Cypress City Council
July 14, 2026

Variable YearroundHA Not Expected. Suitable habitat (vertical banks/cliffs with fine-textured/sandy
soils near streams, rivers, lakes, ocean)
is absent from the Buildout Area.

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026
S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A
P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.4 Biological Resources_final.docx (03/11/26) 4.4-23 Table 4.4.B: Summary of Potential Special-Status Species Species Status Habitat and Distribution Activity
Period
Habitat
Present/Absent
Occurrence Probability
Rynchops niger
(nesting colony)
Black skimmer
US: –
CA: SSC
(breeding)
Casual inland; nests and breeds in coastal
beach, sandbar, shell bank, island, salt
marsh and locally on gravel rooftops.

Associates with terns, gulls, plovers.

Year-round
diurnal
activity
HA Not Expected. Suitable habitat (coastal
beach, sandbar, shell bank, island, salt
marsh) is absent from the Buildout
Area.

Setophagia petechia
(nesting)
Yellow warbler
US: –
CA: SSC
(breeding)
Riparian woodland while nesting in the
western U.S. and northwestern Baja
California; more widespread in brushy
areas and woodlands during migration.

Occurs from western Mexico to northern
South America in winter. Migrants are
widespread and common. Three
subspecies breed in California: morcomi,
brewsteri, and sonorana. (Sonoran yellow
warbler nests along the Colorado River.)
Summer,
winter, or
Year-round,
depending on
locale
HA Not Expected. Suitable habitat (riparian
woodland) is absent from the Buildout
Area.

Sternula antillarum
browni
(nesting colony)
California least tern
US: FE
CA: SE/CFP
Nests along the coast from San Francisco
Bay south to northern Baja California.

Forages in shallow water. Colonial
breeder on bare or sparsely vegetated,
flat substrates, sand beaches, alkali flats,
landfills, or paved areas.

April through
October
HA Not Expected. Suitable habitat (coastal
areas with sandy beaches) is absent
from the Buildout Area. There are three
known occurrences approximately 5
miles southwest of the Buildout Area
(CNDDB). One historical occurrence
from 1904 is mapped in the vicinity of
Seal Beach and is now believed
extirpated. Another occurrence from
1980 documents a site that was
historically used for nesting from 1970
to 1980 and is now extirpated. The last
occurrence from 2016 documents
another historical nest site that is still
extant within the Seal Beach National
Wildlife Refuge.

S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026

4.4 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.4 Biological Resources_final.docx «03/11/26» -24 Table 4.4.B: Summary of Potential Special-Status Species Species Status Habitat and Distribution Activity
Period
Habitat
Present/Absent
Occurrence Probability
Vireo bellii pusillus
Least Bell’s vireo
US: FE
CA: SE
Riparian forests and willow thickets. The
most critical structural component of
Least Bell’s Vireo habitat in California is a
dense shrub layer 2 to 10 feet (0.6–3.0
meter) above ground. Willows usually
dominant. Nests from central California to
northern Baja California. Winters in
southern Baja California.

April through
September
HA Not Expected. Suitable habitat (riparian
forests and willow thickets) is absent
from the Buildout Area. One historical
record from 1900 was documented 2.8
miles north of the Buildout Area and is
noted as being extirpated (CNDDB).

MAMMALS
Sorex ornatus
salicornicus
Southern California
saltmarsh shrew
US: –
CA: SSC
Coastal marshes with dense vegetation
and woody debris for cover. Known only
from Los Angeles, Ventura, and Orange
Counties.

Year-round,
mostly
nocturnal
HA Not Expected. Suitable habitat (coastal
marshes) is absent from the Buildout
Area. One historical record from 1968
occurs 3.8 miles southwest of the
Buildout Area within the Seal Beach
Naval Weapons Station (CNDDB).

Eumops perotis
californicus
Western mastiff bat
US: –
CA: SSC
Occurs in many open, semi-arid to arid
habitats, including conifer and deciduous
woodlands, coastal scrub, grasslands,
chaparral, etc.; roosts in crevices in
vertical cliff faces, high buildings, and
tunnels, and travels widely when
foraging.

Year-round;
nocturnal
HP Moderate. Suitable roosting and
foraging habitat are present in the
Buildout Area and project vicinity.

However, there is a lack of records of
this species in the project vicinity. The
closest known occurrence is from 1990
approximately 3.6 mile northeast from
the Buildout Area (CNDDB).

Lasiurus xanthinus
Western yellow bat
US: –
CA: SSC
Found mostly in desert and desert
riparian areas of the southwest US, but
also expanding its range with the
increased usage of native and non-native
ornamental palms in landscaping.

Individuals typically roost amid dead
fronds of palms in desert oases, but have
also been documented roosting in
cottonwood trees. Forage over many
habitats.

Year-round;
nocturnal
HP Moderate. Suitable roosting and
foraging habitat are present in the
Buildout Area and project vicinity.

However, there is a lack of records of
this species in the project vicinity. The
closest known occurrence is from 1990
approximately 0.85 mile southeast of
the Buildout Area (CNDDB).

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026
S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A
P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.4 Biological Resources_final.docx (03/11/26) 4.4-25 Table 4.4.B: Summary of Potential Special-Status Species Species Status Habitat and Distribution Activity
Period
Habitat
Present/Absent
Occurrence Probability
Nyctinomops
femorosaccus
Pocketed free-tailed
bat
US: –
CA: SSC
Usually associated with cliffs, rock
outcrops, or slopes. May roost in
buildings (including roof tiles) or caves.

Rare in California, where it is found in
Riverside, San Diego, Imperial, and
possibly Los Angeles Counties. More
common in Mexico.

Year-round;
nocturnal
HP Low. Suitable roosting and foraging
habitat are present in the Buildout Area
and project vicinity. However, there is a
lack of records of this species in the
project vicinity. The closest known
occurrence is from 1989 approximately
10 miles northeast of the Buildout Area
(CNDDB).

Nyctinomops macrotis
Big free-tailed bat
US: –
CA: SSC
Inhabits rugged, rocky canyon country in
southwestern United States. Found from
northern South America and the
Caribbean Islands northward to the
western United States. In the
southwestern U.S., populations appear to
be scattered.

Probably
year-round
HA Not Expected. Suitable habitat (rugged,
rocky canyon country) is absent from
the Buildout Area.

Microtus californicus
stephensi
South coast marsh vole
US: –
CA: SSC
Inhabits tidal marshes in Los Angeles,
Orange, and southern Ventura counties.

Year-round HA Not Expected. Suitable habitat (tidal
marshes) is absent from the Buildout
Area. One historical record from 1988
occurs 3.75 miles southwest of the
Buildout Area within the Seal Beach
Wildlife Refuge (CNDDB).

Perognathus
longimembris pacificus
Pacific pocket mouse
US: FE
CA: SSC
Historically occupied open habitats on
sandy soils along the coast from Los
Angeles to the Mexican border. Now
known from only four sites in Orange and
San Diego Counties.

April through
September
HA Not Expected. Suitable habitat (open
habitats on sandy soils) is absent from
the Buildout Area. Additionally, no
known occurrences have been
documented within 5 miles of the
Buildout Area (CNDDB).

Taxidea taxus
American badger
US: –
CA: SSC
Primary habitat requirements seem to be
sufficient food and friable soils in
relatively open uncultivated ground in
grasslands, woodlands, and desert.

Widely distributed in North America.

Year-round HA Not Expected. Suitable habitat (open
uncultivated ground in grasslands,
woodlands, and desert) is absent from
the Buildout Area. Additionally, no
known occurrences have been
documented within 5 miles of the
Buildout Area (CNDDB).

S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026

4.4 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.4 Biological Resources_final.docx «03/11/26» -26 Table 4.4.B: Summary of Potential Special-Status Species Species Status Habitat and Distribution Activity
Period
Habitat
Present/Absent
Occurrence Probability
Sources: California Natural Diversity Database (CDFW 2024a); Biogeographic Information and Observation System (CDFW 2024b); and Information for Planning and Consultation (IPaC) database (USFWS 2024a).

US: Federal Classifications
FT = Listed as threatened
FE = Listed as endangered
FC= Federal Candidate for Listing
CA: State Classifications
SE = Listed as endangered
ST = Listed as threatened
SC = State Candidate for Listing
CFP = California Fully Protected
SSC = Species of Special Concern. Refers to animals with vulnerable or seriously declining populations.

SA = Special Animal. Refers to any other animal monitored by the Natural Diversity Database, regardless of its legal or rarity status.

CNPS Designations
1A = Plants presumed extinct in California and rare/extinct elsewhere 1B.1 = Rare threatened, or endangered in California and elsewhere 1B.2 = Plants rare, threatened, or endangered in California and elsewhere; fairly threatened in California 1B.3 = Plants rare, threatened, or endangered in California and elsewhere; not very threatened in California 2B.2 = Plants rare, threatened, or endangered in California, but more common elsewhere; fairly threatened in California

4.3 = Plants of limited distribution; not very threatened in California CA = California
CDFW = California Department of Fish and Wildlife
CNDDB = California Natural Diversity Database

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026
S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A
P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.4 Biological Resources_final.docx (03/11/26) 4.4-27 Western mastiff bat and western yellow bat have a moderate potential to occur within the Buildout Area, while the other four species have a low potential to occur within the Buildout Area. In addition, the Buildout Area is not within designated or proposed critical habitat for any federally listed species.

Table 4.4.B provides a tabular list of the 43 species-status wildlife species known to occur within the Buildout Area and the immediate vicinity, their current status, their habitat and distribution, and their occurrence probability.

During the field survey, 18 bird species were observed. While only these 18 bird species were documented, the Buildout Area provides suitable habitat for additional bird species that may not have been detected. For example, palm trees near the three ponds on Lots 3, 4, 6, and 7 of proposed Vesting Tentative Tract Map (VTTM) 19247 may serve as potential rookery sites for colonial waterbirds such as the great blue heron (Ardea herodias). At the time of the survey, no active rookeries or other special breeding sites for birds were observed, likely due to regular trimming of trees in and around the Buildout Area.

Bats. Western mastiff bat and western yellow bat have a moderate potential to occur within the Buildout Area, however neither of these two species are State or federally listed. While western yellow bat is typically associated with desert and desert riparian habitats, its range has continued to expand into sheltering in palms used in landscaping. Based on Buildout Area conditions, it was determined that the western mastiff bat may use the Buildout Area to forage and roost due to suitable structures being present on-site. The Buildout Area contains palms for roosting and foraging opportunities over the Buildout Area. Other ornamental tree species within the Buildout Area could provide habitat to native bats in the form of foliage, bark, or cavity roosts. Bats breed in late spring/early summer (April–August), with foliage-dwelling species utilizing peeling bark, thick clumps of leaves, or cavities in trees often alone or in small maternity colonies. While roosting bats were not observed during the field survey conducted on September 25, 2024, the survey was conducted during daylight hours, while bats are nocturnal and typically inactive during this time.

4.4.3.3 Natural Communities
The CNDDB search identified occurrences of one special-status natural (i.e., plant) community within 5 miles of the Buildout Area: Southern Coastal Salt Marsh. Southern Coastal Salt Marsh was identified from the CNDDB as occurring near Alamitos Bay and another occurrence in Anaheim Bay.

Both of these occurrences are historical and are presumed extant. No salt marsh habitat exists within the Buildout Area.

4.4.3.4 Jurisdictional Waters
There is one existing drainage feature, one existing detention basin, and three existing artificial ponds within the Buildout Area. The three artificial ponds are located on Lots 3, 4, 6, and 7 of proposed VTTM 19247, the detention basin is located on Lots 2 and 3, and the drainage feature is located on Lot 3, all within the Buildout Area. Although a formal jurisdictional delineation was not conducted as part of the BRA, the preliminary results of these drainage features and detention basins are discussed below.

S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026

4.4 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.4 Biological Resources_final.docx «03/11/26» -28 The single drainage feature located on Lot 3 originates from a culvert beneath the internal road just northwest of a parking lot. This drainage is an ephemeral, earthen bottom drainage created to carry stormwater. Stormwater flows appear to travel westward underground toward Lexington Drive.

Sparse ruderal vegetation was observed within this drainage. This drainage may connect to Coyote Creek, which is tributary to the San Gabriel River and ultimately flows into the Pacific Ocean.

The detention basin on Lots 2 and 3 was observed during the field survey and is considered a manmade basin created to capture flows. The detention basin is located adjacent to the horse barns (Lot 2 and 3), is entirely lined with polyethylene and bordered by a chain-link fence. It appears to divert accumulated water into the adjacent drainage that terminates into an underground drain system. It is currently unknown where the storm system takes these flows.

The three artificial ponds on Lots 3, 4, 6, and 7 are manmade and thus, hydrologically isolated. The ponds contain hydrophytic vegetation along portions of their shoreline, including species that could be considered wetland indicators.

All of these aquatic features were constructed in previously graded or developed areas and do not represent natural stream channels, wetlands, or riparian systems. Their primary functions are aesthetic or related to stormwater conveyance and retention.

4.4.4 Regulatory Setting
This section includes federal, State, regional, and City regulations relevant to biological resources.

4.4.4.1 Federal Regulations
Clean Water Act, Section 404. The United States Army Corps of Engineers (USACE) regulates discharges of dredged or fill material into waters of the United States. These waters include wetlands and non-wetland bodies of water that meet specific criteria, including a direct or indirect connection to interstate commerce. The USACE regulatory jurisdiction pursuant to Section 404 of the federal Clean Water Act (CWA) is founded on a connection, or nexus, between the waterbody in question and interstate commerce. This connection may be direct (through a tributary system linking a stream channel with traditional navigable waters used in interstate or foreign commerce), or it may be indirect (through a nexus identified in the USACE regulations). To be considered a jurisdictional wetland under Section 404, an area must possess three wetland characteristics, each with its unique set of mandatory criteria: hydrophytic vegetation, hydric soils, and wetland hydrology.

United States Endangered Species Act. The USFWS, pursuant to the Federal Endangered Species Act (FESA), protects endangered and threatened species. FESA defines an endangered species as a species in danger of extinction throughout all or a significant part of its range and a threatened species as one that is likely to become endangered in the foreseeable future. USFWS also identifies species proposed for listing as endangered or threatened. Other than for federal actions, there is no formal protection for candidate species under FESA. However, consultation with USFWS regarding species proposed for listing can prevent project delays that could occur if a species is listed prior to project completion.

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026
S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A
P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.4 Biological Resources_final.docx (03/11/26) 4.4-29 Migratory Bird Treaty Act. The federal Migratory Bird Treaty Act (MBTA) governs the take, possession, import, export, transport, selling, purchasing, or bartering of migratory birds and their eggs, parts, and nests. Section 704 of the MBTA states that the Secretary of the Interior is authorized and directed to determine if, and by what means, the take of migratory birds should be allowed and to adopt suitable regulations permitting and governing take while ensuring that take is compatible with protection of the species. Most bird species are protected under the MBTA.

4.4.4.2 State Regulations
Regional Water Quality Control Board. The Regional Water Quality Control Board (RWQCB) is responsible for the administration of Section 401 of the CWA. Typically, the areas subject to jurisdiction of the RWQCB coincide with those of the USACE (i.e., waters of the United States, including any wetlands). The RWQCB may also assert authority over “waters of the State” under waste discharge requirements pursuant to the Porter-Cologne Water Quality Control Act. All jurisdictional areas are ultimately subject to resource agency determination.

California Fish and Game Code, Sections 1600 through 1616. Sections 1600 through 1616 of the California Fish and Game Code (CFGC), regulates alterations to lakes, rivers, and streams (defined by the presence of a channel bed and banks with at least an intermittent flow of water) where fish or wildlife resources may be adversely affected.

California Fish and Game Code, Sections 1900 through 1913, Native Plant Protection Act. Sections 1900 through 1913 of the CFGC directs the CDFW to carry out the Legislature’s intent to “… preserve, protect and enhance endangered or rare native plants of this state.” The NPPA gives the California Fish and Game Commission the power to designate native plants as “endangered” or “rare” and protect endangered and rare plants from take.

California Fish and Game Code, Sections 3503 and 3513, Nesting Birds and Raptors. Various sections of the CFGC provide protection to nesting birds, birds of prey, and species protected under the MBTA. Section 3503 of the CFGC prohibits the destruction of the nest or eggs of any bird as otherwise provided for in the CGFC. Section 3503.5 specifically extends this protection to the nests or eggs of any bird of prey (species of the Orders Falconiformes [falcons, hawks, eagles, ospreys] or Strigiformes [owls]). The unlawful take, sale, or purchase (whole or in part) of any aigrette or egret, osprey, bird of paradise, goura, or numidi is prohibited under Section 3505. Section 3513 prohibits the unlawful to take or possession of any migratory nongame bird as designated in the MBTA or any part of such migratory nongame bird except as provided by rules and regulations adopted by the Secretary of the Interior under provisions of the MBTA.

California Fish and Game Code, Section 4150. Section 4150 of the CFGC protects nongame mammals, which are defined as any naturally occurring mammal in California that is not a game mammal, fully protected mammal, or fur-bearing mammal. Non-game mammals, which includes bats, bat roosts, and maternity colonies, may not be taken or possessed except as provided by the CFGC or in accordance with applicable regulations.

California Endangered Species Act. The CDFW, through provisions of the California Administrative Code and policies formulated by the California Fish and Game Commission, regulates plant and S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026

4.4 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.4 Biological Resources_final.docx «03/11/26» -30 animal species in danger of, or threatened with, extinction based on the list of endangered, threatened, and candidate species developed by the Fish and Game Commission. Endangered species are native species or subspecies of plants and animals that are in serious danger of becoming extinct throughout all or a significant part of their range. Threatened species are those species that, although not presently threatened with extinction, are likely to become endangered in the foreseeable future without special protection and management. Candidate species are species that the Fish and Game Commission has formally noticed as being under review for addition to the list of endangered or threatened species or as a species proposed for listing.

California Environmental Quality Act. Section 15380(b) of the State CEQA Guidelines provides that a species not listed on the Federal or State lists of protected species may be considered rare or endangered if the species can be shown to meet specified criteria. These criteria have been modeled after the definitions in FESA and CESA and § 2780–2781 of Article 1 of the CFGC dealing with the California Wildlife Protection Act of 1990. This section was included in the guidelines primarily to deal with situations in which a public agency is reviewing a project that may have a significant effect on a species that has not yet been listed by either the USFWS or CDFW.

4.4.4.3 Regional Regulations
There are no regional regulations applicable to the proposed project.

4.4.4.4 Local Regulations
City of Cypress General Plan Conservation/Open Space/Recreation Element. The City of Cypress General Plan identifies goals and policies related to biological resources. Goal COSR-2 in the Conservation/Open Space/Recreation Element (2000) of the City’s General Plan addresses biological resources. The following goals and policies apply to the proposed project:

COSR-2 Preserve the few remaining native plant and animal species, as well as the non-native plants, utilized in landscaping throughout the City.

COSR-2.1 Enforce the Landmark Tree Ordinance that prohibits destroying or pruning landmark trees without a permit.

COSR-2.2 Prohibit the construction of any structure within 30 feet of any landmark tree.

COSR-2.3 Provide for the consistent use of street trees along all sidewalks and property frontages.

COSR-2.4 Provide the opportunity to continue using land for agricultural crops as an interim use prior to further development.

The Cypress Town Center and Commons Specific Plan 3.0 (Specific Plan). The Cypress Town Center and Commons Specific Plan 3.0 contains the following provisions related to biological resources, which supersede the City’s Landmark Tree Ordinance, as codified in Sections 17-17 through 17-27 of the City’s Municipal Code:

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026
S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A
P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.4 Biological Resources_final.docx (03/11/26) 4.4-31 • Tree Replacement. Existing trees within the Specific Plan Area may be removed, provided that any such proposed tree removal for a development project shall be described in the site plan review application for such project for informational purposes. If any such trees are removed, such trees will be replaced onsite with an equivalent number of specimen trees (48-inch box or larger) to be planted as part of the landscaping for the applicable development project. These replacement trees shall be planted in addition to normal tree planting requirements.

4.4.5 Thresholds of Significance
The thresholds of significance for impacts to biological resources used in this analysis are consistent with Appendix G of the State CEQA Guidelines. Based on these thresholds, implementation of the proposed project may be deemed to have a significant impact with respect to biological resources if it would:

Threshold 4.4.1: Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or the U.S. Fish and Wildlife Service;
Threshold 4.4.2: Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, and regulations or by the California Department of Fish and Wildlife or the U.S.

Fish and Wildlife Service;
Threshold 4.4.3: Have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means; Threshold 4.4.4: Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites;
Threshold 4.4.5: Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance; or
Threshold 4.4.6: Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan.

S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026

4.4 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.4 Biological Resources_final.docx «03/11/26» -32

4.4.6 Project Impacts
Threshold 4.4.1: Would the project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or the U.S. Fish and Wildlife Service?
Less Than Significant Impact. The Buildout Area is located within an urban fully developed area in the City. Existing development within the Buildout Area includes horse racing and training facilities such as a racetrack, grandstand, clubhouse, over 40 barns, parking areas, and maintenance structures on the LARC Property; the former Cypress Golf Course, which is now partially used as a maintenance yard and church; and the Grace Church property, which contains a church, small school, open space, and parking areas used for religious and community activities.

Habitats and Vegetation Communities. As discussed in Section 4.4.3, Existing Environmental Setting, the Buildout Area primarily consists of developed land cover. The dominant vegetation within this vegetation community includes ornamental landscaping and ruderal grassland with patches of herbaceous invasive species. Other vegetation communities within the Buildout Area include ornamental landscaping and artificial ponds. The ornamental landscaping community consists of introduced trees, shrubs, flowers, and turf grass, and is located throughout the Buildout Area, particularly within the racetrack infield and around existing structures. These areas are regularly maintained and include species such as Ficus trees, palms, and Bermuda grass, which provide limited ecological value due to their non-native composition and the high level of human disturbance. The central portion of the Buildout Area also includes three constructed artificial ponds. These ponds were excavated in upland areas and are surrounded by ornamental vegetation, including Bermuda grass and ornamental palms. Although some emergent vegetation such as yerba mansa (Anemopsis californica) and cattails (Typha spp.) was observed along portions of the pond margins during the September 2024 biological survey, the ponds are hydrologically isolated and lack natural inflow or outflow. As such, they are not considered natural aquatic features or jurisdictional wetlands.

In addition, no portion of the Buildout Area contains designated or proposed critical habitat for any federally listed plant or animal species. Further, there is a high level of existing disturbance within the Buildout Area, and native wildlife habitat is largely absent within the Buildout Area and in the vicinity. The development surrounding the Buildout Area and the lack of ground cover and suitable foraging habitat make the site undesirable for many native wildlife species.

Therefore, implementation of the proposed project would have no impact on any native habitats or vegetation communities.

Special-Status Plant Species. As noted above in Section 4.4.3, Existing Environmental Setting, no special-status plants were observed within the Buildout Area during the reconnaissance survey; and none of the 30 special-status plant species from the records searches are expected to occur within the Buildout Area due to the lack of suitable habitat and/or conditions. Therefore, implementation of the proposed project would have no impact on any special-status plant species.

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026
S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A
P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.4 Biological Resources_final.docx (03/11/26) 4.4-33 Special-Status Wildlife Species and Migratory/Nesting Birds. No special-status wildlife species were observed during the field survey, and suitable habitat for such species is absent from the Buildout Area due to the high level of development. In addition, no nesting birds or their nests were observed at the time of the field survey.

However, based on a review of resource databases, the following six special-status wildlife species have the potential to occur on or near the Buildout Area:
• Monarch butterfly; wintering sites (Danaus plexippus plexippus) • Ferruginous hawk; wintering (Buteo regalis)
• Swainson’s hawk; nesting (Buteo swainsoni)
• Western mastiff bat (Eumops perotis californicus)
• Western yellow bat (Lasiurus xanthinus)
• Pocketed free-tailed bat (Nyctinomops femorosaccus).

All other species that were identified based on database searches are unlikely or have no potential to occur within the Buildout Area because the Buildout Area is either outside of the known or historical range of the species, the Buildout Area lacks suitable habitat (e.g., marsh, estuarine, perennial stream, vernal pools with sufficient hydrology, chaparral, open forest, or sufficient nesting/roosting substrates), or the Buildout Area lacks connectivity with suitable habitat in the region.

Monarch Butterfly. Originally native to North America, monarch butterfly has dispersed to other parts of the world and non-migratory populations are found from islands in the Pacific Ocean to the western edge of Europe. The western North American migratory monarch population is generally found west of the Rocky Mountains. These butterflies can migrate annually 300 to 1,000 miles (about 500 to 1,600 kilometers). The western population overwinters in hundreds of groves (clusters of trees) along the California coast and into northern Baja California, Mexico.10 Habitat for the monarch during their winter migration typically include roosts which are located in wind-protected tree groves (Eucalyptus, Monterey Pine, Cypress) with nectar and water sources nearby. Although monarch butterfly has the potential to occur on or near the Buildout Area, the Buildout Area provides low potentially suitable roosting habitat (Eucalyptus trees), the wintering habitat is limited, and there are no known wintering roost locations in the Buildout Area. Therefore, implementation of the proposed project is not expected to result in significant impact on the monarch butterfly.

Ferruginous Hawk. Ferruginous hawks forage in open fields, grasslands and agricultural areas, sagebrush flats, desert scrub, fringes of pinyon-juniper habitats, and other open country in western North America; however, they are not known to breed in California. The closest known occurrence per CNDDB records was recorded in 1997 and is located approximately 1 mile southwest of the Buildout Area within the Los Alamitos Armed Forces Reserve Center. Although Ferruginous hawks have the potential to occur within or near the Buildout Area, the Buildout 10 United States Fish and Wildlife Service (USFWS). n.d. Monarch. Website: https://www.fws.gov/species/ monarch-danaus-plexippus( accessed January 20, 2025).

S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026

4.4 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.4 Biological Resources_final.docx «03/11/26» -34 Area provides low suitable foraging habitat, there are no known nesting sites within the Buildout Area or the immediate surrounding area, and no observations of Ferruginous hawks or indication of Ferruginous hawks being present within the Buildout Area have been recorded.

Therefore, implementation of the proposed project is not expected to result in any impact on Ferruginous hawks.

Swainson’s Hawk. Swainson’s hawk occurs in open desert, grassland, or cropland containing scattered trees or small groves. The species breeds in strands with few trees in juniper-sage flats, riparian areas, and in oak savannah in the Central Valley juniper-sage flats, riparian areas, and in oak savannah in the Central Valley. Swainson’s hawks forage in adjacent grasslands or suitable grain or alfalfa fields, or livestock pastures. Although, the Buildout Area may offer low suitable foraging habitat, no suitable trees in juniper-sage flats, riparian areas, or oak savannah are present to support breeding. The closest known occurrence per CNDDB records is from 2019, which documented a breeding pair approximately 2.3 miles south of the Buildout Area to the south of I-405. Although Swainson’s hawk has the potential to occur on or near the Buildout Area, there are no known nesting sites within the Buildout Area, no observations of Swainson’s hawk have been recorded within the Buildout Area, and there is no indication of Swainson’s hawk being present within the Buildout Area. Therefore, implementation of the proposed project is not expected to result in any impact on Swainson’s hawk.

Special Status Bats. The western mastiff bat is known to occur in many open, semi-arid to arid habitats, including conifer and deciduous woodlands, coastal scrub, grasslands, chaparral, etc.

This species roosts in crevices in vertical cliff faces, high buildings, and tunnels, and travels widely when foraging. The closest known occurrence per CNDDB records was recorded in 1990 and is located approximately 0.85-mile southeast of the Buildout Area within the Los Alamitos Armed Forces Reserve Center. Although moderate suitable roosting and foraging habitat is present in the Buildout Area and project vicinity, there is a lack of records of this species in the project vicinity.

The western yellow bat is found mostly in desert and desert riparian areas of the southwest US, but also has expanded its range with the increased usage of native and non-native ornamental palms in landscaping. Individuals typically roost amid dead fronds of palms in desert oases but have also been documented roosting in cottonwood trees. This species is known to forage over many habitats. The closest known occurrence per CNDDB records was recorded in 1990 and is located approximately 0.85-mile southeast of the Buildout Area within the Los Alamitos Armed Forces Reserve Center. Although moderate suitable roosting and foraging habitat is present in the Buildout Area and project vicinity, there is a lack of records of this species in the project vicinity.

The pocketed free-tailed bat is usually associated with cliffs, rock outcrops, or slopes. These species may roost in buildings (including roof tiles) or caves. While rare in California, this species is found in Riverside, San Diego, Imperial, and possibly Los Angeles Counties. The closest known occurrence per CNDDB records was recorded in 1989 approximately 10 miles northeast of the Buildout Area. Although low suitable roosting and foraging habitat are present in the Buildout Area and project vicinity, there is a lack of records of this species in the project vicinity.

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026
S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A
P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.4 Biological Resources_final.docx (03/11/26) 4.4-35 As described above, the western mastiff bat and western yellow bat have a moderate potential to occur within the Buildout Area. While western yellow bat is typically associated with desert and desert riparian habitats, their range has continued to expand into sheltering in palms used in landscaping. The Buildout Area provides palms for roosting and this species may also forage over the Buildout Area. The western mastiff bat may use the Buildout Area to forage and roost due to suitable high buildings being present on site. However, no portion of the Buildout Area is within designated or proposed critical habitat for any federally listed species.

Although no sign of roosting bats was observed during the September 2024 field survey, suitable day and night roosting habitat could be present at several of the building structures throughout the Buildout Area and within the ornamental palm trees located around the Buildout Area.

Additionally, other ornamental tree species within the Buildout Area could provide habitat to native bats in the form of foliage, bark, or cavity roosts. Bats breed in late spring/early summer (April–August), with foliage-dwelling species utilizing peeling bark, thick clumps of leaves, or cavities in trees often alone or in small maternity colonies. Bats attempting to roost or breed in landscape trees and/or buildings can be subject to impacts from tree removal or trimming activities (e.g., the trimming of palm fronds) and construction activities. Because bats have low reproductive turnover (i.e., most species have only one young per year) and high juvenile mortality, a colony or population of bats will require many years to recover from any impacts that result in mortality or even a decrease in reproductive ability. As such, western yellow bats and western mastiff bats may roost in trees and buildings throughout the Buildout Area and batroosting habitat may be subject to the indirect impacts from project construction activities.

As outlined in Section 4.4.4 Regulatory Setting, bats are protected under Section 4150 of the CFGC which protects nongame mammals, which are defined as any naturally occurring mammal in California that is not a game mammal, fully protected mammal, or fur-bearing mammal. Nongame mammals, which includes bats, bat roosts, and maternity colonies, may not be taken or possessed except as provided by the CFGC or in accordance with applicable regulations. Project actions would include removal of all buildings and vegetation in the Buildout Area. As such, the construction of the proposed project could impact bats if demolition took place during bat peak period or roosting season. However, with adherence to Regulatory Compliance Measure BIO-1 below, which reflects existing, applicable regulations, the proposed project’s impact on bats would be less than significant.

Regulatory Compliance Measure BIO-1 Preconstruction Bat Surveys. If construction activities for a specific development project within
the Buildout Area, including structure demolition
and tree removal, will occur during the bat
maternity season (April 1 to August 31), then the
City of Cypress, or designee, shall confirm that the
applicable developer has retained a qualified
biologist who shall conduct a nighttime bat survey
of potential maternity roost habitat no more than
30 days prior to the removal of potential habitat.

These surveys shall be initiated no later than 30
S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026

4.4 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.4 Biological Resources_final.docx «03/11/26» -36 minutes before sunset and continue for no less than
1 hour after sunset. If maternity roosts are found
and the project would result in impacts to roosting
bats, the biologist shall coordinate with California
Department of Fish and Wildlife (CDFW) to establish
appropriate avoidance buffers around all maternity
roost sites, and no construction work shall occur
within the buffers until the completion of the
maternity season. If deemed necessary through
coordination with CDFW, additional measures could
include two-step removal of any trees containing
maternity roosts (outside of the maternity season),
preparation of a Bat Habitat Mitigation and
Monitoring Plan (BHMMP), and humane bat
eviction/exclusion.

Potential impacts on special-status bat species that may be present within the Buildout Area would be addressed through implementation of Regulatory Compliance Measure BIO-1, as maternity bat roosts would be identified, no construction work would occur during maternity season, and appropriate site-specific and species-specific minimization measures would be developed in coordination with the CDFW and a qualified bat biologist.

Nesting Birds. Potential direct and/or indirect impacts (e.g., noise during construction) could potentially disrupt or otherwise adversely affect bird nesting activities in and/or adjacent to the Buildout Area if construction activities would occur within the nesting bird season (between February 1 and August 31). However, the implementation of Regulatory Compliance Measure BIO-2 below would avoid a significant impact on migratory birds. Although large areas of the Buildout Area are paved, it is recommended that Regulatory Compliance Measure BIO-2 be implemented on Lots 1 through 7 and 10 through 14 due to the presence of structures or trees thereon that may provide suitable habitat for nesting birds.

Regulatory Compliance Measure BIO-2 Preconstruction Nesting Bird Surveys and Active Nest Avoidance Buffers. If potential bird nesting
habitat is to be removed from a portion of the
Buildout Area in connection with a specific
development project during the avian nesting
season (January 1 through August 31), including
structures, trees, shrubs and suitable groundnesting areas, a qualified biologist shall conduct a nesting bird survey in such portion of the Buildout
Area within 3 days prior to the commencement of
structure demolition, vegetation removal, or other
construction activities that could remove suitable
nesting habitat.

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026
S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A
P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.4 Biological Resources_final.docx (03/11/26) 4.4-37 If no nesting birds are identified, no additional
survey is required. If at any time an active nest is
identified, the biologist shall establish suitable
buffers around the nests that consider the ecology
of the species present and the location of
construction activities to ensure that disruption of
nesting does not occur. The buffer areas shall be
avoided until the nests are no longer occupied and
the juvenile birds can survive independently from
the nests.

With implementation of Regulatory Compliance Measure BIO-2, the proposed project’s potential impact on nesting birds that may be present within the Buildout Area would be less than significant as nests, if present, would be identified and avoided during construction.

Overall, with implementation of Regulatory Compliance Measure BIO-1 and Regulatory Compliance Measure BIO-2, as discussed above, implementation of the proposed project would not have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by the CDFW or the USFWS. These impacts would therefore be less than significant, and no mitigation is required.

Threshold 4.4.2: Would the project have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, and regulations or by the California Department of Fish and Wildlife or the U.S. Fish and Wildlife Service?
No Impact. As discussed above, the CNDDB search identified Southern Coastal Salt Marsh as occurring near Alamitos Bay and another occurrence in Anaheim Bay, which is within 5 miles of the Buildout Area. However, both of these occurrences are historical and are presumed extant. In addition, no salt marsh habitat exists within the Buildout Area. As such, there would be no impact on the Southern Coastal Salt Marsh, or any other sensitive natural community, with implementation of the proposed project, and no mitigation is required.

The Buildout Area currently contains one existing drainage feature, one existing detention basin, and three existing artificial ponds. The single drainage feature is located on Lot 3 and originates from a culvert beneath the internal road just northwest of a parking lot. This drainage is an ephemeral, earthen bottom drainage created to carry stormwater. The detention basin is located on Lots 2 and 3 and is best described as a manmade basin created to capture flows. It appears to divert accumulated water into the adjacent drainage that terminates into an underground drain system.

The three artificial ponds are on Lots 3, 4, 6, and 7 and are manmade and thus, hydrologically isolated. The ponds contain hydrophytic vegetation along portions of their shoreline, including species that could be considered wetland indicators. All of these aquatic features were constructed in previously graded or developed areas and do not represent natural stream channels, wetlands, or riparian systems. Their primary functions are aesthetic or related to stormwater conveyance and S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026

4.4 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.4 Biological Resources_final.docx «03/11/26» -38 retention. As such, no riparian habitat is present within the Buildout Area. Therefore, no impacts to riparian habitat would result from project implementation, and no mitigation is required.

Threshold 4.4.3: Would the project have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
Less Than Significant with Mitigation Incorporated. As previously discussed, there is one drainage feature, one detention basin, and three ponds within the Buildout Area. The three artificial ponds identified within the Buildout Area contain hydrophytic vegetation along portions of their shoreline, including species that could be considered wetland indicators. However, the ponds are manmade and hydrologically isolated from other waters. As such, the three ponds are not expected to be regulated by USACE, RWQCB, or CDFW. The detention basin is entirely lined with polyethylene, is best described as a manmade basin created to capture flows, and appears to divert accumulated water into the adjacent drainage that terminates into an underground drain system. Similar to the artificial ponds, because the detention basin is and appears to be hydrologically isolated from other waters, the detention basin is also not expected to be regulated by USACE, RWQCB, or CDFW.

However, the single drainage feature located on Lot 3 contains ruderal vegetation and may connect to Coyote Creek, which is tributary to the San Gabriel River and ultimately flows into the Pacific Ocean. Therefore, the removal of this drainage may be subject to regulation by the RWQCB and CDFW. Impacts to these features would be potentially significant, and Mitigation Measure BIO-1 should be required.

Mitigation Measure BIO-1 Jurisdictional Delineation. Prior to commencing construction activities that would impact any of the identified aquatic resources in Lots 2, 3, 4, 6, and 7 of Vesting Tentative Tract Map (VTTM) 19247, a jurisdictional delineation shall be conducted, as follows:
• Regional Water Quality Control Board (RWQCB) Jurisdiction (Waters of the State): Delineation shall follow the State Wetland Definition and Procedures for Discharges of Dredged or Fill Material to Waters of the State (State Water Resources Control Board [SWRCB] 2019).
• California Department of Fish and Wildlife (CDFW) Jurisdiction (Streambed Alteration Program): The extent of CDFW
jurisdiction shall be identified consistent with California Fish and Game Code §§ 1600–1616, including the outer limits of the bed, bank, and channel and the extent of any associated riparian vegetation.
• United States Army Corps of Engineers (USACE) Jurisdiction (Waters of the United States [WOTUS]): The determination that no federal WOTUS occur on site shall be documented consistent with 33 CFR § 328.3, the USACE 1987 Wetland Delineation

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026
S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A
P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.4 Biological Resources_final.docx (03/11/26) 4.4-39 Manual, and the appropriate Regional Supplement (USACE
2008).

If impacts to RWQCB and/or CDFW jurisdictional waters are expected to occur, appropriate permits or authorization (e.g., Water Quality Certification/Waste Discharge Requirements, CDFW Lake and Streambed Alteration Agreement) shall be obtained prior to construction.

With implementation of Mitigation Measure BIO-1, potential impacts to State or federally protected wetlands would be reduced to less than significant as jurisdictional waters would be identified and the appropriate permits and approvals would be obtained, as necessary.

In addition, although construction and operational activities have the potential to result in temporary indirect effects to water quality including a potential increase in erosion and sediment transport into downstream aquatic areas and the contamination of waters from construction equipment, these potential indirect effects to hydrology and water quality would be avoided or substantially minimized through the implementation of Best Management Practices (BMPs) and a Water Quality Management Plan as discussed in Section 4.10, Hydrology and Water Quality.

Specifically, adherence to Regulatory Compliance Measures HYD-1 through HYD-3, provided in Section 4.10, Hydrology and Water Quality, during construction and operation would address erosion-related impacts through implementation of construction site BMPs and operational-period biotreatment BMPs to avoid erosion and sedimentation impacts to downstream aquatic areas and water quality. As such, there would be no impacts on any downstream State or federally protected wetlands. Therefore, the proposed project's impact on wetlands would be less than significant with mitigation incorporated.

Threshold 4.4.4: Would the project interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites?
Less Than Significant Impact. The Buildout Area is located within an urban, built-out area in the City and is currently disturbed and developed with existing uses. Although the Buildout Area contains one drainage feature, one detention basin, and three artificial ponds, which contain hydrophytic vegetation along portions of their shoreline including species that would be considered wetland indicators, these aquatic resources would not support native resident or migratory fish. Additionally, native wildlife habitat is largely absent within the Buildout Area and in the immediate vicinity.

Furthermore, the development surrounding the Buildout Area and the lack of ground cover and suitable foraging habitat make the site undesirable for many native wildlife species.

A total of 19 wildlife species were observed during the September 2024 field survey; however, the wildlife species observed or otherwise detected during the site survey are consistent with those typically encountered in and around urbanized Orange County. In addition, no special-status wildlife species were observed during the site survey, and suitable habitat for such species is absent from S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026

4.4 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.4 Biological Resources_final.docx «03/11/26» -40 the proposed project disturbance limits due to the high level of development. Further, the Buildout Area does not function as a wildlife movement corridor.

Although no sign of roosting bats was observed during the September 2024 field survey, suitable day and night roosting habitat could be present at several of the building structures throughout the Buildout Area and within the ornamental palm trees located around the Buildout Area. Similarly, although no nesting birds or their nests were observed at the time of the field survey, birds may still use the Buildout Area for nesting. Potential direct and/or indirect impacts (e.g., noise during construction) could potentially disrupt or otherwise adversely affect bird nesting or bat roosting activities in and/or adjacent to the Buildout Area. As such, implementation of the Regulatory Compliance Measure BIO-1 and Regulatory Compliance Measure BIO-2, which would require preconstruction nesting bird surveys, active nest avoidance buffers, and preconstruction bat surveys under specified circumstances, would address potential impacts to nesting birds and roosting bats.

Therefore, with implementation of the Regulatory Compliance Measure BIO-1 and Regulatory Compliance Measure BIO-2, any potential impacts related to wildlife nursery sites would be less than significant, and no mitigation is required.

Threshold 4.4.5: Would the project conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance? Less Than Significant Impact. Construction of the proposed project would involve the removal of existing trees. All tree removal activities would be consistent with Section 3.9 of the Specific Plan, which supersedes the City’s Landmark Tree Ordinance, as codified in Sections 17-17 through 17-27 of the City’s Municipal Code, and details the tree replacement standards for development within the Buildout Area. Consistent with Specific Plan requirements, all proposed tree removal required for a future development project would be described in the site plan review application and all removed trees would be replaced with an equivalent number of specimen trees, subject to adjustment in accordance with Section 5.6.2 of the Specific Plan.

With adherence to the tree replacement standards detailed in the Specific Plan, the proposed project would not conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance. The impact would be less than significant, and no mitigation is required.

Threshold 4.4.6: Would the project conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan? No Impact. There is no adopted Habitat Conservation Plan (HCP), Natural Community Conservation Plan (NCCP), or other regional habitat conservation plan applicable to the City. The Orange County Transportation Authority (OCTA) Natural Community Conservation Plan/Habitat Conservation Plan (NCCP/HCP) includes a Plan Area that covers the entirety of Orange County, including the City of Cypress. However, the City is not a party to the OCTA NCCP/HCP, and development activity within the City is not subject to the provisions of the OCTA NCCP/HCP. Therefore, the OCTA NCCP/HCP does not apply to the proposed project, and the proposed project would not conflict with any local,

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026
S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A
P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.4 Biological Resources_final.docx (03/11/26) 4.4-41 regional, or State HCP or NCCP. Therefore, the proposed project would result in no impact related to conflict with any provisions of an HCP or NCCP, and no mitigation is required.

