pdf 2 CARB’s Strategies to Reduce Air Pollution Exposure Near High-Volume Roadways. Available at:
https://ww2.arb.ca.gov/sites/default/files/2017-10/rd_technical_advisory_final.pdf 3 U.S. EPA, “What is a MERV rating?” Available at: https://www.https://www.epa.gov/indoor-air-quality-iaq/whatmerv-rating. 4 South Coast AQMD, Draft Pilot Study of High-Performance Air Filtration For Classroom Applications, October 2009. Available at: https://www.aqmd.gov/docs/default-source/ceqa/handbook/aqmdpilotstudyfinalreport.pdf.

R-1-3
cont.

R-1-4
Alicia Velasco, Planning Director 3 April 30, 2026
expected to be within the range of $120 to $240 per year to replace each filter panel. The initial start-up cost could substantially increase if an HVAC system needs to be installed and if standalone filter units are required. Installation costs may vary, including costs for conducting site assessments and obtaining permits and approvals before filters can be installed. Other costs may include filter life monitoring, annual maintenance, and training for conducting maintenance and reporting. In addition, the filters would not have any effect unless the HVAC system is running. Therefore, when in use, the increased energy consumption from each HVAC system should be evaluated in the Draft EIR. While the filters operate 100 percent of the time when the HVAC is in use while the residents are indoors, the environmental analysis does not generally account for the times when the residents are not using their HVAC and instead have their windows or doors open or are moving throughout the common space outdoor areas of the Proposed Project. Furthermore, when used filters are replaced with new filters, emissions associated with trucks delivering the new filters and waste disposal trucks transporting the used filters to disposal sites should be evaluated in the Draft EIR. Therefore, any presumed effectiveness and feasibility of a particular HVAC filter should be carefully evaluated in more detail based on supporting evidence before assuming they will sufficiently alleviate exposure to DPM emissions.

South Coast AQMD Air Permits and Role as a Responsible Agency If implementation of the Proposed Project would require the use of new stationary and portable sources, including but not limited to emergency generators, fire water pumps, boilers, etc., one or more air permits from South Coast AQMD will be required. The Final EIR should include a discussion about the potentially applicable South Coast AQMD rules that may be applicable to the Proposed Project. Those rules may include, for example, Rule 201 – Permit to Construct,6 Rule 203 – Permit to Operate,7 Rule 401 – Visible Emissions,8 Rule 402 – Nuisance,9 Rule 403 – Fugitive Dust,10 Rule 1110.2 – Emissions from Gaseous and Liquid Fueled Engines,11 Rule 1113 – Architectural Coatings,
12 Rule 1166 – Volatile Organic Compound Emissions from Decontamination of Soil,
13 Rule 1179 – Publicly Owned Treatment Works Operations, 14 Regulation XIII – New Source Review, 15 Rule 1401 – New Source Review of Toxic Air Contaminants,
16 Rule 1466 – Control of Particulate Emissions from Soils with Toxic Air Contaminants,17 Rule 1470 – Requirements for Stationary Diesel-Fueled Internal Combustion and Other Compression Ignition Engines,18 etc. It is important to note if air permits from South Coast AQMD are required, the role of South Coast AQMD would change from a Commenting 5 South Coast AQMD, Draft Pilot Study of High-Performance Air Filtration For Classroom Applications, October 2009. Available at: https://www.aqmd.gov/docs/default-source/ceqa/handbook/aqmdpilotstudyfinalreport.pdf. 6 South Coast AQMD, Rule 201 is available at: https://www.aqmd.gov/docs/default-source/rule-book/reg-ii/rule-201.pdf 7 South Coast AQMD, Rule 203 is available at: https://www.aqmd.gov/docs/default-source/rule-book/reg-ii/rule-203.pdf 8 South Coast AQMD, Rule 401 is available at: https://www.aqmd.gov/docs/default-source/rule-book/rule-iv/rule-401.pdf 9 South Coast AQMD, Rule 402 is available at: https://www.aqmd.gov/docs/default-source/rule-book/rule-iv/rule-402.pdf 10 South Coast AQMD, Rule 403 is available at: https://www.aqmd.gov/docs/default-source/rule-book/rule-iv/rule-403 11 South Coast AQMD, Rule 1110.2 is available at: https://www.aqmd.gov/docs/default-source/rule-book/reg-xi/r1110_2.pdf 12 South Coast AQMD, Rule 1113 is available at https://www.aqmd.gov/docs/default-source/rule-book/reg-xi/r1113.pdf 13 South Coast AQMD, Rule 1166 is available at: https://www.aqmd.gov/docs/default-source/rule-book/reg-xi/rule-1166.pdf 14 South Coast AQMD, Rule 1179 is available at: https://www.aqmd.gov/docs/default-source/rule-book/reg-xi/rule-1179.pdf 15 South Coast AQMD, Regulation XIII is available at: https://www.aqmd.gov/home/rules-compliance/rules/scaqmd-rulebook/regulation-xiii 16 South Coast AQMD, Rule 1401 is available at: https://www.aqmd.gov/docs/default-source/rule-book/reg-xiv/rule-1401.pdf 17 South Coast AQMD, Rule 1466 is available at: https://www.aqmd.gov/docs/default-source/rule-book/reg-xiv/rule-1466.pdf 18 South Coast AQMD, Rule 1470 is available at: https://www.aqmd.gov/docs/default-source/rule-book/reg-xiv/rule-1470.pdf R-1-4
cont.

R-1-5
R-1-6
R-1-7
Alicia Velasco, Planning Director 4 April 30, 2026
Agency to a Responsible Agency under CEQA. In addition, if South Coast AQMD is identified as a Responsible Agency, per CEQA Guidelines Sections 15086, the Lead Agency is required to consult with South Coast AQMD.

Conclusion
As set forth in California Public Resources Code Section 21092.5(a) and CEQA Guidelines Section 15088(a-b), the Lead Agency shall evaluate comments from public agencies on the environmental issues and prepare a written response at least 10 days prior to certifying the Final EIR. As such, please provide South Coast AQMD written responses to all comments contained herein at least 10 days prior to the certification of the Final EIR. In addition, as provided by CEQA Guidelines Section 15088(c), if the Lead Agency’s position is at variance with recommendations provided in this comment letter, detailed reasons supported by substantial evidence in the record to explain why specific comments and suggestions are not accepted must be provided.

Thank you for the opportunity to provide comments. South Coast AQMD staff are available to work with the Lead Agency to address any air quality questions that may arise from this comment letter. Please contact Sahar Ghadimi, Air Quality Specialist, at [email protected] should you have any questions.

Sincerely,
Sam Wang
Sam Wang
Program Supervisor, CEQA IGR
Planning, Rule Development & Implementation
SW:SG
ORC260318-03
Control Number
R-1-7
cont.

R-1-8

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2.3.1 SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT (SCAQMD) Letter Code: R-1
Date: April 30, 2026
Response to Comment R-1-1
This comment provides introductory remarks and summarizes the scope of the Draft EIR.

Response to Comment R-1-2
This comment states the Draft EIR does not analyze the scenario of overlapping construction and operational activities and recommends that the air quality analysis and Draft EIR section be revised to consider air emissions of overlapping construction and operation. This comment also states that if the overlapped emissions analysis is not included in the Final EIR, the City should provide reasons for not having them supported by substantial evidence in the record.

The commenter's concern regarding overlapping construction activities has already been addressed in the Draft EIR. As discussed in Section 4.3, Air Quality, the air quality analysis included a separate CalEEMod modeling scenario specifically developed to evaluate a conservative worst-case construction condition involving simultaneous grading activities across multiple development areas within the Buildout Area. This scenario was intended to represent overlapping construction schedules and to capture peak construction emissions associated with concurrent grading activities.

With respect to overlapping construction and operational activities, the proposed project is a program-level Specific Plan buildout project. Development within the Buildout Area would occur incrementally over time on a project-by-project basis, and the specific timing, sequencing, location, and design of future development projects cannot be determined at this time. As discussed in the Draft EIR, future development may occur in phases based on market conditions, infrastructure availability, financing, and other factors. Therefore, while it is reasonably foreseeable that some portions of the Buildout Area could become operational while construction continues elsewhere, the precise extent and timing of such overlap cannot be known and would be speculative.

CEQA requires analysis of reasonably foreseeable environmental effects but does not require agencies to speculate regarding future project details that are unknown at the time of environmental review. Accordingly, the Draft EIR evaluated a conservative full-buildout operational scenario and a worst-case construction scenario to disclose the maximum anticipated emissions associated with implementation of the proposed project.

Furthermore, the Draft EIR determined that operational emissions at full buildout would exceed applicable SCAQMD regional significance thresholds. As discussed in Section 4.3, even with implementation of Mitigation Measure AIR-1 and Mitigation Measure TRA-1, operational VOC emissions would remain above SCAQMD significance thresholds, resulting in a significant and S PECIFIC PLAN 3.0 B UILDOUT P ROJECT

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4.3-29).

As there are no additional feasible mitigation measures that would reduce project operationalsource VOC emissions to a less than significant level, proposed project operation would result in a significant and unavoidable impact related to a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable federal or State ambient air quality standard. Therefore, the Draft EIR determined that emissions related to operational activities would be considered significant and unavoidable. The evaluation of overlapping construction and operational emissions would not result in the identification of a new significant impact, a substantially more severe impact, or additional feasible mitigation beyond that already disclosed in the Draft EIR. As such, this comment does not identify any new significant environmental issues or impacts that were not already analyzed and disclosed in the Draft EIR.

Response to Comment R-1-3
This comment states that given the scope of the proposed project, it is crucial to ensure that the levels of construction emissions, specifically NOx and particulate matter less than 10 microns in diameter (PM10), remain below significant thresholds during the construction period for each proposed individual project, and that Tier 2 technology is not the cleanest technology when construction occurs later for individual projects. This comment also states that, according to the CARB’s Strategies for Reducing Emissions from Off-Road Construction Equipment, the implementation of off-road Tier 5 would start in 2027 or 2028 and the Governor’s Executive Order in September 2020 requires CARB to develop and propose a full transition to Zero Emission (ZE) by 2035.

As shown in Table 4.3.F and Table 4.3.G in Section 4.3, Air Quality, of the Draft EIR, utilization of Tier 2 construction equipment would result in project-related construction emissions that would be below the SCAQMD’s significance thresholds. Further, as discussed in Section 4.3 of the Draft EIR, according to SCAQMD guidance, projects that exceed the significance thresholds are considered by SCAQMD to result in cumulatively considerable air quality impacts, whereas projects that do not exceed applicable thresholds are generally not considered to result in cumulatively considerable impacts. Because construction emissions associated with the proposed project would not exceed any applicable significance threshold, construction activities would not result in a cumulatively considerable contribution to regional air quality impacts. In addition, as discussed in Section 4.3, construction emissions estimates presented in the Draft EIR are conservative as they are based on default construction equipment assumptions and do not account for the Tier 4 Final or cleaner equipment requirement detailed in Mitigation Measure AIR-2. Actual construction emissions would therefore be expected to be lower than those presented in the modeling results and in Table 4.3.F of the Draft EIR. Accordingly, with compliance with regulatory requirements (as specified in Regulatory Compliance Measures AIR-1 through AIR-4), construction impacts related to a cumulatively considerable net increase of any criteria pollutant for which the project region is in nonattainment under applicable federal or State ambient air quality standards would be less than significant, and no additional mitigation is required.

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Response to Comment R-1-4
This comment expresses concern regarding the potential public health impacts associated with siting existing and new sensitive populations within the proximity of existing air pollution sources and recommends the City consider guidance contained in CARB’s Air Quality Land Use and Handbook: A Community Health Perspective and CARB’s technical advisory regarding strategies to reduce air pollution exposure near high-volume roadways. The comment also recommends consideration of enhanced filtration systems, HVAC design features, vegetation barriers, landscaping, and other exposure-reduction measures for future residential development.

Section 4.3, Air Quality, of the Draft EIR evaluates the potential for operational health risks to new sensitive receptors that would be developed within the Buildout Area, including future residential uses, and discusses the recommendations contained in CARB’s Air Quality Land Use and Handbook:

A Community Health Perspective. As discussed in the Draft EIR, none of the uses outlined in CARB’s siting recommendations (e.g., freeways, distribution centers, rail yards, ports, etc.) are within 500 feet of the Buildout Area. The closest potential uses are the industrial uses on the western and eastern boundaries, which are further than 500 feet. The proposed project is consistent with CARB’s siting recommendations. Further, none of the uses outlined in CARB’s recommendations for siting new sensitive land uses are allowed under the Specific Plan and as such are not part of the proposed project, which includes non-residential and residential uses. Therefore, the uses allowed under the proposed project would not be a substantial source of Toxic Air Contaminants (TACs) that would require specific siting distances based on the CARB recommendations.

The commenter also recommends implementation of enhanced filtration systems, such as MERV-13 or higher filters, HVAC system design features, vegetation barriers, and other exposure-reduction strategies. The City acknowledges these recommendations and notes that such measures may be considered during future project-level design and site planning, as appropriate. However, because the Draft EIR did not identify a significant health risk impact associated with exposure of future residents to nearby air pollution sources, implementation of enhanced filtration systems or other exposure-reduction measures is not required to mitigate a significant impact under CEQA.

As noted by the commenter, filtration systems have inherent limitations and may involve considerations related to energy consumption, maintenance, filter replacement, and long-term operation. Because the Draft EIR did not identify a significant air quality health risk impact requiring mitigation, further evaluation of the effectiveness, operational requirements, or environmental effects associated with such filtration systems is not warranted. Nevertheless, future project applicants may voluntarily incorporate enhanced filtration systems, building orientation strategies, S PECIFIC PLAN 3.0 B UILDOUT P ROJECT

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Furthermore, CEQA generally does not require evaluation of the effects of existing environmental conditions on future project users or residents unless the project would exacerbate an existing environmental hazard or condition. The proposed project would not introduce substantial new TAC sources, nor would it increase emissions from existing nearby sources. Accordingly, the proposed project would not exacerbate any existing air quality hazards in the project vicinity. Therefore, the proposed project would not pose an operational health risk to future tenants or occupants and impacts would be less than significant, as provided in the Draft EIR.

Response to Comment R-1-5
This comment states that if implementation of the proposed project would require the use of new stationary and portable sources, including but not limited to emergency generators, fire water pumps, boilers, etc., one or more air permits from SCAQMD would be required.

The City acknowledges that future development projects implemented within the Buildout Area may include equipment that is subject to SCAQMD permitting requirements. As discussed in Chapter 3.0, Project Description, of the Draft EIR, the proposed project consists of the reasonably foreseeable buildout of a portion of the area governed by the Specific Plan that includes approximately 134 acres of land (Buildout Area) in the city. Full buildout envisioned under the proposed project would include up to 1,791 residential units and 440,000 square feet of non-residential development.

Because specific site plans, building designs, tenant improvements, and equipment specifications have not yet been prepared for future development projects, the precise types, sizes, locations, and operational characteristics of equipment that may require SCAQMD permits are not known at this time.

Accordingly, the Draft EIR evaluates the reasonably foreseeable environmental impacts associated with buildout of the proposed project based on currently available information. Should future development projects propose equipment that is subject to SCAQMD permitting requirements, including but not limited to emergency generators, fire pumps, boilers, or other permitted sources, those projects would be subject to review by SCAQMD and would be required to comply with all applicable federal, State, and local regulations, including applicable SCAQMD permitting requirements and rules. In addition, if permits are required, SCAQMD would serve as a Responsible Agency for the applicable future development project, consistent with CEQA.

In addition, as discussed in Section 4.3, Air Quality, of the Draft EIR, Mitigation Measure AIR-1 requires that, prior to issuance of grading permits for development projects in the Buildout Area, the City shall identify project design details and specifications, where feasible, to document implementation and compliance with applicable emission reduction measures. Compliance with all applicable SCAQMD rules, permit conditions, and regulatory requirements would further reduce and control emissions associated with future development projects implemented within the Buildout Area.

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Response to Comment R-1-6
This comment states that the Final EIR should include a discussion about the potentially applicable SCAQMD rules that may be applicable to the proposed project.

As discussed in Section 4.3, Air Quality, of the Draft EIR, the SCAQMD is the regional agency responsible for regulating stationary and area sources of air emissions within the South Coast Air Basin and for implementing both the federal and California Clean Air Acts through its regulatory programs. Further, all applicable SCAQMD rules and regulations that would be implemented during project implementation are listed on pages 4.3-15 through 4.3-17 of the Draft EIR. The proposed project would be required to implement all applicable SCAQMD rules and permitting requirements n order to limit potential impacts. No revisions are necessary, and no further response is required.

Response to Comment R-1-7
This comment states that if air permits from the SCAQMD are required, the role of the SCAQMD would change from a Commenting Agency to a Responsible Agency under CEQA, which would require consultation between the City as the Lead Agency and the SCAQMD.

