Agenda packet, regular meeting — Cypress City Council, August 25, 2026 (part 4 of 8)

impacts due to the increased volume of traffic in and around the project area, as well as traveling to the westbound 605 interstate freeway. The proximity of these new units to the City of Los Alamitos' neighborhoods will create additional cumulative rush-hour congestion and health issues for the City of Los Alamitos' residents, who have already experienced increased traffic from other large housing projects in this area, particularly in the City of Cypress.

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

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

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

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

Sincerely,
?.J�
Ron Noda
Development Services Director
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cont.

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Notably, page 1 of the County Guidelines states:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Specific Plan 3.0 Buildout Project
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• Construct or Improve Bike Facility (CAPCOA Handbook Strategy T-19-A): This mitigation measure would require the Project to include a new bicycle facility or facilities or improve an existing facility that would connect the Project to the existing regional bicycle network. The construction/improvement of bicycle facilities would provide residents with the opportunity to bi-ke to their destination rather than drive, reducing the number of vehicle trips and overall Project-generated VMT.

Provide a map showing the new bike path.

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

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

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

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

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

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

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

13.21 11.6%

1.2%

10.4%
Kimley-Horn and Associates, Inc.

May2025
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2.4.3 CITY OF LOS ALAMITOS
Letter Code: L-3
Date: April 20, 2026
Response to Comment L-3-1
This comment provides introductory remarks and summarizes the scope of the Draft EIR.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

As discussed in Section 4.17, Transportation, of the Draft EIR, the City’s General Plan Circulation Element contains Policy CIR-2.6, which requires the City to respond to increases in demand for S PECIFIC PLAN 3.0 B UILDOUT P ROJECT

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

3.0, Errata, of this Final EIR.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Thank you for your time and consideration of these comments.

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

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

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

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

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

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

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

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

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

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

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

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

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

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2 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\8_Final EIR and RTC\Specific Plan 3.0 Buildout Project_Final EIR RTC_fnl.docx «06/19/26» -108 majority of the construction equipment and the individual development project would be larger than 20 acres, Mitigation Measure AIR-2 requires the preparation of a project-specific construction health risk assessment (HRA), which may identify additional feasible risk-reduction measures for implementation, as appropriate.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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2 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\8_Final EIR and RTC\Specific Plan 3.0 Buildout Project_Final EIR RTC_fnl.docx «06/19/26» -114 review pursuant to CEQA. Future development within the Buildout Area will be required to comply with the permitted uses and applicable development standards of the Specific Plan. It is also not unusual for development projects of this size and scale to be reduced or modified over time in response to market conditions.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

6. Page 6-4 states, "Greenways and pedestrian and biking trails are envisioned to facilitate alternative modes of transportation by connecting the Residential District to the central public park and town center and the Senior Housing/Medium-Density Residential District to the western public park. In addition, the Town Center District is envisioned as a pedestrian-friendly entertainment and retail destination, designed for patrons to stroll by the various businesses."
On six different pages, the term "trails" is explicitly mentioned to allow both pedestrians and bikes to connect to other areas of the development. Yet there is not a single trail delineated on any of the private parcels within the EIR. The discussion on bikes seems to be completely absent in the EIR except on page 4.17-15, where it states, "the proposed project is assumed to include the addition of approximately 1 mile of bicycle facilities, connecting to the existing bicycle network." If this "trail" language winds up being just painted bike lanes on the arterial streets of Moody and Vessels, then the specific language is so vague and ambiguous it rises to the level of "puffery," as they say in advertising. If it can mean anything, it means nothing. It shouldn't. We all should know what a "reasonable, rational" person thinks when someone says "trail." The Specific Plan says, "A trail system is envisioned within the residential… district."
Attached is a picture from another city's circulation element which I believe displays what people think of as a "trail."
It seems improbable to have any type of trail connectivity or congruity if there are not at least drawn lines and easements for the trails on the subdivision map for the development of 134 acres over 11 or so lots that are going to be further subdivided. There are no cross sections or guidelines for the dimensions of the trails. If the developer's plan is to have subsequent developers propose a plan later, the city may end up with a mish-mash.
• For instance, how does Lot 2's trail connect with anything through Lot 3 and Lot 4? Are we to guess? Will there be none?
Furthermore, pages 10 through 13 of the VMT analysis talk about sidewalks and and what I assume are on-street bike routes.
• So are we believe that all the language regarding trails for pedestrians are nothing more than residential concrete sidewalk?
On page 11 of the VMT analysis, Provide Pedestrian Network Improvement talks about sidewalk. 3 I-3-26
cont.

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• Does that mean all the sidewalks in the the city are trails under the Specific Plan language interpretation?
Imagine bragging to your City Council colleagues in other cities that your city has so many pedestrian trails and their reaction when you tell him you count sidewalk as a pedestrian trail. Again, a cross simple cross section would clear this up because there is a big difference between a five foot sidewalk adjacent to a curb and an eight foot meandering sidewalk within a large parkway/greenway area. The Specific Plan mentions “greenways” which is not defined within the plan. • Are we to assume, since there is no definition, a “greenway” can be a road that is painted green? I bring up this as another sarcastic example up simply to reinforce that when words are not defined their basic and simple meaning should be used. Also, in the specific plan, the “greenway” term is always used with “trails,” thereby reinforcing the voter’s potential image of the graphic presented above. More specifically in the Specific Plan “Greenways and pedestrian and biking trails” conjures up this exact image.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Page 57 ends

Moody Street"

Page 58 ends

Moody Street and Vessels Circle."

Page 59 ends

Circle," but then there is a note that these are for "informational purposes."

Page 99 ends

and Vessels Circle."

Page 99 ends

and Vessels Circle."
I then searched the document for "width" and got no results. I also searched for "trail" and got no results.

So the public cannot determine how wide the on-street bike lane will be, whether it has a three-foot area striped as a buffer, nor whether the bike lane is carried all the way up through the intersections because none of the final street plans have been done per the Vesting Map requirements. Even if the driveway locations are unknown, you can still have conditions on the map and for the public which state the widths and dimensions for a cross section that shows the bike lanes. The map is an open canvas right now. A "by right" development on one of the parcels could negate the future ability to obtain dedications without paying for them.

Concerns Regarding Park Usability and Drainage
Though not my primary issue, as I am already reviewing this matter, I must raise another significant concern. After reviewing the map, I am not a drainage expert, but the contours suggest the park will function as a four-foot-deep lake during rain events. I searched the first document of the EIR for "lake" 15 I-3-47
cont.

I-3-48
I-3-49
I-3-50
and found no mention of the parkland being used as a defacto "bathtub" for runoff. The EIR contains the drainage data, but Park Section in 4.16 no comment regarding the usability of the park under these conditions within 4.16 on Parks. Flooding the park reminds me of how the church parking lot on Katella often floods when it rains heavily, supposedly by design, rendering it unusable. • Why is the usability of the “8 acre” park not covered in the EIR? After further review of the EIR, I found this below in a later section of the EIR. It appears the park property is receiving water from other lots so they won’t have to retain the drainage. This seems as a direct benefit to the developer for the lots which drain into it. It is not that there are basins on the lots, it is the parkland is acting as one giant basin for all these other lots making that land less usable for general park usage. While I appreciate nature parks, one cannot walk around in actual drainage basins during storm seasons, and they are usually closed off. Perhaps this one will be uniquely designed, but how is the reader to know, and who will guarantee it?
This is what the voters read from Section 1.1 of the Specific Plan:
16 EIR Screenshot
EIR Screenshot
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cont.
"Another critical component of this Specific Plan is 20 acres of public park space that will bespread throughout the Specific Plan Area. Two public parks, one 10.2 acres and the other 8 acres, will be located within the public park district, adjacent to Cerritos Avenue.” The Specific Plan does not contain any mention that the intent was to use this parkland as a giant basin.

If that is the case, the Specific Plan should have stated this clearly. This highlights a downfall of the voter-approved Specific Plan to Vesting Map process: developers can paint one picture while the details remain “unworked” out because the environmental analysis was not completed prior to approval. The Specific Plan language appears to set an expectation of a park, not a drainage facility. This "basin" issue is not my only concern, but it gives me serious doubt about the entire process. • How deep is the potential water within the square? (It appears to at least four feet deep) • How is this in conformance with the Specific Plan?
• Is it just crafted language to disguise that the promised parkland is really a basin? • Who is going to pay for the maintenance of this basin and will it be designed with any type of aesthetics?
This should be stated in a general project description on the website for the public. We need to know that the other park mentioned in the Specific Plan is a basin. Otherwise, you risk people attending meetings feeling misled by a "bait and switch" given the lack of mention in the Specific Plan.

If the developer gains a benefit and increased land value from the basin by having more develop-able land on other parcels they can sell, why is the City not requiring that this basin be placed underground on the subdivision map?
I recall hearing the developer built a large underground basin for the Senior Housing Development on Katella Avenue. I did a search and found it stored over 232,000 cubic feet of water.

So it is possible.

Doing so would allow the open space to be usable year-round for the enjoyment of the new tract, all city residents, and visitors. A cost analysis could be done comparing what the value of using the parkland for drainage on the land value versus having each parcel retain their drainage. This would give City Council a clear understanding of what they are trading for a park that seems really can’t be used for public enjoyment like a normal park.

The 2001 General Plan breaks down parks into Community Parks (10 acres or more), Neighborhood Parks (3 to 5 acres) and Mini Parks. This
would fall in between the first two but
more toward a community park which
should provide recreation for large groups
of people.

In case it is argued that the General Plan
does mention the Nature Park off Cerritos
17 Manufacturer Website Screenshot
1970 Orange County GIS Aerial Photo
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cont.

Avenue, it is not comparable. I have been to the Nature Park. It is closed most of the year (“We will be back Summer 2026! Stay tuned for updates.”) and city’s website mentions is a flood control basin built in the 1960’s. There is no ADA access for the Nature Park for many parts including getting down in the basin. I find it hard to square with the Specific Plan language provided above that gives the impression that the 8 acre Park would be usable park area and instead be used as a retention basin for other properties drainage. Furthermore, in my estimation the nature park is just a mere visual screening for the surrounding community and was built as a basin as you can see from a 1970 photo then screened later.
• How is the proposed public park, which is a drainage basin, in conformance with the General Plan Recreation Element for general park usage?
I am also trying to figure out the 8 acres mentioned in the specific plan above with caveat “area to Moody Centerline” when the actual area is 7.37 acres. I think I understand what developer did here but it seems slight of hand to include a proposed primary arterial street as if it were a park. Just say 7.37 acres. (“Two public parks, one 10.2 acres and the other 8 acres”) The creation of the park involves some type of land swap with Lot 5, what I am assuming is the church property.
• Is there a conflict of interest for anyone, if any, who is involved in the on the project on the city side/council member is a member or higher position within the church? Before I even attempt to review the drainage study, though I probably won’t, I noticed it does not contain approval statement like the Traffic Study or the Sewer Study. • Is there a more recent version with a plan checker approval? Project Page & Transparency
18 EIR Screenshot
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cont.

I-3-51
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Why is there no development project page for one of the largest developments in Cypress's history? All that is on the website is the EIR with no explanation or history to preface this development or help the resident wade through what is a technical document. This property and project have been going on probably before even approval of the Specific Plan adoption in 2017 and this is all the public gets. (https://www.cypressca.org/departments/community-development/planning-division/developmentinformation) Also note, it doesn’t even say on the landing page where the public can comment on it or even if there is a deadline for comments. How many of the public would know to click the Notice of Availability to find out? It gives the impression, whether accidental or intentional, that public comments were not wanted. This is also where a link to the full Vesting Tentative Map should a prominent hyperlink.

What is even odder is I found
https://www.cypressca.org/departments/community-development/information-on-notable-projects by a random search with no direct links to it still on the webpage yet the racetrack project is not on it.

Click on the link of each project. There is more information about the McDonald’s when you click on the link than there is regarding the development buildout of the racetrack. 19 I-3-54
cont.

For some other comparisons, here a some examples where cities host project pages for the public to better understand what is going on:

Santa Ana: https://www.santa-ana.org/major-planning-projects-and-monthly-developmentproject-reports/ Newport Beach: https://www.newportbeachca.gov/government/departments/communitydevelopment/planning-division/current-projects-and-cases/residences-at-4440-von-karman Garden Grove: https://ggcity.org/planning/current-projects Also, the previous Specific Plan, prior to the voter approved has been removed from the website. Not sure why but it would have been good context and more transparent for the public.

Since the City uses Laserfiche, a digital outward facing file system, any document related to the project, the previous specific plan, and all the historical documents regarding to this land as well as the developer submittals, including the Vesting Tentative Map, could all have been placed within a folder for public access like the city does for public record requests.

Transparency should always be the goal. I am guessing these files just sit on the city’s servers. The only thing I see available in the Planning Section https://ecms.cypressca.org/WebLink/Browse.aspx? id=33433&dbid=0&repo=CityOfCypress is the 2020 City Center Project EIR.

They are public documents, why can’t the public easily see them. Especially for a project that is this large in the city’s history.
20 I-3-54
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I-3-55
S PECIFIC PLAN 3.0 B UILDOUT P ROJECT

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2.5.3 UNIDENTIFIED COMMENTER ([email protected])
Letter Code: I-3
Date: April 29, 2026
Response to Comment I-3-1
This comment provides introductory remarks.

Response to Comment I-3-2
This comment claims that the project, as currently proposed, appears to be inconsistent with the Subdivision Map Act (State Law), the City's Specific Plan, the City's Municipal Code, and the City's General Plan.

Refer to Section 2.1.1, Consistency with Specific Plan, for the Master Response to comments regarding the proposed project’s consistency with the Cypress Town Center and Commons Specific Plan 3.0 (Specific Plan). In addition, as discussed in Section 4.11, Land Use and Planning, of the Draft EIR, the proposed project would be consistent with the City’s Municipal Code and the City’s General Plan. The proposed project would also be consistent with the requirements of the Subdivision Map Act.

Response to Comment I-3-3
This comment claims that the proposed project and VTTM appear inconsistent with the voterapproved Specific Plan and Government Code Section 66473.5, as the VTTM does not depict a network of dedicated pedestrian and bicycle trails to ensure connectivity between neighborhoods, parks, and the town center.

Refer to Section 2.1.1, Consistency with Specific Plan, for the Master Response to comments regarding the proposed project’s consistency with the Specific Plan, including internal circulation requirements.

The Subdivision Map Act governs how land is divided, sets the rules for creating parcels and lots, and contains requirements for VTTMs. Because the comment does not contain any other substantive comments or questions about the environmental analysis or conclusions contained in the Draft EIR, no further response is required.

Response to Comment I-3-4
This comment claims that the VTTM may not be in compliance with the City’s Municipal Code or the Subdivision Map Act, as the Draft EIR only includes a partial depiction of the VTTM and the full VTTM is not available to the public.

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2 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\8_Final EIR and RTC\Specific Plan 3.0 Buildout Project_Final EIR RTC_fnl.docx «06/19/26» -142 The proposed VTTM No. 19247 is available for review in its entirety for anyone who submits a public records request to the City. Because the comment does not contain any substantive comments or questions about the environmental analysis or conclusions contained in the Draft EIR, no further response is required.

Response to Comment I-3-5
This comment claims that the Draft EIR may be in violation of Section 15126.2 of the State CEQA Guidelines, which requires that an EIR provide an accurate, stable, and finite description of the project, as the project described in the Draft EIR appears to differ materially from the Specific Plan and therefore may fail to provide the public and decision-makers with an accurate description of the proposed project.

Section 15126.2 of the State CEQA Guidelines provides guidance related to the consideration and discussion of significant environmental impacts in an EIR and is not related to the content of project descriptions. Section 15124 of the State CEQA Guidelines outlines the requirements for a project description in an EIR. As outlined in Section 15124, a project description shall contain the following information, but should not supply extensive detail beyond that needed for evaluation and review of the environmental impact:
a) The precise location and boundaries of the proposed project shall be shown on a detailed map, preferably topographic. The location of the project shall also appear on a regional map.
b) A statement of the objectives sought by the proposed project. A clearly written statement of objectives will help the lead agency develop a reasonable range of alternatives to evaluate in the EIR and will aid the decision makers in preparing findings or a statement of overriding considerations, if necessary. The statement of objectives should include the underlying purpose of the project and may discuss the project benefits. c) A general description of the project’s technical, economic, and environmental characteristics, considering the principal engineering proposals if any and supporting public service facilities.
i. A statement briefly describing the intended uses of the EIR, including a list of the agencies that are expected to use the EIR in their decision making, a list of permits and other approvals required to implement the project, and a list of related environmental review and consultation requirements required by federal, state, or local laws, regulations, or policies.

As previously discussed, the Draft EIR analyzed buildout of the Specific Plan within the Buildout Area at a “programmatic” level. Section 15168 of the State CEQA Guidelines provides guidance related to the preparation of a Program EIR. A Program EIR does not describe one fixed project; instead, it describes a series of related actions or a framework for future projects. As such, the project description for a Program EIR can be broader and more flexible, while still providing enough information to support a meaningful analysis of the maximum development potential. Using

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Based on the above, the project description for the proposed project, as provided in Chapter 3.0, Project Description, of the Draft EIR, has been prepared consistent with the State CEQA Guidelines.

Consistent with Section 15126.2 of the State CEQA Guidelines, as modified by the direction in Section 15168 of the State CEQA Guidelines, Chapter 3.0 contains (1) the precise location and boundaries of the Buildout Area, including figures that show the Buildout Area’s local and regional context (refer to Section 3.1, Project Location and Existing Environmental Setting, of the Draft EIR); (2) a statement of objectives, including the underlying purpose of the proposed project (refer to Section 3.4, Project Objectives, of the Draft EIR); and (3) a general description of the project’s technical, economic, and environmental characteristics appropriate for a programmatic document, including a description of the policy, plan, or program (i.e., the Specific Plan and VTTM No. 19247), the types of activities/projects it would allow, and the buildout schedule and assumptions (refer to Section 3.5, Project Description, of the Draft EIR). As such, the project description contained in Chapter 3.0 of the Draft EIR is not in violation of State CEQA Guidelines requirements.

In addition, the proposed project assumes buildup under the Specific Plan, as provided in Chapter

3.0 of the Draft EIR. Specifically, the proposed project would include the construction of an additional 1,791 residential units to meet the maximum allowable number of residential units (1,926 residential units), consistent with the Specific Plan, and the construction of approximately 440,000 square feet of non-residential development. Although the Specific Plan permits an aggregate maximum of 879,170 square feet of non-residential floor area within the Buildout Area, based on current and reasonably foreseeable future market conditions, it is anticipated that the buildout of the Buildout Area will include substantially less than 879,170 square feet of non-residential development (i.e., 440,000 square feet). The proposed project also includes circulation and access improvements, utility improvements, and open space/parkland development, consistent with the Specific Plan. Accordingly, the proposed project is consistent with the Specific Plan and therefore does not differ materially from the Specific Plan. Refer to Section 2.1.1, Consistency with Specific Plan, for the Master Response to comments regarding the proposed project’s consistency with the Specific Plan.

Response to Comment I-3-6
This comment claims that there appears to be a fundamental inconsistency between the proposed project’s transportation analysis and the City’s General Plan because the VMT analysis prepared for the proposed project relies on the City’s General Plan Circulation Element, which was adopted on September 10, 2001, and contains outdated LOS standards.

The City acknowledges this comment. As the City’s General Plan Circulation Element was prepared and adopted in 2001, prior to the State CEQA Guidelines update that changed the basis for transportation impacts under CEQA from LOS to VMT, the City’s General Plan Circulation Element S PECIFIC PLAN 3.0 B UILDOUT P ROJECT

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14 dated September 17, 2020 (County Guidelines), and does not rely on the City’s General Plan Circulation Element. Therefore, the VMT analysis prepared for the proposed project has been prepared pursuant to all applicable guidance documents and accurately reflects the proposed project’s potential impact on transportation under CEQA.

In addition, the City’s General Plan Circulation Element is not a part of the proposed project that is analyzed in the Draft EIR. Because the comment does not contain any other substantive comments or questions about the environmental analysis or conclusions contained in the Draft EIR, no further response is required.

Response to Comment I-3-7
This comment states that the Traffic Study referenced in the Draft EIR was posted separately from the Draft EIR and that the bike lane recommendations in the Traffic Study do not appear binding as they are noted as “for informational purposes only.”
The City acknowledges this comment. As previously discussed, transportation impacts under CEQA are to be evaluated based on a project’s effect on VMT as opposed to vehicle delay and LOS. This change came into effect on December 28, 2018, when the California Office of Administrative Law cleared the revised State CEQA Guidelines for use and removed vehicle delay and LOS from consideration under CEQA. As such, Section 4.17, Transportation, of the Draft EIR contains a projectspecific VMT analysis based on the VMT Memo prepared for the proposed project, which is included as Appendix K to the Draft EIR, in order to assess transportation impacts under CEQA. The Traffic Study is only referenced in the Draft EIR as it relates to the anticipated number of daily vehicle trips associated with full buildout of the proposed project. No analysis contained in the Traffic Study is included in the Draft EIR, and the Traffic Study is provided on the City’s website for informational purposes only. In addition, the bike lane recommendations in the Traffic Study are noted as “for informational purposes only” as they are recommendations and may not reflect the final locations of the bike lanes. Because the specifics of future projects within the Buildout Area cannot be determined at this time, it is not known if the bike lane recommendations provided in the Traffic Study would appropriately fit or be feasible within the ultimate buildout of the Buildout Area.

However, the proposed project is assumed to include the addition of approximately 1 mile of bicycle facilities, connecting to the existing bicycle network. Additionally, as detailed in Mitigation Measure TRA-1, the proposed project would be required to implement feasible TDM strategies to mitigate the proposed project’s VMT impact, which include constructing or improving bicycle facilities that would connect the proposed project to the existing regional bicycle network. All future development facilitated by the proposed project would be required to implement Mitigation Measure TRA-1 and 14 Orange County. 2020. Guidelines For Evaluating Vehicle Miles Traveled Under CEQA for Orange County.

September 17, 2020.

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Further, future development projects associated with implementation of the proposed project would be reviewed by the City on a project-by-project basis in order to ensure that the proposed development is consistent with the Specific Plan and City requirements related to bike lanes and bicycle infrastructure. Specifically, through the design review process, future development projects would be required to submit a detailed site plan that depicts the bike lanes and other trails that would be included in each development, consistent with the planned “backbone” circulation improvements set forth in the Specific Plan. Overall, future development projects would be required to incorporate bike lanes into individual project designs on an as-needed basis in order to ensure consistency with the Specific Plan and other City requirements, even if these bike lanes do not match the general recommendations provided in the Traffic Study.

Response to Comment I-3-8
This comment claims that the extension of Vessels Circle westward to terminate at Moody Street instead of extending further west to Lexington Drive may miss an opportunity to create a through connection that would improve traffic distribution, provide alternative routes for pedestrians and cyclists, provide needed relief for residents traveling eastward om Katella Avenue, and provide redundancy for ambulance, fire, and police services.

Refer to Section 2.1.3, Vessels Circle Through Connection, for the Master Response to comments regarding the Vessels Circle through connection.

Response to Comment I-3-9
This comment claims that the VTTM has not been provided as a complete document and questions if the VTTM is in compliance with the City’s Municipal Code.

The proposed VTTM No. 19247 is available for review in its entirety for anyone who submits a public records request to the City. Because the comment does not contain any substantive comments or questions about the environmental analysis or conclusions contained in the Draft EIR, no further response is required.

Response to Comment I-3-10
This comment states that the City should ensure the proposed project is conditioned to include the dedicated pedestrian and bicycle trails, as detailed in the Specific Plan, and requests the required engineering drawings associated with the VTTM be provided prior to certifying the EIR or recommending approval of the VTTM.

Refer to Section 2.1.1, Consistency with Specific Plan, for the Master Response to comments regarding the proposed project’s consistency with the Specific Plan. Future development within the Buildout Area associated with implementation of the proposed project would be required to demonstrate consistency with the Specific Plan, including pedestrian and bicycle trails and “backbone” circulation improvements described in the Specific Plan. In addition, the proposed VTTM S PECIFIC PLAN 3.0 B UILDOUT P ROJECT

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Response to Comment I-3-11
This comment requests information regarding the City’s legal or factual basis for concluding that the VTTM, which does not depict the dedicated trails described in the Specific Plan, is in "substantial conformance" with Government Code Section 66473.5.

Response to Comment I-3-12
This comment asks if the full set of certified engineering drawings for all nine categories required by the City’s Municipal Code for VTTMs has been submitted, accepted as complete, and are available for public inspection
The proposed VTTM No. 19247 is available for review in its entirety for anyone who submits a public records request to the City. Because the comment does not contain any substantive comments or questions about the environmental analysis or conclusions contained in the Draft EIR, no further response is required.

Response to Comment I-3-13
This comment requests that if any of the nine required engineering categories for VTTM provided in the City’s Municipal Code have been waived by the City, written findings be provided that state such information is "unnecessary, duplicative, or inapplicable" and that such a waiver will not hamper prudent public policy.

Response to Comment I-3-14
This comment asks if there is any documentation that the project developer has requested any item under Sections 25-61 or 25-62 of the City’s Municipal Code or Section 2.2.5 of the Specific Plan and if there was, why this was not available to the public.

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This comment asks how the Draft EIR satisfies Section 15126.2 of the State CEQA Guidelines when it omits the dedicated trail system and required street cross-sections.

Refer to Response to Comment I-3-5, above.

Response to Comment I-3-16
This comment asks what specific legal mechanism exists to guarantee that future developers of the 11 lots will dedicate the necessary land for trails if the City approves the VTTM without the dedicated trails and engineering drawings.

The proposed VTTM No. 19247 is available for review in its entirety for anyone who submits a public records request to the City. Future development within the Buildout Area associated with implementation of the proposed project would be required to demonstrate consistency with the Specific Plan, including through the addition of pedestrian and bicycle trails. Specifically, through the design review process, future development projects would be required to submit a detailed site plan that depicts the pedestrian pathways and bicycle trails that would be included in each development, consistent with the Specific Plan.

Response to Comment I-3-17
This comment asks how the Draft EIR ensures consistency with the General Plan Circulation Element when the Circulation Element was adopted in 2001, only contains build-out projections to 2020, and has not been updated to reflect current VMT requirements.

The Draft EIR contains a consistency analysis with the most recently adopted Circulation Element, as required by CEQA. Table 4.11.D: General Plan Consistency Analysis, in Section 4.11, Land Use and Planning, of the Draft EIR provides a consistency analysis of the goals and policies from the City’s General Plan pertaining to the circulation system that are relevant to the proposed project. As provided in Table 4.11.D, the proposed project would not conflict with any of the goals and policies contained in the City’s General Plan related to the circulation system.

Response to Comment I-3-18
This comment asks what binding conditions will be placed on the VTTM to ensure the bike lane widths, buffers, and intersection treatments identified in the Traffic Study are actually constructed.

As previously discussed, the bike lane recommendations in the Traffic Study are noted as “for informational purposes only” as they are proposed locations only. Because the specific future projects cannot be determined at this time, it is not known if the bike lane recommendations provided in the Traffic Study would appropriately fit or be feasible within the ultimate buildout of the Buildout Area. However, as previously discussed, future development within the Buildout Area associated with implementation of the proposed project would be required to demonstrate consistency with the Specific Plan, including through the addition of pedestrian and bicycle trails, prior to individual project approval. Specifically, through the design review process, future development projects would be required to submit a detailed site plan that depicts the pedestrian S PECIFIC PLAN 3.0 B UILDOUT P ROJECT

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Response to Comment I-3-19
This comment asks for the City’s justification for not requiring the Vessels Circle through connection, including how the decision aligns with the General Plan's circulation goals of facilitating movement and alternative transportation. This comment also asks if the through connection was studied related to improving potential public health, safety and welfare, improving or degrading traffic patterns with regards to the existing senior development on Katella Avenue and pedestrian and bike mobility.

Refer to Section 2.1.3, Vessels Circle Through Connection, for the Master Response to comments regarding the Vessels Circle through connection.

Response to Comment I-3-20
This comment asks where the full, certified VTTM is located and why it was not provided in the Draft EIR. This comment also reiterates the commenter’s concern regarding the VTTM’s compliance with the City’s Municipal Code requirements.

The proposed VTTM No. 19247 is available for review in its entirety for anyone who submits a public records request to the City. The Draft EIR does not include, nor is it required to include, the full proposed VTTM No. 19247. Figure 3-5: Vesting Tentative Map No. 19247, contained in the Draft EIR is intended to provide a high-level depiction of the proposed lots and the main “backbone” circulation improvements within the Buildout Area.

Response to Comment I-3-21
This comment asks if the public will have an opportunity to review the Development Agreement and if the Development Agreement contains information related to trails.

The Development Agreement for the proposed project is currently being prepared by the City and will be available to the public for review once it is completed and prior to its consideration by the City Council. Because the comment does not contain any substantive comments or questions about the environmental analysis or conclusions contained in the Draft EIR, no further response is required.

Response to Comment I-3-22
This comment states that the commenter has attached a letter that they sent to the City Manager and City Council, and requests that all questions posed in the attached letter be answered.

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Response to Comment I-3-23
This comment requests that the commenter’s comments be included in the official administrative record and the specific legal and factual questions raised by the commenter be addressed in the Staff Report and the City’s findings prior to EIR certification and subsequent approval of the VTTM.

This Final EIR provides responses to all comments and questions that address environmental issues or the adequacy of the Draft EIR prepared for the proposed project. Comments that (1) do not address the adequacy or completeness of the Draft EIR; (2) do not raise environmental issues; or (3) do request the incorporation of additional information not relevant to environmental issues, do not require a response in this Final EIR, pursuant to Section 15088(a) of the State CEQA Guidelines.

This Final EIR and the written responses contained herein will be available at least 10 days prior to the EIR certification hearing for the proposed project.

Response to Comment I-3-24
This comment provides introductory remarks and states that the following letter includes comments on the proposed project, focusing on the provision of trails and greenways.

The City acknowledges this comment and has provided responses to the comments raised in the letter below. Because the comment does not contain any substantive comments or questions about the environmental analysis or conclusions contained in the Draft EIR, no further response is required.

Response to Comment I-3-25
This comment claims that the proposed development may not meet the requirements of the voterapproved Specific Plan or the City’s Municipal Code requirements for a VTTM as there is uncertainty regarding the size, dimensions, and characteristics of any trails within the Buildout Area associated with implementation of the proposed project.

Refer to Section 2.1.1, Consistency with Specific Plan, for the Master Response to comments regarding the proposed project’s consistency with the Specific Plan.

The proposed VTTM No. 19247 is available for review in its entirety for anyone who submits a public records request to the City. Because the comment does not contain any other substantive comments or questions about the environmental analysis or conclusions contained in the Draft EIR, no further response is required.

Response to Comment I-3-26
This comment claims that the proposed development does not meet the requirements of the voterapproved Specific Plan.

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2 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\8_Final EIR and RTC\Specific Plan 3.0 Buildout Project_Final EIR RTC_fnl.docx «06/19/26» -150 Refer to Section 2.1.1, Consistency with Specific Plan, for the Master Response to comments regarding the proposed project’s consistency with the Specific Plan.

Response to Comment I-3-27
This comment claims that it seems improbable to have any trail connectivity or congruity if the trails are not depicted on the subdivision map for the Buildout Area and asks how future trails on Lot 2 would connect within trails through Lots 3 and 4.

Refer to Section 2.1.1, Consistency with Specific Plan, for the Master Response to comments regarding the proposed project’s consistency with the Specific Plan.

Future development projects associated with implementation of the proposed project would be reviewed by the City on a project-by-project basis in order to ensure that the proposed development is consistent with the Specific Plan. Specifically, through the design review process, future development projects would be required to submit a detailed site plan that depicts the pedestrian pathways and bicycle trails that would be included in each development, consistent with the Specific Plan, and how these pathways and trails would connect to other existing and planned pathways and trails in the surrounding area. Therefore, although the specific trails that may be located within Lots 2, 3, and 4 cannot be determined at this time, the City would ensure their construction and continuity through the design review process.

Response to Comment I-3-28
This comment asks if the language regarding trails in the Specific Plan refers to only concrete sidewalks and on-street bike routes.

Refer to Section 2.1.1, Consistency with Specific Plan, for the Master Response to comments regarding the proposed project’s consistency with the Specific Plan.

As described above, future development projects associated with implementation of the proposed project would be reviewed by the City on a project-by-project basis in order to ensure that the proposed development is consistent with the Specific Plan. Specifically, through the design review process, future development projects would be required to submit a detailed site plan that depicts the pedestrian pathways and bicycle trails that would be included in each development, consistent with the Specific Plan. These pathways and trails could include concrete sidewalks and on-street bike routes, or be separate trails, not adjacent to roadways.

However, it should be noted that although the Specific Plan includes the provision of pedestrian and bicycle trails within the Buildout Area, it does not require that these trails be public or dedicated to the City. The Specific Plan requirements related to providing pedestrian and bicycle trails may also be satisfied by providing private pedestrian and bicycle trails for use by residents that would connect to the City’s public pedestrian and bicycle network in the surrounding area.

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This comment asks if all sidewalks in the city are trails under the Specific Plan language interpretation.

The Specific Plan is the document that governs land use and circulation improvements within the Specific Plan area; it does not regulate land use and circulation improvements within other parts of the city. Because the comment does not contain any substantive comments or questions about the environmental analysis or conclusions contained in the Draft EIR, no further response is required.

Response to Comment I-3-30
This comment raises concerns over the ambiguity of what a “greenway” is, since there is no definition of “greenway” in the Specific Plan.

A “greenway” is a linear open space corridor that provides recreational and non-motorized transportation opportunities. Because the comment does not contain any substantive comments or questions about the environmental analysis or conclusions contained in the Draft EIR, no further response is required.

Response to Comment I-3-31
This comment claims that the approximately 1 mile of on-street bike lanes associated with the proposed project is being used to satisfy VMT reduction requirements while ignoring the “off-road trail system” envisioned in the Specific Plan.

Although the provision of approximately 1 mile of on-street bike lanes would provide some VMT reduction benefits, it is not associated with the VMT reduction strategies provided in Mitigation Measure TRA-1. Mitigation Measure TRA-1 would require that the proposed project prepare and implement feasible TDM strategies to mitigate the proposed project’s VMT impact, which include constructing or improving bicycle facilities that would connect the proposed project to the existing regional bicycle network (beyond the approximately 1 mile of on-street bike lanes that is considered part of the proposed project) and improving the pedestrian network, including the construction of off-site sidewalks to improve sidewalk coverage and pedestrian access to the surrounding area.

Refer to Section 2.1.1, Consistency with Specific Plan, for additional discussion regarding the proposed project’s consistency with the Specific Plan.

Response to Comment I-3-32
This comment asks if the public will have the opportunity to review the Development Agreement associated with the proposed project.

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This comment asks why there is no proposed east-west through connection through the Buildout Area, which would provide redundancy for medical, fire, and police to get to an emergency, provide an opportunity for a pedestrian and biking trail, and alleviate the traffic congestion issues experienced by the senior community on Katella Avenue.

Refer to Section 2.1.3, Vessels Circle Through Connection, for the Master Response to comments regarding the Vessels Circle through connection.

As previously discussed, transportation impacts under CEQA are required to be evaluated based on a project’s effect on VMT as opposed to vehicle delay and LOS. Accordingly, the Draft EIR does not consider potential traffic delay (LOS) impacts or concerns associated with other developments in the city, such as the senior community on Katella Avenue, and is not required to alleviate existing traffic delay issues in the surrounding area resulting from other developments. No further response is required.

Response to Comment I-3-34
This comment claims that although a Vessels Circle through connection was not included in the Specific Plan, the proposed Moody Street connection was also not included in the Specific Plan, and the Specific Plan allows for infrastructure modifications.

The Specific Plan approved by City of Cypress voters on November 5, 2024, does include the proposed extension of Moody Street from Cerritos Avenue to Katella Avenue. Therefore, the proposed project consists of the reasonably foreseeable buildout of the Buildout Area with implementation of the voter-approved Specific Plan, including the proposed Moody Street extension and the extension of Vessels Circle from its current western terminus to intersect with the Moody Street extension. The City currently has no plans to modify the voter-approved Specific Plan.

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

Response to Comment I-3-35
This comment claims that a Vessels Circle through connection would contribute to a reduction in VMT, which would resolve the proposed project’s significant and unavoidable VMT impact.

Refer to Section 2.1.3, Vessels Circle Through Connection, for the Master Response to comments regarding the Vessels Circle through connection.