4.4.7 Level of Significance Prior to Mitigation
Prior to implementation of regulatory compliance and mitigation measures, the proposed project has the potential to result in significant impacts to nesting birds, roosting bats, jurisdictional waters, and landmark trees. These impacts could arise from vegetation removal, construction noise, disturbance to bat maternity roosts, alteration of aquatic features, and removal or trimming of protected trees.

4.4.8 Regulatory Compliance Measures and Mitigation Measures

4.4.8.1 Regulatory Compliance Measures
The following regulatory compliance measures are existing requirements of the City’s Municipal Code that are applicable to the proposed project and are considered in the analysis of potential impacts related to biological resources. The City considers these requirements to be mandatory; therefore, they are not mitigation measures.

Regulatory Compliance Measure BIO-1 Preconstruction Bat Surveys. If construction activities for a specific development project within the Buildout
Area, including structure demolition and tree removal,
will occur during the bat maternity season (April 1 to
August 31), then the City of Cypress, or designee, shall confirm that the applicable developer has retained a
qualified biologist who shall conduct a nighttime bat
survey of potential maternity roost habitat no more
than 30 days prior to the removal of potential habitat.

These surveys shall be initiated no later than 30 minutes before sunset and continue for no less than 1 hour after sunset. If maternity roosts are found and the project
would result in impacts to roosting bats, the biologist shall coordinate with the California Department of Fish and Wildlife (CDFW) to establish appropriate avoidance
buffers around all maternity roost sites, and no
construction work shall occur within the buffers until
the completion of the maternity season. If deemed
necessary through coordination with CDFW, additional
measures could include two-step removal of any trees
containing maternity roosts (outside of the maternity
season), preparation of a Bat Habitat Mitigation and
Monitoring Plan (BHMMP), and humane bat eviction/
exclusion.

Regulatory Compliance Measure BIO-2 Preconstruction Nesting Bird Surveys and Active Nest Avoidance Buffers. If potential bird nesting habitat is to S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026

4.4 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.4 Biological Resources_final.docx «03/11/26» -42 be removed from a portion of the Buildout Area in
connection with a specific development project during
the avian nesting season (January 1 through August 31), including structures, trees, shrubs, and suitable groundnesting areas, a qualified biologist shall conduct a nesting bird survey in such portion of the Buildout Area within 3 days prior to the commencement of structure
demolition, vegetation removal, or other construction
activities that could remove suitable nesting habitat.

If no nesting birds are identified, no additional survey is required. If at any time an active nest is identified, the biologist shall establish suitable buffers around the
nests that consider the ecology of the species present
and the location of construction activities to ensure that disruption of nesting does not occur. The buffer areas
shall be avoided until the nests are no longer occupied and the juvenile birds can survive independently from
the nests.

Regulatory Compliance Measure HYD-1 Construction General Permit. (See Section 4.10, Hydrology and Water Quality)
Regulatory Compliance Measure HYD-2 Construction Dewatering Permit. (See Section 4.10, Hydrology and Water Quality)
Regulatory Compliance Measure HYD-3 Orange County MS4 Permit/City Municipal Code. (See Section 4.10, Hydrology and Water Quality)

4.4.8.2 Mitigation Measures
Future development facilitated under the proposed project would be required to implement the following Mitigation Measures.

Mitigation Measure BIO-1 Jurisdictional Delineation. Prior to commencing construction activities that would impact any of the identified aquatic resources in Lots 2, 3, 4, 6, and 7 of Vesting Tentative Tract Map (VTTM) 19247, a jurisdictional delineation shall be conducted, as follows:
• Regional Water Quality Control Board (RWQCB) Jurisdiction (Waters of the State): Delineation shall follow the State Wetland Definition and Procedures for Discharges of Dredged or Fill Material to Waters of the State (State Water Resources Control Board [SWRCB] 2019).

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026
S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A
P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.4 Biological Resources_final.docx (03/11/26) 4.4-43 • California Department of Fish and Wildlife (CDFW) Jurisdiction (Streambed Alteration Program): The extent of CDFW
jurisdiction shall be identified consistent with California Fish and Game Code §§ 1600–1616, including the outer limits of the bed, bank, and channel and the extent of any associated riparian vegetation.
• United States Army Corps of Engineers (USACE) Jurisdiction (Waters of the United States [WOTUS]): The determination that no federal WOTUS occur on site shall be documented consistent with 33 CFR § 328.3, the USACE 1987 Wetland Delineation Manual, and the appropriate Regional Supplement (USACE
2008).

If impacts to RWQCB and/or CDFW jurisdictional waters are expected to occur, appropriate permits or authorization (e.g., Water Quality Certification/Waste Discharge Requirements, CDFW Lake and Streambed Alteration Agreement) shall be obtained prior to construction.

4.4.9 Level of Significance after Mitigation
The proposed project would not result in significant impacts related to biological resources with implementation of Mitigation Measure BIO-1.

4.4.10 Cumulative Impacts
As defined in the State CEQA Guidelines, cumulative impacts are the incremental effects of an individual project when viewed in connection with the effects of past, current, and probable future projects within the cumulative impact area for biological resources. The cumulative area for biological impacts is the City and includes the related projects listed in Table 4.A: Summary of Related Projects and shown in Figure 4.1: Related Projects, in Chapter 4.0, Existing Setting.

As described above, due to the developed and disturbed nature of the Buildout Area, proximity to existing development, implementation of Mitigation Measure BIO-1, and adherence to Regulatory Compliance Measures BIO-1 and BIO-2, implementation of the proposed project would not result in significant impacts related to federal and State-listed species, waters of the United States or wetlands, migratory birds and wildlife movement. Additionally, as discussed above, although the Buildout Area is located within the OCTA NCCP/HCP that covers the entirety of Orange County, including the City of Cypress, the City is not a party to the OCTA NCCP/HCP, and development activity within the City is not subject to the provisions of the OCTA NCCP/HCP. Therefore, the OCTA NCCP/HCP does not apply to the proposed project. Additionally, the Buildout Area is not located within a designated habitat reserve and, therefore, the proposed project would not contribute to the loss of natural habitat in the City. The development of the proposed project would not result in the removal of any sensitive habitat species identified in the OCTA NCCP/HCP. Overall, based on the above discussion, implementation of the proposed would not result in significant cumulative effects on biological resources.

S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026

4.4 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.4 Biological Resources_final.docx «03/11/26» -44 In addition, some of the related projects identified in Table 4.A have undergone environmental review pursuant to CEQA, which included an analysis of potential impacts on biological resources.

According to the EIRs prepared for the Shea Properties Mixed Use Development Project (Related Project 1) and Melia Homes -Citrus Square Project (Related Project 2), impacts on biological resources would be less than significant with adherence to regulatory compliance measures related to compliance with existing NPDES permit requirements and the performance of nesting bird surveys, similar to the proposed project. The EIRs also determined that cumulative impacts related to biological resources would be less than significant. In addition, the Initial Study prepared for the Los Alamitos Medical Center Project (Related Project 7) indicated that impacts on biological resources would also be less than significant. The Goodman Commerce Center and the 5665 Plaza Drive Projects (Related Project 3) was analyzed in an Initial Study/Mitigated Negative Declaration (IS/MND) in 2023 and an EIR in 2024, respectively, which determined that all impacts on biological resources would also be less than significant with adherence to regulatory compliance measures related to compliance with existing NPDES permit requirements and the performance of nesting bird surveys, similar to the proposed project.

Furthermore, the Sycamore Creek Charter School Project (Related Project 6) and 4562 Katella Avenue Project (Related Project 8) were determined to be exempt from CEQA review under Section 15332 of the State CEQA Guidelines (for infill development) and Notices of Exemption (NOEs) were prepared. In order for a project to be exempt under Section 15332 of the State CEQA Guidelines, the Buildout Area must have no value as habitat for endangered, rare, or threatened species and the proposed project must not have a significant or cumulative effect on the environment. The LTP Modern Machine Project (Related Project 5) and 8561 Belmont Street Project (Related Project 4) would also be required to undergo environmental review pursuant to CEQA, which would include an analysis of potential impacts on biological resources and the identification of any mitigation measures to reduce potential impacts, if necessary. It should also be noted that each related project is located on a site within an urbanized area that is entirely surrounded by existing development.

Further, some of the related projects are located on infill sites, meaning the site has already been disturbed as part of prior development. As such, development of the related projects in combination with the proposed project would not result in significant impacts on biological resources.

Collectively, recent past, approved, and probable future projects that may occur in the vicinity, including the proposed project, would not result in a cumulatively significant increase in impacts on biological resources.

DRAFT EN VI RONMENTAL IMPACT REPO RT
M ARCH 2026

4.5 CULTURAL RESOURCES
SPECIFIC PLAN 3.0 BU ILDOUT PROJECT

CYPRESS, CALIFO RNIA
This section provides a discussion of the existing cultural resource environment and evaluates the potential impacts on cultural resources, including historical and archaeological resources, from implementation of the Specific Plan 3.0 Buildout Project (proposed project). Historical resources include all properties (historic, archaeological, landscapes, traditional, etc.) eligible or potentially eligible for the National Register of Historic Places, or State and local laws and programs. The analysis in this section is based in part on the Historic Resources Assessment (HRA) prepared for the 2021-2029 Cypress Housing Element Implementation Project1 and the Historic Resources Addendum (HRA Addendum) 2 (both provided in Appendix D) prepared for the proposed project.

The proposed project's impacts on tribal cultural resources are evaluated separately and can be found in Section 4.18, Tribal Cultural Resources.

4.5.1 Scoping Process
The City of Cypress (City) received six comment letters during the public review period of the Notice of Preparation (NOP). For copies of the NOP comment letters, refer to Appendix A of this Draft Environmental Impact Report (Draft EIR). No comment letters included comments related to cultural resources.

4.5.2 Methodology

4.5.2.1 Historical Resources
Race Course Archival Research. Archival research was conducted during the months of May, June, October, and November 2022. Research methods focused on the review of a variety of primary and secondary source materials relating to the history and development of the Los Alamitos Race Course property. Sources included, but were not limited to, information provided by and on file at the Los Alamitos Race Course, online sources, published literature in local and regional history, news articles, historic aerial photographs, and historic maps. Historical themes included horse racing, Quarter Horses, Frank Vessels, Sr., and pari-mutuel betting in California. A complete list of all references consulted in the preparation of the Historic Resources Assessment is provided in Appendix D.

Field Survey. On June 10, 2022, an LSA architectural historian and an LSA photographer conducted the intensive-level architectural survey of the Los Alamitos Race Course facility. The pair was escorted by the Los Alamitos Race Course Facilities Manager, who provided information about the buildings and features, as well as historical information about the facility. The trio began with the clubhouse/grandstand building including, but not limited to, Burgart's bar, the Cypress Room, the Vessels Club restaurant, the Finish Line room, the betting area, box seating, and the jockey room.

They then toured the barns and other features. During the survey, numerous photographs of the 2 LSA Associates, Inc. (LSA). 2023. Historic Resources Assessment, Cypress Housing Element Implementation, Cypress, Orange County, California. November. (Appendix D) LSA Associates, Inc. (LSA). 2025. Historic Resources Assessment Addendum to the Housing Element Implementation Project to support Specific Plan 3.0 Implementation Project, Cypress. November 4. (Appendix D)
P:\A-E\CCP2201.0S LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.S Cultural Resources.docx «03/10/26» 4.5-1 SPECIFIC PLAN 3.0 BUI LOO UT PROJECT

CYPRESS, CALIFORNIA

DR AFT EN VIRONMENTAL IMPACT REPORT
M ARCH 2026
buildings and track and overview shots were taken. LSA's architectural historian made notations regarding the structural and architectural characteristics and current conditions of the buildings and features. The architectural historian also made notes regarding the historical information provided by the Facilities Manager.

The field survey included numerous buildings, structures, and features, which are described below.

Construction and alteration information that was gleaned about the buildings, structures, and features during the survey is included. The focus of the survey was the 0.25-mile track used for horse racing, which provides the main architectural and historical significance to the Los Alamitos Race Course.

California Department of Parks and Recreation (DPR) 523 Series Forms. In August of 2023, California DPR 523 series forms were submitted on behalf of the Los Alamitos Race Course. DPR 523 series forms are used for recording and evaluating resources and for nominating properties to the California Register of Historical Resources. The forms included a description of the Los Alamitos Race Course as well as an evaluation of its historical significance under State and federal criteria, which will be discussed further within Section 4.5.6, Project Impacts.

Supplemental Historic Resources Assessment. In November 2025, an Addendum to the Cypress Housing Element Implementation Project HRA was prepared to update and supplement the HRA in connection with the proposed project.3 The Addendum clarifies the character-defining features of buildings and features that comprise the Los Alamitos Race Course (LARC), as they relate to the Clubhouse and Annex/Burgart's building; identifies how the proposed project would impact LARC's eligibility as a historic resource; and identifies feasible mitigation measures to reduce the proposed project's significant environmental impacts to LARC.

4.5.2.2 Archaeological Resources
Records Searches. In January 2020, a cultural resource record search was completed as part of the environmental review process for the proposed mixed-use Cypress City Center Project, located directly south of the Buildout Area. The record search was conducted at the South Central Coastal Information Center (SCCIC) of the California Historical Resources Information System (CHRIS) at California State University, Fullerton, and included a review of all prehistoric and historic archaeological sites within a 0.25-mile radius of the Cypress City Center Project. As such, the records search performed as part of the Cypress City Center Project included the Buildout Area, as well as a review of known cultural resource survey and excavation reports in the surrounding area. The California Historic Resources Inventory (HRI), the National Register of Historic Places (National Register), California Historical Landmarks (SHL), California Points of Historical Interest (SPHI), and various local historical registers were examined. No archaeological resources had been previously recorded within the Cypress City Center project site, and none were discovered as a result of the 3 LSA Associates, Inc. (LSA). 2025. Historic Resources Assessment Addendum to the Housing Element Implementation Project to support Specific Plan 3.0 Implementation Project, Cypress. November 4. (Appendix D)

4.5-2 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.5 Cultural Resources.docx «03/10/26»

DRAFT EN VI RONMENTAL IMPACT REPO RT
M ARCH 2026
SPECIFIC PLAN 3.0 BU ILDOUT PROJECT

CYPRESS, CALIFO RNIA
record search. 4 The Cypress City Center Project was constructed between 2021 and 2025, and no tribal cultural resources were identified during grading or construction activities. Because the records search for the Cypress City Center Project included the Buildout Area, this record search can be reasonably applied to the proposed project's Buildout Area. As a result of the conditions discussed above, a new cultural resource records search under the proposed project was determined to be unnecessary by the City.

4.5.3 Existing Environmental Setting

4.5.3.1 Pre-Settlement
The area that is now the City of Cypress was prehistorically occupied by several different Native American tribes with unique oral histories, societal structures, and ways of life. To date, no federally recognized tribes claim to have occupied the land that is now considered the City of Cypress.

According to the Cypress General Plan, 5 the level of Gabrielino culture that was encountered by the Spanish in the 18th century was a continuation of a culture formation originating as far back as 1200 AD. Prior to Spanish colonization, the Gabrielino population was estimated at more than 5,000 people. Various Spanish explorers had been in the region earlier, but in 1769, the Spanish under Gaspar de Portola began their colonization of the region. The people were given the name "Gabrielino" by the Franciscan Priests for their association with the Mission San Gabriel Arcangel, which was constructed by 1771 in San Gabriel, approximately 20 miles northwest of the Buildout Area. As a result of their induction into the mission, the Gabrielino population was decimated through disease.

The majority of the information on Gabrielino culture has been obtained from the remains of their material culture; however, much of it was perishable and therefore not available for research purposes. What is known is that they had abundant marine resources, terrestrial animals, and a heavy reliance on acorns. They also engaged in trade networks that included the exchange of resources from the Channel Islands, the mainland, and inland to Arizona, with more than 89 percent of the Gabrielino's physical environment within the extremely rich Sonoran life zone.

4.5.3.2 Settlement and Development
The historic period in California is divided into three periods: Spanish/Mission Period (1769-1821), Mexican/Rancho Period (1821-1848), and the American Period (1848-Present). Spanish exploration of southern California began in the late 1700s as expeditions began seeking routes from San Diego to the Los Angeles basin and further regions of "Alta California." One of the logical, geographic passages between the Pacific Coast and the Los Angeles Basin was what is now known as Santa Ana Canyon. Some of the more notable and documented explorers to use this route, which went through what would become Orange County, were Don Gaspar Portola, Juan Bautista de Anza, and 4 5
City of Cypress. 2020. Cypress City Center Project Environmental Report, Draft, SCH #2019110458. Section

4.16-4. Website: https://files.ceqanet.opr.ca.gov/257330-3/attachment/pPtqudn4yD91UlsUP _CKNqJ72 MJ0kYIHFzJsGzBHYFnlgWkhiTD33EKMOE--41QOdoGX3ne3ABNyl6Km0 (accessed March 2026).

City of Cypress. 2001. Cypress General Plan Conservation/Open Space/Recreation Element. September 10, 2001.

P:\A-E\CCP2201.0S LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.S Cultural Resources.docx «03/10/26» 4.5-3 SPECIFIC PLAN 3.0 BUI LOO UT PROJECT

CYPRESS, CALIFORNIA

DR AFT EN VIRONMENTAL IMPACT REPORT
M ARCH 2026
Don Pedro Fages. In 1784, General Pedro Fages received a petition from three of his soldiers who wanted land to build homes and graze the cattle they had acquired. 6 Fages agreed and that same year {1784) Manuel Perez Nieto was granted 300,000 acres, which became known as Los Nietos and included the area that would become Cypress. 7 After Manuel's death in 1804, the land was divided among his four surviving children and Juan Jose Nieto received the acres called Los Alamitos (approximately 28,000 acres) and Los Coyotes (approximately 49,000 acres), which include Cypress.8 In 1806, Nieto built an adobe house in the southwest corner of Rancho Los Alamitos. 9 In 1821, Mexico won independence from Spain and took over Alta California. In 1834, Juan Jose Nieto was formally granted Los Alamitos by Governor Juan Figueroa and a few months later sold it to the governor for just $500. 10 Figueroa later sold it to Abel Stearns in 1842.11 Eventually Stearns owned both ranchos (Los Alamitos and Los Coyotes) and "built up the largest land and cattle empire in the area." 12
In 1848, Alta California came under control of the United States, and in 1850, it was admitted to the Union. In 1861, Stearns borrowed on the Rancho from money lender Michael Reese to finance a business venture in Los Angeles.13 By 1865, Stearns was in jeopardy of losing his land to Reese so a group of his friends formed the Robinson Trust to save him from bankruptcy.14 In 1866, Reese foreclosed on a portion of the Rancho and began leasing it to the Bixbys, who were sheep farmers from Maine.15 Meanwhile, in 1868, the Trust began to sell 120- to 160-acre tracts and by the time Stearns died in 1871, he was on his way to another fortune.16 The 1880s was a boom period in southern California that helped complete "the transition from range land to agricultural economy." 17 Between 1866 and 1884 the population of Los Angeles increased from approximately 12,000 to around 100,000 and other cities also were expanding rapidly.18 Orange County was formed in 1889, putting half of Rancho Los Alamitos in Los Angeles 6 Carpenter, Virginia. 2003. Ranchos of Orange County: Chronologies of Early California. Produced in cooperation with Jane Mueller. California: The Paragon Agency Publishers. 7 8 9
Ibid.

Ibid.

Ibid.
10 Ibid.
11 Ibid.
12 Wheeler, Eileen, and Dr. Warren Beck. City of Cypress History. News-Enterprise Archives. Website:
http://www.cypressca.org/home/showdocument?id=6 (accessed March 2026). 13 Carpenter, Virginia. 2003. Ranchos of Orange County: Chronologies of Early California. Produced in cooperation with Jane Mueller. California: The Paragon Agency Publishers. 14 Ibid.
15 Ibid.
16 Ibid.
17 Wheeler, Eileen, and Dr. Warren Beck. City of Cypress History. News-Enterprise Archives. Website:
http://www.cypressca.org/home/showdocument?id=6 (accessed March 2026). 18 Ibid.

4.5-4 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.5 Cultural Resources.docx «03/10/26»

DRAFT EN VI RONMENTAL IMPACT REPO RT
M ARCH 2026
SPECIFIC PLAN 3.0 BU ILDOUT PROJECT

CYPRESS, CALIFO RNIA
County and half in Orange County. 19 In 1881, John and Jotham Bixby and Isaac Hellman (a banker) bought Rancho Los Alamitos and joined it to Los Cerritos. 20 They formed the Alamitos Land Company to subdivide part of the Rancho into farm lands. 21 This represents the beginnings of what would become Cypress.

By the late 1880s, white and sweet potatoes, as well as sugar beets were the main crops. 22 However, dairy farming, which was supported by the beet farming, was a major industry with nearby Buena Park at its center. 23 In the Cypress area almost everyone had cows, but sorghum was what the area was really known for. 24 In 1889, the McWilliams family moved to the area, planted sorghum, and established a makeshift processing plant for it. 25 In its first year, it processed 100 gallons of syrup.26 Soon other farmers planted sorghum and the industry steadily expanded.27 In 1907, a regular mill was built that processed 15,000 gallons of syrup its first year. 28 As more people moved into the area, the demand grew for schools. In the early 1890s, there were two schools, Centralia and Bloomfield. 29 In 1895, the Cypress School District was formed, and a building was constructed on an acre of land donated by Charles Lee Damron. 30 The new school was named Cypress School because of the cypress trees planted around the school yard as a windbreak.

For many years, it was the only school in the district.31 "In 1906, Pacific Electric built a line to the area to connect Los Angeles to Santa Ana" and development began to cluster around the rail station "at what is now the intersection of Lincoln Avenue and Walker Street" within the Lincoln Avenue Specific Plan area.32 At that time, the community was nicknamed Waterville due to the preponderance of artesian wells in the area, but the train station was named Cypress reportedly to be consistent with the school. 33 In 1924, the school was replaced with a larger building that became the center of the community's social life.34
19 Carpenter, Virginia. 2003. Ranchos of Orange County: Chronologies of Early California. Produced in cooperation with Jane Mueller. California: The Paragon Agency Publishers. 20 Ibid.

Ibid. 21
22 Wheeler, Eileen, and Dr. Warren Beck. City of Cypress History. News-Enterprise Archives. Website:
http://www.cypressca.org/home/showdocument?id=6 (accessed March 2026). 23 24 25
26 27
28 29
30 Ibid.

Ibid.

Ibid.

Ibid.

Ibid.

Ibid.

Ibid.

Ibid.
31 Epting, Charles. 2014. The New Deal in Orange County California. South Carolina: The History Press. 32 Wheeler, Eileen, and Dr. Warren Beck. City of Cypress History. News-Enterprise Archives. Website:
http://www.cypressca.org/home/showdocument?id=6 (accessed March 2026). 33 Carpenter, Virginia. 2003. Ranchos of Orange County: Chronologies of Early California. Produced in cooperation with Jane Mueller. California: The Paragon Agency Publishers. 34 Ibid.

P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.S Cultural Resources.docx «03/10/26» 4.5-5 SPECIFIC PLAN 3.0 BUI LOO UT PROJECT

CYPRESS, CALIFORNIA

DR AFT EN VIRONMENTAL IMPACT REPORT
M ARCH 2026
During the Depression era, the area was hard hit by the 1933 Long Beach earthquake, which damaged Cypress School, and the 1938 flood, which left most of Waterville under two to three feet of water. 35 The school was rebuilt in 1936 using Public Works Administration funds and was still the only school in the Cypress School District. 36 Although rural communities like Waterville suffered less from the Depression, people still struggled. The needy were assisted by a variety of federal relief programs and many school children received free hot lunches. 37 "In 1910, a local farmer named George Miller formed the Southern California Dairy Association, and by the 1940s, dairies emerged as the community's leading industry." 38 However, the World War II years brought many changes to the area as several military facilities moved nearby. These included the United States Naval Station in Los Alamitos (next to Cypress), the Seal Beach Ammunition Depot, the United States Naval Air Station in Santa Ana, the Santa Ana Army Air Base, and Irvine Park, which was used as an Army training camp. 39 Aircraft plants and ship yards created jobs in nearby communities such as Long Beach and Santa Monica. The combination of new employment opportunities and men joining the armed services created a shortage of labor in the fields. 40 To alleviate the shortage, workers from Mexico were brought in through treaty arrangements and later German prisoners of war were used to harvest crops.41
After the war, returning Gls created such a big demand for housing in surrounding areas that many farmers relocated to Waterville.42 By the late 1940s, Waterville was the third largest dairy district in the country.43 When it incorporated in 1956, it took the name Dairy City. 44 In the 1950s, Dairy City (now Cypress), Dairyland (now La Palma), and Dairy Valley (now Cerritos) were collectively known as "Moo-Valley." 45 In 1957, the city's name was changed to Cypress.46 In the 1960s, skyrocketing real estate prices in Moo Valley resulted in an exodus of dairy farmers to Riverside County. 47 35 36
37 38
39 40
41 42
43 44
45 46
Wheeler, Eileen, and Dr. Warren Beck. City of Cypress History. News-Enterprise Archives. Website:
http://www.cypressca.org/home/showdocument?id=6 (accessed March 2026).

Epting, Charles. 2014. The New Deal in Orange County California. South Carolina: The History Press.

Wheeler, Eileen, and Dr. Warren Beck. City of Cypress History. News-Enterprise Archives. Website:
http://www.cypressca.org/home/showdocument?id=6 (accessed March 2026).

Ibid.

Ibid.

Ibid.

Ibid.

Ibid.

Ibid.

Epting, Charles. 2014. The New Deal in Orange County California. South Carolina: The History Press.

Wheeler, Eileen, and Dr. Warren Beck. City of Cypress History. News-Enterprise Archives. Website:
http://www.cypressca.org/home/showdocument?id=6 (accessed March 2026).

Ibid.
47 Whiting, David. 2015. Cypress Evolves from Cow Town to Community Town . The Orange County Register.

Website: https://www.ocregister.com/2015/08/04/whiting-cypress-evolves-from-cow-town-tocommunity-town/ (accessed March 2026).

4.5-6 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.S Cultural Resources.docx «03/10/26»

DRAFT EN VI RONMENTAL IMPACT REPO RT
M ARCH 2026

4.5.3.3 Frank Vessels, Sr. and the Los Alamitos Race Course SPECIFIC PLAN 3.0 BU ILDOUT PROJECT

CYPRESS, CALIFO RNIA
Frank Vessels was born in Elizabethtown, Kentucky in 1898. In 1920, he was living in San Bernardino County, California, married to Martha Grace Hagey (known as Grace), and working as an attendant at the State hospital. By 1922, the Vessels had relocated to Huntington Beach, and Frank had a business selling boilers and pipe fittings in Santa Fe Springs. In the late 1920s and 1930s, news articles revealed that Frank had at least one oil well in Huntington Beach {1927), a construction business called Industrial Engineering Company in Long Beach where the Vessels also lived {1930), and he owned a 10-acre citrus grove in San Bernardino County {1935). In 1935, it was reported that plans for an $11,000, nine-room Colonial style home and garage designed by architect George Kahrs for Frank Vessels, manager of the Oil Field Construction Company, were being planned. The residence (still extant) was located at 4470 Olive Avenue in Long Beach. Vessels was active in Long Beach civic affairs during the 1930s and into the early 1940s and was often mentioned in the local newspapers. One article noted that he was captain of the Long Beach Honorary Mounted Police Patrol, which was composed of leading businessmen in the city, and another said he was charter vice president of the Oil Field Service Club.

In 1945, it was reported that Vessels bought a yearling bull named President Mischief 9th for $16,750 (over $270,000 in 2023 dollars), the highest price ever paid for a bull in California. In 1946, Vessels purchased 435 acres in what would become the City of Cypress. Around that same time, Vessels and Huntley Gordon of Chino, California, "traveled through Texas and Oklahoma buying railroad carloads of good mares. The need for a stallion was solved when Vessels bought Clobber for $5,000 dollars and shipped the "Iron Horse" from Arizona to his ranch in Cypress, California".

Clobber was named the World's Champion Quarter Horse by the American Quarter Horse Racing Association in 1941. During his racing career, he was used as a rope horse and a racehorse and once ran three quarter-mile races in one day and won them each in 23 seconds. This buying spree was the foundation for Vessels Stallion Farm.

In 1947, Frank Vessels, Sr., built a race track on his 435-acre ranch and stallion farm in present-day Cypress.48 It was initially used for training and match racing the Quarter Horses {QH) he bred there, but by the Spring, Vessels' new race track "located two miles west of Stanton on Katella Road near the Los Alamitos Air Station" began to host motorcycle races sanctioned by the American Motorcycle Association. 49 In August 1947, a crowd variously estimated at between one and two thousand showed up to watch the first full card of QH racing, six non-pari-mutuel races (fans could not bet on the horses). Soon the QH races became a weekly event.50 At that time, the track was located a little southwest of where it is today in an area between Vessels' home and the railroad tracks. The area is now developed with Ovation at Flora Park, a 55+ residential community.

Attendance at the QH races was so high that Vessels had to scale back the races to once a month.

During this time, it was only legal to bet on thoroughbred (TB) horse races and standardbreds 48 Long Beach Press-Telegram. 1947. Cycle Club Bills Races on New Vessels Track. page 16. 49 Ibid.
so Chamberlain, Richard. 2000. Los Alamitos Race Course 50 Years of Racing 1951-2000. Brochure provided by Facilities Manager, Frank Sherran, June 2022.

P:\A-E\CCP2201.0S LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.S Cultural Resources.docx «03/10/26» 4.5-7 SPECIFIC PLAN 3.0 BUI LOO UT PROJECT

CYPRESS, CALIFORNIA

DR AFT EN VIRONMENTAL IMPACT REPORT
M ARCH 2026
(trotters), because the sport generated State tax revenues, which were used, among other things, to improve the breeds. In 1948, the State Attorney General ruled that Quarter Horse racing was legal based on current law, because by then registered Quarter Horses were a recognized breed. Despite this ruling, the California Horse Racing Board {CHRB), which was controlled by the breeders of thoroughbreds, refused to allow betting on QH races.51 This prompted the QH breeders to organize.

Vessels founded and became president of the Pacific Coast Quarter Horse Association, an affiliate of the national association, and began lobbying Sacramento for pari-mutuel wagering on Quarter Horses. 52 The State Legislature passed a bill allowing the State's six major tracks to include one Quarter Horse race per day. Bay Meadows at San Mateo was the first, carding 25 sprints. 53 Finally, the CHRB agreed to pari-mutuel betting on QH races. This had a profound impact on the sport of horse racing and the industry of horse breeding in California.

In December 1951, the first pari-mutuel all-Quarter Horse meet was held at Vessels' track, with more than 400 sprinters from various states and over 4,100 spectators the first day. 54 On closing day, more than 7,000 fans showed up, indicating that Quarter Horse racing would maintain its popularity.55 In 1952, Monita and Black Easter Bunny won "divisions of the first Los Alamitos Invitational Championship, then called the California Championship." 56 By 1953, a new track was under construction northwest of the original track (Historicaerials.com var.57) . The new track (in the current location) opened in 1954 in time for the Fall meet and soon became the "premier Quarter Horse track in the country." 58 By 1959, Los Alamitos Race Course was the second largest revenue generator in the City of Cypress. Frank Vessels, Sr., was inducted into the American Quarter Horse Association Hall of Fame {1989). Los Alamitos Race Course is the premiere Quarter Horse (QH) race track in California, hosting the Champion of Champion stakes race since 1972 ($750,000 purse, 440 yards distance.) The golden age of horse racing came to an end around 1970, when attendance declined due to off track betting (OTB) and competition from other forms of entertainment. The track stayed in the Vessels family until 1984, when it was sold to Hollywood Park. 59 By 1989, it was under a new ownership group, including Edward Allred, that soon began a series of renovations to the buildings and the track's interior. 60 51 52
53 54
55 56
57 Chamberlain, Richard. 2000. Los Alamitos Race Course 50 Years of Racing 1951-2000. Brochure provided by Facilities Manager, Frank Sherran, June 2022.

Ibid.

Ibid.

Ibid.

Chamberlain, Richard. 2000. Los Alamitos Race Course 50 Years of Racing 1951-2000. Brochure provided by Facilities Manager, Frank Sherran, June 2022.

Ibid.

Historicaerials.com. var. Historic aerial photographs of the Los Alamitos Race Course property. Website:
https://www.historicaerials.com/viewer (accessed March 2026). 58 Chamberlain, Richard. 2000. Los Alamitos Race Course 50 Years of Racing 1951-2000. Brochure provided by Facilities Manager, Frank Sherran, June 2022. 59 Ibid. 60 Los Angeles Times. 1991. Los Alamitos: Track Celebrates 40th Anniversary. Website: https://www.latimes. com/archives/la-xpm-1991-12-04-sp-244-story.html (accessed March 2026).

4.5-8 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.S Cultural Resources.docx «03/10/26»

DRAFT EN VI RONMENTAL IMPACT REPO RT
M ARCH 2026
SPECIFIC PLAN 3.0 BU ILDOUT PROJECT

CYPRESS, CALIFO RNIA
Over time, portions of the property originally bought by Frank Vessels, Sr. were sold and incrementally redeveloped into a mix of urban land uses, including recreational, commercial, and residential uses. By 1992, a golf course to the northwest and southwest of the track are visible in aerial photographs. By 2005, several commercial buildings and parking lots had been constructed east of the track along Walker Street. Between 2005 and 2009, a church replaced part of the golf course southwest of the track. After the Hollywood Park racetrack in Inglewood closed in December 2013, the track itself was changed to accommodate thoroughbred racing. Circa 2019, the Ovation at Flora Park retirement community was built south of the barns and southwest of the track on land formerly occupied by a golf course. An apartment building, townhomes, a hotel, and a shopping center were recently constructed on areas that were formerly used as parking lots for the race track.

Although Los Alamitos Race Course has sustained alterations to most, if not all, of its buildings and character-defining features, including the original race track, it retains enough integrity to convey an association with the historic period. All character-defining features remain including the grandstand, race track, and chute on the south side of the track. The Clubhouse and Annex/Burgart's are not character-defining features because these features do not retain sufficient integrity to reflect the Los Alamitos Race Course's period of significance. The period of significance for Los Alamitos Race Course is 1954, when the track was built at the current location, to 1970, which is the end of the golden age of horse racing.

4.5.4 Regulatory Setting
The following section describes the federal, State, regional, and local regulatory framework applicable to analyzing potential impacts related to cultural resources from development of the proposed project.

4.5.4.1 Federal Regulations
The National Historic Preservation Act of 1966 (NHPA). The NHPA requires that the federal government list significant historic resources on the National Register of Historic Places {National Register). Federal agencies must consult the National Register when planning to undertake or grant approval through permits for a project. Prior to the issuance of any license or implementation of any project, the federal agency must consider the effects of a project or license on any historical buildings, sites, structures, or objects that are included on, or eligible for inclusion on, the National Register {16 United States Code [USC] Section 470{f)). This typically includes consultation with the federal agency responsible for the undertaking; the State Historic Preservation Officer (SHPO); local Native American groups and individuals; local and State historical societies and organizations; and relevant archival sources, including the appropriate facility of the California Historical Resources Information System {CHRIS). A cultural resource is evaluated for eligibility for listing in the National Register according to four criteria. These criteria generally require that the resource be 50 years of age or older and significant at the local, State, or national level according to one or more of the following:

A. It is associated with events that have made a significant contribution to the broad patterns of our history;
B. It is associated with the lives of persons significant in our past; P:\A-E\CCP2201.0S LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.S Cultural Resources.docx «03/10/26» 4.5-9 SPECIFIC PLAN 3.0 BUI LOO UT PROJECT

CYPRESS, CALIFORNIA

DR AFT EN VIRONMENTAL IMPACT REPORT
M ARCH 2026
C. It embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of a master, or possesses high artistic values, or that represent a significant and distinguishable entity whose components lack individual distinction; and/or
D. It has yielded, or may be likely to yield, information important to prehistory or history.

Properties that are not 50 years of age or older must have "exceptional significance" in accordance with National Register Criteria Considerations. The National Register also requires that a resource possess integrity, which is defined as "the ability of a property to convey its significance." The aspects of integrity are location, design, setting, materials, workmanship, feeling, and association.

To determine which of these factors are most important will depend on the particular National Register criterion under which the resource is considered eligible for listing.

The Native American Graves Protection and Repatriation Act (NAGPRA). The NAGPRA (Public Law 101-601; 25 USC 3001-3013) describes the rights of Native American lineal descendants, Indian tribes, and Native Hawaiian organizations with respect to the treatment, repatriation, and disposition of Native American human remains, funerary objects, sacred objects, and objects of cultural patrimony, referred to collectively in the statute as cultural items, with which they can show a relationship of lineal descent or cultural affiliation. It requires that federal agencies and museums receiving federal funds inventory holdings of Native American human remains and funerary objects and provide written summaries of other cultural items. 61

4.5.4.2 State Regulations
State CEQA Guidelines Section 15064.5. Pursuant to Section 15064.5 of the State CEQA Guidelines, the term "historical resource" shall include:
(1) A resource listed in, or determined to be eligible by, the State Historical Resources Commission, for listing in the California Register of Historical Resources [California Register] (Pub. Res. Code §5024.1, Title 14 California Code of Regulations [CCR], Section 4850 et seq.). (2) A resource included in a local register of historical resources, as defined in section 5020.l(k) of the Public Resources Code or identified as significant in an historical resource survey meeting the requirements section 5024.l(g) of the Public Resources Code, shall be presumed to be historically or culturally significant. Public agencies must treat any such resource as significant unless the preponderance of evidence demonstrates that it is not historically or culturally significant.
(3) Any object, building, structure, site, area, place, record, or manuscript which a lead agency determines to be historically significant or significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, military, or cultural annals of California may be considered to be an historical resource, provided the lead agency's 61 National Park Service (NPS). The Native American Graves Protection and Repatriation Act (NAGPRA).

Website: https://www.nps.gov/archeology/tools/laws/nagpra.htm (accessed March 2026).

4.5-10 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.5 Cultural Resources.docx «03/10/26»

DRAFT EN VI RONMENTAL IMPACT REPO RT
M ARCH 2026
SPECIFIC PLAN 3.0 BU ILDOUT PROJECT

CYPRESS, CALIFO RNIA
determination is supported by substantial evidence in light of the whole record. Generally, a resource shall be considered by the lead agency to be "historically significant" if the resource meets the criteria for listing on the California Register of Historical Resources (Pub. Res. Code, § 5024.1, Title 14 CCR, Section 4852) including the following:

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

B. Is associated with the lives of persons important in our past.

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

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

In addition, Section 15064.5(a)(4) of the State CEQA Guidelines states that the fact that a resource is not listed in, or determined to be eligible for listing in the California Register, not included in a local register of historical resources (pursuant to PRC Section 5020.l(k)), or identified in an historical resources survey (meeting the criteria in PRC Section 5024.l(g)) does not preclude a lead agency from determining that the resource may be an historical resource as defined in PRC Sections 5020.l(j) or 5024.1.

Further, Section 15064.5(b) of the State CEQA Guidelines states that a project with an effect that may cause a substantial adverse change in the significance of an historical resource is a project that may have a significant effect on the environment. A "substantial adverse change" to a historical resource "means demolition, destruction, relocation, or alteration such that the significance of a historical resource would be impaired."
California Health and Safety Code (HSC) Section 7050.5. California HSC Section 7050.5 states that, in the event of discovery or recognition of any human remains in any location other than a dedicated cemetery, there shall be no further excavation or disturbance of the site or any nearby area reasonably suspected to overlie adjacent remains until the Coroner of the county in which the remains are discovered has determined whether or not the remains are subject to the Coroner's authority. If the human remains are of Native American origin, the Coroner must notify the Native American Heritage Commission (NAHC) within 24 hours of this identification. The NAHC will identify a Native American Most Likely Descendant (MLD) to inspect the site and provide recommendations for the proper treatment of the remains and associated grave goods.

Public Resources Code Section 5097.5. PRC Section 5097.5 provides for the protection of cultural resources and prohibits the removal, destruction, injury, or defacement of archaeological features on any lands under the jurisdiction of State or local authorities.

California Register of Historical Resources (PRC Section 5020 et seq.). State law also protects cultural resources by requiring evaluations of the significance of prehistoric and historic resources in CEQA documents. A cultural resource is an important historical resource if it meets any of the P:\A-E\CCP2201.0S LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.S Cultural Resources.docx «03/10/26» 4.5-11 SPECIFIC PLAN 3.0 BUI LOO UT PROJECT

CYPRESS, CALIFORNIA

DR AFT EN VIRONMENTAL IMPACT REPORT
M ARCH 2026
criteria found in State CEQA Guidelines Section 15064.5(a). These criteria are nearly identical to those for the National Register, which are listed above under Section 4.5.4.1, Federal Regulations.

The SHPO maintains the California Register. Properties listed, or formally designated eligible for listing, on the National Register are nominated to the California Register and then selected to be listed on the California Register, as are State Landmarks and Points of Interest.

The California Register criteria are based on National Register criteria. For a property to be eligible for inclusion in the California Register, one or more of the following criteria must be met:

1. It is associated with the events that have made a significant contribution to the broad patterns of local or regional history, or the cultural heritage of California or the United States;

2. It is associated with the lives of persons important to local, California, or national history;

3. It embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of a master, or possesses high artistic values; and/or

4. It has yielded, or has the potential to yield, information important to the prehistory or history of the local area, California, or the nation.

In addition to meeting one or more of the above criteria, the California Register requires that sufficient time has passed since a resource's period of significance to "obtain a scholarly perspective on the events or individuals associated with the resource." Fifty years is used as a general estimate of time needed to develop the perspective to understand the resource's significance (California Code of Regulations [CCR] 4852[d][2]).

The California Register also requires that a resource possess integrity, which is defined as "the authenticity of an historical resource's physical identity evidenced by the survival of characteristics that existed during the resource's period of significance". 62 To retain integrity, a resource should have its original location, design, setting, materials, workmanship, feeling, and association. Which of these factors is most important depends on the particular criterion under which the resource is considered eligible for listing. 63

4.5.4.3 Regional Regulations
There are no regional regulations that are applicable to cultural resources relevant to the proposed project.
62 63
California Office of Historic Preservation (OHP). 1999. California Register and National Register: A Comparison (for purposes of determining eligibility for the California Register), OHP Technical Assistance Series #6. Pg. 2.

Ibid.

4.5-12 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.5 Cultural Resources.docx «03/10/26»

DRAFT EN VI RONMENTAL IMPACT REPO RT
M ARCH 2026

4.5.4.4 Local Regulations
SPECIFIC PLAN 3.0 BU ILDOUT PROJECT

CYPRESS, CALIFO RNIA
Cypress Town Center and Commons Specific Plan 3.0. The Cypress Town Center and Commons Specific Plan 3.0 does not contain any provisions related to cultural resources.

Cypress General Plan. The Conservation/Open Space/Recreation (COSR) Element of the Cypress General Plan identifies goals and policies related to cultural resources (and includes references to paleontological resources). Goal COSR-5 is to "preserve Cypress' archaeologic and palaeontologic resources." 64 COSR-5.1 and COSR-5.2 were identified as policies in order to achieve Goal COSR-5.