The City acknowledges this comment. If air permits from the SCAQMD are required, the City looks forward to coordinating with the SCAQMD regarding development of the proposed project. Because the comment does not contain any substantive comments or questions about the environmental analysis or conclusions contained in the Draft EIR, no further response is required.

Response to Comment R-1-8
This comment provides concluding remarks, contact information, and request that’s the City provide the SCAQMD with written responses to all comments contained in the comment letter at least 10 days prior to the certification of the Final EIR, as required by California Public Resources Code Section 21092.5(a) and CEQA Guidelines Section 15088(a-b). This comment also states that if the City’s position is at variance with the recommendations provided in the comment letter, detailed reasons supported by substantial evidence in the record to explain why specific comments and suggestions are not accepted must be provided.

The City acknowledges this comment and has provided written responses to all comments contained in the comment letter in this Final EIR, which will be available at least 10 days prior to the certification hearing for the proposed project. Responses to the specific comments raised in the SCAQMD’s comment letter are provided above and no further response is necessary.

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2.4 LOCAL AGENCIES
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OC San has a few issues; first the proposed improvements include a connection to an existing OC San sewer main. Important to note only local public sewers are allowed to connect directly to OC San sewer mains, and a trunk connection permit is required. Utility plans should be submitted to OC San’s Planning Division for review as soon as they are available. Second, the proposed improvements are in a proximity to the existing OC San easement along Lexington Drive. Please note that any encroachment into the easement will require an encroachment agreement.

If you have any questions regarding this letter, please contact Kevin Hadden, Planning Division, at 714 593-7462 or [email protected].

Andrew Brown
Engineering Supervisor
Planning Division
714 593-7052
AB/KH:op
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2.4.1 ORANGE COUNTY SANITATION DISTRICT (OC SAN)
Letter Code: L-1
Date: April 14, 2026
Response to Comment L-1-1
This comment provides introductory remarks and summarizes the scope of the Draft EIR.

Response to Comment L-1-2
This comment states that the proposed project would have an impact to the Orange County Sanitation District (OC San) collection system and that OC San has previously issued a sewer capacity verification letter for the proposed project.

As discussed in Section 4.19, Utilities and Service Systems, of the Draft EIR, the Sewer Capacity Study prepared for the proposed project, which is included as Appendix M to the Draft EIR, analyzed the hydraulic pipe capacity for the proposed sewer lateral connection in Lexington Drive, three different locations along the proposed Moody Street Extension sewer main, and for the proposed Vessels Circle Extension sewer lateral that would connect to Moody Street Extension. The results of this analysis demonstrate that the proposed sewer lines would have adequate capacity to serve the proposed project. In addition, the Sewer Capacity Study found that the existing 18-inch pipe at proposed Sewer Connection B and the existing 21-inch pipe at the existing connection to the 30-inch OC San sewer trunk line would be adequate to serve the proposed project and no replacement facilities with increased capacity would be necessary. In addition, as provided in the Sewer Capacity Verification Letter prepared by OC San and dated July 3, 2024,7 which is referenced in this comment, OC San has determined that it would have sufficient treatment capacity in its facilities to accept the estimated wastewater flows from the Buildout Area, as conveyed to OC San by the City’s municipal sanitary sewer system. Additionally, fees required by OC San would sufficiently offset potential impacts generated by the proposed project.

As also discussed in Section 4.19 of the Draft EIR, all future projects implemented in accordance with the proposed project would be required to adhere to the Specific Plan and comply with applicable development regulations pertaining to wastewater treatment. As a part of the development review process, all future projects would be required to demonstrate that existing public utilities would be sufficient to serve the future projects’ needs. Further, as discussed in the Sewer Capacity Study prepared for the proposed project, if buildout within the Buildout Area exceeds 440,000 square feet of non-residential floor area, each future applicant for a project that would cause the overall nonresidential floor area within the Buildout Area to exceed, or further exceed, 440,000 square feet, would be required to prepare and submit to the City a supplemental study assessing sewer capacity 7 Orange County Sanitation District (OC San). 2024. Orange County Sanitation District Sewer Capacity Verification, 4961 Katella Avenue, Cypress, CA 90720. July 4.

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Therefore, implementation of the proposed project would not result in a significant impact on the OC San collection system.

Response to Comment L-1-3
This comment states that the proposed project includes improvements that would connect to existing OC San sewer mains and notes that only local public sewers are permitted to directly connect to OC San sewer mains. The comment also states that a trunk connection permit from OC San would be required for all sewer main connection.

As discussed in Section 4.19, Utilities and Service Systems, of the Draft EIR, implementation of the proposed project would include the installation of two new sewer connections to existing sewer main lines, including (1) a new 10-inch sewer lateral extending from Lot 2 and connecting to the existing 30-inch sewer trunk line owned and maintained by OC San within Lexington Drive (Sewer Connection A), and (2) a new 8-inch sewer main line that would run north to south along the proposed Moody Street extension (Sewer Connection B), collecting sewer lateral flows from the adjacent lots before connecting to the existing 18-inch VCP City sewer main at the intersection of Siboney (Moody Street) and Katella Avenue. This proposed sewer line would be an 8-inch line where it commences and would gradually increase in size to a 15-inch line at Sewer Connection B. In addition, as recommended by the Sewer Capacity Study prepared for the proposed project, Lots 10 and 11 located on the north side of Vessels Circle would connect to the existing 8-inch City sewer line located southeast of Lot 11.

The proposed sewer infrastructure would be constructed as a local sewer system and, upon completion, would be dedicated to the City, thereby becoming part of the local public sewer system.

Therefore, only local public sewers would directly connect to existing OC San sewer mains. In addition, the proposed project would obtain all necessary trunk connection permits from OC San prior to constructing the proposed connections to the existing OC San sewer system.

Response to Comment L-1-4
This comment states that utility plans should be submitted to OC San’s Planning Division for review as soon as they are available.

Future development under the proposed project would be required to comply with applicable wastewater service provider requirements and regulations as part of future development. As discussed above and in Section 4.19, Utilities and Service Systems, of the Draft EIR, implementation of the proposed project would include the installation of various new sewer connections to existing sewer main lines and a new 8-inch sewer main line that would run north to south along the proposed Moody Street extension (Sewer Connection B). Consistent with OC San requirements,

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Response to Comment L-1-5
This comment states that the proposed sewer improvements would be located near an existing OC San easement along Lexington Drive and notes that any encroachment into this easement would require an encroachment agreement.

The proposed project would be required to comply with applicable OC San standards and obtain necessary permits and approvals for any work within OC San easements. Accordingly, the project applicant would coordinate with OC San and obtain an encroachment agreement prior to any encroachment into the existing OC San easement along Lexington Drive, if necessary.

Response to Comment L-1-6
This comment provides concluding remarks and contact information.

The City acknowledges this comment and looks forward to future coordination with OC San regarding development of the proposed project.

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Sincerely,
Virginia Gomez, Senior Planner
OC Public Works / OC Development Services
601 North Ross Street
Santa Ana, California 92701
[email protected]
cc: Kylie Sanchez, Land Use Manager, OC Development Services Docusign Envelope ID: 680A4586-A5A1-4424-B08E-C82D9D98B7C3 S PECIFIC PLAN 3.0 B UILDOUT P ROJECT

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2.4.2 ORANGE COUNTY PUBLIC WORKS (OCPW)
Letter Code: L-2
Date: April 17, 2026
Response to Comment L-2-1
This comment states that OC Public works has no comments on the proposed project at this time and provides contact information.

The City acknowledges this comment and looks forward to future coordination with OCPW regarding development of the proposed project.

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BUILDOUT PROJECT
Dear Director Velasco:

Thank you for the opportunity to comment on the Notice of Availability of a Draft Environmental Impact Report (DEIR) for the Specific Plan 3.0 Buildout Project in the City of Cypress. We understand that the final project will analyze the environmental impact associated with the proposed project implementation, assess alternatives, and propose mitigation measures for identified potentially significant impacts to minimize, offset, or otherwise reduce or avoid those environmental impacts.

Particularly concerning the City of Los Alamitos is the scope of the DEIR, which will support adding 1,926 residential unit sites and the possibility of 879, 170 square feet of non-residential area on the edge of Los Alamitos. As a neighbor of the City of Cypress, the City of Los Alamitos supports the City's intent to meet its designated housing allocation, but would like to share concerns with the project's potential impacts on our adjacent community, especially the reports noted significant and unavoidable air quality and transportation impacts that come with increased density in a oncesuburban area, which eventually could significantly impact quality of life. Of the alternatives to the project, the "Historic Preservation Alternative" was considered the Environmentally Superior Alternative, and the City of Los Alamitos would agree that, barring increased housing mandates, this would be the most desirable outcome for the project.

Transportation
In the transportation study, the residential VMT impact would exceed the significance threshold by 10.4 percent. Therefore, the proposed project's VMT impact would be significant and unavoidable. As a further result of these locations slated for increased density near Katella Avenue, the City of Los Alamitos would see a concentration of noise, air quality, and transportation Comment Letter L-3
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impacts due to the increased volume of traffic in and around the project area, as well as traveling to the westbound 605 interstate freeway. The proximity of these new units to the City of Los Alamitos' neighborhoods will create additional cumulative rush-hour congestion and health issues for the City of Los Alamitos' residents, who have already experienced increased traffic from other large housing projects in this area, particularly in the City of Cypress.

Air Quality
As stated in the report, the project would result in a significant and unavoidable impact related to a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable federal or State ambient air quality standard. This would, of course, negatively affect the. residents of Los Alamitos.

Possible Transportation and Air Quality Mitigation
The above large concerns aside, as a couple of small mitigation measures that the City of Los Alamitos would urge, given the increased traffic projected by the DEIR, it is recommended that the City of Cypress request that the Orange County Transportation Authority (OCTA) increase bus connections and frequent bus routes throughout high-traffic periods. It is also suggested that additional bike lane connections be planned as a City policy, such as through an Active Transportation Plan (ATP), with links to the City of Los Alamitos' existing and future bike lanes.

Corrections to the VMT Study
As part of our analysis of the project, our City's Traffic Engineer reviewed the VMT analysis. He has provided comments on the analysis, which are attached to this correspondence. However, he notes that, with this large project, the conclusion is likely to be that the project will have significant and unavoidable impacts.

Thank you again for the opportunity to comment on the Notice of Availability of a Draft Environmental Impact Report (DEIR) for the Specific Plan 3.0 Buildout Project in the City of Cypress. If you have any questions regarding the City's comments, please contact Tom Oliver, Senior Planner, at [email protected] or 562-431-3538 ext. 303.

Sincerely,
?.J�
Ron Noda
Development Services Director
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Notably, page 1 of the County Guidelines states:

This document serves as a guide for application and substantial evidence for the County of Orange's (County) adopted project screenings, significance thresholds, and mitigation strategies, modeled after the Governor's Office of Planning and Research's (OPR) Technical Advisory (TA) for CEQA transportation studies.

Despite this statement, the County's characterization of the 50,000-square-foot threshold diverges in a significant way from the OPR Technical Advisory. Rather than using store-level size as a proxy for travel behavior-as OPR recommends-the County Guidelines apply a more rigid, and unsubstantiated, project-level cutoff that will require a detailed VMT analysis for projects that do not involve regional-serving retail.

The proposed Project assumes approximately 440,000 square feet of retail and other commercial space pursuant to the Specific Plan that is intended to provide retail and other service-oriented uses, as well as a limited amount of other types of commercial space, that enhance access to essential goods and services while supporting local employment opportunities. The 440,000 square feet will be distributed on multiple sites within the Buildout Area in a manner that maintains a local-serving character appropriate for the surrounding community. Because the Project is conceptual buildout under the Specific Plan, specific non-residential tenants have not yet been identified. However, Section 3.3.1 of the Specific Plan outlines the range of permitted retail and other commercial uses, which include, for example, general merchandise stores, financial services, hardware stores, florists, barber /beauty shops, and family entertainment centers with party facilities.

As discussed previously, the County Guidelines adopt a 50,000-square-foot threshold to screen out retail projects presumed to have a less-than-significant VMT impact. However, as noted, the County Guidelines apply this threshold to the total retail floor area rather than on a per-store basis, diverging from the OPR Technical Advisory, which more appropriately applies the 50,000-square-foot threshold to individual stores-flagging large-format tenants ( such as big-box retailers) that might draw regional trips and therefore generate higher VMT.

How about grocery store,
hotel, and offices. It is anticipated th
J"-r��""'��P+l'n�7'-1!�� eve loped as part of the Project will exceed 50,000 square fee ough the total non-residential space will exceed 50,000 square feet, each individual retail tenant is anticipated to fall below the OPR's screening threshold for regional-serving retail uses. In this way, the Project remains consistent with the intended function of the 50,000-square-footthreshold as construed in the Applying this approach, the Project's retail component-comprised of a collection of smaller, neighborhood-oriented stores-would not trigger additional VMT analysis under the OPR Specific Plan 3.0 Buildout Project
Vehicle Miles Traveled Analysis
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framework. Although the County Guidelines take a more conservative position by aggregating total project area, the underlying purpose of the threshold is still met because the Project will primarily serve local demand without inducing substantial new regional vehicle trips.

Therefore, the development of the Project's retail uses should be presumed to result in a lessthan-significant VMT impact.

In addition to retail uses, the non-residential component of the Project may include other uses that are not primarily retail in nature, but are less impactful than retail from a VMT How this was assessed . . . . onclusion that these anticipated hotel or motel uses, like the retail uses, are u • if im act. Non-destination hotels and • •
facilities accommodate overnight travelers and event attende helping to reduce overall trip lengths.
this is a regional trips, and not necessarily Cypress local trips The impact of these uses on the transportation system is generally negligible, and in some cases beneficial, provided they do not significantly alter the local supply, become major introduce substantial new travel demand. None of these conditions are connection with the potential hotel or motel uses associated with the Project. --�l"lo,,t-�U,f't:se uses are also presumed to have a less-than-significant VMT impact.

Notwithstanding that OPR's definition of the 50,000-square-foot threshold is a wellsupported approach that is widely followed in VMT analyses of retail projects throughout California, in recognition of the more conservative approach in the County Guidelines to apply the 50,000-square-foot threshold to total project retail area, a quantitative analysis is provided below, in the section title "Quantitative Retail VMT Analysis and Impact Determination," in accordance with the County Guidelines. As shown therein, even when applying the County's more stringent methodology, the Project's retail component will have a less-than-significant VMT impact, further substantiating the conclusion that the Project's neighborhood-serving retail and other commercial uses do not generate substantial new regional vehicle travel.

3. Low VMT Area Projects
Projects located in areas with low VMT are generally presumed to have a less-than-significant VMT impact. The Buildout Area is within a region where residential uses generate less than 85% of the regional average VMT per capita. However, according to the County Guidelines, this screening criterion does not apply to large projects generating 1,000 or more daily vehicle trips. Since the Project is expected to generate over 1,000 daily vehicle trips, a quantitative VMT analysis is required to accurately assess its impacts, and the Project cannot be screened out based on this criterion.

Land development projects that meet applicable VMT screening criteria may be presumed to have a less-than-significant VMT impact. However, any projects or portions of projects that do not meet Specific Plan 3.0 Buildout Project
Vehicle Miles Traveled Analysis
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In OCT AM, non-residential land uses are modeled using employment estimates categorized as retail, service, or basic employment. Therefore, the retail square footage assumed for the Project was converted to employment estimates based on trip generation-based assumptions. Specifically, �::��:::n�:::a��c�;�t��i�:i
employees per 1,000 square feet. Based on the anticipated land use mix, 90% of non-residential Howlnis was assesse d employment was assigned to the retail category and 10% to service, consistent with expected project uses such as general merchandise, food services, personal care, and small-scale office.

These estimates were added to the baseline household and employment values within T AZ 440 for use in both the existing plus project and cumulative plus project model runs. Employment associated with the existing Los Alamitos Race Course was not included, as the continued operation of the racetrack is not part of the proposed Project. Per applicant input, 95 racecourse-related jobs were excluded from the adjusted baseline.

Table 1 below summarizes the final land use inputs applied to the travel demand model for analysis.

Table 1 - Project Model Inputs
Project Land Use Household Retail Service
Employment Employment
ProjectTAZ 1,791 706 79
Project Home-Based VMT Per Capita For Residential Project Component The residential component of the Project was evaluated using a measurement called Home-Based VMT (Vehicle Miles Traveled) per Capita. This metric estimates the average amount of driving generated by each project resident. The calculation is based on the Production-Attraction (PA) method from the OCTAM model, a tool used to analyze travel behavior. Below are the key steps in this process:

1. Trips Generated: The model first estimates how many trips will start or end at the residential units in the Project. These trips could include commuting to work, going to school, shopping, or participating in other activities.

2. Trip Lengths: The model then calculates the average distance of each trip. Some trips might be short, such as visiting a nearby store, while others might be longer, like driving to a workplace.

3. Travel Mode Selection: Based on the trip's length, purpose, and the availability of different transportation options, the model determines how each trip will be completed-whether by walking, biking, or driving.