Response to Comment I-3-36
This comment is related to the information provided on the proposed VTTM No. 19247 and states that the proposed VTTM should include the depictions and cross sections of bicycle trails.

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This comment states that the City Council should be aware the voter-approved Specific Plan was not prepared by the City and has never been evaluated from an environmental and practical perspective. This comment also states that the developer can change the requirements of the Specific Plan through conditional approval by the City, and cites Section 25-61 of the City’s Municipal Code.

The Draft EIR analyzes the proposed project, which consists of the reasonably foreseeable buildout of the voter-approved Specific Plan. As such, the Draft EIR evaluates buildout of the Specific Plan from an environmental perspective. CEQA does not require an EIR to analyze the practicality of a plan or program.

In addition, it should be noted that Section 25-61 of the City’s Municipal Code is not related to changes to a specific plan and instead provides guidance for the preparation of Vesting Tentative Maps that do not match the current zoning at the time they’re submitted. Any proposed modification to the current voter-approved Specific Plan, including from future developers, would be subject to applicable approval procedures, including voter approval, and may require additional environmental review pursuant to CEQA.

Response to Comment I-3-38
This comment asks if a modification to the Specific Plan would require voter approval or the City Council.

As provided in Section 5.6, Amendments and Adjustments, of the voter-approved Specific Plan, the Specific Plan may generally only be amended through voter approval. However, Section 5.6.2 of the Specific Plan allows the Director of Community Development to approve modifications to the Specific Plan that do not substantially alter the distribution, location, extent or density of the uses, improvements and facilities required pursuant to the Specific Plan, in accordance with the procedures set forth in Section 4.19.050, Adjustments, of the City’s Municipal Code.

Specifically, the Director of Community Development shall be required to approve any requested adjustment if the proposed adjustment is generally consistent with the intent of this Specific Plan and is one of the permitted adjustments described in Section 5.6.2 of the Specific Plan. These adjustments include the following:

1. Changes in the boundaries of any Land Use District or Subdistrict that result in less than a 10 percent change in the original acreage within any Land Use District Areas, provided that the Public Park District does not include less than 18 acres of land and the size of the Public Park Overlay is not less than 2 acres.

2. The transfer of up to 5 percent of the number of residential units allowed or required in a Residential Subdistrict to another Residential Subdistrict, provided that the total number of residential units shall not exceed 1,926 units.

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3. Various modifications in development standards, provided that they meet the requirements set forth in Section 5.6.2 of the Specific Plan.

4. Modifications to the conceptual layout of circulation and infrastructure plans shown in Chapter 2 of this Specific Plan, the sizing of infrastructure facilities, and the width of street sections, based on more detailed site planning, traffic studies, environmental review and/or civil engineering plans.

5. Other minor modifications to, or minor relief from, the standards, regulations, requirements and restrictions in this Specific Plan as the Director of Community Development finds is consistent with the intent of this Section and similar to the permitted adjustment described in Section 5.6.2 of the Specific Plan.

In the event that an application or applications are submitted to the City for a development project that requests multiple entitlements, including one or more adjustments, then the City Council, acting as the City's planning agency, shall have original jurisdiction with respect to such adjustment(s) and shall consider and take action on the requested adjustment(s) together with the other requested entitlements. The approval of an adjustment pursuant to Section 5.6.2 of the Specific Plan does not constitute an amendment to the Specific Plan and does not require a vote of the people.

Response to Comment I-3-39
This comment asks if the proposed VTTM is approved and if new subdivision maps are submitted by future subsequent developers who purchase the lots, would the new subdivision maps be “grandfathered” in under the voter-approved Specific Plan or could they be subject to future modifications to the Specific Plan.

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

Response to Comment I-3-40
This comment is related to the content of the proposed VTTM No. 19247 and questions if the proposed VTTM No. 19247 has been prepared consistent with all applicable regulations, including the City’s Municipal Code.

Response to Comment I-3-41
This comment cites three goals contained in the City’s General Plan Circulation Element (CIR-1.5, CIR-2, and CIR-2.4), claims that there are no designated off-road bicycle trails delineated within the

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Section 4.11, Land Use and Planning, of the Draft EIR, provides a consistency analysis of the goals and policies from the City’s General Plan that are relevant to the proposed project, including Policies CIR-2.5 and CIR-2.8, relating to pedestrian and bicycle facilities. Policy-1.5, which states that the City will continue involvement in plans and programs related to the Circulation Element; Goal CIR-2, which outlines the City’s goal to facilitate alternative modes of transportation; and Policy CIR-2.4, which states the City should encourage development and site design which facilitate implementation of high quality, desirable bicycle routes which meet or exceed established standards, are goals and policies for implementation by the City, and not specific developments or projects.

Further, the proposed project would include sidewalks along the project frontages and pedestrian sidewalks and bicycle pathways throughout the Buildout Area that provide connections to existing pedestrian and bicycle facilities in the surrounding area. Specifically, the proposed project is assumed to include the addition of approximately 1 mile of bicycle facilities, connecting to the existing bicycle network. 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 seamless integration with the broader pedestrian network, effectively linking the Buildout Area with nearby amenities and transit options.

Additionally, as required by Mitigation Measure TRA-1, the proposed project would implement feasible TDM strategies to mitigate the proposed project’s VMT impact, which include constructing or improving bicycle facilities that would connect the proposed project to the existing regional bicycle network and improving the pedestrian network, including the construction of off-site sidewalks to improve sidewalk coverage and pedestrian access to the surrounding area. Therefore, the proposed project would not conflict with any adopted bicycle or pedestrian system plans, guidelines, policies, or standards, and would be consistent with the City’s goals related to provided pedestrian and bicycle infrastructure. As such, the Draft EIR determined that impacts to bicycle and pedestrian facilities would be less than significant.

In addition, as previously discussed, future development projects associated with implementation of the proposed project would be reviewed by the City on a project-by-project basis in order to ensure that the proposed development is consistent with the Specific Plan and would comply with City policies regarding bicycle parking and other infrastructure. Specifically, through the design review process, future development projects would be required to submit a detailed site plan that depicts the pedestrian pathways and bicycle trails that would be included in each development, consistent with the Specific Plan and the goals and policies contained in the City’s General Plan Circulation Element.

Refer to Section 2.1.1, Consistency with Specific Plan, for additional discussion regarding the proposed project’s consistency with the Specific Plan and the provision of bicycle trails within the Buildout Area.

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This comment asks if the City is settling for less safety by not providing a barrier or separation on the on-street bike routes, instead of adopting a “complete street” for the proposed project.

As previously discussed, future development projects associated with implementation of the proposed project would be reviewed by the City on a project-by-project basis in order to ensure that the proposed development is consistent with the Specific Plan and would comply with City policies regarding bicycle infrastructure, including safety requirements. As such, proposed bike paths, which may include off-street trails and/or on-street bike lanes, would be required to meet relevant safety criteria.

Response to Comment I-3-43
This comment provides a summary of the specific comments discussed above.

Response to Comment I-3-44
This comment states that the City’s General Plan, particularly the Circulation Element, is outdated and should be updated.

Response to Comment I-3-45
This comment asks that since the proposed VTTM No. 19247 denotes that the Lexington Drive parcels were already dedicated to the city and accepted by the City in a previous parcel map, if the race course has been using City property or if there is an agreement that can be made available to the public.

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This comment asks what, if any, on-street bike lanes would be placed along Lexington Drive.

As previously discussed, because the proposed project is analyzed in the Draft EIR at the programmatic level, the specific future projects associated with implementation of the proposed project, including the specific bike lanes that would be constructed as part of buildout cannot be determined at this time. Future development projects associated with implementation of the proposed project would be reviewed by the City on a project-by-project basis in order to ensure that the proposed development is consistent with the Specific Plan and would comply with City policies regarding bicycle infrastructure. Specifically, through the design review process, future development projects would be required to submit a detailed site plan that depicts the pedestrian pathways and bicycle trails that would be included in each development.

Response to Comment I-3-47
This comment contains questions on the symbols and notations on the proposed VTTM No. 19247, including what the cross-hatching means on the upper Lexington Dedication and what “LARC/OC property” denoted on the southerly portion of the park means.

Response to Comment I-3-48
This comment claims that there are exhibits missing from the City’s General Plan Circulation Element posted on the City’s website.

Response to Comment I-3-49
This comment is related to the Traffic Study prepared for the proposed project and claims that there is no information provided in the Traffic Study related to the specific design and dimensions of future bicycle lanes/trails.

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Response to Comment I-3-50
This comment raises concerns over the use of Lots 5 and 6, which is designated as Public Park District in the Specific Plan, being used for stormwater detention as it may contain standing water during heavy rain events. This comment refers to another development in the city that included an underground basin and suggests a similar approach would allow year-round use of the parkland proposed for Lots 5 and 6. The comment also questions whether the proposed dual use of Lots 5 and 6 as both a park and stormwater detention area is consistent with the Specific Plan and City’s General Plan Recreation Element.

As discussed in Chapter 3.0, Project Description, of the Draft EIR, the proposed project evaluated in the Draft EIR assumes that the Buildout Area would include approximately 11 acres of land on which park and recreational uses would be developed, including the land in Lots 1, 5, and 6 and the two additional acres of public park space that may be located in one or more of the land use districts established in the Specific Plan. The specific amenities and improvements that would be developed in the Public Park District and the additional two acres of public park space would be determined in connection with future development projects that are proposed within the Buildout Area. As provided in Section 4.10, Hydrology and Water Quality, of the Draft EIR, Lots 5 and 6 would contain a proposed detention basin (Basin C), which would collect, detain, and treat stormwater runoff from Drainage Area C, which consists of approximately 61.87 acres in the central portion of the Buildout Area, before discharging to the Cerritos Avenue Storm Drain. As provided in Section 4.10, Basin C would be designed as either an underground detention system and/or a surface detention basin that would collect and store the 100-year high-confidence storm event runoff volume, depending on the final design considerations of the ultimate buildout condition. Because the final design of Basin C is not yet known, Basin C could contain standing water during a heavy rain event if it is constructed as a surface detention basin, or it could be constructed as an underground detention system.

Nevertheless, if Basin C is designed as a surface detention basin and may contain some standing water during heavy rain events, the use of Lots 5 and 6 as both a park and a stormwater detention basin is consistent with common and accepted planning and engineering practices, both within the City, the County, and many other jurisdictions across the State. Multi-benefit stormwater facilities are routinely designed to function as passive or active recreational areas during dry weather conditions while providing temporary stormwater storage during storm events. Such dual-use facilities are consistent with modern stormwater management approaches, including low impact development (LID) and integrated water management strategies, which emphasize maximizing the functional use of land while providing flood control and water quality benefits.

The proposed Basin C, if designed to be a surface detention basin, would be designed to remain dry and available for recreational use under typical conditions. During storm events, Basin C may temporarily hold water for a limited duration to detain peak flows and reduce potential downstream flooding and erosion impacts. These temporary inundation periods are expected to be infrequent,

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Following storm events, Basin C would drain and return to its intended recreational function.

Although the Specific Plan does not explicitly state that the proposed park would also be used for stormwater management and treatment, the Specific Plan does not preclude this dual use. The Specific Plan also states that existing flood control systems around the Specific Plan area are insufficient and that new development within the Buildout Area would require each development project to be graded and landscaped to reduce the volume of storm water that flows off the Specific Plan Area. In other words, the Specific Plan contemplates maximizing onsite storage of storm water flows and infiltration at various places in the Specific Plan area for each development project in order to reduce potential impacts from runoff into the City’s storm drain system.

In addition, this type of design is consistent with applicable regulatory frameworks, including municipal stormwater requirements adopted pursuant to National Pollutant Discharge Elimination System (NPDES) permits and local drainage standards, which encourage or require on-site stormwater detention and multi-benefit use of open space areas. Nothing in these regulations prohibits the co-location of stormwater infrastructure within parkland; rather, such integration is widely encouraged as an efficient and environmentally beneficial land use strategy. In addition, the use of detention basins within designated park areas is not prohibited by the Specific Plan or the City’s General Plan Recreation Element.

Accordingly, the proposed use of Lots 5 and 6 for stormwater detention would not preclude its use for recreation but rather would result in a dual-purpose facility that provides both recreational amenities and necessary stormwater management functions.

Response to Comment I-3-51
This comment states that the Specific Plan specifies a second, 8-acre park, located within the Public Park District and adjacent to Cerritos Avenue, in addition to a 10.2-acre public park; however, Lots 5 and 6 would consist of only 7.37 acres of land.

The Specific Plan establishes the development of standards for land uses proposed as part of the proposed project. As established in the Specific Plan, 18.2 acres of land shall be set aside exclusively for two public parks within the Public Park District. This area was considered to be large enough to provide passive and active recreational uses. An additional 2 acres of public park will be, or have been, provided in one or more of the other Land Use Districts, for a total of approximately 20 acres of public parks.

As the 9-acre Lexington Park has already been developed adjacent to Lots 1 and 2 of VTTM 19247, the Buildout Area would include approximately 11 additional acres of land on which park and recreational uses would be developed. The specific amenities and improvements that would be developed in the Public Park District and additional 2 acres of public park space would be determined in connection with future development projects that are proposed within the Buildout Area. As such, the 7.37 acres of parkland within Lots 5 and 6 would represent a portion of the total parkland development within the Buildout Area, and the overall implementation of the proposed project would develop the Buildout Area with a total of approximately 20 acres of public parkland, S PECIFIC PLAN 3.0 B UILDOUT P ROJECT

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Overall, the amount of open space, improvements, and amenities in the final buildout is not known or defined at this programmatic stage of the proposed project, but would be consistent with requirements in the Specific Plan.

Response to Comment I-3-52
This comment notes that there is a land swap between the project developer and the Grace Church and asks if there is a conflict of interest for anyone who is involved on the project, including City Council, due to being a member of the church.

As discussed in Chapter 3.0, Project Description, of the Draft EIR, the proposed VTTM 19247 includes lots with a total land area of approximately 151.6 acres. The land subject to VTTM 19247 is greater than the Buildout Area as VTTM 19247 includes Lots 8 and 9 (17.55 acres), which are, or will be, part of the Grace Church property, located outside the area governed by the Specific Plan. The environmental analyses in the Draft EIR do not consider future development on Lots 8 and 9 of VTTM 19247. Because the comment does not contain any substantive comments or questions about the environmental analysis or conclusions contained in the Draft EIR, no further response is required.

Response to Comment I-3-53
This comment asks if there is a more recent version of the Drainage Report that has been approved by the City.

Appendix H-1 of the Draft EIR provides the Master Plan of Drainage for Specific Plan 3.0 Buildout Project, 4961 Katella Avenue, Cypress, CA (Drainage Report)15 prepared for the proposed project and dated February 25, 2026. Since publication of the Draft EIR, minor updates to the Drainage Report were made to provide internal document consistency updates and to include an updated exhibit from the Preliminary Water Quality Management Plan, Specific Plan 3.0 Buildout Project (PWQMP),16 which is included as Appendix H-2 to the Draft EIR. This updated Drainage Report17 was reviewed and approved by the City on March 11, 2026. These minor revisions did not substantially change the information and discussion provided in the Drainage Report and do not require revisions to the hydrology and water quality analysis contained in the Draft EIR or Section 4.10, Hydrology and Water Quality, of the Draft EIR.
15 TAIT & Associates, Inc. 2026a. Master Plan of Drainage for Specific Plan 3.0 Buildout Project, 4961 Katella Avenue, Cypress, CA. February 25. 16 TAIT & Associates, Inc. 2025. Preliminary Water Quality Management Plan, Specific Plan 2.0 Buildout Project. October 29. 17 TAIT & Associates, Inc. 2026b. Master Plan of Drainage for Specific Plan 3.0 Buildout Project, 4961 Katella Avenue, Cypress, CA. March 11.

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Response to Comment I-3-54
This comment expresses frustration over the amount and accessibility of project information available on the City’s website.

Information relating to the proposed project and Specific Plan is available on the City’s website at the following link: https://www.cypressca.org/departments/community-development/planningdivision/development-information.

In addition, in accordance with Public Resources Code Sections 21091(a) and 21092(b) and Sections 15105 and 15087(a) of the State CEQA Guidelines, a Notice of Availability (NOA) informing the public that a Draft EIR was prepared for the proposed project and was available for public review was posted to the City’s website on March 16, 2026. The NOA was also mailed to responsible and trustee agencies and those who had requested it as part of the Notice of Preparation (NOP) scoping process, and hardcopy versions of the NOA were posted at several locations in the vicinity of the Buildout Area. As detailed in the NOA, an electronic version of the Draft EIR was available to the public on the City’s website and a copy of the Draft EIR was available for public review at the Cypress Civic Center.

Therefore, the Draft EIR was posted and circulated for public review in accordance with all applicable noticing and CEQA public review requirements. In addition, Section 3.2, Specific Plan Background, in Chapter 3.0, Project Description, of the Draft EIR includes a discussion of the history of the Buildout Area and the iterations of the Specific Plans that were approved by the voters.

Response to Comment I-3-55
This comment states that the previous Specific Plan, prior to the current voter-approved Specific Plan, has been removed from the City’s website and that the public should be able to review it.

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From: ernie hanaoka <[email protected]>
Sent: Thursday, April 30, 2026 4:30 PM
To: Alicia Velasco <[email protected]>
Cc: ernie628 <[email protected]>; Cheryl Hanaoka <[email protected]> Subject: EIR could expand Katella Ave. traffic to beyond “significance” threshold To: Alicia Velasco, Planning Director for the City of Cypress We are Ernest and Cheryl Hanaoka, residents of Cypress (NE corner of Moody and Cerritos Ave.) We are concerned with the proposed over congestion of low to medium income residences of the pr To: Alicia Velasco, Planning Director for the City of Cypress We are Ernest and Cheryl Hanaoka, residents of Cypress (NE corner of Moody and Cerritos Ave.)
We are concerned with the proposed over congestion of low to medium income residences of the previous Los Alamitos race track property.

Parton explained that one alternative is to reduce the number of units by 30% from more than 1900 units to 1,253 units, which would ironically “be significantly closer to the scope previously approved by residents, prior to Measure S, which was 1,250 residences.

If the City Council approves the reduced scope in the EIR, the State will likely require the units to be zoned somewhere else. There is no reason why the only alternative needs to be Lincoln Avenue as proposed in Measure S.

In fact, Pardon said the housing element and other strategies were partly developed during the pandemic and now deserve a second look because conditions have changed.

We agree with George Pardon’s assessment.

Please re-assess the Katella Ave EIR and reduce the number of proposed residences.

Thank you for your consideration,
Ernest and Cheryl Hanaoka
Comment Letter I-4
I-4-1
I-4-2
I-4-3
I-4-4
I-4-5
I-4-6
I-4-7
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

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2.5.4 ERNEST AND CHERYL HANAOKA
Letter Code: I-4
Date: April 30, 2026
Response to Comment I-4-1
This comment provides introductory remarks.

Response to Comment I-4-2
This comment states that the commenters are concerned with the proposed over-congestion of low to medium income residences within the LARC property.

The proposed project was developed based on the Specific Plan that was approved by the voters of the City of Cypress on November 5, 2024, which allows for a maximum of 1,926 residential units, including the 135 units already permitted on the seven-acre Melia Property. Therefore, an additional 1,791 residential units (1,926 – 135) may be developed within the Buildout Area, as analyzed in the Draft EIR. The proposed project is consistent with the limits on residential development capacity provided in the voter-approved Specific Plan. In addition, it should be noted that the specific number of affordable (low income), moderate (medium income), or market rate units that would be constructed within the Buildout Area cannot be determined at this time. Future development projects associated with implementation of the proposed project would be reviewed by the City on a project-by-project basis in order to ensure that the proposed development complies with all State and affordable housing requirements.

Response to Comment I-4-3
This comment states that a community member has claimed that there is an alternative that would reduce the number of units by 30 percent (from more than 1,900 units to 1,253 units), which would be significantly closer to the scope previously approved by residents (1,250 residences), prior to Measure S.

The proposed project evaluated in the Draft EIR includes the construction of approximately 1,791 residential units, not over 1,900 residential units, within the Buildout Area. As summarized in Table

3.A: Specific Plan Land Use Plan Summary, in the Draft EIR, although the Specific Plan allows for a maximum of 1,926 residential units, this includes the units allowed on the seven-acre Melia Property. Melia Homes has previously developed the Belmont residential project with 135 units on the Melia Property. Therefore, an additional 1,791 residential units (1,926 – 135) may be developed within the Buildout Area.

On November 5, 2024, the voters of the City of Cypress approved the current Specific Plan pursuant to “Measure S” as part of the City’s Housing Element Implementation Project. The current Specific Plan replaced and superseded the 2018 Specific Plan. Because the current Specific Plan was S PECIFIC PLAN 3.0 B UILDOUT P ROJECT

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

Response to Comment I-4-4
This comment claims that if the City approved the Reduced Development Alternative, the State would likely require the units to be zoned somewhere, and there is no reason why the only alternative needs to be Lincoln Avenue, as proposed in Measure S.

Response to Comment I-4-5
This comment states that a community member claimed that the City’s Housing Element was partly developed during the COVID-19 pandemic and now deserves a second look as conditions have changed.

Response to Comment I-4-6
This comment states that the commenters agree with another community member’s assessment of the proposed project.

Response to Comment I-4-7
This comment asks the City to re-assess the Draft EIR and reduce the number of proposed residences.

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

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3.0 ERRATA
This section of the Final Environmental Impact Report (EIR) provides changes to the Draft EIR that have been made to clarify, correct, or add to the environmental impact analysis for the proposed Specific Plan 3.0 Buildout Project (project). Such changes are a result of further review of, and public comments related to, the Draft EIR. The changes described in this section are generally minor changes that do not constitute significant new information, change the conclusions of the environmental analysis, or require recirculation of the document (State California Environmental Quality Act [CEQA] Guidelines Section 15088.5).

Such changes to the Draft EIR are indicated in this section under the appropriate Draft EIR section.

Deletions are shown with strikethrough and additions are shown with underline. 1) Chapter 2.0, Introduction, Section 2.2.3, Draft EIR Public Review Period Table 2.A: Notice of Preparation Agency Comments Received has been revised to include the letter received by the California Department of Transportation (Caltrans), District 12 on May 5, 2025, in response to the Notice of Preparation (NOP) prepared for the proposed project.

This change was made for clarification only and has no effect on the analysis or conclusions contained in the Draft EIR. In addition, it should be noted that although this NOP comment letter was not included in Table 2.A of the Draft EIR, this letter was summarized and discussed in Section

4.17, Transportation, of the Draft EIR. Table 2.A of the Draft EIR is revised as follows:

Table 2.A: Notice of Preparation Agency Comments Received Agency/
Organization/
Individual
Date Comments
Addressed in
Section(s) of the
EIR
Native American
Heritage
Commission
(NAHC)
April 8, 2025 The NAHC outlined the City’s tribal consultation requirements under Assembly Bill 52.

Tribal Cultural
Resources
South Coast Air
Quality
Management
District
(SCAQMD)
April 23, 2025 SCAQMD raised concerns regarding potential air quality impacts, greenhouse gas emissions, and health risks
associated with the Specific Plan 3.0 Buildout Project.

SCAQMD recommends that the City rely on the SCAQMD’s
CEQA Air Quality Handbook and use California Emissions
Estimator Model (CalEEMod) to quantify emissions, applying both regional air quality significance thresholds and localized significance thresholds (LSTs). SCAQMD requests that the Draft EIR evaluate all phases of construction and operation, including overlapping activities, indirect sources (e.g., vehicle trips), and identify any new stationary or portable
equipment that would require SCAQMD permits, recognizing the agency as a Responsible Agency if applicable. SCAQMD emphasizes that if significant adverse impacts are identified, all feasible mitigation measures that go beyond existing legal requirements must be implemented, referencing resources Air Quality and
Greenhouse Gas
Emissions
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Organization/
Individual
Date Comments
Addressed in
Section(s) of the
EIR
such as the 2022 Air Quality Management Plan Mitigation Monitoring and Reporting Plan. SCAQMD further
recommends evaluating health risk reduction strategies, such as using enhanced air filtration systems rated MERV 13 (Minimum Efficiency Reporting Value) or better, and
requests that the Draft EIR analyze related secondary
impacts including increased energy consumption,
maintenance, waste generation, and potential limitations in filtration effectiveness.

Southern
California
Association of
Governments
(SCAG)
May 5, 2025 SCAG recommends that the City of Cypress evaluate the project’s alignment with the Connect SoCal 2024 Regional Transportation Plan/Sustainable Communities Strategy
(RTP/SCS), which outlines goals to reduce greenhouse gas emissions, improve regional air quality, and support an integrated multimodal transportation network. SCAG
emphasizes the use of its growth forecasts for population, housing, and employment in assessing potential impacts and planning infrastructure accordingly.

Although SCAG does not implement or approve projects, it advises the City to consult the Connect SoCal 2024 Program Environmental Impact Report 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 highlights 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 RTP/SCS goals.

Air Quality,
Transportation
Orange County
Public Works
(OCPW)
May 5, 2025 OCPW stated that it has no comments regarding the Notice of Preparation (NOP) for the Draft EIR.

Not applicable
California
Department of
Transportation
(Caltrans),
District 12
May 5, 2025 Caltrans requested that analysis and discussion of the 95 percent vehicle queue be included in the traffic analysis due to the additional trips on the off-ramp(s) that lead to the site and/or left-turn lane to on-ramp that came from the site at the Valley View Street interchange. Caltrans also stated that if there is an overflow to the adjacent lane(s), there is a potential cause of safety concerns.

Transportation
City of Garden
Grove1
June 3, 2025 The City of Garden Grove requested that a Level of Service (LOS) analysis be prepared for key intersections in the City of Garden Grove that may be impacted by project-related
traffic. The City of Garden Grove also provided their Traffic Impact Analysis guidelines.

Transportation
Source = LSA (2026).

Notes: All NOP response letters are included in Appendix A of this Draft EIR. 1 The comment letter from the City of Garden Grove was received after the close of the NOP comment period.

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Since publication of the Draft EIR, minor updates to the Drainage Report were made to provide internal document consistency updates and to include an updated exhibit from the Preliminary Water Quality Management Plan (PWQMP) prepared for the proposed project, which is included as Appendix H-2 to the Draft EIR. Accordingly, Appendix H-1 of the Draft EIR, which provides the Drainage Report prepared for the proposed project, has been updated to include the Drainage Report that was reviewed and approved by the City on March 11, 2026.

This change was made for clarification only and has no effect on the analysis or conclusions contained in the Draft EIR. The minor revisions made to the Drainage Report did not substantially change the information and discussion provided in the Drainage Report and do not require revisions to the hydrology and water quality analysis contained in the Draft EIR or further revisions Section

4.10, Hydrology and Water Quality, of the Draft EIR.
3) Section 4.17, Transportation
Based on comments received on the Draft EIR and project-specific VMT analysis, Figure 2 in the Vehicle Miles Traveled (VMT) Analysis for Specific Plan 3.0 Buildout Project (VMT Memo) prepared for the proposed project has been revised to include the planned Class II On-Road bike path that would bisect the Buildout Area connect Cerritos Avenue and Katella Avenue and the planning Class III On-Road bike path that would extend west from Walker Drive. Accordingly, Appendix K of the Draft EIR, which provides the VMT Memo prepared for the proposed project, has been updated to include the revised VMT Memo.

This change was made for clarification only and has no effect on the analysis or conclusions contained in the Draft EIR. The minor revisions made to the VMT Memo do not substantially change the information and discussion provided in the VMT Memo and do not require revisions to the VMT analysis contained in the Draft EIR or further revisions Section 4.17, Transportation, of the Draft EIR.

S PECIFIC PLAN 3.0 B UILDOUT P ROJECT

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ENVIRONMENTAL IMPACT REPORT
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MARCH 2026
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DRAFT

ENVIRONMENTAL IMPACT REPORT
SPECIFIC PLAN 3.0 BUILDOUT PROJECT

CYPRESS, CALIFORNIA
MARCH 2026
Submitted to:

City of Cypress
5275 Orange Avenue
Cypress, California 90630
Prepared by:

LSA
3210 El Camino Real, Suite 100
Irvine, California 92602
(949).553-0666
Project No. CCP2201.05
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SPECIFIC PLAN 3.0 BUILDOUT PROJECT

CYPRESS, CALIFORNIA

TABLE OF CONTENTS

1.0 EXECUTIVE SUMMARY ..................................................................................... 1-1

1.1 Introduction ...................................................................................................................... 1-1

1.2 Summary of Project Description ....................................................................................... 1-1

1.3 Potential Areas of Controversy ......................................................................................... 1-3

1.4 Summary of Impacts and Mitigation Measures ................................................................ 1-4

1.5 Alternatives ....................................................................................................................... 1-6

1.6 Summary of Impacts and Mitigation Measures ................................................................ 1-8

2.0 INTRODUCTION ................................................................................................ 2-1

2.1 Purpose and Type of EIR/Uses of the EIR .......................................................................... 2-1

2.2 Public Review Process ....................................................................................................... 2-3

2.3 Scope of this Draft EIR ....................................................................................................... 2-5

2.4 Format of this Draft EIR ..................................................................................................... 2-6

2.5 Incorporation by Reference .............................................................................................. 2-7

3.0 PROJECT DESCRIPTION ..................................................................................... 3-1

3.1 Project Location and Existing Environmental Setting ....................................................... 3-1

3.2 Specific Plan Background .................................................................................................. 3-9

3.3 Specific Plan Characteristics ............................................................................................ 3-10

3.4 Project Objectives ........................................................................................................... 3-13

3.5 Project Description .......................................................................................................... 3-14

4.0 EXISTING SETTING, ENVIRONMENTAL ANALYSIS, IMPACTS, AND MITIGATION MEASURES ................................................................................... 4-1

4.1 Aesthetics ....................................................................................................................... 4.1-1

4.2 Agriculture and Forestry Resources ............................................................................... 4.2-1

4.3 Air Quality ...................................................................................................................... 4.3-1

4.4 Biological Resources ....................................................................................................... 4.4-1

4.5 Cultural Resources ......................................................................................................... 4.5-1

4.6 Energy ............................................................................................................................. 4.6-1

4.7 Geology and Soils ........................................................................................................... 4.7-1

4.8 Greenhouse Gas Emissions ............................................................................................ 4.8-1

4.9 Hazards and Hazardous Materials ................................................................................. 4.9-1

4.10 Hydrology and Water Quality ...................................................................................... 4.10-1

4.11 Land Use and Planning ................................................................................................. 4.11-1

4.12 Mineral Resources ........................................................................................................ 4.12-1

4.13 Noise ............................................................................................................................. 4.13-1

4.14 Population and Housing ............................................................................................... 4.14-1

4.15 Public Services .............................................................................................................. 4.15-1

4.16 Recreation .................................................................................................................... 4.16-1

4.17 Transportation ............................................................................................................. 4.17-1

4.18 Tribal Cultural Resources ............................................................................................. 4.18-1

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4.20 Wildfire ........................................................................................................................ 4.20-1

5.0 ALTERNATIVES .................................................................................................. 5-1

5.1 Introduction ...................................................................................................................... 5-1

5.2 Proposed Project .............................................................................................................. 5-2

5.3 Alternatives Initially Considered but Rejected from Further Consideration .................... 5-6

5.4 Alternatives under Consideration ..................................................................................... 5-7

5.5 Alternatives Analysis ......................................................................................................... 5-8

5.6 Comparison of Alternatives and Identification of Environmentally Superior Alternative ...................................................................................................................... 5-75

6.0 OTHER CEQA CONSIDERATIONS ........................................................................ 6-1

6.1 Short-and Long-Term Implications ................................................................................... 6-1

6.2 Energy Impacts ................................................................................................................. 6-5

6.3 Summary of Significant Unavoidable Impacts .................................................................. 6-6

6.4 Significant Irreversible Environmental Changes ............................................................... 6-8

6.5 Growth-Inducing Impacts ................................................................................................. 6-9

7.0 LIST OF PREPARERS AND PERSONS CONSULTED ................................................ 7-1

7.1 City of Cypress .................................................................................................................. 7-1

7.2 Draft EIR Preparers ........................................................................................................... 7-1

7.3 Technical Report Preparers .............................................................................................. 7-1

7.4 Persons Consulted ............................................................................................................ 7-3

8.0 REFERENCES ..................................................................................................... 8-1

APPENDICES
A: Notice of Preparation, Scoping Summary Comments
B: Air Quality, CalEEMod Data Files
C: Biological Resources Report
D: Historic Resources Memo and Addendum
E: Energy Calculations
F: Geotechnical Report
G: Phase 1 Environmental Site Assessment
H-1: Drainage Report
H-2: Preliminary Water Quality Management Plan (PWQMP)
I: Noise Analysis
J: CPD Response Letter
K: Vehicle Miles Traveled (VMT) Memorandum
L: Assembly Bill 52 Consultation
M: Sewer Capacity Study
N: Water Supply Assessment (WSA)
0 : Will Serve Letters
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FIGURES
SPECIFIC PLAN 3.0 BUILDOUT PROJECT

CYPRESS, CALIFORNIA

FIGURES AND TABLES
Figure 3-1: Regional Location .............................................................................................................. 3-3 Figure 3-2: Buildout Area .................................................................................................................... 3-5 Figure 3-3: Surrounding Land Uses ...................................................................................................... 3-7 Figure 3-4: Specific Plan, Land Uses and Allowed Dwelling Units per Acre ...................................... 3-11 Figure 3-5: Vesting Tentative Map No. 19247 ................................................................................... 3-17 Figure 4-1: Related Projects ................................................................................................................ 4-5 Figure 4.10-1: Existing Condition Drainage Areas .......................................................................... 4.10-3 Figure 4.10-2: Proposed Drainage Areas ...................................................................................... 4.10-33 Figure 4.10-3: Proposed Drainage Management Areas ............................................................... 4.10-35 Figure 4.13-1: Noise Monitoring Locations .................................................................................... 4.13-3 Figure 4.15-1: School District Boundaries and Potential Residential Growth ................................ 4.15-7 Figure 5-1: Historic Preservation Alternative .................................................................................... 5-19 TABLES
Table 1.A Summary of Impacts and Mitigation Measures from this Draft EIR ................................... 1-9 Table 1.B: Applicable Regulatory Compliance Measures .................................................................. 1-19 Table 2.A: Notice of Preparation Agency Comments Received .......................................................... 2-4 Table 4.A: Summary of Related Projects ............................................................................................. 4-4 Table 4.3.A: Sources and Health Effects of Air Pollutants ................................................................ 4.3-7 Table 4.3.B: Federal and State Ambient Air Quality Standards ........................................................ 4.3-8 Table 4.3.C: Attainment Status of Criteria Pollutants in the South Coast Air Basin ....................... 4.3-10 Table 4.3.D: Ambient Air Quality at the Anaheim 1630 W. Pampas Lane Monitoring Station ...... 4.3-12 Table 4.3.E: SCAQMD Air Quality Significance Thresholds ............................................................. 4.3-20 Table 4.3.F: Unmitigated Regional Project Buildout Construction Emissions ................................ 4.3-22 Table 4.3.G: Unmitigated Regional Concurrent Grading Emissions ............................................... 4.3-27 Table 4.3.H: Unmitigated Regional Project Operational Emissions ............................................... 4.3-28 Table 4.3.1: Mitigated Project Operational Emissions .................................................................... 4.3-28 Table 4.3.J: CARB Recommendations for Siting New Sensitive Land Uses .................................... 4.3-36 Table 4.4.A: Vegetation/Land Cover Classifications at the Buildout Area ....................................... 4.4-2 Table 4.4.B: Summary of Potential Special-Status Species .............................................................. 4.4-5 Table 4.6.A: Energy Consumption Estimates during Construction ................................................ 4.6-13 Table 4.6.B: Energy Consumption Estimates at Buildout ............................................................... 4.6-14 Table 4.8.A: Global Warming Potential of Greenhouse Gases ......................................................... 4.8-3 Table 4.8.B: Greenhouse Gas Emissions (MT/yr) ........................................................................... 4.8-16 Table 4.8.C: Project Consistency with the 2022 Scoping Plan Key Residential and Mixed-Use Project Attributes that Reduce GHGs .................................................................................... 4.8-18 Table 4.10.A: Surface Water Quality Objectives for Inland Surface Waters ................................ 4.10-15 Table 4.10.B: Water Quality Objectives for Enclosed Bays and Estuaries .................................... 4.10-16 Table 4.10.C: Groundwater Quality Objectives for Groundwater Basins .................................... 4.10-17 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_public Draft EIR 2\Master TOC.docx «03/12/26» iii SPECIFI C PL AN 3.0 BUILDOUT PROJECT