Policy COSR-5.1 is "to update records of resource finds and locations when required" 6s and COSR-5.2 states that "[p]rior to development in previously undeveloped areas, [the City will] require strict adherence to the CEQA guidelines for environmental documentation and mitigation measures where development will affect archaeological or paleontological resources." 66 However, the City's General Plan does not identify any historic resources and does not contain any specific policies to protect historic resources. In fact, the City's General Plan states that a record search was conducted by the Regional Information Center at UCLA on November 1, 1991, and yielded negative results for any recorded prehistoric or historic sites. This search also involved a review of maps from the years 1896-1942, which showed a high volume of development between 1942 and 1996. The City contains no National Register listed or eligible properties, or any State Landmarks.

4.5.5 Thresholds of Significance
The thresholds of significance for cultural resources impacts used in this analysis are consistent with Appendix G of the State CEQA Guidelines. Based on these thresholds, implementation of the proposed project would have a significant adverse impact with respect to cultural resources if it would:

Threshold 4.5.1: Cause a substantial adverse change in the significance of a historical resource pursuant to §15064.5;
Threshold 4.5.2: Cause a substantial adverse change in the significance of an archaeological resource pursuant to §15064.5; or
Threshold 4.5.3: Disturb any human remains, including those interred outside of dedicated cemeteries.
64 65
66 City of Cypress. 2001. Cypress General Plan Conservation/Open Space/Recreation Element. September 10, 2001. Website: https://www.cypressca.org/home/showpublisheddocument/686/63612 3123792970000 (accessed March 2026).

Ibid.

Ibid.

P:\A-E\CCP2201.0S LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.S Cultural Resources.docx «03/10/26» 4.5-13 SPECIFIC PLAN 3.0 BUI LOO UT PROJECT

CYPRESS, CALIFORNIA

4.5.6 Project Impacts

DR AFT EN VIRONMENTAL IMPACT REPORT
M ARCH 2026
Threshold 4.5.1: Would the project cause a substantial adverse change in the significance of a historical resource pursuant to §15064.5?
Significant and Unavoidable Impact. The approximately 134-acre Buildout Area includes approximately 97 acres owned by the Los Alamitos Race Course (LARC). The LARC Property includes a variety of existing structures and facilities located on the LARC Property that support horse racing, training, and community activities. Structures include a race track, grandstand structure, three artificial lakes inside the race track, a one-story clubhouse and restaurant structures, lighting structures, approximately 41 permanent one-story barns and several temporary structures and barns. The LARC Property also contains parking areas, landscaping, drainage features, sheds, maintenance areas, and perimeter fencing. The LARC Property's primary structures include the Main Grandstand, Clubhouse Building, and Annex/Burgart's. The Main Grandstand, built in 1958, is a fivestory, 140,000-square-foot structure standing approximately 65 feet high, with a seating capacity of 6,500 people. The Clubhouse Building, constructed in 1955, is a two-story, 35,000-square-foot structure with a capacity of 2,900 people, including an additional 25,000 square feet of patron space. The three-story Annex/Burgart's building was built between the Grandstand and the Clubhouse by 1963 and originally had a rooftop patio, which was enclosed in the 1980s. In 1976, permits were issued for alterations to the Annex/Burgart's building, which indicates that the bar and dining area were to be enlarged and a restroom and future bar were planned at ground level in the breezeway between the grandstand and clubhouse. The south elevation was extensively remodeled, including removal/replacement of all windows and enclosure of the rooftop patio. These alterations occurred outside the period of significance (post-1970).

As noted, there are a total of approximately 41 barns supporting the horse racing and training operations on the LARC Property. This includes 36 cinder block barns built in 1958, each approximately 14,000 square feet (totaling 504,000 square feet). Additionally, there are five modular-style barns built in 2013, each about 12,480 square feet (totaling 62,400 square feet). The LARC Property also features the 1,960-square-foot Horseman's Restaurant, constructed in 1999, along with various temporary structures.

As part of the EIR prepared for the 2021-2029 Cypress Housing Element Implementation Project, a Historic Resources Assessment (HRA) was prepared in October 2023. The HRA included archival research, an intensive-level field survey, and an evaluation of the LARC Property under the criteria for listing in the National Register of Historic Places (National Register) and California Register of Historical Resources (California Register). Upon these evaluations, the LARC Property was determined to be eligible for both the National Register and the California Register. These eligibilities stem from the LARC's association with the establishment and success of organized Quarter House racing in California (National Register Criterion A/California Register Criterion 1) and with Frank Vessels, Sr., who had a profound impact on quarter horse racing and breeding in California (National Register Criterion B and California Register Criterion 2). California Department of Parks and Recreation (DPR) 523 series forms recording and evaluating the site as a historic resource were prepared and are attached as an appendix to the HRA (Appendix D).

4.5-14 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.5 Cultural Resources.docx «03/10/26»

DRAFT ENVIRONMENTAL IMPACT REPORT
MARCH 2026
SPECIFIC PLAN 3.0 BUILDOUT PROJECT

CYPRESS, CALIFORNIA
Subsequent to the preparation of the HRA in October 2023, an Addendum to the HRA was prepared to update and supplement the HRA in connection with the proposed project to (1) clarify the character-defining features of buildings and features that comprise LARC, as they relate to the Clubhouse and Annex/Burgart's building, (2) identify how the proposed project would impact LARC's eligibility as a historic resource, and (3) identify feasible mitigation measures to reduce the proposed project's significant environmental impacts to LARC. Based on the HRA Addendum's findings, the primary buildings and features that comprise the LARC Property are eligible for listing in the National Register and California Register under Criteria A/1 and B/2 for LARC's association with the establishment and success of organized quarter horse racing in California (A/1) and Frank Vessels, Sr (B/2). As such, the LARC Property is considered a "historical resource" for the purposes of CEQA. The HRA identified the LARC character-defining features as (1) the grandstand, (2) the 1954 quarter-mile chute, and (3) the pre-1970 track, with a period of significance of 1954 to 1970. The Clubhouse and Annex/Burgart's building are not character-defining features or part of the historical resource because these features do not retain sufficient integrity to reflect the property's period of significance. According to the integrity analysis performed as part of the HRA Addendum, the cumulative changes to the Clubhouse, particularly the replacement of original windows, removal of trim, and modifications to the north and south elevations, have diminished the integrity of design, materials, and workmanship associated with its original appearance. As a result, the Clubhouse is not considered a character-defining feature of LARC. In addition, due to the alterations and resulting low integrity of design, materials, workmanship, and feeling, the Annex/Burgart's building is not a character-defining feature of LARC.

Actions that result in the diminishment of any of the character-defining features of the LARC Property, such as removal or alteration, could result in a significant impact under CEQA. The proposed project evaluated in this Draft EIR assumes that development of the land uses allowed by the Specific Plan within the Buildout Area would require the demolition and removal of all or a substantial portion of the existing improvements associated with the LARC Property, including all of the character-defining features as well as the Clubhouse and Annex/Burgart's building, accessory buildings, barns and structures and three artificial lakes. The demolition of the grandstand, chute, and track would be a potentially significant impact.

Based on State CEQA Guidelines Section 15064.5(b), the proposed project would have a significant impact on historical resources if it would cause a substantial adverse change in the significance of a historical resource. Historical resources include properties eligible for listing on the National Register, the California Register, or a local register or survey of historical resources. In addition, as described in State CEQA Guidelines Section 15064.5, "substantial adverse change in the significance of an historical resource means physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings such that the significance of an historical resource would be materially impaired." Demolition is considered a material impairment of the historical resource, and no feasible mitigation measures are available to fully mitigate the demolition of a historical resource to a less than significant level. However, implementation of mitigation measures could reduce significant adverse impacts but not completely mitigate or avoid the significant impact. If the historical significance of the building is thoroughly documented, well photographed, and publicly available, the demolition of the building would have a reduced impact on the historical significance of the building, though the impact would still be significant. Implementation of Mitigation Measures P:\A-E\CCP2201.0S LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.S Cultural Resources.docx «03/10/26» 4.5-15 SPECIFIC PLAN 3.0 BUI LOO UT PROJECT

CYPRESS, CALIFORNIA

DR AFT EN VIRONMENTAL IMPACT REPORT
M ARCH 2026
CUL-1 through CUL-3, below, which requires that photographs and memorabilia, including brochures, promotional flyers, marketing materials, special events announcements, and the like (or copies of the same) be available to a local library or an Orange County-based historical society, a historical marker or the Vessels' name, the track logo, racing terminology, and/or the names or likenesses (e.g., statuary, wall or garden art, and photographs) of noteworthy Quarter Horses, and documentation of the historic resource in accordance with the Historic American Building Survey (HABS) standards, would reduce, but not avoid, adverse impacts to the historical resource.

Mitigation Measure CUL-1
Mitigation Measure CUL-2
Mitigation Measure CUL-3

4.5-16
Prior to demolition activities of any character-defining features, the owner of Los Alamitos Race Course, or subsequent project proponents, shall make photographs and memorabilia, including brochures, promotional flyers, marketing materials, special events announcements and the like (or copies of the same) available to a local library or an Orange County-based historical society:
a. For use in an exhibit(s) about horse racing, quarter horses, Frank Vessels, Sr., the Vessels family, pari-mutuel betting and/or the history of Cypress; and/or
b. To be part of a permanent archive for research purposes.

Require future development on portions of the Los Alamitos Race Course property to incorporate one or more of the following:
a. A historical marker that provides information about Frank Vessels, Sr. and Los Alamitos Race Course. The marker should be clearly visible and accessible to the public.
b. The Vessels' name, the track logo, racing terminology, and/or the names or likenesses (e.g., statuary, wall or garden art, and photographs) of noteworthy Quarter Horses (such as Clobber, Go Man Go, or Moonist).

Prior to, or in conjunction with, approval of any demolition or development permits that involves the destruction of any portion of the Los Alamitos Race Course property, the Project Applicant should be required to commission documentation of the property in the form of Historic American Building Survey (HABS)-like
documentation that complies with the Secretary of the Interior's Standards for Architectural and Engineering Documentation (NPS 1990), if any of the character-defining features as identifies are still present. The documentation should generally follow the HABS Level Ill requirements and include digital photographic recordation of the complex, a detailed historic narrative report, and compilation of historic research. Photographic documentation should include:

P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.5 Cultural Resources.docx «03/10/26» DRAFT ENVIRONMENTAL IMPACT REPORT SPECIFIC PLAN 3.0 BUILDOUT PROJECT MARCH 2026 CYPRESS, CALIFORNIA
• General views of the site and landscape as a whole
• Photographs of the 550-yard chute, track, and winner's circle • Photographs of each exterior elevation of all buildings and structures in the complex
• Photographs of the interior of the Grandstand.

The documentation should be completed by a qualified
architectural historian or historian who meets the Secretary of the Interior's Professional Qualification Standards for History and/or Architectural History (NPS 1983). The original archival-quality documentation shall be offered as donated material to the following entities: South Central Coastal Information Center at CSU Fullerton, Preserve Orange County, the Orange County Historical Society and other repositories to be determined such as local libraries and the American Quarter Horse Association Hall of Fame.

Because implementation of the proposed project would demolish the character-defining features of the LARC Property, implementation of the proposed project would result in a substantial adverse change to a historic architectural resource under CEQA. Implementation of Mitigation Measures CUL-1 through CUL-3 would require documenting the character-defining features of LARC Property, but it would not avoid demolition of the character-defining features; therefore, impacts to builtenvironment historic resources as defined in State CEQA Guidelines Section 15064.5 would be significant and unavoidable.

Threshold 4.5.2: Would the project cause a substantial adverse change in the significance of an archaeological resource pursuant to §15064.5?
Less Than Significant Impact. As previously discussed, no known archaeological resources exist within the Buildout Area, as determined by the record search performed for the Cypress City Center Project, which included the Buildout Area. Although no cultural resources have been identified within the Buildout Area, according to the Geotechnical Investigation, 67 the Buildout Area is underlain by 3-5 feet of fill material on top of native alluvial soils. Undisturbed native alluvial soils may contain previously unknown archaeological resources.

Implementation of the proposed project would facilitate the development of up to 1,791 additional residential units and approximately 440,000 square feet of non-residential development within the Buildout Area. Future construction facilitated by the proposed project would include ground disturbing activities including grading and excavation. Ground-disturbing activity into the native alluvial soils associated with project implementation has the potential to unearth previously unknown archaeological deposits or resources, resulting in a potential substantial adverse change in 67 Geotechnologies, Inc. 2024. Environmental Impact Report Soils and Geology Issues, Proposed Mixed-Use Development, 4961 Kate/la Avenue and 5100 Cerritos Avenue, Cypress, California. May 2. (Appendix F) P:\A-E\CCP2201.0S LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.S Cultural Resources.docx «03/10/26» 4.5-17 SPECIFIC PLAN 3.0 BUI LOO UT PROJECT

CYPRESS, CALIFORNIA

DR AFT EN VIRONMENTAL IMPACT REPORT
M ARCH 2026
the significance of a unique archaeological resource, as defined in State CEQA Guidelines Section 15064.5.

However, future development facilitated under the proposed project would be required to adhere to Regulatory Compliance Measure CUL-1, which details provisions in the event that unknown cultural resources are discovered during ground-disturbing construction activities, consistent with the California Code of Regulations (CCR) Section 15064.S(e) and State Health and Safety Code Section 7050.5.

Regulatory Compliance Measure CUL-1 Unknown Archaeological Resources. In the event that archaeological resources are discovered during
excavation, grading, or construction activities, work
shall cease within 50 feet of the find until a qualified archaeologist from the Orange County List of
Qualified Archaeologists has evaluated the find in
accordance with federal, State, and local guidelines
to determine whether the find constitutes a
"unique archaeological resource," as defined in
Section 21083.2(g) of the California Public
Resources Code (PRC). A future project applicant
and its construction contractor shall not collect or
move any archaeological materials and associated
materials. Construction activity may continue
unimpeded on other portions of the project site.

Any found deposits shall be treated in accordance
with federal, State and local guidelines, including
those set forth in PRC Section 21083.2. Prior to
commencement of grading activities, the Director of
the City of Cypress (City) Community Development
Department, or designee, shall verify that all project
grading and construction plans include specific
requirements regarding California PRC (Section
21083.2[g]) and the treatment of archaeological
resources as specified above.

Implementation of Regulatory Compliance Measure CUL-1 would ensure that: (1) if archaeological cultural resources are identified during excavation, these would be evaluated, documented, and studied in accordance with standard archaeological practice, and (2) archaeological deposits and human remains would be treated in a culturally appropriate manner and in accordance with appropriate State codes and regulations. Therefore, implementation of the proposed project would result in less than significant impacts related to archaeological resources.

Threshold 4.5.3: Would the project disturb any human remains, including those interred outside of dedicated cemeteries?

4.5-18 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.5 Cultural Resources.docx «03/10/26»

DRAFT EN VI RONMENTAL IMPACT REPO RT
M ARCH 2026
SPECIFIC PLAN 3.0 BU ILDOUT PROJECT

CYPRESS, CALIFO RNIA
Less Than Significant Impact. There are no known human remains on the project site. However, as previously discussed, future construction facilitated by the proposed project would include ground disturbing activities including grading and excavation. Ground-disturbing activity associated with project implementation has the potential to disturb previously unknown human remains.

In the event that human remains are identified during future ground-disturbing activities, these remains would be treated in accordance with Section 7050.5 of the California Health and Safety Code and PRC Section 5097.98, as detailed in Regulatory Compliance Measure CUL-2. Section 7050.5 of the California Health and Safety Code states that, in the event of discovery or recognition of any human remains in any location other than a dedicated cemetery, there shall be no further excavation or disturbance within 50 feet of the find or any nearby area reasonably suspected to overlie adjacent remains until the coroner of the county in which the remains are discovered has determined whether or not the remains are subject to the Coroner's authority. If the human remains are of Native American origin, the coroner must notify the NAHC within 24 hours of this identification. The NAHC will identify an MLD to inspect the site and provide recommendations for the proper treatment of the remains and associated grave goods.

Regulatory Compliance Measure CUL-2 Human Remains. In the event that human remains are encountered on the project site, work within 50
feet of the discovery shall be redirected and the
County Coroner notified immediately consistent
with the requirements of California Code of
Regulations (CCR) Section 15064.5(e). State Health
and Safety Code Section 7050.5 states that no
further disturbance shall occur until the County
Coroner has made a determination of origin and
disposition pursuant to PRC Section 5097.98. If the
remains are determined to be Native American, the
County Coroner shall notify the Native American
Heritage Commission (NAHC), which shall
determine and notify a Most Likely Descendant
(MLD). With the permission of the property owner,
the MLD may inspect the site of the discovery. The
MLD shall complete the inspection within 48 hours
of notification by the NAHC. The MLD may
recommend scientific removal and non-destructive
analysis of human remains and items associated
with Native American burials. Consistent with CCR
Section 15064.S(d), if the remains are determined
to be Native American and an MLD is notified, the
City of Cypress shall consult with the MLD as
identified by the NAHC to develop an agreement for
treatment and disposition of the remains. Prior to
the issuance of grading permits, the Director of the
City of Cypress Community Development
P:\A-E\CCP2201.0S LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.S Cultural Resources.docx «03/10/26» 4.5-19 SPECIFIC PLAN 3.0 BUI LOO UT PROJECT

CYPRESS, CALIFORNIA

DR AFT EN VIRONMENTAL IMPACT REPORT
M ARCH 2026
Department, or designee, shall verify that all
grading plans specify the requirements of CCR
Section 15064.S(e), State Health and Safety Code
Section 7050.5, and PRC Section 5097.98, as stated
above.

PRC Section 5097.98 states that the NAHC, upon notification of the discovery of Native American human remains pursuant to Health and Safety Code Section 7050.5, shall immediately notify those persons it believes to be descended from the deceased (i.e., the Most Likely Descendant or "MLD").

With permission from the landowner or a designated representative, the MLD may inspect the remains and any associated cultural materials and make recommendations for treatment or disposition of the remains and associated grave goods. The MLD shall provide recommendations or preferences for treatment of the remains and associated cultural materials within 48 hours of being granted access to the site.

In addition, as discussed in Section 4.18, Tribal Cultural Resources, the proposed project would be required to implement Mitigation Measures TCR-1 and TCR-4, which detail provisions for the treatment of Native American human remains and associated funerary objects, if encountered during project construction.

Future development facilitated by the proposed project would be required to comply with the appropriate procedures required under State law, as detailed in Regulatory Compliance Measure CUL-2, and the provisions detailed in Mitigation Measures TCR-3 and TCR-4 for the treatment of human remains in order to ensure that descendant communities have significant input in the treatment and final disposition of human remains, if encountered at the project site during future development activities. Therefore, implementation of the proposed project would result in less than significant impacts related to human remains.

4.5.7 Level of Significance Prior to Mitigation
Impacts on historic resources with implementation of the proposed project would be potentially significant.

4.5.8 Regulatory Compliance Measures and Mitigation Measures

4.5.8.1 Regulatory Compliance Measures
Future development facilitated under the proposed project would be required to adhere to the following regulatory compliance measures.

Regulatory Compliance Measure CUL-1

4.5-20
Unknown Archaeological Resources. In the event that
archaeological resources are discovered during
excavation, grading, or construction activities, work
shall cease within 50 feet of the find until a qualified archaeologist from the Orange County List of Qualified
Archaeologists has evaluated the find in accordance
with federal, State, and local guidelines to determine
P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.5 Cultural Resources.docx «03/10/26»

DRAFT EN VI RONMENTAL IMPACT REPO RT
M ARCH 2026
Regulatory Compliance Measure CUL-2
SPECIFIC PLAN 3.0 BU ILDOUT PROJECT

CYPRESS, CALIFO RNIA
whether the find constitutes a "unique archaeological
resource," as defined in Section 21083.2(g) of the
California Public Resources Code (PRC). A future project applicant and its construction contractor shall not
collect or move any archaeological materials and
associated materials. Construction activity may
continue unimpeded on other portions of the project
site. Any found deposits shall be treated in accordance with federal, State and local guidelines, including those set forth in PRC Section 21083.2. Prior to
commencement of grading activities, the Director of the City of Cypress (City) Community Development
Department, or designee, shall verify that all project
grading and construction plans include specific
requirements regarding California PRC (Section
21083.2[g]) and the treatment of archaeological
resources as specified above.

Human Remains. In the event that human remains are
encountered on the project site, work within 50 feet of the discovery shall be redirected and the County
Coroner notified immediately consistent with the
requirements of California Code of Regulations (CCR)
Section 15064.S(e). State Health and Safety Code
Section 7050.5 states that no further disturbance shall occur until the County Coroner has made a
determination of origin and disposition pursuant to PRC Section 5097.98. If the remains are determined to be
Native American, the County Coroner shall notify the
Native American Heritage Commission (NAHC), which
shall determine and notify a Most Likely Descendant
(MLD). With the permission of the property owner, the
MLD may inspect the site of the discovery. The MLD
shall complete the inspection within 48 hours of
notification by the NAHC. The MLD may recommend
scientific removal and non-destructive analysis of
human remains and items associated with Native
American burials. Consistent with CCR Section
15064.S(d), if the remains are determined to be Native
American and an MLD is notified, the City of Cypress
shall consult with the MLD as identified by the NAHC to develop an agreement for treatment and disposition of
the remains. Prior to the issuance of grading permits,
the Director of the City of Cypress Community
Development Department, or designee, shall verify that
P:\A-E\CCP2201.0S LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.S Cultural Resources.docx «03/10/26» 4.5-21 SPECIFIC PLAN 3.0 BUI LOO UT PROJECT

CYPRESS, CALIFORNIA

DR AFT EN VIRONMENTAL IMPACT REPORT
M ARCH 2026

4.5.8.2 Mitigation Measures
all grading plans specify the requirements of CCR
Section 15064.5{e), State Health and Safety Code
Section 7050.5, and PRC Section 5097.98, as stated
above.

The proposed project would be required to implement the following mitigation measures.

Mitigation Measure CUL-1
Mitigation Measure CUL-2
Mitigation Measure CUL-3

4.5-22
Prior to demolition activities of any character-defining features, the owner of Los Alamitos Race Course, or subsequent project proponents, shall make photographs and memorabilia, including brochures, promotional flyers, marketing materials, special events announcements and the like (or copies of the same) available to a local library or an Orange County-based historical society:
a. For use in an exhibit(s) about horse racing, quarter horses, Frank Vessels, Sr., the Vessels family, pari-mutuel betting and/or the history of Cypress; and/or
b. To be part of a permanent archive for research purposes.

Require future development on portions of the Los Alamitos Race Course property to incorporate one or more of the following:
a. A historical marker that provides information about Frank Vessels, Sr. and Los Alamitos Race Course. The marker should be clearly visible and accessible to the public.
b. The Vessels' name, the track logo, racing terminology, and/or the names or likenesses (e.g., statuary, wall or garden art, and photographs) of noteworthy Quarter Horses (such as Clobber, Go Man Go, or Moonist).

Prior to, or in conjunction with, approval of any demolition or development permits that involves the destruction of any portion of the Los Alamitos Race Course property, the Project Applicant should be required to commission documentation of the property in the form of Historic American Building Survey (HABS)-like
documentation that complies with the Secretary of the Interior's Standards for Architectural and Engineering Documentation (NPS 1990), if any of the character-defining features as identifies are still present. The documentation should generally follow the HABS Level Ill requirements and include digital photographic recordation of the complex, a detailed historic narrative report, and compilation of historic research. Photographic documentation should include:

P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.5 Cultural Resources.docx «03/10/26» DRAFT ENVIRONMENTAL IMPACT REPORT SPECIFIC PLAN 3.0 BUILDOUT PROJECT MARCH 2026 CYPRESS, CALIFORNIA
• General views of the site and landscape as a whole
• Photographs of the 550-yard chute, track, and winner's circle • Photographs of each exterior elevation of all buildings and structures in the complex
• Photographs of the interior of the Grandstand.

The documentation should be completed by a qualified
architectural historian or historian who meets the Secretary of the Interior's Professional Qualification Standards for History and/or Architectural History (NPS 1983). The original archival-quality documentation shall be offered as donated material to the following entities: South Central Coastal Information Center at CSU Fullerton, Preserve Orange County, the Orange County Historical Society and other repositories to be determined such as local libraries and the American Quarter Horse Association Hall of Fame.

4.5.9 Level of Significance after Mitigation
Even with implementation of Mitigation Measures CUL-1 through CUL-3, the proposed project would result in a significant and unavoidable impact related to the substantial adverse change of a historical resource. No other feasible mitigation measures have been identified to reduce this impact to less than significant.

4.5.10 Cumulative Impacts
Defined in Section 15130 of the State CEQA Guidelines, cumulative impacts are the incremental effects of an individual project when viewed in connection with the effects of past, current, and reasonably foreseeable projects in an area of interest. The cumulative impact area for cultural resources is the North Orange County region, including the City of Cypress. Potential impacts of the proposed project to unknown cultural resources, when combined with other past, current, and reasonably foreseeable projects in the city, including the related projects identified in Table 4.A:

Summary of Related Projects and Figure 4.1, in Chapter 4.0, Existing Setting, could contribute to a cumulatively significant impact due to the overall loss of cultural resources in the region, including historical resources.

Each development proposal received by the City is required to undergo individual environmental review pursuant to CEQA. Furthermore, impacts of other projects on cultural resources are generally site-specific because they result from ground -disturbing activities that would require a site-specific impact analysis to determine the nature and extent of the resources and identify appropriate mitigation measures that would reduce or avoid significant impacts. Similar to the proposed project, ground disturbance associated with related projects could result in potentially significant impacts on previously unidentified archaeological sites and associated human remains that may be unearthed.

P:\A-E\CCP2201.0S LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.S Cultural Resources.docx «03/10/26» 4.5-23 SPECIFIC PLAN 3.0 BUI LOO UT PROJECT

CYPRESS, CALIFORNIA

DR AFT EN VIRONMENTAL IMPACT REPORT
M ARCH 2026
When the City considers future development proposals, both within the Buildout Area and citywide, these proposals would undergo environmental review pursuant to CEQA and when necessary, mitigation measures would be adopted as appropriate. In most cases, this environmental review and compliance with project conditions of approval and relevant policies of the General Plan would ensure that significant impacts on cultural resources would be avoided or otherwise mitigated to less than significant levels. Moreover, some of the related projects identified in Table 4.A, which included ground disturbing activities associated with construction of the related projects, have undergone environmental review pursuant to CEQA, which included an analysis of potential impacts on cultural resources, including historical resources. According to the EIRs prepared for the Shea Properties Mixed Use Development Project (Related Project 1), Melia Homes -Citrus Square Project (Related Project 2), and the Los Alamitos Medical Center Project (Related Project 7), impacts on cultural resources with implementation of the projects would be less than significant with implementation of measures similar to Regulatory Compliance Measures CUL-1 and CUL-2 that would ensure there are no impacts to unknown cultural resources during construction. Further, the El Rs determined that cumulative impacts related to cultural resources would be less than significant.

In addition, Goodman Commerce Center and the 5665 Plaza Drive Projects (Related Project 3) were analyzed in an Initial Study/Mitigated Negative Declaration (IS/MND) in 2023 and an EIR in 2024, respectively, which determined that all impacts on cultural resources would also be less than significant with implementation of measures similar to Regulatory Compliance Measures CUL-1 and CUL-2. In addition, none of the above referenced related projects included the demolition of historical resources or resulted in the substantial adverse change in the significance of historic resources. The Sycamore Creek Charter School Project (Related Project 6) and 4562 Katella Avenue Project (Related Project 8) were determined to be exempt from CEQA review under Section 15332 of the State CEQA Guidelines (for infill development) and Notices of Exemption (NOEs) were prepared. In order for a project to be exempt under Section 15332 of the State CEQA Guidelines, the project must not result in impacts on historical resources. As such, development of the related projects in combination with the proposed project would not result in significant impacts on cultural resources. The LTP Modern Machine Project (Related Project 5) and 8561 Belmont Street Project (Related Project 4) would also be required to undergo environmental review pursuant to CEQA, which would include an analysis of potential impacts on cultural resources and the identification of any mitigation measures to reduce potential impacts, if necessary.

Built Historic Resources: The cumulative context for built historic resources is both the City of Cypress as well as quarter horse racing tracks in California. As identified in the 2023 HRA and 2025 Addendum, LARC is eligible for listing in the California Register and National Register under Criteria A/1 and B/2 for its association with the establishment of organized quarter horse racing in California and its connection to Frank Vessels, Sr. The Grandstand, oval track, and 550-yard chute are the property's primary character-defining features that retain integrity from the period of significance (1954-1970). Although the Clubhouse and Annex/Burgart's buildings have been altered and no longer contribute to the resource's significance, demolition of the race course would remove the physical features that embody its historic association and setting. Regionally, the loss of comparable facilities such as the Hollywood Park racetrack in Los Angeles County and the Bay Meadows racetrack in San Mateo County has already diminished the State's inventory of mid-century equestrian and recreational landmarks; therefore, demolition of the LARC would incrementally

4.5-24 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.5 Cultural Resources.docx «03/10/26»

DRAFT ENVIRONMENTAL IMPACT REPORT
MARCH 2026
SPECIFIC PLAN 3.0 BUILDOUT PROJECT

CYPRESS, CALIFORNIA
contribute to this cumulative loss of significant resources. Cumulative impacts would be cumulatively considerable.

Even with the implementation of Mitigation Measures CUL-1 through CUL-3, which includes HABSlevel documentation, archival research, and interpretive elements commemorating Frank Vessels, Sr. and the history of quarter horse racing, the project's contribution to cumulative impacts on historic resources would remain cumulatively considerable and therefore significant and unavoidable under State CEQA Guidelines Sections 15064(h) and 15130. The demolition of all character-defining features would constitute a substantial adverse change in the significance of a historical resource pursuant to PRC Sections 5020.l(q) and 21084.1. While mitigation would preserve historical information and interpretive value, it would not prevent the permanent loss of the physical features that convey LARC's historic identity; as such, the project would result in a significant cumulative impact on historic resources that cannot be reduced to a less than significant level.

Buried Archeological Resources: Ground disturbance associated with future development facilitated by the proposed project could result in a potentially significant impact to cultural resources if previously undiscovered cultural resources are unearthed during ground-disturbing activity.

However, future development facilitated under the proposed project would be required to adhere to Regulatory Compliance Measures CUL-1 and CUL-2, which would ensure less than significant impacts on cultural resources.

Thus, there is low potential for the proposed project to contribute to a significant cumulative impact associated with the significance of an archaeological resource or human remains pursuant to Section 15064.5 of the State CEQA Guidelines. Collectively, recent past, approved, and probable future projects that may occur in the vicinity, including the proposed project, would not result in a cumulative increase in impacts on archaeological resources or human remains, because these resources would be avoided or otherwise removed, analyzed, and reported (i.e., by a qualified archaeologist).

P:\A-E\CCP2201.0S LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.S Cultural Resources.docx «03/10/26» 4.5-25

4.5-26
SPECIFIC PLAN 3.0 BUI LOO UT PROJECT

CYPRESS, CALIFORNIA
This page intentionally left blank

DRAFT ENVIRONMENTAL IMPACT REPORT
MARCH 2026
P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.5 Cultural Resources.docx «03/10/26»

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026
S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A
P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.6 Energy.docx «03/11/26» 4.6-1

4.6 ENERGY
This section evaluates the potential impacts on energy resources from implementation of the proposed Specific Plan 3.0 Buildout Project (proposed project), with particular emphasis on whether the proposed project would result in the wasteful, inefficient, or unnecessary consumption of energy resources or conflict with any applicable plans for renewable energy and energy efficiency.

4.6.1 Scoping Process
The City of Cypress (City) received six comment letters during the public review period of the Notice of Preparation (NOP). For a copy of the NOP comment letters, refer to Appendix A of this Draft Environmental Impact Report (Draft EIR). One of the comment letters, from the South Coast Air Quality Management District (SCAQMD), included comments related to energy consumption.

4.6.2 Methodology
The energy use analysis presented in this section is based on modeling conducted using the California Emissions Estimator Model (CalEEMod) version 2022.1. Modeling results are provided in Appendix B of this Draft EIR.

Operational fuel consumption (gasoline and diesel) associated with vehicle trips was estimated using project trip generation assumptions incorporated into CalEEMod and fuel efficiency factors from the California Air Resources Board (CARB) EMFAC2025 model. The CalEEMod analysis assumed full buildout of the proposed project, consisting of up to 1,791 additional residential units and 440,000 square feet of non-residential development. Default CalEEMod assumptions for electricity and natural gas consumption were applied to estimate building energy use.

Construction-related fuel consumption, including fuel use from construction equipment, haul trucks, vendor trips, and worker commute trips, was also estimated using CalEEMod trip outputs combined with fuel efficiency factors from the CARB EMFAC2025 model.

Consistent with Appendix F of the State CEQA Guidelines, the analysis evaluates four primary energy sources relevant to the proposed project: electricity, natural gas, construction-related fuel, and operational vehicle fuel. To provide regional context, projected project energy consumption is compared to overall energy use within Orange County where applicable. Electricity and natural gas consumption are reported as annual totals based on CalEEMod default building energy assumptions, while construction and operational transportation fuel use are quantified based on modeled trip activity over the applicable analysis periods.

Operational transportation energy use was estimated using the net project trip generation assumptions incorporated into the CalEEMod model to quantify future gasoline and diesel consumption. This analysis represents a conservative estimate of project-related energy demand because existing on-site energy consumption associated with the current operations, including building energy use, lighting, and fuel consumption, was not quantified or deducted from the future energy use totals.

S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026

4.6 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.6 Energy.docx «03/11/26» -2

4.6.3 Existing Environmental Setting

4.6.3.1 Electricity
Electricity is a manmade resource. The production of electricity requires the consumption or conversion of energy resources (including water, wind, oil, gas, coal, solar, geothermal, and nuclear resources) into energy. Electricity is used for a variety of purposes (e.g., lighting, heating, cooling, and refrigeration, and for operating appliances, computers, electronics, machinery, and public transportation systems).

According to the most recent data available, in 2023, California’s electricity was generated primarily by renewable sources (56.1 percent), natural gas (43.7 percent), large hydroelectric (12.6 percent), nuclear (8.2 percent), coal (less than 1.0 percent), and other unspecified sources.

Total electric generation in California in 2023 was 281,140 gigawatt-hours (GWh), down 2.1 percent from the 2022 total generation of 287,220 GWh.1
The Buildout Area is within the service territory of Southern California Edison (SCE). Approximately 49 percent of SCE’s power is estimated to come from carbon-free sources, including wind and solar, along with other carbon-free sources such as large hydroelectric and nuclear power.2SCE provides electricity to more than 15 million people in a 50,000 square mile area of Central, Coastal, and Southern California.3 According to the California Energy Commission (CEC), total electricity consumption in the SCE service area in 2024 was 79,341 GWh. Total electricity consumption in Orange County in 2024 was 19,225 GWh (19,225,000,000 kilowatt-hours [kWh]).4Existing electricity consumption in the Buildout Area is associated with the existing race course and stables; however, the existing electricity consumption associated with the land uses in the Buildout Area is unknown and has not been quantified or included as part of this analysis.

4.6.3.2 Natural Gas
Natural gas is a nonrenewable fossil fuel. Fossil fuels are formed when layers of decomposing plant and animal matter are exposed to intense heat and pressure under the surface of the Earth over millions of years. Natural gas is a combustible mixture of hydrocarbon compounds (primarily methane) that is used as a fuel source. Natural gas is found in naturally occurring reservoirs in deep underground rock formations. Natural gas is used for a variety of uses (e.g., heating buildings, generating electricity, and powering appliances such as stoves, washing machines and dryers, gas fireplaces, and gas grills).
1 California Energy Commission (CEC). 2023. 2023 Total System Electric Generation. Website:
https://www.energy.ca.gov/data-reports/energy-almanac/california-electricity-data/2023-total-systemelectric-generation (accessed October 2025). 2 Southern California Edison (SCE). 2024. Southern California Edison Fact Sheet. October 16. 3 Southern California Edison (SCE). n.d. About Us. Website: https://www.sce.com/about-us/who-we-are (accessed October 2025).
4 California Energy Commission (CEC). 2025a. California Electricity Consumption Dashboard. Website:
https://www.energy.ca.gov/data-reports/energy-almanac/california-electricity-data/california-energyconsumption-dashboards-0 (accessed October 2025).

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026
S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A
P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.6 Energy.docx «03/11/26» 4.6-3 Natural gas consumed in California is used for electricity generation (45 percent), residential uses (21 percent), industrial uses (25 percent), and commercial uses (9 percent). California continues to depend on out-of-state imports for nearly 90 percent of its natural gas supply.5 The Southern California Gas Company (SoCalGas) is the natural gas service provider for the Buildout Area. SoCalGas provides natural gas to approximately 21.8 million people in a 24,000 sq mi service area throughout Central and Southern California, from Visalia to the Mexican border.6 According to the CEC, total natural gas consumption in the SoCalGas service area in 2024 was 4,959 million therms.
7 Total natural gas consumption in Orange County in 2024 was 561.7 million therms.8 Existing natural gas consumption in the Buildout Area is associated with the existing Race Course; however, the existing natural gas consumption has not been quantified as part of this analysis.

4.6.3.3 Petroleum/Transportation Energy
Petroleum is also a non-renewable fossil fuel. Petroleum is a thick, flammable, yellow-to-black mixture of gaseous, liquid, and solid hydrocarbons that occurs naturally beneath the earth's surface.

Petroleum is primarily recovered by oil drilling. It is refined into a large number of consumer products, primarily fuel oil, gasoline, and diesel.

Gasoline is the most used transportation fuel in California, with 97 percent of all gasoline being consumed by light-duty cars, pickup trucks, and sport utility vehicles. According to the most recent data available, in 2021, total gasoline consumption in California was 289,918 thousand barrels (12.2 billion gallons) or 1,464.7 trillion British Thermal Units (BTU).9 Of the total gasoline consumption, 273,289 thousand barrels (11.5 billion gallons) or 1,380.7 trillion BTU were consumed for transportation.10 Diesel fuel is the second largest transportation fuel used in California, representing 17 percent of total fuel sales behind gasoline. In 2024, 3.5 billion gallons of diesel (including offroad diesel) was sold in California.
11 Based on fuel consumption obtained from CARB’s
California Emissions Factor Model, Version 2025 (EMFAC2025), approximately 1,003.9 million gallons of gasoline and approximately 170.5 million gallons of diesel will be consumed from vehicle trips in Orange County in 2025. Gasoline and diesel fuel consumption in the Buildout Area is 5 California Energy Commission (CEC). 2021. Supply and Demand of Natural Gas in California. Website:
https://www.energy.ca.gov/data-reports/energy-almanac/californias-natural-gas-market/supply-anddemand-natural-gas-california (accessed October 2025). 6 Southern California Gas Company (SoCalGas). 2020. About SoCalGas. Website: https://www.socalgas. com/about-us (accessed October 2025).
7 California Energy Commission (CEC). 2025b. Natural Gas Consumption Dashboard. Website:
https://www.energy.ca.gov/data-reports/energy-almanac/california-electricity-data/california-energyconsumption-dashboards-1 (accessed October 2025). 8 Ibid.
9 United States Energy Information Administration (EIA). 2022. California State Profile and Energy Estimates, Data. Website: www.eia.gov/state/seds/data.php?incfile=/state/seds/sep_fuel/html/fuel_mg. html&sid=CA (accessed September 2025).
10 Ibid.
11 California Energy Commission (CEC). n.d. Diesel Fuel Data, Facts, and Statistics. Website:
https://www.energy.ca.gov/data-reports/energy-almanac/transportation-energy/diesel-fuel-data-factsand-statistics (accessed January 2026).

S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026

4.6 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.6 Energy.docx «03/11/26» -4 associated with employee, horse trainer, and attendee vehicle trips associated with the existing Race Course. The existing gasoline and diesel fuel consumption within the Buildout Area was not quantified as part of this analysis; however, the existing trips were included in the proposed project’s estimated trip generation.

4.6.4 Regulatory Setting
Federal and State agencies regulate energy use and consumption through various means and programs. On the federal level, the United States Department of Transportation, the United States Department of Energy, and the United States Environmental Protection Agency are three federal agencies with substantial influence over energy policies and programs. Generally, federal agencies influence and regulate transportation energy consumption through establishment and enforcement of fuel economy standards for automobiles and light trucks, through funding of energy-related research and development projects, and through funding for transportation infrastructure improvements. On the State level, the California Public Utilities Commission (CPUC) and the CEC are two agencies with authority over different aspects of energy.

The CPUC regulates privately owned electric, natural gas, telecommunications, water, railroad, rail transit, and passenger transportation companies and serves the public interest by protecting consumers and ensuring the provision of safe, reliable utility service and infrastructure at reasonable rates, with a commitment to environmental enhancement and a healthy California economy.

The CEC is the State’s primary energy policy and planning agency. The CEC forecasts future energy needs, promotes energy efficiency, supports energy research, develops renewable energy resources, and plans for/directs State response to energy emergencies. The applicable federal, State, regional, and local regulatory framework is discussed below.

4.6.4.1 Federal Regulations
Energy Policy Act of 2005. The Energy Policy Act of 2005 seeks to reduce reliance on nonrenewable energy resources and provides incentives to reduce current demand on these resources. For example, under this Act, consumers and businesses can obtain federal tax credits for purchasing fuel-efficient appliances and products (including hybrid vehicles), building energy-efficient buildings, and improving the energy efficiency of commercial buildings. Additionally, tax credits are available for the installation of qualified fuel cells, stationary microturbine power plants, and solar power equipment.

Corporate Average Fuel Economy Standards. On March 31, 2022, the National Highway Traffic Safety Administration (NHTSA) finalized the CAFE standards for Model Years 2024–2026 Passenger Cars and Light Trucks. The amended CAFE standards would require an industry wide fleet average of approximately 49 mpg for passenger cars and light trucks in model year 2026, by increasing fuel efficiency by 8 percent annually for model years 2024–2025, and 10 percent annually for model year 2026. The final standards are estimated to save about 234 billion gallons of gasoline between model years 2030 to 2050. Heavy-duty pickup truck and van fuel efficiency will increase 10 percent per year for model years 2030–2032 and 8 percent per year for model years 2033–2035.

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026
S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A
P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.6 Energy.docx «03/11/26» 4.6-5

4.6.4.2 State Regulations
Executive Order B-55-18. EO) B-55-18, signed September 10, 2018, sets a goal “to achieve carbon neutrality as soon as possible, and no later than 2045, and achieve and maintain net negative emissions thereafter.” EO B-55-18 directs the CARB to work with relevant State agencies to ensure future Scoping Plans identify and recommend measures to achieve the carbon neutrality goal. The goal of carbon neutrality by 2045 is in addition to other statewide goals, meaning not only should emissions be reduced to 80 percent below 1990 levels by 2050, but that, by no later than 2045, the remaining emissions be offset by equivalent net removals of CO2e from the atmosphere, including through sequestration in forests, soils, and other natural landscapes.

