Implementation of the proposed project would provide sidewalks along the project frontages. In addition, pedestrian sidewalks and pathways would be provided throughout the Buildout Area and provide connections to existing pedestrian and bicycle facilities in the surrounding area. Specifically, the proposed project is assumed to include the addition of approximately 1 mile of bicycle facilities, connecting to the existing bicycle network. In addition, pedestrian access via sidewalks to the Buildout Area would be from Katella Avenue, Cerritos Avenue, Lexington Drive, and Vessels Circle, as extended. 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 discussed further in Threshold 4.17.2 and detailed in Mitigation Measure TRA-1, the proposed project would be required to implement feasible Transportation Demand Management (TDM) strategies to mitigate the proposed project’s 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. All future development facilitated by the proposed project would be required to comply with City policies regarding bicycle parking and other infrastructure. In addition, the proposed project would not include features that would disrupt existing or planned bicycle or pedestrian facilities. Therefore, the proposed project would not conflict with any adopted bicycle or pedestrian system plans, guidelines, policies, or standards and impacts to bicycle and pedestrian facilities would be less than significant. 11 Orange County Transportation Authority (OCTA). 2025b. OCTA Approves $1.74 Billion Balanced Budget for FY 2025-26. June 6. Website: https://www.octa.net/news/news-releases/octa-approves-174-billionbalanced-budget-for-fy-2025-26 (accessed October 2025).
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4.17 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.17 Transportation.docx (03/11/26) -16 Roadway System. The proposed project would include the extension of Moody Street from Cerritos Avenue to the northern terminus of Siboney Street, as well as the extension of Vessels Circle from its current western terminus to intersect with the Moody Street extension, consistent with the Specific Plan. The proposed project also includes, consistent with the Specific Plan, the widening of Lexington Drive within Lot B in proposed VTTM 19247 and seven access driveways, including one at Lexington Drive and two each at Cerritos Avenue, Moody Street, and Vessels Circle.
It is anticipated that construction would commence in 2026 and be completed in 2038. Large construction equipment such as bulldozers, loaders, scrapers, backhoes, water trucks, and pavers would be required during various construction phases and would be delivered to the Buildout Area as needed.
The proposed project would be constructed over an extended period and the phasing of specific development projects cannot be precisely determined at this time. Haul routes for construction traffic would be along the designated truck routes, including Katella Avenue, Cerritos Avenue, Walker Street and Valley View Street, in the Cities of Cypress, Los Alamitos and Garden Grove to I-605, SR-22 or I-405. Use of the Moody Street extension after it is built and/or Lexington Drive may be needed for grading activities in some portions of the Buildout Area to access the noted designated truck routes. As each specific development project is identified, specific haul routes can be determined.
During construction, temporary delays in traffic may occur due to oversized vehicles traveling at lower speeds on the surrounding roadways turning into the Buildout Area. In addition, construction activities may require temporary road or lane closures in the vicinity of the Buildout Area.
Temporary road or lane closures during construction would be a potential significant impact to roadways and safety . The traffic generated by construction activity would be limited in duration and would not materially impact the LOS at any study intersections or freeway mainline segments. In addition, a transportation construction plan (TCP) for construction activities associated with each development project withing the Buildout Area would be submitted to the City of Cypress Public Works Department for review and approval.
For the reasons set forth above, construction traffic impacts associated with conflict with a program, plan, ordinance, or policy addressing the roadway system during construction would be less than significant.
Operation: The project would not conflict with adopted programs, plans, ordinances, or policies addressing the circulation system in the City of Cypress. The project would be consistent with the City of Cypress General Plan circulation framework, which emphasizes safe and efficient movement for vehicles, transit, bicycles, and pedestrians, as well as the Circulation Plan contained in the Specific Plan. The project would not cause physical deterioration of roadway facilities, interfere with transit operations, or preclude the implementation of existing or planned bicycle and pedestrian facilities. Project access, internal circulation, and connections to the surrounding transportation network would comply with City standards and applicable design requirements.
Congestion Management Plan Analysis. Pursuant to SB 743 and Section 15064.3 of the State CEQA Guidelines, the determination of significance for transportation impacts under CEQA is based on
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P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.17 Transportation.docx (03/11/26) 4.17-17 VMT rather than roadway LOS. Accordingly, congestion or delay at intersections, including those on the Orange County CMP network, is no longer considered a significant environmental impact under CEQA. Although LOS is no longer used for CEQA significance determinations, the City’s General Plan Circulation Element and the Orange County CMP continue to identify LOS standards for local policy and regional consistency purposes. Therefore, the CMP analysis in this document is provided for informational purposes only and does not influence the environmental significance determinations related to transportation impacts, pursuant to CEQA. This discussion is provided to demonstrate consistency with the City’s circulation policies and the performance requirements of OCTA, which administers the countywide CMP pursuant to Government Code § 65088 et seq.