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Table 4.10.D: Existing and Proposed Drainage Conditions .......................................................... 4.10-32 Table 4.11.A: Specific Plan Land Use Plan Summary ..................................................................... 4.11-8 Table 4.11.B: Maximum/Reasonably Foreseeable Project Buildout ........................................... 4.11-10 Table 4.11.C: Connect SoCal Consistency Analysis ...................................................................... 4.11-12 Table 4.11.D: General Plan Consistency Analysis ........................................................................ 4.11-14 Table 4.13.A: City of Cypress Interior and Exterior Noise Standards ........................................... 4.13-10 Table 4.13.B: Exterior Noise Level Standards .............................................................................. 4.13-11 Table 4.13.C: Interior Noise Level Standards ............................................................................... 4.13-11 Table 4.13.D: Interpretation of Vibration Criteria for Detailed Analysis ..................................... 4.13-12 Table 4.13.E: Construction Vibration Damage Criteria ................................................................ 4.13-12 Table 4.13.F: Off-Site Sensitive Receptors ................................................................................... 4.13-13 Table 4.13.G: Existing Noise Level Measurements ...................................................................... 4.13-14 Table 4.13.H: Typical Maximum Construction Equipment Noise Levels (Lmax) ............................ 4.13-19 Table 4.13.1: Traffic Noise Levels Without and With Proposed Project ....................................... 4.13-23 Table 4.13.J: Vibration Source Amplitudes for Construction Equipment .................................... 4.13-24 Table 4.14.A: Connect SoCal Population and Housing Forecasts {2019-2050) ............................. 4.14-2 Table 4.14.B: City of Cypress and Orange County Age Characteristics {2022) .............................. 4.14-3 Table 4.15.A: Incident Information for Fire Station Nos. 17, 46, and 84 (2022) ........................... 4.15-3 Table 4.15.B: Residential Lot Acreage and Residential Dwelling Units Distribution by School District ................................................................................................................................. 4.15-17 Table 4.15.C: Student Generation Factor .................................................................................... 4.15-18 Table 4.16.A: City of Cypress Parks and Recreational Facilities in the Vicinity of the Buildout Area ....................................................................................................................................... 4.16-3 Table 4.17.A: Project Residential VMT Impacts ........................................................................... 4.17-20 Table 4.19.A: Orange County Class Ill Landfills .............................................................................. 4.19-3 Table 4.19.B: Projected Water Demands by Use Through 2045 (AFY) .......................................... 4.19-6 Table 4.19.C: Total Water Supplies Available to GSWC West Orange Through 2045 (AFY) .......... 4.19-6 Table 4.19.D: Existing and Proposed Drainage Conditions .......................................................... 4.19-16 Table 5.A: Comparison of Project Buildout for the Proposed Project and Historic Preservation Alternative .......................................................................................................... 5-21 Table 5.B: Proposed Project and Project Alternatives Impact Comparison ..................................... 5-75 Table 5.C: Summary of Ability of the Proposed Project and Alternatives to Address Project Objectives ................................................................................................................................ 5-83 iv P:\A-E\CCP2201.05 IARC EIR\PRODUCTS\3_public Draft EIR 2\Master TOC.docx «03/12/26»

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µg/m3
AAQS
AB
ACMs
ACS
ACWM
ADA
ADT
AELUP
afy
AGR
ALUC
APA
APN
APS
APST
AQMP
ASBS
ASCE
AST
ASTM
AUHSD
Basin
Basin Plan
BEP
BER
BHMMP

LIST OF ACRONYMS AND ABBREVIATIONS
degrees Celsius
degrees Fahrenheit
micrograms per cubic meter
Ambient Air Quality Standards
Assembly Bill
asbestos-containing materials
American Community Survey
asbestos-containing waste material
Americans with Disabilities Act
average daily traffic
Airport Environs Land Use Plan
acre-feet per year
agricultural supply
Airport Land Use Commission
American Planning Association
Assessor's Parcel Number
Alternative Planning Strategy
Aboveground Petroleum Storage Tank
Air Quality Management Plan
Areas of Special Biological Significance
American Society of Civil Engineers
Aboveground Storage Tank
American Society for Testing and Materials
Anaheim Union High School District
South Coast Air Basin
Santa Ana RWQCB's Water Quality Control Plan
Business Emergency Plan
business environmental risk
Bat Habitat Mitigation and Monitoring Plan
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BMPs
BRA
BTU

CA MUTCD
CAA
CAAQS
CAFE

CAL FIRE
Cal/EPA
Cal/OSHA
CalARP
CalEEMod
CALGreen Code
California Register
Cal Recycle
Caltrans
CAPCOA
CARB
CARB Handbook
CBC
CCAA
CCR
CDFW
CDMG
CEC
CEQA
CERCLA
CERS
CESA
CFC
vi
Best Management Practices
Biological Resources Assessment
British Thermal Units
California Manual on Uniform Traffic Control Devices
Clean Air Act
California Ambient Air Quality Standards
Corporate Average Fuel Economy
California Department of Forestry and Fire Protection
California Environmental Protection Agency
California Occupational Safety and Health Administration California Accidental Release Prevention
California Emissions Estimator Model
California Green Building Standards Code
California Register of Historical Resources
California Department of Resources Recycling and Recovery California Department of Transportation
California Air Pollution Control Officers Association
California Air Resources Board
CARB's Air Quality and land Use Handbook: A Community Health Perspective
California Building Code
California Clean Air Act
California Code of Regulations
California Department of Fish and Wildlife
California Division of Mines and Geology (now known as the California Geological Survey or CGS)
California Energy Commission
California Environmental Quality Act
Comprehensive Environmental Response, Compensation, and Liability Act California Environmental Reporting System
California Endangered Species Act
California Fire Code
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CFGC
CFR
cfs
cfs/acre
CGS
CH4
CHRB
CHRIS
City
City MPD
CLCA
CMC
CMP
CNDDB
CNEL
CNPS
co
COM
ConnectSoCal2024
COSR
County
County Guidelines
CPD
CPT
CPTED
CPUC
CREC
CSD
California Fish and Game Code
Code of Federal Regulations
cubic feet per second
cubic feet per second per acre
California Geological Survey
methane
California Horse Racing Board
California Historical Resources Information System
City of Cypress
City of Cypress' Master Plan of Drainage
California Land Conservation Act of 1965
Cypress Municipal Code
Congestion Management Plan
California Natural Diversity Database
Community Noise Equivalent Level
California Native Plant Society
carbon monoxide
carbon dioxide
carbon dioxide equivalents
commercial
The 2024-2050 Regional Transportation Plan/Sustainable Communities Strategy of the Southern California Association of Governments Conservation/Open Space/Recreation
County of Orange
Guidelines For Evaluating Vehicle Miles Traveled Under CEQA for Orange County
Cypress Police Department
Cone Penetration Test
Crime Prevention Through Environmental Design
California Public Utilities Commission
controlled recognized environmental condition
Cypress School District
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CUPA
CWA
DAMP
dB
dBA
DDD
DDE
DDT
DIR
DMAs
DOC
DOSH
DPM
DPR
Draft EIR
DTSC
du/ac
DWR
EDD
EDR
EIA
EIR
EJ
EMFAC2025
EO
ESA
EV
FAA
FAR
FC
viii
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California Toxics Rule
Certified Unified Program Agency
Clean Water Act
Drainage Area Management Plan
decibel
A-weighted decibel
dichlorodiphenyldichloroethane
dichlorodiphenyldichloroethylene
dichlorodiphenyltrichloroethane
California Department of Industrial Relations
Drainage Management Areas
California Department of Conservation
Division of Occupational Safety and Health
diesel particulate matter
California Department of Parks and Recreation
Draft Environmental Impact Report

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California Department of Toxic Substances Control
dwelling units per acre
California Department of Water Resources
California Employment Development Department
Environmental Data Resources, Inc.

Energy Information Administration
Environmental Impact Report
environmental justice
California Emissions Factor Model, Version 2025
Executive Order
Environmental Site Assessment
electric vehicle
Federal Aviation Administration
Federal Aviation Regulation, also floor area ratio
Federal Candidate
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FCAA Federal Clean Air Act
FEMA Federal Emergency Management Agency
FESA Federal Endangered Species Act
FHSZs Fire Hazard Severity Zones
FHWA Federal Highway Administration
FIRM Federal Insurance Rate Map
FMMP Farmland Mapping and Monitoring Program
Forest Practice Act
FRA
FRAP
FSZ
FTA
FTA Manual
FY
g
GHG
GIS
gpy
GSP
GSWC
GWh
GWP
HA
HABS
HASP
HAZNET
HCD
HCOC
HCP
HCS
HOR
Z'Berg-Nejedly Forest Practice Act
Federal Responsibility Area
Fire and Resources Assessment Program
Farmland Security Zone
Federal Transit Administration
FTA's 2018 Transit Noise and Vibration Impact Assessment Manual Fiscal Year
acceleration due to gravity
greenhouse gas
Geographic Information System
gallons per year
Groundwater Sustainability Plan
Golden State Water Company
gigawatt-hours
Global Warming Potential
hydrologic area
Historic American Building Survey
Health and Safety Plan
DTSC's Hazardous Waste Tracking System
California Department of Housing and Community Development hydrologic conditions of concern
Habitat Conservation Plan
Habitat Classification System
High-Density Residential
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HFCs
HI
HMD
HMSS
HQTA
HQTC
HRA
HREC
HRI
HSA
HSC
HU
HVAC
HW
HWCL
1-5
1-405
1-605
ICC
IFC
in/sec
IND
IPaC
IPCC
IS/MND
ITE
JFTB Los Alamitos
kWh
LARC
LAUSD
LBP
X
hyd rofl uoroca rbons
hazard index
Hazardous Materials Disclosure
OCFA's Hazardous Materials Services Section
High Quality Transit Area
High-Quality Transit Corridor
Health Risk Assessment, also Historic Resources Assessment Historical Recognized Environmental Condition
California Historic Resources Inventory
hydrologic subarea
California Health and Safety Code
hydrologic unit
heating, ventilation, and air conditioning
Hazardous Waste
Hazardous Waste Control Law
Interstate 5
Interstate 405
Interstate 605
International Code Council
International Fire Code
inches per second
industrial service supply
Information for Planning and Consultation
Intergovernmental Panel on Climate Change
Initial Study/Mitigated Negative Declaration
Institute of Transportation Engineers
Joint Forces Training Base Los Alamitos
kilowatt-hours
Los Alamitos Race Course
Los Alamitos Unified School District
lead-based paint
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lbs/day pounds per day
LCFS low carbon fuel standard
LCI Governors' Office of Land Use and Climate Innovation, previously known LEED
LESA
Leq
Lmax
LID
LIP
LST
LUST
Lv
Ma
MBTA
MDR
MERV
mg/L
mgd
MICR
MLD
MMT
MMTCO2e
MPAH
mph
MPO
MRZ
MS4
MT
MT/yr
as the Governor's Office of Planning and Research
Leadership in Energy and Environmental Design
Land Evaluation and Site Assessment
day-night average noise level
equivalent continuous sound level
maximum noise level
Low Impact Development
Local Implementation Plan
Localized Significance Thresholds
Leaking Underground Storage Tank
root mean square vibration level
million years ago
Migratory Bird Treaty Act
Medium-Density Residential
Minimum Efficiency Reporting Value
milligrams per liter
million gallons per day
maximum individual cancer risk
Most Likely Descendant
million metric tons
million metric tons of carbon dioxide equivalents
Master Plan of Arterial Highways
miles per hour
Metropolitan Planning Organization
Mineral Resource Zone
Municipal Separate Storm Sewer System
metric tons
metric tons per year
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MTBE
MUN
MUTCD
MWD
MWDOC
N2O
NAAQS
NAGPRA
NAHC
National Register
NCCP

NCCP/HCP
NFHL
NFIP
NFPA
NHMLA
NHPA
NHTSA
NIMS
NMAs
NO2
NOC
NOE
NOi
NOP
NOT
NOx
NPDES
NPS
NRCS
O&M
xii
methyl tertiary butyl ether
municipal and domestic supply
California Manual of Uniform Traffic Control Devices
Metropolitan Water District
Municipal Water District of Orange County
nitrous oxide
National Ambient Air Quality Standards
Native American Graves Protection and Repatriation Act
Native American Heritage Commission
National Register of Historic Places
Natural Community Conservation Plan
Natural Community Conservation Plan/Habitat Conservation Plan National Flood Hazard Layer
National Flood Insurance Program
National Fire Protection Association
National History Museum of Los Angeles County
National Historic Preservation Act
National Highway Traffic Safety Administration
National Incident Management System
Neighborhood Mobility Areas
nitrogen dioxide
Notice of Completion
Notice of Exemption
Notice of Intent
Notice of Preparation
Notice of Termination
nitrogen oxides
National Pollutant Discharge Elimination System
National Park Service
Natural Resources Conservation Service
Operations and Maintenance
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03 OC Basin
OCSan
OCFA
OCFCD
OCHCA
OCPL
OCTA
OCTAM
OCWD
OHP
QPR
OSHA
OSHPD
OTB
P.A.C.E.

PA
Pb
PC
PCB
PCH
pCi/L
PDAs
PEIR
PFCs
Phase I ESA
PM
PM2.s
PM10
Porter-Cologne Act
ozone
Orange County Groundwater Basin
Orange County Sanitation District
Orange County Fire Authority
Orange County Flood Control District
Orange County Health Care Agency
Orange County Public Libraries
Orange County Transportation Authority
Orange County Transportation Analysis Model
Orange County Water District
California Office of Historic Preservation
Governor's Office of Planning and Research, now known as the Governors' Office of Land Use and Climate Innovation (LCI) Occupational Safety and Health Administration
Department of Health Care Access and Information
off track betting
Positive Actions through Character Education
Production-Attraction
lead
Planned Community
polychlorinated biphenyl
Pacific Coast Highway, also State Route 1
picocuries per liter
Priority Development Areas
Program Environmental Impact Report
perfluorocarbons
Phase I Environmental Site Assessment
particulate matter
particulate matter less than 2.5 microns in diameter
particulate matter less than al0 microns in diameter
Porter-Cologne Water Quality Control Act of 1970
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PPV
PRC
PROC
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parts per million
peak particle velocity
Public Resources Code
industrial process supply

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proposed project
PV
Specific Plan 3.0 Buildout Project
photovoltaic
PWQMP
QH
RCB
RCP
RCRA

RCRA-SQG
RECs
RHNA
RMS
ROCs
ROGs
ROW
RPS
RTIP
RTP

RTP/SCS
RWQCB
SA
SARFPA
SB
SCAG
SCAQMD
SCCIC
SCE
SCH
xiv
Preliminary Water Quality Management Plan
Quarter Horse
reinforced concrete box
Regional Comprehensive Plan, also reinforced concrete pipe Resource Conservation and Recovery Act
Resource Conservation and Recovery Act Small Quantity Generator Recognized Environmental Conditions
Regional Housing Needs Assessment
root-mean-square
reactive organic compounds
reactive organic gases
right-of-way
Renewables Portfolio Standard
Regional Transportation Improvement Program
Regional Transportation Plan
Regional Transportation Plan /Sustainable Communities Strategy Regional Water Quality Control Board
California Special Animal
Santa Ana River Flood Protection Agency
Senate Bill
Southern California Association of Governments
South Coast Air Quality Management District
South Central Coastal Information Center
Southern California Edison
State Clearinghouse
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SCS Sustainable Communities Strategy
SDSs Safety Data Sheets
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SEMS Standard Emergency Management System
SF6 sulfur hexafluoride
SGMA Sustainable Groundwater Management Act
SHL California Historical Landmarks
SHMA Seismic Hazard Mapping Act
SHMP California State Hazard Mitigation Plan
SHPO State Historic Preservation Officer
SIP State Implementation Plan
SLF Sacred Lands File
SMARA Surface Mining and Reclamation Act
SMARTS Stormwater Multiple Application and Report Tracking System SMGB California State Mining and Geology Board
SO2 sulfur dioxide
SoCalGas Southern California Gas Company
Specific Plan Cypress Town Center and Commons Specific Plan 3.0 SPHI California Points of Historical Interest
SPT Standard Penetration Test
SR-1 State Route 1, also PCH
SR-22 State Route 22
SR-39 State Route 39, also Beach Boulevard
SR-55 State Route 55
SR-91 State Route 91
SRA State Responsibility Area
SSC California Species of Special Concern
ST California State Threatened
State State of California
State CEQA Guidelines Guidelines for the California Environmental Quality Act SVP Society of Vertebrate Paleontology
SWPPP Stormwater Pollution Prevention Plan
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SWRCB
TACs
TAZ
TB
TCP
TCRs
TDM
TDS
TGD, also Technical
Guidance Document
TIA
TMDL
TPAs
TPZs
Tribe
TTM
TUA
U.S.

UNFCCC
USACE
USC
USDA
USDOT
USEPA
USFWS
USGS
UST
UWMP
VdB
VECs
xvi
State Water Resources Control Board
Toxic Air Contaminants
Transportation Analysis Zones
thoroughbred
transportation construction plan
tribal cultural resources
Transportation Demand Management
total dissolved solids
Technical Guidance Document (TGD) for the Preparation of Conceptual/Preliminary and/or Project Water Quality Management Plans
Traffic Impact Analysis
Total Maximum Daily Loads
Transit Priority Areas
Timberland Production Zones
Gabrielefio Band of Mission Indians - Kizh Nation
Tentative Tract Map
Traditional Use Area
United States
United Nations Framework Convention on Climate Change
United States Army Corps of Engineers
United States Code
United States Department of Agriculture
United States Department of Transportation
United States Environmental Protection Agency
United States Fish and Wildlife Service
United States Geological Survey
underground storage tank
Urban Water Management Plan
vibration velocity decibels
vapor encroachment conditions
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VHFHSZ very high fire hazard severity zone
VMT vehicle miles traveled
voes volatile organic compounds
VTTM Vesting Tentative Tract Map
WHO World Health Organization
WOTUS Waters of the United States
WQMP Water Quality Management Plan
WSA Water Supply Assessment
WUI Wildland Urban Interface
ZEVs zero emission vehicles
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1.1 INTRODUCTION

1.0 SPECIFIC PLAN 3 . 0 BUILDOUT PROJECT

CYPRESS, CALIFORNIA

EXECUTIVE SUMMARY
The California Environmental Quality Act {CEQA) requires that local government agencies, before taking action on projects over which they have discretionary approval authority, consider the environmental consequences of such projects. An Environmental Impact Report (EIR) is a document designed to provide to the public and to local and State governmental agency decision-makers an analysis of potential environmental consequences of a project to support informed decision-making.

This Draft EIR (Draft EIR) has been prepared by the City of Cypress (City) to evaluate environmental impacts associated with the proposed Specific Plan 3.0 Buildout Project (proposed project); to discuss alternatives; and to propose mitigation measures that will minimize, offset, or otherwise reduce or avoid the identified potentially significant environmental impacts.

This Draft EIR has been prepared pursuant to the requirements of CEQA and the State CEQA Guidelines. The City is the Lead Agency, and as such, has reviewed all submitted drafts, technical studies, and reports for consistency with applicable City regulations and policies and has commissioned the preparation of this EIR to reflect its own independent judgment.

Data for this Draft EIR was obtained from on-site field observations; discussion with affected agencies; review of adopted plans and policies; review of available studies, reports, and data; and specialized environmental assessments prepared for the project (e.g., air quality, biology, geology, hazards, historic, hydrology and water quality, noise, utilities, and traffic).

The Executive Summary is intended to highlight the major areas of importance in the environmental analysis for the proposed project as required by State CEQA Guidelines Section 15123. The Executive Summary includes a brief description of the proposed project, areas of controversy known to the City, including issues raised by agencies and the public, a summary of the significant unavoidable impacts of the proposed project, and a summary of alternatives evaluated in the EIR. This Executive Summary also provides a table summarizing (1) the potential environmental impacts that would occur as a result of project implementation and operation; (2) the level of significance prior to implementation of mitigation measures; (3) regulatory compliance measures and mitigation measures that avoid or reduce the significant impacts of the proposed project, and (4) the level of significance after mitigation measures are implemented.

1.2 SUMMARY OF PROJECT DESCRIPTION
The proposed project analyzed in this Draft EIR consists of the reasonably foreseeable buildout of a portion of the area governed by the Cypress Town Center and Commons Specific Plan 3.0 (Specific Plan) that includes approximately 134 acres of land (Buildout Area) in Cypress. The City of Cypress voters approved the Specific Plan on November 5, 2024, pursuant to "Measure S" as part of the Housing Element Implementation Project. The proposed project includes the approval of Vesting Tentative Tract Map No. 19247 (VTTM 19247). VTTM 19247 includes lots with a total land area of approximately 151.6 acres. The land subject to VTTM 19247 is greater than the Buildout Area as VTTM 19247 includes Lots 8 and 9 (17.55 acres), which are, or will be, part of the Grace Church P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_public Draft EIR 2\1.0 Executive Summary.docx (03/12/26) 1-1 SPECIFI C PL AN 3.0 BUILDOUT PROJECT

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property, which is located outside the area governed by the Specific Plan. The environmental analyses in this Draft EIR do not consider future development on Lots 8 and 9 of VTTM 19247.

In addition, the proposed project does not consider the development of two discrete portions of the land subject to the Specific Plan, which include (1) seven acres of land within the area governed by the Specific Plan (Melia Property) that Melia Homes has previously developed as the Belmont residential project (State Clearinghouse [SCH] 2020099025) and (2) nine acres of land on which the City has previously developed Lexington Park. The Specific Plan also included 20 acres of public park space spread throughout the Specific Plan Area. The City previously constructed Lexington Park on nine acres of that land, which land was donated to the City by Cypress GC, LLC.

The proposed project evaluated in this Draft EIR includes 1,791 residential units and 440,000 square feet of non-residential uses that could occur within the Buildout Area.

1.2.1 Project Characteristics
Residential Development: As summarized in Table 3.A: Specific Plan Land Use Plan Summary in Chapter 3.0, Project Description, the Specific Plan allows for a maximum of 1,926 residential units, including the units allowed on the seven-acre Melia Property. Melia Homes previously developed the Belmont residential project with 135 units on the Melia Property. Therefore, as shown in Table 3.A, an additional 1,791 residential units (1,926 - 135) may be developed within the Buildout Area.

Non-Residential Development: As shown in Table 3.A, the Specific Plan permits an aggregate maximum of 879,170 square feet of non-residential floor area within the Buildout Area. However, it is anticipated that, based on current and reasonably foreseeable future market conditions, the buildout of the Buildout Area will include substantially less than 879,170 square feet of nonresidential development. Therefore, the environmental analyses in this Draft EIR are based in part on the assumption that only 440,000 square feet of non-residential development will occur within the Buildout Area. This represents approximately 50 percent of the maximum amount of permitted non-residential development. If non-residential development that cumulatively exceeds 440,000 square feet is later proposed within the Buildout Area, additional environmental review in accordance with the provisions of CEQA and the State CEQA Guidelines may be required if and to the extent such non-residential development requires any discretionary action by the City.

Development of Lot 14: Melia Homes has proposed a project (Lot 14 Project) on the entirety of Lot 14 in proposed VTTM 19247, which includes approximately 7.33 acres of land, as shown on Figure 3-5: Vesting Tentative Map No. 19247 and Table 3.8: Maximum/Reasonably Foreseeable Project 8uildout, in Chapter 3.0, Project Description. The Lot 14 Project includes the subdivision of proposed Lot 14 into 8 lots (Lots 1-6, A and B) for condominium purposes for the construction and sale of 112 attached townhomes, with common areas for landscaping, recreation center, parking, drive aisles and easements. The Lot 14 Site is located in the Mixed-Use (Town Center/MOR) District established in the Specific Plan.

As shown in in Table 3.8, the analyses in this Draft EIR are based on the assumed development of Lot 14 with 128 residential units and a portion of the 440,000 square feet of non-residential 1-2 P:\A-E\CCP2201.05 IARC EIR\PRODUCTS\3_public Draft EIR 2\1.0 Executive Summary.docx «03/12/26»

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SPECIFIC PL AN 3 . 0 BUILDOUT PROJECT

CYPRE SS, CALIFORNIA
development that is anticipated to occur in the Buildout Area. Given that the Lot 14 Project includes only 112 residential units (fewer than the 120 residential units assumed for analytical purposes in this Draft EIR) and no non-residential uses, the environmental analyses in this Draft EIR fully account for the proposed Lot 14 Project and are conservative in that they overstate the environmental impacts associated with the development of Lot 14.

1.2.2 Relationship to Lots in VTTM 19247
As shown in Figure 3-5: Vesting Tentative Map No. 19247 in Chapter 3.0, Project Description, proposed VTTM 19247 would divide the Buildout Area and other land currently owned by Grace Church into 14 numbered lots. The numbered lots would accommodate the development of residential, non-residential and park and recreational uses. VTTM 19247 also includes existing Siboney Street, land that would be used to expand a portion of Lexington Drive adjacent to Lot 1 and Lexington Park, the further extension of Vessels Circle between Lots 7 and 12 and the extension of Moody Street to connect to Siboney Street, with Siboney Street becoming part of Moody Street.

In accordance with the approved Specific Plan, the proposed project evaluated in this Draft EIR includes residential development on Lots 2 through 4, 7, and 10 through 14, non-residential development on Lots 10 through 14, and the development of park and recreational improvements on Lots 1, 5 and 6 (as well as two additional acres within the Specific Plan that will be specified in the future).

Development on Lots 1, 5 and 6 is limited to park and recreational uses. The Public Park District includes 18.2 of specifically identified land, which includes the nine acres of land that the City previously developed as Lexington Park following its approval as the Cypress Sports Park Project (SCH No. 2019089093).

The proposed project evaluated in this Draft EIR does not assume any development on Lots 8 and 9.

Grace Church owns Lot 9 where its existing church facilities are located. It is anticipated that Grace Church would acquire Lot 8 from LARC in exchange for transferring ownership of Lots 5 and 10 to LARC. Following this anticipated land swap, Grace Church would own Lots 8 and 9, which collectively include approximately 17.55 acres of land and are not located within the Buildout Area. Lots 8 and 9 have been included in VTTM 19247 solely in connection with the contemplated land swap and no development is presently contemplated on those lots by Grace Church.

The maximum residential buildout and reasonably foreseeable non-residential buildout of the Buildout Area pursuant to the Specific Plan, shown in Table 3.B, reflects the land swap described above and therefore includes Lots 5 and 10, and excludes Lots 8 and 9.

1.3 POTENTIAL AREAS OF CONTROVERSY
Pursuant to State CEQA Guidelines Section 15123, this Draft EIR acknowledges the areas of controversy and issues to be resolved that are known to the City or were raised during the scoping process. The City held a public scoping meeting on April 16, 2025, to present the proposed project and to solicit input from interested parties regarding environmental issues that should be addressed in this Draft EIR. One member of the public attended the scoping meeting. They did not raise any issues or concerns about the proposed project.

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During the Notice of Preparation (NOP) comment period, the City received five comment letters, including from the Native American Heritage Commission (NAHC), South Coast Air Quality Management District {SCAQMD), Southern California Association of Governments {SCAG), the Orange County Public Works Department {OCPW), and the California Department of Transportation {Caltrans). These letters included comments related to tribal cultural resources, air quality, greenhouse gas emissions, and transportation impacts with implementation of the proposed project. In addition, one letter, from the City of Garden Grove, was received after the close of the NOP comment period and included comments related to transportation impacts with implementation of the proposed project.

This Draft EIR addresses the above areas of concern in detail, examines project-related and cumulative environmental impacts, identifies significant adverse environmental impacts, and proposes mitigation measures and/or alternatives designed to reduce or eliminate potentially significant impacts. Appendix A to this Draft EIR includes the written comments received in response to the NOP and a comment summary.

1.4 SUMMARY OF IMPACTS AND MITIGATION MEASURES
Section 15126.2{b) of the State CEQA Guidelines requires that an EIR describe significant environmental impacts that cannot be avoided, including those effects that can be mitigated but not reduced to a less than significant level. This summary provides an overview of the analysis contained in Chapter 4.0, Setting, Impacts, and Mitigation Measures, ofthis Draft EIR.

1.4.1 Significant Impacts
Under CEQA, a significant impact on the environment is defined as " ... a substantial, or potentially substantial, adverse change in any of the physical conditions within the area affected by the project, including land, air, water, minerals, flora, fauna, ambient noise, and objects of historic or aesthetic significance." As discussed in more detail in Chapter 4.0 of this Draft EIR, impacts in the following areas would be potentially significant without the implementation of mitigation measures, but would be reduced to a less than significant level if the mitigation measures recommended in this Draft EIR are implemented:
• Biological Resources • Hydrology and Water Quality
• Geology and Soils • Transportation
• Greenhouse Gas Emissions • Tribal Cultural Resources
• Hazards and Hazardous Materials
In addition, as discussed in more detail in Chapter 4.0 of this Draft EIR, impacts in the following areas would be significant and unavoidable, even with implementation of mitigation measures recommended in this Draft EIR, as discussed in more detail below:
• Air Quality • Transportation
• Cultural Resources
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1.4.1.1 Air Quality
SPECIFIC PLAN 3 . 0 BUILDOUT PROJECT

CYPRESS, CALIFORNIA
Conflict with Air Quality Plan. Although the proposed project would be consistent with Indicator 2 of SCAQMD's 2022 Air Quality Management Plan (AQMP) as the proposed project would not exceed the growth assumptions in the SCAG's 2024-2050 RTP/SCS (Connect SoCal 2024) or the 2022 AQMP, the proposed project would have the potential to conflict or obstruct implementation of applicable air quality plans under Indicator 1 of the 2022 AQMP because buildout of the proposed project would result in significant and unavoidable long-term operational pollutant emissions. Although there is no feasible mitigation to reduce operational pollutant emissions to a less than significant level, Mitigation Measure AIR-1 and Mitigation Measure TRA-1 would incorporate design features that would contribute to reducing criteria air pollutant emissions generated during operational activities associated with the proposed project. Nevertheless, because the proposed project would conflict with Indicator 1, impacts related to conflict with the applicable air quality plan would be significant and unavoidable.

Operational Emissions. As discussed in Section 4.3, Air Quality, operational emissions associated with the proposed project would exceed the South Coast Air Quality Management District's (SCAQMD) thresholds and it is assumed that construction and operational emissions combined would exceed the significance threshold established by the SCAQMD for daily project emissions.

Mitigation Measure AIR-1, which requires the implementation of all feasible measures to reduce operational impacts associated with buildout envisioned under the proposed project, and Mitigation Measure TRA-1, which requires the implementation of Transportation Demand Management (TDM) strategies to lower project VMT for the proposed project's residential component, would further reduce impacts. With implementation of Mitigation Measure AIR-1 and Mitigation Measure TRA-1, NOx emissions would be reduced to below the SCAQMD's significance criteria. However, VOC emissions would still exceed the SCAQMD's significance criteria. As there are no additional feasible mitigation measures that would reduce project operational-source VOC emissions to a less-than-significant level, operation of the proposed project would result in a significant and unavoidable impact related to a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable federal or State ambient air quality standard.

1.4.1.2 Cultural Resources
Historical Resources. Proposed project implementation would include the demolition of the character-defining features of the LARC Property and as such would result in a substantial adverse change to a historic architectural resource under CEQA, as outlined in Section 4.5, Cultural Resources, of this Draft EIR, which is a potentially significant impact.

The proposed project would be required to implement Mitigation Measures CUL-1 through CUL-3 which require documentation, interpretation, and archival preservation of the Los Alamitos Race Course's historic significance prior to demolition or redevelopment. Measures include (1) the donation of historic photographs and memorabilia to a local library or Orange County-based historical society for exhibit or archival purposes; (2) incorporation of on-site interpretive features such as a publicly accessible historical marker and/or design elements referencing Frank Vessels, Sr., the Vessels family, racing history, and notable Quarter Horses; and (3) preparation of HABS-like documentation, consistent with the Secretary of the Interior's Standards, by a qualified historian P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_public Draft EIR 2\1.0 Executive Summary.docx (03/12/26) 1-5 SPECIFI C PL AN 3.0 BUILDOUT PROJECT

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prior to demolition of any character-defining features. The documentation would include photographic recordation, a detailed historical narrative, and archival research, with materials donated to appropriate local and regional archival repositories. However, impacts to historical resources as defined in State CEQA Guidelines Section 15064.5 would remain significant and unavoidable.

1.4.1.3 Transportation
Vehicle Miles Traveled. As discussed in Section 4.17, Transportation, the residential component of the proposed project would result in a higher VMT per capita than the County's residential VMT significance thresholds under both existing and cumulative plus project conditions by 11.6 percent, and thus would result in a potentially significant impact. As such, the proposed project would be required to implement feasible TDM strategies to mitigate the proposed project's VMT impact, as detailed in Mitigation Measure TRA-1.

These VMT reduction measures include constructing or improving bicycle facilities that would connect the proposed project to the existing regional bicycle network and improving the pedestrian network, including the construction of off-site sidewalks to improve sidewalk coverage and pedestrian access to the surrounding area. However, the implementation of these measures would only reduce the proposed project's residential VMT impact by 1.2 percent. As such, even with implementation of the identified TDM strategies, the proposed project's residential VMT impact would remain significant, with a residential VMT impact of 10.4 percent over the significance threshold. Therefore, the proposed project's VMT impact would be significant and unavoidable.

1.4.2 Cumulative Impacts
CEQA defines cumulative impacts as "two or more individual effects which, when considered together, are considerable, or which can compound or increase other environmental impacts." Section 15130 of the State CEQA Guidelines requires that an EIR evaluate potential environmental impacts that are individually limited but cumulatively significant. These impacts can result from the proposed project when combined with other past, present, or reasonably foreseeable future projects. As discussed in more detail in Chapter 4.0 of this Draft EIR, cumulative impacts in the following areas would be significant and unavoidable, even with implementation of mitigation measures recommended in this Draft EIR:
• Air Quality • Transportation
• Cultural Resources

1.5 ALTERNATIVES

1.5.1 Alternatives Evaluated in this Draft EIR
Public Resources Code (PRC) Section 21100 and State CEQA Guidelines Section 15126 require an EIR to identify and discuss a No Project Alternative and a reasonable range of alternatives to the proposed project that would feasibly attain most of the basic objectives of the project and would avoid or substantially lessen any of the significant environmental impacts. The following three alternatives have been determined to represent a reasonable range of alternatives that have the 1-6 P:\A-E\CCP2201.05 IARC EIR\PRODUCTS\3_public Draft EIR 2\1.0 Executive Summary.docx «03/12/26»

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potential to feasibly attain most of the basic objectives of the proposed project but that may avoid or substantially lessen any of the significant impacts of the proposed project. Therefore, the alternatives considered in this Draft EIR include the following:
• No Project Alternative. Under the No Project Alternative, the Buildout Area would not be developed with new residential or non-residential uses. The Buildout Area would remain as it is in its current condition, with no demolition of existing structures, grading, or new construction occurring within the Buildout Area. Specifically, the Buildout Area would remain developed with the existing structures and facilities that support horse racing, training, and community activities, including the race track, grandstand structure, three 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 barn; and parking structures.

In addition, the roadway improvements and extensions envisioned under the proposed project would not occur.
• Historic Preservation Alternative. The Historic Preservation Alternative would develop new residential and non-residential uses within the Buildout Area; however, the character-defining features at the LARC Property would be retained and converted into a performance venue for future concerts, plays, and other entertainment performances. Lots 5 through 8 and portions of Lots 3 and 4 would be used as a park/recreational use that is open to the public when the performance venue is not in use. Overall, the Historic Preservation Alternative would result in development of approximately 1,400 residential units and 440,000 square feet of nonresidential development. The existing character-defining features of the LARC Property that would be retained include the original pre-1970 track, the 1954 quarter-mile chute, the infield and ponds, and a portion of the grandstand, as outlined in Section 5.5.2 below. All non-historic features of the race course, including the race-track extensions, barns, temporary buildings, clubhouse building, and annex would be demolished. Siboney Street would only be extended to the intersection of Vessels Circle and would not extend to Moody Street. Existing restaurants, food service, and the three existing lakes within the original race track would be retained. • Reduced Development Alternative (30% Reduction). Under the Reduced Development Alternative, the overall intensity of the proposed project, including residential and commercial development, would be reduced by 30 percent. As such, the Reduced Development Alternative would facilitate the future development of 1,253 residential units and approximately 308,000 square feet of non-residential uses.

1.5.2 Identification of the Environmentally Superior Alternative:

CEQA requires the identification of an Environmentally Superior Alternative among the proposed project and the alternatives evaluated in an EIR. State CEQA Guidelines Section 15126.6(e)(2) provides that, if the No Project Alternative is the Environmentally Superior Alternative, then the EIR shall also identify an Environmentally Superior Alternative among the other alternatives and the proposed project.