Executive Order B-48-18. In January 2018, Governor Brown signed EO B-48-18 requiring all State entities to work with the private sector to have at least 5 million zero emission vehicles (ZEVs) on the road by 2030, as well as install 200 hydrogen fueling stations and 250,000 electric vehicle charging stations by 2025. It specifies that 10,000 of the electric vehicle charging stations should be direct current fast chargers. This order also requires all State entities to continue to partner with local and regional governments to streamline the installation of ZEV infrastructure. The Governor’s Office of Business and Economic Development is required to publish a Plug-in Charging Station Design Guidebook and update the 2015 Hydrogen Station Permitting Guidebook to aid in these efforts. All State entities are required to participate in updating the 2016 Zero-Emissions Vehicle Action Plan to help expand private investment in ZEV infrastructure with a focus on serving lowincome and disadvantaged communities. Additionally, all State entities are to support and recommend policies and actions to expand ZEV infrastructure at residential land uses, through the LCFS Program, and recommend how to ensure affordability and accessibility for all drivers.

Executive Order N-79-20. EO N-79-20, which was signed by the Governor on September 23, 2020, sets the following goals for the State: 100 percent of in-state sales of new passenger cars and trucks shall be zero-emission by 2035; 100 percent of medium- and heavy-duty vehicles in the State shall be zero-emission by 2045 for all operations where feasible and by 2035 for drayage trucks; and 100 percent of off-road vehicles and equipment in the State shall be zero-emission by 2035, where feasible.

Assembly Bill 1575, Warren-Alquist Act. In 1975, largely in response to the oil crisis of the 1970s, the State Legislature adopted Assembly Bill (AB) 1575 (also known as the Warren-Alquist Act), which created the CEC. The statutory mission of the CEC is to forecast future energy needs; license power plants of 50 megawatts (MW) or larger; develop energy technologies and renewable energy resources; plan for and direct State responses to energy emergencies; and, perhaps most importantly, promote energy efficiency through the adoption and enforcement of appliance and building energy efficiency standards. AB 1575 also amended Public Resources Code (PRC) Section 21100(b)(3) and State CEQA Guidelines Section 15126.4 to require EIRs to include, where relevant, mitigation measures proposed to minimize the wasteful, inefficient, and unnecessary consumption of energy caused by a project. Thereafter, the State Resources Agency created Appendix F to the State CEQA Guidelines. Appendix F assists EIR preparers in determining whether a project will result in the inefficient, wasteful, and unnecessary consumption of energy. Appendix F of the State CEQA Guidelines also states that the goal of conserving energy implies the wise and efficient use of energy and the means of achieving this goal, including (1) decreasing overall per S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026

4.6 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.6 Energy.docx «03/11/26» -6 capita energy consumption; (2) decreasing reliance on fossil fuels such as coal, natural gas, and oil; and (3) increasing reliance on renewable energy sources.

Senate Bill 1389, Energy: Planning and Forecasting. In 2002, the State Legislature passed Senate Bill (SB) 1389, which required the CEC to develop an integrated energy plan every 2 years for electricity, natural gas, and transportation fuels, known as the Integrated Energy Policy Report. The plan calls for the State to assist in the transformation of the transportation system to improve air quality, reduce congestion, and increase the efficient use of fuel supplies with the least environmental and energy costs. To further this policy, the plan identifies a number of strategies, including assistance to public agencies and fleet operators in implementing incentive programs for ZEVs and their infrastructure needs, and encouragement of urban designs that reduce vehicle miles traveled (VMT) and accommodate pedestrian and bicycle access.

In compliance with the requirements of SB 1389, the CEC adopts an Integrated Energy Policy Report every 2 years and an update every other year. The most recently adopted report includes the 2024 Integrated Energy Policy Report Update.
12 The 2024 Integrated Energy Policy Report Update covers a broad range of topics, including decarbonizing buildings, energy efficiency, energy equity, integrating renewable energy, updates on electricity reliability, climate adaptation activities for the energy sector, natural gas assessment, transportation energy demand forecast, and the California Energy Demand Forecast. The 2024 Integrated Energy Policy Report Update provides the results of the CEC’s assessments of a variety of energy issues facing California. Many of these issues will require action if the State is to meet its climate, energy, air quality, and other environmental goals while maintaining energy reliability and controlling costs.

Senate Bill 350 (2015) Clean Energy and Pollution Reduction Act. SB 350, signed by Governor Jerry Brown on October 7, 2015, updates and enhances AB 32 by introducing the following set of objectives in clean energy, clean air, and pollution reduction for 2030:
• Raise California’s renewable portfolio standard from 33 percent to 50 percent; and • Increasing energy efficiency in buildings by 50 percent by the year 2030.

The 50 percent renewable energy standard will be implemented by the California Public Utilities Commission for the private utilities and by the California Energy Commission for municipal utilities.

Each utility must submit a procurement plan showing it will purchase clean energy to displace other non-renewable resources. The 50 percent increase in energy efficiency in buildings must be achieved through the use of existing energy efficiency retrofit funding and regulatory tools already available to State energy agencies under existing law. The addition made by this legislation requires State energy agencies to plan for and implement those programs in a manner that achieves the energy efficiency target.

Renewable Portfolio Standard. SB 1078 established the California Renewable Portfolio Standards program in 2002. SB 1078 initially required that 20 percent of electricity retail sales be served by renewable resources by 2017; however, this standard has become more stringent over time. In 12 California Energy Commission (CEC). 2024. 2024 Integrated Energy Policy Report Update. Docket Number 24-IEPR-01.

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026
S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A
P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.6 Energy.docx «03/11/26» 4.6-7 2006, SB 107 accelerated the standard by requiring that the 20 percent mandate be met by 2010. In April 2011, SB 2 required that 33 percent of electricity retail sales be served by renewable resources by 2020. In 2015, SB 350 established tiered increases to the Renewable Portfolio Standards of 40 percent by 2024, 45 percent by 2027, and 50 percent by 2030. In 2018, SB 100 increased the requirement to 60 percent by 2030 and required that all the State’s electricity come from carbonfree resources by 2045. SB 100 took effect on January 1, 2019.13 Assembly Bill 1279. AB 1279 was signed in September 2022 and codifies the State goals of achieving net carbon neutrality by 2045 and maintaining net negative greenhouse gas (GHG) emissions thereafter. This bill also requires California to reduce statewide GHG emissions by 85 percent compared to 1990 levels by 2045 and directs CARB to work with relevant State agencies to achieve these goals.

California Energy Code. Energy consumption by new buildings in California is regulated by the Building Energy Efficiency Standards in Part 6 of Title 24 of the California Code of Regulations (CCR), known as the Energy Code. The CEC first adopted the Building Energy Efficiency Standards for Residential and Nonresidential Buildings in 1978 in response to a legislative mandate to reduce energy consumption in the State. The Energy Code is updated every 3 years, with the most recent update consisting of the 2025 Energy Code that became effective January 1, 2026. The efficiency standards apply to both new construction and rehabilitation of both residential and nonresidential buildings, and regulate energy consumed for heating, cooling, ventilation, water heating, and lighting. The building efficiency standards are enforced through the local building permit process.

Local government agencies may adopt and enforce energy standards for new buildings, provided these standards meet or exceed those provided in the Energy Code.

California Green Building Standards Code (CALGreen Code). In 2010, the California Building Standards Commission (CBSC) adopted Part 11 of the Title 24 Building Energy Efficiency Standards, referred to as the California Green Building Standards Code (CALGreen Code). The CALGreen Code took effect on January 1, 2011. The CALGreen Code is updated on a regular basis, with the most recent update consisting of the 2025 CALGreen Code standards that became effective January 1, 2023. The CALGreen Code establishes mandatory measures for residential and nonresidential building construction and encourages sustainable construction practices in the following five categories: (1) planning and design, (2) energy efficiency, (3) water efficiency and conservation, (4) material conservation and resource efficiency, and (5) indoor environmental quality. The mandatory measures are enforced through the local building permit process. Although the CALGreen Code was adopted as part of the State’s efforts to reduce GHG emissions, the CALGreen Code standards have co-benefits of reducing energy consumption from residential and nonresidential buildings subject to the standard.

Appliance Efficiency Regulations. Appliance Efficiency Regulations set minimum energy and water performance standards for products like refrigerators, lighting, and air conditioners, driven by the CEC (Title 20), complementing federal rules, to promote efficiency and reduce energy use. 13 California Public Utilities Commission (CPUC). 2019. Renewables Portfolio Standard Program. Website:
cpuc.ca.gov/rps (accessed September 2025).

S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026

4.6 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.6 Energy.docx «03/11/26» -8 California Energy Efficiency Strategic Plan. On September 18, 2008, the CPUC adopted California’s first Long-Term Energy Efficiency Strategic Plan, presenting a roadmap for energy efficiency in California. The Strategic Plan was updated in 2011. The plan articulates a long-term vision and goals for each economic sector and identifies specific near-term, mid-term, and long-term strategies to assist in achieving those goals. The Plan also reiterates the following four specific programmatic goals known as the “Big Bold Energy Efficiency Strategies” that were established by the CPUC in Decisions D.07-10-032 and D.07-12-051:
• All new residential construction will be zero net energy (ZNE) by 2020. • All new commercial construction will be ZNE by 2030.
• 50 percent of commercial buildings will be retrofitted to ZNE by 2030. • 50 percent of new major renovations of State buildings will be ZNE by 2025.

Low Carbon Fuel Standard and Advanced Clean Cars. EO S-01-07 established a low carbon fuel standard (LCFS) with a Statewide goal to be established to reduce the carbon intensity of California’s transportation fuels that applies to all refiners, blenders, producers, or importers (“Providers”) of transportation fuels in California, including fuels used by off-road construction equipment. CARB approved amendments in 2018 to readjust carbon intensity benchmarks to meet California’s 2030 GHG reductions targets under SB 32. These amendments include opportunities to promote zero emission vehicle (ZEV) adoption, carbon capture and sequestration, and advanced technologies for decarbonization of the transportation sector.

4.6.4.3 Regional Regulations
Southern California Association of Governments. On April 4, 2024, the Southern California Association of Governments (SCAG) adopted Connect SoCal—the 2024–2050 Regional Transportation Plan/Sustainable Communities Strategy (Connect SoCal 2024) for the SCAG region.14 In general, Connect SoCal 2024 outlines a development pattern for the region, which, when integrated with the transportation network and other transportation measures and policies, would reduce vehicle miles traveled from automobiles and light-duty trucks and thereby reduce GHG emissions from these sources. For the SCAG region, CARB has set GHG reduction targets at 19 percent below 2005 per capita emissions levels by 2035. Connect SoCal 2024 lays out a strategy for the region to meet these targets. Overall, Connect SoCal 2024 is meant to provide growth strategies that will achieve the regional GHG emissions reduction targets. Land use strategies to achieve the region’s targets include planning for new growth around high-quality transit areas and livable corridors, and creating neighborhood mobility areas to integrate land use and transportation and plan for more active lifestyles.15 However, local General Plans, Specific Plans, or zoning are not required to be consistent with Connect SoCal 2024; SCAG is required to consider local land use controls when drafting the RTP/SCS.
14 Southern California Association of Governments (SCAG). 2024. Connect SoCal 2024: The 2024–2050 Regional Transportation Plan/Sustainable Communities Strategy of the Southern California Association of Governments. Website: https://scag.ca.gov/sites/default/files/2024-05/23-2987-connect-socal-2024- final-complete-040424.pdf (accessed October 2025).
15 Ibid.

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026
S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A
P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.6 Energy.docx «03/11/26» 4.6-9 California Gas Report. The California Gas Report presents a comprehensive outlook on natural gas requirements and supplies for California, as well as historical gas supply and recorded gas requirements for the previous five years. A comprehensive report is prepared in even-numbered years, followed by a supplemental report in odd-numbered years. The projections in the California Gas Report are for long-term planning and do not necessarily reflect the day-to-day operational plans of the utilities. The latest California Gas Report is the 2025 California Gas Report Supplement.

4.6.4.4 Local Regulations
Cypress Municipal Code. The City of Cypress has adopted the 2022 CALGreen Code and incorporated the CALGreen Code by reference into the City Municipal Code (Chapter 5, Buildings, Article 1, Building Code, Section 5-1 California Building Codes – Adopted; where filed).

City of Cypress General Plan. The following goals and policies from the City of Cypress General Plan are applicable to the proposed project:
• COSR-3: Conserve energy resources through the use of available technology and conservation practices.
• COSR-3.1: Encourage innovative site planning and building designs that minimize energy consumption by taking advantage of sun/shade patterns, prevailing winds, landscaping, and building materials.
• COSR-3.2: Encourage new development and existing structures to install energy saving features. • AQ-1.3: Locate multiple family developments close to commercial areas to encourage pedestrian rather than vehicular travel.
• AQ-1.4: Develop neighborhood parks near concentrations of residents to encourage pedestrian travel to the recreation facilities.
• AQ-4.1: Promote energy conservation in all sectors of the City including residential, commercial, and industrial.
• AQ-4.3: Adopt incentives and regulations to reduce emissions from swimming pool heaters and residential and commercial water heaters.

Cypress Town Center and Commons Specific Plan 3.0. The following sustainable guidelines from the Specific Plan are applicable to the proposed project:

4.6 Lighting

1. Encourage the use of low-contrast lighting, low-voltage fixtures and energy-efficient bulbs, such as compact fluorescent and light emitting diodes.

2. Promote the use of lights with automated occupancy sensors in nonresidential buildings that automatically shut off when rooms are unoccupied.

S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026

4.6 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.6 Energy.docx «03/11/26» -10

3. Utilize solar-powered lights in landscaped areas for energy savings where possible.

4.7 Building Envelope

1. Install radiant barriers to reduce summer heat gain and winter heat loss.

2. Use natural ventilation techniques, such as operable windows, to take advantage of airflow for cooling interiors and reduce energy demand.

3. Use passive design to improve building energy performance through skylights, building orientation, landscaping and colors.

4. Consider reducing heat gain with the use of “cool roofs” that are painted with a highly reflective coating or employ light-colored materials.

5. Utilize water- and energy-saving fixtures and appliances, such as showerheads, toilets, washing machines, clothes dryers, refrigerators, and dishwashers certified as Energy Star compliant.

6. Encourage the use of recirculating hot water systems, which reduce the need to heat water, or tankless water heaters that heat water as needed instead of storing hot water in tanks, thereby reducing standby energy use.

7. Utilize a minimum insulation value of R30 in ceilings to reduce the need for additional heating and cooling.

8. Utilize programmable thermostats to provide more efficient and effective heating and cooling.

4.9 Energy Conservation

1. Utilize energy-efficient windows, such as models with spectrally selective low-e glass and with wood, vinyl, or fiberglass frames.

2. Utilize efficient building materials that take advantage of heat storage or thermal mass to reduce energy needed for heating and cooling interiors.

3. Reduce the number and area of east and west facing windows to reduce heat gain.

4. Insulate domestic hot water pipes where feasible.

5. Insulate attics.

6. Use dual pane and tinted windows where appropriate.

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026
S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A
P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.6 Energy.docx «03/11/26» 4.6-11

4.10 Heating, Ventilation, and Air Conditioning

1. Design and install heating, ventilation, and air conditioning (HVAC) systems according to the standards provided by the Air Conditioning Contractors of America handbooks or other comparable high-performance HVAC standards.

2. Install sealed-combustion/sealed-duct furnaces and water heaters for increased efficiency and indoor air quality.

3. Install only Energy Star-qualified ceiling fans to circulate air and reduce the demand on heating and cooling systems.

4. Locate windows in a manner that promotes natural cross ventilation.

5. Promote smart climate controls for both residential and commercial buildings to efficiently regulate temperature controls.

4.6.5 Thresholds of Significance
The thresholds of significance for energy impacts used in this analysis are consistent with Appendix G of the State CEQA Guidelines. Based on these thresholds, implementation of the proposed project would have a significant adverse impact with respect to energy if it would:

Threshold 4.6.1: Result in a potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation; or
Threshold 4.6.2: Conflict with or obstruct a state or local plan for renewable energy or energy efficiency.

4.6.6 Project Impacts
Threshold 4.6.1: Would the project result in a potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation?
Less Than Significant Impact. The proposed project would consume energy through day-to-day operations and fuel usage associated with project construction. This section discusses energy use resulting from future buildout envisioned under the proposed project and evaluates whether the proposed project would result in the wasteful, inefficient, or unnecessary consumption of energy resources during project construction or operation.

Construction. Construction is anticipated to commence in 2026 and be completed by 2038.Project-related demolition and construction activities would require energy resources primarily in the form of fuel consumption to operate heavy equipment, light-duty vehicles, machinery, and generators. Construction activities would include demolition, site preparation, grading, building construction, paving, and architectural coatings (painting). The construction- S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026

4.6 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.6 Energy.docx «03/11/26» -12 related equipment would be fueled by diesel fuel and gasoline. No natural gas demand is anticipated during construction. While some electricity may be required during construction activities, associated with generators and lighting, this analysis assumes that most energy required during project construction would be associated with fuel consumption.

As identified above, transportation energy represents the largest energy use during construction and would occur from the transport and use of construction equipment, delivery vehicles and haul trucks, and construction worker vehicles that would use petroleum fuels (e.g., diesel fuel and/or gasoline). Therefore, the analysis of energy use during construction focuses on fuel consumption. Construction trucks and vendor trucks hauling materials to and from the Buildout Area would be anticipated to use diesel fuel, whereas construction workers traveling to and from the Buildout Area would be anticipated to use gasoline-powered vehicles. Fuel consumption from transportation uses depends on the type and number of trips, VMT, the fuel efficiency of the vehicles, and the travel mode.

Estimates of fuel consumption (diesel fuel and gasoline) from construction equipment, construction trucks, and construction worker vehicles were based on default construction equipment assumptions and trip estimates from CalEEMod and fuel efficiencies from EMFAC2025.

Construction associated with buildout envisioned under the proposed project is anticipated to occur over an approximately 12-year timeline, which was included in CalEEMod. As described in Section 4.3, Air Quality, specific construction information for specific development projects, such as construction phasing and schedule, is not yet known; however, construction of the entire Buildout Area is assumed to commence in 2026 and conclude in 2038, which was included in CalEEMod. Other assumptions in the model include:
• Construction activities would include demolition, site preparation, grading, building construction, paving, and architectural coatings (painting). • The proposed project would require the cut of 248,600 cubic yards of soil and fill of 333,500 cubic yards of soil, which would result in the net import of 84,900 cubic yards of soil. • The proposed project would require the demolition of approximately 768,360 square feet of existing buildings. Based on information provided by the project applicant, demolition activities would require up to four excavators, two track loaders, a crawler crane, and several bobcats/backhoes.
• Tier 2 construction equipment would be used and the proposed project would comply with SCAQMD Rule 403 measures, which would ensure fuel efficiency. • Default assumptions (e.g., construction worker and truck trips and fleet activities) from CalEEMod were used where specific information regarding construction was not available.

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026
S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A
P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.6 Energy.docx «03/11/26» 4.6-13 Fuel consumption estimates are presented in Table 4.6.A: Energy Consumption Estimates during Construction. CalEEMod output sheets are included in Appendix B and detailed energy calculations are included in Appendix E of this Draft EIR.

Table 4.6.A: Energy Consumption Estimates during Construction Energy Type Total Energy Consumption Annual Energy Consumption Gasoline (gallons) 5,892,834.6 491,069.5
Diesel Fuel (gallons) 2,352,156.6 196,013.0
Source: Compiled by LSA Associates, Inc. (November 2025).

As indicated in Table 4.6.A, construction associated with the future buildout envisioned under the proposed project would consume approximately 5,892,834.6 gallons of gasoline and approximately 2,352,156.6 gallons of diesel fuel. As discussed above, the proposed project would be constructed over an approximately 12-year period; therefore, when averaged over 12 years, the proposed project would consume approximately 491,069.5 gallons of gasoline per year and 196,013.0 gallons of diesel fuel per year during construction. Based on fuel consumption obtained from EMFAC2025, approximately 1,003.9 million gallons of gasoline and approximately 170.5 million gallons of diesel will be consumed from vehicle trips in Orange County in 2025. Therefore, construction associated with future buildout of the proposed project would increase the annual fuel consumption from vehicle trips in Orange County by approximately 0.6 percent for gasoline fuel usage and approximately 1.4 percent for diesel fuel usage. Based on current crude oil production, it is assumed that there would be sufficient gasoline and diesel fuel to meet the project’s needs.16 Due to the minimal increase in annual fuel consumption in Orange County, project construction activities would have a negligible effect on local and regional energy supplies. Furthermore, impacts related to energy use during construction would be temporary and relatively small in comparison to Orange County’s overall use of the State’s available energy resources. No unusual project characteristics would necessitate the use of construction equipment that would be less energy efficient than at comparable construction sites in the region or the State. In addition, construction activities are not anticipated to result in an inefficient use of energy as gasoline and diesel fuel would be supplied by construction contractors who would conserve the use of their supplies to minimize their costs on the project. The proposed project would also utilize construction equipment that meets Tier 2 emissions standards or higher, which would ensure fuel efficiency. Assuming the use of Tier 2 construction equipment is conservative as construction contractors would utilize Tier 4 equipment when feasible. Construction of the proposed project would not cause or result in the need for additional energy facilities or an additional or expanded delivery system. Additionally, construction equipment and trucks would comply with CARB’s anti-idling regulations, including the In-Use Off-Road Diesel-Fueled Fleets regulation, which would result in efficient use of construction-related energy and reduce fuel consumption. Furthermore, on-road vehicles, such as haul trucks and worker vehicles, would be subject to federal fuel efficiency requirements. For these reasons, the proposed project would 16 United States Energy Information Administration (EIA). 2026. Short-Term Energy Outlook. Website:
https://www.eia.gov/outlooks/steo/report/petro_prod.php (accessed January 2026).

S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026

4.6 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.6 Energy.docx «03/11/26» -14 not cause wasteful, inefficient, or unnecessary consumption of energy resources during construction, and impacts would be less than significant.

Operation. Energy use associated with operation of the proposed project would consist of natural gas use, electricity consumption, and fuel used for vehicle trips associated with the project. Electricity and natural gas for the development allowed within the Buildout Area would be supplied by SCE and SoCalGas, respectively, through connections to existing service lines.

Electricity and natural gas use in buildings is divided into energy consumed by the built environment and energy consumed by uses that are independent of the construction of the building such as in plug-in appliances. In California, the California Building Standards Code Title 24 governs energy consumed by the built environment, mechanical systems, and some types of fixed lighting. Non-building energy use, or “plug-in” energy use can be further subdivided by specific end-use (refrigeration, cooking, appliances, etc.). Annual natural gas and electricity usage estimates associated with project operation were estimated through CalEEMod.

In addition, operation of the proposed project would result in energy usage associated with gasoline and diesel to fuel project-related trips. As identified in Table 4.17.A in Section 4.17, Transportation, buildout of the proposed project is expected to generate approximately 21,041 net new average daily trips. The amount of operational fuel use was estimated using CARB’s EMFAC2025 model, which provided projections for typical daily fuel usage in Orange County.

Table 4.6.B: Energy Consumption Estimates at Buildout provides the proposed project’s estimated annual operational energy usage. The energy estimates presented in Table 4.6.B are conservative as they do not take into account the energy usage from the existing uses except for the existing trip generation.

Table 4.6.B: Energy Consumption Estimates at Buildout
Energy Type Annual Energy Consumption
Electricity Consumption (kWh/year) 12,369,646.0
Natural Gas Consumption (therms/year) 142,377.0
Fuel Consumption
Gasoline (gallons/year) 326,558.6
Diesel Fuel (gallons/year) 27,084.4
Source: Compiled by LSA Associates, Inc. (November 2025). kWh = kilowatt-hours
Electricity. As shown in Table 4.6.B, the estimated potential increase in operational electricity demand associated with future buildout envisioned under the proposed project is 12,369,646.0 kWh per year. Total electricity demand in Orange County in 2024 was 19,225 GWh (19,225,000,000 kWh). Therefore, operational activities associated with buildout of the proposed project would increase the annual electricity consumption in Orange County by approximately 0.06 percent. While operational activities associated with buildout of the proposed project would result in an increase in demand for electricity, SCE has provided a will-serve letter. As such, SCE would be able to accommodate the project’s future electricity

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026
S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A
P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.6 Energy.docx «03/11/26» 4.6-15 demand during peak and base period demands without having to expand or construct new infrastructure.

Natural Gas. As shown in Table 4.6.B, the estimated potential increase in operational natural gas demand associated with future buildout envisioned under the proposed project is 142,377.0 therms per year. Total natural gas consumption in Orange County in 2024 was 561.7 million therms. Therefore, operational activities associated with buildout of the proposed project would negligibly increase the annual natural gas consumption in Orange County by approximately 0.03 percent. While operational activities associated with buildout of the proposed project would result in an increase in demand for natural gas, SoCalGas has provided a will-serve letter. As such, SoCalGas would be able to meet the natural gas demand during peak and base period demands of the related projects without additional facilities.

The proposed project’s electrical and natural gas demand would be relatively small in comparison to Orange County’s overall use of the State’s available electricity resources.

Therefore, the proposed project’s electrical demand would not be considered inefficient, wasteful, or unnecessary in comparison to other similar developments in the region. In addition, SCE is the private utility that would supply the proposed project’s electricity services. SCE is positioned to meet the State’s 60 percent goal for renewable energy by 2030 and the 100 percent goal for achieving carbon neutrality by 2045 mandate set forth in SB 100. SCE plans to continue to provide reliable service to their customers and upgrade their distribution systems as necessary to meet future demand.

Furthermore, the proposed project would be constructed using energy efficient modern building materials and construction practices, and would use new modern appliances and equipment, in accordance with the Appliance Efficiency Regulations (Title 20, CCR Sections 1601 through 1608). Future development would also be designed to meet sustainability goals, including the CALGreen Code and Title 24 energy efficiency requirements. CALGreen Code and Title 24 building energy efficiency standards establish minimum efficiency standards related to various building features, including appliances, water and space heating and cooling equipment, building insulation and roofing, and lighting, which would reduce energy usage. As such, electrical and natural gas demand associated with project operations would not be considered inefficient, wasteful, or unnecessary in comparison to other similar developments in the region.

Fuel Consumption. Buildout of the proposed project would also result in energy usage associated with gasoline and diesel fuel consumed by project-related vehicle trips. As shown in Table 4.6.B, fuel use associated with the vehicle trips generated by buildout of the proposed project is estimated at approximately 326,558.6 gallons of gasoline and 27,084.4 gallons of diesel fuel per year. Based on fuel consumption obtained from EMFAC2025, approximately 1,003.9 million gallons of gasoline and approximately 170.5 million gallons of diesel will be consumed from vehicle trips in Orange County in 2025. Therefore, vehicle trips associated with buildout of the proposed project would increase the annual fuel consumption in Orange County by approximately 0.03 percent for gasoline fuel usage and approximately 0.02 percent for diesel fuel usage. Therefore, gasoline and diesel fuel S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026

4.6 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.6 Energy.docx «03/11/26» -16 demand generated by vehicle trips associated with the proposed project would be a minimal fraction of gasoline and diesel fuel consumption in Orange County.

In addition, vehicles associated with trips to and from the Buildout Area would be subject to fuel economy and efficiency standards, which are applicable throughout the State. As such, the fuel efficiency of vehicles associated with future project operations would increase throughout the life of the project due to increasingly stringent standards over time. In addition, transit service in the vicinity of the Buildout Area is provided by the Orange County Transportation Authority (OCTA) along Katella Avenue and Valley View Street. As discussed in Section 4.17, Transportation, the proposed project is expected to generate approximately 210 daily transit trips, which would not interfere with the City’s transit infrastructure planning, including the specific actions to address the growing need for expanded transit service. In addition, the proposed project would include the addition of approximately 1 mile of bicycle facilities, connecting to the existing bicycle network.

Pedestrian access via sidewalks to the Buildout Area would be from Katella Avenue, Cerritos Avenue, Lexington Drive, and Vessels Circle, as extended. Further 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 integration with the broader pedestrian network, effectively linking the Buildout Area with nearby amenities and transit options.

As discussed further in Section 4.17, Transportation, future development under the proposed project would be required to implement Mitigation Measure TRA-1, which requires the implementation of feasible TDM strategies to mitigate the proposed project’s VMT impact. The TDM strategies 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. All future development facilitated by the proposed project would 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. As such, implementation of Mitigation Measure TRA-1 would help to reduce project-generated vehicle trips and VMT and encourage travel by other modes. In addition, since the proposed project would support the ability of future residents and visitors to use alternative transportation and would result in fuel usage that is a small fraction of current annual fuel use in Orange County, fuel consumption associated with vehicle trips generated by project operations would not be considered inefficient, wasteful, or unnecessary in comparison to other similar developments in the region.

Therefore, the proposed project would not result in a potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources during project construction or operation. Impacts would be less than significant, and no mitigation is required.

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026
S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A
P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.6 Energy.docx «03/11/26» 4.6-17 Threshold 4.6.2: Would the project conflict with or obstruct a state or local plan for renewable energy or energy efficiency?
Less Than Significant Impact. In 2002, the Legislature passed SB 1389, which required the CEC to develop an integrated energy plan every two years for electricity, natural gas, and transportation fuels, known as the Integrated Energy Policy Report. The plan calls for the State to assist in the transformation of the transportation system to improve air quality, reduce congestion, and increase the efficient use of fuel supplies with the least environmental and energy costs. To further this policy, the plan identifies a number of strategies, including assistance to public agencies and fleet operators in implementing incentive programs for ZEVs and their infrastructure needs, and encouragement of urban designs that reduce VMT and accommodate pedestrian and bicycle access.

The CEC’s 2024 Integrated Energy Policy Report Update provides the results of the CEC’s assessments of a variety of energy issues facing California. As indicated above, energy usage associated with buildout envisioned under the proposed project from construction activities would be temporary in nature and would be relatively small in comparison to the overall use in the County.

In addition, energy usage associated with future operation of buildout of the proposed project would be relatively small in comparison to the overall use in Orange County, and the State’s available energy resources. Therefore, energy impacts at the regional level would be negligible.

Because California’s energy conservation planning actions are conducted at a regional level, and because the proposed project’s total impact on regional energy supplies would be minor, buildout of the proposed project would not conflict with or obstruct California’s energy conservation plans as described in the CEC’s Integrated Energy Policy Report.

In addition, Connect SoCal 2024 identifies land use strategies that focus on new housing and job growth in areas served by high quality transit and other opportunity areas would be consistent with a land use development pattern that supports and complements the proposed transportation network. The forecasted development pattern, when integrated with the financially constrained transportation investments identified in Connect SoCal 2024, would reach emissions reduction target set by CARB, including the regional target of reducing GHG emissions from autos and lightduty trucks by 19 percent by 2035 (compared to 2005 levels). Buildout of the proposed project introduces new housing consistent with planned regional housing growth included in the SCAG Regional Housing Needs Assessment (RHNA) Allocation. As such, because the proposed project would accommodate planned regional housing growth included in the SCAG RHNA, the proposed project would not conflict with SCAG’s regional strategies outlined in Connect SoCal 2024.

The proposed project would be constructed using energy efficient modern building materials and construction practices, and would use new modern appliances and equipment, in accordance with the Appliance Efficiency Regulations (Title 20, CCR Sections 1601 through 1608). Future development would also be designed to meet sustainability goals, including the CALGreen Code and Title 24 energy efficiency requirements. CALGreen Code and Title 24 building energy efficiency standards establish minimum efficiency standards related to various building features, including appliances, water and space heating and cooling equipment, building insulation and roofing, and lighting, which would reduce energy usage.

S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026

4.6 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.6 Energy.docx «03/11/26» -18 Additionally, as demonstrated above, given that the proposed project would result in a minimal increase in annual electricity and natural gas consumption and that SCE and SoCalGas have provided will-serve letters, the proposed project would not result in the wasteful, inefficient, or unnecessary consumption of energy. Therefore, potential impacts related to conflict with or obstruction of a State or local plan for renewable energy or energy efficiency would be less than significant, and no mitigation is required.

4.6.7 Level of Significance Prior to Mitigation
The proposed project would result in less than significant impacts related to energy, and no mitigation is required.

4.6.8 Regulatory Compliance Measures and Mitigation Measures

4.6.8.1 Regulatory Compliance Measures
No Regulatory Compliance Measures are applicable to the proposed project pertaining to energy.

4.6.8.2 Mitigation Measures
Although the implementation of the following mitigation measure would reduce the proposed project’s less than significant impact related to energy, its implementation is not required to reduce the proposed project’s energy impacts to less than significant.

Mitigation Measure TRA-1 Transportation Demand Management Strategies. The Development Agreement between the City of Cypress and a future project applicant regarding the proposed project shall include a provision requiring that any future project applicants for subsequent residential development projects within the Buildout Area demonstrate the project's
consistency with the measures set forth in Items 1 and 2 below that are applicable to such project prior to its
approval to the satisfaction of the City of Cypress Planning Director.

1. Construct or Improve Bike Facility (California Air
Pollution Control Officers Association [CAPCOA]
Handbook Strategy T-19-A): This transportation
demand management strategy requires 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 bike to their
destination rather than drive, reducing the number of
vehicle trips and overall project-generated vehicle miles traveled (VMT).

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026
S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A
P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.6 Energy.docx «03/11/26» 4.6-19

2. Provide Pedestrian Network Improvement (CAPCOA
Handbook Strategy T-18): This transportation demand
management strategy requires the construction of offsite sidewalks to improve sidewalk coverage and pedestrian access to the surrounding area.

4.6.9 Level of Significance after Mitigation
The proposed project would result in less than significant impacts related to energy, and no mitigation is required.

4.6.10 Cumulative Impacts
The proposed project would have a significant effect on the environment if it, in combination with other past, present, and future projects, would contribute to a significant cumulative impact related to energy.

The geographic area for cumulative analysis of electricity is the SCE service area, while the geographic area for cumulative analysis of natural gas service is the SoCalGas service area. Although the proposed project would result in an increase in demand for electricity, this increase would not require SCE to expand or construct infrastructure that could cause substantial environmental impacts due to SCE’s will-serve letter and the proposed project’s minimal increase in annual energy consumption. As discussed previously, total electricity consumption in the SCE service area in 2024 was 79,341 GWh. By 2030, consumption is anticipated to increase by approximately 12,000 GWh for the low-demand scenario and by approximately 22,000 GWh for the high-demand scenario. 17 While
this forecast for the overall service area represents a large increase in electricity consumption, the proposed project’s consumption would be minimal in comparison to the total overall increase in energy consumption. Therefore, given the will-serve letter and SCE’s planned increase in total electricity consumption, the proposed project, in combination with cumulative development, is within SCE’s system-wide net annual increase in electricity supplies over the 2018 to 2030 period, and there are sufficient planned electricity supplies in the region for estimated net increases in energy demands.

Furthermore, as demonstrated in Table 4.6.B above, the estimated potential increase in operational electricity demand associated with future buildout envisioned under the proposed project is 12,369,646.0 kWh per year. Therefore, operational activities associated with buildout of the proposed project would increase the annual electricity consumption in the SCE service area by approximately 0.03 percent. As such, the proposed project’s share of cumulative electricity consumption would be negligible. In addition, as described above, future development under the proposed project is required to comply with various federal and State regulations to improve energy efficiency in buildings, equipment, and appliances, which would help to reduce electricity consumption associated with the proposed project. Therefore, the proposed project’s contribution 17 California Energy Commission (CEC). 2018. California Energy Demand, 2018–2030 Revised Forecast.

Publication Number: CEC-200-2018-002-CMF. February. Website: https://efiling.energy.ca.gov/ getdocument.aspx?tn=223244 (accessed November 2025).

S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026

4.6 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.6 Energy.docx «03/11/26» -20 to impacts related to the inefficient, wasteful, and unnecessary consumption of electricity would not be cumulatively considerable.

Similarly, the proposed project is not anticipated to require additional natural gas infrastructure as a result of the cumulative development due to SoCalGas’ will-serve letter and the proposed project’s minimal increase in annual natural as consumption. Total natural gas consumption in the SoCalGas service area in 2024 was 4,959 million therms. Between 2018 and 2030, total natural gas consumption in the SoCalGas service area is forecast to remain steady for the low- and mid-demand scenarios and to increase by approximately 650 million therms in the high-demand scenario due to intense energy efficiency efforts.
18 As shown in Table 4.6.B above, the estimated potential increase in operational natural gas demand associated with future buildout envisioned under the proposed project is 142,337.0 therms per year. Therefore, operational activities associated with buildout of the proposed project would increase the annual natural gas consumption in the SoCalGas service area by less than 0.01 percent. As such, the proposed project’s share of consumption of natural gas in the SoCalGas service area would be minimal. Given the will-serve letter and SoCalGas’ planned increase in total natural gas consumption, It is anticipated that SoCalGas would be able to meet the natural gas demand of the related projects without additional facilities. Therefore, the proposed project’s contribution to impacts related to the inefficient, wasteful, and unnecessary consumption of natural gas would not be cumulatively considerable.

In addition, both SCE and SoCalGas demand forecasts include the growth contemplated by the proposed project and the related projects. Increased energy efficiency to comply with building energy efficiency standards would reduce energy consumption on a per-square-foot basis.

Furthermore, utility companies are required to increase their renewable energy sources to meet the Renewable Portfolio Standards mandate of 60 percent renewable supplies by 2030. SCE and SoCalGas plan to continue to provide reliable service to their customers and upgrade their distribution systems as necessary to meet future demand.

Future development associated with buildout of the proposed project would also result in energy usage associated with gasoline and diesel fuel consumed by project-related vehicle trips. As shown in Table 4.6.B, fuel use associated with the vehicle trips generated by future buildout of the proposed project is estimated at approximately 326,558.6 gallons of gasoline and 27,084.4 gallons of diesel fuel per year. Based on fuel consumption obtained from EMFAC2025, approximately 1,003.9 million gallons of gasoline and approximately 170.5 million gallons of diesel will be consumed from vehicle trips in Orange County in 2025. Therefore, vehicle trips associated with buildout of the proposed project would increase the annual fuel consumption in Orange County by approximately 0.03 percent for gasoline fuel usage and approximately 0.02 percent for diesel fuel usage. As such, although transportation energy use would increase, this negligible increase in transportation energy use would not represent a major amount of energy use when compared to the amount of existing fuel consumption and total number of vehicle trips and VMT throughout Orange County and the region. Therefore, given the project’s negligible increase in fuel consumption and the availability of gasoline and diesel fuel, the proposed project’s contribution to impacts 18 California Energy Commission (CEC). 2018. California Energy Demand, 2018–2030 Revised Forecast.

Publication Number: CEC-200-2018-002-CMF. February. Website: https://efiling.energy.ca.gov/ getdocument.aspx?tn=223244 (accessed November 2025).

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026
S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A
P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.6 Energy.docx «03/11/26» 4.6-21 related to the inefficient, wasteful, and unnecessary consumption of fuel would not be cumulatively considerable.

In addition, vehicles associated with trips to and from the Buildout Area would be subject to fuel economy and efficiency standards, which are applicable throughout the State. As such, the fuel efficiency of vehicles associated with project operations would increase throughout the life of the proposed project due to increasingly stringent standards over time. As discussed further in Section 4.17, Transportation, the future development under the proposed project would be required to implement Mitigation Measure TRA-1, which requires the implementation of feasible TDM strategies to mitigate the proposed project’s residential 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, and cumulative projects throughout the City, would 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. As such, implementation of Mitigation Measure TRA-1 would help to reduce project-generated vehicle trips and residential VMT and encourage travel by other modes. In addition, since the proposed project would result in fuel usage that is a small fraction of current annual fuel use in Orange County, fuel consumption associated with vehicle trips generated by project operations would not be considered inefficient, wasteful, or unnecessary in comparison to other similar developments in the region.

Furthermore, as previously discussed, the proposed project would be consistent with the CEC’s 2024 Integrated Energy Policy Report Update and Connect SoCal 2024. As the project is consistent with the identified applicable renewable energy and energy efficiency plans, its contribution to cumulative impacts related to consistency with adopted energy conservation plans, or state or local energy standards for renewable energy or energy efficiency would not be cumulatively considerable.

As demonstrated above, the proposed project, in combination with other past, present, and potential future projects, would not result in wasteful, inefficient, or unnecessary consumption of energy or conflict with or obstruct a State or local plan for renewable energy or energy efficiency.

Therefore, the proposed project’s contribution to impacts related to energy would not be cumulatively considerable, and this impact would be less than significant. No mitigation is required.

S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026

4.6 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.6 Energy.docx «03/11/26» -22 This page intentionally left blank

DRAFT EN VI RONMENTAL IMPACT REPO RT
M ARCH 2026

4.7 GEOLOGY AND SOILS
SPECIFIC PLAN 3.0 BU ILDOUT PROJECT

CYPRESS, CALIFO RNIA
This section provides a discussion of the existing geology and soils setting and an analysis of the potential for the Specific Plan 3.0 Buildout Project (proposed project) to result in impacts related to geology and soils. This section addresses potential impacts due to the local geology underlying the Buildout Area, as well as slope stability, ground settlement, soil conditions, grading, and regional and local seismic conditions. This section also evaluates potential impacts to paleontological resources.

The geology and soils analysis in this section is based in part on the technical analysis contained in the Environmental Impact Report, Soils and Geology Issues, Proposed Mixed-Use Development, 4961 Kate/la Avenue and 5100 Cerritos Avenue, Cypress, California (Geotechnical lnvestigation) 1 (Appendix F) that was prepared for the proposed project. The paleontological analysis relies on the Geotechnical Investigation and on a literature review and locality search completed for the Buildout Area. This section also incorporates data from the City of Cypress General Plan, 2 numerous State and federal studies of geologic and seismic hazards in the vicinity of the City, site-specific investigations in the Buildout Area, and field observations.

4.7.1 Scoping Process
The City of Cypress (City) received six comment letters during the public review period for the Notice of Preparation (NOP). For copies of the NOP comment letters, refer to Appendix A of this Draft Environmental Impact Report (Draft EIR). No comment letters included comments related to geology and soils.

4. 7 .2 Methodology
To assess the potential impacts of the proposed project with respect to geologic and soil conditions, Geotechnologies conducted a soils and geotechnical investigation in March 2024, which was then revised in May 2024 (Geotechnical Investigation). The discussion below describes the scope of the investigation, including methods used during background research and data review, site reconnaissance, field exploration, and engineering analyses.

4.7.2.1 Background Research and Data Review
Existing geologic literature (i.e., geologic maps, boring logs, and other applicable data) was reviewed by Geotechnologies, Inc. as is reflected in Appendix F.

4.7.2.2 Field Exploration
As part of the Geotechnical Investigation (Appendix F), the Buildout Area was explored on January 3, 4, and 5, 2024, by excavating six borings and by performing seven Cone Penetration Test (CPT) soundings. The borings were excavated to depths ranging between 50 and 60 feet below grade, with the aid of a truck-mounted drilling machine. The CPTs were conducted to depths ranging between

60.31 and 60.52 feet below the existing grade. The boring and CPT locations and the interpretation 2 Geotechnologies, Inc. 2024. Environmental Impact Report, Soils and Geology Issues, Proposed Mixed-Use Development, 4961 Kate/la Avenue and 5100 Cerritos Avenue, Cypress, California. May 2. (Appendix F) City of Cypress. 2001. Cypress General Plan Safety Element.