4. Total Travel Distance: The model adds up the total distance for trips made by vehicles only.

This total is referred to as the Home-Based Production VMT.

Specific Plan 3.0 Buildout Project
Vehicle Miles Traveled Analysis
- 7 - Kimley-Horn and Associates, Inc.

May2025
L-3-13

• Construct or Improve Bike Facility (CAPCOA Handbook Strategy T-19-A): This mitigation measure would require the Project to include a new bicycle facility or facilities or improve an existing facility that would connect the Project to the existing regional bicycle network. The construction/improvement of bicycle facilities would provide residents with the opportunity to bi-ke to their destination rather than drive, reducing the number of vehicle trips and overall Project-generated VMT.

Provide a map showing the new bike path.

The Project is assumed to include the addition of approximately 1 mile of bicycle facilities, pplying the calculation parameters applicable to the __. .............. _,...._. .............. __ ......... _��---.,.,,.,..-- surroun ing area as provi e in t e P OA Handbook for Measure T-19-A, this improvement is estimated to achieve a 0.1 % reduction in VMT by enhancing active transportation options, increasing network connectivity, and encouraging a shift away from single-occupancy vehicle trips.

Figure 2, on the following page, shows the existing Bikeways per the Orange County Transportation Authority (OCTA) Bikeways map. The segment of Cerritos Avenue, adjacent to the Buildout Area, is an existing Class II Bike facility with buffered bike lanes. West of Denni Street/Lexington Drive and east of Walker Street it is a Class III Bike facility. Denni Street is an existing Class III Bike facility.

Moody Street and Walker Street have existing Class II Bike facilities with a dedicated bike lane. • Provide Pedestrian Network Improvement (CAPCOA Handbook Strategy T-18): This mitigation measure requires the construction of off-site sidewalks to improve sidewalk coverage and pedestrian access to the surrounding area. The construction of such pedestrian facilities would provide residents with the opportunity to walk to their destination rather than drive, reducing the number of vehicle trips and overall Project-generated VMT. The Project will add approximately 1.7 miles of new sidewalks along the Moody Street and Vessels Circle extensions, which will be public streets. From the CAPCOA Guidelines, the recommended study area of 0.6 mile from the project perimeter was used to determine the length of existing off-site sidewalks, within that radius, which is 7.7 miles. The Project will increase the existing study area sidewalk length from 7.7 miles to 9.4 miles, which would reduce VMT by 1.1 % according to the formula provided in the County Guidelines. This estimate assumes moderate improvements to pedestrian infrastructure, such as creating new connections to Moody Street and Vessels Circle, as well as typical safety and accessibility upgrades.

Pedestrian access by sidewalks to the Buildout Area will be from Katella Avenue, Cerritos Avenue, Lexington Drive, and Vessels Circle, as extended. Further pedestrian circulation improvements include sidewalk along the extension of Moody Street south of Cerritos Avenue. These pathways, together with the existing pedestrian infrastructure on the surrounding streets, will ensure seamless integration with the broader pedestrian network, effectively linking the Buildout Area with nearby amenities and transit options
Specific Plan 3.0 Buildout Project
Vehicle Miles Traveled Analysis
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L-3-14
Figure 2 - Existing Bikeways Near Buildout Area
\' yra A.·1e
in (�
c
C ,:,,
w :.,
Co.lh}· Ave
MJrcelloAve
OloaAve
.,..,t·111on Ave
show the project proposed bike facilities and
classifications
w
�
Anl1e .J 1 A11e
Kc::irs.Jr e .A.•1e
T11pol! Av ..

Source: OCTA Orange County Bikeways Map
Cc,
Re IOtd Ave
a
Plaza Dr
p,
Table 5 summarizes the Residential VMT reductions taken from implementing both the T-19-A, Construct or Improve Bike Facility and T-18, Provide Pedestrian Network Improvement, totaling

1.2%. This results in a net increase in Residential VMT % in excess of the significance threshold with mitigation of 10.4%.

Table 5 - Residential VMT Impact with Mitigation
Analysis Scenario
Significance Threshold
flSo/o Below Existing regional average)
VMT % In Excess of Threshold
VMT Reduction from Mitigations
VMT % In Excess of Threshold with Mitigation
Specific Plan 3.0 Buildout Project
Vehicle Miles Traveled Analysis
- 12 -
Home-Based
VMT/Capita

13.21 11.6%

1.2%

10.4%
Kimley-Horn and Associates, Inc.

May2025
L-3-15

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2.4.3 CITY OF LOS ALAMITOS
Letter Code: L-3
Date: April 20, 2026
Response to Comment L-3-1
This comment provides introductory remarks and summarizes the scope of the Draft EIR.

Response to Comment L-3-2
This comment states that although the City of Los Alamitos supports the City of Cypress' intent to meet its designated housing allocation, the City of Los Alamitos has concerns regarding potential impacts on Los Alamitos residents due to the proposed project’s significant and unavoidable air quality and transportation impacts.

The City acknowledges this comment. As discussed in the Draft EIR, implementation of the proposed project would result in significant and unavoidable impacts related to transportation (VMT) and air quality (conflict with applicable air quality management plans and operational air quality emissions).

Although the Draft EIR included Mitigation Measures AIR-1 and TRA-1, which would reduce these impacts, implementation of these measures would not reduce the impacts to less than significant.

Therefore, while air quality and transportation impacts would remain significant and unavoidable, the Draft EIR identifies and prescribes all feasible mitigation measures that would reduce the impact to the extent practicable, as required by CEQA.

Because the comment does not contain any other substantive comments or questions about the environmental analysis or conclusions contained in the Draft EIR, no further response is required.

Response to Comment L-3-3
This comment states that the City of Los Alamitos agrees that the Historic Preservation Alternative is the Environmentally Superior Alternative and that implementation of this alternative would be the most desirable outcome for the proposed project, barring increased housing mandates.

As discussed in Chapter 5.0, Alternatives, of the Draft EIR, the Historic Preservation Alternative would avoid the significant and unavoidable impact to historical resources as defined in Section 15064.5 of the State CEQA Guidelines associated with the proposed project. Therefore, the Draft EIR identified the Historic Preservation Alternative as the Environmentally Superior Alternative.

However, implementation of the Historic Preservation Alternative would still result in significant and unavoidable impacts associated with air quality (conflict with applicable air quality management plans and operational air quality emissions) and transportation (VMT), similar to the proposed project. In addition, although these impacts would still be considered less than significant, impacts related to noise and public services would be greater when compared to the proposed project, as the Historic Preservation Alternative would include the conversion of the Los Alamitos Race Course S PECIFIC PLAN 3.0 B UILDOUT P ROJECT

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2 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\8_Final EIR and RTC\Specific Plan 3.0 Buildout Project_Final EIR RTC_fnl.docx «06/19/26» -84 (LARC) character-defining features, including the original pre-1970 track, the 1954 quarter-mile chute, the infield and ponds, and a portion of the grandstand into a performance venue for future concerts, plays, and other entertainment performances.

Further, as discussed in Chapter 5.0, the Historic Preservation Alternative would not meet the project objectives to the same extent as the proposed project. Specifically, while the Historic Preservation Alternative would facilitate development of 1,400 residential units within the Buildout Area, which would help meet the significant unmet demand for housing in the City and the project vicinity, the Historic Preservation Alternative would result in 391 fewer residential units than the proposed project. In addition, this alternative would require amendments, approved by the voters, to allow for the performance venue within the Specific Plan, which is not a use currently permitted within the Specific Plan area. Therefore, the Historic Preservation Alternative would be inconsistent with the voter-approved Specific Plan.

Because the comment does not contain any other substantive comments or questions about the environmental analysis or conclusions contained in the Draft EIR, no further response is required.

Response to Comment L-3-4
This comment claims that Los Alamitos residents would experience increased traffic, noise, and air quality impacts due to the proposed project’s significant and unavoidable residential VMT impact, which would create additional cumulative rush-hour congestion and health issues for Los Alamitos residents, who have already experiences increased traffic from other large housing projects in the area, particularly in the City of Cypress.

As previously discussed, transportation impacts under CEQA are to be evaluated based on a project’s effect on VMT as opposed to vehicle delay and LOS (i.e., traffic congestion). This change came into effect on December 28, 2018, when the California Office of Administrative Law cleared the revised State CEQA Guidelines for use and removed vehicle delay and LOS from consideration under CEQA. Therefore, the Draft EIR discusses potential VMT impact with implementation of the proposed project. As discussed in Section 4.17, Transportation, of the Draft EIR, the residential component of the proposed project would result in a higher VMT per capita than the County's residential VMT significance thresholds under both existing and cumulative plus project conditions by 11.6 percent. As such, the proposed project would be required to implement feasible Transportation Demand Management (TDM) strategies to mitigate the proposed project’s VMT impact, as detailed in Mitigation Measure TRA-1. However, implementation of Mitigation Measure TRA-1 would only reduce the proposed project’s residential VMT impact by 1.2 percent. Accordingly, even with implementation of the identified TDM strategies, the proposed project’s residential VMT impact would remain significant, with a residential VMT impact of 10.4 percent over the significance threshold. Therefore, the proposed project’s VMT impact would be significant and unavoidable, as identified in the Draft EIR.

Section 4.17 of the Draft EIR also analyzed cumulative transportation impacts, including cumulative VMT impacts associated with the cumulative plus project (2050) scenarios. The cumulative plus project (2050) scenario reflects 2050 conditions with the proposed project incorporated. As discussed in Section 4.17, even with implementation of Mitigation Measure TRA-1, which requires

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P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\8_Final EIR and RTC\Specific Plan 3.0 Buildout Project_Final EIR RTC_fnl.docx «06/19/26» 2-85 inclusion of pedestrian sidewalks and bicycle lanes, the proposed project would result in a significant and unavoidable impact related to residential VMT. Pursuant to the Technical Advisory on Evaluating Transportation Impacts in CEQA prepared by the Governor’s Office of Planning and Research (OPR; now the Governor’s Office of Land Use and Climate Innovation [LCI]),8 if a project individually has a significant VMT impact, then it also has a significant cumulative VMT impact, and vice-versa. Therefore, the proposed project would have a significant and unavoidable cumulative residential VMT impact, while the cumulative impact related to non-residential VMT would be less than significant. Accordingly, the Draft EIR determined that implementation of the proposed project, in addition to other recently completed, planned, and reasonably foreseeable projects within the City and surrounding area, could result in cumulative transportation impacts.

Section 4.13, Noise, of the Draft EIR analyzed potential operational traffic noise impacts. As discussed in Section 4.13 of the Draft EIR, the results of this analysis indicate that the increase in noise associated with project-related traffic, comparing existing without project traffic volumes to existing plus project traffic volumes, would be up to 0.3 A-weighted decibel Community Noise Equivalent Level (dBA CNEL) along the analyzed road segments, located adjacent to the Buildout Area. A noise level increase of less than 3 dBA would not be perceptible to the human ear in an outdoor environment. Because project-related traffic would not result in a perceptible increase (i.e., 3 dBA or greater) in ambient roadway noise levels, off-site traffic noise impacts would be less than significant. In addition, because residents of Los Alamitos would be located further west and south of the analyzed road segments, they would experience less than 0.3 dBA CNEL, which would not be perceptible to the human ear in an outdoor environment. Therefore, implementation of the proposed project and the additional vehicles traveling the vicinity of the Buildout Area would not result in significant noise impacts that would increase health issues for Los Alamitos residents.

As discussed in Section 4.3, Air Quality, of the Draft EIR, the primary emissions associated with the proposed project are regional in nature, meaning that air pollutants are rapidly dispersed on release or, in the case of vehicle emissions associated with the proposed project, emissions are released in other areas of the South Coast Air Basin (Basin). Further, as discussed in Section 4.3, Air Quality, of the Draft EIR, implementation of the proposed project would not expose sensitive receptors, including residential uses in the City of Los Alamitos located west and south of the Buildout Area, to substantial pollutant concentrations with implementation of Mitigation Measure AIR-2, which requires use of USEPA Tier 4 Final or cleaner construction equipment if and to the extent commercially available, or the cleanest available technology that is commercially available and feasible to reduce construction-related diesel particulate matter (DPM) emissions at the source. If Tier 4 Final equipment or cleaner construction equipment is not commercially available for a majority of the construction equipment and the individual development project would be larger than 20 acres, Mitigation Measure AIR-2 requires the preparation of a project-specific construction Health Risk Assessment (HRA), which may identify additional feasible risk-reduction measures for implementation, as appropriate. Therefore, implementation of the proposed project would not expose Los Alamitos residents to substantial pollutant concentrations that would increase health issues for Los Alamitos residents.
8 Governor’s Office of Land Use and Climate Innovation (LCI) (previously the Governor’s Office of Planning and Research [OPR]). 2018. Technical Advisory on Evaluating Transportation Impact In CEQA. April.

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2 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\8_Final EIR and RTC\Specific Plan 3.0 Buildout Project_Final EIR RTC_fnl.docx «06/19/26» -86 Section 4.3 also included an analysis of operational public health effects. Known health effects related to ozone include worsening of bronchitis, asthma, and emphysema and a decrease in lung function. Particulate matter can also lead to a variety of health effects in people. These include premature death of people with heart or lung disease, heart attacks, irregular heartbeat, decreased lung function, and increased respiratory symptoms. Although the emissions from operations resulting from buildout of the proposed project are expected to exceed the SCAQMD’s project level thresholds, it should be noted that exceeding or not exceeding the SCAQMD’s numeric regional mass daily thresholds does not, by itself, directly correlate to a determination regarding health risk impacts on nearby sensitive receptors. The project level thresholds are intended to provide a means of consistency in significance determination within the environmental review process, and do not provide a finding on health risk impacts on nearby sensitive receptors, including residential uses in the City of Los Alamitos located west and south of the Buildout Area.

The SCAQMD acknowledges that it has only been able to correlate potential health outcomes for very large emissions sources; specifically, 6,620 pounds per day (lbs/day) of NOX, and 89,180 lbs/day of VOCs were expected to result in approximately 20 premature deaths per year and 89,947 school absences due to ozone.9 As provided in Section 4.3, with implementation of Mitigation Measure AIR-1 and Mitigation Measure TRA-1, operation of the proposed project would generate a maximum of 37.3 lbs/day of NOX and 104.2 lbs/day of VOCs well below the VOC emission directly corelate to health impacts. Therefore, emissions associated with the proposed project are not sufficiently high to correlate health effects on a Basin-wide level, which includes the City of Los Alamitos. Furthermore, air quality trends for emissions of NOX, VOCs, and ozone (which is a byproduct of NOX and VOCs) have been trending downward within the Basin even as development has increased over the last several years. Therefore, proposed project implementation is not expected to result in any Basin-wide increase in health effects that would reduce neighborhood livability and would therefore not result in health issues for Los Alamitos residents.

The Draft EIR recognizes that emissions of ozone precursors (VOCs) can contribute to regional exceedances of air quality standards and that such exceedances are associated with increased respiratory and cardiovascular symptoms in sensitive populations. However, the proposed project’s emissions are small relative to regional totals and SCAQMD addresses and manages air basin-wide concentrations through its Air Quality Management Plan. Further, the precise concentrations at which VOC would trigger these symptoms for a single project is not currently scientifically feasible. It is also not technically feasible to directly correlate regional emissions to specific localized health public health effects (e.g., the number of asthma cases) from an individual project. In addition, is not scientifically feasible to assess potential impacts on Los Alamitos residents specifically. Accordingly, the Draft EIR discloses these impacts as significant and unavoidable and includes all feasible mitigation measures to minimize emissions during operation, as discussed above. Therefore, while air quality and transportation impacts would remain significant and unavoidable, the Draft EIR identifies and prescribes all feasible mitigation measures that would reduce the impact to the extent practicable, as required by CEQA.
9 Supreme Court of California. 2015. Sierra Club, Revive the San Joaquin, and League of Women Voters of Fresno, Plaintiffs and Appellants, v. County of Fresno, Defendant and Despondent, and Friant Ranch, L.P., Real Part in Interest and Despondent. April.

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P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\8_Final EIR and RTC\Specific Plan 3.0 Buildout Project_Final EIR RTC_fnl.docx «06/19/26» 2-87 Section 4.3 of the Draft EIR also analyzed cumulative air quality impacts, including cumulative health risk impacts. As discussed in Section 4.3, because diesel particulate matter emissions from construction activities would be minimized through required use of Tier 4 Final or cleaner equipment or subject to project-specific review where warranted, the proposed project’s contribution to cumulative localized health risk impacts would not be cumulatively considerable.

Therefore, cumulative impacts related to construction TAC exposure to sensitive receptors would be less than significant with mitigation.

Overall, while air quality and VMT impacts would remain significant and unavoidable, the Draft EIR identifies and prescribes all feasible mitigation measures that would reduce the impact to the extent practicable, as required by CEQA.