The No Project Alternative would have the fewest environmental impacts and would be the environmentally superior alternative. However, under CEQA, if the No Project Alternative is the P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_public Draft EIR 2\1.0 Executive Summary.docx (03/12/26) 1-7 SPECIFI C PL AN 3.0 BUILDOUT PROJECT

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environmentally superior alternative, the EIR must identify an environmentally superior alternative from among the other alternatives (State CEQA Guidelines Section 15126.6{e)(2)). While the No Project Alternative would be environmentally superior in the technical sense in that contribution to the aforementioned impacts would not occur, it would also fail to achieve any of the project's objectives. Because the Historic Preservation Alternative would avoid the significant and unavoidable impact to historical resources as defined in State CEQA Guidelines Section 15064.5 associated with the proposed project, the Historic Preservation Alternative is considered the Environmentally Superior Alternative. As discussed above, the Reduced Development Alternative would not avoid the significant and unavoidable impact on historical resources as it would include the demolition and removal of the character-defining features that contribute to the LARC Property's eligibility for listing in the National Register and California Register. None of the selected alternatives would avoid the significant and unavoidable impacts associated with VMT, air quality, or greenhouse gas emissions. Accordingly, the Historic Preservation Alternative is considered the Environmentally Superior Alternative.

1.6 SUMMARY OF IMPACTS AND MITIGATION MEASURES
Information in Table 1.A: Summary of Impacts and Mitigation Measures from this Draft EIR summarizes the mitigation measures identified in this Draft EIR and has been organized to correspond with environmental issues discussed in Chapter 4.0. Table 1.B: Applicable Regulatory Compliance Measures summarizes the regulatory compliance measures that would be applicable to the proposed project. Table 1.A is arranged in four columns: (1) impacts; (2) level of significance without mitigation; (3) regulatory compliance measures and/or mitigation measures; and (4) level of significance with mitigation. Table 1.B is arranged in two columns: (1) environmental issue areas and (2) regulatory compliance measures. Levels of significance are categorized as follows:
1-8
PS
LTSM
SU
Potentially Significant
Less Than Significant with Mitigation
Significant and Unavoidable
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Table 1.A: Summary of Impacts and Mitigation Measures from this Draft EIR Environmental Impacts

4.1 AESTHETICS
There are no significant impacts related to aesthetics.

4.2 AGRICULTURE AND FORESTRY RESOURCES
There are no significant impacts related to agriculture and forestry resources.

4.3 AIR QUALITY
Long-term operational emissions associated with the proposed project would exceed the SCAQMD's established significance thresholds, which would be inconsistent with Indicator 1 of the SCAQMD's 2022 AQMP.

Level of
Significance
Without
Mitigation
PS
Mitigation Measures
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 Planning Division shall identify project design details and specifications, where feasible, to document implementation and 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.
• 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.

SPECIFIC PLAN 3.0 BUILDOUT PROJECT

CYPRESS, CALIFORNIA
Level of Significance With Mitigation
SU
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Table 1.A: Summary of Impacts and Mitigation Measures from this Draft EIR Environmental Impacts
Long-term operational emissions associated with the proposed project would exceed the SCAQMD's established significance thresholds, which would result in a cumulatively considerable net increase in a criteria pollutant for which the Basin is in nonattainment (i.e., voe emissions).

Construction activities associated with future development of the proposed project could generate emissions of particulate matter and diesel exhaust from heavy-duty equipment, which could expose sensitive receptors to substantial pollutant concentrations.

4.4 BIOLOGICAL RESOURCES
Implementation of the proposed project would remove the single drainage feature located on Lot 3, which could be subject to regulation by the RWQCB and CDFW.

4.5 CULTURAL RESOURCES
Construction of the proposed project would include the demolition of character defining features of the LARC Property, which is considered a "historical resource" for the purposes of CEQA.

Level of
Significance
Without
Mitigation
PS
PS
PS
PS
Mitigation Measures
Mitigation Measure AIR-1. (provided above)
Mitigation Measure TRA-1: Transportation Demand Management Strategies. (Refer to Section 4.17, Transportation, below)
Mitigation Measure AIR-2: All construction activities in the Buildout Area shall utilize U.S.

EPA Tier 4 Final diesel construction equipment for equipment rated at greater than 50 brake horsepower (bhp) if and to the extent commercially available, or the cleanest available equipment and technology that is commercially available and feasible at the time of construction (e.g., zero-emission or equivalent low-emission equipment), to minimize diesel particulate matter (DPM) emissions.

If Tier 4 Final equipment is not commercially available for a majority of the construction equipment and an individual development project would be larger than 20 acres, the City shall require preparation of a construction Health Risk Assessment (HRA) for such development project.

If a construction HRA is required, it shall be prepared in accordance with current OEHHA methodology and applicable SCAQMD CEQA and health risk assessment guidance.

Additional feasible risk-reduction measures identified through the HRA process shall be implemented as determined necessary by the City.

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. • US Army Corps of Engineers (USACE) Jurisdiction (Waters of the United States [WOTUS]): The determination that no federal WOTUS occur onsite 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 Stream bed Alteration Agreement) shall be obtained prior to construction.

Mitigation Measure CUL-1: 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.

Level of Significance With Mitigation
SU
LTSM
LTSM
SU
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Table 1.A: Summary of Impacts and Mitigation Measures from this Draft EIR Environmental Impacts
Ground disturbing activities during construction for future development under the proposed project, including grading and excavation, has the potential to unearth previously unknown human remains.

4.6 ENERGY
There are no significant impacts related to energy.

4.7 GEOLOGY AND SOILS
The Buildout Area is located in a liquefaction hazard zone. The on-site soils are considered to be susceptible to liquefaction settlement during an earthquake, and 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, implementation of the proposed project could result in differential settlements that could directly or indirectly cause potential substantial adverse effects, including risk of loss, injury, or death from liquefaction.

P:\A-E\CCP2201.0S LARC EIR\PRODUCTS\3_Public Draft EIR 2\1.0 Executive Summary.docx (03/12/26) Level of
Significance
Without
Mitigation
PS
PS
Mitigation Measures
Mitigation Measure CUL-2: 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 Clabber, Go Man Go, or Moonist).

Mitigation Measure CUL-3: 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 identified 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:
• 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.

Mitigation Measure TCR-3: Unanticipated Discovery of Human Remains and Associated Funerary Objects. (Refer to Section 4.18, Tribal Cultural Resources) Mitigation Measure TCR-4: Procedures for Burials and Funerary Remains. (Refer to Section 4.18, Tribal Cultural Resources)
Mitigation Measure GEO-1: 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 may consist of rammed aggregate piers, vibrated aggregate piers, or similar techniques. The ground improvements must be designed by a qualified ground SPECIFIC PLAN 3.0 BUILDOUT PROJECT

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Level of Significance With Mitigation
LTSM
LTSM
1-11
1-12
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Table 1.A: Summary of Impacts and Mitigation Measures from this Draft EIR Environmental Impacts
Proposed structures constructed 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.

Construction activities associated with implementation of the proposed project could disturb native alluvium at a depth below 10 feet, which could result in impacts on unknown paleontological resources.

Level of
Significance
Without
Mitigation
PS
PS
Mitigation Measures
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).

Mitigation Measure GE0-1: Implementation of Geotechnical Investigation Recommendations. (provided above)
Mitigation Measure GE0-2: 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 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 Level of Significance With Mitigation
LTSM
LTSM
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Table 1.A: Summary of Impacts and Mitigation Measures from this Draft EIR Environmental Impacts

4.8 GREENHOUSE GAS EMISSIONS
Implementation of the proposed project would generate GHG emissions that could create a significant impact on the environment.

Level of
Significance
Without
Mitigation
PS
Mitigation Measures
material to the museum repository.

Mitigation Measure GEO-3: 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 grounddisturbing 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.

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, future project applicants 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.
• 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 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 SPECIFIC PLAN 3.0 BUILDOUT PROJECT

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Level of Significance With Mitigation
LTSM
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Table 1.A: Summary of Impacts and Mitigation Measures from this Draft EIR Level of
Environmental Impacts Significance Mitigation Measures Level of Significance With Mitigation Without Mitigation
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, lowwater, or drought-tolerant plant species. • Install rainwater harvesting systems, where feasible . • Prohibit or restrict the use of potable water for cleaning non-vegetated 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: (Refer to Section 4.3, Air Quality, above) Mitigation Measure TRA-1: Transportation Demand Management Strategies. (Refer to Section 4.17, Transportation, below)
Long-term operational emissions associated with the proposed project would exceed the SCAQMD's established PS Mitigation Measure GHG-1. (provided above) LTSM significance thresholds, implementation of the proposed project would exceed the City's residential VMT significance threshold of 13.21 VMT per capita, and operation of the proposed project could use natural gas, which could conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases (i.e., CARB 2022 Climate Change Scoping Plan).

4.9 HAZARDS AND HAZARDOUS MATERIALS
The Phase I ESA identified one controlled recognized environmental condition (CREC) associated with the PS Mitigation Measure HAZ-1: Prior to the issuance of a building permit, a future project LTSM historical removal of four USTs (two 10,000-gallon, one 2,000-gallon, and one 1,000-gallon) that had been used to applicant/developer shall demonstrate the recommendations provided in the Phase I store gasoline and diesel for maintenance vehicles. The 1996 regulatory case closure by OCHCA requires Environmental Site Assessment (Phase I ESA) prepared for the Buildout Area have been, or notification of OCHCA if a change in land use is proposed. The proposed project includes changes to the existing will be, implemented. Recommendations provided in the Phase I ESA include the following:
land uses in the Buildout Area, and could create a significant hazard to the public or the environment through • Preparation and implementation of an Operations and Maintenance (O&M) reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the Program in order to safely manage the suspect asbestos-containing materials environment. (ACMs) and/or lead-based paint (LBP) associated with the existing structures located within the Buildout Area; and
• Providing a copy of this Draft Environmental Impact Report (EIR) and the Notice of Completion (NOC) to the Orange County Health Care Agency (OCHCA) in order to notify them of the proposed change in land use facilitated under the proposed project.

The Phase I ESA identified one CREC, one historic recognized environmental condition (HREC), and one BER, and PS Mitigation Measure HAZ-1. (provided above) LTSM implementation of the proposed project could create a significant hazard to the public or the environment through being located on an identified hazardous materials site.

4.10 HYDROLOGY AND WATER QUALITY
Implementation of the proposed project would remove the single drainage feature located on Lot 3, which would PS Mitigation Measure B1O-1: Jurisdictional Delineation. (Refer to Section 4.4, Biological LTSM result in impacts on wetland or riparian habitat. Resources, above)

4.11 LAND USE AND PLANNING
There are no significant impacts related to land use and planning.

4.12 MINERAL RESOURCES
There are no significant impacts on mineral resources.

4.13 NOISE
There are no significant impacts related to noise.
1-14 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\1.0 Executive Summary.docx «03/12/26»

DRAFT ENVIRONMENTAL IMPACT REPORT
MARCH 2026
Table 1.A: Summary of Impacts and Mitigation Measures from this Draft EIR Level of
Environmental Impacts Significance Mitigation Measures
Without
Mitigation

4.14 POPULATION AND HOUSING
There are no significant impacts related to population and housing.

4.15 PUBLIC SERVICES
There are no significant impacts on public services.

4.16 RECREATION
There are no significant impacts related to recreation.

4.17 TRANSPORTATION
Implementation of the proposed project would exceed the City's residential VMT significance threshold of 13.21 PS Mitigation Measure TRA-1: Transportation Demand Management Strategies. The VMT per capita under both existing and cumulative plus project conditions. Development Agreement between the City and the 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 projectgenerated vehicle miles traveled (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.

4.18 TRIBAL CULTURAL RESOURCES
Ground disturbing activities during construction, including grading and excavation, could cause a substantial PS Mitigation Measure TCR-1: Tribal Cultural Resources Training and ALERT Sheet Posting. adverse change in the significance of a tribal cultural resource, as defined in PRC Section 21074. Prior to the start of any ground-disturbing activities, a qualified archaeologist meeting the Secretary of the Interior standards, in consultation with a representative from a traditionally and culturally affiliated Native American Tribe, under the direction of the City of Cypress Planning Division, shall prepare a Cultural Resources Sensitivity Summary. This summary shall include a brief description of the types of archaeological and tribal cultural resources that may be encountered, visual examples (if available), reporting procedures in the event of a discovery, and appropriate contact information.

The summary shall be printed and posted in a visible location at the construction site for the duration of all ground-disturbing activities.

An initial worker environmental training shall be provided by a qualified archaeologist in collaboration with a tribal representative prior to the start of construction, under the direction of the City of Cypress Planning Division. The training shall include a review of applicable laws, procedures to follow if resources are discovered, and cultural sensitivity guidance. A sign-in sheet shall be maintained to document attendance. As construction progresses, the construction manager shall be responsible for ensuring that all new personnel receive the same information through on-site orientation and review of the posted materials. Documentation of ongoing training shall be maintained and made available to the City upon request.

P:\A·E\CCP2201.0S LARC EIR\PRODUCTS\3_Public Draft EIR 2\1.0 Executive Summary.docx (03/12/26) SPECIFIC PLAN 3.0 BUILDOUT PROJECT

CYPRESS, CALIFORNIA
Level of Significance With Mitigation
SU
LTSM
1-15
1-16
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Environmental Impacts
Table 1.A: Summary of Impacts and Mitigation Measures from this Draft EIR Level of
Significance
Without
Mitigation
Mitigation Measures
Mitigation Measure TCR-2: Retain a Native American Monitor Prior to Commencement of Ground-Disturbing Activities. Prior to the issuance of any grading permits for projects within the Buildout Area that would require "ground-disturbing activity," where such disturbance activity would occur in undisturbed native sediment, a future project applicant/City shall retain a Native American Monitor from or approved by the Gabrielef\o Band of Mission Indians - Kizh Nation (Tribe). "Ground-disturbing activity" shall include, but is not limited to, demolition, pavement removal, potholing, auguring, grubbing, tree removal, boring, grading, excavation, drilling, and trenching on both on-site and any off-site locations that are included in the Project Description/ definition and/or required in connection with the projects, such as public improvement work.

A copy of the executed monitoring agreement shall be submitted to the Director of the City of Cypress Community Development Department, or their designee, prior to the earlier of the commencement of any ground-disturbing activity, or the issuance of any permit necessary to commence a ground-disturbing activity. The tribal monitor shall also provide appropriate insurance certificates.

The monitor shall complete daily monitoring logs that will provide descriptions of the relevant ground-disturbing activities, the type of construction activities performed, locations of ground-disturbing activities, soil types, cultural-related materials, and any other facts, conditions, materials, or discoveries of significance to the Tribe. Monitor logs shall identify and describe any discovered tribal cultural resources (TCRs), including but not limited to, Native American cultural and historical artifacts, remains, places of significance, etc., (collectively, "TCRs"), as well as any discovered Native American (ancestral) human remains and burial goods. Copies of monitor logs shall be provided to the future project applicant/City upon written request to the Tribe.

On-site tribal monitoring shall conclude upon the latter of the following (1) written confirmation to the Tribe from a designated point of contact for the future project applicant/City that all ground-disturbing activities and phases that may involve grounddisturbing activities in native (previously undisturbed) soil has occurred (i.e., no tribal monitoring shall be required for landscaping activities occurring after completion of project grading and trenching, as this soil will have been previously monitored) or in connection with the project are complete; or (2) a determination and written notification by the Tribe to the future project applicant/City that no future, planned construction activity and/or development/construction phase associated with the project possesses the potential to impact TCRs.

Upon discovery of any TCRs, all construction activities in the immediate vicinity of the discovery shall cease (i.e., not less than the surrounding 50 feet) and shall not resume until the discovered TCR has been fully assessed by the Tribe's monitor and/or archaeologist.

The Tribe will recover and retain all discovered TCRs in the form and/or manner the Tribe deems appropriate, in the Tribe's sole discretion, and for any purpose the Tribe deems appropriate, including for educational, cultural, and/or historic purposes.

Mitigation Measure TCR-3: Unanticipated Discovery of Human Remains and Associated Funerary Objects. Native American human remains are defined in Public Resources Code (PRC) Section 5097.98 (d)(l) as an inhumation or cremation, and in any state of decomposition or skeletal completeness. Funerary objects, called associated grave goods in PRC Section 5097.98, are also to be treated according to this statute.

Level of Significance With Mitigation
P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\1.0 Executive Summary.docx «03/12/26»

DRAFT ENVIRONMENTAL IMPACT REPORT
MARCH 2026
Environmental Impacts
P:\A-E\CCP2201.0S LARC EIR\PRODUCTS\3_Public Draft EIR 2\1.0 Executive Summary.docx (03/12/26) Table 1.A: Summary of Impacts and Mitigation Measures from this Draft EIR Level of
Significance
Without
Mitigation
Mitigation Measures
If Native American human remains and/or grave goods are discovered or recognized during ground-disturbing activities associated with projects within the Buildout Area, then all construction activities shall immediately cease within 50 feet of the find. Health and Safety Code Section 7050.5 dictates that any discoveries of human skeletal material shall be immediately reported to the County Coroner and all ground-disturbing activities shall immediately halt and shall remain halted until the Coroner has determined the nature of the remains. If the Coroner recognizes the human remains to be those of a Native American or has reason to believe they are Native American, he or she shall contact, by telephone within 24 hours, the Native American Heritage Commission (NAHC), and PRC Section 5097.98 shall be followed.

Human remains and grave/burial goods shall be treated alike per PRC Section 5097.98(d)(1) and (2).

If Native American human remains are discovered or recognized on any construction sites within the Buildout Area during ground-disturbing activities and the NAHC subsequently identifies the Gabrielefio Band of Mission Indians - Kizh Nation (Tribe) to be the Most Likely Descendant (MLD), construction activities may resume in other parts of the construction site at a minimum of 200 feet away from discovered human remains and/or burial goods, if the Tribe determines in its sole discretion that resuming construction activities at that distance is acceptable and provides the project manager express consent of that determination (along with any other mitigation measures the Tribe's monitor and/or archaeologist deems necessary). (State CEQA Guidelines Section 15064.S(f).) Preservation in place (i.e., avoidance) is the Tribe's preferred manner of treatment for discovered human remains and/or burial goods.

Any discovery of human remains/burial goods shall be kept confidential to the extent feasible to prevent further disturbance.

Mitigation Measure TCR-4: Procedures for Burials and Funerary Remains. If Native American human remains are discovered or recognized on any construction sites within the Buildout Area during ground-disturbing activities and the Native American Heritage Commission subsequently identifies the Gabrielefio Band of Mission Indians - Kizh Nation (Tribe) to be the Most Likely Descendant ("MLD"), the Koo-nas-gna Burial Policy, as described below, shall be implemented. To the Tribe, the term "human remains" encompasses more than human bones. In ancient as well as historic times, Tribal Traditions included, but were not limited to, the preparation of the soil for burial, the burial of funerary objects with the deceased, and the ceremonial burning of human remains.

If the discovery of human remains includes four or more burials, the discovery location shall be treated as a cemetery and a separate treatment plan shall be created.

The prepared soil and cremation soils are to be treated in the same manner as bone fragments that remain intact. Associated funerary objects are objects that, as part of the death rite or ceremony of a culture, are reasonably believed to have been placed with individual human remains either at the time of death or later; other items made exclusively for burial purposes or to contain human remains can also be considered as associated funerary objects. Cremations will either be removed in bulk or by means as necessary to ensure complete recovery of all sacred materials.

SPECIFIC PLAN 3.0 BUILDOUT PROJECT

CYPRESS, CALIFORNIA
Level of Significance With Mitigation
1-17
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Table 1.A: Summary of Impacts and Mitigation Measures from this Draft EIR Level of
Environmental Impacts Significance Mitigation Measures Level of Significance With Mitigation Without Mitigation
In the case where discovered human remains cannot be fully documented and recovered on the same day, the remains will be covered with muslin cloth and a steel plate that can be moved by heavy equipment placed over the excavation opening to protect the remains.

If this type of steel plate is not available, a 24-hour guard should be posted outside of working hours. The Tribe will make every effort to recommend diverting the project and keeping the remains in situ and protected. If the project cannot be diverted, it may be determined that burials will be removed.

In the event preservation in place is not possible despite good faith efforts by the future project applicant/City and/or landowner, before ground-disturbing activities may resume on the project site, the landowner shall arrange a designated site location within the footprint of the project for the respectful reburial of the human remains and/or ceremonial objects.

Each occurrence of human remains and associated funerary objects will be stored using opaque cloth bags. All human remains, funerary objects, sacred objects and objects of cultural patrimony will be removed to a secure container on site if possible. These items should be retained and reburied within 6 months of recovery. The site of reburial/repatriation shall be on the project site but at a location agreed upon between the Tribe and the landowner at a site to be protected in perpetuity. There shall be no publicity regarding any cultural materials recovered.

The Tribe will work closely with the project's qualified archaeologist to ensure that the excavation is treated carefully, ethically and respectfully. If data recovery is approved by the Tribe, documentation shall be prepared and shall include (at a minimum) detailed descriptive notes and sketches. All data recovery data recovery-related forms of documentation shall be approved in advance by the Tribe. If any data recovery is performed, once complete, a final report shall be submitted to the Tribe and the NAHC. The Tribe does not authorize any scientific study or the utilization of any invasive and/or destructive diagnostics on human remains.

4.19 UTILITIES AND SERVICE SYSTEMS
There are no significant impacts on utilities and service systems.

4.20 WILDFIRE
There are no significant impacts related to wildfire.

Source: LSA (2026).
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DRAFT ENVIRONMENTAL IMPACT REPORT
MARCH 2026

4.3 AIR QUALITY
Environmental Issue Area
Construction Air Quality Emissions

4.4 BIOLOGICAL RESOURCES
Special-Status Species

4.5 CULTURAL RESOURCES
Unknown Archaeological Resources
Human Remains
P:\A-E\CCP2201.0S LARC EIR\PRODUCTS\3_Public Draft EIR 2\1.0 Executive Summary.docx (03/12/26) Table 1.B: Applicable Regulatory Compliance Measures
Regulatory Compliance Measure
SPECIFIC PLAN 3.0 BUILDOUT PROJECT

CYPRESS, CALIFORNIA
Regulatory Compliance Measure AIR-1: During clearing, grading, earth moving, or excavation operations, excessive fugitive dust emissions shall be controlled by regular watering or other dust preventative measures by using the following procedures, in compliance with South Coast Air Quality Management District (SCAQMD) Rule 403 during construction. The applicable Rule 403 measures are as follows:
• Apply nontoxic chemical soil stabilizers according to manufacturers' specifications to all inactive construction areas (previously graded areas inactive for 10 days or more). • Water active sites at least twice daily (locations where grading is to occur shall be thoroughly watered prior to earthmoving). • Cover all trucks hauling dirt, sand, soil, or other loose materials, or maintain at least 2 feet (0.6 meter) of freeboard (vertical space between the top of the load and the top of the trailer) in accordance with the requirements of California Vehicle Code Section 23114. • Pave construction access roads at least 100 feet (30 meters) onto the site from the main road. • Reduce traffic speeds on all unpaved roads to 15 miles per hour or less.

Regulatory Compliance Measure AIR-2: All trucks that are to haul excavated or graded material shall comply with State Vehicle Code Section 23114, with special attention to Sections 23114(b)(F), (e}(2}, and (e)(4} as amended, regarding the prevention of such material spilling onto public streets and roads.

Regulatory Compliance Measure AIR-3: Prior to approval of future project plans and specifications, the City of Cypress shall confirm that the construction bid packages specify:
• Contractors shall use high-volume low-pressure paint applicators with a minimum transfer efficiency of at least 50 percent; • Coatings and solvents that will be utilized have a volatile organic compound content lower than required under SCAQMD Rule 1113; and • To the extent feasible, construction/building materials shall be composed of pre-painted materials.

Regulatory Compliance Measure AIR-4: Future projects shall comply with SCAQMD Rule 402. Rule 402 prohibits the discharge of air contaminants or other material from any type of operations, which can cause nuisance or annoyance to any considerable number of people or to the public or which endangers the comfort or repose of any such persons, or the public.

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, 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 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 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 ground-nesting 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 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.

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 15064.5(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 1-19
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Table 1.B: Applicable Regulatory Compliance Measures
Environmental Issue Area Regulatory Compliance Measure
grading permits, the Director of the City of Cypress Community Development 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.

4.9 HAZARDS AND HAZARDOUS MATERIALS
Airport Hazards Regulatory Compliance Measure HAZ-1: Federal Aviation Regulation Title 14 Part 77. A future project applicant/developer shall notify the Federal Aviation Administration (FAA) of any proposed structure(s) that would penetrate the 100 to 1 imaginary surface that surrounds the runway at Joint Forces Training Base Los Alamitos at least 45 days prior to beginning construction.

4.10 HYDROLOGY AND WATER QUALITY
Water Quality Regulatory Compliance Measure HYD-1: Construction General Permit. If construction of future projects associated with the proposed project would disturb greater than 1 acre of soil, prior to commencement of construction activities within the proposed Buildout Area, the Construction Contractor shall obtain coverage under the National Pollutant Discharge Elimination System (NPDES) General Permit far Stormwater Discharges Associated with Construction and Land Disturbance Activities, Order WQ 2022-0057-DWQ, NPDES No. CAS000002 (Construction General Permit), or any other subsequent permit. This shall include submission of Permit Registration Documents, including permit application fees, a Notice of Intent (NOi), a risk assessment, a site plan, a Stormwater Pollution Prevent Plan (SWPPP), a signed certification statement, and any other compliance-related documents required by the permit, to the State Water Resources Control Board via the Stormwater Multiple Application and Report Tracking System (SMARTS). Construction activities shall not commence until a Waste Discharge Identification Number is obtained for the project from the SMARTS and provided to the Director of Public Works for the City of Cypress, or designee, to demonstrate that coverage under the Construction General Permit has been obtained. Project construction shall comply with all applicable requirements specified in the Construction General Permit, including but not limited to, preparation of a SWPPP and implementation of construction site best management practices (BMPs) to address all construction-related activities, equipment, and materials that have the potential to impact water quality for the appropriate risk level identified for the project. The SWPPP shall identify the sources of pollutants that may affect the quality of storm water and shall include BMPs (e.g., Sediment Control, Erosion Control, and Good Housekeeping BMPs) to control the pollutants in storm water runoff. Upon completion of construction activities and stabilization of the Buildout Area, a Notice ofTermination (NOT) shall be submitted via SMARTS.

If construction of future projects associated with the proposed project would disturb less than 1 acre of soil, prior to commencement of construction activities within the Buildout Area, the Construction Contractor shall provide evidence that project construction would comply with Section 4.106 of the 2019 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 (e.g., Sediment Control, Erosion Control, and Good Housekeeping BMPs).

Regulatory Compliance Measure HYD-2: Construction Dewatering Permit. If groundwater dewatering is required during excavation activities, the Applicant/City shall obtain coverage under the General Waste Discharge Requirements for Discharges to Surface Waters that Pose an Insignificant (De Minimis) Threat to Water Quality, Order No. R8-2020-0006, NPDES No. CAG998001 (Construction Dewatering Permit). This shall include submission of a Notice of Intent (NOi) for coverage under the permit to the Santa Ana Regional Water Quality Control Board (RWQCB) at least 45 days prior to the start of dewatering. Groundwater dewatering activities shall comply with all applicable provisions in the permit, including water sampling, analysis, treatment (if required), and reporting of dewatering-related discharges. Upon completion of groundwater dewatering activities, a Notice of Termination shall be submitted to the Santa Ana RWQCB.

Regulatory Compliance Measure HYD-3: Orange County MS4 Permit/City Municipal Code. Prior to issuance of a grading permit for future projects associated with the proposed project, the future project Applicant shall prepare and submit a final project-specific water quality management plan (WQMP) to specify BMPs that would be implemented to capture, treat, and reduce pollutants of concern in stormwater runoff in compliance with the Waste Discharge Requirements for the County of Orange, Orange County Flood Control District and the Incorporated Cities of Orange County within the Santa Ana Region Areawide Urban Storm Water Runoff Orange County, Order R8-2009-0030, NPDES No. CAS618030, as amended by Order No. R8-2010-0062 (Orange County MS4 Permit), Orange County Drainage Area Management Plan (DAMP), and the City of Cypress Local Implementation Plan (LIP). The WQMP shall also incorporate the results of the Final Hydrology and Hydraulic Analyses to demonstrate that the bioretention facilities meet the hydromodification requirements of the Orange County MS4 Permit and Chapter 13-23 of the Cypress Municipal Code. The City Engineer/Public Works Director, or designee, shall ensure that the BMPs specified in the WQMP are incorporated into the final project design of future projects associated with the proposed project.

4.13 NOISE
Construction Noise Regulatory Compliance Measure NOl-1: The construction contractor shall limit all construction-related activities to between the hours 7:00 a.m. and 8:00 p.m. on weekdays and between the hours of 9:00 a.m. and 8:00 p.m. on Saturdays. No construction shall be permitted outside of these hours or on Sundays or a federal holiday with the exception of certain construction activities that are time sensitive and require a 24-hour rotation. In those situations, a temporary use permit can be obtained from the City of Cypress' Community Development Direct Stationary Noise Regulatory Compliance Measure NOl-2: Mechanical equipment, including air conditioning units in residential and non-residential zoning districts, shall be enclosed within a structure or completely screened from view from surrounding properties by the use of a fence or wall consistent with Section 3.11.lO0(b) of the City of Cypress Municipal Code. Additionally, prior to the issuance of building permits, a future applicant/developer shall demonstrate, to the satisfaction of the City Director of Community Development, or designee, that on-site stationary noise sources, such as air conditioners, shall not exceed City noise standards as stated within the City's Municipal Code Sections 13-68 and 13-69.

4.15 PUBLIC SERVICES
Fire Protection Services Regulatory Compliance Measure PS-1: Any future projects implemented within the Buildout Area in accordance with the City of Cypress (City) Cypress Town Center and Commons Specific Plan

3.0 (Specific Plan) would be required to coordinate with the Orange County Fire Authority (OCFA) to determine the appropriate development impact fees required to offset potential impact to OCFA staffing and service ability. Prior to the approval of such projects, the designated site developer shall enter into a Secured Fire Protection Agreement with OCFA that details the agreedupon development impact fees required for the project.

School Services Regulatory Compliance Measure PS-2: Payment of School Fees. Prior to issuance of any building permits within the Buildout Area in accordance with the Specific Plan, the applicant/ developer of future development projects facilitated by the proposed project shall provide proof to the Director of the City of Cypress Community Development Department, or designee, that payment of all applicable school fees has been made to the appropriate school district(s) in compliance with Section 65995 of the California Government Code. 1-20 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\1.0 Executive Summary.docx «03/12/26»

DRAFT ENVIRONMENTAL IMPACT REPORT
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Recreation Facilities
Environmental Issue Area

4.19 UTILITIES AND SERVICE SYSTEMS
Construction and Demolition Waste
Source: LSA (2026).

P:\A-E\CCP2201.0S LARC EIR\PRODUCTS\3_Public Draft EIR 2\1.0 Executive Summary.docx (03/12/26) Table 1.B: Applicable Regulatory Compliance Measures
Regulatory Compliance Measure
SPECIFIC PLAN 3.0 BUILDOUT PROJECT

CYPRESS, CALIFORNIA
Regulatory Compliance Measure PS-3: Dedication of Parkland and/or Payment of Park Fees. Prior to issuance of any building permits within the Buildout Area in accordance with the Cypress Town Center and Commons Specific Plan 3.0 (Specific Plan), a future applicant/developer shall provide proof of compliance with the applicable provisions of Chapter 25 (Subdivisions), Article VI, Park and Recreational Facilities, of the City of Cypress Municipal Code.

Regulatory Compliance Measure UTIL-1: Construction and Demolition Ordinance. The construction contractor shall comply with the provisions of the City of Cypress Ordinance No. 1166 and the 2022 California Green Building Standards Code, which would reduce construction and demolition waste. Ordinance No. 1166 is codified in Article VIII, Materials Questionnaire for Certain Construction and Demolition Projects within the City of Cypress, in the Cypress Municipal Code. 1-21
1-22
2029 CYPRESS HOUSING ELEMENT IMPLEMENTATION PROJECT

S, CALIFORNIA
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DRAFT EN VI RONMENTAL IMPACT REPO RT
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SPECIFIC PLAN 3.0 BU ILDOUT PROJECT

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2.0 INTRODUCTION
This Draft Environmental Impact Report (Draft EIR) has been prepared to evaluate the environmental impacts associated with the proposed Specific Plan 3.0 Buildout Project (proposed project) in Cypress, California, which involves the development of approximately 134 acres of land (Buildout Area) subject to the previously approved Cypress Town Center and Commons Specific Plan

3.0 (Specific Plan). The City of Cypress (City) is the "public agency which has the principal responsibility for carrying out or approving the project" 1 and, as such, is the "Lead Agency" for the proposed project under the California Environmental Quality Act (CEQA) (Public Resources Code Section 21000 et seq.). CEQA requires the Lead Agency to consider the information contained in this Draft EIR and the balance of the Final Environmental Impact Report (Final EIR) for the proposed project prior to taking any discretionary action on the proposed project. The Final EIR is intended to serve as an informational document to be considered by the City and any Responsible Agencies during deliberations on the proposed project. Public Resources Code Section 21069 defines a "Responsible Agency" as a public agency other than the Lead Agency that has responsibility for carrying out or approving a project. The approvals and permits associated with the proposed project are described in Chapter 3.0, Project Description.

The City, as Lead Agency, determined that the proposed project may have a significant effect on the environment and that an EIR would be required to more fully evaluate potential adverse environmental impacts that may result from development of the proposed project. As a result, this Draft EIR has been prepared in accordance with CEQA and the State CEQA Guidelines (California Code of Regulations [CCR], Title 14, Section 15000 et seq.). This Draft EIR also complies with the procedures established by the City for the implementation of CEQA.

Questions regarding the preparation of this document and City review of the proposed project should be referred to the following person:

Alicia Velasco, Planning Director
City of Cypress Community Development Department
5275 Orange Avenue
Cypress, CA 90630
Phone: (714) 229-6720
Email: [email protected]

2.1 PURPOSE AND TYPE OF EIR/USES OF THE EIR
This Draft EIR has been prepared to evaluate potential environmental impacts that could result from implementation of the proposed project. As the Lead Agency, the City has the principal responsibility for approving the proposed project. In that capacity, the City has decided to prepare this Draft EIR and, after the public review process, will decide whether to certify the Final EIR.

The City and any Responsible Agencies have the authority to make decisions on discretionary actions relating to development of the proposed project. As stated previously, this Draft EIR is intended to As defined in Public Resources Code Section 21067.

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serve as an informational document to be considered by the City and Responsible Agencies during deliberations on the proposed project. No Responsible Agencies have been identified for the proposed project. This Draft EIR evaluates a reasonable worst-case scenario of potential impacts associated with the proposed project and identifies feasible mitigation and alternatives for any identified significant impacts.

The Final EIR will serve as a Program Environmental Impact Report (Program EIR) pursuant to State CEQA Guidelines Section 15168. According to Section 15168, a Program EIR may be prepared for a series of actions that are related geographically, as logical parts in a chain of contemplated actions, or in connection with the issuance of plans that govern the conduct of a continuing program (per Section 15168(a)). The advantages of a Program EIR include the ability to provide a more exhaustive consideration of alternatives and cumulative effects than might be possible in a single projectspecific EIR; to avoid duplication of basic policy considerations; provide the lead agency with the ability to consider broad program-wide policies and mitigation measures that would apply to specific projects or later activities within the overall program (Section 15168(b)); and use the Program EIR when examining later activities to determine whether any additional environmental document must be prepared (Section 15168(c)). If a later activity is found to be within the scope of the Program EIR, no further environmental documents would be required.

As the Lead Agency for the proposed project under CEQA, the City must consider the information contained in the Final EIR prior to taking any discretionary action with respect to the proposed project. This Draft EIR provides information to the Lead Agency and other public agencies, the general public, and decision-makers regarding the potential environmental impacts from construction and operation of the proposed project. The purpose of the public review of this Draft EIR is to evaluate the adequacy of the environmental analysis in terms of compliance with CEQA.