P:\A-E\CCP2201.0S LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.7 Geology and Soils.docx «03/10/26» 4.7-1 SPECIFIC PLAN 3.0 BUI LOO UT PROJECT

CYPRESS, CALIFORNIA

DRAFT ENVIRONMENTAL IMPACT REPORT
MARCH 2026
of the geologic materials encountered are provided in the Boring Logs, Plates A-1 through A-6 and CPT Data Logs, which are included as an appendix to the Geotechnical Investigation (Appendix F).

4.7.2.3 Liquefaction Analysis
Geotechnologies performed a total of ten liquefaction analyses utilizing Standard Penetration Test (SPT) data collected in the borings, laboratory test data, and CPT data. The liquefaction potential evaluations were performed by utilizing a magnitude 6.77 earthquake and a peak horizontal acceleration of 0. 70g (acceleration due to gravity), consistent with American Society of Civil Engineers (ASCE), the California Department of Health Care Access and Information (HCAI), the California Geological Survey (CGS), and the United States Geological Survey (USGS) guidelines. CPT data were also analyzed utilizing liquefaction assessment software.

4.7.3 Existing Environmental Setting

4.7.3.1 Buildout Area
According to the Geotechnical Investigation, the topography of the Buildout Area is relatively level, with no pronounced high or low areas. A variety of existing structures and facilities are located on the Los Alamitos Race Course (LARC) Property that support horse racing, training, and community activities. Structures include a race track, grandstand structure, three artificial lakes inside the total track area, one-story clubhouse and restaurant structures, lighting structures, approximately 41 permanent one-story barns and several temporary structures and barns. The LARC Property also contains parking areas, landscaping, drainage features, sheds, maintenance areas, and perimeter fencing. The Cypress GC Property includes a portion of the former Cypress Golf Club, which ceased operation years ago. LARC currently uses approximately one acre of the Cypress GC Property (designated as Lot 1 in Vesting Tentative Tract Map (VTTM) 19247) as a maintenance yard, while the clubhouse for the former Cypress Golf Club is presently being used as a church.

The land owned by Grace Church within the Buildout Area, designated as Lots 5 and 10 in VTTM 19247, is part of a larger church property that is currently used for religious services and events and includes a small school, open space, and parking areas.

4.7.3.2 Regional Geology
The Buildout Area is located within the Los Angeles Basin and within the Peninsular Ranges Geomorphic Province. The Peninsular Ranges are characterized by northwest-trending blocks of mountain ridges and sediment-floored valleys. The dominant geologic structural features are northwest trending fault zones that either die out to the northwest or terminate at east-west trending reverse faults that form the southern margin of the Transverse Ranges.

The Los Angeles Basin is located at the northern end of the Peninsular Ranges Geomorphic Province.

The basin is bounded to the east and southeast by the Santa Ana Mountains and San Joaquin Hills. It is bounded to the northwest by the Santa Monica Mountains. Over 22 million years ago, the Los Angeles basin was a deep marine basin formed by tectonic forces between the North American and Pacific plates. Since that time, over 5 miles of marine and non-marine sedimentary rock as well as intrusive and extrusive igneous rocks have filled the basin. During the last 2 million years, defined by the Pleistocene and Holocene epochs, the Los Angeles basin and surrounding mountain ranges have been

4.7-2 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.7 Geology and Soils.docx «03/10/26»

DRAFT ENVIRONMENTAL IMPACT REPORT
MARCH 2026
SPECIFIC PLAN 3.0 BUILDOUT PROJECT

CYPRESS, CALIFORNIA
uplifted to form the present-day landscape. Erosion of the surrounding mountains has resulted in deposition of unconsolidated sediments in low-lying areas by rivers such as the Los Angeles River.

Areas that have experienced subtle uplift have been eroded with gullies.

4.7.3.3 Local Geology and Subsurface Conditions
As part of the Geotechnical Investigation, six exploratory borings were drilled to depths ranging from approximately 50 to 60 feet and seven CPTs were performed and advanced to depths from

60.31 to 60.52 feet to determine subsurface conditions in the Buildout Area. Fill materials were encountered in all six exploratory borings at depths ranging from 3 to 5 feet below the existing grade, consisting of a mixture of silty sand and sandy silt in colors from yellowish brown to dark brown, with a moist, stiff to medium dense, fine-grained texture and occasional gravel. Fill materials are underlain by native alluvial soils consisting of interlayered mixtures of sandy to silty clay, sandy to clayey silt, silty to clayey sand, and sand. The alluvial soils range from yellowish brown to grayish brown to dark gray in color, and are moist to wet, firm to very stiff, or loose to very dense, and fine grained.

4.7.3.4 Local Groundwater Conditions
Historically, the highest groundwater level beneath the Buildout Area is approximately 10 feet below the ground surface level. 3 Seasonal fluctuations in the level of groundwater may occur due to variations in rainfall, temperature, and other factors not evident at the time the measurements were taken. Fluctuations also may occur across the site.

According to the Geotechnical Investigation, groundwater was encountered at depths of 5 to

12.5 feet below ground surface, indicating the presence of shallow groundwater conditions beneath the Buildout Area. Four of the borings encountered groundwater at depths 5 to 8 feet below ground surface, and two borings encountered groundwater at depths 9 to 12.5 feet below ground surface, which is slightly higher than the historically highest groundwater level for the Buildout Area established by the California Geological Survey Seismic Hazard Zone report of the Los Alamitos Quadrangle in 1998, as described above. 4

4.7.3.5 Fault Systems and Seismic Conditions
A potentially active fault is defined by the State as a fault with a history of movement within Pleistocene time (between 11,000 and 1.6 million years ago [Ma]). The active and potentially active faults are capable of producing potentially strong seismic shaking at the Buildout Area. It is anticipated that the Buildout Area will periodically experience ground acceleration as a result of earthquakes. The closest mapped active faults to the Buildout Area include the Newport-Inglewood and Whittier Fault Zones located approximately 4.8 miles southwest and 11.6 miles east of the Buildout Area, respectively.
3 4
California Department of Conservation (DOC) California Geological Survey (CGS). 1998, Revised 2006.

Seismic Hazard Zone Report of the Los Alamitos Quadrangle, Plate 1.2, entitled "Historically Highest Ground Water Contours".

Ibid.

P:\A-E\CCP2201.0S LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.7 Geology and Soils.docx «03/10/26» 4.7-3 SPECIFIC PLAN 3.0 BUI LOO UT PROJECT

CYPRESS, CALIFORNIA

DRAFT EN VIRONMENTAL IMPACT REPORT
MARCH 2026
The Buildout Area is not located within the boundaries of an "Earthquake Fault Zone," as defined by the State of California in the Alquist-Priolo Earthquake Fault Zoning Act. 5 Furthermore, the Cypress General Plan Safety Element indicates that no active faults have been identified within City boundaries.

Seismic shaking is characterized by the physical movement of the land surface during and subsequent to an earthquake. Seismic shaking has the potential to cause destruction and damage to buildings and property, including damage resulting from damaged or destroyed gas or electrical utility lines, disruption of surface drainage, blockage of surface seepage and groundwater flow, changes in groundwater flow, dislocation of street alignments, displacement of drainage channels and drains and possible loss of life. In addition, ground shaking can induce several kinds of secondary seismic effects, including liquefaction, differential settlement, and landslides.

The intensity of seismic shaking during an earthquake depends largely on the geologic foundation conditions of the materials composing the upper several hundred feet of the Earth's surface. The greatest amplitudes and longest durations of ground shaking occur on thick, water-saturated, unconsolidated alluvial sediments, which may lead to liquefaction (as further described below).

Ground shaking can also cause ground failure or deformation due to lurching and liquefaction.

Surface fault rupture refers to the displacement of the ground surface along a fault, which can occur during strong earthquakes. The potential for seismic hazards within the Buildout Area is a consequence of ground shaking caused by events on nearby active faults. However, as previously discussed, the Buildout Area is not located within a designated Alquist-Priolo Earthquake Fault Zone, so the possibility for surface fault rupture is low. The Buildout Area is, however, located approximately 4.8 miles to the northeast of an earthquake fault zone that has been established around the active traces of the Newport-Inglewood Fault.

4.7.3.6 Liquefaction and Lateral Spreading
Liquefaction occurs when saturated, cohesionless soils temporarily lose shear strength (liquefy) due to increased pore water pressures induced by strong ground motion during an earthquake. Intervals of loose sand may, therefore, be subject to liquefaction if these materials are or were to become submerged and also exposed to strong seismic ground shaking. Seismic ground shaking of relatively loose, granular soils that are saturated or submerged can cause the soils to liquefy and temporarily behave as a dense fluid. This loss of support can produce local ground failure such as settlement or lateral spreading that may damage overlying improvements.

Lateral spreading typically occurs as a form of horizontal displacement of relatively flat-lying alluvial material toward an open or "unconfined" face such as an open body of water, channel, or excavation. In soils, this movement is generally due to failure along a weak plane and is often 5 California Department of Conservation (DOC) California Geological Survey. 2025a. Earthquake Zones of Required Investigation. Website: https://ma ps.conservation.ca.gov /cgs/informationwa rehouse/ eqza pp/ (accessed January 21, 2025).

4.7-4 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.7 Geology and Soils.docx «03/10/26»

DRAFT ENVIRONMENTAL IMPACT REPORT
MARCH 2026
SPECIFIC PLAN 3.0 BUILDOUT PROJECT

CYPRESS, CALIFORNIA
associated with liquefaction. The Safety Element of the City's General Plan and the California Geological Survey identify the Buildout Area as an area at a potentially high risk of liquefaction. 6 As discussed in the Geotechnical Investigation, the Buildout Area is located within an area designated as "liquefiable" based on groundwater depth records, soil type and distance to a fault capable of producing a substantial earthquake. Therefore, Geotechnologies performed a total of ten liquefaction analyses utilizing SPT data collected in the borings, laboratory test data, and CPT data.

The liquefaction potential evaluations were performed by utilizing a magnitude 6.77 earthquake and a peak horizontal acceleration of 0.70g, consistent with ASCE, HCAI, CGS, and USGS guidelines. The liquefaction analyses of three of the borings revealed that some of the soil layers located on the Buildout Area between 7.5 to 60 feet below existing grade may liquefy in the event of an earthquake on a local or regional fault.

CPT data were also analyzed utilizing liquefaction assessment software, which indicated some of the soil layers at varying depths below the ground surface are susceptible to liquefaction. These layers are located between approximately a few inches and several feet in thickness. The Geotechnical Investigation concluded that differential settlement at the existing ground surface due to liquefaction could be expected to range between 1.24 and 3.67 inches without stabilization techniques at the upper soils being implemented.

4.7.3.7 Subsidence
The phenomenon of widespread land sinking, or subsidence, is generally related to substantial over pumping of groundwater or petroleum reserves from deep underground reservoirs. Like most of northern Orange County, the City lies atop the Orange County Groundwater Basin (Orange County Basin). Although slight subsidence has been observed elsewhere in the Orange County Basin in Santa Ana (likely due to groundwater withdrawal) and in the Huntington Beach area (likely due to oil extraction), there is no recent history of subsidence in the vicinity of the Buildout Area. 7 Groundwater levels and storage in the Orange County Basin are managed by the Orange County Water District (OCWD) in a manner that reduces the potential for land subsidence to occur. The Geotechnical Investigation concluded that the Buildout Area is not located within a zone of known subsidence due to oil or other fluid withdrawal.

4.7.3.8 Lateral Spreading
Lateral spreading can occur when blocks of mostly intact surficial soil displace down gradient or towards a free face along a shear zone that has formed within the liquefied sediment. It is the most pervasive type of liquefaction-induced ground failure. The Buildout Area, and its vicinity, are relatively level, and there are no free faces present at the site or its surroundings. Therefore, 6 7
California Department of Conservation (DOC) California Geological Survey. 2025a. Earthquake Zones of Required Investigation. Website: https://maps.conservation.ca.gov/cgs/informationwarehouse/eqzapp/ (accessed January 21, 2025).

California Department of Water Resources (DWR). 2013. California's Groundwater Update 2013. Natural Resources Agency. Website: https://cawaterlibrary.net/wp-content/uploads/2017 /05/GWU2013_ Ch6_ SouthCoast_Final.pdf (accessed January 22, 2025).

P:\A-E\CCP2201.0S LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.7 Geology and Soils.docx «03/10/26» 4.7-5 SPECIFIC PLAN 3.0 BUI LOO UT PROJECT

CYPRESS, CALIFORNIA

DRAFT EN VIRONMENTAL IMPACT REPORT
MARCH 2026
according to the Geotechnical Investigation, the potential for lateral spreading occurring within the Buildout Area is low.

4.7.3.9 Compressible/Collapsible Soils
Compressible soils are soils that consolidate when exposed to new loading, such as Artificial Fill or foundation loads. Soil collapse occurs when soils substantially decrease in volume following an increase in moisture content. The results of the subsurface investigation within the Buildout Area indicated that the majority of the Buildout Area is underlain by fill materials and alluvial soils, which generally consist of silty sand and sandy silt, and interlayered mixtures of sandy to silty clay, sandy to clayey silt, silty to clayey sand, and sand. The Geotechnical Investigation concluded that the Buildout Area soils are not considered prone to collapsing or compressing.

4.7.3.10 Landslides and Unstable Slopes
Landsliding can occur in areas where topography is generally sloped. The Buildout Area is considered to have level topography, with no substantial slopes. Therefore, according to the Geotechnical Investigation, the probability of seismically induced landslides occurring within the Buildout Area is considered to be negligible.

4.7.3.11 Paleontological Resources
Results of the literature review indicate that the Buildout Area is located within the Peninsular Ranges Geomorphic Province, a 900-mile long northwest-southeast trending structural block that extends from the Transverse Ranges in the north to the tip of Baja California in the south and includes the Los Angeles Basin. 8•9 This province is characterized by mountains and valleys that trend in a northwest-southeast direction, roughly parallel to the San Andreas Fault Zone.10,11 Within this larger region, the Buildout Area is located in the Los Angeles Basin, a broad alluvial lowland bounded to the north and east by the San Gabriel and Santa Ana Mountains, respectively, and by the Pacific Ocean to the southwest.12 The basin is underlain by a structural depression that has discontinuously accumulated thousands of feet of marine and terrestrial deposits since the Late Cretaceous (approximately 100.5 Ma).13
Subsurface exploration for the proposed project, including six exploratory borings and seven CPTs, identified a thin mantle of artificial fill (3-5 feet thick) underlain by native Quaternary alluvial deposits. The artificial fill consists primarily of silty sand and sandy silt with occasional gravel, whereas the alluvium is interlayered with sandy to silty clay, sandy to clayey silt, silty to clayey sand, 8 9
10 California Department of Conservation (DOC) California Geological Survey (CGS). 2002. California Geomorphic Provinces. Note 36.

Norris, R.M., and R.W. Webb. 1976. Geology of California. Wiley.

Ibid.
11 Sharp, R.V. 1976. Surface faulting in Imperial Valley during the earthquake swarm of January-February 1975. Bulletin of the Seismological Society of America, 66(4), 1145-1154. 12 Yerkes, R.F., T.H. Mcculloh, J.E. Schoell ha mer, and J.G. Vedder. 1965. Geology of the Los Angeles, Basin, California -An Introduction, U.S. Geological Survey Professional Paper 420-A. 13 Ibid.

4.7-6 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.7 Geology and Soils.docx «03/10/26»

DRAFT ENVIRONMENTAL IMPACT REPORT
MARCH 2026
SPECIFIC PLAN 3.0 BUILDOUT PROJECT

CYPRESS, CALIFORNIA
and sand. 14 Groundwater was encountered between 5 and 12.5 feet below grade, consistent with historically shallow groundwater levels in the basin. 15 Artificial fill consists of sediments that have been removed from one location and transported to another location by human activity, rather than by natural means. The transportation distance can vary from a few feet to many miles, and composition is dependent on the source and purpose.

Artificial fill will sometimes contain modern debris such as asphalt, wood, bricks, concrete, metal, glass, plastic, and even plant material. While artificial fill may contain fossils, these fossils have been removed from their original location and are thus out of stratigraphic context. Therefore, they are not considered important for scientific study, and artificial fill has no paleontological sensitivity. 16 The underlying alluvial deposits are late Quaternary in age (Pleistocene to Holocene) and vary in paleontological sensitivity depending on depth. The upper Holocene deposits (less than 11,700 years old) are generally considered to have low sensitivity, as fossils from this interval are relatively uncommon and typically lack scientific significance. 17 In contrast, the deeper Pleistocene deposits (older than 11,700 years) are assigned high paleontological sensitivity because they may yield significant vertebrate fossils (e.g., mammoth, horse, camel, bison), as well as smaller mammals, reptiles, and plants elsewhere in the region. 18
According to the locality search conducted by the National History Museum of Los Angeles County (NHMLA), there are no known fossil localities within the Buildout Area or in the City. However, the search did return fossil localities, present in the same type of sedimentary deposits that underlay19 the Buildout Area, located within a 10-mile radius of the Buildout Area. Such deposits are often paleontologically sensitive, as they can contain vertebrate fossils (e.g., mammoths, ground sloths, camelids) at depth. Typically, the upper 5 feet of shallow fill and disturbed soils are low sensitivity, but deeper undisturbed alluvium is considered to have high sensitivity under Society of Vertebrate Paleontology (SVP) guidelines. 20 The closest locality, LACM VP 3660 is northwest of the Buildout Area at Cover Street and Pixie Avenue, approximately 6.8 miles northwest in the City of Lakewood.

This locality produced specimens of Mammoth (Mammuthus) at a depth of 19 feet below ground surface. Farther to the west in Long Beach, approximately 13 miles away, localities LACM VP 3260 and LACM VP 7493 produced fossils of Bison (Bison) at 8.5 feet below ground surface and camel (Camelidae) at surface. A copy of the results letter from the NHMLA is included in Appendix F. 14 Geotechnologies, Inc. 2024. Environmental Impact Report Soils and Geology Issues, Proposed Mixed-Use Development, 4961 Kate/la Avenue and 5100 Cerritos Avenue, Cypress, California. May 2. (Appendix F) 15 Ibid.
16 Society of Vertebrate Paleontology (SVP). 2010. Standard Procedures for the Assessment and Mitigation of Adverse Impacts to Paleontological Resources. Bethesda, MD. 17 Ibid. 18 Ibid.
19 Geotechnologies, Inc. 2024. Environmental Impact Report Soils and Geology Issues, Proposed Mixed-Use Development, 4961 Kate/la Avenue and 5100 Cerritos Avenue, Cypress, California. May 2. (Appendix F) 20 Society of Vertebrate Paleontology (SVP). 2010. Standard Procedures for the Assessment and Mitigation of Adverse Impacts to Paleontological Resources. Bethesda, MD.

P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.7 Geology and Soils.docx «03/10/26» 4.7-7 SPECIFIC PLAN 3.0 BUI LOO UT PROJECT

CYPRESS, CALIFORNIA

4.7.4 Regulatory Setting

DRAFT EN VIRONMENTAL IMPACT REPORT
MARCH 2026
The following section describes the federal, State, regional, and local regulatory framework applicable to analyzing potential impacts related to geology and soils from development of the proposed project.

4.7.4.1 Federal Regulations
There are no federal policies or regulations related to geology and soils that are applicable to the proposed project.

4.7.4.2 State Regulations
Alquist-Priolo Earthquake Fault Zoning Act (1972) (Pub. Resources Code § 2621 et seq.). The Alquist-Priolo Earthquake Fault Zoning Act of 1972 and updates (Pub. Resources Code, Section 2621, et seq.) is the principal California State guidance to prevent the construction of habitable structures on the surface trace of active earthquake faults. If an active fault is found, a structure for human occupancy must be set back from the fault (generally 50 feet). The Alquist-Priolo Earthquake Fault Zoning Act only addresses the hazard of surface fault rupture; it does not consider other earthquake hazards. There are no known earthquake fault zones on or in the near vicinity of the Buildout Area; therefore, regulations recommended by the CGS for investigations conducted in such zones do not specifically apply.

Seismic Hazard Mapping Act (1990) (Pub. Resources Code §§ 2690-2699.6). The Seismic Hazard Mapping Act {SHMA) was adopted by the State in 1990 to address the potential hazards posed by secondary effects of seismic activity, including strong ground shaking, soil liquefaction, and associated ground failure and seismically induced landslides. The CGS prepares and provides local governments with seismic hazard zone maps that identify areas susceptible to amplified shaking, liquefaction, earthquake-induced landslides, and other ground failures. The seismic hazard zones are referred to as "zones of required investigation" because site-specific geological investigations are required for construction projects located within these areas. Before a project can be permitted, a geologic investigation, evaluation, and written report must be prepared by a licensed geologist to demonstrate that the potential hazards can be successfully mitigated.

Public Resources Code. Section 5097.5 of the PRC provides for the protection of cultural and paleontological resources and prohibits the removal, destruction, injury, or defacement of archaeological and paleontological features on any lands under the jurisdiction of State or local authorities.

4.7.4.3 Regional Regulations
There are no regional policies or regulations related to geology and soils that are applicable to the proposed project.

4.7.4.4 Local Regulations
Cypress Town Center and Commons Specific Plan 3.0. The Cypress Town Center and Commons Specific Plan 3.0 does not contain any provisions related to geology and soils.

4.7-8 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.7 Geology and Soils.docx «03/10/26»

DRAFT EN VI RONMENTAL IMPACT REPO RT
M ARCH 2026
SPECIFIC PLAN 3.0 BU ILDOUT PROJECT

CYPRESS, CALIFO RNIA
City of Cypress General Plan Conservation/Open Space/Recreation Element. The City of Cypress General Plan identifies goals and policies related to paleontological resources. Goal COSR-5 in the Conservation/Open Space/Recreation Element (2000) of the City's General Plan addresses paleontological resources (and potential resources) and indicates that conservation of the resources and investigation of potential resource areas is an important undertaking for connecting with the community's past.

The following goals and policies apply to the proposed project:
• COSR-5: Preserve Cypress' archaeologic and paleontological resources. o COSR-5.1: Update records of resource finds and locations when required. o COSR-5.2: Prior to development in previously undeveloped areas, require strict adherence to the CEQA guidelines for environmental documentation and mitigation measures where development will affect archaeological or paleontological resources.

City of Cypress Municipal Code. Building and construction in the City are subject to the regulations of the City of Cypress Municipal Code. California Code of Regulations (CCR), Title 24, Part 2, the California Building Code (CBC) (2022), provides minimum standards for building design in the State.

Local codes are permitted to be more restrictive than Title 24, but not less restrictive. The procedures and limitations for the design of structures are based on site characteristics, occupancy type, configuration, structural system height, and seismic design category. The seismic ratings used in the CBC are derived from the International Building Code specifications. Most of coastal Southern California, including the Buildout Area, is located in Seismic Design Category D. Construction activities are subject to occupational safety standards for excavation, shoring, and trenching as specified in the California Occupational Safety and Health Administration (Cal/OSHA) regulations (CCR, Title 8). In addition, future development allowed under the approved Specific Plan would be required to adhere to the regulatory standards described in Regulatory Compliance Measure GE0-1, provided below, which includes the seismic and building standards in the City's Building Code that adopt the CBC with amendments and modifications.

4.7.5 Thresholds of Significance
The thresholds of significance for geology and soils impacts used in this analysis are consistent with Appendix G of the State CEQA Guidelines. Based on these thresholds, implementation of the proposed project would have a significant impact with respect to geology and soils if it would:

Threshold 4.7.1: Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:
(i): Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidences of known fault; (Refer to Division of Mines and Geology Special Publication 42)
P:\A-E\CCP2201.0S LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.7 Geology and Soils.docx «03/10/26» 4.7-9 SPECIFIC PLAN 3.0 BUI LOO UT PROJECT

CYPRESS, CALIFORNIA

DRAFT EN VIRONMENTAL IMPACT REPORT
MARCH 2026
Threshold 4.7.2:

Threshold 4.7.3:

Threshold 4.7.4:

Threshold 4.7.5:

Threshold 4.7.6:
(ii): Strong seismic ground shaking;
(iii): Seismic-related ground failure, including liquefaction; (iv): Landslides;
Result in substantial soil erosion or the loss of topsoil; Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on-site or off-site landslides, lateral spreading, subsidence, liquefaction, or collapse; Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code {1994), creating direct or indirect substantial risks to life or property;
Have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater; or
Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature.

4.7.6 Project Impacts
Potential impacts of the proposed project related to geology and soils are discussed below pursuant to the thresholds established in Section 4.7.5, above.

Threshold 4.7.l(i): Would the project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving: Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidences of known fault? (Refer to Division of Mines and Geology Special Publication 42)
No Impact. As with all of Southern California, the Buildout Area is subject to strong ground motion resulting from earthquakes on nearby faults. The entire region of Southern California is considered to be seismically active. 21 There are, however, no known faults crossing the Buildout Area. According to the United States Geological Survey (USGS) Quaternary Faults Map, the closest fault to the Buildout Area, the Newport-Inglewood Fault System, is 4.8 miles southwest. The Whittier-Elsinore Fault System is the second closest fault to the Buildout Area, located approximately 11.6 miles east of the site.

The Buildout Area is not within an Alquist-Priolo Fault Hazard Zone. Additionally, according to the City's General Plan Safety Element, there are no active or potentially active faults in the City. As 21 City of Cypress. 2001. Cypress General Plan Safety Element. Website: https://www.cypressca.org/ home/showdocument?id=714 (accessed January 20, 2025).

4.7-10 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.7 Geology and Soils.docx «03/10/26»

DRAFT EN VI RONMENTAL IMPACT REPO RT
M ARCH 2026
SPECIFIC PLAN 3.0 BU ILDOUT PROJECT

CYPRESS, CALIFO RNIA
such, the chance for surface fault rupture, during or as a consequence of seismic activity, is considered unlikely. Therefore, future development of the land uses allowed under the Specific Plan would not expose people or structures to substantial adverse effects involving the rupture of a known earthquake fault as delineated in the most recent Alquist-Priolo Fault Zone Map. Therefore, the proposed project would have no impact related to this threshold. No mitigation measures are required.

Threshold 4. 7 .l(ii): Would the project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving: Strong seismic ground shaking?
Less Than Significant Impact. According to the California Geological Survey, there are no active faults or Alquist-Priolo Fault Zones within the City. However, the Buildout Area is located in the highly seismic Southern California region within the influence of several fault systems. The degree of seismic ground shaking will depend on several factors including the fault location, distance from the Buildout Area, the soil conditions, the depth to groundwater, and the earthquake magnitude. As specified in Regulatory Compliance Measure GE0-1, new development within the Buildout Area would be subject to the seismic design criteria of the 2022 California Building Standards Code requirements that aim to prevent building collapse and reduce the impacts of seismic ground shaking. Adherence to these requirements would reduce injury and loss of life and building damage after an earthquake. Therefore, with the implementation of Regulatory Compliance Measure GE0-1, impacts related to seismic ground shaking would be less than significant. No mitigation measures are required.

Threshold 4.7.l(iii): Would the project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving: Seismic-related ground failure, including liquefaction?
Less Than Significant with Mitigation Incorporated. The entirety of the City is in a CGS Liquefaction Zone. 22 A CGS Liquefaction Zone is defined as an area where historical occurrence of liquefaction, or local geological, geotechnical and ground water conditions indicate a potential for permanent ground displacements such that mitigation as defined in PRC Section 2693(c) would be required. Soil liquefaction is a phenomenon in which cyclical stresses, produced by earthquake-induced ground motion, create excess pore pressures in relatively cohesionless and low plastic soils. According to the National Resource Conservation Service Web Soil Survey, the soil and the underlying geologic structure under the City include discontinuous human-transported material over mixed alluvium deposits that may become unstable during intense ground shaking. The Buildout Area is underlain by a thin mantle of fill materials and native alluvial soils. Based on the Geotechnical Investigation, site soils are considered to be susceptible to liquefaction settlement during an earthquake.

In addition, the Buildout Area was observed to have a relatively shallow groundwater level, which would increase the risk of liquefaction. According to the Orange County General Plan Safety Element 22 California Department of Conservation (DOC) California Geological Survey. 2025a. Earthquake Zones of Required Investigation. Website: https://maps.conservation.ca.gov/cgs/informationwarehouse/eqzapp/ (accessed January 21, 2025).

P:\A-E\CCP2201.0S LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.7 Geology and Soils.docx «03/10/26» 4.7-11 SPECIFIC PLAN 3.0 BUI LOO UT PROJECT

CYPRESS, CALIFORNIA

DRAFT ENVIRONMENTAL IMPACT REPORT
MARCH 2026
{2013), the City is underlain by a granular sand soil with high water content and is located within a liquefaction zone associated with the Newport-Inglewood Fault and the San Andreas Fault.

The Geotechnical Investigation prepared for the proposed project provides recommendations to reduce the potential for liquefaction at the Buildout Area. The Geotechnical Investigation concluded that total settlement at the existing ground surface due to liquefaction could be expected to range between 1.24 and 3.67 inches. Given the nature and size of the proposed development, the possibility of differential settlements under current conditions that could directly or indirectly cause potential substantial adverse effects, including risk of loss, injury, or death from liquefaction would be considered significant without stabilization techniques at the upper soils being implemented.

Therefore, future construction contractors would be required to comply with the recommendations in the Geotechnical Investigation, as detailed in Mitigation Measure GE0-1 provided below, to ensure impacts are reduced to a less than significant level. Mitigation Measure GE0-1 would require that the upper soils of the Buildout Area be stabilized with ground improvement techniques beneath any structure intended for human occupancy. The ground improvements may consist of Rammed Aggregate Piers, Vibrated Aggregate Piers, or similar techniques, and would be required to be designed by a qualified ground improvement contractor in an interactive process with the geotechnical engineer and structural engineer.

In addition to proposed ground improvements, any future development within the Buildout Area would be required to be supported on a mat, or mat-type foundation system. Conventional foundations may be utilized for support of lighter at-grade structures if ground improvements reduce the total potential liquefaction settlement potential to a threshold suitable for this type of foundation.

With the addition of the ground improvements in Mitigation Measure GE0-1, the potential for surface manifestations of liquefaction that would impact proposed structures in the Buildout Area is considered low, and impacts would be less than significant.

Threshold 4.7.l(iv): Would the project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving: Landslides? No Impact. According to the City's General Plan Safety Element, landslides have not been recorded within the City boundaries and are not anticipated based on the lack of any significant topographic features. Further, according to the CGS's Landslide Inventory, there are no recorded landslides within the vicinity of the Buildout Area. 23 Both the Buildout Area and surrounding properties are flat with no unusual geographic features. Therefore, neither the Buildout Area nor the surrounding area have the potential for impacts related to landslides. No mitigation is required.

Threshold 4.7.2: Would the project result in substantial soil erosion or the loss of topsoil? Less Than Significant Impact. Construction in the Buildout Area would result in soil erosion and siltation compared to existing conditions. Construction activities would occur on a project-by-project 23 California Department of Conservation (DOC) California Geological Survey. 2025b. Landslide Inventory.

Website: https://maps.conservation.ca.gov/cgs/lsi/app/ (accessed January 21, 2025).

4.7-12 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.7 Geology and Soils.docx «03/10/26»

DRAFT EN VI RONMENTAL IMPACT REPO RT
M ARCH 2026
SPECIFIC PLAN 3.0 BU ILDOUT PROJECT

CYPRESS, CALIFO RNIA
basis, but would likely include site clearing, excavations, grading, and filling. The increased erosion potential could result in short-term water quality impacts as discussed in Section 4.10, Hydrology and Water Quality, of this Draft EIR. Implementation of the proposed project would increase impervious surfaces in the Buildout Area by about 10 percent. This increase would result in higher volumes and velocities of stormwater runoff, which could lead to soil erosion or loss of topsoil.

Any projects in the Buildout Area that would disturb more than one acre of soil would be required to implement Regulatory Compliance Measure HYD-1, provided in Section 4.10, which requires preparation of a Stormwater Pollution Prevention Plan {SWPPP). The SWPPP details Erosion Control and Sediment Control Best Management Practices {BMPs) that would be implemented during project construction to minimize erosion and retain sediment on site. If construction of future development associated with the proposed project would disturb less than one acre of soil, those projects would be required to comply with Section 4.106 of the California Green Building Standards Code {CALGreen Code). Section 4.106 of the CALGreen Code requires implementation of BMPs to prevent flooding and erosion and to retain sediment on site. With incorporation of construction BMPs as required by Regulatory Compliance Measure HYD-1, impacts related to erosion during construction would be less than significant, and no mitigation is required.

Implementation of the proposed project would increase impervious surfaces in the Buildout Area by about 10 percent. This increase would result in higher volumes and velocities of stormwater runoff, which could lead to soil erosion or loss of topsoil. Increases in stormwater runoff velocity can lead to downstream erosion in receiving waters. However, future development associated with the proposed project would be required to comply with Regulatory Compliance Measure HYD-3, also provided in Section 4.10, which mandates that stormwater runoff be captured in detention basins and/or proprietary flow-based biofiltration systems. These features would detain, filter, and treat runoff prior to discharge into the surrounding storm drain system, thereby substantially reducing the potential for erosion and protecting downstream water quality.

Additionally, according to the Preliminary Water Quality Management Plan (Appendix H-2) only one drainage management area in the Buildout Area drains through the Walker Street Storm Drain to a portion of the Balsa Chica Channel that is not concrete lined and more susceptible to erosion. As required by Regulatory Compliance Measure HYD-3, future development associated with the proposed project will include measures to reduce changes to the natural flow of water to reduce erosion. For these reasons, operational impacts related to substantial on-site, off-site, or downstream erosion or siltation would be less than significant, and no mitigation is required.

Threshold 4.7.3: Would the project be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on-site or off-site landslides, lateral spreading, subsidence, liquefaction, or collapse?
Less Than Significant with Mitigation Incorporated. Landslides and other forms of mass wasting, including mud flows, debris flows, and soil slips, occur as soil moves downslope under the influence of gravity. Landslides are frequently triggered by intense rainfall or seismic shaking. The Buildout Area is relatively flat. As such, landslides and other forms of slope instability do not represent a P:\A-E\CCP2201.0S LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.7 Geology and Soils.docx «03/10/26» 4.7-13 SPECIFIC PLAN 3.0 BUI LOO UT PROJECT

CYPRESS, CALIFORNIA

DRAFT ENVIRONMENTAL IMPACT REPORT
MARCH 2026
significant hazard to the Buildout Area or the surrounding area. In addition, as discussed in Response 4.7.l(iv), the Buildout Area is not within an area susceptible to landslides.

Based on the preliminary grading plans, approximately 95,370 cubic yards of material would need to be imported to the Buildout Area to facilitate proposed project implementation. Construction of future projects may also require trenching to accommodate the installation of utilities. All excavation and grading required for construction must be performed in accordance with City of Cypress Municipal Code Chapter 10 and State Building Codes, and the State Division of Occupational Safety and Health requirements.

Subsidence, the sinking of the land surface due to oil, gas, and water production, causes loss of pore pressure as the weight of the overburden compacts the underlying sediments. No subsidence associated with fluid withdrawal is known to have occurred on or in the vicinity of the Buildout Area.

According to the Geotechnical Investigation, groundwater within the Buildout Area has a historic depth of less than 10 feet below ground surface, ranging from approximately 5 to 12.5 feet below ground surface. 24 As shallow groundwater is present, it is likely that groundwater dewatering would be required during excavation activities. However, any groundwater dewatering would need to implement Regulatory Compliance Measure HYD-2, also provided in Section 4.10, which outlines requirements of the Groundwater Dewatering Permit, as specified in Section 4.10. During operation of the proposed project, no groundwater dewatering would occur. Therefore, subsidence associated with dewatering is not anticipated to occur during construction or operation of the proposed project.

As discussed in Response 4.7.l(iii), structures built on or above potentially liquefiable soils may experience bearing capacity failures due to the temporary loss of foundation support or vertical settlements (both total and differential) and/or undergo lateral spreading. Loss of bearing and ground settlement are of concern within the Buildout Area. This would be a potentially significant impact. However, as part of the proposed project, the construction contractor would comply with all recommendations in the Geotechnical Investigation and include ground improvement techniques, stable foundations would be required for all future projects (Mitigation Measure GE0-1), and all development would be required to comply with the CBC (Regulatory Compliance Measure GE0-1).

Therefore, impacts would be less than significant with mitigation incorporated.

Threshold 4.7.4: Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating direct or indirect substantial risks to life or property?
No Impact. According to the City's General Plan Program EIR, Geologic and Seismic Hazards Chapter, 25 all soil types within the City are suitable for urban development. Of the known soil types 24 25
California Department of Conservation (DOC) California Geological Survey (CGS). 2006. Seismic Hazard Zone Report of the Los Alamitos Quadrangle, Plate 1.2.

City of Cypress. 2001. Cypress General Plan Environmental Impact Report, Geologic and Seismic Hazards, pp. 4.6-13. Website: https://www.cypressca.org/home/showpublisheddocument/678/636123124960830 000 (accessed January 21, 2025).

4.7-14 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.7 Geology and Soils.docx «03/10/26»

DRAFT ENVIRONMENTAL IMPACT REPORT
MARCH 2026
SPECIFIC PLAN 3.0 BUILDOUT PROJECT

CYPRESS, CALIFORNIA
within the City, none are expansive. Therefore, there is low potential for risks to life or property as a result of the future development within the Buildout Area being located on expansive soil, and the proposed project would have no impact related to expansive soils. No mitigation is required.

Threshold 4.7.5: Have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater?
No Impact. Future development within the Buildout Area would be served by the City and the Orange County Sanitation District. The proposed project includes the installation of wastewater infrastructure identified in the Specific Plan to serve the future development allowed under the Specific Plan, including two new sewer connections to existing main sewer lines. As detailed in Chapter 3.0, Project Description, future development within the Buildout Area would not include the development of or use of any septic tanks or alternative wastewater disposal systems, as all wastewater generation would be served by the City's existing sewer system. Therefore, the proposed project would not have any impacts related to soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems. No mitigation measures are required.

Threshold 4.7.6: Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
Less Than Significant with Mitigation Incorporated. According to the City of Cypress General Plan EIR, there are no known paleontological resources in the City. A search of the paleontology collection records for the locality and specimen data at the NHMLA was requested for the proposed project and results were returned on June 1, 2025. The record search did not identify any existing fossil localities within the Buildout Area. However, the search did return fossil localities, present in the same type of sedimentary deposits that underlay26 the Buildout Area, located within a 10-mile radius of the Buildout Area.

As detailed in the Geotechnical Investigation, fill soils are present in the upper 3 to 5 feet of the Buildout Area, and are mainly composed of silty sand and sandy silt, yellowish. Underlying the fill are native soils at a depth of approximately 10 feet, consisting of interlayered sandy to silty clay, sandy to clayey silt, silty to clayey sand, and sand. Based on the geologic setting, the native soils are Quaternary alluvial deposits within the Los Angeles Basin. Such deposits are often paleontologically sensitive, as they can contain vertebrate fossils (e.g., mammoths, ground sloths, camelids) at depth.

Typically, the upper 5 feet of shallow fill and disturbed soils are low sensitivity, but deeper undisturbed alluvium is considered to have high sensitivity under SVP guidelines. 27 Therefore, construction activities associated with the proposed project that have the potential to disturb native alluvium at a depth below 10 feet would have the potential to have a potentially 26 Geotechnologies, Inc. 2024. Environmental Impact Report Soils and Geology Issues, Proposed Mixed-Use Development, 4961 Kate/la Avenue and 5100 Cerritos Avenue, Cypress, California. May 2. (Appendix F) Society of Vertebrate Paleontology (SVP). 2010. Standard Procedures for the Assessment and Mitigation of 27 Adverse Impacts to Paleontological Resources. Bethesda, MD.

P:\A-E\CCP2201.0S LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.7 Geology and Soils.docx «03/10/26» 4.7-15 SPECIFIC PLAN 3.0 BUI LOO UT PROJECT

CYPRESS, CALIFORNIA

DRAFT EN VIRONMENTAL IMPACT REPORT
MARCH 2026
significant impact on paleontological resources without implementation of mitigation measures.

Therefore, Mitigation Measures GE0-2 and GE0-3 shall be required. With implementation of these mitigation measures, which make provisions for unknown paleontological resources, discovery stop work procedures, and worker training procedures, project impacts would be mitigated to a less than significant level.

4.7.7 Level of Significance Prior to Mitigation
The potential for surface fault rupture, erosion, subsidence, landslides, lateral spreading, and expansive soil is less than significant, and no mitigation is required. The potential impacts related to seismic shaking and liquefaction would be potentially significant prior to mitigation. The proposed project would also have potentially significant impacts on paleontological resources prior to the implementation of mitigation.

4.7.8 Regulatory Compliance Measures and Mitigation Measures

4.7.8.1 Regulatory Compliance Measures
The following regulatory compliance measure is a requirement of the CBC that is applicable to the proposed project and is considered in the analysis of potential impacts related to geology and soils.

The City considers this requirement to be mandatory; therefore, it is not a mitigation measure.

Regulatory Compliance Measure GE0-1 Compliance with Seismic and Standards in the Building Code. Prior to issuance of any building permit within
the Buildout Area, the City of Cypress (City) Engineer, Building Official, or their designee, and a future project applicant's soils engineer shall review the building plans to verify that the structural design conforms to the
requirements of the City of Cypress' latest adopted
edition of the California Building Standards Code.

Structures and walls shall be designed in accordance
with applicable sections of the City's Building Code.

4.7.8.2 Mitigation Measures
In addition to the regulatory requirements and regulatory compliance measure described above, the following mitigation measures would reduce potential impacts related to seismic ground shaking, liquefaction, and paleontological resources to a less than significant level.

Mitigation Measure GE0-1

4.7-16
Implementation of Geotechnical Investigation Recommendations.

Future development projects within the Buildout Area shall implement the recommendations of the Geotechnical Investigation prepared for the proposed project, to the satisfaction of the City of Cypress' (City) Building Official, including, but not limited to:

Ground Improvement Techniques. Ground improvement
techniques shall be implemented in the Buildout Area beneath any structure intended for human occupancy. Ground improvements P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.7 Geology and Soils.docx «03/10/26»

DRAFT ENVIRONMENTAL IMPACT REPORT
MARCH 2026
Mitigation Measure GE0-2
SPECIFIC PLAN 3.0 BUILDOUT PROJECT

CYPRESS, CALIFORNIA
may consist of rammed aggregate piers, vibrated aggregate piers, or similar techniques. The ground improvements must be designed by a qualified ground improvement contractor through coordination with a geotechnical engineer and/or structural engineer to ensure liquefaction in the upper soils.

Building Foundation Techniques. Subsequent to the installation of any proposed ground improvements, proposed structures, mat or mat-type foundation systems will be used. Conventional
foundations may be utilized for support of the lighter at-grade structure if the ground improvements reduce the total and differential settlement to a threshold confirmed by the geotechnical engineer, the structural engineer, and the construction contractor.

Additional site testing and final design evaluation(s) shall be conducted by a geotechnical consultant to refine and/or enhance these requirements during buildout of the project on an as-needed basis. A future project applicant(s) shall require the geotechnical consultant to assess whether the recommendations in the Geotechnical Investigation need to be modified or refined to address any changes in the project features prior to start of grading.