Response to Comment L-3-5
This comment claims that the proposed project’ significant and unavoidable impact associated with a cumulatively considerable net increase of criteria pollutants for which the project region is nonattainment under an applicable federal or state ambient air quality standard would negatively impact City of Los Alamitos residents.

As discussed above, while implementation of Mitigation Measure AIR-1 and Mitigation Measure TRA-1 would incorporate design features that would contribute to reducing criteria air pollutant emissions generated during operational activities associated with the full buildout envisioned under the proposed project, the long-term operational VOC emissions associated with the proposed project would cumulatively contribute to the nonattainment designations in the Basin and project impacts would not be lowered below SCAQMD thresholds. Therefore, while air quality impacts would remain significant and unavoidable, the Draft EIR identifies and prescribes all feasible mitigation measures that would reduce the impact to the extent practicable, as required by CEQA.

However, as discussed above, emissions associated with the proposed project are not sufficiently high to correlate health effects on a Basin-wide level, which includes the City of Los Alamitos.

Furthermore, air quality trends for emissions of NOX, VOCs, and ozone (which is a byproduct of NOX and VOCs) have been trending downward within the Basin even as development has increased over the last several years. Therefore, proposed project implementation is not expected to result in any Basin-wide increase in health effects that would reduce neighborhood livability and would therefore not result in significantly impact Los Alamitos residents. Refer to Response to Comment L-3-4, above, for additional discussion.

Response to Comment L-3-6
This comment recommends that in order to address the increased traffic with the proposed project and other projects in the area, the City of Los Alamitos requests that the Orange County Transportation Authority (OCTA) increase bus connections and frequent bus routes during hightraffic periods, and that additional bike lane connections be planned through an Active Transportation Plan (ATP) with links to the City of Los Alamitos’ existing and future bike lanes.

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2 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\8_Final EIR and RTC\Specific Plan 3.0 Buildout Project_Final EIR RTC_fnl.docx «06/19/26» -88 additional bus service through interaction with OCTA and other available resources. Accordingly, the City continually assesses ridership demand and coordinates with OCTA in order to address any deficiencies in service. OCTA has also recently completed the 2024 Orange County Transit Vision Master Plan,10 which aims to integrate, enhance, and expand multimodal transportation services throughout the County and is currently developing the Directions 2050 plan11 to update OCTA’s LRTP. Directions 2050 will look ahead to 2050 and outline strategies to ensure that the County’s transportation system remains efficient, safe, balanced, and sustainable, and addresses the provision of transit services. OCTA’s FY 2025-2026 budget also highlights increased transit service, including adding more bus service to meet rising demand, and investments in transit infrastructure.12 Therefore, the City is already coordinating with OCTA regarding the need for potential transit service improvements. Further, implementation of the proposed project would not interfere with implementation of these transit planning documents, including the specific actions to address the growing need for expanded transit service.

At this time, the City does not have an adopted ATP or plans to prepare an ATP. Because the comment does not contain any other substantive comments or questions about the environmental analysis or conclusions contained in the Draft EIR, no further response is required.

Response to Comment L-3-7
This comment states that the City of Los Alamitos’ Traffic Engineer reviewed the VMT analysis prepared for the proposed project, which is included as Appendix K of the Draft EIR, and has provided comments on the analysis, which are provided as an attachment to the comment letter.

This comment also states that the Traffic Engineer agrees that VMT impacts associated with implementation of the proposed project would be significant and unavoidable.

Specific responses to the comments provided by the City of Los Alamitos’ Traffic Engineer on the Vehicle Miles Traveled (VMT) Analysis for Specific Plan 3.0 Buildout Project (VMT Memo)13 prepared for the proposed project are provided in Response to Comment L-1-9 through Response to Comment L-1-14, below.

Response to Comment L-3-8
This comment provides concluding remarks and contact information.

The City acknowledges this comment and looks forward to future communications with the City of Alamitos regarding development of the proposed project. 10 Orange County Transportation Authority (OCTA). 2025a. 2024 Orange County Transit Vision Master Plan.

May. 11 Orange County Transportation Authority (OCTA). 2025c. OCTA Seeks Public Input to Help Shape Orange County’s Transportation Future. October 3. Website: https://www.octa.net/news/news-releases/octaseeks-public-input (accessed October 2025). 12 Orange County Transportation Authority (OCTA). 2025b. OCTA Approves $1.74 Billion Balanced Budget for FY 2025-26. June 6. Website: https://www.octa.net/news/news-releases/octa-approves-174-billionbalanced-budget-for-fy-2025-26 (accessed October 2025). 13 Kimley-Horn and Associates, Inc. 2025. Vehicle Miles Traveled (VMT) Analysis for Specific Plan 3.0 Buildout Project. May.

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This comment asks if future grocery stores, hotel, or office uses developed as part of the proposed project would exceed 50,000 square feet in size.

The proposed project is the conceptual buildout under Specific Plan 3.0 and no specific future nonresidential tenants or operators have been identified. It is expected that no single retail establishment developed as part of the proposed project, including grocery store, hotel, or office uses, would exceed 50,000 square feet in size. As discussed in the VMT Memo prepared for the proposed project, included as Appendix K to the Draft EIR, even though the proposed project would result in up to 440,000 square feet of non-residential uses, each individual retail tenant is anticipated to fall below the Office of Land Use and Climate Innovation’s (LCI) screening threshold for regional-serving retail uses. Therefore, the proposed project would be consistent with the intended function of the 50,000-square-foot threshold, as construed in the appropriate technical advisory, and VMT impacts associated with future retail establishments are presumed to be less than significant.

Regardless, the VMT Memo assessed potential impacts related to retail uses larger than 50,000 square feet and found that even if the retail use exceeds the 50,000 square foot threshold (like a grocery store), the proposed project would still have a net reduction in VMT. Table 4 in Appendix K of the Draft EIR shows that the Retail VMT would be less than significant. Hotel uses are not assessed using the travel demand model since the model does not have a specific hotel land use to include. A qualitative analysis was completed for hotel uses, as discussed in more detail in Response to Comment L-3-10, below. Office uses are assumed to be within 10 percent of the proposed retail uses, however these office uses are anticipated to be customer-based rather than employee-based and therefore have similar VMT results.

Response to Comment L-3-10
This comment asks how the qualitative VMT assessment of the other potential non-residential uses that could be developed within the Buildout Area that are not primarily retail in nature, such as hotels or motels, was assessed.

The VMT Memo prepared for the proposed project included a qualitative VMT assessment based on the anticipated travel characteristics of the potential hotel or motel use within the Buildout Area.

The analysis assumed a hotel/motel use would be non-destination in nature and would serve travelers already moving within or through the region, which is pre-determined based on their final destination. This assessment was not restricted to trips within the City of Cypress only and is a reasonable assumption based on the final destination being a family visit, business visit to nearby offices, or central location to Southern California attractions.

Response to Comment L-3-11
This comment appears to note that although non-destination hotels and motels do accommodate overnight travelers and event attendees already in the region, these uses would reduce overall trip lengths in the region and not necessarily local vehicle trips within the City of Cypress.

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2 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\8_Final EIR and RTC\Specific Plan 3.0 Buildout Project_Final EIR RTC_fnl.docx «06/19/26» -90 For VMT purposes, the relevant question is whether the use would generate substantial new regional travel or increase trip lengths compared with existing travel patterns. Non-destination hotels and motels typically accommodate travelers who are already in the region for business, events, freeway travel, or other purposes. Therefore, these types of lodging facilities generally capture or redistribute existing regional lodging demand rather than creating a new major destination that would induce additional long-distance travel. In some cases, providing lodging near a traveler’s destination or travel route can reduce overall trip length compared with lodging located farther away.

Therefore, although the anticipated vehicle trips may be regional in nature and not necessarily local to the Cypress area, the anticipated hotel or motel use is not expected to substantially increase VMT as it would not significantly alter regional lodging supply, function as a major attraction, or introduce substantial new travel demand.

Response to Comment L-3-12
This comment asks for clarification regarding how the internal trip capture was determined in the project-specific VMT analysis if the retail portion of the proposed project cannot be determined at this time.

The VMT model identifies project land use input as a general retail use and does not require the specific type of retail be identified. The model is a trip-based travel demand model that simulates travel behavior based on socio-economic data, including household, population, employment characteristics and proximities between different land uses type, to estimate trip generation and mode choice. In addition, the model includes residential and retail land uses within the project zone which accounts for internal capture within the zone.

Response to Comment L-3-13
This comment asks how the retail employment rate of approximately two employees per 1,000 square feet was assessed.

The retail employment rate of approximately two employees per 1,000 square feet is derived using the Institute of Transportation Engineers (ITE) Trip Generation Manual for General Retail uses. Based on an equal combination of the ITE trip rates by square feet and trip rates by number of employees, the proposed project is forecast to generate approximately two employees per 1,000 square feet.

Response to Comment L-3-14
This comment requests a map that shows the proposed new bike facilities associated with the proposed project be provided.

Figure 2 in the VMT Memo prepared for the proposed project has been revised to include the planned Class II On-Road bike path that would bisect the Buildout Area connect Cerritos Avenue and Katella Avenue and the planned Class III On-Road bike path that would extend west from Walker Street. Refer to Section 3.0, Errata, of this Final EIR.

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P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\8_Final EIR and RTC\Specific Plan 3.0 Buildout Project_Final EIR RTC_fnl.docx «06/19/26» 2-91 The Draft EIR analyzed buildout of the Specific Plan within the Buildout Area at a “programmatic” level. Because the proposed project is examined at a programmatic level, the Draft EIR only discusses and analyzes the overarching, “maximum development” scenario and the specific future development projects and associated future bicycle infrastructure are not discussed in the Draft EIR because they cannot be determined at this time. Future development projects associated with implementation of the proposed project would be reviewed by the City on a project-by-project basis in order to ensure that the proposed development is consistent with the Specific Plan. Specifically, through the design review process, future development projects would be required to submit a detailed site plan that depicts the bicycle facilities that would be included in each development, consistent with the Specific Plan.

Response to Comment L-3-15
This comment requests that Figure 2, Existing Bikeways Near Buildout Area, in the VMT analysis memorandum show the proposed new bike facilities and classifications associated with the proposed project.

As noted in the Response to Comment L-3-15, Figure 2 in the VMT Memo prepared for the proposed project in Appendix K of the EIR has been revised to include the planned Class II On-Road bike path that would bisect the Buildout Area and connect Cerritos Avenue and Katella Avenue and the planned Class III On-Road bike path that would extend west from Walker Street. Refer to Section

3.0, Errata, of this Final EIR.

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April 30, 2026
Alicia Velasco, Planning Director
City of Cypress Community Development Department, Planning Division 5275 Orange Avenue
Cypress, California 90630
RE: NOTICE OF AVAILABILITY OF A DRAFT ENVIRONMENTAL IMPACT REPORT FOR THE SPECIFIC PLAN 3.0 BUILDOUT PROJECT
Dear Alicia Velasco,
Thank you for providing the Notice of Availability for the Specific Plan 3.0 Buildout Project Draft EIR (“Project”), in the City of Cypress (“City”). City of Garden Grove Staff have reviewed the available documents, and the following comments are provided for your consideration:
 The Draft EIR assumes approximately 50% buildout of the non-residential floor area (440,000 sq. ft. of the 879,170 sq. ft. of maximum development capacity that would be approved under the Specific Plan). [DEIR at pp. 1-2, 3-14.] To support this assumption, the Draft EIR states:
“[I]t is anticipated that, based on current and reasonably foreseeable future market conditions, the buildout of the Buildout Area will include substantially less than 879,170 square feet of non-residential development. Therefore, the environmental analyses in this Draft EIR are based in part on the assumption that only 440,000 square feet of non-residential development will occur within the Buildout Area. This represents approximately 50 percent of the maximum amount of permitted non-residential development.” [DEIR at pp. 1-2, 3-14.] The Draft EIR does not explain its methodology for arriving at the 50% figure. While the City of Cypress is “not required to engage in speculation in order to analyze a ‘worst case scenario’” (see Napa Citizens for Honest Government v. Napa County Bd. of Supervisors (2001) 91 Cal.App.4th 342, 373), the City must support its 50% buildout assumption with substantial evidence under CEQA Guidelines Section 15384.

The City should provide greater support for its assumption that only 50% of the nonresidential development will be built out.

The Draft EIR adds: “If non-residential development that cumulatively exceeds 440,000 square feet is later proposed within the Buildout Area, additional environmental review in accordance with the provisions of CEQA and the State CEQA Guidelines may be required if and to the extent such non-residential development requires any discretionary action by the City.” [DEIR at p. 3-14.] However, it is unclear what additional “discretionary action by the City” (as opposed to ministerial approval) Comment Letter L-4
L-4-1
L-4-2
L-4-3
Specific Plan 3.0 Draft EIR Notice of Availability Page 2 would be necessary if the Specific Plan allowing a maximum buildout of 879,170 square feet of non-residential development is approved.
 In reviewing the Level of Service (LOS) analysis, it is noted that LOS at the Valley View Street and SR-22 ramp intersections degrades from LOS C under existing conditions to LOS D under Buildout Year 2038 conditions. These intersections serve as critical access points to the SR-22 Freeway and provide connectivity to the I-405 Freeway. As such, they are particularly sensitive to increases in traffic volumes and delay. While LOS D may be considered acceptable, degradation at freeway ramp intersections is concerning because it can lead to:
o Increased queuing and potential spillback onto Valley View Street o Reduced efficiency of traffic progression along the corridor o Impacts to upstream intersections, including those within Garden Grove In addition, the current analysis does not appear to account for corridor-level operational behavior along Valley View Street. As a major north-south arterial that is signal-coordinated, changes in traffic volumes can have broader system effects beyond a single intersection. Incremental increases in traffic can:
o Disrupt signal progression
o Break up vehicle platoons
o Increase stops and delays across multiple intersections o Create cumulative impacts along the corridor
These effects are particularly relevant at key downstream intersections such as:
o Valley View Street / Chapman Avenue
o Valley View Street / Lampson Avenue
o Valley View Street / West Grove Avenue
Given that project traffic traveling southbound on Valley View Street must pass through these ramp intersections to access the regional freeway system, even a modest increase in volume can contribute to cumulative operational impacts.

Accordingly, the City requests that the analysis be expanded to include the following downstream intersections within Garden Grove to better evaluate corridor-level and freeway access impacts:
o Valley View Street / Chapman Avenue
o Valley View Street / West Grove Avenue
o Valley View Street / Belgrave Avenue
o Valley View Street / Lampson Avenue
o Valley View Street / Cerulean Avenue
There are additional concerns that the assumed buildout of non-residential floor area will is only at 50%. Should the entirety of the approve 879,170 square feet of nonresidential floor area be built out, the added non-residential uses will also contribute to further degradation of LOS on Valley View Street.

If you have any questions, please contact me at (714) 741-5303 or [email protected].

Sincerely,
Priit Kaskla, AICP
Senior Planner
L-4-4
L-4-5
L-4-6
L-4-7
L-4-3
cont.

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2.4.4 CITY OF GARDEN GROVE
Letter Code: L-4
Date: April 30, 2026
Response to Comment L-4-1
This comment provides introductory remarks and states that the City of Garden Grove has reviewed the Draft EIR.

Response to Comment L-4-2
This comment asks the City to provide greater support for its assumption that only approximately 50 percent (approximately 440,000 square feet) of the total maximum non-residential development capacity approved under the Specific Plan (879,170 square feet) would be built out.

As discussed in Chapter 3.0, Project Description, of the Draft EIR, the Specific Plan permits an aggregate maximum of 879,170 square feet of non-residential floor area within the Buildout Area.

However, the application submitted to the City by the Applicant for buildout of the Buildout Area under the Specific Plan proposes approximately 440,000 square feet of non-residential area. As such, the proposed project evaluated in the Draft EIR is based in part on the assumption that only 440,000 square feet of non-residential development will occur within the Buildout Area. The amount of anticipated non-residential floor area is based on current and reasonably foreseeable future market conditions. Accordingly, the buildout of the Buildout Area as well as the associated Development Agreement will include substantially less than 879,170 square feet of non-residential development.

Response to Comment L-4-3
This comment refers to page 3-14 of the Draft EIR, which states that additional environmental review may be required if and to the extent that cumulative non-residential development exceeds 440,000 square feet, and states that it is unclear what additional discretionary action would be necessary if the Specific Plan allows a maximum buildout of 879,170 square feet of non-residential development is approved.

Future development projects associated with implementation of the proposed project would be required to submit development applications for review and approval by the City. Through this application review process, the City would monitor and track the cumulative non-residential development within the Buildout Area to ensure that it would not exceed the 440,000 square foot assumption that was analyzed in the Draft EIR. If future buildout exceeds 440,000 square feet of non-residential floor area, each future applicant for a project that would cause the overall nonresidential floor area within the Buildout Area to exceed, or further exceed, 440,000 square feet, would be required to prepare and submit to the City supplemental studies and analysis, which may include additional environmental review pursuant to CEQA, for such a project. In addition, if future S PECIFIC PLAN 3.0 B UILDOUT P ROJECT

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Response to Comment L-4-4
This comment states that according to the LOS analysis prepared for the proposed project, the LOS at the Valley View Street and SR-22 ramp intersections degrades from LOS C under existing conditions to LOS D under Buildout Year 2038 conditions, which could lead to degradation at the freeway ramp intersection.