State CEQA Guidelines Section 15151 states the following regarding the standards from which adequacy is judged:
"An EIR should be prepared with a sufficient degree of analysis to provide decisionmakers with information which enables them to make a decision which intelligently takes account of environmental consequences. An evaluation of the environmental effects of a proposed project need not be exhaustive, but the sufficiency of an EIR is to be reviewed in the light of what is reasonably feasible. Disagreement among experts does not make an EIR inadequate, but the EIR should summarize the main points of disagreement among experts. The courts have not looked for perfection but for adequacy, completeness, and a good faith effort at full disclosure." Public Resources Code Section 21002.l(a) states:
"The purpose of an environmental impact report is to identify the significant effects on the environment of a project, to identify alternatives to the project, and to indicate the manner in which those significant effects can be mitigated or avoided." An EIR is the most comprehensive form of environmental documentation identified in CEQA and the State CEQA Guidelines and provides the information needed to assess the environmental consequences of a proposed project. EIRs are intended to provide an objective, factually supported, 2-2 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\2.0 lntroduction.docx «03/11/26»

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full-disclosure analysis of the environmental consequences associated with a proposed project that has the potential to result in significant, adverse environmental impacts.

2.2 PUBLIC REVIEW PROCESS
In compliance with CEQA and the State CEQA Guidelines, the City has taken steps to promote opportunities for the public and other public agencies to participate in the environmental review process. The City issued a Notice of Preparation (NOP) for the proposed project, conducted the scoping process, held a public scoping meeting, and determined that an EIR was required to evaluate the potentially significant environmental effects of the proposed project and related actions. Further, this Draft EIR is subject to public review and comment. These topics related to the environmental review process are described in further detail below.

2.2.1 Notice of Preparation
The City, as the Lead Agency, issued an NOP for the Draft EIR on April 4, 2025, which was distributed via the State Clearinghouse (SCH). The SCH issued a project number for the Draft EIR (SCH No. 2025040377). In accordance with State CEQA Guidelines Section 15082, the NOP was circulated to responsible agencies and individuals for a period of 30 days, from April 4 to May 5, 2025, during which time written comments were solicited pertaining to environmental issues and topics that this Draft EIR should evaluate. Comments received during the public review of the NOP are summarized in Table 2.A: Notice of Preparation Agency Comments Received and utilized to identify the potential environmental impacts addressed in Chapter 4.0, Existing Setting, of this Draft EIR. The NOP and all comments received during the public review period are provided in Appendix A, respectively.

2.2.2 Scoping Meeting
The City held a public scoping meeting to present the project and to solicit input from interested individuals regarding environmental issues that should be addressed in this Draft EIR. The scoping meeting was held virtually via Microsoft Teams on April 16, 2025. No environmental issues or concerns were raised at the scoping meeting.

2.2.3 Draft EIR Public Review Period
This Draft EIR is being distributed to numerous public agencies and other interested parties for review and comment. This Draft EIR is also available at the following locations and on the City's website for the proposed project (available online at: https://www.cypressca.org/home/show publisheddocument/12927 /638720249212130000):

City of Cypress
Community Development Department
5275 Orange Avenue
Cypress, CA 90630
Cypress Branch Library
5331 Orange Avenue
Cypress, CA 90630
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Table 2.A: Notice of Preparation Agency Comments Received Agency/
Organization/
Individual
Date
Native American April 8, 2025
Heritage
Commission
(NAHC)
South Coast Air April 23, 2025
Quality
Management
District
(SCAQMD)
Southern May 5, 2025
California
Association of
Governments
(SCAG)
2-4
Comments
Addressed in
Section(s) of the
EIR
The NAHC outlined the City's tribal consultation Tribal Cultural requirements under Assembly Bill 52. Resources
SCAQMD raised concerns regarding potential air quality
impacts, greenhouse gas emissions, and health risks
associated with the Specific Plan 3.0 Buildout Project.

SCAQMD recommends that the City rely on the SCAQMD's
CEQA Air Quality Handbook and use California Emissions
Estimator Model (CalEEMod) to quantify emissions, applying both regional air quality significance thresholds and localized significance thresholds (LSTs). SCAQMD requests that the Draft EIR evaluate all phases of construction and operation, including overlapping activities, indirect sources (e.g., vehicle trips), and identify any new stationary or portable
equipment that would require SCAQMD permits, recognizing the agency as a Responsible Agency if applicable. SCAQMD emphasizes that if significant adverse impacts are identified, all feasible mitigation measures that go beyond existing legal requirements must be implemented, referencing resources such as the 2022 Air Quality Management Plan Mitigation Monitoring and Reporting Plan. SCAQMD further
recommends evaluating health risk reduction strategies, such as using enhanced air filtration systems rated MERV 13 (Minimum Efficiency Reporting Value) or better, and
requests that the Draft EIR analyze related secondary
impacts including increased energy consumption,
maintenance, waste generation, and potential limitations in filtration effectiveness.

SCAG recommends that the City of Cypress evaluate the
project's alignment with the Connect SoCal 2024 Regional Transportation Plan/Sustainable Communities Strategy
(RTP/SCS), which outlines goals to reduce greenhouse gas emissions, improve regional air quality, and support an integrated multimodal transportation network. SCAG
emphasizes the use of its growth forecasts for population, housing, and employment in assessing potential impacts and planning infrastructure accordingly.

Air Quality and
Greenhouse Gas
Emissions
Air Quality,
Transportation
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Table 2.A: Notice of Preparation Agency Comments Received Agency/ Addressed in
Organization/ Date Comments Section(s) of the
Individual EIR
Orange County May 5, 2025 OCPW stated that it has no comments regarding the Notice Not applicable Public Works of Preparation (NOP) for the Draft EIR.
(OCPW)
City of Garden June 3, 2025 The City of Garden Grove requested that a Level of Service Transportation Grove1 (LOS) analysis be prepared for key intersections in the City of Garden Grove that may be impacted by project-related
traffic. The City of Garden Grove also provided their Traffic Impact Analysis guidelines.

Source = LSA (2026).

Notes: All NOP response letters are included in Appendix A of this Draft EIR. 1 The comment letter from the City of Garden Grove was received after the close of the NOP comment period.

All comments received from agencies and individuals on this Draft EIR will be accepted during the public comment period, which will not be less than 45 days, in compliance with CEQA and the State CEQA Guidelines. All comments on this Draft EIR should be sent to the following City contact person:

Alicia Velasco, Planning Director
City of Cypress Community Development Department
5275 Orange Avenue
Cypress, CA 90630
Email: [email protected]
Following the closure of the public comment period, the City will prepare written responses to all written comments received during the public comment period and will compile these comments and responses, together with any text changes to this Draft EIR, into the Final EIR that includes all of the information required pursuant to State CEQA Guidelines Section 15132. The Final EIR will be provided to all public agencies that submitted comments on this Draft EIR at least 10 days prior to certification of the Final EIR. The Final EIR will consist of this Draft EIR or a revision of the draft; comments and recommendations received on this Draft EIR either verbatim or in summary; a list of persons, organizations, and public agencies commenting on this Draft EIR; the response of the City to significant environmental points raised in the review and consultation process and in comments submitted on this Draft EIR; and any other information added by the City.

The City will determine findings regarding the extent and nature of the impacts as presented in the Final EIR. The Final EIR must be certified as complete by the City Council prior to making a decision on the requested entitlements for the proposed project. Public input is encouraged at all public hearings regarding the proposed project.

2.3 SCOPE OF THIS DRAFT EIR
As required by State CEQA Guidelines Section 15128, this Draft EIR must identify the effects of the proposed project that are determined to be significant. Consistent with Appendix G of the State CEQA Guidelines, this Draft EIR evaluates all environmental issue areas that may be affected by the P:\A-E\CCP2201.0S LARC EIR\PRODUCTS\3_Public Draft EIR 2\2.0 lntroduction.docx «03/11/26» 2-5 SPECIFIC PLAN 3.0 BUI LOO UT PROJECT

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proposed project, including but not limited to aesthetics, agriculture and forestry resources, air quality, biological resources, cultural and tribal cultural resources, energy, geology and soils, greenhouse gas emissions, hazards and hazardous materials, hydrology and water quality, land use and planning, mineral resources, noise, population and housing, public services, recreation, transportation, utilities and service systems, and wildfire, as applicable.

2.4 FORMAT OF THIS DRAFT EIR
This Draft EIR contains the information and analysis required by CEQA and the State CEQA Guidelines, including Section 15122-15131, and is generally organized as follows:
• Chapter 1.0: Executive Summary. Chapter 1.0 contains the Executive Summary of this Draft EIR, which lists all significant project impacts, feasible mitigation measures that have been recommended to reduce any significant impacts of the proposed project, and the level of significance of each impact following feasible mitigation. The summary is presented in a table format.
• Chapter 2.0: Introduction. Chapter 2.0 contains a discussion of the purpose and intended use of this Draft EIR.
• Chapter 3.0: Project Description. Chapter 3.0 includes a discussion of the proposed project, the Buildout Area and its existing environmental setting, overall project relationship to the Specific Plan, background and related planning documents, the project objectives, and discretionary actions, permits, and other approvals.
• Chapter 4.0: Environmental Impact Analysis. Chapter 4.0 includes an analysis of the proposed project's environmental impacts. The environmental setting discussions describe the "existing conditions" of the environment within the Buildout Area as they pertain to the environmental issues being analyzed (State CEQA Guidelines Section 15125). 2-6
The impact discussions identify and focus on the potentially significant environmental effects of the proposed project. The direct and indirect effects of the proposed project on the environment are identified and described, giving due consideration to both the short-term and long-term effects, as necessary {State CEQA Guidelines Section 15126.2[a]).

Chapter 4.0 also includes within the analysis of each environmental topic a discussion of the cumulative effects of the proposed project when considered in combination with other projects causing related impacts, as required by State CEQA Guidelines Section 15130. The proposed project is the implementation of the Specific Plan and assumes the development of 1,791 residential units and 440,000 square feet of non-residential uses within the Buildout Area.

The discussions of mitigation measures identify and describe feasible measures that could minimize or lessen potentially significant impacts for each significant environmental effect identified in this Draft EIR (State CEQA Guidelines Section 15126[e]). The levels of significance before and after mitigation measures are recommended. Significant unavoidable adverse effects are identified where recommended feasible mitigation measures are not expected to reduce the effects to less than significant levels.

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• Chapter 5.0: Alternatives to the Proposed Project. In accordance with CEQA, the alternatives discussion in Chapter 5.0 describes a reasonable range of alternatives that could feasibly attain the basic objectives of the proposed project and are capable of eliminating or substantially reducing any of the proposed project's significant unavoidable adverse environmental effects or reducing them to a less than significant level. The alternatives analyzed in Chapter 5.0 include three alternatives: (1) the No Project Alternative, (2) the Historic Preservation Alternative, and (3) the Reduced Development Alternative.
• Chapter 6.0: Other CEQA Considerations. Chapter 6.0 contains discussions on the following topics as required by State CEQA Guidelines Section 15126: (1) growth-inducing impacts of the proposed project; and (2) whether there are any significant irreversible environmental changes caused by the proposed project, adverse environmental impacts associated with the proposed project for which either no mitigation or only partial mitigation is feasible. • Chapter 7.0: List of Preparers. Chapter 7.0 provides the organizations and persons contacted during preparation of this Draft EIR, the Draft EIR preparers and technical report authors, and other experts involved in the preparation of this Draft EIR. • Chapter 8.0: References. Chapter 8.0 provides the references cited in this Draft EIR.

2.5 INCORPORATION BY REFERENCE
An EIR may incorporate by reference all or portions of another document that is a matter of public record or is generally available to the public, consistent with State CEQA Guidelines Section 15150.

Informational details from the documents that have been incorporated by reference are summarized in the appropriate sections of this Draft EIR, along with descriptions regarding how the public may review these documents. All documents are available for review at the City of Cypress, Community Development Department. These documents include, without limitation:
• City of Cypress General Plan (available online at: https://www.cypressca.org/departments/ community-development/planning-division)
• City of Cypress Municipal Code (available on line at: https://qcode.us/codes/cypress/) • Cypress Town Center and Commons Specific Plan 3.0 (available online at: https://www.cypress ca.org/home/showpublisheddocument/12927 /638720249212130000) P:\A-E\CCP2201.0S LARC EIR\PRODUCTS\3_Public Draft EIR 2\2.0 lntroduction.docx «03/11/26» 2-7 2-8
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3.0 PROJECT DESCRIPTION
This section describes the proposed Specific Plan 3.0 Buildout Project (proposed project), including a project overview and descriptions of the proposed project’s location, objectives, and the approvals required for project implementation. Consistent with State CEQA Guidelines Section 15050, the City of Cypress (City) is the Lead Agency under CEQA and is responsible for the certification of the Final Environmental Impact Report (Final EIR) and approval of the proposed project. Los Alamitos Race Course (LARC) is the Project Applicant.

The proposed project consists of the reasonably foreseeable buildout of a portion of the area governed by the Cypress Town Center and Commons Specific Plan 3.0 (Specific Plan) that includes approximately 134 acres of land (Buildout Area) in the City. The proposed project includes the approval of Vesting Tentative Tract Map No. 19247 (VTTM 19247). VTTM 19247 includes lots with a total land area of approximately 151.6 acres. The land subject to VTTM 19247 is greater than the Buildout Area as VTTM 19247 includes Lots 8 and 9 (17.55 acres), which are, or will be, part of the Grace Church property, which is located outside the area governed by the Specific Plan. The environmental analyses in this Draft Environmental Impact Report (Draft EIR) do not consider future development on Lots 8 and 9 of VTTM 19247.

The proposed project evaluated in this Draft EIR includes 1,791 residential units and 440,000 square feet of non-residential uses that could occur within the Buildout Area.

3.1 PROJECT LOCATION AND EXISTING ENVIRONMENTAL SETTING The following sections describe the location and characteristics of the Buildout Area and provide a brief overview of the existing land uses within and in the vicinity of the Buildout Area.

The Buildout Area has multiple owners. LARC owns approximately 97 acres (LARC Property), Cypress Golf Course (GC), LLC owns approximately 33 acres (Cypress GC Property), and Grace Community Church of Cypress dba Seacoast Grace Church (Grace Church) owns approximately four acres. LARC currently operates Los Alamitos Race Course on the LARC Property. The Cypress GC Property is a portion of the former Cypress Golf Club. Grace Church currently operates a portion of its church on its four acres of land in the Buildout Area.

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3.1.1 Project Location
As illustrated in Figure 3-1: Regional Location, the Buildout Area is situated in the southern portion of the city of Cypress, within Orange County. The city of Cypress is bordered on the north by the cities of La Palma and Buena Park, on the east by the cities of Anaheim and Stanton, on the south and west by the city of Los Alamitos, and on the west by the cities of Long Beach, Hawaiian Gardens, and Lakewood.

The Buildout Area includes all of the land governed by the Specific Plan, except for the Melia Property and Lexington Park, which have previously been developed, and the portions of Lots 8 and 9 in VTTM 19247 that are not part of the land governed by the Specific Plan, see Figure 3-2: Buildout Area.

The Buildout Area is generally bounded by Cerritos Avenue to the north, on the east by several existing commercial and institutional uses along and near Walker Street including Grace Church and office and retail uses, on the west by Lexington Drive, and on the south by Katella Avenue and several existing commercial, retail, and residential uses.

Regional vehicular access to the Buildout Area is provided by Interstates 605 and 405 (I-605 and I-405), which are approximately 1.5 miles to the west and 2.1 miles to the south, respectively; Beach Boulevard (State Route 39 [SR-39]), approximately 2.7 miles to the east; and State Route 22 (SR-22), approximately 2 miles to the south.

3.1.2 Existing Land Uses
The Buildout Area is surrounded by a variety of commercial, office, business park, commercial and retail, residential, park and religious uses as shown in Figure 3-3: Surrounding Land Uses.

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 most of the Buildout Area is Lexington Park, a nine-acre park located at 4600 W. Cerritos Avenue at the southeast corner of the Cerritos Avenue/Lexington Drive intersection, immediately west and north of the Buildout Area. 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 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 Specific Plan 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. East of Lexington Drive are light industrial, office, and commercial uses.

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P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\3.0 Project Description_final.docx «03/11/26» 3-9 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 Grandstand, an annex to the Grandstand, and a Clubhouse building. The Grandstand, completed in 1959 and opened in 1960, is a five-story, 140,000- square-foot structure standing approximately 65 feet high. The Clubhouse building, constructed in the mid-1950s, is a two-story, 35,000-square-foot structure, including an additional 25,000 square feet of patron space. The Annex building, completed by 1963, is a three-story building constructed between the Grandstand and the Clubhouse building. The combined seating capacity for the Grandstand, Clubhouse building, and Annex building is approximately 3,700 people. 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).

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 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.

3.2 SPECIFIC PLAN BACKGROUND
In 1946, Frank Vessels purchased 435 acres of land that included the Buildout Area in what would become the City of Cypress. Vessels initially used this land to raise cattle and quarter horses. In 1947, Vessels built a racetrack on a portion of the property that was used for car and quarter horse racing.

In 1954, a new racetrack was developed at its current location within the Buildout Area. The adjoining Cypress Golf Club (Golf Club) was constructed in 1961 and permanently closed in 2004.

On April 17, 1990, the Cypress City Council adopted the original Cypress Business & Professional Center Specific Plan (Original Specific Plan), which established comprehensive guidance and regulations for the development of approximately 298.2 gross acres of land within the City that included all of the land that is currently governed by the Specific Plan, as well as the former Cypress Golf Club and several other properties in the surrounding areas. Subsequently, on April 24, 1990, in accordance with Measure D, the voters of the City of Cypress approved an initiative that changed the General Plan land use designation and the zoning designation for approximately 75 acres of land within the Original Specific Plan area. The Original Specific Plan was subsequently amended several times in connection with proposed development projects within the Original Specific Plan area.

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3 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\3.0 Project Description_final.docx «03/11/26» -10 On June 5, 2012, the voters of the City of Cypress approved "Measure L", a ballot initiative that, among other things, amended and restated in its entirety the Original Specific Plan as previously amended.

This Amended and Restated Cypress Business & Professional Center Specific Plan (2012 Specific Plan) established a new Planning Area 9, which consisted of portions of Planning Areas 6, 7, and 8 from the Original Specific Plan, and permitted a range of senior housing, retail, and commercial uses. It also confirmed the intent to redevelop the Cypress GC Property.

On June 5, 2018, the voters of the City of Cypress approved the Cypress Town Center and Commons Specific Plan 2.0 (2018 Specific Plan) pursuant to "Measure A". The 2018 Specific Plan superseded and replaced the 2012 Specific Plan with respect to all of the real property within the area governed by the 2018 Specific Plan (2018 Specific Plan Area).

In May 2018, Cypress GC donated to the City nine acres of land within the 2018 Specific Plan Area located within and adjacent to the designated Public Park District at the southeast corner of Cerritos Avenue and Lexington Drive. The City subsequently developed Lexington Park on that site. Melia Homes recently developed a multi-family residential project with 135 residential units (Melia Project) on the eastern seven acres of the land within the designated Town Center District in the 2018 Specific Plan.

On November 5, 2024, the voters of the City of Cypress approved the current Specific Plan pursuant to “Measure S” as part of the Cypress Housing Element Implementation Project (Housing Implementation Project). The current Specific Plan superseded and replaced the 2018 Specific Plan.

Prior to the voter's approval of Measure S, the City Council certified a Final Environmental Impact Report (SCH No. 2023040560) for the Housing Element Implementation Project (Housing Element Implementation Final EIR) that analyzed the environmental impacts associated with adding 676 residential units within the 2018 Specific Plan Area beyond the maximum number of residential units permitted under the 2018 Specific Plan. The 2018 Specific Plan permitted a maximum of 1,250 residential units, so the increase of 676 units now allows a maximum of 1,926 residential units within the 2018 Specific Plan Area (including the 135 residential units previously developed as part of the Melia Project). This Draft EIR conservatively analyzes the environmental impacts associated with the 676 additional residential units as part of the overall proposed project, notwithstanding that the Housing Element Implementation Final EIR recently analyzed those impacts. Accordingly, this Draft EIR incorporates the Housing Element Implementation Final EIR by reference.

3.3 SPECIFIC PLAN CHARACTERISTICS
The Specific Plan includes six land use districts that permit the development of residential, commercial, retail, restaurant, entertainment, and park and recreational uses. As shown on Figure 2-1 (Land Use Plan) of the Specific Plan, the land use districts include a Residential District (46.2 acres), Senior Housing/Medium-Density Residential District (23.1 acres), Mixed-Use (Town Center/HDR) District (24.1 acres), Mixed-Use (Town Center/MDR) (9.5 acres), Medium-Density Residential District (20.7 acres), and Public Park District (20 acres). As shown on Figure 2-2 (Residential Subdistricts) of the Specific Plan, the Residential District has been divided into a Single-Family Detached Subdistrict (19.7 acres) and a Single-Family Attached Subdistrict (27.2 acres), see Figure 3-4: Specific Plan Land Uses and Allowed Dwelling Units per Acre.
0 450 900
SOURCE: Forma, 12/2017
FEET
FIGURE 3-4
Land Uses and Allowed Dwelling Units per Acre
Specific Plan 3.0 Buildout Project
CYPRESS TOWN CENTER AND COMMONS Land Use Plan
SPECIFIC PLAN 3.0
Figure 2-1
Katella Avenue
Cerritos Avenue
Lexington Drive
Walker Street
Denni Street
Moody Street
Siboney Street
Vessels Circle
Enterprise Drive
! " ! ! #! ! May 2024
Winners Circle
(Area to Moody
Centerline)
I:\C\CCP2201.050\G\Land_Use.ai (4/2/2025)
VTTM 19247
Buildout Area
Proposed Lot Line
Public Park District
Mixed-Use (Town Center/HDR) District
Mixed-Use (Town Center/MDR) District
Medium-Density Residential District
Residential District
Senior Housing/ Medium-Density Residential District
Public Park Overlay (2.0 Acres)
LEGEND

LAND USES
LOT 5

1.95 Acres
LOT 6

5.42 Acres
LOT 7

20.66 Acres
15 du/ac
LOT 11

1.75 Acres
LOT 12

8.86 Acres
30 du/ac
LOT 13

6.52 Acres
30 du/ac
LOT 14

7.33 Acres
15-20 du/ac
LOT 10

2.0 Acres
LOT 9

13.37 Acres
LOT 8

4.18 Acres LOT 4
19 Acres
8 du/ac
LOT 3

27.15 Acres
10 du/ac
LOT 2

23.08 Acres
15-20 du/ac
LOT 1

1.20 Acres
LSA c:J
- CJ
$ - CJ
-
-
-
rl'Zij
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P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\3.0 Project Description_final.docx «03/11/26» 3-13 The Specific Plan includes development standards for each land use district that quantify the maximum amount of residential and non-residential development that can occur within a land use district and the overall area governed by the Specific Plan. 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. The Specific Plan also includes the general locations of the permitted development, various development restrictions and limitations, infrastructure plans and sustainability guidelines.

The proposed project does not include any proposed amendments or modifications to the adopted Specific Plan. This Draft EIR analyzes programmatically the environmental impacts associated with residential and non-residential development within the Buildout Area based on a reasonably foreseeable buildout scenario, as presented in Section 3.5, Project Description, below.

3.4 PROJECT OBJECTIVES
Section 15124(b) of the State CEQA Guidelines states that the project description shall contain “a statement of the objectives sought by the proposed project.” Section 15124(b) of the State CEQA Guidelines further states that “the statement of objectives should include the underlying purpose of the project.”
The underlying purpose of the proposed project is to redevelop the Buildout Area in accordance with the voted-approved Specific Plan. This will be accomplished consistent with the following objectives:

1. Provide a significant number of new residential units in the Buildout Area to help meet the unmet demand for housing in the City and the project vicinity, consistent with the City’s Housing Element and the Cypress Town Center and Commons Specific Plan 3.0 approved by the voters of the City of Cypress.

2. Establish a mixed-use town center that is intended to be the City's "main street" and a gathering place for the community with a vibrant mix of entertainment, retail, restaurant, commercial and residential uses.

3. Revitalize a large urban area in the City that is currently significantly underutilized.

4. Diversify the City's existing housing stock by providing various housing product types and densities to meet a range of housing needs of Cypress and area residents.

5. Provide a mix of residential, commercial, retail and park and recreational uses that encourages project residents to walk or bike to and from the commercial areas and attractions and parks within the Buildout Area and provides an enhanced consumer and employee base for the new commercial uses.

6. Develop a project that will invigorate the local economy by providing new employment and business opportunities

7. Provide residential and commercial/retail improvement that will generate new sources of revenue for the City through increased property values and retail sales.

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8. Extend existing City streets through all or a portion of the Buildout Area to improve overall traffic circulation in the project vicinity and provide necessary vehicular and pedestrian access for project residents, tenants, visitors and patrons.

9. Develop new residential and senior housing communities with sufficient housing units to support the size, scale and operation of planned public parks and other amenities and common areas included in the proposed project.

3.5 PROJECT DESCRIPTION
The project analyzed in this Draft EIR is the reasonably foreseeable buildout allowed under the current Specific Plan, which City of Cypress voters approved on November 5, 2024, pursuant to "Measure S" as part of the Housing Element Implementation Project.

3.5.1 Project Scope
Residential Development: As summarized in Table 3.A: Specific Plan Land Use Plan Summary below, the Specific Plan allows for a maximum of 1,926 residential units, including the units allowed on the seven-acre Melia Property. Melia Homes previously developed the Belmont residential project with 135 units on the Melia Property. Therefore, as shown in Table 3.A, an additional 1,791 residential units (1,926 – 135) may be developed within the Buildout Area.

Non-Residential Development: As shown in Table 3.A, the Specific Plan permits an aggregate maximum of 879,170 square feet of non-residential floor area within the Buildout Area. However, it is anticipated that, based on current and reasonably foreseeable future market conditions, the buildout of the Buildout Area will include substantially less than 879,170 square feet of non-residential development. Therefore, the environmental analyses in this Draft EIR are based in part on the assumption that only 440,000 square feet of non-residential development will occur within the Buildout Area. This represents approximately 50 percent of the maximum amount of permitted nonresidential development. If non-residential development that cumulatively exceeds 440,000 square feet is later proposed within the Buildout Area, additional environmental review in accordance with the provisions of CEQA and the State CEQA Guidelines may be required if and to the extent such nonresidential development requires any discretionary action by the City.

Development of Lot 14: Melia Homes has proposed a project (Lot 14 Project) on the entirety of Lot 14 in proposed VTTM 19247, which includes approximately 7.33 acres of land, as shown on Figure 3-5: Vesting Tentative Map No. 19247 and Table 3.B: Maximum/Reasonably Foreseeable Project Buildout below. The Lot 14 Project includes the subdivision of proposed Lot 14 into 8 lots (Lots 1-6, A and B) for condominium purposes for the construction and sale of 112 attached townhomes, with common areas for landscaping, recreation center, parking, drive aisles, and easements. The Lot 14 Project is located in the Mixed-Use (Town Center/MDR) District established in the Specific Plan.

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P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\3.0 Project Description_final.docx «03/11/26» 3-15 Table 3.A: Specific Plan Land Use Plan Summary
Land Use District Area
(acres) Maximum FAR1 Maximum Residential Units
Maximum
Development
Capacity (sq ft)
Public Park 18.22 N/A N/A N/A
Mixed-Use
(Town Center/HDR) 24.1 0.6:1
1,926
(aggregate total for
Residential, Senior
Housing/MediumDensity Residential,
Medium-Density
Residential and
Mixed-Use Districts)
629,878
Mixed-Use
(Town Center/MDR) 9.5 0.6:1 248,292
Residential 46.2 N/A N/A
Senior
Housing/MediumDensity Residential23.1 N/A N/A
Medium-Density
Residential 20.7 0.6:1 N/A
Roads 9.6 N/A N/A N/A
Total Specific Plan 3.0 151.44 -- 1,9263 879,170
Source: LSA (2025).
1 This development restriction on floor area ratio (FAR) does not apply to residential development or the residential component of a mixed-use development. The maximum FAR allowed on any development parcel is 1.0:1. 2 The minimum amount of public park space within the area governed by the Specific Plan is 20 acres. In addition to the 18.2 acres of public park space within the Public Park District, a 2-acre public park has been designated as a land use overlay within the Mixed-Use (Town Center/HDR) District, provided that this additional required public park space may be located (a) in any Land Use District or multiple Land Use Districts, and (b) adjacent to one or both of the Public Park Districts in order to increase the size of the public parks that would be developed there.
3 The aggregate total of 1,926 residential units includes the 135 residential units previously developed on the Melia Property. Therefore, an additional 1,791 residential units are allowed in these districts within the Buildout Area. 4 In preparing VTTM 19247, the acreages for the Land Use Districts and roads within the area governed by the Specific Plan were more accurately calculated, resulting in a slightly reduced total land area of approximately 150.1 acres.

HDR= High-Density Residential
MDR= Medium-Density Residential
N/A = not applicable
SFR= Single-Family Residential
sq ft = square feet
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) '---- -= - __J l L__
7 NAP.
n TT
LSA
¢
0 400 800
FEET
SOURCE: TAIT & Associates
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ITnTr - /fF~1r-11r=-=--i1P
LEGEND:
-- - -- CENlERUNE

RIGHT CF WAY/PROPERTY LINE

PROPOSED LOT LINE

PROPOSED DETENTION BASIN
l:\C\CCP2201.0S0\G\Vest_Tentative_Tract_Map_Exist_Sub_LO.ai (3/11/2026) AVENUE~~ lfj
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I I
I I _ _ _,,.,.,..."'"'"-----11 I
=1J:~,tfli=,4'=j~ ~ b ~ =-11 : I 20' SEl1ER EASEMENT

CITYCFC'IPRESS
F

VESSELS CIRCLE --,
FIGURE 3-5
Specific Plan 3.0 Bui/dout Project
Vesting Tentative Tract No. 19247
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P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\3.0 Project Description_final.docx «03/11/26» 3-19 Table 3.B: Maximum/Reasonably Foreseeable Project Buildout Lot
Number
Specific Plan Land Use
District
Lot Size
(ac)
Maximum Number
of Dwelling Units
(du)/Reasonably
Foreseeable NonResidential Floor
Area
Maximum
Residential
Density
(du/ac)
Maximum
Effective
Residential
Density
(du/ac)
2 Senior Housing/MDR 23.08 404 du 15-20 17.5*
3 Residential 27.15 269 du 10 9.9
4 Residential 19.00 141 du 8 7.4
7 Medium-Density Residential 20.66 309 du 15 14.9
10 Mixed-Use (Town
Center/MDR)

2.00 29 du 15 14.5
11 Mixed-Use (Town
Center/HDR)

1.75 51 du 30 29.1
12 Mixed-Use (Town
Center/HDR)

8.86 265 du 30 29.9
13 Mixed-Use (Town
Center/HDR)

6.52 195 du 30 29.9
14 Mixed-Use (Town
Center/MDR)

7.33 128 du 15-20 17.5*
10-14 Non-Residential 26.6 440,000 sq ft
Non-Residential N/A N/A
Total
1,791 additional
dwelling units
440,000 square
feet of nonresidential floor
area
Source: LSA (2025).
ac = acres
Specific Plan = Cypress Town Center and Commons Specific Plan 3.0 du = dwelling units
du/ac = dwelling units per acre
HDR = High-Density Residential
MDR = Medium-Density Residential
N/A = not applicable
sq ft = square feet
* This number of dwelling units per acre is a midpoint between the maximum density for medium-density residential (15 du/ac) and the maximum density for senior housing (20 du/ac) allowed on this lot pursuant to the Specific Plan.

As shown in Table 3.B: Maximum/Reasonably Foreseeable Project Buildout below, the analyses in this Draft EIR are based on the assumed development of Lot 14 with 128 residential units and a portion of the 440,000 square feet of non-residential development that is anticipated to occur in the Buildout Area. Given that the Lot 14 Project includes only 112 residential units (fewer than the 120 residential units assumed for analytical purposes in this Draft EIR) and no non-residential uses, the environmental analyses in this Draft EIR fully account for the proposed Lot 14 Project and are conservative in that they overstate the environmental impacts associated with the development of Lot 14.

3.5.2 Relationship to Lots in VTTM 19247
As shown in Figure 3-5: Vesting Tentative Map No. 19247, proposed VTTM 19247 would divide the Buildout Area and other land currently owned by Grace Church into 14 numbered lots. The numbered lots would accommodate the development of residential, non-residential and park and recreational 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

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3 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\3.0 Project Description_final.docx «03/11/26» -20 uses. VTTM 19247 also includes existing Siboney Street, land that would be used to expand a portion of Lexington Drive adjacent to Lot 1 and Lexington Park, the further extension of Vessels Circle between Lots 7 and 12 and the extension of Moody Street to connect to Siboney Street, with Siboney Street becoming part of Moody Street.

In accordance with the approved Specific Plan, the proposed project evaluated in this Draft EIR includes residential development on Lots 2 through 4, 7, and 10 through 14, non-residential development on Lots 10 through 14, and the development of park and recreational improvements on Lots 1, 5, and 6 (as well as two additional acres within the Specific Plan that will be specified in the future).

Development on Lots 1, 5, and 6 is limited to park and recreational uses. The Public Park District includes 18.2 acres of specifically identified land, which includes the nine acres of land that the City has previously developed as Lexington Park following its approval as the Cypress Sports Park Project (SCH No. 2019089093).

The proposed project evaluated in this Draft EIR does not assume any development on Lots 8 and 9.

Following this anticipated land swap, Grace Church would own Lots 8 and 9, which collectively include approximately 17.55 acres of land and are not located within the Buildout Area. Lots 8 and 9 have been included in VTTM 19247 solely in connection with the contemplated land swap and no development is presently contemplated on those lots by Grace Church.

The maximum residential buildout and reasonably foreseeable non-residential buildout of the Buildout Area pursuant to the Specific Plan, shown in Table 3.B: Maximum/Reasonably Foreseeable Project Buildout below, reflects the land swap described above and therefore includes Lots 5 and 10, and excludes Lots 8 and 9.

3.5.3 Circulation and Access
As shown on Figure 3-5, consistent with the approved Specific Plan, the proposed project evaluated in this Draft EIR assumes the extension of Moody Street from Cerritos Avenue to Katella Avenue, as well as the extension of Vessels Circle from its current western terminus to intersect with the Moody Street extension. The Moody Street extension would traverse the Buildout Area, passing adjacent to Lots 3, 4, 13, and 14 in VTTM 19247, and create a central north-south corridor, while the extension of Vessels Circle within Lot C would, among other things, provide access to Lots 10 and 11 in VTTM 19247.

The proposed project also includes, consistent with the Specific Plan, the widening of Lexington Drive within Lot B in VTTM 19247. Future development within the Buildout Area may require the construction of private driveways, accessways and/or streets that connect to the Moody Street and Vessels Circle extensions and existing public streets adjacent to the Buildout Area, but their specific locations and sizes would be determined during the design process.

3.5.4 Open Space and Landscaping
The proposed project evaluated in this Draft EIR also assumes that the Buildout Area would include landscaped areas as required by the Specific Plan and the City of Cypress Municipal Code (Municipal

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P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\3.0 Project Description_final.docx «03/11/26» 3-21 Code), as applicable. The exact location and amount of landscaped areas have not been designed yet and would be determined in connection with the future development of specific development projects.

The proposed project evaluated in this Draft EIR also assumes that the Buildout Area would include approximately 11 acres of land on which park and recreational uses would be developed, including the land in Lots 1, 5, and 6 and the two additional acres of public park space that may be located in one or more of the land use districts established in the Specific Plan. The specific amenities and improvements that would be developed in the Public Park District and the additional two acres of public park space would be determined in connection with future development projects that are proposed within the Buildout Area.

3.5.5 Water
As set forth in Section 2.3 (Water Plan) of the Specific Plan, the Golden State Water Company (GSWC) provides water supply to the land within the Buildout Area. There are existing water lines within Lexington Drive, Cerritos Avenue, and Katella Avenue, as depicted on Figure 2-4 (Water Plan) in the Specific Plan, that currently serve, and would continue to serve, the Buildout Area. GSWC has indicated that these existing lines are adequate for the approved uses within the Buildout Area.

3.5.6 Wastewater
As set forth in Section 2.4 (Wastewater Plan) of the Specific Plan, existing sewer lines consist of a 30-inch Orange County Sanitation District (OC San) regional sub-trunk in Lexington Drive that flows south to Katella Avenue, 21-inch and 18-inch City sewer lines that connect to the OC San facility at the intersection of Katella Avenue and Lexington Drive, and a trunk line in Enterprise Drive. The existing trunk sewer lines adjacent to the Buildout Area are shown on the Wastewater Plan in Figure 2-5 of the Specific Plan. New development that occurs within the Buildout Area would connect to the existing trunk sewer lines.