If the geotechnical consultant identifies modifications or refinements to the recommendations, the future project
applicant(s) shall make modifications to the final project design and specifications. Examples of additional measures could include: a moisture or vapor retarding system below foundations, additional ground stabilization techniques like cement treatment or aggregate, or removal and replacement of existing soil to eliminate any unsuitable materials or undocumented fill. Design, grading, and construction shall be performed in accordance with applicable requirements in the Municipal Code, the California Building Code, local grading regulations, and any additional measures
recommended by the geotechnical consultant in the subsequent geotechnical evaluation(s).

Procedures for Unexpected Paleontological Resources Discoveries.

If paleontological resources are discovered during ground-disturbing activities associated with the proposed project, construction personnel shall immediately halt work within 50 feet of the discovery, and a future project applicant/developer or construction supervisor shall contact a qualified paleontologist to assess the discovery for scientific importance. A qualified paleontologist is defined as a person with an M.S. or Ph.D. in geology or paleontology and who meets the standards set forth by the Society of Vertebrate Paleontology. The paleontologist shall make recommendations P:\A-E\CCP2201.0S LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.7 Geology and Soils.docx «03/10/26» 4.7-17 SPECIFIC PLAN 3.0 BUI LOO UT PROJECT

CYPRESS, CALIFORNIA

DRAFT EN VIRONMENTAL IMPACT REPORT
MARCH 2026
Mitigation Measure GE0-3
regarding the collection, treatment, and disposition of the discovery. Scientifically important resources shall be prepared to the point of identification, identified to the lowest taxonomic level possible, cataloged, and curated into the permanent collections of a museum repository. If paleontological resources are discovered, regardless of their scientific importance, paleontological monitoring shall be required for subsequent ground-disturbing activities at a frequency, depth, and/or interval determined by the paleontologist.

Paleontological monitoring shall be conducted by a qualified paleontological monitor as set forth in the Society of Vertebrate Paleontology standards. At the conclusion of monitoring, a final monitoring report shall be prepared by the paleontologist to document the results of monitoring and project compliance with all regulations and project requirements. If scientifically important paleontological resources are recovered, this report shall also document those paleontological resources with a catalog, descriptions, and photographs as determined appropriate by the paleontologist. The final monitoring report shall be submitted to the City of Cypress Director of Community Development Department or designee for review and approval. A copy of this final report shall also accompany the fossil material to the museum repository.

Worker Sensitivity Training: Prior to issuance of grading permits, applicants for projects that would include ground-disturbing activities below 10 feet in undisturbed native sediments ranked as having a moderate or high paleontological sensitivity shall be required to retain a qualified paleontologist meeting the requirements set forth by the Society of Vertebrate Paleontology.

Prior to and during initial ground-disturbing activities, the qualified paleontologist (or their designee) shall provide worker environmental awareness training to construction personnel.

Training shall include recognition of potential fossil materials, appropriate worker response protocols, and contact information for the paleontologist.

4.7.9 Level of Significance after Mitigation
With implementation of Regulatory Compliance Measure GE0-1 and Mitigation Measures GE0-1 through GE0-3, all identified potentially significant impacts related to geotechnical hazards and paleontological resources would be reduced below a level of significance.

4.7.10 Cumulative Impacts
As defined in Section 15130 of the State CEQA Guidelines, cumulative impacts are the incremental effects of an individual project when viewed in connection with the effects of past, current, and probable future projects within the cumulative impact area for geology and soils. Typically, geology

4.7-18 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.7 Geology and Soils.docx «03/10/26»

DRAFT ENVIRONMENTAL IMPACT REPORT
MARCH 2026
SPECIFIC PLAN 3.0 BUILDOUT PROJECT

CYPRESS, CALIFORNIA
and soils impacts are specific to a particular project area and there is little, if any, cumulative relationship between the development of a proposed project and development within a larger geographic area. Therefore, the cumulative impact area for geology and soils is the Buildout Area.

Moreover, while seismic conditions are regional in nature, seismic impacts on a given project area are site-specific. For example, development within the Buildout Area would not alter geologic events or soil features/characteristics (such as ground shaking, seismic intensity, or soil expansion or compression). Therefore, the proposed project would not affect the level of intensity at which a seismic event on an adjacent site is experienced.

While seismic events may affect a broad region, development of the cumulative projects would not increase the intensity, frequency, or duration of seismic events or the properties of off-site geology or soils. The CBC (adopted by reference in Chapter 15.08 [Construction Codes] of the City's Municipal Code) contains provisions to safeguard against major structural failures or loss of life caused by earthquakes, liquefaction, ground shaking, landslides, and other seismically induced hazards, as codified in Regulatory Compliance Measure GE0-1. In addition, the Geotechnical Investigation recommendations would reduce potential impacts related to seismic ground shaking, liquefaction, compressible/collapsible soils, and paleontological resources as required by Mitigation Measures GE0-1 and GE0-3.

Related projects would also require environmental review pursuant to CEQA including, as necessary, site-specific investigation of potential geologic, seismic, or soil-related impacts. It is reasonable to expect that such site-specific investigation would appropriately identify the siting, design, and construction criteria established in the CBC and/or by the City to address site-specific geologic/soil conditions affecting future development, and that the City would condition future development to fully satisfy said criteria. Therefore, any potential cumulative geologic, seismic, or soil-related impacts would be rendered to a less than significant level, and the project's contribution to such impacts would not be cumulatively considerable.

It is not anticipated that development of the related projects would have any geotechnical impact on the Buildout Area or the buildings that would be constructed as part of the proposed project, nor would the project have geotechnical impacts on any of the eight related projects identified in Table 4.A: Summary of Related Projects, in Chapter 4.0, Existing Setting. Therefore, the proposed project and the applicable related projects would not have the potential to cause cumulatively significant adverse impacts related to geology and soils.

Potential impacts of the proposed project to unknown paleontological resources and unique geologic features, when combined with the impacts of past, present, and reasonably foreseeable probable future projects in the City, could contribute to a cumulatively significant impact due to the overall loss of paleontological remains unique to the region. Some of the related projects identified in Table 4.A have undergone environmental review pursuant to CEQA, which included an analysis of potential impacts relating to paleontological resources. According to the EIRs prepared for the Shea Properties Mixed Use Development Project (Related Project 1) and Melia Homes -Citrus Square Project (Related Project 2) and the Initial Study/Mitigated Negative Declaration (IS/MND) prepared for the Goodman Commerce Center Project (Related Project 3), impacts related to paleontological resources would be less than significant with implementation of mitigation measures, including procedures for unexpected paleontological resources discoveries. The EIR prepared for the Los P:\A-E\CCP2201.0S LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.7 Geology and Soils.docx «03/10/26» 4.7-19 SPECIFIC PLAN 3.0 BUI LOO UT PROJECT

CYPRESS, CALIFORNIA

DRAFT ENVIRONMENTAL IMPACT REPORT
MARCH 2026
Alamitos Medical Center Project (Related Project 7) determined that impacts related to paleontological resources would not occur with implementation of the Los Alamitos Medical Center Project and all three EIRs determined that cumulative impacts related to paleontological resources would be less than significant. The Sycamore Creek Charter School Project (Related Project 6) and 4562 Katella Avenue Project (Related Project 8) were determined to be exempt from CEQA review under Section 15332 of the State CEQA Guidelines (for infill development) and Notices of Exemption {NOEs) were prepared. In order for a project to be exempt under Section 15332 of the State CEQA Guidelines, the project must not result in significant effects due to unusual circumstances, which includes impacts to paleontological resources. As such, development of the related projects in combination with the proposed project would not result in significant impacts relating to paleontological resources. The LTP Modern Machine Project (Related Project 5) and 8561 Belmont Street Project (Related Project 4) would also be required to undergo environmental review pursuant to CEQA, which would include an analysis of potential impacts relating to paleontological resources and the identification of any mitigation measures to reduce potential impacts, if necessary. In addition, with implementation of Mitigation Measures GE0-2 and GE0-3, implementation of the proposed project would not result in significant impacts on paleontological resources. If there were any potential for significant impacts to paleontological resources or unique geologic features, an investigation would be required to determine the nature and extent of the resources and identify appropriate mitigation measures. Since all projects within the cumulative study area would be required to implement appropriate mitigation measures and adhere to applicable regulations, implementation of the proposed project, when evaluated in combination with the development of projects listed in Table 4.A: Summary of Related Projects, would not contribute to a cumulatively considerable impact related to paleontological resources. Therefore, there would be no cumulatively significant impact related to paleontological resources.

4.7-20 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.7 Geology and Soils.docx «03/10/26»

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026
S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A
P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.8 Greenhouse Gas Emissions_final.docx (03/11/26) 4.8-1

4.8 GREENHOUSE GAS EMISSIONS
This section evaluates the potential impacts related to greenhouse gas (GHG) emissions from implementation of the Specific Plan 3.0 Buildout Project (proposed project) using methodologies and assumptions recommended in the air quality impact assessment guidelines of the South Coast Air Quality Management District (SCAQMD). This section summarizes existing GHG emissions and discusses global climate change, its causes, and the contribution of human activities. This section also estimates the likely GHG emissions that would result from construction and operational activities associated with build out of the proposed project, including vehicular traffic, energy consumption and other emission sources.

4.8.1 Scoping Process
The City of Cypress (City) received six comment letters during the public review period of the Notice of Preparation (NOP). For a copy of the NOP comment letters, refer to Appendix A of this Draft Environmental Impact Report (Draft EIR). One of the comment letters, from the Southern California Association of Governments (SCAG), included comments related to GHG emissions.

SCAG recommended that this Draft EIR evaluate the proposed project’s consistency with the Connect SoCal 2024 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) (Connect SoCal 2024), which outlines goals to reduce greenhouse gas emissions, improve regional air quality, and support an integrated multimodal transportation network. Although SCAG does not implement or approve projects, it advised the City to consult the Connect SoCal 2024 Program Environmental Impact Report (PEIR) for guidance on identifying appropriate CEQA mitigation strategies. These may include measures to minimize emissions, reduce vehicle miles traveled, and enhance transportation efficiency. SCAG also highlighted that achieving regional sustainability goals depends on local agency action and encourages the use of a side-by-side consistency analysis comparing project features with Connect SoCal 2024 goals. These comments are addressed in this section.

4.8.2 Methodology
This Draft EIR uses the State-recommended approach of evaluating whether the project maintains consistency with Statewide climate goals by incorporating and enabling key planning-level GHGreducing attributes. The significance of the project’s GHG emissions impacts is based on the project’s compliance with Statewide GHG reduction regulations and requirements, including the 2022 Scoping Plan and Connect SoCal 2024.

A lead agency may also use modeling to estimate GHGs from a project.1This allows the lead agency to quantify GHGs resulting from a project. Here, any quantification is for informational purposes, and is not used for a comparative analysis or as a threshold of significance. To that end, this section includes quantified GHG emissions from the California Emissions Estimator Model (CalEEMod) version 2022.1 to for both construction and operation activities associated with the proposed project.

CalEEMod output is contained in Appendix B.
1 State CEQA Guidelines Section 15064.4.

S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026

4.8 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.8 Greenhouse Gas Emissions_final.docx (03/11/26) -2 This estimate further serves to inform the public and decisionmakers of the extent to which the proposed project may increase or reduce GHGs compared to existing conditions. The primary purpose of quantifying the proposed project’s GHG emissions is to satisfy State CEQA Guidelines Section 15064.4(a), which calls for a good-faith effort to describe and calculate emissions. The estimated emissions inventory is also used to estimate GHG reductions associated with the proposed project.

However, the determination of whether or not the proposed project would have a significant impact with regard to GHG emissions is not based on the numeric or quantified GHG emissions resulting from the proposed project.

4.8.3 Existing Environmental Setting
The following describes existing GHG emissions in Cypress, beginning with typical GHG sources, impacts of global climate change, the regulatory framework surrounding these issues, and current emission levels.

4.8.3.1 Background
The following section provides background information on GHGs and global climate change.

Greenhouse Gases.Global climate change is the observed increase in the average temperature of the Earth’s atmosphere and oceans in recent decades. The Earth’s average near-surface atmospheric temperature rose 0.6 ± 0.2 degrees Celsius (°C) or 1.1 ± 0.4 degrees Fahrenheit (°F) in the 20th century.

The prevailing scientific opinion on climate change is that most of the warming observed over the last 50 years is attributable to human activities. The increased amounts of carbon dioxide and other GHGs are the primary causes of the human-induced component of warming. GHGs are released by the burning of fossil fuels, land clearing, agriculture, and other activities, and lead to an increase in the greenhouse effect.2
GHGs are present in the atmosphere naturally, are released by natural sources, or are formed from secondary reactions taking place in the atmosphere. The gases that are widely seen as the principal contributors to human-induced global climate change are the following:
• Carbon dioxide (CO2)
• Methane (CH4)
• Nitrous oxide (N2O)
• Hydrofluorocarbons (HFCs)
• Perfluorocarbons (PFCs)
• Sulfur hexafluoride (SF6)
2 The temperature on Earth is regulated by a system commonly known as the “greenhouse effect.” Just as the glass in a greenhouse allows heat from sunlight in and reduces the heat escaping, GHGs such as carbon dioxide, methane, and nitrous oxide in the atmosphere keep the Earth at a relatively even temperature.

Without the greenhouse effect, the Earth would be a frozen globe; thus, although an excess of GHGs results in global warming, the naturally occurring greenhouse effect is necessary to keep the planet at a comfortable temperature.

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026
S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A
P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.8 Greenhouse Gas Emissions_final.docx (03/11/26) 4.8-3 Over the last 200 years, humans have caused substantial quantities of GHGs to be released into the atmosphere. These extra emissions are increasing GHG concentrations in the atmosphere and enhancing the natural greenhouse effect, which is believed to be causing global warming. While manmade GHGs include naturally occurring GHGs such as CO2, CH4, and N2O, some gases, such as HFCs, PFCs, and SF6, are completely new to the atmosphere.

Certain gases, such as water vapor, are short-lived in the atmosphere. Others remain in the atmosphere for significant periods of time, contributing to climate change in the long term. Water vapor is excluded from the list of GHGs above because it is short-lived in the atmosphere and its atmospheric concentrations are largely determined by natural processes, such as oceanic evaporation. For the purposes of this analysis, the term “GHGs” will refer collectively only to the six gases listed above, consistent with the GHGs that the California Air Resources Board (CARB) is responsible to monitor and regulate.

These gases vary considerably in terms of Global Warming Potential (GWP), which is a concept developed to compare the ability of each GHG to trap heat in the atmosphere relative to another gas.

The global warming potential is based on several factors, including the relative effectiveness of a gas to absorb infrared radiation and length of time that the gas remains in the atmosphere (“atmospheric lifetime”). The GWP of each gas is measured relative to carbon dioxide, the most abundant GHG; the definition of GWP for a particular GHG is the ratio of heat trapped by one unit mass of the GHG to the ratio of heat trapped by one unit mass of CO2 over a specified time period. GHG emissions are typically measured in terms of pounds or tons of “CO2 equivalents” (CO2e). Table 4.8.A: Global Warming Potential of Greenhouse Gases shows the GWP for each type of GHG. For example, sulfur hexafluoride is 23,900 times more potent at contributing to global warming than carbon dioxide.

Table 4.8.A: Global Warming Potential of Greenhouse Gases Gas Atmospheric Lifetime (Years) Global Warming Potential (100-year Time Horizon)
Carbon Dioxide (CO2) 50–200 1
Methane (CH4) 12 21
Nitrous Oxide (N2O) 114 310
HFC-32 270 11,700
HFC-134a 14 140
HFC-152a 1.4 140
PFC: Tetrafluoromethane (CF4) 50,000 6,500
PFC: Hexafluoromethane (C2F6) 10,000 9,200
Sulfur Hexafluoride (SF6) 3,200 23,900
Source: Second Update to the Climate Change Scoping Plan: Building on the Framework (CARB 2017b). Website:
www.arb.ca.gov/our-work/programs/ab-32-climate-change-scoping-plan/2017-scoping-plan-documents (accessed October 2025).

CARB = California Air Resources Board
The following summarizes the characteristics of the six GHGs and black carbon. Black carbon, a solid particle that is classified as a potent short-lived climate pollutant, also contributes to climate change and is therefore discussed below.

S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026

4.8 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.8 Greenhouse Gas Emissions_final.docx (03/11/26) -4 Carbon Dioxide. In the atmosphere, carbon generally exists in its oxidized form, as carbon dioxide (CO2). Natural sources of CO2 include the respiration (breathing) of humans, animals, and plants, volcanic out gassing, decomposition of organic matter and evaporation from the oceans. Human caused sources of CO2 include the combustion of fossil fuels and wood, waste incineration, mineral production, and deforestation. Natural sources release approximately 150 billion tons of CO2 each year, far outweighing the 7 billion tons of manmade emissions of CO2 each year. Nevertheless, natural removal processes, such as photosynthesis by land- and ocean-dwelling plant species, cannot keep pace with this extra input of manmade CO2, and consequently, the gas is building up in the atmosphere.

In 2022, total annual CO2 accounted for approximately 81.0 percent of California’s overall GHG emissions.3Transportation is the single largest source of CO2 in California, which is primarily comprised of on-road travel. Electricity production, industrial and residential sources also make important contributions to CO2 emissions in California.

Methane. Methane (CH4) is produced when organic matter decomposes in environments lacking sufficient oxygen. Natural sources include wetlands, termites, and oceans. Decomposition occurring in landfills accounts for the majority of human-generated CH4 emissions in California and in the United States as a whole. Agricultural processes such as intestinal fermentation, manure management, and rice cultivation are also significant sources of CH4 in California. Total annual emissions of CH4 accounted for approximately 9.8 percent of GHG emissions in California in 2022. 4 Nitrous Oxide. Nitrous oxide (N2O) is produced naturally by a wide variety of biological sources, particularly microbial action in soils and water. Tropical soils and oceans account for the majority of natural source emissions. Nitrous oxide is a product of the reaction that occurs between nitrogen and oxygen during fuel combustion. Both mobile and stationary combustion emit N2O, and the quantity emitted varies according to the type of fuel, technology, and pollution control device used, as well as maintenance and operating practices. Agricultural soil management and fossil fuel combustion are the primary sources of human-generated N2O emissions in California. Nitrous oxide emissions accounted for approximately 3.4 percent of GHG emissions in California in 2022. 5 Hydrofluorocarbons, Perfluorocarbons, and Sulfur Hexafluoride. Hydrofluorocarbons (HFCs) are primarily used as substitutes for ozone-depleting substances regulated under the Montreal Protocol.6 Perfluorocarbons (PFCs) and sulfur hexafluoride (SF6) are emitted from various industrial processes, including aluminum smelting, semiconductor manufacturing, electric power transmission and distribution, and magnesium casting. There is no aluminum or magnesium production in California; 3 California Air Resources Board (CARB). 2024. Assembly Bill 32 Greenhouse Gas Emissions Inventory for 2000-2022 – by Gas.
4 Ibid.
5 Ibid.
6 The Montreal Protocol is an international treaty that was approved on January 1, 1989, and was designated to protect the ozone layer by phasing out the production of several groups of halogenated hydrocarbons believed to be responsible for ozone depletion.

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026
S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A
P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.8 Greenhouse Gas Emissions_final.docx (03/11/26) 4.8-5 however, the rapid growth in the semiconductor industry leads to greater use of PFCs. HFCs, PFCs, and SF6 accounted for about 5.7 percent of GHG emissions in California in 2022.7 Black Carbon. Black carbon is the most strongly light-absorbing component of PM, formed by burning fossil fuels such as coal, diesel, and biomass. Black carbon is emitted directly into the atmosphere in the form of PM2.5 and is the most effective form of PM, by mass, at absorbing solar energy. Per unit of mass in the atmosphere, black carbon can absorb one million times more energy than CO2. 8 Black
carbon contributes to climate change both directly, such as absorbing sunlight, and indirectly, such as affecting cloud formation. However, because black carbon is short-lived in the atmosphere, it can be difficult to quantify its effect on global warming.

Most U.S. emissions of black carbon come from mobile sources (52 percent), particularly from dieselfueled vehicles. The other major source of black carbon is open biomass burning, including wildfires, although residential heating and industry also contribute. CARB estimates that the annual black carbon emissions in California will be reduced approximately 50 percent below 2013 levels by 2030.9 Emissions Inventories. An emissions inventory that identifies and quantifies the primary humangenerated sources and sinks of GHGs is a well-recognized and useful tool for addressing climate change. This section summarizes the latest information on global, United States, and California GHG emission inventories.

Global Emissions. Worldwide emissions of GHGs in 2021, the latest inventory year available, totaled

19.2 billion metric tons (MT) of CO2e. Global estimates are based on country inventories developed as part of the programs of the United Nations Framework Convention on Climate Change.10 United States Emissions. In 2022, the year for which the most recent data are available, the United States emitted about 6,343.2 million metric tons of CO2e (MMT CO2e). Overall, emissions in 2022 increased by 0.2 percent compared to the 2021 total GHG emissions. This increase in total GHG emissions was driven by fossil fuel combustion due primarily to economic activity rebounding after the height of the COVID-19 pandemic. However, GHG emissions in 2022 were 16.7 percent below those of 2005 levels. Of the five major sectors—residential and commercial, agricultural, industry, transportation, and electricity generation—transportation accounted for the highest amount of GHG 7 California Air Resources Board (CARB). 2024. Assembly Bill 32 Greenhouse Gas Emissions Inventory for 2000-2022 – by Gas.
8 United States Environmental Protection Agency (USEPA). 2015. Black Carbon, Basic Information. February 14, 2017. Website: 19january2017snapshot.epa.gov/www3/airquality/blackcarbon/basic.html (accessed October 2025).
9 California Air Resources Board (CARB). 2017c. Short-Lived Climate Pollutant Reduction Strategy. March.

Website: https://ww2.arb.ca.gov/sites/default/files/2020-07/final_SLCP_strategy.pdf (accessed October 2025).
10 United Nations Framework Convention on Climate Change (UNFCCC). 2023. GHG Data from UNFCCC.

Website: unfccc.int/process-and-meetings/transparency-and-reporting/greenhouse-gas-data/ghg-dataunfccc/ghg-data-from-unfccc (accessed October 2025).

S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026

4.8 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.8 Greenhouse Gas Emissions_final.docx (03/11/26) -6 emissions in 2022 (28 percent), with electricity generation second at 25 percent and emissions from industry third at 23 percent.11
State of California Emissions. The State emitted approximately 371.1 MMT CO2e emissions in 2022,

9.3 MMT CO2e lower than 2021 levels.
12 CARB estimates that transportation was the source of approximately 39 percent of the State’s GHG emissions in 2022. The next largest sources included industrial sources at approximately 23 percent and electricity generation at 16 percent. The remaining sources of GHG emissions were residential activities at 8 percent, agriculture at 8 percent, and commercial activities at 6 percent.13

4.8.4 Regulatory Setting
The following section describes the federal, State, regional, and local regulatory framework applicable to analyzing potential impacts related to GHG emissions from development of the proposed project.

4.8.4.1 Federal Regulations
Federal regulations applicable to GHG emissions are described below.

Federal Clean Air Act. The United States has historically had a voluntary approach to reducing GHG emissions. However, on April 2, 2007, the United States Supreme Court ruled that the USEPA has the authority to regulate CO2 emissions under the Federal Clean Air Act. While there currently are no adopted federal regulations for the control or reduction of GHG emissions, the USEPA commenced several actions in 2009 to implement a regulatory approach to global climate change.

This includes the 2009 USEPA final rule for mandatory reporting of GHGs from large GHG emission sources in the United States. Additionally, the USEPA Administrator signed an endangerment finding action in 2009 under the Federal Clean Air Act, finding that six GHGs (CO2, CH4, N2O, HFCs, PFCs, and SF6) constitute a threat to public health and welfare, and that the combined emissions from motor vehicles cause and contribute to global climate change, leading to national GHG emission standards.

Energy Independence and Security Act. Signed on December 19, 2007 by President Bush, the Energy Independence and Security Act of 2007 (EISA) aims to: move the United States toward greater energy independence and security; increase the production of clean renewable fuels; protect consumers; increase the efficiency of products, buildings, and vehicles; promote research on and deploy greenhouse gas capture and storage options; improve the energy performance of the Federal Government; and increase U.S. energy security, develop renewable fuel production, and improve vehicle fuel economy. EISA reinforces the energy reduction goals for federal agencies put forth in Executive Order (EO) 13423, as well as introduces more aggressive requirements. The three key 11 United States Environmental Protection Agency (USEPA). 2024. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2022. Website: https://www.epa.gov/ghgemissions/inventory-us-greenhouse-gasemissions-and-sinks-1990-2022 (accessed October 2025). 12 California Air Resources Board (CARB). 2024. California Greenhouse Gas Emissions for 2000 to 2022, Trends of Emissions and Other Indicators Report. Website: https://ww2.arb.ca.gov/sites/default/files/2024-09/nc2000_2022_ghg_inventory_trends.pdf (accessed October 2025). 13 Ibid.

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026
S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A
P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.8 Greenhouse Gas Emissions_final.docx (03/11/26) 4.8-7 provisions enacted are the Corporate Average Fuel Economy (CAFE) Standards, the Renewable Fuel Standard, and the appliance/lighting efficiency standards.

Corporate Average Fuel Economy Standards. On March 31, 2022, the National Highway Traffic Safety Administration (NHTSA) finalized the CAFE standards for Model Years 2024–2026 Passenger Cars and Light Trucks. The amended CAFE standards would require an industry wide fleet average of approximately 49 miles per gallon for passenger cars and light trucks in model year 2026, by increasing fuel efficiency by 8 percent annually for model years 2024–2025, and 10 percent annually for model year 2026. The final standards are estimated to save about 234 billion gallons of gasoline between model years 2030 to 2050. Heavy-duty pickup truck and van fuel efficiency will increase 10 percent per year for model years 2030–2032 and 8 percent per year for model years 2033–2035.

4.8.4.2 State Regulations
Key efforts by the State are described below.

Executive Order S-3-05 (2005). Governor Arnold Schwarzenegger signed EO S-3-05 on June 1, 2005, which proclaimed that California is vulnerable to the impacts of climate change. To combat those concerns, the executive order established California’s GHG emissions reduction targets:
• GHG emissions should be reduced to 2000 levels by 2010 • GHG emissions should be reduced to 1990 levels by 2020 • GHG emissions should be reduced to 80 percent below 1990 levels by 2050 Executive Order B-30-15 (2015). Governor Jerry Brown signed EO B-30-15 on April 29, 2015, which added the following immediate target:
• GHG emissions should be reduced to 40 percent below 1990 levels by 2030 All State agencies with jurisdiction over sources of GHG emissions were directed to implement measures to achieve reductions of GHG emissions to meet the 2030 and 2050 targets. The CARB was directed to update the AB 32 Scoping Plan to reflect the 2030 target and therefore is moving forward with the update process. The mid-term target is critical to help frame the suite of policy measures, regulations, planning efforts, and investments in clean technologies and infrastructure needed to continue reducing emissions.

Executive Order B-55-18. EO B-55-18, signed September 10, 2018, sets a goal “to achieve carbon neutrality as soon as possible, and no later than 2045, and achieve and maintain net negative emissions thereafter.” EO B-55-18 directs the CARB to work with relevant State agencies to ensure future Scoping Plans identify and recommend measures to achieve the carbon neutrality goal. The goal of carbon neutrality by 2045 is in addition to other statewide goals, meaning not only should emissions be reduced to 80 percent below 1990 levels by 2050, but that, by no later than 2045, the remaining emissions be offset by equivalent net removals of CO2e from the atmosphere, including through sequestration in forests, soils, and other natural landscapes.

S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026

4.8 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.8 Greenhouse Gas Emissions_final.docx (03/11/26) -8 Executive Order N-79-20. EO N-79-20, which was signed by the Governor on September 23, 2020, sets the following goals for the State: 100 percent of in-state sales of new passenger cars and trucks shall be zero-emission by 2035; 100 percent of medium- and heavy-duty vehicles in the State shall be zero-emission by 2045 for all operations where feasible and by 2035 for drayage trucks; and 100 percent of off-road vehicles and equipment in the State shall be zero-emission by 2035, where feasible.

Executive Order B-48-18. In January 2018, Governor Brown signed EO B-48-18 requiring all State entities to work with the private sector to have at least 5 million zero emission vehicle (ZEVs) on the road by 2030, as well as install 200 hydrogen fueling stations and 250,000 electric vehicle charging stations by 2025. It specifies that 10,000 of the electric vehicle charging stations should be direct current fast chargers. This order also requires all State entities to continue to partner with local and regional governments to streamline the installation of ZEV infrastructure. The Governor’s Office of Business and Economic Development is required to publish a Plug-in Charging Station Design Guidebook and update the 2015 Hydrogen Station Permitting Guidebook to aid in these efforts. All State entities are required to participate in updating the 2016 Zero-Emissions Vehicle Action Plan to help expand private investment in ZEV infrastructure with a focus on serving low-income and disadvantaged communities. Additionally, all State entities are to support and recommend policies and actions to expand ZEV infrastructure at residential land uses, through the LCFS Program, and recommend how to ensure affordability and accessibility for all drivers.

Assembly Bill 32 (2006), California Global Warming Solutions Act. California’s major initiative for reducing GHG emissions is Assembly Bill (AB) 32, passed by the State Legislature on August 31, 2006.

This effort aims to reduce GHG emissions to 1990 levels by 2020. The CARB has established the level of GHG emissions in 1990 at 427 MMT CO2e. The emissions target of 427 MMT requires the reduction of 169 MMT from the State’s projected business-as-usual 2020 emissions of 596 MMT. AB 32 requires the CARB to prepare a Scoping Plan that outlines the main State strategies for meeting the 2020 deadline and to reduce GHGs that contribute to global climate change. The Scoping Plan was approved by the CARB on December 11, 2008, which contains the main strategies California will implement to achieve the reduction goals and includes CARB-recommended GHG reductions for each emissions sector of the State’s GHG inventory.

Assembly Bill 32 (2006), California Global Warming Solutions Act. The CARB approved the First Update to the Climate Change Scoping Plan (First Update) on May 22, 2014. The First Update identifies opportunities to leverage existing and new funds to further drive GHG emission reductions through strategic planning and targeted low carbon investments. The First Update defines CARB climate change priorities until 2020 and also sets the groundwork to reach long-term goals set forth in EOs S3-05 and B-16-2012. The First Update highlights California’s progress toward meeting the “near-term” 2020 GHG emission reduction goals as defined in the initial Scoping Plan. It also evaluates how to align the State’s “longer-term” GHG reduction strategies with other State policy priorities for water, waste, natural resources, clean energy, transportation, and land use. The CARB released a second update to the Scoping Plan, the 2017 Scoping Plan,14 to reflect the 2030 target set by EO B-30-15 and codified by SB 32.
14 California Air Resources Board (CARB). 2017a. California’s 2017 Climate Change Scoping Plan. November.

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026
S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A
P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.8 Greenhouse Gas Emissions_final.docx (03/11/26) 4.8-9 A third update to the Scoping Plan, the 2022 Scoping Plan15 was approved in December 2022 and assesses progress toward achieving the SB 32 2030 target and laying out a path to achieve carbon neutrality no later than 2045. The 2022 Scoping Plan focuses on outcomes needed to achieve carbon neutrality by assessing paths for clean technology, energy deployment, natural and working lands, and others, and is designed to meet the State’s long-term climate objectives and support a range of economic, environmental, energy security, environmental justice, and public health priorities.

Senate Bill 350 (2015) Clean Energy and Pollution Reduction Act. Senate Bill (SB) 350, signed by Governor Jerry Brown on October 7, 2015, updates and enhances AB 32 by introducing the following set of objectives in clean energy, clean air, and pollution reduction for 2030:
• Raise California’s renewable portfolio standard from 33 percent to 50 percent; and • Increasing energy efficiency in buildings by 50 percent by the year 2030.

The 50 percent renewable energy standard will be implemented by the California Public Utilities Commission for the private utilities and by the California Energy Commission for municipal utilities.

Each utility must submit a procurement plan showing it will purchase clean energy to displace other non-renewable resources. The 50 percent increase in energy efficiency in buildings must be achieved through the use of existing energy efficiency retrofit funding and regulatory tools already available to State energy agencies under existing law. The addition made by this legislation requires State energy agencies to plan for and implement those programs in a manner that achieves the energy efficiency target.

Senate Bill 32, California Global Warming Solutions Act of 2016, and Assembly Bill 197. In 2016, the Governor signed SB 32 and AB 197. SB 32 affirms the importance of addressing climate change by codifying into statute the GHG emissions reductions target of at least 40 percent below 1990 levels by 2030 contained in Governor Brown’s April 2015 EO B-30-15. SB 32 builds on AB 32 and keeps California on the path toward achieving the State’s 2050 objective of reducing emissions to 80 percent below 1990 levels, consistent with an IPCC analysis of the emissions trajectory that would stabilize atmospheric GHG concentrations at 450 parts per million CO2e and reduce the likelihood of catastrophic impacts from climate change.

The companion bill to SB 32, AB 197, provides additional direction to the CARB related to the adoption of strategies to reduce GHG emissions. Additional direction in AB 197 meant to provide easier public access to air emissions data that are collected by the CARB was posted in December 2016.

Senate Bill 100. On September 10, 2018, Governor Brown signed SB 100, which raises California’s Renewables Portfolio Standard (RPS) requirements to 60 percent by 2030, with interim targets, and 100 percent by 2045. The bill also establishes a State policy that eligible renewable energy resources and zero-carbon resources supply 100 percent of all retail sales of electricity to California end-use customers and 100 percent of electricity procured to serve all State agencies by December 31, 2045. 15 California Air Resources Board (CARB). 2022a. 2022 Scoping Plan. November 16. Website: https://ww2. arb.ca.gov/sites/default/files/2022-12/2022-sp.pdf (accessed October 2025).

S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026

4.8 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.8 Greenhouse Gas Emissions_final.docx (03/11/26) -10 Under the bill, the State cannot increase carbon emissions elsewhere in the western grid or allow resource shuffling to achieve the 100 percent carbon-free electricity target.

Assembly Bill 1279. AB 1279 was signed in September 2022 and codifies the State goals of achieving net carbon neutrality by 2045 and maintaining net negative GHG emissions thereafter. This bill also requires California to reduce statewide GHG emissions by 85 percent compared to 1990 levels by 2045 and directs CARB to work with relevant State agencies to achieve these goals.

California Building Efficiency Standards (Title 24, Part 6). The California Building Standards Code, or Title 24 of the California Code of Regulations (CCR) contains the regulations that govern the construction of buildings in California. Within the Building Standards Code, two parts pertain to the incorporation of both energy efficient and green building elements into land use development. Part 6 is California’s Energy Efficiency Standards for Residential and Non-Residential Buildings. These standards were first adopted in 1978 in response to a legislative mandate to reduce California’s energy consumption and are updated on an approximately 3-year cycle to allow consideration and possible incorporation of new energy efficient technologies and methods. In November 2008, the California Building Standards Commission established the California Green Building Standards Code (CALGreen Code), which sets performance standards for residential and non-residential development to reduce environmental impacts and encourage sustainable construction practices. The CALGreen Code addresses energy efficiency, water conservation, material conservation, planning and design, and overall environmental quality. The current set of standards were adopted in 2022 and will apply to projects seeking building permits on or after January 1, 2023. Energy efficient buildings require less electricity; therefore, increased energy efficiency reduces fossil fuel consumption and decreases GHG emissions.

Low Carbon Fuel Standard and Advanced Clean Cars. EO S-01-07 established a low carbon fuel standard (LCFS) with a Statewide goal to be established to reduce the carbon intensity of California’s transportation fuels that applies to all refiners, blenders, producers, or importers (“Providers”) of transportation fuels in California, including fuels used by off-road construction equipment. CARB approved amendments in 2018 to readjust carbon intensity benchmarks to meet California’s 2030 GHG reductions targets under SB 32. These amendments include opportunities to promote ZEV adoption, carbon capture and sequestration, and advanced technologies for decarbonization of the transportation sector.

4.8.4.3 Regional Regulations
South Coast Air Quality Management District. In 2008, the SCAQMD formed a Working Group to identify GHG emissions thresholds for land use projects that could be used by local lead agencies in the Basin. The Working Group developed several different options that are contained in the SCAQMD 2008 draft guidance document titled Interim CEQA GHG Significance Threshold for Stationary Sources, Rules and Plans16 that could be applied by lead agencies. On September 28, 2010, SCAQMD Working 16 South Coast Air Quality Management District (SCAQMD). 2008. Interim CEQA GHG Significance Threshold for Stationary Sources, Rules and Plans. Website: https://www.aqmd.gov/docs/default-source/ceqa/ handbook/greenhouse-gases-(ghg)-ceqa-significance-thresholds/ghgboardsynopsis.pdf (accessed October 2025).

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026
S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A
P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.8 Greenhouse Gas Emissions_final.docx (03/11/26) 4.8-11 Group Meeting No. 15 provided further guidance, including a tiered approach for evaluating GHG emissions for development projects where the SCAQMD is not the lead agency. The SCAQMD has not presented a finalized version of these thresholds to the governing board.

The SCAQMD identifies the emissions level for which a project would not be expected to substantially conflict with any State legislation adopted to reduce statewide GHG emissions. As such, the utilization of a service population represents the rates of emissions needed to achieve a fair share of the State’s mandated emissions reductions. Overall, the SCAQMD identifies a GHG efficiency level that, when applied statewide or to a defined geographic area, would meet the 2020 and post-2020 emissions targets as required by AB 32 and SB 32. If projects are able to achieve targeted rates of emissions per the service population, the State will be able to accommodate expected population growth and achieve economic development objectives, while also abiding by AB 32’s emissions target and future post-2020 targets.

Southern California Association of Governments. On April 4, 2024, SCAG adopted Connect SoCal— the 2024–2050 Regional Transportation Plan/Sustainable Communities Strategy (Connect SoCal 2024) for the SCAG region.
17 In general, Connect SoCal 2024 outlines a development pattern for the region, which, when integrated with the transportation network and other transportation measures and policies, would reduce vehicle miles traveled from automobiles and light-duty trucks and thereby reduce GHG emissions from these sources. For the SCAG region, CARB has set GHG reduction targets at 19 percent below 2005 per capita emissions levels by 2035. Connect SoCal 2024 lays out a strategy for the region to meet these targets. Overall, Connect SoCal 2024 is meant to provide growth strategies that will achieve the regional GHG emissions reduction targets. Land use strategies to achieve the region’s targets include planning for new growth around high-quality transit areas and livable corridors, and creating neighborhood mobility areas to integrate land use and transportation and plan for more active lifestyles.18 However, local General Plans, Specific Plans, or zoning are not required to be consistent with Connect SoCal 2024; SCAG is required to consider local land use controls when drafting the RTP/SCS.

South Coast Air Quality Management District. In 2008, the SCAQMD formed a Working Group to identify GHG emissions thresholds for land use projects that could be used by local lead agencies in the Basin. The Working Group developed several different options that are contained in the SCAQMD 2008 draft guidance document titled Interim CEQA GHG Significance Threshold for Stationary Sources, Rules and Plans19 that could be applied by lead agencies. On September 28, 2010, SCAQMD Working Group Meeting #15 provided further guidance, including a tiered approach for evaluating GHG 17 Southern California Association of Governments (SCAG). 2024b. Connect SoCal 2024: The 2024–2050 Regional Transportation Plan/Sustainable Communities Strategy of the Southern California Association of Governments. Website: https://scag.ca.gov/sites/default/files/2024-05/23-2987-connect-socal-2024-finalcomplete-040424.pdf (accessed October 2025). 18 Ibid.
19 South Coast Air Quality Management District (SCAQMD). 2008. Interim CEQA GHG Significance Threshold for Stationary Sources, Rules and Plans. Website: https://www.aqmd.gov/docs/default-source/ceqa/ handbook/greenhouse-gases-(ghg)-ceqa-significance-thresholds/ghgboardsynopsis.pdf (accessed October 2025).

S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026

4.8 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.8 Greenhouse Gas Emissions_final.docx (03/11/26) -12 emissions for development projects where the SCAQMD is not the lead agency. The SCAQMD has not presented a finalized version of these thresholds to its Governing Board.

The SCAQMD identifies the emissions level for which a project would not be expected to substantially conflict with any State legislation adopted to reduce statewide GHG emissions. As such, the utilization of a service population represents the rates of emissions needed to achieve a fair share of the State’s mandated emissions reductions. Overall, the SCAQMD identifies a GHG efficiency level that, when applied statewide or to a defined geographic area, would meet the post-2020 emissions targets as required by AB 32 and SB 32.

4.8.4.4 Local Regulations
The City of Cypress does not currently have an applicable plan, policy, or regulation adopted for the purpose of reducing GHG emissions.

4.8.5 Thresholds of Significance
The thresholds of significance for greenhouse gas emissions impacts used in this analysis are consistent with Appendix G of the State CEQA Guidelines. Based on Appendix G, implementation of the proposed project would have a significant impact with respect to greenhouse gas emissions if it would:

Threshold 4.8.1: Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment; or
Threshold 4.8.2: Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases.

Section 15064.4 of the State CEQA Guidelines provides that a lead agency should make a good-faith effort, based on scientific and factual data, to describe, calculate, or estimate the amount of GHG emissions resulting from a project. The Guidelines further provide that a lead agency has discretion to determine the appropriate methodology for evaluating significance, including the use of quantitative modeling, qualitative analysis, performance-based standards, or consistency with applicable plans and regulations. Consistent with Section 15064.4, this analysis quantitatively estimates both construction-related and operational GHG emissions associated with the proposed project. However, the quantification is for informational purposes, and is not used for a comparative analysis or as a threshold of significance.

4.8.5.1 SCAQMD Guidance
The SCAQMD released a draft guidance document in 2008 titled, Draft Guidance Document – Interim CEQA Greenhouse Gas (GHG) Significance Threshold,
20 which presented potential screening
thresholds and a tiered evaluation framework. However, the SCAQMD’s draft interim CEQA thresholds guidance document was not adopted or approved by its Governing Board, and therefore no SCAQMD-adopted quantitative thresholds are applicable to the proposed project. Accordingly, the

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026
S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A
P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.8 Greenhouse Gas Emissions_final.docx (03/11/26) 4.8-13 City does not rely on the SCAQMD’s draft numeric screening thresholds as significance criteria for this project.

4.8.5.2 Selected Thresholds for Proposed Project Analysis Because no locally adopted quantitative GHG threshold or CEQA-qualified Climate Action Plan applies to the project, the City evaluates significance based on:
• Consistency with statewide GHG reduction regulations and policies, including the CARB 2022 Climate Change Scoping Plan;
• Consistency with Connect SoCal 2024, which integrates regional growth projections and greenhouse gas reduction targets consistent with SB 375; and • Consideration of applicable statewide regulatory programs that will reduce emissions intensity over time (e.g., SB 100, Advanced Clean Cars II, Low Carbon Fuel Standard, Title 24).

The 2022 Climate Change Scoping Plan provides statewide policy guidance and identifies strategies and planning considerations that support long-term decarbonization. The Scoping Plan’s discussion of project attributes is used in this analysis as qualitative guidance to inform the overall evaluation of consistency with statewide climate policy. The City’s significance determination is based on the project’s incremental contribution to cumulative emissions in light of statewide regulatory programs and regional planning assumptions.