The City acknowledges this comment. As previously discussed, transportation impacts under CEQA are to be evaluated based on a project’s effect on VMT as opposed to vehicle delay and LOS. This change came into effect on December 28, 2018, when the California Office of Administrative Law cleared the revised State CEQA Guidelines for use and removed vehicle delay and LOS from consideration under CEQA. Because the additional corridor-level operational analysis requested by the City of Garden Grove is also related to LOS, it is also not required by CEQA.

Consistent with CEQA requirements, potential transportation impacts were assessed based on project-specific VMT analysis, as provided in the VMT Memo prepared for the proposed project.

However, the Traffic Study prepared for the proposed project, which is not included in the Draft EIR, was prepared consistent with the Orange County Congestion Management Program (CMP) and addressed potential LOS impacts with implementation of the proposed project. Because the comment does not contain any substantive comments or questions about the environmental analysis or conclusions contained in the Draft EIR, no further response is required.

Response to Comment L-4-5
This comment states that the LOS analysis does not appear to account for corridor-level operational behavior along Valley View Street, and requests that the LOS analysis be expanded to include several downstream intersections within the City of Garden Grove to better evaluate corridor-level and freeway access impacts.

The City acknowledges this comment. As discussed above, transportation impacts under CEQA are evaluated based on a project’s effect on VMT, not LOS. Because the comment does not contain any substantive comments or questions about the environmental analysis or conclusions contained in the Draft EIR, no further response is required.

Response to Comment L-4-6
This comment claims that should the entirety of the approved 879,170 square feet of nonresidential floor area be built out, the added non-residential uses would also contribute to further degradation of LOS on Valley View Street.

The City acknowledges this comment. As discussed above, transportation impacts under CEQA are evaluated based on a project’s effect on VMT, not LOS. Further, as discussed above, the City would monitor and track the cumulative non-residential development within the Buildout Area to ensure that it would not exceed the 440,000 square foot assumption that was analyzed in the Draft EIR. If

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Response to Comment L-4-7
This comment provides contact information.

The City acknowledges this comment and looks forward to future communications with the City of Garden Grove regarding development of the proposed project.

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2.5 INDIVIDUALS
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From: ernesto munoz
To: Alicia Velasco
Cc: City Council
Subject: Comment on Draft Los Alamitos Race Track EIR – Specific Plan 3.0 Buildout Project (Opposition and Request for Reduced-Density Alternative)
Date: Monday, April 20, 2026 8:02:41 PM
Dear Ms. Velasco, Planning Director, Commissioners, and honorable City Council Members, My name is Ernesto Muñoz. I am a registered Civil Engineer in the State of California, a 32- year resident of the City of Cypress, and a former member of the City’s engineering staff.

I am writing to formally comment on the Draft Environmental Impact Report (EIR) for the Specific Plan 3.0 Buildout Project and Housing Element implementation.

Based on both my professional background and long-term familiarity with Cypress infrastructure and traffic patterns, I must respectfully oppose the project as currently proposed.

1. Traffic and Vehicle Miles Traveled (VMT) Impacts
The VMT analysis prepared by Kimley-Horn indicates a substantial increase in total vehicle miles traveled associated with the nearly 1,800 proposed residential units. From an engineering and practical standpoint, this translates directly into increased congestion on key arterial and collector roadways serving the project area and surrounding neighborhoods.

Of particular concern are the cumulative impacts to intersections and corridors that already experience peak-hour congestion, including:

Katella Avenue & Valley View Street
Katella Avenue & Walker Street
Lincoln Avenue & Valley View Street
Lincoln Avenue & Walker Street
Ball Road & Valley View Street
In addition, local neighborhood circulation near my residence—including connections feeding into Valley View Street and Lincoln Avenue—will experience increased cut-through traffic as drivers seek to avoid congested arterials. These are not speculative concerns; they reflect welldocumented driver behavior patterns in built-out suburban systems under added demand.

Under CEQA, VMT is used precisely because it correlates with congestion, emissions, and environmental degradation. The increase identified in the EIR is therefore a clear indicator of significant and unavoidable impacts.

2. Air Quality, Greenhouse Gas, and Quality of Life Impacts Increased VMT will directly result in:

Comment Letter I-1
I-1-1
I-1-2
I-1-3
Higher greenhouse gas emissions
Degradation of local air quality
Increased noise levels and reduced neighborhood livability These impacts are inconsistent with the City’s long-standing goals of maintaining a safe, stable, and high-quality residential environment. Cypress is largely built out, and incremental increases of this magnitude have disproportionate effects on both infrastructure and quality of life.

3. Professional Concern Regarding Scale and Infrastructure Capacity Based on my experience as a civil engineer and former City staff member, the proposed scale —approaching 1,800 units—represents an intensity of development that exceeds what the existing circulation network can reasonably absorb without substantial degradation of service levels and community character.

While I recognize the City’s obligations under RHNA, those obligations do not require maximizing density at every opportunity without balancing infrastructure constraints and environmental impacts.

4. Failure to Adequately Evaluate a Reasonable Reduced-Density Alternative CEQA requires a good-faith evaluation of feasible alternatives that can reduce significant impacts. A reduced-density alternative has not been meaningfully advanced as a preferred option.

I respectfully request that the City evaluate and adopt a reduced-density alternative consisting of approximately 1,253 units (a 30% reduction from the proposed ~1,800 units). This alternative would:

Reduce VMT and peak-hour traffic volumes
Improve intersection performance and reduce cut-through traffic Lower greenhouse gas emissions and air quality impacts
Better preserve neighborhood character and quality of life Importantly, such a reduction would still allow the City to make substantial progress toward meeting its housing obligations while mitigating the most severe impacts.

5. Request for Project Revision and Recirculation
Given the magnitude of the impacts identified, I respectfully request that the City:

Revise the project to incorporate a reduced-density alternative (~1,253 units) Fully analyze this alternative in a recirculated EIR
Incorporate meaningful VMT-reduction strategies and enforceable mitigation measures Reevaluate the project’s consistency with infrastructure capacity and community character

6. Conclusion
As both a professional engineer and long-time resident, I believe the current proposal places an undue burden on Cypress’s transportation network and overall livability. A reduced-density I-1-3
cont.

I-1-4
I-1-5
I-1-6
I-1-7
alternative represents a reasonable and necessary path forward that better balances state housing requirements with local environmental and community considerations.

Thank you for your time and consideration of these comments.

Sincerely,
Ernesto Muñoz, P.E.
10496 Julie Beth Circle
Cypress, CA 90630
I-1-7 cont.

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2.5.1 ERNESTO MUÑOZ
Letter Code: I-1
Date: April 20, 2026
Response to Comment I-1-1
This comment provides introductory remarks and states that the commenter opposes the proposed project as currently designed.

Response to Comment I-1-2
This comment claims that the substantial increase in total VMT associated with implementation of the proposed project would translate into increased congestion on roadways serving the project area and surrounding neighborhoods and would result in a significant and unavoidable impact related to VMT, congestion, emissions, and environmental degradation.

VMT measures the amount of driving a project is expected to generate compared to the regional average. It looks at the average number of miles people travel each day for activities like commuting, shopping, and errands. Under CEQA, VMT is used to evaluate a project’s transportation impacts as well as impacts on air quality and greenhouse gas emissions, since more travel generally results in more pollution. Projects located near jobs, shops, and public transit tend to have lower VMT, while those in more auto-dependent areas tend to have higher VMT. Importantly, VMT does not measure traffic congestion or roadway conditions. It focuses on how far people travel, not how traffic flows. As previously discussed, transportation impacts under CEQA are to be evaluated based on a project’s effect on VMT as opposed to vehicle delay and LOS. This change came into effect on December 28, 2018, when the California Office of Administrative Law cleared the revised State CEQA Guidelines for use and removed vehicle delay and LOS from consideration under CEQA.

As discussed in Section 4.17, Transportation, of the Draft EIR, the proposed project’s non-residential component is presumed to result in a less than significant VMT impact as future non-residential development under the proposed project would qualify as a neighborhood-serving retail development under the LCI Technical Advisory. A supplemental quantitative analysis was also conducted in accordance with the County Guidelines that confirmed that the proposed project’s non-residential uses would result in a less than significant VMT impact, supporting the conclusion that the proposed project satisfies both the intent and technical requirements for VMT screening.

However, the residential component of the proposed project would result in a higher VMT per capita than the County's residential VMT significance thresholds under both existing and cumulative plus project conditions by 11.6 percent. As such, the proposed project would be required to implement feasible TDM strategies to mitigate the proposed project’s VMT impact, as detailed in Mitigation Measure TRA-1. These VMT reduction measures include constructing or improving bicycle facilities that would connect the proposed project to the existing regional bicycle network and improving the pedestrian network, including the construction of off-site sidewalks to improve S PECIFIC PLAN 3.0 B UILDOUT P ROJECT

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Refer to Response to Comments R-1-2 and L-3-5, above for a discussion of air quality emissions and the mitigation measures prescribed to reduce potential impacts. Overall, even with the implementation of potential VMT reductions required in Mitigation Measure TRA-1, VOC emissions would remain above the SCAQMD thresholds. As there are no additional feasible mitigation measures that would reduce project operational-source VOC emissions to a less than significant level proposed project operation would result in a significant and unavoidable impact related to a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable federal or State ambient air quality standard, as identified in the Draft EIR.

However, it should be noted that implementation of the proposed project would not result in any significant impacts associated with greenhouse gas (GHG) emissions, as discussed in Section 4.8, Greenhouse Gas Emissions, of the Draft EIR. As discussed in Section 4.8, the proposed project would be consistent with the land use and growth assumptions underlying the Southern California Association of Governments’ (SCAG) Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) (Connect SoCal 2024) and would implement planned housing growth identified in the City’s adopted and California Department of Housing and Community Development (HCD)- certified Housing Element. The project’s GHG emissions were quantitatively estimated for both construction and operational phases in accordance with State CEQA Guidelines Section 15064.4 and were evaluated in the context of statewide regulatory programs, regional emissions reduction strategies, and project-specific mitigation measures. The CARB 2022 Climate Change Scoping Plan was used as statewide policy guidance to inform the analysis. The City considered the project’s overall consistency with statewide and regional emissions reduction trajectories, including implementation of State-mandated housing growth within a CARB-certified regional planning framework. With implementation of Mitigation Measure GHG-1, Mitigation Measure AIR-1, and Mitigation Measure TRA-1, the project’s incremental contribution to cumulative GHG emissions would not be cumulatively considerable. Therefore, impacts related to the generation of GHG emissions, either directly or indirectly, and potential conflict with applicable plans, policies, or regulations adopted to reduce greenhouse gas emissions would be less than significant with mitigation.

As summarized above, the Draft EIR adequately analyzed and identified potential impacts associated with air quality emissions, GHG emissions, and transportation (VMT) and identified all feasible mitigation measures to reduce the significant impacts to the greatest extent practicable. Therefore, while air quality and transportation impacts would remain significant and unavoidable, the Draft EIR identifies and prescribes all feasible mitigation measures that would reduce the impact to the extent practicable, as required by CEQA.

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This comment claims that the increased VMT associated with implementation of the proposed project would directly result in increased GHG emissions, the degradation of local air quality, increased noise levels, and reduced neighborhood livability, which is inconsistent with the City’s long-standing goals of maintaining a safe, stable, and high-quality residential environment.

As previously discussed, implementation of the proposed project would result in a significant and unavoidable VMT impact associated with the proposed residential uses, even with implementation of the VMT reduction strategies provided in Mitigation Measure TRA-1. Increased VMT would result in increased GHG emissions and traffic noise and could result in the degradation of local air quality, all of which could impact neighborhood livability. The proposed project’s potential impacts associated with GHG emissions, noise, and local air quality are discussed below. Overall, as further discussed below, although the proposed project would result in a significant and unavoidable VMT impact, this would not result in other significant impacts related to GHG emissions, traffic noise, and local air quality that would substantially reduce neighborhood livability.

As discussed above, although implementation of the proposed project would increase GHG emissions during project construction and operation, the proposed project would be consistent with the land use and growth assumptions underlying Connect SoCal 2024 and would implement planned housing growth identified in the City’s adopted and HCD-certified Housing Element. Additionally, the City considered the project’s overall consistency with statewide and regional emissions reduction trajectories, including implementation of State-mandated housing growth within a CARB-certified regional planning framework. The analysis found that the proposed project would be consistent with all statewide and regional emissions reduction trajectories and would not conflict with CARB’s 2022 Scoping Plan as the proposed project would not conflict with the key project attributes provided in the 2022 Scoping Plan related to transportation electrification, VMT reduction, and building decarbonization. Therefore, impacts related to the generation of GHG emissions, either directly or indirectly, and potential conflict with applicable plans, policies, or regulations adopted to reduce greenhouse gas emissions would be less than significant with implementation of Mitigation Measure GHG-1, Mitigation Measure AIR-1, and Mitigation Measure TRA-1. Therefore, implementation of the proposed project would not result in significant GHG emissions that would reduce neighborhood livability.

In addition, as discussed above, implementation of the proposed project would result in a significant and unavoidable impact related to operational air quality emissions, even with implementation of Mitigation Measure AIR-1 and Mitigation Measure TRA-1. These potential impacts have been adequately analyzed and identified in the Draft EIR and all feasible mitigation measures to reduce these impacts to the greatest extent practicable have been identified and prescribed in the Draft EIR, as required by CEQA. However, as discussed in Section 4.3, Air Quality, of the Draft EIR, implementation of the proposed project would not expose sensitive receptors, such as residential uses, to substantial pollutant concentrations with implementation of Mitigation Measure AIR-2, which requires use of USEPA Tier 4 Final or cleaner construction equipment if and to the extent commercially available, or the cleanest available technology that is commercially available and feasible to reduce construction-related diesel particulate matter (DPM) emissions at the source. If Tier 4 Final equipment or cleaner construction equipment is not commercially available for a S PECIFIC PLAN 3.0 B UILDOUT P ROJECT

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Refer to Response to Comment L-3-4, above for a discussion of the proposed project’s anticipated operational public health effects. Overall, as previously discussed, proposed project implementation is not expected to result in any Basin-wide increase in health effects that would reduce neighborhood livability.

The Draft EIR also recognizes that emissions of ozone precursors (VOCs) can contribute to regional exceedances of air quality standards and that such exceedances are associated with increased respiratory and cardiovascular symptoms in sensitive populations. However, the proposed project’s emissions are small relative to regional totals and SCAQMD addresses and manages air basin-wide concentrations are addressed through the SCAQMD’s Air Quality Management Plan. Further, the precise concentrations at which VOCs would trigger these symptoms for a single project is not currently scientifically feasible. It is also not technically feasible to directly correlate regional emissions to specific localized health public health effects (e.g., the number of asthma cases) from an individual project. Accordingly, the Draft EIR discloses these impacts as significant and unavoidable and includes all feasible mitigation measures to minimize emissions during operation, as discussed above.

Overall, the Draft EIR adequately analyzed and identified potential impacts associated with air quality emissions, GHG emissions, and noise, disclosed their potential impact on surrounding neighborhoods, and identified all feasible mitigation measures to reduce the significant impacts to the greatest extent practicable, as required by CEQA. Implementation of identified mitigation measures would further the City’s long-standing goals of maintaining a safe, stable, and high-quality residential environment while allowing for development of new residential and non-residential uses to help meet the unmet demand for housing in the City and the project vicinity, consistent with the with the City’s Housing Element, Regional Housing Needs Allocation (RHNA) requirements, and the voter-approved Specific Plan.

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This comment claims that the scale of the proposed project would exceed what the existing circulation network can reasonably absorb without substantial degradation of service levels and community character.

As previously discussed in the Response to Comment I-1-2, transportation impacts under CEQA are to be evaluated based on a project’s effect on VMT as opposed to vehicle delay and LOS.

Accordingly, the Draft EIR does not consider degradation of LOS as part of the transportation analysis. In addition, the City’s Public Works Department has already assessed the potential impacts to transportation infrastructure with implementation of the proposed project and identified a range of infrastructure improvements to ensure that the surrounding roadways would be able to accommodate the additional vehicles associated with operation of the proposed project.

As described in Chapter 3.0, Project Description, of the Draft EIR, the Specific Plan allows a maximum of 1,791 residential units and, for purposes of the environmental review in the Draft EIR, up to 440,000 square feet of non-residential development within the Buildout Area. As discussed in Section 4.1, Aesthetics, of the Draft EIR, this proposed development density within the Buildout Area would be higher than what currently exists. However, the Specific Plan provides specific development standards for residential and mixed-use development, including maximum structure height and setback requirements, which would be applicable to the future development under the proposed project. As provided in Table 3-1 of the Specific Plan, future single-family detached residential structures shall not exceed 35 feet and 2 stories, and future single-family attached residential structures shall not exceed 35 feet and 3 stories. In addition, future senior housing structures shall not exceed 35 feet in height, and future structures within the mixed-use district shall not exceed 75 feet in height.