Wastewater services for future development within the Buildout Area would be provided by the City of Cypress and OC San. The proposed project evaluated in this Draft EIR assumes the installation of the following two new sewer connections to existing sewer main lines: (1) a new 8-inch line on Lot 2, which would connect to the existing 30-inch sewer trunk line owned and maintained by OC San within Lexington Drive; and (2) a new 8-inch sewer line (which would gradually increase in size to a 15-inch line at the existing main line connection) on Lots 3 to 7 and Lots 10 to 14, running north to south along the proposed extension of Moody Street. The second sewer connection would connect to the existing 18-inch and 21-inch sewer main lines in Katella Avenue that are owned and maintained by the City. To maintain sufficient capacity to serve the development allowed within the Buildout Area, it is anticipated that the 18-inch and 21-inch sewer main lines within Katella Avenue would need to be upsized to a 24-inch main line that would ultimately connect to the existing 30-inch OC San sewer trunk line.

3.5.7 Stormwater
Under existing conditions, the southern portion of the Buildout Area generally drains south towards the Katella Avenue Storm Drain, the northwestern portion of the Buildout Area drains west towards 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

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3 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\3.0 Project Description_final.docx «03/11/26» -22 Lexington Drive, and a small portion of the Buildout Area in the north drains north towards Cerritos Avenue. To accommodate the anticipated drainage patterns within the Buildout Area, it is assumed that an additional outfall would be installed at the existing Vessels Circle Storm Drain. The proposed project evaluated in this Draft EIR also assumes the installation of a tributary line to the Walker Street Storm Drain.

3.5.8 Solid Waste
Solid waste collection for the Buildout Area would be provided by Valley Vista Services of Orange County, a private solid waste hauler. The City currently contracts with Valley Vista Services of Orange County to collect and dispose of the solid waste/refuse generated in the City.

3.5.9 Electricity and Communication
Electricity for the development allowed within the Buildout Area would be supplied by Southern California Edison (SCE) through connections to existing service lines. Telephone, television, and internet services are offered by a variety of providers in the City of Cypress, including AT&T, Frontier Communications, Spectrum, HughesNet, and ViaSat. Non-satellite providers include Frontier and Spectrum Cable. Satellite internet providers include ViaSat, DirectTV, and DishTV. These services are privately operated and offered to each location in the City for a fee defined by the provider.

3.5.10 Construction Assumptions
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 Los Alamitos Race Course, including the race track and infield area, grandstand, buildings, barns and structures and two artificial lakes.

That would be followed by the grading for and construction of specific development projects within discrete portions of the Buildout Area. It is anticipated that construction would commence in 2026 and be completed in 2038.

As discussed above, development within the Buildout Area would occur on a project-by-project basis and the specific design and sequencing of those projects cannot be determined at this time. However, the construction analyses in this Draft EIR are based on two different construction scenarios to provide a conservative, worst-case analysis. The first construction scenario evaluates full buildout of 1,791 additional residential units and 440,000 square feet of non-residential development, consistent with CEQA and South Coast Air Quality Management District (SCAQMD) guidance. Regional construction emissions were calculated for demolition, site preparation, grading, building construction, paving, and architectural coating activities. Operational emissions, including those from vehicle trips and energy use, were also estimated.

The second construction scenario includes construction emissions based on a reasonable worst-case circumstance that includes the simultaneous grading of multiple development areas to reflect a conservative construction scenario. This scenario assumes that grading activities would occur concurrently on five lots—Lots 2, 4, 7, 12, and 13—with full grading of Lots 4, 12, and 13, as well as partial grading of the southern 8 acres of Lot 2 and the northern 11 acres of Lot 7. The purpose of this model run is to capture the potential for overlapping construction schedules. As such, this scenario

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3.5.11 Requested Entitlements, Approvals and Permits
The list below includes the anticipated approvals and permits required for the proposed project, with the understanding that the Specific Plan has already been approved by Cypress voters. This Draft EIR analyzes the environmental impacts of the proposed project and provides environmental review sufficient for all necessary entitlements, approvals, permits and other agency actions associated with the proposed project. In accordance with Sections 15050 and 15367 of the State CEQA Guidelines, the City is the designated lead agency for the proposed project and has principal authority and jurisdiction for CEQA actions and project approvals. The discretionary entitlements, approvals, and permits for the proposed project include, but are not necessarily limited to the approval of the following:
• Vesting Tentative Tract Map No. 19247; and
• Development Agreement pursuant to Section 65864 et seq. of the California Government Code.

In addition to the specific discretionary approvals listed above, subsequent development projects within the Buildout Area would also require discretionary and/or ministerial approvals and permits, including, but not limited to, the approval of site plan review pursuant to Section 5.8 of the Specific Plan, further subdivision maps, demolition permits, grading permits, and building permits.

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4.0 EXISTING SETTING, ENVIRONMENTAL ANALYSIS, IMPACTS, AND

MITIGATION MEASURES

OVERVIEW OF ENVIRONMENTAL SETTING
This chapter contains 20 sections, and each section addresses one environmental topic listed in Appendix G to the Guidelines for the California Environmental Quality Act (State CEQA Guidelines) (California Code of Regulations [CCR] Title 14, Chapter 3, Sections 15000-15397).

For each environmental impact issue analyzed, this Draft Environmental Impact Report (Draft EIR) includes a detailed explanation of the existing conditions, thresholds of significance that will be applied to determine whether the project's impacts are significant or less than significant, analysis of the environmental impacts, and a determination of whether the project would have a significant impact if implemented. A "significant impact" or "significant effect" means "a substantial, or potentially substantial, adverse change in any of the physical conditions within the area affected by the project, including land, air, water, flora fauna, ambient noise, and object of aesthetic significance. An economic or social change by itself shall not considered to be a significant effect on the environment." (14 CCR Section 15382). Each environmental topic section in Chapter 4.0 also includes a discussion of the cumulative effects of the project when considered in combination with other projects, causing related impacts, as required by State CEQA Guidelines Section 15130.

Each of the sections is organized into eleven subsections, as follows:
• Introduction briefly describes the topics and issues covered in the section. • Scoping Process briefly summarizes the comment letters received in response to the Notice of Preparation (NOP).
• Methodology describes the approach and methods employed to complete the environmental analysis for the issue under investigation.
• Existing Environmental Setting describes the relevant physical conditions that exist at the time of the issuance of the NOP that may influence or affect the issue under investigation. This section focuses on physical site characteristics that are relevant to the environmental topic being analyzed.
• Regulatory Setting lists and discusses the laws, ordinances, regulations, plans, and policies that relate to the specific environmental topic and how they apply to the proposed project. • Thresholds of Significance sets forth the thresholds that are the basis of the conclusions regarding significance, which are primarily the criteria in Appendix G to the State CEQA Guidelines and the City of Cypress' (City) Initial Study/Environmental Checklist. • Project Impacts describes the potential environmental changes to the existing physical conditions that may occur if the proposed project is implemented. Evidence is presented to show the cause-and-effect relationship between the proposed project and potential changes in P:\A-E\CCP2201.0S LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.0 Existing Environmental Setting.docx (03/10/26) 4-1 SPECIFIC PLAN 3.0 BUI LOO UT PROJECT

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the environment. In accordance with State CEQA Guidelines Section 15126.2(a), this Draft EIR is required to "identify and focus on the significant environmental effects" of the proposed project. The magnitude, duration, extent, frequency, and range or other parameters of a potential impact are ascertained to the extent feasible to determine whether impacts may be significant. In accordance with CEQA and the State CEQA Guidelines, potential project impacts, if any, are classified as follows for each of the environmental topics discussed in this Draft EIR. o Significant and Unavoidable Impact: An impact is considered significant and unavoidable when the Lead Agency finds that even with the application of all feasible mitigation measures or project alternatives, the project would still result in a substantial adverse change in the identified significant environment. In other words, no reasonable actions are available that would reduce the impact to a less than significant level. If the proposed project is approved with significant and unavoidable impacts, the decision-making body is required to adopt a statement of overriding considerations pursuant to State CEQA Guidelines Section 15093 explaining why the project benefits outweigh the unavoidable adverse environmental effects caused by those significant and unavoidable environmental impacts.
o Less Than Significant with Mitigation Incorporated: An impact is considered less than significant with mitigation incorporated when the proposed project could potentially cause a significant environmental effect, but feasible mitigation measures or project modifications are available and would be implemented to avoid or substantially reduce the significant impact to below the threshold of significance. After mitigation, no significant adverse environmental effects would remain. If the proposed project is approved, the decisionmaking body is required to make findings pursuant to State CEQA Guidelines Section 15091 that significant impacts have been mitigated to the extent feasible through implementation of mitigation measures.
o Less Than Significant Impact: An impact is considered less than significant when the proposed project would not result in a substantial adverse change in the environment, and the level of effect would not exceed the applicable threshold of significance established under CEQA. In this case, the impact would be minor, temporary, or adequately controlled through standard regulations, project design features, or existing policies, such that no mitigation measures are required to reduce the impact. No mitigation is required for less than significant impacts.
o No Impact: A determination of no impact is made when the proposed project would not result in any change to the physical environment for the resource in question. In this case, there would be no effect on existing environmental conditions, and the impact would not occur under any circumstances.
• Level of Significance Prior to Mitigation summarizes the potentially significant impacts of the project, if any, prior to mitigation.
• Regulatory Compliance Measures and Mitigation Measures describe relevant laws or regulations that must be adhered to with respect to the construction and/or operation of the 4-2 P:\A-E\CCP2201.0S LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.0 Existing Environmental Setting.docx (03/10/26)

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proposed project and that would reduce or lessen potential impacts related to a particular environmental area and identifies project-specific measures that avoid, minimize, rectify, reduce, eliminate, or compensate for a potentially significant impact. • Level of Significance after Mitigation describes the significance of potential impacts after implementation of feasible, recommended mitigation measures. Potential significant and unavoidable impacts are clearly stated in this section. • Cumulative Impacts refers to potential environmental changes to the existing physical conditions that may occur as a result of project implementation together with all other reasonably foreseeable, planned, and approved future projects in the vicinity of the approximately 134 acres of land on which the proposed project would be developed (Buildout Area) that produce related impacts. State CEQA Guidelines Section 15355 defines cumulative impacts as "two or more individual effects which, when considered together, are considerable or which compound or increase other environmental impacts." Cumulative impacts may result from individually minor but collectively significant projects taking place over a period of time.

Projects that have progressed to the stage where a project application has been filed are normally treated as foreseeable probable future projects. For each of the environmental topics considered in this Draft EIR, the geographic scope of the cumulative analysis is defined.

Thresholds of Significance
The threshold questions used in this Draft EIR are consistent with Appendix G to the State CEQA Guidelines.

Related Projects
In accordance with State CEQA Guidelines Section 15130, cumulative impacts are anticipated impacts of the proposed project along with reasonably foreseeable growth. Reasonably foreseeable growth may be based on either:
• A list of past, present, and probable future projects producing related or cumulative impacts, including, if necessary, those projects outside the control of the agency; or • A summary of projections contained in the adopted General Plan or related planning document, or in a prior environmental document that has been adopted or certified, and that described or evaluated regional or area-wide conditions contributing to the cumulative impact.

Each environmental topic in this Draft EIR includes a cumulative impact analysis that follows the CEQA-recommended approaches outlined in State CEQA Guidelines Section 15130. For topic areas using the project list approach, the analysis begins with a summary of the past, present, and reasonably foreseeable future projects that could contribute to cumulative impacts, including a summary of CEQA findings for the project that underwent environmental clearance. Each section identifies the relevant projects and, where appropriate, specifies the geographic scope for the cumulative analysis if it differs from the overall cumulative project list (for example, when a resource area's impact footprint is broader or more localized than the Buildout Area). For topic areas where the plan-based approach is more appropriate, the analysis relies on regional growth P:\A-E\CCP2201.0S LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.0 Existing Environmental Setting.docx (03/10/26) 4-3 SPECIFIC PLAN 3.0 BUI LOO UT PROJECT

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projections and assumptions from adopted plans and previously certified environmental documents, consistent with CEQA's second allowable method, like air quality, greenhouse gas emissions and energy. This structure ensures that each cumulative impact discussion is tailored to the resource analyzed and grounded in the appropriate scale of cumulative effect.

The discussion of cumulative impacts "should be guided by the standards of practicality and reasonableness" (Environmental Protection Info. Center v. Department of Forestry & Fire Protection (2008) 44 Cal.4th 459, 524). A proposal that has not crystallized to the point that it would be reasonable and practical to evaluate its cumulative impacts need not be treated as a probable future project (City of Maywood v. Los Angeles Unified School District (2012) 208 Cal.App.4th 362, 397).

Rather, a potential future project qualifies for inclusion in an analysis of cumulative impacts only to the extent the future project is "both probable and sufficiently certain to allow for meaningful cumulative impact analysis" (Id. at 398; see City of Long Beach v. Los Angeles Unified School Dist. (2009) 176 Cal.App.4th 889, 902 [when "review[ing] the agency's decision to include information in the cumulative impacts analysis[,] ... [w]e determine whether inclusion was reasonable and practical"]).

Table 4.A: Summary of Related Projects and Figure 4-1: Related Projects provide a list of related projects within the cities of Cypress and Los Alamitos.

Table 4.A: Summary of Related Projects
Project No. Related Project and Location Description
1 Shea Properties Mixed Use Development Development of a 43,200-square-foot theater, five-story (5155-5253 Katella Avenue, Cypress) hotel with up to 120 rooms, approximately 20,800 square feet of retail and restaurant uses, and a four-story
residential component with up to 251 market-rate
apartment units.
2 Melia Homes - Citrus Square Development of 135 dwelling units, including 56 two-story (9470 Moody Street, Cypress) condominiums and 79 three-story row townhomes. 3 Goodman Commerce Center Development of 581,663 square feet of warehouse space. (5755 and 5885 Plaza Drive, Cypress)
4 8561 Belmont Street, Cypress Development of eight multi-family housing units. 5 LTP Modern Machine Development of a 24,252-square-foot warehouse facility. (10900 Walker Street, Cypress)
6 Sycamore Creek Charter School Private school for 340 students. (4321 Cerritos Avenue, Cypress)
7 Los Alamitos Medical Center, Los Alamitos Development of a medical center consisting of 218 beds. 8 4562 Katella Avenue, Los Alamitos Development of a 5,020-square-foot general office building.

Source: City of Cypress (April 2025).
4-4 P:\A-E\CCP2201.0S LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.0 Existing Environmental Setting.docx (03/10/26) LSA l=l Project Site
:::::1 City Boundary
0 Related Project
Site Operational Status
0 0.25 0.5 Active
Miles
SOURCE: Earthstar Geographies (2024)
l:\C\CCP2201.050\GIS\Pro\Los Alamitos Race Course Development Project\Los Alamitos Race Course Development Project.aprx (5/28/2025) FIGURE 4-1
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4.1 AESTHETICS
This section identifies the existing aesthetic condition of the Buildout Area and the surrounding area and evaluates the potential impacts of the Specific Plan 3.0 Buildout Project (proposed project) relating to scenic vistas, scenic resources, visual resources and lighting. Information in this section is based on the design guidelines and development standards contained in the Cypress Town Center and Commons Specific Plan 3.0 (Specific Plan), the City of Cypress Zoning Ordinance, and the Cypress General Plan Conservation/Open Space/Recreation Element.1

4.1.1 Scoping
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 aesthetics.

4.1.2 Methodology
The assessment of aesthetic impacts is subjective by nature. This analysis identifies and objectively examines factors that contribute to the perception of aesthetic impacts that could be caused by the proposed project. The potential aesthetic impacts of the proposed project were assessed based on consideration of several factors, including setting, scale, mass, and proportion. Public viewer groups are limited to motorists and pedestrians along public roadways in the project vicinity, as well as users of nearby parks and/or public open spaces.

The concepts and terminology used in this analysis are described below.

4.1.2.1 Scenic Resources
Scenic resources are defined as natural or manmade elements that contribute to an area’s scenic value and are generally viewed as visually pleasing or otherwise in a positive light. Scenic resources may include landforms, vegetation, trees, rock outcroppings, water, or historic buildings within a state scenic highway, and may include a cultural modification to the natural environment. A development could impact a scenic resource directly through physical changes (e.g., removal, disturbance, or development on a ridgeline, hillside, peak or shoreline) and/or through limiting access to the scenic resource to the viewing public. The degree to which these resources are present or significant is based on the values of the community and the viewing public.

4.1.2.2 Scenic Vista
A scenic vista typically consists of an expansive view or viewshed designated by the community or a feature valued by the viewing public. A development project can affect a scenic vista by either blocking or partially obstructing publicly available views of the vista, or by blocking access to said vistas.
1 City of Cypress. 2001. Cypress General Plan Conservation, Open Space/Recreation Element.

Website: https://www.cypressca.org/home/showpublisheddocument/686/636123123792970000 (accessed March 2026).

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4.1.2.3 Scenic Corridors
Scenic corridors are public features that facilitate movement (primarily by automobile, transit, bicycle, or foot) from one location to another and provide expansive views of natural landscapes and/or visually attractive manmade development. Scenic corridors analyzed under the California Environmental Quality Act (CEQA) typically include State-designated scenic highways and locally designated scenic routes.

4.1.2.4 Scenic Character
The scenic character of an area is defined by the natural or manmade features that create an overall impression of an area. In this context, scenic character will vary widely based on one’s location. For example, the scenic character of a residential neighborhood may be defined by a pleasing streetscape with mature landscaping and well-maintained residences, while that of a commercial area may be defined by the age, style, and mix of uses; the pedestrian scale (or lack thereof); access and parking areas; landscaping; and public amenities. In general, scenic character can be organized around four basic elements: (1) site utilization; (2) buildings and structures; (3) landscaping; and (4) signage. Adverse effects to scenic character may result from the development of incompatible uses, the absence of required public amenities, poor building siting and design, and/or insufficient, inappropriate, incompatible signage, landscaping, screening, or lighting.

4.1.2.5 Glare
Glare is a continuous or periodic intense light that may cause eye discomfort or be temporarily blinding to humans. Glare in the form of sunlight reflecting off windows and building surfaces may affect adjacent uses or interfere with the operation of motor vehicles, aviation, or other activities.

Glare can also be produced during evening and nighttime hours by artificial light sources, such as illuminated signage and vehicle headlights. Glare-sensitive uses generally include residences and transportation corridors (i.e., roadways).

4.1.2.6 Light Sources
A light source is a device that produces illumination, including incandescent bulbs, fluorescent and neon tubes, halogen and other vapor lamps, light-emitting diode (LED) fixtures, and reflecting surfaces or refractors incorporated into a lighting fixture. Any translucent enclosure of a light source is considered to be part of the light source.

4.1.2.7 Vantage Point
A vantage point is a particular point of observation.

4.1.2.8 Light and Glare
The analysis of light and glare identifies the location of light-sensitive land uses and describes the existing ambient conditions in and in the vicinity of the Buildout Area. The analysis describes the proposed project’s light and glare sources and the extent to which project lighting, including any potential illuminated signage, would spill off the Buildout Area onto adjacent light-sensitive areas.

The analysis also describes the affected street frontages, the direction in which the light would be focused, and the extent to which the proposed project would illuminate sensitive land uses. The

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4.1.3 Environmental Setting
The Buildout Area is relatively flat with slight elevation changes throughout. 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, two artificial water features 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. Regional vehicular access to the Buildout Area is provided by Interstates 605 and 405 (I-605 and I-405), which are approximately 1.5 miles to the west and 2.1 miles to the south, respectively; Beach Boulevard (State Route 39 [SR-39]), approximately

2.7 miles to the east; and State Route 22 (SR-22), approximately 2 miles to the south.

The area southeast of the Buildout Area is developed with the Belmont residential project by Melia Homes, which consists exclusively of residential uses, and The Square at Cypress by Shea Homes, which includes residential, hotel, retail, and service uses. Farther east, a retail center at 5401 Katella Avenue contains a Costco Wholesale warehouse and gas station, as well as other commercial uses.

Southwest of the Buildout Area, along Katella Avenue, are Cottonwood Church (4505 Katella Avenue), the Ovation at Flora Park senior housing community, and a commercial center that includes restaurant, retail, service uses, a 24 Hour Fitness, and the Residence Inn Cypress Los Alamitos (4931 Katella Avenue). West of Lexington Drive, existing development includes light industrial, office, and commercial uses. Buildings within the vicinity of the Buildout Area generally range from one to four stories (approximately 15 to 70 feet in height) and include a mix of residential, commercial, industrial, and public uses.

The Buildout Area includes approximately 134 acres of land. As such, there are many different public vantage points of the Buildout Area. It is visible from the north by vehicles and pedestrians traveling southbound along Moody Street and along both sides of W. Cerritos Avenue. From the east, the Buildout Area is visible to vehicles and pedestrians traveling along Vessels Circle and other access roadways. From the west, the Buildout Area is visible to vehicles and pedestrians traveling along Lexington Drive and people visiting Lexington Park. From the south, the Buildout Area is visible to vehicles and pedestrians traveling along Katella Avenue and Enterprise Drive.

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

4.1.4.1 Federal Regulations
No federal regulations pertaining to aesthetics are applicable to the proposed project.

4.1.4.2 State Regulations
Caltrans Scenic Highway Program. The California Department of Transportation’s (Caltrans) Scenic Highway Program protects the natural scenic beauty of the State’s highways and corridors through its designated scenic highways throughout the State.2 Caltrans designates freeways, highways, roads, or other public rights-of-way (ROW) as scenic highways pursuant to a variety of factors, including whether the ROW traverses an area of outstanding scenic quality and contains striking views, flora, geology, and other unique natural attributes. Other considerations given to a scenic highway designation include how much of the natural landscape a traveler may see and the extent to which visual intrusions degrade the scenic corridor.

According to Caltrans, the only State-designated Scenic Highway in Orange County is a 4-mile portion of State Route 91 (SR-91) from State Route 55 (SR-55) to east of the Anaheim city limits.

This portion of SR-91 is approximately 12 miles northeast of the Buildout Area. The nearest State highway that is eligible for official designation as a State Scenic Highway is a portion of Pacific Coast Highway (PCH or State Route 1 [SR-1]), which is located approximately 5.5 miles southwest of the Buildout Area in the City of Seal Beach.

Title 24 of the California Code of Regulations Building Energy Efficiency Standards. The California Building Code (California Code of Regulations [CCR], Title 24)—including Title 24, Part 6—includes Section 140.7 and Section 130.2 of the 2022 Building Energy Efficiency Standards, which regulate outdoor lighting characteristics such as maximum power, brightness, shielding, and the use of sensor controls to automatically turn lighting on and off. Lighting standards vary by designated lighting zones, which are established based on ambient light levels and land use intensity. These zones are classified using population data from the 2010 United State (U.S.) Census and range from Lighting Zone 0 (very low ambient light) to Lighting Zone 4 (high ambient light). Specifically, Lighting Zone 1 represents low ambient illumination (e.g., rural or natural areas), Zone 2 represents moderate ambient illumination (e.g., rural/suburban), and Zone 3 applies to urban areas with moderately high ambient illumination. The Buildout Area is located in Lighting Zone 3 (LZ3), and outdoor lighting for the proposed project would be required to comply with all applicable standards for this zone, including limits on lighting power density and requirements for full cutoff fixtures and motion-sensing controls, thereby reducing energy consumption and minimizing light pollution. 2 California Department of Transportation (Caltrans). 2008. Scenic Highway Guidelines. Website:
https://dot.ca.gov/programs/design/lap-landscape-architecture-and-community-livability/lap-liv-i-scenichighways (accessed March 2026).

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4.1.4.3 Regional Regulations
No regional regulations pertaining to aesthetics are applicable to the proposed project.

4.1.4.4 Local Regulations
Cypress Town Center and Commons Specific Plan 3.0. The Specific Plan includes sustainable design strategies for development within the Buildout Area and incorporates by reference relevant design strategies in the California Green Building Standards Code and the City's Residential Green Building Suggestions and Water Efficient Landscape Guidelines. Applicants for specific development projects within the Buildout Area would comply with, as applicable, these sustainable design strategies. The sustainable design strategies expressly stated in the Specific Plan with respect to scenic quality include the following:
• Encourage the use of low-contrast lighting, low-voltage fixtures and energy-efficient bulbs, such as compact fluorescent and light emitting diodes.
• Prioritize the use of native and drought tolerant plant species to reduce water demand. • Limit the use of turf as groundcover and encourage water-conserving native groundcovers or perennial grasses, shrubs, and trees.
• Provide landscaped shade canopies to reduce the heat island effect in surface parking areas. • Use renewable or recycled building materials to the extent feasible. Such materials may include flooring alternatives like bamboo, wheatboard, and cork. Linoleum, exposed concrete, and recycled-content ceramic tiles are also desirable materials.

The Specific Plan also specifies that all multi-family residential development within the Buildout Area shall comply with the applicable requirements in Section 3.17.310 of the Zoning Ordinance, which includes objective development standards relating to aesthetics and scenic quality, including exterior lighting and landscaping and open space requirements, except as otherwise required or permitted by State law or provided under the Specific Plan.

Cypress Zoning Ordinance. The Specific Plan establishes the zoning for the Buildout Area and prevails over and supersedes conflicting provisions in the City's Zoning Ordinance (Appendix I to the Municipal Code). Where no such conflict exists, the applicable requirements in the Zoning Ordinance shall apply. The Zoning Ordinance includes development standards relevant to aesthetics and scenic quality that do not conflict with the Specific Plan and therefore apply to the Buildout Area, as follows:
• Section 3.11.060.A (Exterior Fixtures): Lighting fixtures shall be architecturally compatible with the character of the surrounding structure(s) and shall be energy efficient. Fixtures shall be appropriate in height, intensity, and scale to the use they are serving. • Section 3.11.060.B (Intensity): The level of parking lot light projected onto any ground or wall surface shall not be less than two (2) footcandles nor more than five (5) footcandles at the base 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

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• Section 3.11.060.C (Security Lighting): Security lighting shall provide a minimum of two (2) footcandles and a maximum of three (3) footcandles at the ground level of the entrance. • Section 3.11.060.D (Shielding of Light Source): Where the light source is visible from outside the project boundary, shielding shall be required to reduce glare so that neither the light source nor its image from a reflective surface shall be directly visible from any point beyond the property line. This requirement shall not apply to traffic safety lighting or public street lighting. • Section 3.14.050.C.4 (Required Improvements for Off-Street Parking Areas): Off-street parking areas shall have lighting as specified by the building official and police department, with special attention to directing light and glare away from adjacent properties. The level of parking lot light shall not exceed one footcandle at a site’s property lines. • Section 3.15.060 (General Provisions for All Signs): All signs shall be structurally safe, consist of rust-inhibitive material, be maintained in good condition, and be consistent with the requirements of Section 3.15, including standards related to the sign height, width, and area. • Section 3.15.070 (Prohibited Signs): The following signs are specifically prohibited within the City: (1) Signs painted or imprinted upon, or attached in any way to a motor vehicle, vehicle part, or trailer that is parked or stored at all times on or within 50 feet of the City's arterial highways, and for a period in excess of 24 hours on all other public rights-of-way; (2) Roof signs; (3) The exhibition, posting, or displaying of any statement, symbol, or picture of an obscene nature upon any sign or wall; (4) Signs painted on structures in all zoning districts except the CH (Commercial Heavy) zoning district; (5) Any sign rotating or simulating movement by fluttering, spinning, or the use of reflective devices; (6) Any sign blinking, flashing, or animated by lighting in any fashion; (7) Canopy signs that project above the canopy; (8) Signs encroaching upon or overhanging adjacent property; (9) Any sign erected, constructed, enlarged, modified, or relocated within the City without a building permit; (10) Any electrical sign or sign illuminated by electricity that is erected, constructed, enlarged, modified, or relocated within, without both a building permit and an electrical permit; (11) Any sign that simulates or imitates in size, color, lettering, or design and traffic sign or signal, or which makes use of the words "stop," "look," "danger," or any other words, phrases, symbols, or characters in a manner that interferes with, misleads, or confuses traffic; (12) Aerial signs and displays; (13) Inflatable displays; (14) Portable A-frame signs; and (15) Supergraphic signs.
• Section 3.15.110 (Standards for Specific Types of Signs): Neon signs, non-profit organization special event signs, political campaign signs, signs over a public right-of-way, special purpose signs, temporary signs, and window signs shall be subject to the development standards set forth in this section.
• Section 3.17.310(D)(4) (Objective Standards for Multi-Family Dwellings): Sets forth exterior lighting requirements for multi-family residential developments. It mandates that lighting be provided for key areas such as building entries, pedestrian pathways, open spaces, parking

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A photometric lighting plan demonstrating compliance is required prior to issuance of building permits. To further limit light trespass, illumination at property lines must not exceed

0.5 footcandle.

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

Threshold 4.1.1: Have a substantial adverse effect on a scenic vista; Threshold 4.1.2: Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway; Threshold 4.1.3: In nonurbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings. (Public views are those that are experienced from publicly accessible vantage point). If the project is in an urbanized area, conflict with applicable zoning and other regulations governing scenic quality; or
Threshold 4.1.4: Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area.

4.1.6 Project Impacts
Threshold 4.1.1: Would the project have a substantial adverse effect on a scenic vista? No Impact. The City's General Plan does not provide a definition of scenic vista. However, a scenic vista can be defined as a viewpoint that provides expansive views of a highly valued landscape for the benefit of the general public. Aesthetic components of a scenic vista generally include (1) scenic quality, (2) sensitivity level, and (3) view access. Potential scenic vistas include areas with views of the coastline, mountains, or other prominent scenic features that are considered significant visual resources for residents and businesses.

The City is almost entirely developed, and no public vantage point provides substantial views of any water bodies, mountains, hills, or any other significant visual resources. 3 Given that no scenic vista is
currently viewable from any public vantage point in proximity to the Buildout Area, the development of the proposed project would not alter an existing scenic vista or block views of any 3 City of Cypress. 2001. Cypress General Plan. September.

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Threshold 4.1.2: Would the project substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway?
No Impact. The Caltrans Scenic Highway Program protects the natural scenic beauty of the State’s highways and corridors by designating scenic highways throughout the State. Caltrans designates freeways, highways, roads, or other public ROW as scenic highways pursuant to a variety of factors, including whether the ROW traverses an area of outstanding scenic quality and contains striking views, flora, geology, and other unique natural attributes. Other considerations given to a scenic highway designation include how much of the natural landscape a traveler may see and the extent to which visual intrusions degrade the scenic corridor.

There are no designated State Scenic Highways within the City’s limits. According to the List of Eligible and Officially Designated State Scenic Highways published by Caltrans, the only Statedesignated Scenic Highway in the County is a 4-mile segment of SR-91 from SR-55 to the east of the Anaheim city limits.4That segment of SR-91 is approximately 12 miles northeast of the Buildout Area. The nearest State highway that is eligible for official designation as a State Scenic Highway is a segment of PCH (or SR-1) located in the City of Seal Beach, approximately 5.5 miles southwest of the Buildout Area. Due to distance and intervening land uses, no portion of the Buildout Area is visible from the officially designated segment of SR-91 or the eligible segment of PCH. Therefore, the proposed project would have no impact related to the substantial damage of scenic resources within a State Scenic Highway, and no mitigation is required.

Threshold 4.1.3: In nonurbanized areas, would the project substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality? Less Than Significant Impact. According to the U.S. Census Bureau, the City is located within the Los Angeles—Long Beach—Anaheim, CA Urbanized Area.5 As described in the State CEQA Guidelines Section 15387 and defined by the U.S. Census Bureau, an “urbanized area” is a central city or a group of contiguous cities with a population of 50,000 or more people, together with adjacent densely populated areas having a population density of at least 1,000 people per square mile.6 Given 4 California Department of Transportation (Caltrans). 2015. Last modified July 2019. List of Eligible and Officially Designated State Scenic Highways. Website: https://dot.ca.gov/-/media/dot-media/programs/ design/documents/desig-and-eligible-aug2019_a11y.xlsx (accessed May 19, 2025). 5 United States Census Bureau. 2010a. Los Angeles—Long Beach—Anaheim, CA Urbanized Area No. 51445.

Website: https://www2.census.gov/geo/maps/dc10map/UAUC_RefMap/ua/ua51445_los_angeles--long_ beach--anaheim_ca/DC10UA51445_000.pdf (accessed May 19, 2025). 6 United States Census Bureau. 2010b. Census Urban Area FAQs. Website: https://www.census.gov/ programs-surveys/geography/about/faq/2010-urban-area-faq.html (accessed May 19, 2025).

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P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.1 Aesthetics_final.docx «03/11/26» 4.1-9 that the collective population of the City of Cypress and the contiguous cities substantially exceeds 50,000, the Buildout Area and the surrounding project vicinity are located in an urbanized area.

Therefore, the applicable portion of Threshold 4.1.3 is whether the proposed project would conflict with applicable zoning and other regulations governing scenic quality.

The proposed project would include higher density development within the Buildout Area than currently exists. As described in the Chapter 3.0, Project Description, the Specific Plan allows a maximum of 1,791 residential units and, for purposes of the environmental review in this Draft EIR, up to 440,000 square feet of non-residential development within the Buildout Area. The Specific Plan provides specific development standards for residential and mixed-use development, including maximum structure height and setback requirements, which would be applicable to the future development under the proposed project. As provided in Table 3-1 of the Specific Plan, future single-family detached residential structures shall not exceed 35 feet and 2 stories, and future single-family attached residential structures shall not exceed 35 feet and 3 stories. In addition, future senior housing structures shall not exceed 35 feet in height, and future structures within the mixed-use district shall not exceed 75 feet in height. Existing development in the vicinity of the Buildout Area includes residential and commercial buildings that generally range in height from one to three stories. In addition, some surrounding development, such as the Homewood Suites and the Acadia Apartments located approximately 800 feet south of the Buildout Area, exceed three stories and approach 75 feet in height. As such, the development allowed in the Buildout Area pursuant to the Specific Plan would be consistent with the mass and scale of existing development near the Buildout Area. In addition, future development facilitated by the proposed project would be required to adhere to the development and design guidelines contained in the Specific Plan, including landscaping requirements and those related to size and scale of the future buildings.

The proposed project would change the aesthetic character of the Buildout Area. However, all development pursuant to the Specific Plan would be required to comply with all relevant sustainable design strategies stated or referenced in the Specific Plan. In addition, all development within the Buildout Area would be required to comply with the design regulations in the Zoning Ordinance that relate to scenic quality, including the objective design standards in Section 3.17.110 of the Zoning Ordinance with respect to multi-family development that are not inconsistent with the Specific Plan and Section 3.15 of the Zoning Ordinance related to signage design standards. Therefore, the proposed project would have a less than significant impact related to conflict with applicable zoning and other regulations governing scenic quality, and no mitigation is required.

Threshold 4.1.4: Would the project create a new source of substantial light or glare which would adversely affect day or nighttime views in the area? Less Than Significant Impact. Currently, lighting is produced in the vicinity of the Buildout Area by surrounding commercial and residential development, street lighting, and vehicles on adjacent roadways, including Katella Avenue, West Cerritos Avenue, Lexington Drive, and Walker Street. In addition, existing uses within the Buildout Area, such as the race track, include outdoor lighting features. In the existing condition, the surface parking area on the south side of the Grandstand building is lit by light poles that are approximately 20 feet tall. Additionally, during evening horse racing events, the race track is illuminated by approximately 45 high-mast lights, with additional lighting mounted on the roof of the Grandstand building. Existing light sources in the vicinity of the 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

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Construction: Construction activities would occur only during daylight hours. Any constructionrelated illumination during evening and nighttime hours would be used for safety and security purposes only and would occur only for the duration required for the temporary construction process. Light resulting from construction activities would not substantially impact sensitive uses, substantially alter the character of surrounding uses or interfere with the performance of off-site activities. In addition, construction activities are not anticipated to result in flat, shiny surfaces that would reflect sunlight or cause other natural glare. Minor glare from sunlight on construction equipment and vehicle windshields is not anticipated to impact visibility in the area as the construction sites would be fenced and shielded from pedestrian and vehicular views. In addition, construction vehicles would not operate at night and thus would not create nighttime sources of glare. Therefore, construction of the proposed project would not create a new source of substantial light or glare that would adversely affect day or nighttime views in the area, and light and glare impacts associated with construction would be less than significant. No mitigation is required.

Operation: Implementation of the proposed project would facilitate the removal of the existing uses within the Buildout Area and allow up to 1,791 residential units and, for environmental review purposes, 440,000 square feet of non-residential development. As development occurs within the Buildout Area, new housing and non-residential development would result in new sources of light and glare, including from new street and pedestrian lighting, individual lighting from new buildings, reflective building materials, such as glass, stainless steel, aluminum, and photovoltaic panels. In addition, the proposed project would increase vehicle trips to and from the Buildout Area that would incrementally increase ambient nighttime illumination in the area.