Neither CARB nor SCAQMD has adopted a quantitative threshold of significance for constructionrelated GHG emissions. Consistent with State CEQA Guidelines Section 15064.4, construction emissions are quantitatively estimated and disclosed along with operational emissions as part of a good-faith effort to estimate project emissions and to inform the overall significance determination.

4.8.5.3 Summary of Significance Framework
The significance of greenhouse gas emissions for the proposed project is determined based on whether the project’s incremental contribution to cumulative GHG emissions would be cumulatively considerable in light of:
• Statewide statutory emission reduction targets,
• Regional growth assumptions and emissions modeling,
• Applicable regulatory programs, and
• Project-specific mitigation measures.

The City recognizes that GHG impacts are inherently cumulative and therefore evaluates the project’s consistency with statewide and regional emissions reduction trajectories rather than relying on a single numeric threshold, consistent with State CEQA Guidelines Section 15064.4.

S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026

4.8 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.8 Greenhouse Gas Emissions_final.docx (03/11/26) -14

4.8.6 Project Impacts
Threshold 4.8.1: Would the project generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment? Threshold 4.8.2: Would the project conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases? Less than Significant Impact with Mitigation. 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 that includes approximately 134 acres of land in the City. The proposed project would include the development of up to 1,791 additional residential units within the Buildout Area and 440,000 square feet of non-residential development. The following analysis describes the construction- and operation-related GHG emissions associated with buildout of the proposed project and assesses whether the project’s incremental contribution to cumulative GHG emissions would be cumulatively considerable.

Consistent with State CEQA Guidelines Section 15064.4, construction and operational GHG emissions associated with the proposed project are quantitatively estimated to disclose the magnitude and sources of emissions.

As described below, with implementation of Mitigation Measure GHG-1, Mitigation Measure AIR-1, and Mitigation Measure TRA-1, impacts related to greenhouse gas emissions would be less than significant with mitigation.

Construction Greenhouse Gas Emissions. The following analysis estimates the potential construction GHG emissions associated with future buildout envisioned under the proposed project. These estimates are for informational purposes and provided to supplement the environmental analysis and public disclosure requirements of CEQA in accordance with State CEQA Guidelines Section 15064.4.

Construction activities associated with future buildout envisioned under the proposed project would produce combustion emissions from various sources. During construction, GHGs would be emitted through the operation of construction equipment and from worker and builder supply vendor vehicles, each of which typically use fossil-based fuels to operate. The combustion of fossil-based fuels creates GHGs such as CO2, CH4, and N2O. Furthermore, CH4 is emitted during the fueling of heavy equipment. Exhaust emissions from on-site construction activities would vary daily as construction activity levels change.

Construction emissions were estimated for future buildout envisioned under the proposed project using CalEEMod. As described in Section 4.3, Air Quality, information regarding the exact scope of each future development project is not yet known; however, construction is assumed to commence in 2026 and conclude in 2038, which was the assumption included in CalEEMod. Construction activities would include demolition, site preparation, grading, building construction, paving, and architectural coatings (painting). The proposed project would require the cut of 248,600 cubic yards of soil and fill of 333,500 cubic yards of soil, which would result in the net import of 84,900 cubic yards of soil, which was also included in CalEEMod. In addition, the proposed project would require the

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026
S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A
P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.8 Greenhouse Gas Emissions_final.docx (03/11/26) 4.8-15 demolition of approximately 768,360 square feet of existing buildings. Based on information provided by the project applicant, demolition activities would require the use of up to four excavators, two track loaders, a crawler crane, and several bobcats/backhoes, which were included in CalEEMod. This analysis uses default construction equipment in CalEEMod for all other construction phases. This analysis also conservatively assumes the use of Tier 2 construction equipment and that the proposed project would comply with SCAQMD Rule 403 dust control measures. It should be noted that this is a conservative analysis that does not take into account the expected emission reductions that would be achieved through the implementation of Mitigation Measure AIR-2, which requires the use of 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. All other construction details are not yet known; therefore, default assumptions (e.g., construction worker and truck trips and fleet activities) from CalEEMod were used. CalEEMod output sheets are included in Appendix B.

Using CalEEMod, it is estimated that future buildout envisioned under the proposed project would generate approximately 32,899.0 MT CO2e during the 12-year construction period of the project.

Construction GHG emissions were amortized over the life of the project (assumed to be 30 years) and added to the operational emissions. When annualized over the life of the project, amortized construction emissions would be approximately 1,096.6 MT CO2e.

Operational Greenhouse Gas Emissions.As identified above, the proposed project consists of the reasonably foreseeable buildout of up to 1,791 additional residential units within the Buildout Area and 440,000 square feet of non-residential development. As such, the following analysis estimates the potential operational-related energy usage associated with future buildout envisioned under the proposed project.

Long-term GHG emissions are typically generated from mobile sources (e.g., vehicle trips), area sources (e.g., maintenance activities and landscaping), and indirect emissions from sources associated with energy consumption, waste sources (land filling and waste disposal), and water sources (water supply and conveyance, treatment, and distribution). Mobile-source GHG emissions would include project-generated vehicle trips to and from the project. Area-source emissions would be associated with activities such as landscaping and maintenance in the Buildout Area. Energy source emissions would be generated at off-site utility providers because of increased electricity demand generated by the project. Waste source emissions generated by the proposed project include energy generated by land filling and other methods of disposal related to transporting and managing project-generated waste. In addition, water source emissions associated with the proposed project are generated by water supply and conveyance, water treatment, water distribution, and wastewater treatment.

In accordance with State CEQA Guidelines Section 15064.4(c), GHG emissions were estimated for future buildout envisioned by the proposed project using CalEEMod, assuming up to 1,791 residential units and 440,000 square feet of non-residential development as identified in Table 3.B in Chapter

3.0, Project Description. Trip generation rates used in CalEEMod for project were based on the project’s trip generation estimate of 21,041 net new average daily trips, as identified in Table 4.17.A in Section 4.17, Transportation. It is not yet known whether future buildout under the proposed project would include natural gas; therefore, this analysis conservatively uses default assumptions for natural gas usage. This analysis assumes there would be no woodburning hearths. Where projectspecific data were not available, default assumptions (e.g., electricity usage, water usage, and solid S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026

4.8 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.8 Greenhouse Gas Emissions_final.docx (03/11/26) -16 waste generation) from CalEEMod were used to estimate project emissions. Table 4.8.B: Greenhouse Gas Emissions (MT/yr) shows the calculated GHG emissions for the proposed project. The emissions presented in Table 4.8.B are for informational purposes and conservative as they do not take into account the emissions from the existing uses, except for the existing trip generation.

Table 4.8.B: Greenhouse Gas Emissions (MT/yr)
Emissions Source Operational Emissions (MT/yr)
CO2 CH4 N2O CO2e
Mobile Sources 16,389.0 0.7 0.7 16,606.0
Area Sources 406.8 <0.1 <0.1 407.3
Energy Sources 3,493.4 0.4 <0.1 3,510.4
Water Sources 170.2 3.3 0.1 275.6
Waste Sources 161.6 16.1 0.0 565.3
Total Project Operational Emissions 21,364.6
Amortized Construction Emissions 1,096.6
Total Annual Emissions 22,461.2
Source: Compiled by LSA (November 2025).

CH4 = methane
CO2 = carbon dioxide
CO2e = carbon dioxide equivalent
MT/yr = metric tons per year
N2O = nitrous oxide
SCAQMD = South Coast Air Quality Management District
The proposed project would generate approximately 22,461 MT CO₂e per year, including amortized construction emissions. The City has made a good-faith effort to quantify both construction-related and operational GHG emissions associated with the proposed project using available project information and accepted modeling tools. The resulting emissions estimates are provided to disclose the anticipated magnitude and sources of project-related GHG emissions and to inform decision makers and the public. However, the significance determination is not based on the magnitude of quantified emissions, but rather on evaluation of the project’s consistency with applicable statewide and regional policies, regulatory programs, and mitigation measures, as further discussed below.

As described in Section 4.8.5, no locally adopted quantitative GHG threshold or CEQA-qualified Climate Action Plan apply to the project. Therefore, the City evaluates significance based on State CEQA Guidelines Section 15064.4, which allows lead agencies to consider quantified emissions, consistency with applicable plans and regulations, or the extent to which a project contributes to cumulative greenhouse gas emissions in light of Statewide and regional emissions reduction programs. The following analysis follows the State-recommended framework described in the 2022 Scoping Plan to evaluate whether the project generally aligns with statewide climate goals through the incorporation of planning-level GHG-reducing attributes. Accordingly, the significance determination is based on the project’s consistency with applicable Statewide and regional GHG reduction policies, including the 2022 Scoping Plan and Connect SoCal 2024.

CARB’s Scoping Plan. The following discussion evaluates future buildout envisioned under the proposed project according to the goals of the 2022 Scoping Plan, EO B-30-15, AB 1279, SB 32, and AB 197.

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026
S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A
P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.8 Greenhouse Gas Emissions_final.docx (03/11/26) 4.8-17 EO B-30-15 established an interim target of reducing statewide GHG emissions to 40 percent below 1990 levels by 2030. SB 32 codified this target and reinforced California’s long-term emissions reduction trajectory established under AB 32. The companion bill to SB 32, AB 197, provides additional direction to the CARB related to the adoption of strategies to reduce GHG emissions. AB 1279 establishes State policy to achieve carbon neutrality and to reduce Statewide anthropogenic GHG emissions to at least 85 percent below 1990 levels by 2045.

The 2022 Scoping Plan21 establishes a statewide strategy for achieving these statutory goals. The Scoping Plan is a statewide policy document and does not establish project-level CEQA significance thresholds. Rather, it identifies sector-based decarbonization strategies, regulatory programs, and broad land use and transportation policies intended to reduce emissions over time through widespread implementation. The 2022 Scoping Plan emphasizes expansion of clean energy generation, electrification of buildings and transportation systems, and transition away from fossil fuel use. Statewide programs such as EO N-79-20, which directs that all new passenger vehicles sold in California be zero-emission by 2035, are anticipated to substantially reduce transportation-related emissions over time.

Appendix D (Local Actions)
22 of the 2022 Scoping Plan includes “key project attributes” that may indicate alignment of residential or mixed-use development with statewide climate objectives. These attributes are not mandatory requirements and do not constitute adopted CEQA thresholds of significance. Instead, they provide general guidance for evaluating whether development patterns support the State’s long-term decarbonization strategy.

The City reviewed the proposed project relative to the 2022 Scoping Plan’s policy framework.

Table 4.8.C: Project Consistency with the 2022 Scoping Plan Key Residential and Mixed-Use Project Attributes that Reduce GHGs summarizes project consistency with the Scoping Plan’s planning-level attributes. The analysis demonstrates that the project generally supports the State’s decarbonization strategy through infill development patterns, transit accessibility, and implementation of projectspecific mitigation measures.

With implementation of Mitigation Measure AIR-1, future development facilitated by the proposed project would provide enhanced electric vehicle charging infrastructure consistent with Scoping Plan guidance. The project would also avoid conversion of natural or working lands and, with implementation of Mitigation Measure TRA-1, would incorporate transportation demand management strategies supportive of reduced vehicle travel. Building energy performance and electrification measures required under Mitigation Measure GHG-1 further support long-term building decarbonization objectives.
21 California Air Resources Board (CARB). 2022b. 2022 Scoping Plan Appendix D Local Actions. November.

Website: https://ww2.arb.ca.gov/sites/default/files/2022-11/2022-sp-appendix-d-local-actions.pdf (accessed November 2025).
22 Ibid.

S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026

4.8 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.8 Greenhouse Gas Emissions_final.docx (03/11/26) -18 Table 4.8.C: Project Consistency with the 2022 Scoping Plan Key Residential and Mixed-Use Project Attributes that Reduce GHGs
Priority Areas Key Project Attribute Would the Project Conflict? Transportation
Electrification
Provides EV charging infrastructure that,
at minimum, meets the most ambitious
voluntary standard in the California
Green Building Standards Code at the
time of project approval.

No Conflict. The CALGreen Code requires provision of
infrastructure to accommodate electric vehicle (EV)
chargers for new single-family and attached dwelling
units/town houses. It is not yet known whether future
development facilitated by the proposed project would
include electric vehicle charging; however, Mitigation
Measure AIR-1 requires that all future development
facilitated the proposed project install EV charging
capabilities that meet the requirements of the latest
version of the CALGreen Code Tier 2 Voluntary
Standards. With implementation of Mitigation
Measure AIR-1, the proposed project would not
conflict with this key project attribute.

VMT Reduction Is located on infill sites that are
surrounded by existing urban uses and
reuses or redevelops previously
undeveloped or underutilized land that is
presently served by existing utilities and
essential public services (e.g., transit,
streets, water, sewer).

No Conflict. The Buildout Area consists of 134 acres
within the boundaries of the Specific Plan. As stated
above, the Buildout Area is currently surrounded by a
variety of land uses, including commercial, office,
business park, retail, park, residential, religious
facilities, and mixed-use land uses. The Buildout Area is currently occupied by the Los Alamitos Race Course and
related facilities is presently served by existing utilities and essential public services (e.g., transit, streets,
water, sewer). As such, the project would facilitate
development on infill sites surrounded by existing
urban uses.

Does not result in the loss or conversion
of natural and working lands.

No Conflict. The Buildout Area is surrounded by a
variety of commercial, office, business park,
commercial and retail services, park, residential uses, and religious facilities uses. The Specific Plan designates the Buildout Area for a mix of urban land uses, including parks, residential and local serving commercial uses.

The Buildout Area is not currently zoned for or used as natural or working lands. Therefore, the proposed
project would not conflict with this key project
attribute.

Consists of transit-supportive densities
(minimum of 20 residential dwelling units
per acre), or is in proximity to existing
transit stops (within a half mile), or
satisfies more detailed and stringent
criteria specified in the region’s SCS.

No Conflict with Mitigation Measure TRA-1. The
Specific Plan includes six land use districts that permit the development of residential, commercial, retail,
restaurant, entertainment and park and recreational
uses within the Buildout Area. Within the land use
districts that permit residential uses (which includes all of the land use districts other than the Public Park
District), the maximum residential densities range from 8 dwelling units/acre (du/ac) to 30 du/ac. In addition, bus service is currently provided by the Orange County
Transportation Authority (OCTA) along Katella Avenue
and Valley View Street. All future development
facilitated by the proposed project would be required
to comply with City policies regarding bicycle parking
and other infrastructure. Additionally, the proposed

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026
S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A
P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.8 Greenhouse Gas Emissions_final.docx (03/11/26) 4.8-19 Table 4.8.C: Project Consistency with the 2022 Scoping Plan Key Residential and Mixed-Use Project Attributes that Reduce GHGs
Priority Areas Key Project Attribute Would the Project Conflict? project would implement Mitigation Measure TRA-1,
which requires that any future project applicants for
residential development projects within the Buildout
Area demonstrate the project’s consistency with the
Specific Plan-level vehicle miles traveled (VMT)
mitigation framework that applies to such project prior to its approval. This framework provides for the
construction or improvement of bicycle facilities or
sidewalks, which would encourage non-vehicular
transportation. Therefore, future buildout envisioned
under the proposed project would support the ability
to use alternative modes of transportation. Because
the proposed project would promote initiatives to
reduce vehicle trips and VMT and would increase the
use of alternate means of transportation, The proposed
project would not conflict with this key project
attribute.

Reduces parking requirements by:
eliminating parking requirements or
including maximum allowable parking
ratios (i.e., the ratio of parking spaces to
residential units or square feet); or
providing residential parking supply at a
ratio of less than one parking space per
dwelling unit; or for multifamily
residential development, requiring
parking costs to be unbundled from costs
to rent or own a residential unit.

No Conflict with Mitigation Measure TRA-1. The
Specific Plan requires future development within the
Buildout Area to comply with the parking standards
established in the Cypress Zoning Ordinance.

Accordingly, the proposed project does not include
policies or development standards that would reduce
parking requirements (e.g., elimination of minimum
parking requirements, parking maximums, reduced
residential parking ratios, or unbundled residential
parking costs).

However, Mitigation Measure TRA-1 requires that
future residential development projects demonstrate
consistency with the Specific Plan-VMT mitigation
framework prior to project approval. This requirement
ensures that future projects incorporate transportation demand management measures and project design
features intended to reduce automobile travel and
associated VMT. Therefore, although the proposed
project does not directly reduce parking requirements,
implementation of Mitigation Measure TRA-1 would
ensure that the project does not conflict with this key Scoping Plan attribute from an overall VMT reduction
perspective.

At least 20 percent of units included are
affordable to lower-income residents.

No Conflict. The proposed project does not conflict
with this goal because it delivers a range of residential uses, from single-family to high-density housing. This
diversity of housing types would offer options to
accommodate varying household needs within the
community. As such, the project supports the provision
of varied housing opportunities and would not conflict
with this policy.

S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026

4.8 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.8 Greenhouse Gas Emissions_final.docx (03/11/26) -20 Table 4.8.C: Project Consistency with the 2022 Scoping Plan Key Residential and Mixed-Use Project Attributes that Reduce GHGs
Priority Areas Key Project Attribute Would the Project Conflict? Results in no net loss of existing
affordable units.

No Conflict. The proposed project would require the
demolition and removal of all or a substantial portion
of the existing improvements associated with Los
Alamitos Race Course, including the race track and
infield area, grandstand, buildings, barns and
structures and two artificial lakes. The removal of these structures would not result in a net loss of existing
affordable uses. As such, the proposed project would
not conflict with this key project attribute.

Building
Decarbonization
Uses all-electric appliances without any
natural gas connections and does not use
propane or other fossil fuels for space
heating, water heating, or indoor
cooking.

No Conflict with Mitigation Measure GHG-1. The
specific building systems and energy sources for future development facilitated by the proposed project have
not yet been determined; therefore, it is not known at
this time whether all future development would be
fully all-electric or include natural gas infrastructure.

However, Mitigation Measure GHG-1 requires future
development projects to either implement all-electric
building design or, where all-electric design is
determined to be infeasible, incorporate additional
greenhouse gas reduction measures to minimize
emissions associated with building energy use.

These measures include, but are not limited to,
exceeding applicable Title 24 energy efficiency
standards, achieving Leadership in Energy and
Environmental Design (LEED) or equivalent
sustainability performance, installation of on-site solar photovoltaic (PV) systems, and implementation of
energy and water conservation features. Through
implementation of Mitigation Measure GHG-1, future
development would reduce building-related GHG
emissions consistent with statewide building
decarbonization objectives identified in the 2022
Scoping Plan. Therefore, the proposed project would
not conflict with this key Scoping Plan attribute.

Source: CARB (2022) and Compiled by LSA (November 2025).

California has adopted numerous statewide regulatory programs that will substantially reduce emissions intensity over time, including:
• Advanced Clean Cars II and Executive Order N-79-20 (100 percent new passenger vehicle ZEV sales by 2035);
• The Low Carbon Fuel Standard;
• Senate Bill 100 (carbon-free electricity by 2045);

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026
S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A
P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.8 Greenhouse Gas Emissions_final.docx (03/11/26) 4.8-21 • Title 24 Building Energy Efficiency Standards;
• CALGreen standards; and
• Senate Bill 1383 methane reduction requirements.

Transportation emissions represent the largest portion of project operational emissions. Although the project would introduce additional vehicle trips, per-mile GHG intensity is expected to decline substantially over the life of the project due to mandatory fleet electrification and fuel decarbonization requirements. Similarly, electricity-related emissions will decline as grid carbon intensity decreases pursuant to SB 100. Therefore, while the project would generate operational emissions, those emissions will occur within a regulatory environment designed to ultimately reduce GHG emissions from transportation-related sources on a statewide basis, independent of projectspecific mitigation.

As discussed in Section 4.17, Transportation, the project would result in a significant and unavoidable VMT impact under State CEQA Guidelines Section 15064.3. VMT significance under CEQA evaluates transportation efficiency and environmental impacts associated with vehicle travel patterns. It does not, by itself, determine whether a project’s GHG emissions are cumulatively considerable. Although transportation activity would increase, statewide regulatory programs will reduce GHG emissions per mile traveled over time. Therefore, a significant VMT impact does not compel a conclusion that the project’s GHG emissions would conflict with statewide climate goals. GHG impacts are evaluated separately pursuant to State CEQA Guidelines Section 15064.4.

To provide additional context, the City evaluated the project’s operational greenhouse gas emissions on a per capita basis. Based on an estimated residential population of approximately 5,516 persons at buildout, annual operational emissions of approximately 22,461 MT CO₂e equate to approximately

4.1 MT CO₂e per capita per year. For comparison, California’s statewide per capita emissions were approximately 9 MT CO₂e per person in recent reporting years. The project’s per capita emissions are therefore substantially below the current statewide average and are expected to decline further over time due to fleet electrification, fuel decarbonization, and grid decarbonization under SB 100 and related regulatory programs. This per capita efficiency analysis demonstrates that the project would accommodate State-mandated housing growth at an emissions intensity consistent with Statewide climate objectives.

Furthermore, Mitigation Measure GHG-1 as presented below, Mitigation Measure AIR-1, and Mitigation Measure TRA-1 require:
• All-electric design or implementation of feasible GHG reduction measures for mixed-fuel projects; • Enhanced EV charging infrastructure; and
• Transportation demand management strategies.

These measures further reduce project emissions and support long-term decarbonization.

S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026

4.8 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.8 Greenhouse Gas Emissions_final.docx (03/11/26) -22 The City has determined that prohibiting natural gas usage is infeasible due to cost-effectiveness considerations, based in part on 2022 studies conducted by the California Public Utilities Commission (CPUC) and the California Energy Commission (CEC).
23 Furthermore, in 2023 and again in 2024, the
Ninth Circuit Court of Appeals held that a City ordinance prohibiting natural gas infrastructure in new construction was preempted by the federal Energy Policy and Conservation Act and was therefore unlawful.24 For these reasons, the City, as lead agency for the environmental review of the proposed project, has found that requiring mitigation to prohibit the usage of natural gas in future projects is not feasible. Accordingly, Mitigation Measure GHG-1 requires that future development under the proposed project either be all-electric or incorporate additional emission reduction measures if allelectric development is not feasible.

Mitigation Measure GHG-1 Prior to issuance of building permits, project applicants for future development within the Buildout Area shall demonstrate to the satisfaction of the City of Cypress (City) Planning Division that the proposed buildings incorporate feasible greenhouse gas (GHG) reduction strategies consistent with current State and local decarbonization goals. Compliance shall be demonstrated through building plans, energy modeling, California Green Building Standards Code (CALGreen Code) checklists, or similar documentation submitted during the plan check process, as deemed necessary by the City.

Future project applicants shall comply with either the All-Electric Design Path or the Efficient Mixed-Fuel Design Path, as described below:

Preferred Compliance Path: All Electric Design - Future development shall be designed and constructed without natural gas infrastructure or natural gas appliances. All space heating, water heating, cooking, and clothes drying systems shall be fully electric. Electrical service panels shall be sized to accommodate expected loads and future electrification needs.

Alternative Compliance Path: Efficient Mixed-Fuel Design - If a project proposes to install natural gas infrastructure or natural gas appliances, a future project applicant shall implement a combination of GHG reduction measures sufficient to minimize GHG emissions from natural gas usage to the maximum extent feasible. Measures may include, but are not limited to, the following:
23 Southern California Edison (SCE). 2022. 2019 Reach Code Cost-Effectiveness Analysis. Full Service and QuickService Restaurants. February. 24 United States Court of Appeals for the Ninth Circuit. Filed April 17, 2023. California Restaurant Association v. City of Berkeley, (9th Cir. 2023) 65 F. 4th 1045, amended and superseded by (9th Cir. 2024) 89 F.4th 1094.

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026
S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A
P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.8 Greenhouse Gas Emissions_final.docx (03/11/26) 4.8-23 • Exceed Title 24, Part 6 (Building Energy Efficiency Standards) performance requirements by 10–20 percent, where feasible, as demonstrated through energy modeling or prescriptive
compliance documentation.
• Install on-site solar photovoltaic (PV) systems to the maximum feasible extent, including on rooftops and parking canopy structures, where structurally and technically feasible. • Provide electric-ready infrastructure, including service panel capacity, conduit, wiring, and dedicated circuits, to allow future conversion to all-electric appliances and systems.
• Design buildings to achieve, at minimum, Leadership in Energy and Environmental Design (LEED) Silver certification or an equivalent third-party green building rating.
• Install programmable thermostats, advanced metering
infrastructure, and smart home energy management systems. • Provide heating, ventilation, and air conditioning (HVAC) commissioning consistent with CALGreen Code Sections 5.410.2–

5.410.4, including a commissioning plan, functional performance testing, and a commissioning report.
• Install cool roof materials meeting an aged solar reflectance of ≥

0.30, or the most current CALGreen Code requirement,
whichever is more stringent.
• Provide infrastructure to accommodate up to 50 percent recycled water use for landscape irrigation, where recycled water supply is available.
• Use water-efficient irrigation systems, minimize turf, and incorporate native, low-water, or drought-tolerant plant species. • Install rainwater harvesting systems, where feasible. • Prohibit or restrict the use of potable water for cleaning nonvegetated outdoor surfaces and prohibit systems that apply water to hardscape surfaces.
• Implement and maintain robust solid waste diversion programs, including recycling and organic waste collection consistent with Senate Bill (SB) 1383 requirements.

S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026

4.8 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.8 Greenhouse Gas Emissions_final.docx (03/11/26) -24 • All selected GHG reduction measures shall be clearly identified on improvement plans and construction drawings. Compliance with this measure shall be verified by City staff during plan check and confirmed through building inspection prior to final occupancy.

With implementation of Mitigation Measure GHG-1, the proposed project would incorporate building design and operational measures that reduce greenhouse gas emissions and support the decarbonization strategies identified in the 2022 Scoping Plan. While the project may not include every planning-level attribute described in the Scoping Plan, those attributes are intended as qualitative guidance and do not constitute adopted CEQA significance thresholds. Based on the project’s overall consistency with statewide regulatory programs and long-term emissions reduction strategies, the City concludes that the project would generally align with the policy objectives of the 2022 Scoping Plan and would not, on this basis, conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing greenhouse gas emissions.

SCAG’s 2024-2050 Regional Transportation Plan/Sustainable Communities Strategy (Connect SoCal 2024). Connect SoCal 2024 identifies land use strategies intended to reduce VMT and GHG emissions by focusing housing and employment growth in urbanized areas served by transit and other opportunity areas. The RTP/SCS emphasizes integrated land use and transportation planning, improved system efficiency, complete streets, preservation of the transportation system, expansion of transit options, and promotion of compact development patterns.

Connect SoCal 2024 includes transportation investments and regional growth forecasts that collectively demonstrate achievement of CARB-assigned greenhouse gas reduction targets under SB 375. Specifically, Connect SoCal 2024 demonstrates attainment of the regional target of reducing percapita GHG emissions from passenger vehicles and light-duty trucks by 19 percent by 2035 compared to 2005 levels. While Connect SoCal 2024 does not require local General Plans, Specific Plans, or zoning to be consistent with the strategy, it establishes a regional framework that encourages local jurisdictions to align land use decisions with regional sustainability objectives.

The proposed project consists of reasonably foreseeable buildout of a portion of the Specific Plan area, including development of up to 1,791 residential units and 440,000 square feet of nonresidential uses within an existing urbanized area. The Buildout Area has been identified in the Housing Element and would assist the City in meeting its Regional Housing Needs Allocation (RHNA) obligations. RHNA allocations are incorporated into SCAG’s regional growth forecasts and are therefore represented within the assumptions used in the emissions modeling completed for Connect SoCal 2024.

Connect SoCal 2024’s modeling assumes housing growth consistent with RHNA allocations while demonstrating achievement of regional per-capita GHG reduction targets. The number of residential units in the proposed project does not exceed SCAG’s regional growth assumptions. As an infill development located within an existing urbanized area and near existing transit service, the project’s development pattern is consistent with the strategy of accommodating growth in developed areas to reduce pressure for outward expansion and associated transportation emissions contained in Connect SoCal 2024.

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026
S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A
P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.8 Greenhouse Gas Emissions_final.docx (03/11/26) 4.8-25 According to the United States Census Bureau, the average household size in Cypress from 2019-2023 was approximately 3.08 persons per household.
25 Based on this ratio, the proposed project would
accommodate approximately 5,516 persons at full buildout. According to the Connect SoCal 2024 Growth Forecast Technical Report,
26 Cypress’s population is anticipated to increase from approximately 50,200 people in 2019 to 56,200 people in 2050, and the City’s Sixth Cycle RHNA allocation identifies a housing need of 3,936 units for the 2021–2029 planning period. 27 Development
facilitated by the proposed project would contribute to accommodating this planned regional growth rather than introducing growth beyond that contemplated in Connect SoCal 2024.

Because the project implements planned housing growth assumed within SCAG’s CARB-certified regional emissions modeling framework, implementation of the project would not interfere with SCAG’s ability to achieve the regional greenhouse gas reduction targets established under SB 375. In addition, mitigation measures incorporated into the project, including Mitigation Measure GHG-1, Mitigation Measure AIR-1, and Mitigation Measure TRA-1, are generally consistent with strategies identified in the Connect SoCal 2024 Program Environmental Impact Report for reducing emissions and improving transportation efficiency.

Accordingly, the proposed project would be consistent with the land use and growth assumptions underlying Connect SoCal 2024 and would not conflict with the region’s ability to achieve adopted GHG reduction targets. As identified above, the proposed project would help the City meet its RHNA allocation, which is consistent with SCAG’s objectives to provide more housing in Priority Development Areas to preserve natural lands and open spaces and to address the existing housing need as defined by the RHNA. As such, the proposed project would be consistent with Connect SoCal 2024.

Summary. As discussed above, 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. 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 greenhouse gas emissions, either directly or indirectly, and potential conflict with applicable plans, 25 United States Census Bureau. 2024. Cypress City, California QuickFacts. Website: https://www.census. gov/quickfacts/fact/table/cypresscitycalifornia/PST045224 (accessed October 2025). 26 Southern California Association of Governments (SCAG). 2024a. 2024–2050 RTP/SCS Draft Connect SoCal 2024 Growth Projections.
27 Southern California Association of Governments (SCAG). 2021. SCAG 6th Cycle Final RHNA Allocation Plan.

Website: https://scag.ca.gov/sites/main/files/file-attachments/6th_cycle_final_rhna_allocation_plan_ 070121.pdf?1646938785 (accessed January 28, 2025).

S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026

4.8 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.8 Greenhouse Gas Emissions_final.docx (03/11/26) -26 policies, or regulations adopted to reduce greenhouse gas emissions would be less than significant with mitigation.

4.8.7 Level of Significance Prior to Mitigation
The proposed project would result in potentially significant impact related to GHG emissions.

4.8.8 Mitigation Measures
Mitigation Measure GHG-1 Prior to issuance of building permits, project applicants for future development within the Buildout Area shall demonstrate to the satisfaction of the City of Cypress (City) Planning Division that the proposed buildings incorporate feasible greenhouse gas (GHG) reduction strategies consistent with current State and local decarbonization goals. Compliance shall be demonstrated through building plans, energy modeling, California Green Building Standards Code (CALGreen Code) checklists, or similar documentation submitted during the plan check process, as deemed necessary by the City.

Future project applicants shall comply with either the All-Electric Design Path or the Efficient Mixed-Fuel Design Path, as described below:

Preferred Compliance Path: All Electric Design - Future development shall be designed and constructed without natural gas infrastructure or natural gas appliances. All space heating, water heating, cooking, and clothes drying systems shall be fully electric. Electrical service panels shall be sized to accommodate expected loads and future electrification needs.

Alternative Compliance Path: Efficient Mixed-Fuel Design - If a project proposes to install natural gas infrastructure or natural gas appliances, the project applicant shall implement a combination of GHG reduction measures sufficient to minimize GHG emissions from natural gas usage to the maximum extent feasible. Measures may include, but are not limited to, the following:
• Exceed Title 24, Part 6 (Building Energy Efficiency Standards) performance requirements by 10–20 percent, where feasible, as demonstrated through energy modeling or prescriptive
compliance documentation.
• Install on-site solar photovoltaic (PV) systems to the maximum feasible extent, including on rooftops and parking canopy structures, where structurally and technically feasible.

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026
S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A
P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.8 Greenhouse Gas Emissions_final.docx (03/11/26) 4.8-27 • Provide electric-ready infrastructure, including service panel capacity, conduit, wiring, and dedicated circuits, to allow future conversion to all-electric appliances and systems.
• Design buildings to achieve, at minimum, Leadership in Energy and Environmental Design (LEED) Silver certification or an equivalent third-party green building rating.
• Install programmable thermostats, advanced metering
infrastructure, and smart home energy management systems. • Provide heating, ventilation, and air conditioning (HVAC) commissioning consistent with CALGreen Code Sections 5.410.2–

5.410.4, including a commissioning plan, functional performance testing, and a commissioning report.
• Install cool roof materials meeting an aged solar reflectance of ≥

0.30, or the most current CALGreen Code requirement,
whichever is more stringent.
• Provide infrastructure to accommodate up to 50 percent recycled water use for landscape irrigation, where recycled water supply is available.
• Use water-efficient irrigation systems, minimize turf, and incorporate native, low-water, or drought-tolerant plant species. • Install rainwater harvesting systems, where feasible. • Prohibit or restrict the use of potable water for cleaning nonvegetated outdoor surfaces and prohibit systems that apply water to hardscape surfaces.
• Implement and maintain robust solid waste diversion programs, including recycling and organic waste collection consistent with Senate Bill (SB) 1383 requirements.

All selected GHG reduction measures shall be clearly identified on improvement plans and construction drawings. Compliance with this measure shall be verified by City staff during plan check and confirmed through building inspection prior to final occupancy.

Mitigation Measure AIR-1 Prior to issuance of grading permits for development projects in the Buildout Area, a future project applicant in collaboration with the City of Cypress (City) Planning Division shall identify project design details and specifications, where feasible, to document implementation and S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026

4.8 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.8 Greenhouse Gas Emissions_final.docx (03/11/26) -28 compliance with emission reduction measures. The City of Cypress Planning Division shall verify compliance through: (1) review and approval of construction drawings and building permit submittals demonstrating incorporation of the emission-reduction measures; (2) documentation or reporting from the contractor or a future project applicant, as deemed necessary by the City of Cypress Planning Division, demonstrating adherence to approved measures.

The measures below shall be implemented and updated as necessary as they are considered feasible and effective in reducing criteria pollutant emissions generated by the project. These measures shall be reviewed and updated in accordance with the most recent emission-reduction and emission-minimization guidance available, including, at a minimum, the California Air Pollution Control Officers Association (CAPCOA) 2024 guidance. A future project applicant shall incorporate all feasible and updated measures into the final construction drawings, building plans, and contractor specifications for City review, including, but not limited to, the following:
• Provide building access and paths which are physically separated from street parking lot traffic and that eliminate physical barriers such as walls, berms, landscaping and slopes that impede the use of pedestrians, bicycle facilities, or public transportation vehicles. • Provide continuous sidewalks separated from the roadway by landscaping and on street parking.
• Provide a parking lot design that includes clearly marked and shaded pedestrian pathways between transit facilities and building entrances.
• Provide preferential parking spaces near the entrance of buildings for those who carpool/vanpool/rideshare and provide signage.
• Install electric vehicle charging capabilities that meet the requirements of the latest version of the California Green Building Standards Code (CALGreen Code) Tier 2 Voluntary Standards.
• Install ENERGY STAR certified heating, cooling, and lighting devices, and appliances or equivalent.
• Install only electric fireplaces.
• Install low-flow water fixtures.

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026
S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A
P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.8 Greenhouse Gas Emissions_final.docx (03/11/26) 4.8-29 • Utilize energy-efficient design features, including appropriate site orientation, use of lighter color roofing and building materials, and use of deciduous shade trees and windbreak trees to reduce fuel consumption for heating and cooling.
• Use light-colored paving and roofing materials.
• Use low-volatile organic compound (VOC) paints with 10 grams per liter or less.
• Require the use of all-electric landscaping equipment. • Maximize the planting of trees in landscaping and parking lots.

Mitigation Measure TRA-1 Transportation Demand Management (TDM) Strategies. The Development Agreement between the City of Cypress and the Project Applicant governing the development of the Buildout Area shall include a provision requiring that any future project applicants for subsequent residential development projects within the Buildout Area demonstrate the project's consistency with the Specific Planlevel vehicle miles traveled (VMT) mitigation framework set forth in Items 1 and 2 below that are applicable to such project prior to its approval.

The project-level VMT Evaluation and TDM Plan shall be prepared to the satisfaction of the City of Cypress Planning Director.

1. Construct or Improve Bike Facility (California Air Pollution Control Officers Association [CAPCOA] Handbook Strategy T-19- A): This transportation demand management strategy requires 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 bike to their destination rather than drive, reducing the number of vehicle trips and overall project-generated VMT.

2. Provide Pedestrian Network Improvement (CAPCOA Handbook Strategy T-18): This transportation demand management
strategy requires the construction of off-site sidewalks to improve sidewalk coverage and pedestrian access to the
surrounding area.

4.8.9 Level of Significance after Mitigation
With implementation of Mitigation Measure GHG-1, Mitigation Measure AIR-1 and Mitigation Measure TRA-1, the proposed project’s incremental contribution to cumulative GHG emissions would S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026

4.8 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.8 Greenhouse Gas Emissions_final.docx (03/11/26) -30 be reduced and would not be cumulatively considerable. As discussed in Section 4.8.6, the project’s construction and operational GHG emissions were quantitatively estimated consistent with CEQA Guidelines Section 15064.4 and evaluated in the context of applicable statewide and regional greenhouse gas reduction frameworks, including the CARB 2022 Climate Change Scoping Plan and Connect SoCal 2024.

The project would implement planned housing growth identified in the City’s adopted and HCDcertified Housing Element and would not exceed regional growth assumptions incorporated into SCAG’s CARB-certified emissions modeling. In addition, applicable statewide regulatory programs and project-level mitigation measures would further reduce emissions over time.

Therefore, impacts related to the generation of greenhouse gas emissions, either directly or indirectly, and potential conflict with applicable plans, policies, or regulations adopted for the purpose of reducing GHG emissions would be less than significant with mitigation.

4.8.10 Cumulative Impacts
GHG impacts are by their nature cumulative impacts. Localized impacts of climate change are the result of the cumulative impact of global emissions. The combined benefits of reductions achieved by all levels of government help to slow or reverse the growth in GHG emissions. In the absence of comprehensive international agreements on appropriate levels of reductions achieved by each country, another measure of cumulative contribution is required. This serves to define the State’s share of the reductions regardless of the activities or lack of activities of other areas of the U.S. or the world. Therefore, a cumulative threshold based on consistency with State targets and actions to reduce GHGs is an appropriate standard of comparison for significance determinations.

As described above, both construction and operational GHG emissions associated with the proposed project were quantitatively estimated and evaluated in the context of statewide and regional planning frameworks, including the CARB 2022 Climate Change Scoping Plan and Connect SoCal 2024. The Scoping Plan’s project attributes are considered as qualitative guidance and are not applied as mandatory pass/fail significance thresholds. The proposed project incorporates key project attributes that are generally supportive of California’s long-term GHG emissions reduction goals and carbon neutrality objectives.

The proposed project represents planned infill growth within an existing urbanized area and has been identified as a key housing opportunity site in the City’s adopted and HCD-certified Housing Element.

Housing growth facilitated by the project would support the City’s RHNA goals, which are incorporated into SCAG’s RTP/SCS growth assumptions and associated GHG emissions modeling completed for Connect SoCal 2024. Therefore, the proposed project would not exceed regional growth projections or interfere with implementation of regional strategies to achieve SB 375 percapita GHG reduction targets.

In addition, implementation of project-specific mitigation measures would reduce project-related emissions, including:

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026
S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A
P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.8 Greenhouse Gas Emissions_final.docx (03/11/26) 4.8-31 • Mitigation Measure GHG-1, which requires future development to implement either all-electric building design or enhanced mixed-fuel energy performance standards supported by energy modeling and building efficiency measures;
• Mitigation Measure AIR-1, which includes measures such as electric vehicle charging infrastructure and related emission-reducing building and site design features; and • Mitigation Measure TRA-1, which requires transportation demand management strategies intended to reduce vehicle trips and support lower-emission travel options.

These measures, together with statewide regulatory programs such as SB 100, Advanced Clean Cars II, the Low Carbon Fuel Standard, Title 24 building efficiency standards, and SB 1383, will reduce emissions intensity over the life of the project.

Therefore, when considered in the context of applicable statewide and regional emissions reduction frameworks and implementation of project-specific mitigation measures, the project’s incremental contribution to cumulative GHG emissions would not be cumulatively considerable. Cumulative GHG impacts would be less than significant with mitigation.

S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T

CY P R E S S , C A L I F O R N I A

DR A F T EN V I R O N M E N T A L I M P A C T RE P O R T MA R C H 2026

4.8 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.8 Greenhouse Gas Emissions_final.docx (03/11/26) -32 This page intentionally left blank

DRAFT ENVIRONMENTAL IMPACT REPORT
MARCH 2026
SPECIFIC PLAN 3.0 BUILDOUT PROJECT

CYPRESS, CALIFORNIA

4.9 HAZARDS AND HAZARDOUS MATERIALS
This section evaluates the potential for implementation of the Specific Plan 3.0 Buildout Project (proposed project) to result in impacts to hazards and hazardous materials with consideration of local, State, and federal regulations and policies. This section also describes the existing setting for hazards and hazardous materials conditions at the Buildout Area, relates potentially significant adverse public health impacts anticipated as a result of the proposed project, and provides recommended measures pursuant to the California Environmental Quality Act {CEQA).

The hazards and hazardous materials analysis in this section is based in part on the technical analysis contained in the Phase I Environmental Site Assessment Report Update, Los Alamitos Race Course Redevelopment, 4961 Kate/la Avenue, Cypress, California 90720 (Phase I ESA) 1 (Appendix G), prepared for the proposed project by Partner Engineering and Science, Inc. (Partner Engineering).

4.9.1 Scoping Process
The City of Cypress {City) received six comment letters during the public review period of the Notice of Preparation {NOP). For copies of the NOP comment letters, refer to Appendix A of this Draft Environmental Impact Report (Draft EIR). None of the comment letters included comments related to hazards and hazardous materials.

4.9.2 Methodology
Generally, hazardous materials are chemicals that could potentially cause harm during an accidental release or mishap, and are defined as being toxic, corrosive, flammable, reactive, and an irritant, or strong sensitizer. 2 Hazardous substances include all chemicals regulated under the United States Department of Transportation {USDOT) "hazardous materials" regulations and the United States Environmental Protection Agency {USEPA) "hazardous waste" regulations. Hazardous materials require special handling and disposal because of their potential to damage public health and the environment. The probable frequency and severity of consequences from the routine transport, use, or disposal of hazardous materials is affected by the type of substance, the quantity used or managed, and the nature of the activities and operations.

To assess the impacts of the proposed project with respect to hazardous materials, Partner Engineering performed a Phase I ESA for the Buildout Area.