Existing development in the vicinity of the Buildout Area includes residential and commercial buildings that generally range in height from one to three stories. In addition, some surrounding development, such as the Homewood Suites and the Acadia Apartments located approximately 800 feet south of the Buildout Area, exceed three stories and approach 75 feet in height. As such, the development allowed in the Buildout Area pursuant to the Specific Plan would be consistent with the mass and scale of existing development near the Buildout Area. In addition, future development facilitated by the proposed project would be required to adhere to the development and design guidelines contained in the Specific Plan, including landscaping requirements and those related to size and scale of the future buildings.

Therefore, while the proposed project would change the aesthetic character of the Buildout Area due to an increase in proposed development density, all development pursuant to the Specific Plan would be required to comply with all relevant sustainable design strategies stated or referenced in the Specific Plan and would be required to comply with the design regulations in the City’s Zoning Ordinance that relate to scenic quality. Therefore, implementation of the proposed project at the scale proposed would not result in significant impacts related to community character.

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This comment claims that the Draft EIR does not adequately analyze a reduced density alternative and requests that the City evaluate and adopt a reduced density alternative consisting of approximately 1,253 units (a 30 percent reduction from the proposed project). This comment also claims that the implementation of a reduced density alternative would reduce VMT and peak-hour traffic volumes, improve intersection performance and reduce cut-through traffic, lower GHG emissions and air quality impacts, and better preserve neighborhood character and quality of life, while still allowing the City to make substantial progress toward meeting its housing obligations.

Refer to Section 2.1.3, Reduced Development Alternative, for the Master Response to comments regarding implementation of a reduced development alternative and associated impacts.

Response to Comment I-1-6
This comment requests that the City revise the proposed project to incorporate a reduced density alternative, revise the Draft EIR to fully analyze a reduced density alternative, incorporate meaningful VMT-reduction strategies and enforceable mitigation, reevaluate the project’s consistency with infrastructure capacity and community character, and recirculate the Draft EIR.

As discussed in Section 2.1.2, Reduced Development Alternative above, the Draft EIR included a full analysis of a reduced density alternative (Reduced Density Alternative [30% Reduction]). The Draft EIR also identified and prescribed all feasible mitigation requiring VMT reduction strategies be incorporated into future development of the proposed project (Mitigation Measure TRA-1) and included a consistency evaluation related to community character, as discussed above. Further, as noted above, LOS is no longer the standard for evaluating a project’s potential impact on transportation, and the Draft EIR included a project-specific VMT Memo. Therefore, the Draft EIR adequately analyzes all potential project impacts and includes all feasible mitigation measures, as necessary and required by CEQA. No revisions to the Draft EIR are necessary and recirculation of the Draft EIR is not required.

Response to Comment I-1-7
This comment provides concluding remarks and summarizes the comments discussed above.

The City acknowledges this comment. Because the comment does not contain any new substantive comments or questions about the environmental analysis or conclusions contained in the Draft EIR, beyond those provided and responses to above, no further response is required. Refer to Response to Comment I-1-2 through Response to Comment I-1-6, above.

From: George Pardon
To: Alicia Velasco
Cc: City Council
Subject: Draft EIR for Cypress Town Center and Commons Specific Plan 3.0 Buildout Project Date: Sunday, April 26, 2026 10:37:26 PM
Dear Planning Director Velasco,
I am writing to convey my concerns with the above referenced EIR.

With traffic already increasing on other streets in Cypress as drivers seek alternatives to Katella Ave, I was alarmed to read that the proposed project anticipates that Vehicle Miles Traveled (VMT) will be 11.6% over the significance threshold. Even with proposed mitigations, VMT would be 10.4% over the significance threshold. This VMT is higher per capita than the County's residential VMT. While the EIR indicates the proposed project's VMT impact would be significant, the EIR also says it is unavoidable although one alternative project proposed would reduce the number of residential units by 30% from almost 1,800 units to 1,253 units.

What’s interesting is that this reduced scope would be very close to the scope previously approved by residents prior to Measure S. It’s unfortunate that this EIR information was not provided before residents were asked to vote on Measure S. It’s also unfortunate that a community meeting has not been held by the city to discuss the impacts of this proposed project. Another significant problem with Measure S is that residents were only given the option of putting 676 more units on the race course or 766 more units in the Lincoln Avenue Specific Plan. When asked about options in the business park area, the city simply responded that those businesses weren’t interested. The residents were not given the option of ‘None of the Above’ in Measure S.

Another concern is that this plan continues to refer to the Cypress Town Center yet with this added density, the development of a town center with the retail, restaurants, and entertainment that was proposed in the previous ballot measure is unlikely. Unfortunately, the likely loss of a town center was not mentioned in Measure S.

The scope of this project should be revisited because the Housing Element that added the 676 units to the race course was developed during the Covid-19 pandemic which limited significant public input. The Housing Element states that “Due to the Covid-19 pandemic, all workshops were held virtually through the Webex video conference platform.” I also think there would be value in evaluating if there are additional land use alternatives that may have come about since the pandemic.

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I believe the best choice would be for the City Council to approve the alternative that reduces the number of residential units by 30%. I understand that if the reduced number of units is approved by the City Council, the State will likely require the units to be zoned somewhere else. If other locations are considered, there is no reason why the only alternative needs to be the Lincoln Avenue Specific Plan as proposed in Measure S. One outstanding option would be the 25-acre Yamaha site on Katella Ave since Yamaha is leaving. The Yamaha site is conveniently located near restaurants and shopping. There are likely more options without considering the race course and Lincoln Avenue as alternatives.

While I know that revisiting the issue of finding an alternative site for the units removed from the race course will likely have some time and financial costs, the ramifications of the traffic in the project as proposed would have long lasting negative impacts on our community.

I have reached out to the staff in the Housing and Community Development office in Sacramento and they responded in writing stating that ‘cities are able to revise their housing element and sites inventory after adoption, doing so would require a submittal of any draft changes to HCD for review as a new housing element submission for approval.’ I respectfully request that you approve the EIR for this project with the alternative of reducing the number of residential units by 30%.

Sincerely,
George Pardon
37-year Cypress resident
cc: Cypress City Council
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2.5.2 GEORGE PARDON
Letter Code: I-2
Date: April 26, 2026
Response to Comment I-2-1
This comment provides introductory remarks and states that the commenter has concerns with implementation of the proposed project.

Response to Comment I-2-2
This comment expresses concern over the proposed project’s significant and unavoidable VMT impact when there is a Reduced Development Alternative that would reduce the number of residential units by 30 percent. This comment also includes comments related to Measure S.

Refer to Section 2.1.2, Reduced Development Alternative, for the Master Response to comments regarding implementation of a reduced development alternative and associated transportation impacts.

As the remainder of this comment is related to Measure S and not the environmental analysis or conclusions contained in the Draft EIR, no further response is required.

Response to Comment I-2-3
This comment claims that development of a town center with retail, restaurants, and entertainment, which was proposed in the approved ballot measure, would be unlikely due to the residential density proposed under the project.

The proposed project evaluated in the Draft EIR includes 1,791 residential units and 440,000 square feet of non-residential uses that could occur within the Buildout Area. Although the Specific Plan permits a maximum of 879,170 square feet of non-residential floor area within the Buildout Area, it is anticipated that, based on current and reasonably foreseeable future market conditions, the buildout of the Buildout Area will include substantially less than 879,170 square feet of nonresidential development. Therefore, the environmental analyses in the Draft EIR are based on the assumption that only 440,000 square feet of non-residential development will be built within the Buildout Area. This represents approximately 50 percent of the maximum amount of non-residential development permitted in the Specific Plan and is consistent with the provisions of the draft Development Agreement and related planning application being considered by the City as part of the proposed project.

The Draft EIR analyzed the proposed project based on reasonably foreseeable market conditions, including the maximum number of residential units and non-residential square footage that could be developed without requiring an amendment to the Specific Plan or additional environmental S PECIFIC PLAN 3.0 B UILDOUT P ROJECT

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Response to Comment I-2-4
This comment states that the scope of the proposed project should be revisited as the City’s Housing Element, which added 676 units to the racecourse property, was developed during the COVID-19 pandemic which limited significant public input.

The proposed project was developed based on the Specific Plan that was approved by the voters of the City of Cypress on November 5, 2024, by the voters of the City of Cypress. As this comment is related to the City’s Housing Element and not the environmental analysis or conclusions contained in the Draft EIR, no further response is required.

Response to Comment I-2-5
This comment recommends that the City Council should approved the Reduced Development Alternative (30% Reduction) described in the Draft EIR. This comment also includes comments related to rezoning other areas of the city for residential development and updating the City’s Housing Element.

Refer to Section 2.1.3, Reduced Development Alternative, for the Master Response to comments regarding implementation of a reduced development alternative and associated impacts.

As the remainder of this comment is related to rezoning other areas of the city for residential development and updating the City’s Housing Element and not the environmental analysis or conclusions contained in the Draft EIR, no further response is required.

April 29, 2016
Alicia Velasco, Planning Director
RE: Formal Comments on the Environmental Impact Report (EIR) and Vesting Tentative Tract Map for the Los Alamitos Racetrack Project
Dear Ms. Velasco,
I am submitting these formal comments regarding the Environmental Impact Report (EIR) and the proposed Vesting Tentative Tract Map for the Los Alamitos Racetrack development.

The project, as currently proposed, appears to raise significant legal and procedural concerns regarding compliance with the Subdivision Map Act (State Law), the City's Specific Plan, the City's Municipal Code, and the City's General Plan.

1. Potential Non-Conformance with Gov. Code § 66473.5 and the Specific Plan Government Code § 66473.5 requires that a tentative map be in "substantial conformance" with the applicable Specific Plan. The voter-approved Specific Plan explicitly "envisions" a network of dedicated pedestrian and bicycle trails to ensure connectivity between neighborhoods, parks, and the town center (see Specific Plan Pages 1-1, 1-6, 2-1, 2-4, 6-3, and 6-4).

The current Vesting Tentative Map removes these dedicated off-street trails entirely, replacing them with vague references to on-street facilities or leaving the connectivity undefined. This discrepancy raises serious questions as to whether the map meets the statutory requirement of substantial conformance. A map that omits a core component of the governing Specific Plan may not be considered in substantial conformance.

Furthermore, the VMT analysis states that the project is 'assumed' to include only 'approximately 1 mile' of on-street bicycle facilities to achieve a 0.1% VMT reduction. This admission highlights a potential flaw in the project's consistency: the developer may be using minimal on-street lanes to satisfy CEQA/VMT requirements while omitting the “envisioned” trail system stated within the Specific Plan. Who knows? Who can tell from this statetment?
If the project relies solely on on-street lanes to meet VMT mitigation, how can the City certify that the project is in 'substantial conformance' with the Specific Plan, which discusses a 'trail system' for 'exercise and casual enjoyment' distinct from street traffic? Does the City consider on-street bike lanes a valid substitute for the dedicated trail easements that one could envision in the Specific Plan, and if so, on what legal basis? What about sidewalks for pedestrian trails? Why are their no cross section of said facilities? Do the subsequent developers flexibility to design what it wants take priority over the public’s right to know?

2. Potential Non-Compliance with Municipal Code § 25-57 and the Subdivision Map Act Under the Subdivision Map Act, a Vesting Tentative Map is a privileged status that requires strict adherence to local ordinances. City Municipal Code § 25-57(d) explicitly lists nine (9) distinct categories of engineering information that must be submitted for a Vesting Map, including certified drawings for streets, drainage, grading, utilities, etc...

The current EIR submission includes only a partial depiction (Figure 3.5) and appears to lack the full suite of certified engineering drawings required by § 25-57(d). Specifically, the public record appears 1 Comment Letter I-3
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to lack the certified engineering drawings for street locations, widths, and alignments required by § 25-57(d)(6), as well as the supporting data for the other eight categories.

Because the City has not made the full engineering package available for public review, and because the EIR does not demonstrate that these mandatory submissions have been received and verified, it is unclear whether the City can legally determine that the map is in substantial conformance with the ordinance. Is the submitted application in compliance with all the requirements of Furthermore, if the City intends to proceed without these submissions, § 25-57(e) requires a written finding based on "substantial evidence" that such information is "unnecessary, duplicative, or inapplicable." Given that the Specific Plan envisions a complex trail and street network, it appears legally difficult to claim that engineering drawings for these features are "unnecessary." The absence of these drawings in the public record creates a presumption that the map is incomplete and noncompliant.

Given these discoveries, is the application in compliance with “Article II: Division of Land by Tract Map" and "Article IX: Vesting Tentative Map” of the municipal code?

3. Potential Violation of CEQA Guidelines § 15126.2 CEQA Guidelines § 15126.2 requires that an EIR provide an accurate, stable, and finite description of the project. The Specific Plan describes a project with a dedicated trail system. The current EIR describes a project with only on-street bike routes or "assumed" facilities, failing to analyze the environmental impacts of removing the dedicated trail system.

By describing a project that differs materially from the Specific Plan and omitting the required engineering details, the EIR may fail to provide the public and decision-makers with an accurate description of the project. This omission could render the EIR legally inadequate under CEQA.

4. Reliance on Outdated General Plan Circulation Element The City's General Plan Circulation Element was adopted on September 10, 2001, and contains build-out tables projecting Level of Service metrics to 2020. State law has since changed to require Vehicle Miles Traveled (VMT) analysis, yet the Circulation Element has not been updated to reflect these requirements.

The EIR includes a VMT analysis, but it relies on an outdated Circulation Element that contains obsolete Level of Service standards and missing exhibits. This creates a fundamental inconsistency:
the EIR analyzes the project using current state standards while the governing General Plan uses 25- year-old metrics. Additionally, the Traffic Study referenced in the EIR is posted separately from the EIR itself, with bike lane recommendations marked as "for informational purposes" only, meaning they may not carry binding weight.

5. Circulation Connectivity and Infrastructure Efficiency Vessels Street currently terminates at Moody Street. Extending Vessels westward through the development would connect to Enterprise Drive (which runs north-south) and ultimately terminate into Lexington Avenue, a through street that runs north-south. This connection is not included in the proposed map.

This raises significant concerns regarding the efficiency of public infrastructure and circulation planning. A public street that terminates at Moody instead of extending to Lexington may miss an opportunity to create a through connection that would improve traffic distribution and provide alternative routes for pedestrians and cyclists. If the intention was for this corridor to remain disconnected, there should be a documented rationale explaining why a through street was not 2 I-3-4
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prioritized, particularly given the General Plan's stated goals of facilitating movement and alternative transportation.

Furthermore, this potential connection would provide needed relief from residents who traveling eastward on Katella Avenue, can not make a left turn northward on Enterprise Drive.

Not only does east – west connection provide relief, does it also not provide redundancy for ambulance, fire and police to access the development? Was any of this studied as part of the EIR and would this east – west connection enhance the public health, safety and welfare?

6. Lack of Access to the Actual Vesting Tentative Map The public record currently includes only a small, low-resolution image of the map labeled "Figure 3.5" within the EIR. The actual Vesting Tentative Tract Map—the legal document that defines the project's boundaries, easements, and dedications—is not provided as a separate, accessible PDF or physical document.

It appears procedurally improper to treat the Vesting Map as a mere "exhibit" within a larger report.

The Vesting Map is the primary legal instrument of the project. Hiding the actual map behind a small figure may prevent the public from verifying easement widths, lot dimensions, and connectivity points. If the actual map is buried in a separate study or engineering file, the City may be failing to provide the public with the ability to inspect the very document that grants the developer their vested rights.

Given these discoveries, is the application and map in compliance with “Article II: Division of Land by Tract Map" and "Article IX: Vesting Tentative Map” of the municipal code? Request for Action and Required Responses
Before certifying the EIR or recommending approval of the Vesting Tentative Map, the City should ensure the project is conditioned to include the dedicated pedestrian and bicycle trails and the required engineering drawings. Approving this project without these elements could result in violations of state law, the Specific Plan, local ordinance, and the General Plan.

To ensure the administrative record is complete, I request written responses to the following questions in the Staff Report and Final EIR:

1.Substantial Conformance: On what specific legal or factual basis does the City conclude that a tentative map lacking the dedicated trail easements mandated by the Specific Plan is in "substantial conformance" with Gov. Code § 66473.5?

2.Completeness of Submission: The Municipal Code § 25-57(d) requires nine specific categories of engineering data for a Vesting Map. The current EIR only displays a partial figure (Figure 3.5). Can the City confirm in writing that the full set of certified engineering drawings for all nine categories has been submitted, accepted as complete, and is available for public inspection? If not, on what basis is the map being processed as a Vesting Map?