All project lighting is required to meet all applicable lighting standards in the City’s Zoning Ordinance. As required by Section 3.11.060.A (Exterior Features) of the Zoning Ordinance, lighting fixtures shall be architecturally compatible with the character of the surrounding structure(s) and shall be energy efficient. Fixtures shall be appropriate in height, intensity, and scale to the use they are serving. In accordance with Section 3.11.060.B (Intensity), the level of parking lot light projected onto any ground or wall surface shall not be more than 5 footcandles at the base of the light fixture and building-mounted decorative lights shall not exceed 5 footcandles measured 5 feet from the light source. In accordance with Section 3.11.060.C (Security Lighting), security lighting shall provide a maximum of 3 footcandles at the ground level of the project entrances. Pursuant to Section

3.11.060.D (Shielding of Light Source), where a project light source is visible from outside the project boundary (other than public street lighting), the light source shall be shielded to reduce glare so that neither the light source nor its image from a reflective surface shall be directly visible from any point beyond the property line. As required by Section 3.14.050.C.4 (Required Improvements for OffStreet Parking Areas), the level of parking lot light shall not exceed 1 footcandle at the boundaries of the Buildout Area.

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P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.1 Aesthetics_final.docx «03/11/26» 4.1-11 Section 4.6: Lighting, of the Specific Plan includes policies to minimize light impacts on surrounding uses: (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; and (3) utilize solar-powered lights in landscaped areas for energy savings where possible.

In addition, all illuminated and neon signs associated with future development within the Buildout Area would be required to adhere to the development standards detailed in Section 3.15.110 (Standards for Specific Types of Signs) of the Zoning Ordinance. Section 3.15.110(A) states that the use of neon signs shall enhance the viewer's appreciation of the City's nighttime atmosphere and shall be primarily aesthetic and decorative with a utilitarian function only when used as signage. In addition, neon signage and linear tubing shall be UL listed with a maximum 20 amps per circuit and shall be designed to accommodate a dimmer in order to reduce the brightness of the neon. Neon linear tubing shall also not exceed one-half in width, shall reinforce the architecture of a structure, and shall be concealed from view when possible through the use of architectural features (e.g., parapets, cornices, etc.), and neon signs adjacent to residential uses shall be a maximum of one-half footcandle from the property line.

Although the proposed project would increase the overall intensity of on-site land uses and associated lighting, the increase in lighting would not result in substantial increases in light intensity at off-site locations through compliance with the applicable lighting standards in the Specific Plan and the Zoning Ordinance. In addition, light intensity diminishes rapidly as an observer moves away from the light source. As such, the intensity of project-related lighting would be concentrated onsite with little potential to create perceptible changes in ambient lighting intensity at off-site, lightsensitive locations.

Daytime glare can result from natural sunlight reflecting from a shiny surface that would interfere with the performance of an off-site activity, such as the operation of a motor vehicle. Reflective surfaces can be associated with window glass and polished surfaces. The proposed buildings would incorporate a variety of building materials, which would primarily be non-reflective materials (i.e., neutral colors and a variety of materials, such as tile, cement, plaster, and wood). Therefore, the proposed project would not have the potential to produce a substantial degree of glare.

Nighttime lighting and glare sources from the proposed project could also include lighting from interior and exterior building lighting, security lighting, parking lot lighting, and vehicle headlights.

The nighttime glare produced by these sources would be similar to the existing nighttime glare produced by the surrounding commercial/retail, residential and hotel uses and would not result in enough glare to be considered substantial or affect nighttime view because lighting would be required to meet all applicable lighting standards in the Specific Plan and the Zoning Ordinance as discussed above.

For these reasons, the proposed project would not create a new source of substantial light or glare that would adversely affect day or nighttime views in the surrounding urban area, and project impacts would be less than significant. No mitigation is required.

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4.1.7 Level of Significance Prior to Mitigation
The proposed project would not result in any significant impacts related to aesthetics, and no mitigation is required.

4.1.8 Regulatory Compliance Measures and Mitigation Measures No regulatory compliance measures are applicable to the proposed project, and no mitigation measures are required.

4.1.9 Level of Significance after Mitigation
The proposed project would not result in any significant impacts related to aesthetics, and no mitigation is required.

4.1.10 Cumulative Impacts
As defined in Section 15130 of the State CEQA Guidelines, cumulative impacts are impacts created as a result of the combination of an individual project together with other past, current, and probable future projects causing related impacts. An EIR must discuss cumulative impacts of a project when the project’s incremental effect is cumulatively considerable. The cumulative impact area for aesthetics related to the proposed project are projects located within 0.5 mile of the Buildout Area, as these projects would be collectively visible from the same public vantage points.

Of the eight related projects provided in Table 4.A: Summary of Related Projects in Chapter 4.0, Existing Setting, of this Draft EIR, five projects that are approved or under construction within the cities of Cypress and Los Alamitos are within 0.5 mile of the Buildout Area, including the Shea Properties Mixed Use Development Project (Related Project 1), Goodman Commerce Center Project (Related Project 3), LTP Modern Machine Project (Related Project 5), Sycamore Creek Charter School Project (Related Project 6), and 4562 Katella Avenue Project (Related Project 8). The Melia Homes Project (Related Project 2), 8561 Belmont Street Project (Related Project 4), and Los Alamitos Medical Center Project (Related Project 7) are farther than 0.5 mile from the Buildout Area and would not be collectively visible from the same public vantage points. Therefore, these projects are not included in this cumulative aesthetic analysis.

Overall, the development of the related projects in combination with the proposed project would not substantially degrade the existing character or quality of the environment because the project area is already highly urbanized, and these related projects are or would be well designed to be compatible with one another and the existing buildings in the surrounding area. In addition, similar to the proposed project, all related projects would be required to adhere to existing City regulations relating to aesthetic and visual character, including specific development standards for the respective project sites, Section 3.15 of the Zoning Ordinance related to signage design standards, and lighting standards detailed in Section 3.11 of the Zoning Ordinance. In addition, as discussed above, existing development in the vicinity of the Buildout Area is similar in size and scale as the future development envisioned in the Buildout Area. As such, implementation of the proposed project represents a continuation of the existing development pattern in the City, and the proposed project’s potential cumulative impact with respect to visual character would be less than significant.

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P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.1 Aesthetics_final.docx «03/11/26» 4.1-13 Moreover, some of the related projects within 0.5 mile of the Buildout Area have undergone environmental review pursuant to CEQA, which included an analysis of potential aesthetic impacts.

According to the EIR prepared for the Shea Properties Mixed Use Development (Related Project 1), no impacts relating to scenic vistas would occur with implementation of the project and less than significant impacts to visual character and light and glare would occur. Further, the EIR determined that cumulative aesthetic impacts 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 2023), and an EIR in 2024 respectively, which determined that all impacts relating to aesthetics would be less than significant, or no impact would occur. 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 be consistent with the applicable General Plan designation and General Plan policies, as well as with applicable zoning designation and regulations, including those related to aesthetic resources. As such, development of the related projects in combination with the proposed project would not result in significant aesthetic impacts. The LTP Modern Machine Project (Related Project 5) would also be required to undergo environmental review pursuant to CEQA, which would include an analysis of potential aesthetic impacts and the identification of any mitigation measures to reduce potential impacts, if necessary.

With regard to light and glare, the Buildout Area is located within a highly urbanized community surrounded by major arterial streets, with urban lighting characteristics exhibiting relatively high ambient nighttime light levels. As such, the proposed project and nearby related projects, including those listed above (which would include many of the same types of land uses as would be allowed within the Buildout Area under the Specific Plan) would not substantially alter the existing light and glare currently experienced in the area. In addition, cumulative lighting would not be expected to interfere with the performance of off-site activities given the relatively high ambient nighttime artificial light levels already present. Furthermore, the related projects are also required to adhere to applicable City requirements regarding lighting, similar to the proposed project, which would minimize the cumulative light and glare impact. As such, there would be no cumulatively considerable impact related to light and glare.

Therefore, because the proposed project would not result in significant impacts related to aesthetics, and the proposed project in combination with the related projects within 0.5 mile of the Buildout Area would be required to adhere to State and local regulations designed to reduce and/or avoid impacts related to aesthetics, the proposed project’s impact related to aesthetics would not be cumulatively considerable.

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4.2 AGRICULTURE AND FORESTRY RESOURCES
SPECIFIC PLAN 3.0 BU ILDOUT PROJECT

CYPRESS, CALIFO RNIA
This section evaluates the potential for implementation of the Specific Plan 3.0 Buildout Project (proposed project) to result in impacts to agriculture and forestry resources. This section also describes the existing setting for agriculture and forestry resources within and near the Buildout Area and sets forth the relevant regulatory requirements that apply to the proposed project's potential impacts on agriculture and forestry resources.

4.2.1 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). None of the comment letters included comments related to agriculture and forestry resources.

4.2.2 Methodology
This section is based, in part, on information provided by the California Department of Conservation (DOC) Farmland Mapping and Monitoring Program (FMMP), the United States Department of Agriculture (USDA), and the Natural Resources Conservation Service (NRCS), as well as applicable provisions of the City of Cypress' General Plan and the County of Orange's (County) General Plan.

Impacts to agriculture and forestry resources were assessed based on documents and maps from the DOC, the County Agricultural Commissioner's Office, and the City's General Plan. Impacts to forestry resources were considered based on the proposed project's potential to convert or accelerate deterioration of forestry resources.

This information was used in this section of the Draft EIR to assess potential impacts to agriculture and forestry resources within the Buildout Area. Impacts that could result from implementation of the proposed project were evaluated qualitatively based on existing conditions in the Buildout Area, 1 expected construction practices, and operational activities.

4.2.3 Existing Environmental Setting
The Buildout Area is predominantly characterized by urban development and urban built-out land.

The Buildout Area is surrounded by West Cerritos Avenue to the north; Grace Church and commercial uses to the east; Cypress Corporate Park, Cottonwood Church, the Square at Cypress, the Belmont residential project, the Ovation at Flora Park, a commercial center, a 24 Hour Fitness, a Marriott Hotel, commercial and retail services including a Costco Warehouse and restaurants, and Katella Avenue to the south; and Lexington Park and Lexington Drive to the west.

The Buildout Area is not used for agricultural production and is not designated Prime Farmland, Unique Farmland, or Farmland of Statewide Importance on maps prepared as part of the DOC FMMP. As of 2020, the entire Buildout Area and surrounding area was designated as "Urban and As described in Chapter 3.0 of this Draft EIR, the baseline condition generally consists of the existing conditions in and in the vicinity of the Buildout Area at the time the NOP was published (April 4, 2022).

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Built-Up Land." 2 The nearest Prime Farmland is located approximately 2.5 miles southwest of the site, south of Interstate 405 and adjacent to the Seal Beach National Wildlife Refuge. There are no parcels within the Buildout Area that are currently under a Williamson Act contract.

4.2.3.1 Forestry Resources
As discussed above, the Buildout Area is predominantly characterized by urban built-out land and is currently developed and highly disturbed. Specifically, under existing conditions, the Buildout Area is occupied by the Los Alamitos Race Course (LARC) and Grace Church and does not contain any forest land.

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

4.2.4.1 Federal Regulations
No federal plans, policies, regulations, or laws related to agriculture and forestry resources are applicable to the Buildout Area because the Buildout Area is privately owned and does not include any lands owned by the federal government or require federal approvals related to agriculture and forestry resources.

4.2.4.2 State Regulations
California Department of Conservation Farmland Mapping and Monitoring Program. Pursuant to California Government Code Section 65570, the DOC FMMP compiles consistent, timely, and accurate data to decision-makers for use in planning for the present and future of California's agricultural land resources. The FMMP provides maps and statistical data to the public, academia, and local, State, and federal governments on the nature, location, and extent of farmland, grazing land, and urban built-up areas in the State to assist in making informed decisions for the best utilization of California's farmland. Government Code Section 65570 mandates the FMMP to biennially report to the State Legislature on the conversion of farmland and grazing land and to provide maps and data to local government and the public. The FMMP also was directed to prepare and maintain an automated map and database system to record and report changes in the use of agricultural lands. These maps combine soil survey and current land use information from the USDA and NRCS to provide an inventory of agricultural resources in each county. The maps show urbanized lands and a qualitative sequence of agricultural designations. Pursuant to the FMMP, all lands within California are classified into one of seven map categories. The minimum mapping unit is generally 10 acres, except as otherwise noted.3 Provided below is a description of the various map 2 3
California Department of Conservation (DOC). 2020. California Important Farmland Finder. Website:
https://maps.conservation.ca .gov/DLRP/CIFF/ (accessed January 20, 2025).

California Department of Conservation (DOC). 2004. A Guide to the Farmland Mapping and Monitoring Program. Website: https://www.conservation.ca .gov/ d lrp/fm mp/Docu ments/fmm p/ Arch ive/fmmp _ guide_2004.pdf (accessed February 5, 2025).

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categories established by the FMMP, assessing the importance of agricultural land based on factors such as soil characteristics, climate, and water supply:
• Prime Farmland: The best combination of physical and chemical features and able to sustain long-term agricultural production. This land has the soil quality, growing season, and moisture supply needed to produce sustained high yields. Land must have been used for irrigated agricultural production at some time during the 4 years prior to the mapping date. • Farmland of Statewide Importance: Similar to Prime Farmland but with minor shortcomings, such as steeper slopes or less ability to store soil moisture. Land must have been used for irrigated agricultural production at some time during the 4 years prior to the mapping date. • Unique Farmland: Lesser-quality soils used for the production of the State's leading agricultural crops. This land is usually irrigated but may include unirrigated orchards or vineyards. Land must have been cultivated at some time during the 4 years prior to the mapping date. • Farmland of Local Importance: Land of importance to the local economy, as defined by each county's local advisory committee and adopted by its board of supervisors. This refers to all farmable lands in Orange County that do not meet the definitions of Prime, Statewide, or Unique. This includes land that is or has been used for irrigated pasture, dryland farming, confined livestock and dairy, poultry facilities, aquaculture, and grazing land. • Grazing Land: This type of land is occupied with vegetation suited to grazing livestock. This category was developed in cooperation with the California Cattleman's Association, the University of California Cooperative Extension, and other groups interested in the extent of grazing activities. The minimum mapping unit is 40 acres. • Urban and Built-Up Land: This type of land is occupied by structures with a building density of at least one unit to 1.5 acres, or approximately six structures to a 10-acre parcel. Common examples of land uses include residential, industrial, commercial, institutional facilities, public administrative purposes, railroad and transportation yards, cemeteries, airports, golf courses, sanitary landfills, sewage treatment, and water control structures, and other developed purposes.
• Other Land: This type of land is not included in any other mapping category. Common examples include low-density rural developments; brush; timber wetland; riparian area not suitable for livestock grazing; confined livestock, poultry, or aquaculture facilities; strip mines; and water bodies smaller than 40 acres. Vacant and non-agricultural land surrounded on all sides by urban development that is greater than 40 acres is mapped as Other Land.

Williamson Act and Farmland Security Act. The California Land Conservation Act of 1965 (CLCA), better known as the Williamson Act (Government Code Section 51200 et seq.), enables local governments to enter into contracts with private landowners for the purpose of restricting specific parcels of land to agricultural or related open space use. In return, landowners receive property tax assessments that are much lower than normal because they are based on farming and open space uses as opposed to full market value. Pursuant to Government Code Section 51230, counties and P:\A-E\CCP2201.0S LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.2 Agriculture and Forestry Resources.docx «03/10/26» 4.2-3 SPECIFIC PLAN 3.0 BUI LOO UT PROJECT

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cities may establish Agricultural Preserves, which define the boundaries of those areas within which the city or county will be willing to enter into contracts pursuant to the CLCA. Contracts pursuant to the CLCA are only allowed for areas within established Agricultural Preserves. Williamson Act contracts have a minimum term of 10 years, with renewal occurring automatically each year, although local governments can establish initial contract terms for longer periods of time. The contracts run with the land and are binding on all successors in the interest of the landowner. Only land located within an Agricultural Preserve is eligible for a Williamson Act contract. An Agricultural Preserve boundary is designated by a resolution of the board of supervisors or city council having jurisdiction. The rules of each Agricultural Preserve specify the uses allowed. Land uses within an Agricultural Preserve must be agricultural in nature or other such uses that are not incompatible with agricultural uses, as identified by the local government, for the duration of the contract.

Agricultural Preserves generally must be at least 100 acres in size; however, a city or county may allow for lesser acreage if a finding is made that the characteristics of the agricultural enterprises in the area are unique and that the establishment of preserves of less than 100 acres is consistent with the general plan of the county or city.

In return for entering into a contract, the landowner is granted preferential taxes that are based on agricultural and related land uses rather than fair market value. Contracts may be canceled at the option of the landowner or local government by initiating the process of term non-renewal. Under this process, the remaining contract term (9 years in the case of an original term of 10 years) is allowed to lapse, with the contract null and void at the end of the term. During the non-renewal process, the annual tax assessment continually increases each year until it is equivalent to current tax rates at the end of the non-renewal period. Under a set of specifically defined circumstances, a contract may be cancelled without completing the process of term non-renewal. Contract cancellation, however, involves a comprehensive review and approval process and the payment of a fee by the landowner.

In August 1998, Senate Bill (SB) 1182 established the Farmland Security Zone (FSZ) provisions of the Williamson Act. An FSZ is created within an Agricultural Preserve by approval of the county board of supervisors and at the request of a landowner or group of landowners. FSZ contracts offer landowners greater property tax reductions in return for an initial contract term of 20 years, with renewal occurring automatically each year. Land restricted by an FSZ contract is valued for property assessment purposes at 65 percent of its Williamson Act valuation, or 65 percent of its Proposition 13 valuation, whichever is lower. New special taxes for urban-related services must be levied at an unspecified reduced rate unless the tax directly benefits the land or living improvements. Cities and special districts that provide non-agricultural services are generally prohibited from annexing land enrolled under an FSZ contract. Similarly, school districts are prohibited from using FSZ lands for school facilities.

Z'Berg-Nejedly Forest Practice Act. The Z'Berg-Nejedly Forest Practice Act (Forest Practice Act) identifies operating methods and procedures that seek to protect fish, wildlife, forests, and streams within timber harvesting areas. The Forest Practice Act is intended to achieve "maximum sustained production of high-quality timber products ... while giving consideration to values relating to recreation, watershed, wildlife, range and forage, fisheries, regional economic vitality, employment

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and aesthetic enjoyment." 4 The regulations created by the Forest Practice Act define factors such as the size and location of harvest areas, include measures to prevent unreasonable damage to residual trees, and address the protection of riparian areas, watercourses and lakes, wildlife, and habitat areas.

Z'Berg-Warren-Keene-Collier Forest Taxation Reform Act. According to the Z'Berg-Warren-KeeneCollier Forest Taxation Reform Act 5 enacted in 1976, counties must provide for the zoning of land used for growing and harvesting timber as Timberland Production Zones (TPZs). TPZs were established to preserve and protect timberland from conversion to other uses and avoid land use conflicts.

Timberland Productivity Act. The Timberland Productivity Act represents the Legislature's declared intent "to fully realize the productive potential of the forest resources and timberlands of the state." The act imposes mandatory restrictions on parcels zoned as timberland production. Such parcels "shall be zoned so as to restrict their use to growing and harvesting timber and to compatible uses." 6 In exchange, property owners are required to pay property taxes on the land based solely on its value for timber harvest and not for its development potential, as is the case with qualifying agricultural and open space lands under the Williamson Act. Government Code Section 51104(g) of the Timberland Productivity Act defines "timberland production zone" as an area which has been zoned pursuant to Section 51112 or 51113 and is devoted to and used for growing and harvesting timber, or for growing and harvesting timber and compatible uses. Compatible uses are defined under Section 51104(h) and include management for watersheds; management for habitat or hunting and fishing; access roads and staging areas for timber harvesting; gas, electric, water, or communication transmission facilities; grazing; or a residence or other structure necessary for timber management.

California Government Code Section 21095 - California Agricultural Land Evaluation and Site Assessment Model. Land Evaluation and Site Assessment (LESA) is a term used to define an approach for rating the relative quality of agricultural land based upon specific measurable features.The formulation of a California LESA Model is the result of Senate Bill 850 (Chapter 812/1993), which charges the Resource Agency (in consultation with the Governor's Office of Planning and Research) with developing an amendment to Appendix G of the State CEQA Guidelines concerning agricultural lands. Such an amendment is intended "to provide lead agencies with an optional methodology to ensure that significant effects on the environment of agricultural land conversions are quantitatively and consistently considered in the environmental review process" (Public Resources Code Section 21095).

A LESA analysis is based on the following definition of agricultural land contained in CEQA, Public Resources Code Section 21060.1:
4 5
6 Public Resources Codes Section 4513[b] .

Government Code Sections 51110-51119.5: Article 2.

Government Code Section 51115.

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21060.1 (a) "Agricultural land" means prime farmland, farmland of statewide importance, or unique farmlands, as defined by the United States Department of Agriculture land inventory and monitoring criteria, as modified for California. 21060.1 (b) In those areas of the state where lands have not been surveyed for the classifications specified in subdivision (a), "agricultural land" means land that meets the requirements of "prime agricultural land" as defined in paragraph (1), (2), (3), or (4) of subdivision (c) of Section 51201 of the Government Code [the Williamson Act].

California Government Code Section 12220(g) - Forest Land. "Forest land" is land that can support 10-percent native tree cover of any species, including hardwoods, under natural conditions, and that allows for management of one or more forest resources, including timber, aesthetics, fish and wildlife, biodiversity, water quality, recreation, and other public benefits.

California Government Code Section 4526 - Timberland. "Timberland" means land, other than land owned by the federal government and land designated by the board as experimental forest land, which is available for, and capable of, growing a crop of trees of a commercial species used to produce lumber and other forest products, including Christmas trees. Commercial species shall be determined by the board on a district basis.

California Government Code Section 51104(g) - Timberland Production Zone. Government Code Section 51104{g) defines "timberland production zone" to mean an area that has been zoned pursuant to Government Code Sections 51112 or 51113 and is devoted to and used for growing and harvesting timber, or for growing and harvesting timber and compatible uses. Compatible uses are defined under Government Code Section 51104{h).

4.2.4.3 Regional Regulations
There are no regional regulations that apply to the proposed project with respect to agriculture and forestry resources.

4.2.4.4 Local Regulations
City of Cypress General Plan. The following provision from the City's General Plan Conservation/ Open Space/Recreation Element7 is related to agriculture and forestry resources. The Cypress Town Center and Commons Specific Plan 3.0 {Specific Plan) does not contain any applicable provisions regarding agriculture or forestry resources.
• Conservation/Open Space/Recreation Element
7 o Policy COSR-2.4: Provide the opportunity to continue using land for agricultural crops as an interim use prior to further development.

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

Website: https://www.cypressca.org/home/showpublisheddocument/686/636123123792970000 (accessed January 21, 2025).

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4.2.5 Thresholds of Significance
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The thresholds of significance for agriculture and forestry 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 agriculture and forestry resources if it would:

Threshold 4.2.1: Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use;
Threshold 4.2.2: Conflict with existing zoning for agricultural use or a Williamson Act contract; Threshold 4.2.3: Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g));
Threshold 4.2.4: Result in the loss of forest land or conversion of forest land to non-forest use; or Threshold 4.2.5: Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland to non-agricultural use or conversion of forest land to non-forest use.

4.2.6 Project Impacts
Potential impacts of the proposed project related to agriculture and forestry resources are discussed below pursuant to the thresholds established in Section 4.2.5, above.

Threshold 4.2.1: Would the project convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance {Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use?
No Impact. Historically, the Buildout Area was used as agricultural land until 1946, when it was developed for cattle and horse ranch uses. The Los Alamitos Race Course was built at its current location in 1954, and the adjacent Cypress Golf Course was constructed in 1961. The Cypress Golf Course was permanently closed in 2004, demolished, and re-graded with all vegetation removed.

From 1952 to the present, the Buildout Area was developed with several uses, including the Cypress Golf Club; Tee Time Res (2001); Cypress Junior Golf League (2003); and Cypress GC LLC, Seventh-Day Adventist Church (2007-present). In addition, Grace Church was developed around 2007, east of the race track and is currently in use.

As shown in Figure 3-2: Aerial Imagery Surrounding Land Uses in Chapter 3.0, Project Description, of this Draft EIR, 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 Buildout Area P:\A-E\CCP2201.0S LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.2 Agriculture and Forestry Resources.docx «03/10/26» 4.2-7 SPECIFIC PLAN 3.0 BUI LOO UT PROJECT

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is not currently used for agricultural production and is not designated Prime Farmland, Unique Farmland, or Farmland of Statewide Importance on maps prepared as part of the Farmland Mapping and Monitoring Program for the California Resources Agency. 8 According to the California Department of Conservation's California Important Farmland Finder, the entire Buildout Area and surrounding area is designated as "Urban and Built-Up Land." The proposed project would not convert farmland to non-agricultural use or result in the conversion of farmland to a non-agricultural use. Therefore, no impact to agricultural resources would occur, and no mitigation is required.

Threshold 4.2.2: Would the project conflict with existing zoning for agricultural use or a Williamson Act contract?
No Impact. As stated previously, the Buildout Area is not used for agricultural production and is not protected by, or eligible for, a Williamson Act contract. The area surrounding the Buildout Area consists of Urban and Built-Up Land, and the Buildout Area itself is non-enrolled land (land not enrolled in a Williamson Act contract and not mapped by the Farmland Mapping and Monitoring Program). 9 There is no agriculturally zoned land nor is there land under a Williamson Act contract in the City.10 Therefore, no impacts to agricultural use or a Williamson Act contract would occur, and no mitigation is required.

Threshold 4.2.3: Would the project conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code Section 12220(g)), timberland (as defined by Public Resources Code Section 4526), or timberland zoned Timberland Production (as defined by Government Code Section 51104(g))? No Impact. All of the land within the Buildout Area is designated as Specific Plan Area by the City's General Plan and Cypress Town Center and Commons (PC) under the City's Zoning Ordinance. As outlined in the Specific Plan, the Buildout Area can be developed with Recreational/Open Space uses, Commercial/Mixed Use uses, and Residential uses. The Buildout Area is not used for timberland production, is not zoned as forest land, timberland, or timberland zoned Timberland Production, and does not contain forest or timberland resources. In addition, there is no forest land or timberland in the vicinity of the Buildout Area. The proposed project would not conflict with any existing zoning for, or cause rezoning of, forest land to non-forest use. Therefore, no impacts to forest land or timberland would occur, and no mitigation is required.

Threshold 4.2.4: Would the project result in the loss of forest land or conversion of forest land to non-forest use?
8 9
California Department of Conservation (DOC). 2022. California Resources Agency. Farmland Mapping and Monitoring Program. Website: https://maps.conservation.ca.gov/dlrp/ciff/ (accessed January 20, 2025).

California Department of Conservation (DOC). 2023. California Resources Agency. California Williamson Act Enrollment Finder. Website: https://maps.conservation.ca .gov/dlrp/WilliamsonAct/ App/index.html (accessed January 20, 2025).
1° City of Cypress. 2025. City of Cypress Zoning Map. August. Website: https://www.cypressca.org/ departments/community-development/zoning-map (accessed January 20, 2025).

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No Impact. Refer to Response 4.2.3 above. The proposed project would not result in the loss of forest land or conversion of forest land to non-forest use. Therefore, no impacts to forest land would occur, and no mitigation is required.

Threshold 4.2.5: Would the project involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland to nonagricultural use or conversion of forest land to non-forest use? No Impact. The Buildout Area is not used for agricultural or timberland production or designated or zoned for agricultural uses or as forest land, timberland, or timberland zoned Timberland Production. In addition, there is no forest land, timberland, or agriculturally zoned land in the vicinity of the Buildout Area. The proposed project would not convert farmland to non-agricultural use or forest land to non-forest use. Likewise, the proposed project would not contribute to environmental changes that could result in the conversion of farmland to non-agricultural use or conversion of forest land to non-forest use. Therefore, no impacts to farmland or forest land would occur, and no mitigation is required.

4.2.7 Level of Significance Prior to Mitigation
The proposed project would not result in any significant impacts related to agriculture and forestry resources, and no mitigation is required.

4.2.8 Regulatory Compliance Measures and Mitigation Measures No mitigation measures or regulatory compliance measures are required.

4.2.9 Level of Significance after Mitigation
The proposed project would not result in any significant impacts related to agriculture and forestry resources.

4.2.10 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 agriculture and forestry. The cumulative impact area for agriculture and forestry is the entire County of Orange, which contains approximately 18,142 acres of land identified as Important Farmland (Prime Farmland, Unique Farmland, and Farmland of Statewide lmportance). 11 However, neither the Buildout Area nor any of the surrounding land uses contain or are zoned for forest land, timberland, timberland production, or agriculture.

Cumulative impacts are addressed only for those thresholds that would result in a project-related impact, whether it be less than significant or less than significant with mitigation. If the project would result in no impact with respect to a particular threshold, by definition, it would not 11 County of Orange. n.d. Orange County General Plan Resources Element. pp.Vl-9. Website: https://ocds. ocpublicworks.com/sites/ocpwocds/files/import/data/files/40235.pdf (accessed February 5, 2025).

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contribute to a cumulative impact. Therefore, the proposed project would have no cumulatively considerable impact on agricultural or forestry resources.

As detailed in this section, the proposed project would have no impact on agriculture and forestry resources. The Buildout Area is characterized by urban land uses. Under existing conditions, the Buildout Area is currently occupied by the LARC, Grace Church, and Cypress GC properties, is zoned Cypress Town Center and Commons (PC) under the City's Zoning Ordinance, and is designated Specific Plan Area by the City's General Plan, allowing for Recreational/Open Space uses, Commercial/Mixed Use uses, and Residential uses.

The proposed project would not result in the conversion of agricultural land to non-agricultural uses.

As of 2023, the County of Orange has no inventory of Williamson Act contract lands. Therefore, there are no Williamson Act contract lands within the Buildout Area. The Buildout Area is not zoned for forest land or timberland, nor is it occupied by forest land resources. As such, implementation of the proposed project would not result in rezoning from forest land or timberland to non-forest land or non-timberland zoning, nor would reduction of forest land resources occur.

Because the proposed project would have no impact on agriculture and forestry resources, it would not contribute to a cumulatively considerable impact on agriculture and forestry resources.

Therefore, there would be no cumulatively significant impact on agriculture and forestry resources, and no mitigation is required.

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4.3 AIR QUALITY
This section evaluates the potential air quality impacts from implementation of the proposed 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) in its California Environmental Quality Act (CEQA) Air Quality Handbook,
1 and associated updates. In keeping with these guidelines, this section describes existing air quality and evaluates short-term impacts during construction, long-term emissions associated with operation, and how potential impacts correlate to human health. Air quality modeling data are included in Appendix B.

4.3.1 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). Two of the comment letters, from the Southern California Association of Governments (SCAG) and SCAQMD, included comments related to air quality.

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 individual development projects, it advised the City to consult the Connect SoCal 2024 Program Environmental Impact Report (PEIR) for guidance on identifying appropriate CEQA mitigation strategies 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.

SCAQMD provided recommendations on how to analyze air quality impacts, greenhouse gas emissions impacts, and health risk reduction strategies for the proposed project. SCAQMD recommends that the City rely on the SCAQMD’s CEQA Air Quality Handbook and use the California Emissions Estimator Model (CalEEMod) to quantify air quality emissions, applying both regional air quality significance thresholds and localized significance thresholds (LSTs). SCAQMD requests that the Draft EIR evaluate all phases of construction and operation, including overlapping activities, indirect sources (e.g., vehicle trips), and identify any new stationary or portable equipment that would require SCAQMD permits, recognizing the agency as a Responsible Agency if applicable.

SCAQMD emphasizes that if significant adverse impacts are identified, all feasible mitigation measures that go beyond existing legal requirements must be implemented, referencing resources such as the 2022 Air Quality Management Plan Mitigation Monitoring and Reporting Plan. SCAQMD further recommends evaluating health risk reduction strategies, such as using enhanced air filtration systems rated MERV-13 (Minimum Efficiency Reporting Value) or better, and requests that the Draft 1 South Coast Air Quality Management District (SCAQMD). 1993. CEQA Air Quality Handbook. Website:
http://www.aqmd.gov/home/rules-compliance/ceqa/air-quality-analysis-handbook/ceqa-air-qualityhandbook-(1993) (accessed October 2025).

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These comments are addressed in this section.

4.3.2 Methodology
This analysis utilized the CalEEMod version 2022.1 to quantify the criteria pollutant emissions for both construction and operation of the proposed project. The maximum daily emissions are calculated for the criteria pollutants. The CalEEMod output is contained in Appendix B of this Draft EIR.

CalEEMod provides a platform to calculate both construction emissions and operational emissions from a project. It calculates both the daily maximum and annual average for criteria pollutants as well as total or annual greenhouse gas (GHG) emissions. The model also provides default values for energy and water use. Specifically, the model performs the following calculations:
• Short-term construction emissions associated with demolition, site preparation, grading, building, paving, and architectural coating (painting) from off-road construction equipment; onroad mobile equipment associated with workers, vendors, delivery, and hauling; fugitive dust associated with grading, demolition, truck loading, and roads; and emissions of volatile organic compounds (VOCs) from architectural coating and paving. • Operational emissions, such as on-road mobile vehicle traffic generated by the land uses, fugitive dust associated with roads, VOCs from architectural coatings, off-road emissions from landscaping equipment, VOCs from consumer products and cleaning supplies, natural gas usage in the buildings, electricity usage in the buildings, water usage by the land uses, and solid waste disposal by the land uses.

As such, this analysis utilized CalEEMod to evaluate construction and operation of the proposed project. This analysis included two model runs to evaluate a worst-case construction scenario. The first model run evaluates full buildout of up to 1,791 additional residential units and 440,000 square feet of non-residential development, consistent with CEQA and SCAQMD guidance. Regional construction emissions were calculated for demolition, site preparation, grading, building construction, paving, and architectural coating activities. Operational emissions, including those from vehicle trips and energy use, were also estimated.

The second model run includes construction emissions only through a phased approach to grading that includes the simultaneous grading of multiple development areas to reflect a conservative worst-case construction scenario. This scenario assumes that grading activities would occur concurrently on five lots—Lots 2, 4, 7, 12, and 13—with full grading of Lots 4, 12, and 13, as well as partial grading of the southern 8 acres of Lot 2 and the northern 11 acres of Lot 7. The purpose of this model run is to capture the potential for overlapping construction schedules and to model the potential worst-case scenario for grading activities. As such, this modeling run focuses solely on grading to represent the most intensive construction activities that would generate peak construction emissions.

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4.3.3 Existing Environmental Setting
The City of Cypress is part of the South Coast Air Basin (Basin) and is under the jurisdiction of SCAQMD. Background information about air pollutants and health effects, climate, meteorological conditions, and regional air quality conditions in the Basin and local air quality conditions in the vicinity of the Buildout Area is provided below.

4.3.3.1 Criteria Air Pollutants and Health Effects
Both State and federal governments have established health-based Ambient Air Quality Standards (AAQS) for the following criteria air pollutants: carbon monoxide (CO), ozone (O3), nitrogen dioxide (NO2), sulfur dioxide (SO2), lead (Pb), and suspended particulate matter (PM). In addition, the State has set standards for sulfates, hydrogen sulfide, vinyl chloride, and visibility-reducing particles.

These standards are designed to protect the health and welfare of the populace with a reasonable margin of safety. Long-term exposure to elevated levels of criteria pollutants may result in adverse health effects. However, emission thresholds established by an air quality district are used to manage total regional emissions within an air basin based on the air basin’s attainment status for criteria pollutants. These emission thresholds were established for individual projects that would contribute to regional emissions and pollutant concentrations and could adversely affect or delay the projected attainment target year for certain criteria pollutants.

At the regional level, the SCAQMD is the regulatory agency responsible for ensuring that State and national AAQS are achieved and maintained for the Air Basin. In developing thresholds of significance for air pollutants, the SCAQMD considered the emission levels for which a project’s individual emissions would be cumulatively considerable. Because of the conservative nature of the criteria pollutant emissions thresholds set by the SCAQMD and the basin-wide context of individual project emissions, there is no known direct correlation between a single project and localized air quality-related health effects. One individual project that generates emissions exceeding a threshold does not necessarily result in adverse public health effects for residents in the project vicinity. This condition is especially true when the criteria pollutants exceeding thresholds are those with regional effects, such as ozone precursors like nitrogen oxides (NOx) and VOCs. As shown in Figure 3-3: Surrounding Land Uses in Chapter 3.0, Project Description, the closest existing sensitive receptors to the Buildout Area include the following: residential uses located north of the Buildout Area across Cerritos Avenue; residential/mixed-use buildings located adjacent to the eastern boundary of the Buildout Area along Katella Avenue; senior housing located adjacent to the southern and western boundaries of the Buildout Area along Katella Avenue; and residential uses located south of the Buildout Area across Katella Avenue.