CMP requirements state that a Traffic Impact Analysis (TIA) is required for CMP purposes for any proposed development generating 2,400 or more daily trips, except that for developments which will directly access a CMP Highway System roadway segment, the threshold for requiring a TIA is reduced to 1,600 or more trips per day. Given that the proposed project is estimated to generate a total of 21,041 daily trips, and would include access directly from Katella Avenue, which is a CMP facility, a TIA for the proposed project has been prepared and is available from the City upon request. The CMP requires that the traffic study area for the proposed project extend far enough to cover any CMP roadway segment on which the project traffic would represent 3 percent or more of the roadway segment LOS E capacity. Within the cities of Cypress and Los Alamitos, the CMP Highway System includes two arterials: Valley View Street and Katella Avenue. Currently, Katella Avenue and Valley View Street operate at LOS E. The proposed project’s daily traffic volumes would exceed the 3 percent threshold for relatively short distances on Katella Avenue east and west of the Buildout Area and along Valley View Street to the north and south.
For Katella Avenue, the proposed project’s daily traffic volumes would be below the 3 percent threshold at the Katella Avenue at I-605 Southbound Ramps CMP intersection to the west; and the Beach Boulevard and Katella Avenue intersection, which is the next CMP intersection to the east. In regard to Valley View Street, the proposed project’s daily traffic volumes would be below the 3 percent threshold along Valley View Street before reaching the next CMP intersection to the north, which is the SR-91 Eastbound Ramp and Valley View Street intersection in the city of Buena Park, and the next CMP intersection to the south, which is Bolsa Chica Road at I-405 Southbound Ramps. Therefore, the CMP traffic analysis has been carried out sufficiently far enough to satisfy CMP requirements and no further analysis is required.
Conclusion: Based on the above analysis, and because the proposed project would be required to adhere to the Specific Plan and the General Plan, the proposed project would generally be consistent with all programs, plans, ordinances, and policies addressing the circulation system, including those regulating transit, roadway, bicycle, and pedestrian facilities. Therefore, impacts would be less than significant, and no mitigation is required.
Threshold 4.17.2: Would the project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)?
Significant and Unavoidable Impact. As previously discussed, a VMT screening was conducted as part of the VMT Memo (Appendix K) to evaluate the proposed project based on the pre-established criteria outlined in the County Guidelines for presuming a less than significant impact. Specifically, 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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4.17 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.17 Transportation.docx (03/11/26) -18 the following applicable screening criteria in the County Guidelines were considered for the proposed project.
Project in High Quality Transit Area (HQTA). A project located within 0.5 mile from an existing major transit stop12 or within 0.5 mile from an existing stop along a high-quality transit corridor13 is considered an HQTA project and is presumed to result in a less than significant VMT impact. The VMT Memo determined that while the Buildout Area is served by OCTA Route 50, none of the stops have bus routes operating with a frequency of 20 minutes interval and therefore cannot be considered a major transit stop. Therefore, the proposed project does not meet this criterion.
Neighborhood Retail Project. The County Guidelines include a 50,000-square-foot screening threshold for the totality of local-serving retail on a project site. However, this threshold departs from how the LCI applies this threshold in its Technical Advisory on Evaluating Transportation Impacts In CEQA (LCI Technical Advisory),14 which states that retail development including stores larger than 50,000 square feet might be considered regional-serving, and so lead agencies should undertake an analysis to determine whether the project might increase or decrease VMT. This language is commonly understood to mean that the threshold applies on a per-store basis. The intent is to identify larger, individual retail tenants, such as big-box stores, that are more likely to attract regional trips and therefore increase VMT. In contrast, smaller stores below this threshold are generally presumed to be local-serving, with the potential to reduce trip lengths by serving nearby residents.
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 proposed 440,000 square feet of non-residential area would 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 proposed project is a 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.
Further, it is anticipated that no single retail establishment developed as part of the proposed would exceed 50,000 square feet in size. Accordingly, even though the total non-residential space would 12 Under the amended Public Resources Code § 21064.3 – “‘Major transit stop’ means a site containing an existing rail or bus rapid transit station, a ferry terminal served by either a bus or rail transit service, or the intersection of two or more major bus routes with a frequency of service interval of 20 minutes or less during the morning and afternoon peak commute periods.” 13 Public Resources Code § 21155 - For purposes of this section, a “‘high-quality transit corridor’ means a corridor with fixed route bus service with service intervals no longer than 15 minutes during peak commute hours.”
14 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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P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.17 Transportation.docx (03/11/26) 4.17-19 exceed 50,000 square feet, each individual retail tenant is anticipated to fall below the LCI’s screening threshold for regional-serving retail uses. In this way, the proposed project remains consistent with the intended function of the 50,000-square-foot threshold as construed in the LCI Technical Advisory, supporting the presumption that typical small-format, local-serving retail establishments are unlikely to result in a significant VMT impact.