Partner Engineering performed the Phase I ESA in general accordance with the American Society for Testing Materials (ASTM) Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process (ASTM E1527-21) 3 in an effort to identify, to the extent 2 3
Partner Engineering and Science, Inc. 2025. Phase I Environmental Site Assessment Report Update, Los Alamitos Race Course Redevelopment, 4961 Kate/la Avenue, Cypress, California 90720. July 17. (Appendix G)
A "sensitizer" is a chemical that can cause a substantial proportion of people or animals to develop an allergic reaction in normal tissue after repeated exposure to a chemical.

ASTM Standard E1527-21 constitutes "all appropriate inquiry into the previous ownership and uses of the property consistent with good commercial or customary practice" as defined at 42 United States Code §9601(35)(B).

P:\A-E\CCP2201.0S LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.9 Hazards and Hazardous Materials.docx (03/10/26) 4.9-1 SPECIFIC PLAN 3.0 BUI LOO UT PROJECT

CYPRESS, CALIFORNIA

DRAFT EN VIRONMENTAL IMPACT REPORT
MARCH 2026
feasible, potential Recognized Environmental Conditions (RECs) 4 affecting the Buildout Area that:
(1) constitute or result in a material violation or a potential material violation of any applicable environmental law; (2) impose any material constraints on the operation of the Buildout Area or require a material change in the use thereof; (3) require clean-up, remedial action or other response with respect to hazardous substances or petroleum products on or affecting the Buildout Area under any applicable environmental law; (4) may affect the value of the Buildout Area; and (5) may require specific actions to be performed with regard to such conditions and circumstances.

4.9.2.1 Background Research and Data Review
Partner Engineering performed a records review for the Buildout Area and surrounding properties in an effort to identify potential RECs in connection with the Buildout Area and assess potential concerns associated with the migration of hazardous substances to the Buildout Area from off-site sources. The records review included reasonably ascertainable historical data, which can be helpful in identifying the past uses of the Buildout Area and surrounding areas, as they may relate to the environmental condition of the Buildout Area.

4.9.2.2 Site Reconnaissance
On July 7, 2025, Partner Engineering visually assessed the Buildout Area for potential RECs, including, but not limited to, potential underground storage tanks, aboveground storage tanks, polychlorinated biphenyl (PCB)-containing equipment, hazardous materials storage or handling areas, containerized or bulk wastes, and visual indications of impacted soil.

4.9.2.3 Testing and Evaluation
As part of the Phase I ESA, Partner Engineering reviewed previous subsurface investigations for the Buildout Area and a nearby property (5100 Katella Avenue).

4.9.3 Existing Environmental Setting
The Buildout Area has a generally flat topography with a gentle slope towards the west. The approximate elevation of the Buildout Area is 33 feet above mean sea level. The Buildout Area is surrounded by a variety of commercial, office, business park, retail, residential, park and religious uses. Additionally, the Buildout Area is bounded by W. Cerritos Avenue to the north, several existing commercial and institutional uses along and near Walker Street to the east, Katella Avenue and several existing commercial, retail and residential uses to the south, and Lexington Drive to the west. Immediately northwest of the Buildout Area is Lexington Park, a 9-acre park located at 4600 W. Cerritos Avenue at the southeast corner of the Cerritos Avenue/Lexington Drive intersection.
4 A recognized environmental condition (REC) refers to the presence of hazardous substances or petroleum products in, on, or at the project site due to a release to the environment; the likely presence of hazardous substances or petroleum products in, on, or at the project site due to a release or likely release to the environment; or the presence of hazardous substances or petroleum products in, on, or at the project site under conditions that pose a material threat of a future release to the environment.

4.9-2 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.9 Hazards and Hazardous Materials.docx (03/10/26)

DRAFT ENVIRONMENTAL IMPACT REPORT
MARCH 2026
SPECIFIC PLAN 3.0 BUILDOUT PROJECT

CYPRESS, CALIFORNIA
Immediately east and north of the Buildout Area is Grace Church, located at 5100 W. Cerritos Avenue. Southeast of the Buildout Area is the Belmont residential project developed by Melia Homes, which includes only residential uses, and The Square at Cypress developed by Shea Homes, which includes residential, hotel, retail, and service uses, including the Homewood Suites by Hilton Cypress Orange County located at 5233 Katella Avenue and a Costco Wholesale at 5401 Katella Avenue. Cottonwood Church, located at 4505 Katella Avenue, is located southwest of the Buildout Area, along with the Ovation at Flora Park, a senior housing community, and a commercial center that includes restaurant and commercial services uses, a 24 Hour Fitness, and the Residence Inn Cypress Los Alamitos, at 4931 Katella Avenue. West of Lexington Drive are light industrial, office, and commercial uses. The 134-acre Buildout Area consists of three properties that contain existing structures and developed areas as detailed below:

Los Alamitos Race Course (LARC) Property (approximately 97 acres): A variety of existing structures and facilities are located on the LARC Property that support horse racing, training, and community activities. Structures include a race track, grandstand structure, two artificial lakes inside the race track, one-story clubhouse and restaurant structures, lighting structures, approximately 41 permanent one-story barns and several temporary structures and barns. The LARC Property also contains parking areas, landscaping, drainage features, sheds, maintenance areas, and perimeter fencing.

The LARC Property's primary structures include the Main Grandstand and Clubhouse Building. The Main Grandstand, built in 1958, is a five-story, 140,000-square-foot structure standing approximately 65 feet high, with a seating capacity of 6,500 people. The Clubhouse Building, constructed in 1955, is a two-story, 35,000-square-foot structure with a capacity of 2,900 people, including an additional 25,000 square feet of patron space. As noted, there are a total of approximately 41 barns supporting the horse racing and training operations on the LARC Property.

This includes 36 cinder block barns built in 1958, each approximately 14,000 square feet (totaling 504,000 square feet). Additionally, there are five modular-style barns built in 2013, each about 12,480 square feet (totaling 62,400 square feet). The LARC Property also features the 1,960-squarefoot Horseman's Restaurant, constructed in 1999, along with various temporary structures.

Cypress Golf Course (approximately 33 acres): The Cypress GC Property includes a portion of the former Cypress Golf Club, which ceased operation years ago. LARC currently uses approximately one acre of the Cypress GC Property (designated as Lot 1 in Vesting Tentative Tract Map (VTTM) 19247) as a maintenance yard, while the clubhouse for the former Cypress Golf Club is presently being used as a church.

Grace Church Property (approximately 4 acres): The land owned by Grace Church within the Buildout Area, designated as Lots 5 and 10 in VTTM 19247, is part of a larger church property that is currently used for religious services and events and includes a small school, open space and parking areas.

According to aerial photographs, topographic maps, and a City directory obtained from Environmental Data Resources, Inc. (EDR) (provided in Appendix G), the Buildout Area was formerly agricultural land as early as 1928; developed with barns associated with the race course by 1952; developed with the current grandstand and race course by 1962; and developed with the current P:\A-E\CCP2201.0S LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.9 Hazards and Hazardous Materials.docx (03/10/26) 4.9-3 SPECIFIC PLAN 3.0 BUI LOO UT PROJECT

CYPRESS, CALIFORNIA

DRAFT ENVIRONMENTAL IMPACT REPORT
MARCH 2026
race course, barns, and church structure by 1994. Tenants on the Buildout Area have included Cypress Golf Club (1996-2001); Tee Time Res (2001); Cypress Junior Golf League (2003); Cypress GC LLC, Seventh-Day Adventist Church (2007-present); Cottonwood Christian Center (2011); and Los Alamitos Race Course and Occupants (1952-present).

The site reconnaissance conducted by Partner Engineering at the Buildout Area did not identify any RECs within the Buildout Area. The site reconnaissance did, however, identify a controlled recognized environmental condition (CREC) 5 associated with four petroleum underground storage tanks (USTs) that were removed from the receiving barn area in the southwest exterior of the race track. The USTs consisted of two 10,000-gallon, one 2,000-gallon, and one 1,000-gallon tank. The tanks contained gasoline and diesel and were used to fuel the various maintenance vehicles on site.

Regulatory closure for the former USTs was issued by the Orange County Health Care Agency (OCHCA) on June 26, 1996. Based on the removal of the tanks, the limited residual contamination, and the regulatory closure with a land use stipulation, the site is considered a CREC.

The site reconnaissance also identified a Historical Recognized Environmental Condition (HREC) associated with a 2,000-gallon, two-compartment UST used for gasoline and diesel fuel. The UST, located in the former golf course maintenance area near Lexington Drive (now 4511 Katella Avenue; Assessor's Parcel Number [APN] 241-221-32), 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.

The Phase I ESA also identified a potential business environmental risk (BER), associated with the age of the existing buildings within the Buildout Area. Due to the age of the existing buildings, Partner Engineering identified a potential that asbestos-containing materials (ACMs) and/or leadbased paint (LBP) are present. However, Partner Engineering noted that all suspect ACMs and painted surfaces were observed in good condition and do not pose a health and safety concern to the occupants of the subject property at this time.

In addition, the Phase I ESA identified potential environmental hazards at the Buildout Area, including the following:

1. Hazardous substances including approximately 20 or more 20-gallon propane tanks and one GO-gallon propane tank for on-site use, located on the western exterior of the grandstand;

2. Seven 55-gallon drums of bleach near the domestic well area, on the southern portion of the Buildout Area;

3. Various emergency generators near the exterior of the grandstand structure; 5 An REC affecting the Buildout Area that has been addressed to the satisfaction of the applicable regulatory authority or authorities with hazardous substances or petroleum products allowed to remain in place subject to implementation of required controls.

4.9-4 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.9 Hazards and Hazardous Materials.docx (03/10/26)

DRAFT ENVIRONMENTAL IMPACT REPORT
MARCH 2026
SPECIFIC PLAN 3.0 BUILDOUT PROJECT

CYPRESS, CALIFORNIA

4. A 100,000-gallon empty Aboveground Storage Tank (AST) and a 50,000-gallon AST filled with water, located on the southwest portion of the Buildout Area, southwest of the grandstand structure; and

5. Electrical equipment that Partner Engineering determined is unlikely to contain PCBs.

A limited non-intrusive vapor screening was completed at the Buildout Area to identify, to the extent feasible, the potential for vapor encroachment conditions (VECs) in connection with the Buildout Area. The screening determined that vapor intrusion is unlikely to be an issue of concern in connection with the existing structures on the Buildout Area. The Buildout Area was visually inspected for the presence of ACMs and given the relative age of the buildings, which were constructed in 1963, there are suspect ACMs in the drywall systems, floor tiles, floor tile mastic, and acoustical ceiling tiles of the church, grandstand, and barn areas.

The Phase I ESA determined that the Buildout Area is located in USEPA Radon Zone 3, which has a low potential for radon (less than 2.0 picocuries per liter [pCi/L]), and therefore radon is not considered an environmental concern. Due to the commercial nature of the Buildout Area, LBP was not included in the scope of the Phase I ESA. No obvious indications of water damage or mold growth were observed during the visual inspection. No hazardous substances, ASTs or USTs, or PCBcontaining materials were observed on adjoining properties during the limited adjoining property reconnaissance.

4.9.4 Regulatory Setting
Hazards and hazardous materials are subject to numerous federal, State, and local laws and regulations intended to protect health, safety, and the environment. The USEPA, the California Environmental Protection Agency (Cal/EPA), the California Department of Toxic Substance Control (DTSC), the Santa Ana Regional Water Quality Control Board (RWQCB), and the County of Orange (County) are the primary agencies responsible for enforcing these regulations. Local regulatory agencies enforce many federal and State regulations through the Certified Unified Program Agency (CUPA) program.

The following section describes the federal, State, regional, and local regulatory framework applicable to analyzing potential impacts related to hazards and hazardous materials from development of the proposed project.

4.9.4.1 Federal Regulations
Occupational Safety and Health Administration (OSHA), Title 29 Code of Federal Regulations (CFR).

OSHA is the federal agency responsible for ensuring worker safety. These regulations provide standards for safe workplaces and work practices, including those relating to hazardous materials handling.

United States Environmental Protection Agency (USEPA), Title 40 Code of Federal Regulations (CFR) 700-799 (Toxic Substances Control Act). The Toxic Substances Control Act regulates manufacturing, inventory, and disposition of industrial chemicals, including hazardous materials.

P:\A-E\CCP2201.0S LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.9 Hazards and Hazardous Materials.docx (03/10/26) 4.9-5 SPECIFIC PLAN 3.0 BUI LOO UT PROJECT

CYPRESS, CALIFORNIA

DRAFT ENVIRONMENTAL IMPACT REPORT
MARCH 2026
It addresses the production, importation, use, and disposal of specific chemicals including PCBs, ACMs, and LBP.

United States Department of Transportation (USDOT) Regulations, Title 49 Code of Federal Regulations (CFR). USDOT, in conjunction with the USEPA, is responsible for enforcement and implementation of federal laws and regulations pertaining to safe storage and transportation of hazardous materials. CFR 49, 171-180, regulates the transportation of hazardous materials, types of material defined as hazardous, and the marking of vehicles transporting hazardous materials.

Federal Air Regulations, Part 77. The Federal Aviation Administration (FAA) is responsible for the review of construction activities that occur in the vicinity of airports. Its role in reviewing these activities is to ensure that new structures do not result in a hazard to navigation. The regulations in the Federal Air Regulations (14 CFR, Part 77) are designed to ensure that no obstructions in navigable air space are allowed to exist that would endanger the public. Federal Air Regulations Part 77 identifies the maximum height at which a structure would be considered an obstacle at any given point around an airport. The extent of the off-airport coverage that needs to be evaluated for tall structure impacts can extend miles from an airport facility. In addition, Federal Air Regulations Part 77 establishes standards for determining whether objects constructed near airports will be considered obstructions in navigable airspace, sets forth notice requirements of certain types of proposed construction or alterations, and provides for aeronautical studies to determine the potential impacts of a structure on the flight of aircraft through navigable airspace.

Resource Conservation and Recovery Act. The Resource Conservation and Recovery Act (RCRA) of 1976 is administered by the USEPA and regulates hazardous waste (materials that have already been discarded or are destined for disposal, treatment, or recycling) from its creation through transport, treatment, storage, and disposal. Its purpose is to protect human health and the environment by ensuring hazardous wastes are properly identified, tracked, and handled. RCRA works alongside USDOT hazardous materials rules, which cover safe transport, to create a complete system for controlling dangerous substances.

Comprehensive Environmental Response, Compensation, and Liability Act. The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980 is administered by the USEPA and regulates hazardous substances that have already been released, or threaten to be released, into the environment. The CERCLA allows the federal government to respond to chemical spills, leaks, or contaminated sites; establishes a cleanup process and gives the USEPA authority to make responsible parties (past or present owners, operators, transporters, or arrangers) pay for cleanup costs; and created the Superfund trust fund to pay for cleanups when no responsible party can be found.

4.9.4.2 State Regulations
State Assembly Bill 2948. In response to the growing statewide concern of hazardous waste management, Assembly Bill 2948 (Tanner 1986) enacted legislation authorizing local governments to develop comprehensive hazardous waste management plans. The intent of each plan is to assure that adequate treatment and disposal capacity is available to manage the hazardous wastes generated within its jurisdiction.

4.9-6 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.9 Hazards and Hazardous Materials.docx (03/10/26)

DRAFT ENVIRONMENTAL IMPACT REPORT
MARCH 2026
SPECIFIC PLAN 3.0 BUILDOUT PROJECT

CYPRESS, CALIFORNIA
California Occupational Safety and Health Administration (Cal/OSHA) Regulations. Cal/OSHA is responsible for developing and enforcing workplace safety standards and assuring worker safety in the handling and use of hazardous materials. Among other requirements, Cal/OSHA requires many entities to prepare injury and illness prevention plans and chemical hygiene plans and provides specific regulations to limit exposure of construction workers to lead.

Cortese List Statute (California Government Code, §65962.5). This regulation requires the California DTSC to compile and maintain lists of potentially contaminated sites throughout the State and includes the Hazardous Waste and Substances Sites List. The overall list is called the "Cortese" List.

Safe Drinking Water and Toxic Enforcement Act (Proposition 65, California Health and Safety Code, §25249.5 et seq.). The Safe Drinking Water and Toxic Enforcement Act is similar to the federal Safe Drinking Water Act and Clean Water Act in that it regulates the discharge of contaminants to groundwater.

Hazardous Waste Control Law. The Hazardous Waste Control Law (HWCL) regulates hazardous waste, working in parallel with the federal RCRA program. Its purpose is to protect public health and the environment by requiring that hazardous wastes are properly identified, tracked, stored, treated, transported, and disposed of. The law gives the California DTSC primary authority to oversee hazardous waste generators and facilities, and in many areas, it is stricter than the federal RCRA, setting additional requirements specific to California.

4.9.4.3 Regional Regulations
Certified Unified Program Agency (CUPA). Senate Bill 1082 provides for the designation of a CUPA that would be responsible for the permitting process and collection of fees regarding hazardous materials. The CUPA would be responsible for implementing at the local level the Unified Program, which serves to consolidate, coordinate, and make consistent the administrative requirements, permits, inspections, and enforcement activities for the following environmental and emergency management programs: Hazardous Waste; Hazardous Materials Business Plan; California Accidental Release Prevention Program; Underground Hazardous Materials Storage Tanks; Aboveground Petroleum Storage Tanks/Spill Prevention Control & Countermeasure Plans; and Hazardous Waste Generator and On-Site Hazardous Waste Treatment (tiered permitting) Programs.

The Environmental Health Division of the OCHCA is designated as the CUPA for the City, and coordinates the regulation of hazardous materials and hazardous wastes in the City for construction and operational activities through the following programs:
• Aboveground Petroleum Storage Tank (APST)
• Business Emergency Plan (BEP)
• California Accidental Release Prevention (CalARP)
• Hazardous Materials Disclosure (HMD)
• Hazardous Waste (HW)
• Underground Storage Tank (UST)
P:\A-E\CCP2201.0S LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.9 Hazards and Hazardous Materials.docx (03/10/26) 4.9-7 SPECIFIC PLAN 3.0 BUI LOO UT PROJECT

CYPRESS, CALIFORNIA

DRAFT EN VIRONMENTAL IMPACT REPORT
MARCH 2026
The Orange County Fire Authority (OCFA) is the administering agency for the chemical inventory and business emergency plan regulations for the City. OCFA's disclosure activities are coordinated with the OCHCA. OCFA's Hazardous Materials Services Section (HMSS) is staffed with technical and administrative personnel who are assigned the implementation and management of the disclosure program.

County of Orange and Orange County Fire Authority {OCFA) Local Hazard Mitigation Plan {2021).

This plan identifies risks and vulnerabilities, establishes hazard mitigation strategies, describes emergency organization, task assignments, and general procedures, and provides for coordination of response in the event of an emergency.

Airport Environs Land Use Plan for Joint Forces Training Base Los Alamitos. The Airport Environs Land Use Plan for Joint Forces Training Base Los Alamitos was developed by the Orange County Airport Land Use Commission (ALUC) and serves to ensure safe and compatible development in areas surrounding the military airfield.

South Coast Air Quality Management District Rule 1403. Rule 1403, issued by the South Coast Air Quality Management District (SCAQMD), establishes mandatory work-practice standards to limit asbestos emissions during building demolition, renovation, and related activities where ACMs may be disturbed. Rule 1403 also enforces the requirements for asbestos surveys, prior notification, safe removal, cleanup procedures, and proper disposal of asbestos-containing waste material (ACWM).

4.9.4.4 Local Regulations
Cypress Town Center and Commons Specific Plan 3.0. The Cypress Town Center and Commons Specific Plan 3.0 (Specific Plan) contains applicable goals from the Safety Element of the City of Cypress General Plan, including Goals SAF-3, SAF-5, and SAF-8, as detailed below. The Specific Plan also states that any use, storage, or transport of hazardous materials would be in accordance with all applicable federal, State and local laws. The Specific Plan further states that development pursuant to the Specific Plan will be consistent with the height and noise limitations and notification requirements in the ALUC's 2017 Airport Environs Land Use Plan (AELUP) for Joint Forces Training Base (JFTB) Los Alamitos, 6 as described in the Safety Element of the City of Cypress General Plan. On July 18, 2024, the ALUC voted in favor of the staff recommendation to find the Specific Plan consistent with the AELUP for JFTB Los Alamitos.

City of Cypress General Plan 2001. The Safety Element of the City of Cypress General Plan contains the following applicable goals and policies related to hazards and hazardous materials:
• SAF-3 Hazardous Materials. Minimize risks to life and property associated with the handling, transporting, treating, generating, and storing of hazardous materials. 6 o SAF-3.1: Locate new and relocate existing land uses that utilize, produce, transport, or store hazardous materials a safe distance from other land uses that may be adversely affected by such activities.

Orange County Airport Land Use Commission (ALUC). 2017. Airport Environs Land Use Plan (AELUP) for Joint Forces Training Base (JFTB) Los Alamitos. Amended August 17, 2017.

4.9-8 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.9 Hazards and Hazardous Materials.docx (03/10/26)

DRAFT ENVIRONMENTAL IMPACT REPORT
MARCH 2026
SPECIFIC PLAN 3.0 BUILDOUT PROJECT

CYPRESS, CALIFORNIA
o SAF-3.2: Encourage and support the proper disposal of household waste and waste oil.

Monitor dry cleaners, film processors, auto service establishments, and other businesses generating hazardous waste materials to ensure compliance with approved disposal procedures.
o SAF-3.3: Prosecute unlicensed dumping of toxic or hazardous materials into the ground or water in Cypress. Increase the fines levied for illegal dumping. Encourage citizens to report dumping when they observe it.
o SAF-3.4: Support efforts to enforce State "right to know" laws, which outline the public's right to information about local toxics producers.
• SAF-5 Fire Protection. Protect life and property in Cypress from urban fires. Maintain the Orange County Fire Authority's high level of service to community businesses and residents. o SAF-5.1: Maintain a response time of eight minutes for the first responder engine and provide paramedic service within five minutes.
o SAF-5.2: Evaluate the effects of new development on the Orange County Fire Authority's response time. Ensure through the development review process that new development will not result in reduced emergency service levels.
o SAF-5.3: Maintain and periodically review procedures for dealing with fire emergencies in the City's Disaster Plan.
o SAF-5.4: Establish evacuation routes for an urban fire. o SAF-5.5: Maintain mutual aid agreements with surrounding jurisdictions for fire protection. o SAF-5.6: Provide adequate fire equipment access to structures within the community. o SAF-5.7: Maintain an ongoing fire inspection program to reduce fire hazards associated with older buildings, critical facilities, public assembly facilities, and industrial and commercial buildings.
o SAF-5.8: Promote the utilization of fire-safe building materials and enforce the City's fire sprinkler ordinance.
• SAF-8 Aircraft Overflight. Protect Cypress residents from air operation accidents. o SAF-8.1: Limit development height within the flight approach to the Joint Forces Training Center (JFTC) Los Alamitos to minimize safety hazards to aircraft and protect the airfield. o SAF-8.2: Monitor legislation and regulations established by the Joint Forces Training Center (JFTC) Los Alamitos.
o SAF-8.3: Establish an emergency response plan for aircraft incidents.

P:\A-E\CCP2201.0S LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.9 Hazards and Hazardous Materials.docx (03/10/26) 4.9-9 SPECIFIC PLAN 3.0 BUI LOO UT PROJECT

CYPRESS, CALIFORNIA

DRAFT EN VIRONMENTAL IMPACT REPORT
MARCH 2026
City of Cypress Municipal Code. Article 3, Section 10.050 (Hazardous Materials Storage) of the Cypress Municipal Code includes the regulations that would apply to the proposed project related to the provision of hazardous materials. The intent of this chapter is to ensure that the use, handling, storage, and transportation of hazardous substances comply with all applicable State laws (Government Code Section 65850.2 and Health and Safety Code Section 25505, et seq.) and that appropriate information is reported to the City in a timely manner.

4.9.5 Thresholds of Significance
The thresholds of significance for hazards and hazardous materials impacts used in this analysis are consistent with Appendix G of the State CEQA Guidelines. Based on these thresholds, implementation of the proposed project would have a significant impact with respect to hazards and hazardous materials if it would:

Threshold 4.9.1:

Threshold 4.9.2:

Threshold 4.9.3:

Threshold 4.9.4:

Threshold 4.9.5:

Threshold 4.9.6:

Threshold 4.9.7:

Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials; Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment;
Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school;
Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would create a significant hazard to the public or the environment; For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area;
Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan; or Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wild land fires.

4.9.6 Project Impacts
Threshold 4.9.1:

4.9-10
Would the project create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials?
P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.9 Hazards and Hazardous Materials.docx (03/10/26)

DRAFT ENVIRONMENTAL IMPACT REPORT
MARCH 2026
SPECIFIC PLAN 3.0 BUILDOUT PROJECT

CYPRESS, CALIFORNIA
Less Than Significant Impact. The proposed project would not involve the routine transport of hazardous materials to and from the Buildout Area. During demolition, excavation, on-site grading, and building construction, hazardous materials such as fuels and oils associated with construction equipment, as well as paints, solvents, cement products containing strong basic or acidic chemicals could be routinely used in the Buildout Area throughout construction. These materials are commonly used at construction sites. The amount of hazardous chemicals present during construction would be limited to what is required to operate construction equipment, and construction activities would be required to comply with applicable State and federal regulations for proper transport, use, storage, and disposal of excess hazardous materials and hazardous construction waste. The temporary transport, use, storage, or disposal of fuels, lubricants, paints, and other hazardous materials related to construction would not pose a significant hazard to the public or the environment unless the materials were accidentally spilled or released into the environment. The potential for the release of hazardous materials during project construction is low, and even if a release were to occur, it would not result in a significant hazard to the public, surrounding land uses, or the environment due to the small quantities of these materials associated with construction vehicles. In addition, California standards for workers dealing with hazardous materials are contained in California Code of Regulations (CCR) Title 8 and include practices for all industries (General Industrial Safety Orders), as well as specific practices for construction. Workers at hazardous waste sites (or workers who may be exposed to hazardous wastes that might be encountered during excavation of contaminated soils) must receive specialized training and medical supervision according to the Hazardous Waste Operations and Emergency Response regulations. 7 Additional regulations have been developed for construction workers potentially exposed to lead8 and asbestos.9
The transport, use, storage, or disposal of hazardous materials during construction would be regulated by the OCFA and Cal/OSHA. Additionally, the USDOT Office of Hazardous Materials Safety prescribes strict regulations for the safe transportation of hazardous materials by truck and rail on State highways and rail lines, as described in CFR Title 49 and implemented by CCR Title 13. Worker health and safety is also regulated at the federal level by the United States Department of Labor OSHA. OSHA regulations include training requirements for construction workers and a requirement that hazardous materials are accompanied by manufacturer's Safety Data Sheets (SDSs). The Federal Occupational Safety and Health Act of 1970 authorizes states to establish their own safety and health programs with OSHA approval. Worker health and safety protections in California are regulated by the California Department of Industrial Relations (DIR). The DIR includes the Division of Occupational Safety and Health (DOSH), better known as Cal/OSHA, which acts to protect workers from safety hazards. Cal/OSHA regulations include requirements for protective clothing, training, and limits on exposure to hazardous materials. California standards for workers dealing with hazardous materials are contained in CCR Title 8 and include practices for all industries (General Industrial Safety Orders), and specific practices for construction, and other industries. The routine transport, use, and disposal of hazardous materials within the Buildout Area during construction activities would be required to comply with a project Health and Safety Plan (HASP) prepared in accordance with CCR Title 8, which would reduce potential health hazards for construction workers 7 8
9 California Code of Regulations, Title 8, Section 5192.

California Code of Regulations, Title 8, Section 1532.1.

California Code of Regulations, Title 8, Section 1529.

P:\A-E\CCP2201.0S LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.9 Hazards and Hazardous Materials.docx (03/10/26) 4.9-11 SPECIFIC PLAN 3.0 BUI LOO UT PROJECT

CYPRESS, CALIFORNIA

DRAFT EN VIRONMENTAL IMPACT REPORT
MARCH 2026
from the routine transport, use, or disposal of hazardous materials. Construction activities would comply with applicable regulations, as outlined above, including requiring hazardous materials carriers to register with the DTSC as required by the USDOT, which regulates the transport of hazardous materials and waste in connection with construction activities. In addition, Regulatory Compliance Measures HYD-1 through HYD-3, provided in Section 4.10, Hydrology and Water Quality, would ensure compliance with waste discharge permit requirements to avoid potential impacts to water quality due to spills or runoff from hazardous materials used during construction.

Therefore, impacts related to the routine transport, use, or disposal of hazardous materials during demolition would be less than significant. No mitigation measures would be required.

The proposed project would include development of up to 1,791 new residential units within the Buildout Area, reflecting the remaining allowable units under the Specific Plan after accounting for the previously constructed 135-unit Belmont residential project. In addition, the proposed project is anticipated to include approximately 440,000 square feet of non-residential development, which represents about 50 percent of the 879,170 square feet permitted under the Specific Plan.

Operation of residential uses typically do not present a hazard associated with the accidental release of hazardous substances into the environment because residents are not anticipated to use, store, dispose of, or transport large volumes of hazardous materials. Hazardous substances associated with residential uses are typically limited in both amount and use, such that they can be contained without impacting the environment. In addition, the proposed non-residential uses would include commercial space pursuant to the Specific Plan that is intended to provide retail and other serviceoriented uses. These types of non-residential uses would use minimal amounts of hazardous materials during operations that would be similar to those used by residential uses (i.e., cleaning products, pesticides/herbicides/fertilizers associated with landscaping), and therefore are also unlikely to present a hazard associated with the accidental release of hazardous substances into the environment.

Long-term operations activities typical of the residential and non-residential uses envisioned under the proposed project involve the use and storage of small quantities of potentially hazardous materials in the form of cleaning solvents, fertilizers, and pesticides. For example, maintenance activities related to landscaping include the use of fertilizers and light equipment (e.g., lawn mowers and edgers) that may require fuel. As stated previously, these types of activities do not involve the use of a large or substantial amount of hazardous materials. Further, such materials would be contained, stored, and used in accordance with manufacturers' instructions and handled in compliance with applicable federal, State, and local regulations. In addition, operation of future residential and non-residential development associated with the proposed project would not store, transport, generate, or dispose of large quantities of hazardous substances. Therefore, potential impacts from the routine transport, use, or disposal of hazardous materials resulting from operation of the proposed project would be less than significant, and no mitigation would be required.

The City's Safety Element, 10 which includes Goals SAF-3, SAF-5, and SAF-8 and the associated policies discussed in Section 4.9.4, establishes the framework for addressing public safety hazards, including those related to hazardous materials. Additionally, the OCFA HMSS and the Environmental 1° City of Cypress. 2001. Cypress General Plan Safety Element. Website: https://www.cypressca. org/ home/showpublisheddocument/11369/638061 699910600000 (accessed August 2025).

4.9-12 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.9 Hazards and Hazardous Materials.docx (03/10/26)

DRAFT EN VI RONMENTAL IMPACT REPO RT
M ARCH 2026
SPECIFIC PLAN 3.0 BU ILDOUT PROJECT

CYPRESS, CALIFO RNIA
Health Division of the OCHCA serve as the primary agencies overseeing hazardous materials management within the City. The County's Hazardous Material Management Plan 11 ensures that adequate treatment and disposal capacity is available to manage the hazardous waste generated within the County and addresses issues related to the disposal, handling, processing, storage, and treatment of local hazardous materials and waste products.

Future development applications within the Buildout Area would be required to comply with all applicable regulations and standards related to the proper transport, use, storage, and disposal of hazardous materials and hazardous waste. Additionally, future developments would be reviewed by the OCFA for hazardous materials and would be required to comply with waste discharge permit requirements to avoid potential impacts to water quality due to spills or runoff from hazardous materials used during construction. Moreover, any future development projects requiring discretionary actions would be subject to environmental review, in accordance with the provisions of CEQA and the State CEQA Guidelines.

Therefore, implementation of the proposed project would result in less than significant impacts related to the routine transport, use, or disposal of hazardous materials, and no mitigation is required.

Threshold 4.9.2: Would the project create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?
Less Than Significant with Mitigation Incorporated. The Buildout Area was historically used for agricultural purposes until approximately 1947. Based on historical agricultural use, pesticides, or herbicides may have been utilized on the Buildout Area and near-surface soils may have at one time contained these compounds. However, the soils on the Buildout Area were reworked when the Buildout Area was developed beginning in the 1950s, and, therefore, it is not anticipated that any hazardous materials in the soil remain related to past agricultural use.

The Phase I ESA concluded that there was no evidence of RECs at the Buildout Area. However, one CREC was identified 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. Soil and groundwater remediation took place between 1989 and 1993, utilizing vapor extraction and groundwater treatment systems. 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 proposed project includes changes to the existing land uses in the Buildout Area, so a copy of this Draft EIR and the Notice of Completion (NOC) will be provided to OCHCA, as specified in Mitigation Measure HAZ-1 and provided below. No active remediation systems or groundwater monitoring wells are currently present within the Buildout Area.
11 Orange County Fire Authority (OCFA). 2007. Hazardous Material Management Plan. Hazardous Materials Identification. December 6, 2007.

P:\A-E\CCP2201.0S LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.9 Hazards and Hazardous Materials.docx (03/10/26) 4.9-13 SPECIFIC PLAN 3.0 BUI LOO UT PROJECT

CYPRESS, CALIFORNIA

DRAFT EN VIRONMENTAL IMPACT REPORT
MARCH 2026
The Phase I ESA also identified an HREC associated with a 2,000-gallon, two-compartment UST used for gasoline and diesel fuel. The UST, located in the former golf course maintenance area near Lexington Drive (now 4511 Katella Avenue; APN 241-221-32), 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.

Additionally, the Phase I ESA identified one potential BER associated with the age of the buildings on site, which may include ACMs or LBP. In accordance with SCAQMD Rule 1403, a comprehensive asbestos survey would be required prior to demolition. All identified ACMs and suspect materials would be removed by a certified asbestos abatement contractor in accordance with applicable regulations. Therefore, through compliance with applicable regulations, the proposed project would not create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving ACMs, and impacts would be less than significant.

The identified presence of a CREC, an HREC, and a BER in association with the Buildout Area represents a potentially significant impact associated with creating a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment. To address this potentially significant impact, the Phase I ESA recommended preparation and implementation of an Operations and Maintenance (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. No additional subsurface investigations were recommended. Future development facilitated by the proposed project would be required to implement these recommendations, as detailed in Mitigation Measure HAZ-1.

Based on the analysis provided above, impacts associated with the release of hazardous materials into the environment through reasonably foreseeable upset and accident conditions would be less than significant with adherence to existing regulatory requirements, including SCAQMD Rule 1403, and implementation of Mitigation Measure HAZ-1, requiring implementation of the recommendations provided in the Phase I ESA. Therefore, with incorporation of Mitigation Measure HAZ-1, project impacts would be less than significant.

Threshold 4.9.3: Would the project emit hazardous emIssIons or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school?
Less Than Significant Impact. There are five schools located within 0.25 mile of the Buildout Area :
• Grace Christian School, a religious school located at 4545 Myra Avenue; • Del Sol School, a non-public school located at 5400 Myra Avenue; • Little School of the West, a preschool located at 5471 West Cerritos Avenue; • Miracle Land Preschool, a preschool located at 4371 West Cerritos Avenue; and • Sycamore Creek Charter School, located at 4321 West Cerritos Avenue.

4.9-14 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.9 Hazards and Hazardous Materials.docx (03/10/26)

DRAFT ENVIRONMENTAL IMPACT REPORT
MARCH 2026
SPECIFIC PLAN 3.0 BUILDOUT PROJECT

CYPRESS, CALIFORNIA
As described above, the proposed project would not create a significant hazard to the public or the environment due to hazardous materials with compliance with federal, State, and local regulations for the management of hazardous materials. In addition, the proposed residential and nonresidential uses within the Buildout Area would not present a hazard associated with the accidental release of hazardous substances into the environment as these uses are not anticipated to use, store, dispose or transport large volumes of hazardous materials. Hazardous substances associated with these uses are typically limited in both amount and use such that they can be contained without impacting the environment. Therefore, implementation of the proposed project would not result in hazardous emissions or the handling of hazardous or acutely hazardous materials, substances, or waste within 0.25 mile of an existing or proposed school. Project impacts are considered less than significant, and no mitigation is required.

Threshold 4.9.4: Would the project be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment?
Less Than Significant with Mitigation Incorporated. Database searches of the Buildout Area, including a GeoTracker search and a search of Superfund sites, determined that the Buildout Area is not included on a list of hazardous materials sites that could create a significant hazard to the public or the environment, is not included on the Cortese List compiled pursuant to Government Code Section 65962.5, and is not a recorded Superfund site. As part of the Phase I ESA for the Buildout Area, a comprehensive government records database search was conducted to identify potential environmental concerns within a specified radius of the Buildout Area. The regulatory database search results indicated the Buildout Area was listed in multiple databases, including but not limited to: AST, California Environmental Reporting System (CERS) Tank, Cleanup Sites, Department of Toxic Substances Control's Hazardous Waste Tracking System (HAZNET), Leaking Underground Storage Tank (LUST), and Resource Conservation and Recovery Act Small Quantity Generator (RCRA-SQG).

Although the Phase I ESA identified these listings, none were determined to be RECs or HRECs.

Additionally, while the Phase I ESA concluded that the Buildout Area is not associated with any active RECs, it is associated with one CREC, one HREC, and one BER, which include:
• Four underground storage tanks: two 10,000-gallon USTs, one 2,000-gallon UST, and one 1,000- gallon UST, which were used to store unleaded gasoline and diesel for maintenance vehicles.

These USTs were removed in 1988 under the oversight of the OCHCA. Following their removal, soil and groundwater remediation was conducted between 1989 and 1993 using soil vapor extraction and groundwater treatment systems. The site was granted regulatory case closure in 1996 by OCHCA, which confirmed that contamination levels were reduced below thresholds of concern. The closure requires notification of OCHCA if a change in land use is proposed. The proposed project includes changes to the existing land uses in the Buildout Area, so a copy of this Draft EIR and the NOC will be provided to OCHCA.
• One underground storage tank: a 2,000-gallon, two-compartment UST used for gasoline and diesel fuel. The UST, located in the former golf course maintenance area near Lexington Drive (now 4511 Katella Avenue; APN 241-221-32), was removed in March 2004. Due to the removal P:\A-E\CCP2201.0S LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.9 Hazards and Hazardous Materials.docx (03/10/26) 4.9-15 SPECIFIC PLAN 3.0 BUI LOO UT PROJECT

CYPRESS, CALIFORNIA

DRAFT EN VIRONMENTAL IMPACT REPORT
MARCH 2026
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. • Due to the age of the existing on-site structures, including barns and other buildings, the potential presence of ACMs and LBP represents a BER. No sampling was conducted as part of the Phase I ESA. However, should renovation or demolition of these older structures occur, ACMs and LBP could pose a hazard to workers and occupants if not properly identified and managed. As such, adherence with SCAQMD Rule 1403, which requires that a comprehensive asbestos survey be conducted prior to demolition, would ensure that potential ACMs and LBP would not expose workers or building occupants during construction and demolition activities.

As discussed in Response 4.9.2, impacts associated with the release of hazardous materials into the environment through reasonably foreseeable upset and accident conditions would be potentially significant, but would be reduced to less than significant with adherence to existing regulatory requirements, including the notification of OCHCA due to the proposed change in land use and SCAQMD Rule 1403, and implementation of Mitigation Measure HAZ-1, requiring implementation of the recommendations provided in the Phase I ESA. In addition, as the Buildout Area is not included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5, the proposed project would not create a significant hazard to the public or the environment. Impacts would be less than significant with mitigation incorporated.

Threshold 4.9.5: For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the Buildout Area?
Less Than Significant Impact. The Buildout Area is located approximately 0.3 mile north of JFTB Los Alamitos. The facilities at JFTB Los Alamitos include two runways and associated taxiways, ramp space, and hangars. According to the ALUC's 2017 AELUP for JFTB Los Alamitos, the Buildout Area is located in the FAA's Part 77 Notification Area (Exhibit D1) and the AELUP height restriction zone for JFTB Los Alamitos (Exhibit D2).12 Height limitations are imposed on projects within a height restriction zone so that structures or trees (1) do not obstruct the airspace required for takeoff, flight, or landing of aircraft at an airport, or (2) are not otherwise hazardous to the landing or taking off of aircraft. On July 18, 2024, the ALUC found the Specific Plan consistent with the AELUP for JFTB Los Alamitos.

Implementation of the proposed project would not result in a safety hazard or excessive noise for people residing or working in the Buildout Area because any future development within the Buildout Area would be required to comply with all appropriate FAA standards and requirements, including Regulatory Compliance Measure HAZ-1, detailed below, which requires that the FAA be notified of any proposed structure(s) that would penetrate the 100 to 1 imaginary surface that surrounds the runway at JFTB Los Alamitos. The FAA would then be responsible for reviewing the height of the 12 Orange County Airport Land Use Commission (ALUC). 2017. Airport Environs Land Use Plan for Joint Forces Training Base Los Alamitos. Amended August 17, 2017.

4.9-16 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.9 Hazards and Hazardous Materials.docx (03/10/26)

DRAFT ENVIRONMENTAL IMPACT REPORT
MARCH 2026
SPECIFIC PLAN 3.0 BUILDOUT PROJECT

CYPRESS, CALIFORNIA
proposed structures and determining whether they pose a potential aviation hazard. With adherence to the regulatory standards provided in Regulatory Compliance Measure HAZ-1, the proposed project would result in less than significant impacts related to the Buildout Area's proximity to a public airport or public use airport, and no mitigation is required.

Threshold 4.9.6: Would the project impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan? No Impact. As shown in General Plan Safety Element Exhibit SAF-5, 13 evacuation routes within the City include Ball Road, a west-to-east arterial, and Valley View Street, a north-to-south arterial.

Although the proposed project would include future development within the Buildout Area of up to 1,791 additional residential units and approximately 440,000 square feet of non-residential floor area, the Buildout Area is not located along either of the emergency evacuation routes identified above.

All emergency evacuation activities are coordinated by the City Police Chief. The Police Chief would issue evacuation orders based on information gathered from emergency experts. Evacuation operations would be conducted by law enforcement agencies, highway/road/street departments, and public and private transportation providers. 14 Future development projects within the Buildout Area would be required to conform with the adopted emergency response or evacuation plan established by the City. Therefore, the proposed project would not impair implementation of or physically interfere with the adopted emergency response plan or emergency evacuation plan. No impact would occur, and no mitigation is required.

Threshold 4.9.7: Would the project expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires?
No Impact. According to the California Department of Forestry and Fire Protection's (CAL FIRE) Very High Fire Hazard Severity Zone Maps for the Orange County region, there are no portions of the City in a very high fire hazard severity zone (VHFHSZ). 15 As such, the proposed project would not expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wild land fires. Future developments under the proposed project would be required to conform with applicable City standards and criteria, including consistency with the City's General Plan goals and policies as detailed in Section 4.9.4, Regulatory Setting, and the City's Building Code, including general fire safety provisions consistent with the California Fire Code; 16 automatic, on-site fire 13 City of Cypress. 2001. Cypress General Plan Safety Element. Emergency Evacuation Routes Map (Exhibit SAF-5). Website: https://www.cypressca.org/home/showpublisheddocument/11369/638061699910 600000 (accessed August 2025).
14 City of Cypress. 2001. Cypress General Plan Environmental Impact Report. Geology and Seismic Hazards.