3.Waiver Validity: If any of the nine required engineering categories are missing from the submission, where is the written finding required by § 25-57(e) stating that such information is "unnecessary, duplicative, or inapplicable" and that waiving it will not hamper prudent public policy? Also regarding any deviations from the code or the Specific Plan, is there any documentation that the developer has requested any item under § 25-61, 25-62 or Specific Plan Section 2.2.5 Alternative Street Sections? If so, what are they, what was the result and why was not any of this disclosed to the 3 I-3-8
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publc on the website or in the EIR? How will any of these be covered in the agenda report? Also, given § 25-61 could involve the process of changing the Specific Plan, does a change to the Specific Plan require a vote of the people or can it be changed within the authority of the City Council and municipal code?

4.CEQA Description: How does the EIR satisfy the requirement of § 15126.2 to provide an "accurate" description of the project when it omits the dedicated trail system and the required street crosssections?

5.Future Certainty: If the City approves this map without dedicated trail easements and engineering drawings, what specific legal mechanism exists to guarantee that future developers of the 11 lots will dedicate the necessary land for trails, given that the Specific Plan requires them?

6.General Plan Consistency: How does the EIR ensure consistency with the General Plan Circulation Element when that Element was adopted in 2001, contains build-out projections to 2020, and has not been updated to reflect current VMT requirements?

7.Traffic Study Binding Status: The Traffic Study is posted separately from the EIR and marks bike lane recommendations as "for informational purposes." What binding conditions will be placed on the map to ensure the bike lane widths, buffers, and intersection treatments identified in the Traffic Study are actually constructed?

8.Street Connectivity Rationale: Vessels Street terminates at Moody Street but could extend westward to connect to Enterprise Drive and ultimately Lexington Avenue, a through street. What is the City's justification for not requiring this through connection, and how does this decision align with the General Plan's circulation goals of facilitating movement and alternative transportation? Was the connection studied related to improving potential public health, safety and welfare? How would the connection improve or degrade traffic patterns with regards to the existing senior development on Katella Avenue including not only turning movements but pedestrian and bike mobility?

9.Map Accessibility and Certification: Where is the actual, certified Vesting Tentative Tract Map located in the public record? Why was it not provided as a standalone, high-resolution PDF document? If the map is buried in a separate study or engineering file, please provide a direct link or location for immediate public access to the full map, including all easements and lot lines, to allow for meaningful public review. Given issues raised in this letter, what items in the development application and map are not in compliance or have been waived and under what authority with “Article II: Division of Land by Tract Map" and "Article IX: Vesting Tentative Map” of the municipal code?

10. Development Agreement - Page 3-23 of the EIR mentions the developer is seeking approval of the Vesting Map and a Development Agreement pursuant to Section 65864 et seq. of the California Government Code. Will the public have access to evaluate the development agreement or at least a draft prior to the approval meeting by City Council? What is anticipated to be in the development agreement regarding any trails?

11. Attached Letter to City Council – I have attached the letter I sent to the City Manager and City Council. Please review and answer all the questions posed in the attached letter. They are usually denoted with bullet points.

I expect and request these comments to be included in the official administrative record and for these specific legal and factual questions to be addressed in the Staff Report and the City's findings prior to any vote on the EIR certification or more importantly any subsequent approval of the Vesting Tentative Map.
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Sincerely,
Concerned Bike Rider
Attachment – 4/28/26 Letter to City Manager and City Council 5 April 28, 2026
Subject: Where are the trails for bikes and pedestrians? Call to Action to City Council.

Dear City Council and City Manager,
A bit about me. I have been riding bikes for years. I still remember when the original ballot measure for this property first came around. Someone approached me outside a local store asking me to sign the petition to get it on the ballot. At the time, there was a buzz about what the development would include for the public. What really stood out in the initial plan, aside from the generous donation for the soccer park, was the mention of trails and greenways for both bikes and pedestrians. I ride three bikes myself:
a cross/city bike, a beach cruiser, and a pedal-assist e-bike. Those trails matter to me. On top of that, I have had a bad scare riding near traffic where a vehicle got too close, almost running me off the road.

That experience made me even more aware of how important safe bike infrastructure is.

I recently saw on a local blog/Facebook posts that the Environmental Impact Report (EIR) for the Los Alamitos Racetrack is out for comment so I took a look. Having worked in the development area, I knew I needed to dig deeper once I started reading the EIR. It is a huge document and a huge project.

Some of the attached appendix are huge. I reached out to my network including consultants and city staff from different cities in the LA area, to help me better understand the project and the documents.

Based on that combined perspective, here are my "pro bono publico" comments to the City Council, the City Manager, and the Orange County Bicycle Coalition.

This letter will be a frank discussion on the development and a plea for action by the City Council. I apologize if I have misinterpreted anything or got something wrong; going through this process to research bike and pedestrian trails was difficult. There was not one exhibit/map in the EIR providing any certainty. Just imagine what the average person would encounter. It became a learning experience for me to go through it.

I will write a separate letter with my formal comments to the EIR, addressed directly to the Planning Director as noted on in the EIR, to preserve rights and ensure answers are provided as required by law.

In my experience, responses to comments are often too formal, filled with planning jargon and developer legalese, and would rarely lead to the outcome I hope for. I am not trying to stop the project, but rather to ensure it includes with certainty what was claimed in the Specific Plan. That is where the City Council comes in, as I will explain.

As my subject line asks: Where are the trails & greenways? 1 Cross Section from another city’s Circulation Element I-3-24
Before City Council approves this project, I believe there must be certainty regarding the size, dimensions, and characteristics of any trails on the private lots. After reviewing the EIR, my general opinion for the City Council is twofold: (1) the proposed development may not meet the requirements of the voter-approved Specific Plan, and (2) the proposed development may not meet the requirements of the city code for a Vesting Tentative Map.

Everything comes down to this one question. Simply put, do you believe sidewalks and painted street bike lanes on the streets are “trails” as written in the Specific Plan approved by the voters or do you see trails as off-road, separate and with certain definable characteristics? Proposed Development Does Not Meet the Requirements of the Voter-Approved Specific Plan First, a simple word search of the Specific Plan reveals the following (bold added):

1. Page 1-1 states, "Trails and greenways are envisioned to connect the neighborhoods and provide pedestrian and bike routes to the public parks and town center."

2. Page 1-6 notes, "This Specific Plan places a strong emphasis on wellness in that active recreation opportunities are integrated into the land use districts. A trail system is envisioned within the residential and public park districts affording residents and visitors opportunities to walk, jog, run, bike for exercise or simply for casual enjoyment, and will provide convenient access to the public parks, theaters, shopping, dining, and workplaces."

3. Page 2-1 says, "Greenways and trails will connect the neighborhoods to the town center and the parks in the Public Park District to allow for easy pedestrian and bicycle access to these destinations."

4. Page 2-4 mentions, "The Residential District includes approximately 73.6 acres of land and is intended to accommodate a variety of residential opportunities. In addition to the residential units, trails and greenways are envisioned to connect the neighborhoods and provide pedestrian and bike routes to the central public park and town center." 2 Touted “Greenway” in a Southern
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5. Page 6-3 adds, "Trails and greenways will connect the residential Subdistricts and Senior Housing/Medium-Density Residential District, and provide convenient pedestrian and bike access to the public parks and town center."

6. Page 6-4 states, "Greenways and pedestrian and biking trails are envisioned to facilitate alternative modes of transportation by connecting the Residential District to the central public park and town center and the Senior Housing/Medium-Density Residential District to the western public park. In addition, the Town Center District is envisioned as a pedestrian-friendly entertainment and retail destination, designed for patrons to stroll by the various businesses."
On six different pages, the term "trails" is explicitly mentioned to allow both pedestrians and bikes to connect to other areas of the development. Yet there is not a single trail delineated on any of the private parcels within the EIR. The discussion on bikes seems to be completely absent in the EIR except on page 4.17-15, where it states, "the proposed project is assumed to include the addition of approximately 1 mile of bicycle facilities, connecting to the existing bicycle network." If this "trail" language winds up being just painted bike lanes on the arterial streets of Moody and Vessels, then the specific language is so vague and ambiguous it rises to the level of "puffery," as they say in advertising. If it can mean anything, it means nothing. It shouldn't. We all should know what a "reasonable, rational" person thinks when someone says "trail." The Specific Plan says, "A trail system is envisioned within the residential… district."
Attached is a picture from another city's circulation element which I believe displays what people think of as a "trail."
It seems improbable to have any type of trail connectivity or congruity if there are not at least drawn lines and easements for the trails on the subdivision map for the development of 134 acres over 11 or so lots that are going to be further subdivided. There are no cross sections or guidelines for the dimensions of the trails. If the developer's plan is to have subsequent developers propose a plan later, the city may end up with a mish-mash.
• For instance, how does Lot 2's trail connect with anything through Lot 3 and Lot 4? Are we to guess? Will there be none?
Furthermore, pages 10 through 13 of the VMT analysis talk about sidewalks and and what I assume are on-street bike routes.
• So are we believe that all the language regarding trails for pedestrians are nothing more than residential concrete sidewalk?
On page 11 of the VMT analysis, Provide Pedestrian Network Improvement talks about sidewalk. 3 I-3-26
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• Does that mean all the sidewalks in the the city are trails under the Specific Plan language interpretation?
Imagine bragging to your City Council colleagues in other cities that your city has so many pedestrian trails and their reaction when you tell him you count sidewalk as a pedestrian trail. Again, a cross simple cross section would clear this up because there is a big difference between a five foot sidewalk adjacent to a curb and an eight foot meandering sidewalk within a large parkway/greenway area. The Specific Plan mentions “greenways” which is not defined within the plan. • Are we to assume, since there is no definition, a “greenway” can be a road that is painted green? I bring up this as another sarcastic example up simply to reinforce that when words are not defined their basic and simple meaning should be used. Also, in the specific plan, the “greenway” term is always used with “trails,” thereby reinforcing the voter’s potential image of the graphic presented above. More specifically in the Specific Plan “Greenways and pedestrian and biking trails” conjures up this exact image.

The VMT analysis seems to admit that the project's 'bicycle facility' mitigation is merely 'assumed' to include 'approximately 1 mile' of on-street lanes (Class II/III). This may confirm the developer's strategy: they are relying on on-street bike lanes to satisfy state VMT reduction requirements, while completely ignoring or potentially over generally interpreting the voter-approved Specific Plan's envisioning of a 'trail system' within the residential districts. Also, there is not even an attempt at a breakdown the mileage of Class II vs Class III that I found. I have provided a drawing below for what is a Class II versus Class III bike lanes. The City’s own project along Cerritos Avenue has an off road trail component. Riding in Class III bike lanes is mostly used for existing streets where right of way acquisition is expensive or not feasible and not for design for new bike routes when the right of way does not exist yet.
• Would most people think about riding in Class III lanes with vehicles in traffic lane for “simply casual enjoyment” as mentioned in the Specific Plan? Would the City Council? Would they want to take their children for a casual ride in the traffic lane? How about Seniors? Does that feel like a setting where these groups can have casual enjoyment? 4 I-3-29
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The Specific Plan discusses trails, envisioning a network for 'walk, jog, run, bike for exercise.' By substituting on-street lanes for off-street trails, the project seems to fail to deliver the 'wellness' and 'safe connectivity' promised to voters. The 0.1% VMT reduction cited in the analysis could have been improved by including the very off-street trail network that the Specific Plan talked about for public safety and recreation. This does not seem to be compliance; but rather a substitution of a lower standard for a higher one alluded to in the Specific Plan.
• How can these on street sidewalks and ride in the travel lane bike routes even meet the intent of the language of the Specific Plan as compared to off-road trails? The mitigation measure regarding bike lanes mentions a development agreement (Development Agreement pursuant to Section 65864 et seq. of the California Government Code.) and on page 3-23 of the EIR as part of the approval.
• Will the public have access to evaluate the Development Agreement prior to the approval meeting?
• Will it be enough time to review?
5 Screenshot from another city's Circulation Element
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Vessels Street Extension to Lexington
When I was thinking about how to put trails in, it seems obvious to at least me there should be a through east-west trail, and then thought why isn’t there a public through street. I did not find any reference in the documents and am quite perplexed why there is not this public street that continues Vessels west to connect with Enterprise Drive and ultimately Lexington Avenue. There doesn’t seem to be a point of the city having a public street at Enterprise Drive if it was not going to connect with something going east, west or both. It seems a waste of a public road that the city has to maintain which could have been a private drive and stayed with the adjacent properties. • More importantly, would another east – west connection provide redundancy for medical, fire and police to get to an emergency? Were these options present to OCFA, Police, Ambulance regarding if they would improve safety?
• Wouldn’t this be a logical place to put an off road “greenway and pedestrian and biking trail” adjacent to the this roadway?
Also, once you plot east – west connection on a map (see the dashed line above), it appears to solve the problem I have heard about from the recently built 55 and over community who can not make a left at Enterprise Drive from eastbound Katella Avenue.
• Does this connection alleviate the issue experience by the the Senior Community on Katella Avenue adjacent to Enterprise?
I have heard and read about complaints that they have to make the u-turn at Siboney Street. That District 4 council member (Mayor Madrano) should be very interested in this for the potential of his existing constituents to make a left at Lexington Drive, then a right eastward at this extension then right 6 Dashed Line Represents East-West Public Road Connection from Lexington Drive – Connecting to Enterprise then going eastward to Moody Street.

No left turn
Potential East – West Connection
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southward on Enterprise Drive. It would also enable these residents to access this new development without creating longer trips on Katella Avenue which could reduce vehicle miles especially if it includes a trail. If I lived or moved there one day, I would surely want one. • Why was east-west connection not studied regarding traffic operations, increased usage of bikes and pedestrians and public safety redundancy and efficacy? Before it is brought up that this was not within the Specific Plan, Moody Street going through was not in the Specific Plan either. The Specific Plan, as well as the Subdivision Map Process, both allow modification to infrastructure.

Note the east – west connection depicted by the “dashed” line in the figure could be placed more northerly away from the existing Senior Development in case northerly houses objected but then Enterprise Drive would need to be extended northward to intersect.

Given that the EIR states that 'the Transportation (residential vehicle miles traveled [VMT]) would remain significant and unavoidable,' and this public street could contribute to a reduction in vehicle miles traveled, especially if an off-road trail is included, this issue should be resolved. Regardless, a public east-west connection seems a straightforward solution from a 'traffic operations' standpoint, as it mitigates an existing access problem. This should be addressed now prior to approval or as part of the approval of the subdivision map.

Tentative Map Figure in the EIR
The following really gets to me. Even the figure for the Tentative Map does not provide street cross sections, either on the public streets or the private lots, so the public has no way of knowing whether these streets will be able to handle off-road trails. I can safely assume the proposed public streets won't fit an off-road trail within the right-of-way on either Moody or Vessels. Section 2.2.5 of the Specific Plan says the streets shall be designed in conformance "with the Circulation Element of the City's General Plan and the City of Cypress Standard Plans." A major street needs to be 120 feet wide, and a primary street needs to be 100 feet wide. Any deviation from standards should be clearly identified. An off road trail can not fit within those types of right of way irregardless. I will address the Vesting Tentative Tract Map exhibit later, which does not seem to be the actual map. From my search of the document, only Figure 3.5 is listed as the Vesting Map in the table of contents. There is no appendix document labeled as the Vesting Map either. This is disconcerting from a transparency viewpoint.

The Time is Now for Bike Planning
Bike planning should be done now. It should not be piece by piece. Later does not suffice and this does not seem that hard. One could easily create a loop trail that goes along the perimeter of most of the 134 acres that connects to the new and existing public streets. I hesitate to draw one but easily could and I bet so could the public.

There are myriad ways you could show concepts as well as cross sections. This was not done within the EIR, nor is it shown as a dedication on the Vesting Map. It’s now making me think why it wasn’t done in the Specific Plan.

Future developers that buy any of the lots should know what potential land they will need to dedicate, and it should be a requirement of this map. Figure 3.5 (Vesting Map) has no easement or dedications between parcels for access either by road or for bike and pedestrians. Side note, lot 10 appears to be “landlocked” and it should be described directly on the map how it has access “25-12 c All lots created 7 I-3-33
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by the division of land, whether by tract or parcel map, shall have frontage or approved access to a dedicated public street or highway.”
• Does this process maximize land value for the existing owners by “passing the buck” of where trails will go to the next developer and the city to figure out? If not, how will the public have confidence of where the trails and connection points will be if not on the map now? • Or are they not just going to build any off-road trails at all? • Will the city even have the power to force adequate dedications on future developers if this ambiguity is kept the same?
• What safeguards are in place in case all the subsequent developments propose private streets and gates (like those on the Senior Development on Katella Avenue) that there will still be through access for visitors? It appears the provided map provides no safeguards. Each parcel could deny access through the other parcel thereby negating any talk of a connecting “trails and greenways” network in the Specific Plan.