Occupants of certain types of facilities such as schools, daycare centers, parks and playgrounds, hospitals, and nursing and convalescent homes are considered to be more sensitive than the general 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

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4.3 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.3 Air Quality.docx «03/11/26» -4 public to air pollutants because these population groups have increased susceptibility to respiratory disease. Persons engaged in strenuous work or exercise also have increased sensitivity to poor air quality. Residential areas are considered more sensitive to air quality conditions, compared to commercial and industrial areas, because people generally spend longer periods of time at their residences, with greater associated exposure to ambient air quality conditions. Recreational uses are also considered sensitive compared to commercial and industrial uses due to greater exposure to ambient air quality conditions associated with exercise.

Criteria Pollutants. As identified above, State and federal AAQS have been established for the following criteria pollutants: CO, O3, NO2, SO2, Pb, and PM. These pollutants are regulated due to their potential to cause adverse effects on public health and the environment. In addition, key pollutant constituents—such as VOCs, which contribute to ozone formation—are also evaluated in air quality analyses. The characteristics, primary sources, and health effects of these criteria pollutants and related constituents are described below.

Ozone. Rather than being directly emitted, ozone (smog) is formed by photochemical reactions between NOx and VOCs. Ozone is a pungent, colorless gas. Elevated ozone concentrations result in reduced lung function, particularly during vigorous physical activity. This health problem is particularly acute in sensitive receptors such as the sick, elderly, and young children. Ozone levels peak during the summer and early fall months.

Particulate Matter. Particulate matter is the term used for a mixture of solid particles and liquid droplets found in the air. Coarse particles are those that are 10 microns or less in diameter, or PM10.

Fine, suspended particulate matter with an aerodynamic diameter of 2.5 microns or less, or PM2.5, is not readily filtered out by the lungs. Nitrates, sulfates, dust, and combustion particulates are major components of PM10 and PM2.5. These small particles can be directly emitted into the atmosphere as byproducts of fuel combustion; through abrasion, such as tire or brake lining wear; or through fugitive dust (wind or mechanical erosion of soil). They can also be formed in the atmosphere through chemical reactions. Particulates may transport carcinogens and other toxic compounds that adhere to the particle surfaces and can enter the human body through the lungs.

Carbon Monoxide. CO is formed by the incomplete combustion of fossil fuels, almost entirely from automobiles. It is a colorless, odorless gas that can cause dizziness, fatigue, and impairments to central nervous system functions. CO passes through the lungs into the bloodstream, where it interferes with the transfer of oxygen to body tissues.

Nitrogen Dioxide. NO2 is a reddish-brown gas that is a byproduct of combustion processes.

Automobiles and industrial operations are the main sources of NO2. Aside from its contribution to ozone formation, NO2 also contributes to other pollution problems, including a high concentration of fine particulate matter, poor visibility, and acid deposition. NO2 may be visible as a coloring component on high pollution days, especially in conjunction with high ozone levels. NO2 decreases lung function and may reduce resistance to infection.

Sulfur Dioxide. SO2 is a colorless, irritating gas formed primarily from incomplete combustion of fuels containing sulfur. Industrial facilities also contribute to gaseous SO2 levels in the region. SO2

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P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.3 Air Quality.docx «03/11/26» 4.3-5 irritates the respiratory tract, can injure lung tissue when combined with fine particulate matter, and reduces visibility and the level of sunlight.

Lead. Leaded gasoline (phased out in the United States beginning in 1973), paint (on older houses and cars), smelters (metal refineries), and the manufacture of lead storage batteries have been the primary sources of lead released into the atmosphere. Lead has multiple adverse neurotoxic health effects, and children are at special risk. Some lead-containing chemicals cause cancer in animals.

Lead levels in the air have decreased substantially since leaded gasoline was eliminated. Ambient lead concentrations are only monitored on an as-warranted, site-specific basis in California. On October 15, 2008, the United States Environmental Protection Agency (USEPA) strengthened the national ambient air quality standard for lead by lowering it from 1.5 to 0.15 micrograms per cubic meter (µg/m3). The USEPA revised the monitoring requirements for lead in December 2010. These requirements focus on airports and large urban areas, resulting in an increase in 76 monitors nationally.

Volatile Organic Compounds. VOCs (also known as reactive organic gases [ROGs] and reactive organic compounds [ROCs]) are formed from the combustion of fuels and the evaporation of organic solvents. VOCs are not defined as criteria pollutants, however, because VOCs accumulate in the atmosphere more quickly during the winter, when sunlight is limited and photochemical reactions are slower, they are a prime component of the photochemical smog reaction. There are no attainment designations for VOCs.

4.3.3.2 Toxic Air Contaminants.

In addition to the criteria pollutants discussed above, toxic air contaminants (TACs) are another group of pollutants of concern. TACs are injurious in small quantities and are regulated by the USEPA and California Air Resources Board (CARB). Some examples of TACs include benzene, butadiene, formaldehyde, and hydrogen sulfide. The identification, regulation, and monitoring of TACs is relatively recent compared to that for criteria pollutants.

TACs do not have AAQS, but are regulated by USEPA, CARB, and SCAQMD. In 1998, the CARB identified particulate matter from diesel-fueled engines as a TAC. The CARB has completed a risk management process that identified potential cancer risks for a range of activities using dieselfueled engines.2 High-volume freeways, stationary diesel engines, and facilities attracting heavy and constant diesel vehicle traffic (e.g., distribution centers and truck stops) were identified as posing the highest risk to adjacent receptors. Other facilities associated with increased risk include warehouse distribution centers, large retail or industrial facilities, high-volume transit centers, and schools with a high volume of bus traffic. Health risks from TACs are a function of both concentration and duration of exposure.

Unlike TACs emitted from industrial and other stationary sources noted above, most diesel particulate matter is emitted from mobile sources—primarily “off-road” sources such as 2 California Air Resources Board (CARB). 2000. Stationary Source Division and Mobile Source Control Division. Risk Reduction Plan to Reduce Particulate Matter Emissions from Diesel-Fueled Engines and Vehicles. October.

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4.3 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.3 Air Quality.docx «03/11/26» -6 construction and mining equipment, agricultural equipment, and truck-mounted refrigeration units, as well as “on-road” sources such as trucks and buses traveling on freeways and local roadways.

Although not specifically monitored, recent studies indicate that exposure to diesel particulate matter may contribute significantly to a cancer risk (a risk of approximately 500 to 700 in 1,000,000) that is greater than all other measured TACs combined.3The technology for reducing diesel particulate matter emissions from heavy-duty trucks is well established, and both State and federal agencies are moving aggressively to regulate engines and emission control systems to reduce and remediate diesel emissions. The CARB anticipates that by 2020, average statewide diesel particulate matter concentrations will decrease by 85 percent from levels in 2000 with full implementation of the CARB’s Diesel Risk Reduction Plan,4 meaning that the statewide health risk from diesel particulate matter is expected to decrease from 540 cancer cases in 1,000,000 to 21.5 cancer cases in 1,000,000.

Table 4.3.A: Sources and Health Effects of Air Pollutants summarizes the sources and health effects of air pollutants discussed in this section. Table 4.3.B: Federal and State Ambient Air Quality Standards presents a summary of both California ambient air quality standards (CAAQS), and national ambient air quality standards (NAAQS).

4.3.3.3 Climate/Meteorology
Air quality in the Basin is affected not only by various emission sources (mobile and industry, etc.), but also by atmospheric conditions such as wind speed, wind direction, temperature, and rainfall, etc. The combination of topography, low mixing height, abundant sunshine, and emissions from the second-largest urban area in the United States contributes to air pollution in the Basin.

The Basin is a coastal plain characterized by connecting broad valleys and low hills, delineated by the Pacific Ocean as its southwestern border, and fringed by high mountains that form the inland portion of its border. The region lies in the semi-permanent high-pressure zone of the eastern Pacific Ocean. The resulting climate is mild and tempered by cool ocean breezes. It maintains moderate temperatures and comfortable humidity, and precipitation is typically limited to a few storms during the winter wet season. This weather pattern is fairly predictable. However, periods of extremely hot weather, winter storms, or Santa Ana winds do take place.

Although the Basin has a semi-arid climate, air near the earth’s surface is generally moist due to the presence of a shallow marine layer. With very low average wind speeds, there is a limited ability to disperse air contaminants horizontally. The typical wind flow pattern fluctuates only with occasional winter storms or strong northeasterly Santa Ana winds from the mountains and deserts northeast of the Basin. Summer wind flow patterns represent worst-case conditions for air pollution, as this is a period of higher temperatures and more sunlight, which results in O3 formation. 3 California Air Resources Board (CARB). 2000. Stationary Source Division and Mobile Source Control Division. Risk Reduction Plan to Reduce Particulate Matter Emissions from Diesel-Fueled Engines and Vehicles. October.
4 Ibid.

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P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.3 Air Quality.docx «03/11/26» 4.3-7 Table 4.3.A: Sources and Health Effects of Air Pollutants Pollutants Sources Primary Effects
Carbon Monoxide
(CO)
⚫ Incomplete combustion of fuels
and other carbon-containing
substances, such as motor exhaust
⚫ Natural events, such as
decomposition of organic matter
⚫ Reduced tolerance for exercise
⚫ Impairment of mental function
⚫ Impairment of fetal development
⚫ Aggravation of some heart diseases (angina)
⚫ Death at high levels of exposure
Nitrogen Dioxide
(NO2)
⚫ Motor vehicle exhaust
⚫ High temperature stationary
combustion
⚫ Atmospheric reactions
⚫ Aggravation of respiratory illness
⚫ Reduced visibility
⚫ Reduced plant growth
⚫ Formation of acid rain
Ozone
(O3)
⚫ Atmospheric reaction of organic
gases with nitrogen oxides in
sunlight
⚫ Aggravation of respiratory and cardiovascular
diseases
⚫ Irritation of eyes
⚫ Impairment of cardiopulmonary function
⚫ Plant leaf injury
Lead
(Pb)
⚫ Contaminated soil ⚫ Impairment of blood functions and nerve construction
⚫ Behavioral and hearing problems in children
Suspended
Particulate Matter
(PM2.5 and PM10)
⚫ Stationary combustion of solid
fuels
⚫ Construction activities
⚫ Industrial processes
⚫ Atmospheric chemical reactions
⚫ Reduced lung function
⚫ Aggravation of the effects of gaseous pollutants
⚫ Aggravation of respiratory and cardiorespiratory
diseases
⚫ Increased cough and chest discomfort
⚫ Soiling
⚫ Reduced visibility
Sulfur Dioxide
(SO2)
⚫ Combustion of sulfur-containing
fossil fuels
⚫ Smelting of sulfur-bearing metal
ores Industrial processes
⚫ Aggravation of respiratory diseases (asthma,
emphysema)
⚫ Reduced lung function
⚫ Irritation of eyes
⚫ Reduced visibility
⚫ Plant injury
⚫ Deterioration of metals, textiles, leather, finishes, and coatings, etc.

Source: California Air Resources Board (CARB). Common Air Pollutants (2025a) (Website: https://ww2.arb.ca.gov/resources/commonair-pollutants (accessed October 2025).

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4.3 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.3 Air Quality.docx «03/11/26» -8 Table 4.3.B: Federal and State Ambient Air Quality Standards Pollutant Averaging
Time
California Standards 1 Federal Standards 2
Concentration 3 Method 4 Primary 3,4 Secondary 3,6 Method 7 Ozone
(O3)
8 1-Hour 0.09 ppm
(180 μg/m3) Ultraviolet
Photometry
– Same as
Primary
Standard
Ultraviolet
Photometry 8-Hour 0.07 ppm
(137 μg/m3)

0.070 ppm
(137 μg/m3)
Respirable
Particulate
Matter
(PM10)
9 24-Hour 50 μg/m3
Gravimetric or Beta
Attenuation
150 μg/m3
Same as
Primary
Standard
Inertial
Separation and
Gravimetric
Analysis
Annual
Arithmetic
Mean
20 μg/m3 –
Fine
Particulate
Matter
(PM2.5)
9 24-Hour – 35 μg/m3
Same as
Primary
Standard
Inertial
Separation and
Gravimetric
Analysis
Annual
Arithmetic
Mean
12 μg/m3 Gravimetric or Beta
Attenuation 9.0 μg/m3 o 15.0 μg/m3 o
Carbon
Monoxide
(CO)
1-Hour 20 ppm
(23 mg/m3) Non-Dispersive
Infrared
Photometry
(NDIR)
35 ppm
(40 mg/m3)
–
Non-Dispersive
Infrared
Photometry
(NDIR)
8-Hour 9 ppm
(10 mg/m3)
9 ppm
(10 mg/m3)
8-Hour
(Lake Tahoe)
6 ppm
(7 mg/m3)
– –
Nitrogen
Dioxide
(NO2)
10 1-Hour 0.18 ppm
(339 μg/m3)
Gas Phase
Chemi-luminescence
100 ppb
(188 μg/m3)
–
Gas Phase
Chemiluminescence
Annual
Arithmetic
Mean

0.03 ppm
(57 μg/m3)
53 ppb
(100 μg/m3)
Same as
Primary
Standard
Sulfur
Dioxide
(SO2)
11 1-Hour 0.25 ppm
(655 μg/m3)
Ultraviolet
Fluorescence
75 ppb
(196 μg/m3)
k –
Ultraviolet
Fluorescence;
Spectrophotometry
(Pararosaniline
Method)
3-Hour – –

0.5 ppm
(1300 μg/m3)
24-Hour 0.04 ppm
(105 μg/m3)

0.14 ppm
(for certain
areas)
–
Annual
Arithmetic
Mean
–

0.030 ppm
(for certain
areas)k
–
Lead
(Pb)12,13
30-Day
Average 1.5 μg/m3
Atomic
Absorption
– –
High-Volume
Sampler and
Atomic
Absorption
Calendar
Quarter –

1.5 μg/m3
(for certain
areas)l Same as
Primary
Standard Rolling 3-
Month
Average
– 0.15 μg/m3
VisibilityReducing
Particles 14
8-Hour See footnote 14
Beta Attenuation
and Transmittance
through Filter Tape
No
Federal
Standards
Sulfates 24-Hour 25 μg/m3Ion Chromatography
Hydrogen
Sulfide 1-Hour 0.03 ppm (42 μg/m3)
Ultraviolet
Fluorescence
Vinyl
Chloride 12 24-Hour 0.01 ppm (26 μg/m3)
Gas
Chromatography
Source: Ambient Air Quality Standards (California Air Resources Board 2024).

Table notes continued on the following page.

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P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.3 Air Quality.docx «03/11/26» 4.3-9 1 California standards for ozone, carbon monoxide (except 8-hour Lake Tahoe), sulfur dioxide (1- and 24-hour), nitrogen dioxide, and particulate matter (PM10, PM2.5, and visibility reducing particles), are values that are not to be exceeded. All others are not to be equaled or exceeded. California ambient air quality standards are listed in the Table of Standards in Section 70200 of Title 17 of the California Code of Regulations.
2 National standards (other than ozone, particulate matter, and those based on annual arithmetic mean) are not to be exceeded more than once a year. The ozone standard is attained when the fourth highest 8-hour concentration measured at each site in a year, averaged over three years, is equal to or less than the standard. For PM10, the 24-hour standard is attained when the expected number of days per calendar year with a 24-hour average concentration above 150 μg/m3is equal to or less than one. For PM2.5, the 24-hour standard is attained when 98 percent of the daily concentrations, averaged over three years, are equal to or less than the standard.

Contact USEPA for further clarification and current national policies. 3 Concentration expressed first in units in which it was promulgated. Equivalent units given in parentheses are based upon a reference temperature of 25°C and a reference pressure of 760 torr. Most measurements of air quality are to be corrected to a reference temperature of 25°C and a reference pressure of 760 torr; ppm in this table refers to ppm by volume, or micromoles of pollutant per mole of gas.
4 Any equivalent measurement method which can be shown to the satisfaction of the CARB to give equivalent results at or near the level of the air quality standard may be used.
5 National Primary Standards: The levels of air quality necessary, with an adequate margin of safety to protect the public health. 6 National Secondary Standards: The levels of air quality necessary to protect the public welfare from any known or anticipated adverse effects of a pollutant.
7 Reference method as described by the USEPA. An “equivalent method” of measurement may be used but must have a “consistent relationship to the reference method” and must be approved by the USEPA. 8 On October 1, 2015, the national 8-hour ozone primary and secondary standards were lowered from 0.075 to 0.070 ppm. 9 On February 7, 2024, the national annual PM2.5 standard was lowered from 12.0 μg/m3 to 9.0 μg/m3. The existing national 24-hour
PM2.5 standards (primary and secondary) were retained at 35 μg/m3, as was the annual secondary standard of 15 μg/m3. The existing 24-hour PM10 standards (primary and secondary) of 150 μg/m3also were retained. The form of the annual primary and secondary standards is the annual mean, averaged over 3 years.
10 To attain the 1-hour national standard, the three-year average of the annual 98th percentile of the 1-hour daily maximum concentrations at each site must not exceed 100 ppb. Note that the national 1-hour standard is in units of parts per billion (ppb).

California standards are in units of parts per million (ppm). To directly compare the national 1-hour standard to the California standards the units can be converted from ppb to ppm. In this case, the national standard of 100 ppb is identical to 0.100 ppm. 11 On June 2, 2010, a new 1-hour SO2 standard was established and the existing 24-hour and annual primary standards were revoked. To attain the 1-hour national standard, the three-year average of the annual 99th percentile of the 1-hour daily maximum concentrations at each site must not exceed 75 ppb. The 1971 SO2 national standards (24-hour and annual) remain in effect until one year after an area is designated for the 2010 standard, except that in areas designated nonattainment for the 1971 standards, the 1971 standards remain in effect until implementation plans to attain or maintain the 2010 standards are approved.

Note that the 1-hour national standard is in units of parts per billion (ppb). California standards are in units of parts per million (ppm).

To directly compare the 1-hour national standard to the California standard the units can be converted to ppm. In this case, the national standard of 75 ppb is identical to 0.075 ppm.
12 The CARB has identified lead and vinyl chloride as ‘toxic air contaminants’ with no threshold level of exposure for adverse health effects determined. These actions allow for the implementation of control measures at levels below the ambient concentrations specified for these pollutants.
13 The national standard for lead was revised on October 15, 2008, to a rolling 3-month average. The 1978 lead standard (1.5 μg/m3 as a
quarterly average) remains in effect until one year after an area is designated for the 2008 standard, except that in areas designated nonattainment for the 1978 standard, the 1978 standard remains in effect until implementation plans to attain or maintain the 2008 standard are approved.
14 In 1989, the CARB converted both the general Statewide 10-mile visibility standard and the Lake Tahoe 30-mile visibility standard to instrumental equivalents, which are “extinction of 0.23 per kilometer” and “extinction of 0.07 per kilometer” for the Statewide and Lake Tahoe Air Basin standards, respectively.
°C = degrees Celsius
µg/m3= micrograms per cubic meter
CARB = California Air Resources Board
mg/m3= milligrams per cubic meter
ppb = parts per billion
ppm = parts per million
USEPA = United States Environmental Protection Agency
Air pollutant emissions within the Basin are generated primarily by stationary and mobile sources.

Stationary sources can be divided into two major subcategories: point and area sources. Point sources occur at a specific location and are often identified by an exhaust vent or stack. Examples 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

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4.3 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.3 Air Quality.docx «03/11/26» -10 include boilers or combustion equipment that produce electricity or generate heat. Area sources are widely distributed and include such sources as residential and commercial water heaters, painting operations, lawnmowers, agricultural fields, landfills, and some consumer products. Mobile sources refer to emissions from motor vehicles, including tailpipe and evaporative emissions, and are classified as either on-road or off-road. On-road sources may be legally operated on roadways and highways. Off-road sources include aircraft, ships, trains, and self-propelled construction equipment.

Air pollutants can also be generated by the natural environment, such as when high winds suspend fine dust particles.

4.3.3.4 Attainment Status
The CARB is required to designate areas of the State as attainment, nonattainment, or unclassified for all State standards. An attainment designation for an area signifies that pollutant concentrations did not violate the standard for that pollutant in that area. A nonattainment designation indicates that a pollutant concentration violated the standard at least once, excluding those occasions when a violation was caused by an exceptional event, as defined in the criteria. An unclassified designation signifies that data does not support either an attainment or nonattainment status. The California Clean Air Act (CCAA) divides districts into moderate, serious, and severe air pollution categories, with increasingly stringent control requirements mandated for each category.

The USEPA designates areas for O3, CO, and NO2 as either: does not meet the primary standards (or cannot be classified), or better than national standards. For SO2, areas are designated as: does not meet the primary standards, does not meet the secondary standards, cannot be classified, or better than national standards.

Table 4.3.C: Attainment Status of Criteria Pollutants in the South Coast Air Basin provides a summary of the attainment status for the Basin with respect to the NAAQS and the CAAQS.

Table 4.3.C: Attainment Status of Criteria Pollutants in the South Coast Air Basin Pollutant State Federal
O3 1 hour Nonattainment Extreme Nonattainment
O3 8 hour Nonattainment Extreme Nonattainment
PM10 Nonattainment Attainment/Maintenance
PM2.5 Nonattainment Serious Nonattainment
CO Attainment Attainment/Maintenance
NO2 Attainment Attainment/Maintenance
SO2 N/A Attainment/Unclassified
Lead Attainment Attainment1
All others Attainment/Unclassified Attainment/Unclassified Source: National Ambient Air Quality Standards (NAAQS) and California Ambient Air Quality Standards (CAAQS) Attainment Status for South Coast Air Basin (SCAQMD 2018) (Website: http://www.aqmd.gov/docs/default-source/clean-air-plans/air-quality-managementplans/naaqs-caaqs-feb2016.pdf; accessed October 2025). 1 Except in Los Angeles County.

CARB = California Air Resources Board
CO = carbon monoxide
N/A = not applicable
NO2 = nitrogen dioxide
O3 = ozone
PM10 = particulate matter less than 10 microns in size
PM2.5 = particulate matter less than 2.5 microns in size SCAQMD = South Coast Air Quality Management District
SO2 = sulfur dioxide

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4.3.3.5 Regional Air Quality
The Southern California region lies in the semi-permanent high-pressure zone of the eastern Pacific.

As a result, the climate is mild and tempered by cool sea breezes. The usually mild climate is interrupted infrequently by periods of extremely hot weather, winter storms, or Santa Ana winds.

Meteorological conditions and topography affect the dispersion of pollutants and make the Basin susceptible to air pollution. The extent and severity of the air pollution problem in the Basin is also affected by manmade influences, such as development patterns and lifestyle.

The greatest air pollution impacts throughout the Basin occur from June through September. This condition is generally attributed to the high emissions, as well as light winds and shallow vertical atmospheric mixing, which reduce dispersion. Pollutant concentrations in the Basin vary with location, season, and time of day. O3 concentrations, for example, tend to be higher in the inland valleys than either along the coast or in the far inland areas of the Basin and adjacent desert. Over the past 30 years, substantial progress has been made in reducing air pollution levels in Southern California. However, the Basin still fails to meet federal standards for O3 and PM2.5.

4.3.3.6 Local Air Quality
Air quality monitoring stations are located throughout the nation and are maintained by the local air pollution control district and State air quality regulating agencies. The SCAQMD, together with the CARB, maintains ambient air quality monitoring stations in the Basin. The air quality monitoring station closest to the Buildout Area is the 1630 W. Pampas Lane ambient air quality monitoring station in Anaheim. The air quality trends from this station are used to represent the ambient air quality in the vicinity of the Buildout Area. Ambient air quality data in the vicinity of the Buildout Area from 2022 to 2024 are shown in Table 4.3.D: Ambient Air Quality at the Anaheim 1630 W.

Pampas Lane Monitoring Station. SO2 is not monitored in Orange County.

Pollutant monitoring results for the years 2022 to 2024 at the Anaheim 1630 W. Pampas Lane ambient air quality monitoring station indicate that air quality in the project vicinity has generally been good. As indicated in the monitoring results, no violations of the federal PM10 standard occurred during the 3-year period. The State PM10 standard was exceeded five times in 2017, twice in 2018, and four times in 2019. PM2.5 levels exceeded the federal standard once in 2022 and 2023 and an unknown number of times in 2024. In addition, the federal PM10 standard was exceeded once in 2023 and five times in 2024. The State 1-hour ozone standard was exceeded once in 2022 and three times in 2024. In addition, the State and federal 8-hour ozone standards were each exceeded once in 2022, twice in 2023, and three times in 2024. The CO, SO2, and NO2 standards were also not exceeded in this area during the 3-year period.

4.3.4 Regulatory Setting
The USEPA and the CARB regulate direct emissions from motor vehicles. The SCAQMD is the regional agency primarily responsible for regulating air pollution emissions from stationary sources (e.g., factories) and indirect sources (e.g., traffic associated with new development), as well as monitoring ambient pollutant concentrations.

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Pollutant Standard 2022 2023 2024
Carbon Monoxide (CO)
Maximum 1-hour concentration (ppm) 2.4 2.2 2.8
Number of days exceeded: State: > 20 ppm 0 0 0
Federal: > 35 ppm 0 0 0
Maximum 8-hour concentration (ppm) 1.4 1.6 2.4
Number of days exceeded: State: > 9 ppm 0 0 0
Federal: > 9 ppm 0 0 0
Ozone (O3)
Maximum 1-hour concentration (ppm) 0.102 0.089 0.104
Number of days exceeded: State: > 0.09 ppm 1 0 3
Maximum 8-hour concentration (ppm) 0.077 0.077 0.079
Number of days exceeded: State: > 0.07 ppm 1 2 3
Federal: > 0.08 ppm 1 2 3
Coarse Particulates (PM10)
Maximum 24-hour concentration (µg/m3) 67.0 99.4 118.9
Number of days exceeded: State: > 50 µg/m3 1 1 ND
Federal: > 150 µg/m3 0 0 0
Annual arithmetic average concentration (µg/m3) 20.9 20.6 27.7 Exceeded for the year: State: > 20 µg/m3 Yes Yes Yes
Federal: > 50 µg/m3 No No No
Fine Particulates (PM2.5)
Maximum 24-hour concentration (µg/m3) 33.1 50.7 49.7
Number of days exceeded: Federal: > 35 µg/m3 0 1 5
Annual arithmetic average concentration (µg/m3) 9.9 9.1 10.5 Exceeded for the year: State: > 12 µg/m3 No No No
Federal: > 12 µg/m3 No No No
Nitrogen Dioxide (NO2)
Maximum 1-hour concentration (ppm) 0.053 0.051 0.053
Number of days exceeded: State: > 0.250 ppm 0 0 0
Annual arithmetic average concentration (ppm) 0.012 0.010 0.011 Exceeded for the year: Federal: > 0.053 ppm No No No
Sulfur Dioxide (SO2)
Maximum 1-hour concentration (ppm) ND ND ND
Number of days exceeded: State: > 0.25 ppm ND ND ND
Maximum 24-hour concentration (ppm) ND ND ND
Number of days exceeded: State: > 0.04 ppm ND ND ND
Federal: > 0.14 ppm ND ND ND
Annual arithmetic average concentration (ppm) ND ND ND
Exceeded for the year: Federal: > 0.030 ppm ND ND ND
Sources: Top Four (CARB 2025b) (Website: https://www.arb.ca.gov/adam/topfour/topfour1.php; accessed October 2025); Outdoor Air Quality Data, Monitor Values Report (USEPA 2025) (Website: https://www.epa.gov/outdoor-air-quality-data/monitor-valuesreport; accessed October 2025). µg/m3 = micrograms per cubic meter
CARB = California Air Resources Board
ND = No data. There was insufficient (or no) data to determine the value. ppm = parts per million
USEPA = United States Environmental Protection Agency
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P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.3 Air Quality.docx «03/11/26» 4.3-13 The following section describes the federal, State, regional, and local regulatory framework applicable to analyzing potential impacts related to air quality from development of the proposed project.

4.3.4.1 Federal Regulations
At the federal level, the USEPA has been charged with implementing national air quality programs.

The USEPA’s air quality mandates are drawn primarily from the Federal Clean Air Act (FCAA), discussed below.

Federal Clean Air Act. The FCAA was enacted in 1963 and was amended in 1970, 1977, and 1990.

The FCAA required the USEPA to establish primary and secondary NAAQS and required each state to prepare an air quality control plan referred to as a State Implementation Plan (SIP). The FCAA Amendments of 1990 added requirements for states with nonattainment areas to revise their SIPs to incorporate additional control measures to reduce air pollution. The SIP is periodically modified to reflect the latest emission inventories, planning documents, and rules and regulations of the air basins as reported by their jurisdictional agencies. The USEPA has responsibility to review all state SIPs to determine conformity with the mandates of the FCAA and determine if implementation will achieve air quality goals. If the USEPA determines a SIP to be inadequate, a Federal Implementation Plan may be prepared for the nonattainment area, which imposes additional control measures.

Failure to submit an approvable SIP or to implement the plan within the mandated timeframe may result in sanctions on transportation funding and stationary air pollution sources in the air basin.

The USEPA is also required to develop National Emission Standards for Hazardous Air Pollutants, which are defined as those that may reasonably be anticipated to result in increased deaths or serious illness, and that are not already regulated. An independent science advisory board reviews the health and exposure analyses conducted by the USEPA on suspected hazardous pollutants prior to regulatory development.

4.3.4.2 State Regulations
The CARB is the agency responsible for the coordination and oversight of State and local air pollution control programs in California and for implementing the CCAA, as discussed below.

California Clean Air Act. In 1988, the CCAA required that all air quality districts in the State endeavor to achieve and maintain CAAQS for CO, O3, SO2, and NO2 by the earliest practical date. The CCAA provides districts with authority to regulate indirect sources and mandates that air quality districts focus particular attention on reducing emissions from transportation and area-wide emission sources. Each nonattainment district is required to adopt a plan to achieve a 5 percent annual reduction, averaged over consecutive 3-year periods, in district-wide emissions of each nonattainment pollutant or its precursors. A Clean Air Plan shows how a district would reduce emissions to achieve air quality standards. Generally, the State standards for these pollutants are more stringent than the national standards.

California Air Resources Board. The CARB is the State’s clean air agency. The CARB’s goals are to attain and maintain healthy air quality, protect the public from exposure to TACs, and oversee compliance with air pollution rules and regulations.

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4.3 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.3 Air Quality.docx «03/11/26» -14 Assembly Bill 2588 Air Toxics “Hot Spots” Information and Assessment Act. Under Assembly Bill (AB) 2588, stationary sources of air pollutants are required to report the types and quantities of certain substances that their facilities routinely released into the air. The goals of the Air Toxics “Hot Spots” Act are to collect emission data, identify facilities having localized impacts, determine health risks, and notify nearby residents of significant risks.

The California Air Resources Board Handbook. The CARB has developed an Air Quality and Land Use Handbook5(CARB Handbook), which is intended to serve as a general reference guide for evaluating and reducing air pollution impacts associated with new projects that go through the land use decision-making process. According to the CARB Handbook, air pollution studies have shown an association between respiratory and other non-cancer health effects and proximity to high traffic roadways. Other studies have shown that diesel exhaust and other cancer-causing chemicals emitted from cars and trucks are responsible for much of the overall cancer risk from airborne toxics in California. The CARB Handbook recommends that county and city planning agencies strongly consider proximity to these sources when finding new locations for sensitive land uses such as homes, medical facilities, daycare centers, schools, and playgrounds.

Land use designations with air pollution sources of concern include freeways, rail yards, ports, refineries, distribution centers, chrome plating facilities, dry cleaners, and large gasoline service stations. Key recommendations in the CARB Handbook include taking steps to avoid siting new, sensitive land uses:
• Within 500 feet of a freeway, urban roads with 100,000 vehicles/day, or rural roads with 50,000 vehicles/day;
• Within 1,000 feet of a major service and maintenance rail yard; • Immediately downwind of ports (in the most heavily impacted zones) and petroleum refineries; • Within 300 feet of any dry cleaning operation (for operations with two or more machines, provide 500 feet); and
• Within 300 feet of a large gas station (defined as a facility with a throughput of 3.6 million gallons per year or greater).

The CARB Handbook specifically states that its recommendations are advisory and acknowledges land use agencies have to balance other considerations, including housing and transportation needs, economic development priorities, and other quality of life issues.

The recommendations are generalized and do not consider site-specific meteorology, freeway truck percentages, or other factors that influence risk for a particular project site. The purpose of this guidance is to further examine project sites for actual health risk associated with the location of new sensitive land uses.
5 California Air Resources Board (CARB). 2005. Air Quality and Land Use Handbook: A Community Health Perspective (CARB Handbook). April.

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4.3.4.3 Regional Regulations
South Coast Air Quality Management District. The SCAQMD has jurisdiction over most air quality matters in the Basin. This area includes all of Orange County, Los Angeles County except for the Antelope Valley, the non-desert portion of western San Bernardino County, and the western and Coachella Valley portions of Riverside County. The SCAQMD is the agency principally responsible for comprehensive air pollution control in the Basin and is tasked with implementing certain programs and regulations required by the Clean Air Act (CAA) and the CCAA. The SCAQMD prepares plans to attain CAAQS and NAAQS. SCAQMD is directly responsible for reducing emissions from stationary (area and point) sources. The SCAQMD develops rules and regulations, establishes permitting requirements, inspects emissions sources, and enforces such measures though educational programs or fines, when necessary.
• Regulation IV - Prohibitions: This regulation sets forth the restrictions for visible emissions, odor nuisance, fugitive dust, various air pollutant emissions, fuel contaminants, start-up/shutdown exemptions, and breakdown events.
○ Rule 402 - Nuisance: This rule restricts the discharge of any contaminant in quantities that cause or have a natural ability to cause injury, damage, nuisance, or annoyance to businesses, property, or the public. Future development projects that are implemented in the Buildout Area will be required to comply with Rule 402. ○ Rule 403 - Fugitive Dust: This rule requires the prevention, reduction, or mitigation fugitive dust emissions from a project site. Rule 403 restricts visible fugitive dust to a project property line, restricts the net PM10 emissions to less than 50 micrograms per cubic meter (µg/m3) and restricts the tracking out of bulk materials onto public roads.

Additionally, Rule 403 requires a future project applicant for a development project in the Buildout Area to use one or more of the best available control measures (identified in the tables within the rule). Control measures may include adding freeboard to haul vehicles, covering loose material on haul vehicles, watering, using chemical stabilizers, and/or ceasing all activities. Finally, Rule 403 requires that a contingency plan be prepared if so determined by the USEPA. In addition, SCAQMD Rule 403(e), Additional Requirements for Large Operations, includes requirements to provide Large Operation Notification Form 403 N, appropriate signage, additional dust control measures, and employment of a dust control supervisor that has successfully completed the Dust Control training class in the South Coast Air Basin. Future development projects that are implemented in the Buildout Area will be required to comply with Rule 403. • Regulation XI - Source Specific Standards: Regulation XI sets emissions standards for different sources.
○ Rule 1113 - Architectural Coatings: This rule limits the amount of VOCs from architectural coatings and solvents, which lowers the emissions of odorous compounds. Future development projects that are implemented in the Buildout Area will be required to comply with Rule 1113.

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4.3 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.3 Air Quality.docx «03/11/26» -16 • Regulation XIV – Toxics and Other Non-Criteria Pollutants: This regulation sets forth the restrictions for visible emissions, odor nuisance, fugitive dust, various air pollutant emissions, fuel contaminants, start-up/shutdown exemptions, and breakdown events. ○ Rule 1401 – New Source Review of Toxic Air Contaminants: This rule specifies limits for maximum individual cancer risk (MICR), cancer burden, and noncancer acute and chronic hazard index (HI) from new permit units, relocations, or modifications to existing permit units which emit toxic air contaminants. ○ Rule 1403 – Asbestos Emissions from Demolition/Renovation Activities: The purpose of this rule is to specify work practice requirements to limit asbestos emissions from building demolition and renovation activities, including the removal and associated disturbance of asbestos-containing materials (ACMs). Demolition activities associated with the proposed project will be required to comply with Rule 1403.

Cypress City CouncilAugust 25, 2026

Cypress City Council
August 25, 2026