I believe the city has a rational and reasonable nexus to determine the size and scope of the bike and pedestrian trail system (“trails and greenways”) now, with the adoption of this map, given its powers under the Subdivision Map Act and the language of the Specific Plan. I encourage this new City Council to reread the above-cited paragraphs from the Specific Plan regarding trails. Picture in your mind what the paragraphs with “trails and greenways” conjured for you and what you think the public thought it meant when they voted.

If an argument is made that the developer cannot plan for it now, the same argument could have been made for the proposed arterial street system. They are dedications. They can be changed. • If a dedicated trail on the Vesting Map does not work for a subsequent development, could not the subsequent developer propose an alternative location while keeping the same cross section on their subdivision map with the same connectivity points? Having the trail on the Vesting Map now would seem to put the city in a more advantageous position and keep the integrity and connectivity of any multi-parcel trail.

Lastly, the new City Council should be aware that this developer funded Voter Approved Initiative DID NOT require an environmental analysis. My understanding is the city did not draft the Specific Plan and it has never been evaluated from an environmental and practical perspective. Lastly, Specific Plans can be changed and that is always an option for the developer or the city. See “§ 25-61Development inconsistent with zoning;” conditional approval for if the developer wants to change the specific plan during this process. I do not believe the city can change a specific plan unless the application is no longer active.

Also, it begs the following questions.
• Isn’t this the first time this development, as well as the items in the Specific Plan, are being evaluated from an environmental (EIR) and practical perspective? • Does an actual change to the Specific Plan, not authorized within its framework, need to go to the voters or are they now under the authority of the City Council? • Assuming the Vesting Map is approved without changes to the Specific Plan, are subsequent developers who purchase the lots and submit new subdivision maps also 'grandfathered' under 8 I-3-36
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that Specific Plan? If so, is there a time limit on this protection, or can the City change the Specific Plan later, forcing subsequent developers to comply with the new rules? The latter question is important, because actions could potentially “tie the hands” of future City Council or public initiated measures depending on the answer.

Vesting Tentative Subdivision Map
The developer did not submit a regular Tentative Tract Map. Instead, they submitted a Vesting Map.

This requires them to do everything they would have done with a Tentative Map (Section 25-10, subsections (e)(1-14) and (f)(1-4)) and then meet additional requirements to obtain a Vesting Map (Section 25-57, Filing and Processing). If all these code sections are complicated, think of how some of the general public feels reading them to ascertain what the rules are for this development.

My understanding is that a Vesting Tentative Subdivision Map holds significant value for a developer because it locks in their rights. In exchange, cities typically enforce code requirements that push work normally done at the building permit stage to happen much earlier. This should include completed street construction plans as well as dedications shown on the map. If those were done, the public would know exactly where the trail connectivity is supposed to go for all the parcels. The developer could have submitted a regular Tentative Subdivision Map that does not have these requirements, though it can be argued that even those requirements demand showing the dedications on the map (Section 25- 10, subsections (e)(10 & 14)).

Your municipal code is very specific about this for Vesting Maps. Section 25-57, subsection (d)(6) explicitly requires for streets:
"Certified, engineering drawings showing the location, widths, and horizontal and vertical alignments of all public and private streets and alleys within and adjacent to the boundaries of the vesting tentative map site."
My assumption, based on the map I saw within the EIR, is that these have not been prepared.

Furthermore, the code is equally specific about how any of the nine categories (Section 25-57, subsection (d)(1-9)) can be waived. Any waiver requires written findings based on "substantial evidence" proving the information is "unnecessary, duplicative, and inapplicable." The code further states that prudent public policy and decision-making will not be hampered by such a waiver. In my opinion, delaying trail planning and withholding detailed cross-sections is the exact opposite of prudent planning.

The code states in its entirety:
"(e) Should the information required in subsection (d) above be deemed unnecessary, duplicative, or inapplicable to a particular development proposal for which a vesting tentative map is sought to be filed, the city's director of public works/city engineer shall have the authority to waive said informational requirement upon a written finding that said informational requirement is unnecessary, duplicative, or inapplicable to a particular development proposal. Said written finding shall be based on substantial evidence and include a statement that the public health, safety, or welfare will not be placed in jeopardy or danger and that prudent public policy and decision-making will not be hampered by the waiving of said informational requirement."
I am assuming the city has Vesting Map requirements in the municipal code for a good reason all these years. Not adhering to them for this large development seems like forcing a square peg into a round 9 I-3-39
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hole. If neither the regular tentative map or vesting map code ordinances addressed what the developer was trying to accomplish given their concept, they could have petitioned the city to make changes to its subdivision ordinance prior to submittal of their application. This begs another question why is the City even granting a Vesting map. Ask the City Attorney to specifically state on record to the public, what advantages or specific legal rights do the developers gain from having a vesting map and why would the city bend on these rules.

I am certain there is tremendous interest in purchasing these parcels when they become available. I am betting the developer could sell the land outright as it is currently configured and develop under one master development. I am also betting that it would not provide the maximum amount for the land sold.

For curiosity, council members could ask what ballpark percentage value does that increase the parcels they will now be selling or developing? What is the average cost per acre of this land expected in the sale if a vesting map were approved? Ask any developer who may want to buy the property. From my recollection and research, didn’t William Lyon Homes, Shea Properties and Melia Homes all develop properties around the site?
There needs to be transparency regarding the Vesting Map as well as the development meeting all the requirements in "Article II: Division of Land by Tract Map" and "Article IX: Vesting Tentative Map." This should be addressed in any report to the City Council as it would be beneficial to the public to have this information on the website so the public can confirm exactly what code or rules or rules are being waived, set aside, or modified for this development.

Back to what got me started in the first place to this tremendous effort. It is hard to believe that Figure

3.5, labeled "Vesting Tentative Tract No. 19247," is the actual submittal to the city; it appears to be merely a snippet or depiction. Maybe I am wrong but it doesn’t even have street widths, lot dimensions, lot classification.... Clearly the map is missing pages or something since it contains cross sections that are labeled (A-A) through (K-K). Took me a while to find, but see the City’s Checklist for Vesting Maps for a complete checklist of what is required and compare to what is missing. The checklist matches what is in the code. Here is a Tentative Map from your agenda system that went to City Council for approval for a 45 unit residential development on Orange Avenue for comparison. Note the difference between what goes to Council for approval and what is shown in this figure. The linked map has a stamp. My recollection is the City of Irvine requires all tentative maps to be stamped by a licensed civil engineer.

The lack of this document is frustrating and I can not think of a reason why it is not a separate attachment clearly called out by name. This would seem to deprive the public the ability to evaluate the project.

While I could file a Public Records Act request to obtain the full developer submittal of the complete Vesting Map if I am correct, the right thing to do is for the city to post the complete documents on its website for public review and transparency.

I also assume there has to be some type of documentation the city uses to deem an application complete in compliance with code Section 25-57 and other related sections.

Questions:
• Why is the city granting a Vesting Map if it does not meet many or most of the requirements? • Does the proposed Vesting Map meet all the requirements of Article I and IX in the municipal code?
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cont.
• Where is the Vesting Map and why has it not been posted publicly as part of this EIR in a location as a separate attachment that is readily apparent to the reader? • Also, if this map involves infrastructure which it does, shouldn’t it be stamped by a Licensed Professional Engineer who prepared pursuant to Business and Professions Code section 6735? This question assumes that the figure is the map.
• How can the EIR be effectively evaluated by the public as a project if the most important project document, the actual Vesting Tentative Map is not attached? Is this good practice or even legal? Does the EIR need to be recirculated again due to this? • When was the Vesting Map application was first submitted? When was the application deemed complete, or was it ever deemed complete? If so by whom, and where is the documentation? My understanding from the EIR, the project is the Vesting Tentative Map. The developer is also asking for approval of a development agreement. These are what you will be approving. Ask your City Attorney if you can approve a Subdivision Map that does not comply with all its local ordinances. 2001 Cypress General Plan
As background, the Circulation Element states: "The circulation plan is developed to meet present and future travel demand throughout the City. This Element is a general guide for the planning, development, and enhancement of the City of Cypress circulation system, based on existing and anticipated land uses."
In a later section of this letter, I will discuss how I believe the General Plan appears to be way past its time to be updated now going on its 25th year. Even the traffic services level projections only went to 2020.

I searched for goals within the Circulation Element to compare against the development for consistency. I found three that I believe are relevant specifically to this project with regards to bikes. "CIR-1.5: The City of Cypress will continue involvement in plans and programs related to the Circulation Element. This involvement is anticipated to result in traffic studies to be undertaken by City staff, to identify specific circulation programs and improvements to be implemented, in order to satisfy the various related programs."
"CIR-2: To facilitate alternative modes of transportation, including public transportation, bicycles, ridesharing, and pedestrians, to support the land use plans and related transportation needs."
"CIR-2.4: Encourage development and site design which facilitate implementation of high quality, desirable bicycle routes which meet or exceed established standards." Pay particular attention that the goal and policy is to "meet or exceed standards." Again, there is a canvas of 134 acres, yet there is not one designated off-road trail delineated anywhere on any of the parcels. The City Council has the ultimate authority here to direct public policy and condition the map with a trail system it believes is adequate within the law. • Where has the City undertaken any study to examine bicycle movement overall and especially within the development (CIR-2)?
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• While there was much talk in the voter-approved Specific Plan about "envisioning" trails, where is any documentation that the city possesses regarding any of this so called “envisioning” plans from the developer?
Under additional considerations, I talk about how General Plan way overdue for a complete overhaul including its Circulation Element. Here above is a concept of complete streets from another update Circulation Element that could be applied on the Moody Extension. It is assumed it would require additional right of way from what the developer is proposing to provide a street buffer between the bike lane and the sidewalks. When such a large tract is developing, these are some of the few times a city can achieve this with out expensive right of way acquisition. Something else for the Council to consider in addition to the trails. This street buffer would have also prevented my near miss where a vehicle almost took me out.
• Is the City settling for less safety without barrier or separation on the on-street bike routes instead of adopting a complete street for the project?
Although state law requires a three-foot buffer for passing, relying on driver compliance is insufficient.

P hysical separation provides the necessary protection to save lives when that buffer is violated.

Some type of physical buffer should be conditioned as part of the approval of the Vesting Map.

Summary
Let's paint a picture. Imagine the City Council requiring a looped networked off-road trail system throughout these parcels, connecting with the existing trail on Cerritos Avenue, which could be widened starting at the new soccer park. This loop would serve all new residents, including seniors, by connecting them to the development safely, free from vehicle interference, while still utilizing on-street routes when needed. It would also connect to the large 55-and-over development on Katella Avenue and serve as a vital amenity for both residents and visitors.

I urge the City Council to delay or deny any approval of the Vesting Tentative Map until these trail specifics are resolved. While the EIR and the map are connected, they are separate actions that do not need to happen simultaneously. The map approval does not have to occur at the same meeting as the environmental document. Even if the EIR is approved, the map can and should be conditioned to ensure the trails are built and can be approved subsequently. I propose that the City hire its own thirdparty consultant to independently evaluate and propose specific trail locations, dimensions, and materials for this 134-acre development. This step is necessary to provide the public with certainty regarding what will actually be built.
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This aligns with General Plan Policy CIR-1.5, which states the “City staff” will identify specific circulation programs and improvements. Since the developer has failed to provide certainty, it is the City's duty to identify alternative transportation means. The City Council has the power under the Subdivision Map Act to condition the map with dedications, easements, construction timelines, and adequate bonding. I would argue there is a clear nexus based on the language in the voter-approved Specific Plan, and it is entirely reasonable for a project of this scope and acreage to require in and it is what the public expects. With the Public Works Department and City Attorney, you can draft a "bulletproof" condition that holds the developer accountable. The study you approve would provide the blueprint.

Ultimately, the Council must decide: Do you believe sidewalks and painted bike lanes satisfy the voterapproved Specific Plan's definition of "trails," or do you recognize that true trails are off-road, separate, and distinct? If the “trails and greenways” are not developed, the responsibility will rest at the feet of the City Council.

Do not hide behind legal or other advice to maintain silence. While the Council as a body cannot deliberate until this is on the agenda, individual members can and must speak up. Every council member has the power and duty to individually request that the City Manager direct staff to answer these questions immediately, creating a transparent public record that leaves no room for excuses, delays, or claims of ignorance when the vote comes.

Be aware of the political risk. Voters may demand that incumbents not only pledge support for off-road trails but actively fight for them from the dais. This could become an election issue in November. If they fail to do so, they risk being voted out. This standard is even stricter for candidates: since they are not bound by the Brown Act, they have the freedom to speak clearly now how they feel about requiring the project to have true off road trails. Voters may reject any candidate who won't commit to this vision.

Let's ensure the outcome is a beautiful off-road trail and greenway system, not a missed opportunity.

Many of you are new council members, and Cypress has a new City Manager. I trust you will give this matter the detailed, thorough review it deserves. I have copied the Orange County Bicycle Coalition and welcome any interested public to join this effort. I recognize that without a Planning Commission, the burden of oversight falls entirely on you; you are the only "public eyes" standing between the community and this project. Please rise to that challenge.

Sincerely,
Concerned Bike Rider
cc: Orange County Bicycle Coalition
Additional Considerations
I would like to ask the Council to consider a few more points regarding the EIR and this process.

Outdated General Plan
Let's talk about the age of the General Plan. The City of Cypress General Plan was adopted on September 10, 2001. At what point is the City going to do a comprehensive update of the General Plan, since it is going on 25 years old? Of note, within the Circulation Element, the build-out tables for Level of Service are projected to 2020. While I understand state law has changed, the Circulation Element should have been updated to reflect the new requirements of Vehicle Miles Traveled (VMT). From my research, Level of Service metrics are still valuable in traffic engineering efforts to ensure that 13 I-3-43
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developers build appropriate improvements for any subdivision map-related efforts, traffic mitigation fees, and compliance with any required Congestion Management Plans.

While I saw the city is updating certain elements of the General Plan (safety and open space) because of state law, I did not see any indication of the Circulation Element https://www.cypressca.org/departments/general-plan-survey being updated. • While I saw the environmental consultant did a VMT analysis in the EIR, how can it be legal or good practice to let such an outdated Circulation Element stay in place with outdated service numbers? There seems to be zero bike planning?
What this likely tells me is that the city has done next to no planning on a citywide basis regarding bike and pedestrian movement, or that it is buried in some other project-related document. The mere fact that the Racetrack is developing should have triggered a revision to the General Plan regarding onstreet bike lanes on the extension of Lexington and now Moody. So I ask: Where has the city done any bike planning regarding its Circulation Element as an effective means of alternative transportation? From a neighboring city’s Circulation Element “Convenient bicycling and walking facilities play an important role in improving public health, reducing congestion and GHG emissions, and improving local economic vitality by supporting shorter trips to local neighborhood retail establishments.” Yet, because the racetrack existed, there were no plans for any bike routes or trails through the racetrack. It is sort of an “Escherian Stairwell.” You can never plan for the racetrack until the racetrack develops and then it is too late because you didn’t plan for the racetrack. (My lawyers out there might know this term from a 2018 case on qualified
immunity and I thought it was apropos to this situation as the planning never happens).

The City missed an opportunity to place bike lanes and off road trails along Lexington/Denni as part of their park project and also when the church was built. It seems this seemingly “piecemeal” effort over decades has missed
opportunities for bike planning and the General Plan was never revised to consider development of the racetrack but the city knew it would be ultimately developed even accepted dedications Lexington Drive as discussed next.

The figure for the Vesting Map denotes that the Lexington Street parcels were already dedicated to the city and accepted by the City by a previous Parcel Map.
• Does this mean the Racetrack has been using city property on Lexington all these years or is there an agreement available? If so, what does it entail?
• According to the Traffic Study, “Along some segments, Class II bike lanes are provided, while other segments are designated Class III bike routes. What, if any on street bike lanes, will be placed along Lexington Drive since there is no cross section A/A in the figure? • What does the cross hatching mean on the upper Lexington Dedication? 14 Escherian Stairwell
EIR Screenshot
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• What is this “LARC/OC property” denoted on the southerly portion of the park? There is no lot on the County’s GIS system so it seems to be part of the parcel? Is it an easement? Normally property, even if shared are parcels, otherwise there is an agreement to use or an easement. It looks like an access road the Racetrack is using on the park? What are the city’s plan for this? Will the Vesting Map be revised to truly reflect what it is and refer to the appropriate legal document for its authorization? Since bike trails were not provide on Lexington, west of Lexington Park, the city could use this as part of a trail.

Lastly, as a side note: When you go to the Circulation Element, you will find all of the exhibits are missing if you go to the section individually. Luckily, they are there when you download the entire document. The same cannot be said for the EIR for the General Plan. The planning department should correct.

Traffic Study (Not included in the EIR but the most useful) The website says, "You can find the LARC traffic study here. Please note, the traffic study is not included as part of the EIR public review process and is posted for informational purposes." I did review it and found this was the only place where information was provided regarding bike lanes.

Chalk one up for the engineers. If you search for "bike," you can find instances where it says "bike lane":

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Cypress City CouncilJuly 14, 2026

Cypress City Council
July 14, 2026