Applying this approach, the proposed project’s retail component comprised of a collection of smaller, neighborhood-oriented stores would not trigger additional VMT analysis under the LCI 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 proposed project would primarily serve local demand without inducing substantial new regional vehicle trips.
Therefore, the development of the proposed project’s non-residential uses are presumed to result in a less than significant VMT impact.
Nevertheless, 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 was performed as part of the VMT Memo in accordance with the County Guidelines. The results of this analysis show that, even when applying the County’s more stringent methodology, the proposed project’s non-residential component would have a less than significant VMT impact, further substantiating the conclusion that the proposed project’s neighborhood-serving retail and other commercial uses would not generate substantial new regional vehicle travel. Specifically, the non-residential component of the proposed project would result in net decrease in total Countywide VMT under both existing and cumulative scenarios with the addition of the proposed project. This reduction occurs because integrating retail uses into the Buildout Area would enable more trips to occur internally or over shorter distances, reducing the need for residents to travel off-site for essential services and goods.
Low VMT Area Project. 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 percent 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. As the proposed project is expected to generate over 1,000 daily vehicle trips, a quantitative VMT analysis is required to accurately assess its impacts, and the proposed project cannot be screened out based on this criterion.
The results of the VMT screening determined that the proposed project does not meet the HQTA or Low VMT Area screening criteria, but does qualify as a neighborhood-serving retail development under the LCI Technical Advisory. A supplemental quantitative analysis conducted in accordance with the County Guidelines confirmed that the proposed project’s non-residential uses 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 does not meet any of the applicable project-type screening criteria and, therefore, cannot be presumed to have a less than significant VMT impact. Consequently, a full VMT analysis was conducted for the proposed residential uses in accordance with the County Guidelines, as detailed below.
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4.17 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.17 Transportation.docx (03/11/26) -20 To calculate VMT for the proposed project, OCTAM was run for both existing plus project (2019) and cumulative plus project (2050) scenarios, and calculations from the relevant OCTAM output files were completed to estimate the anticipated Home-Based VMT for the project’s TAZ. The City's threshold of significance for a project's VMT impact with respect to residential uses, based on the County Guidelines, is 13.21 VMT per capita (15 percent below the existing regional average).
As provided in the VMT Memo and shown in Table 4.17.A: Project Residential VMT Impacts, the Home-Based VMT per Capita for the proposed project would be higher than the County's residential VMT significance thresholds under both existing and cumulative plus project conditions, resulting in a Home-Based VMT per Capita that would exceed the significance threshold by 11.6 percent.
Table 4.17.A: Project Residential VMT Impacts
Analysis Scenario Home-Based VMT/Capita
Significance Threshold
(15% Below Existing regional average) 13.21
Existing Plus Project (2019) 14.29
Cumulative Plus Project (2050) 14.96
VMT in Excess of Significance Threshold 1.73
VMT % In Excess of Threshold 11.6%
Source: Vehicle Miles Traveled (VMT) Analysis for Specific Plan 3.0 Buildout Project. (Kimley-Horn and Associates, Inc., May 2025b).
Because the proposed project would exceed this residential significance threshold, the proposed project's residential component is considered to have a potentially significant VMT impact under CEQA. As such, future residential development in the Buildout Area would be required to comply with Mitigation Measure TRA-1.
Mitigation Measure TRA-1 Transportation Demand Management Strategies. The Development Agreement between the City of Cypress 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,
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P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.17 Transportation.docx (03/11/26) 4.17-21 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.
Implementation of Mitigation Measure TRA-1 would require the proposed project to reduce overall VMT in order to contribute to achieving the overall VMT reduction target established in this Draft EIR of 11.6 percent.
The bike facility improvement in Item 1 of Mitigation Measure TRA-1 is estimated to achieve a
0.1 percent reduction in VMT by enhancing active transportation options, increasing network connectivity, and encouraging a shift away from single-occupancy vehicle trips.
The construction of the pedestrian facilities in Item 2 of Mitigation Measure TRA-1 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 would 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 would increase the existing study area sidewalk length from 7.7 miles to 9.4 miles, which would reduce VMT by 1.1 percent 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.
Therefore, while the implementation of Mitigation Measure TRA-1 would reduce the residential VMT impact, that impact would remain above the established threshold for residential VMT and the residential VMT impact would be significant and unavoidable.
Threshold 4.17.3: Would the project substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)?
Less Than Significant Impact. For purposes of CEQA, transportation-related hazards refer to engineering aspects of a project (e.g., speed, turning movements, complex designs, substantial distance between street crossings, sight lines) that may cause a greater risk of collisions that result in serious or fatal physical injury than a typical project. This analysis focuses on hazards that could reasonably stem from the proposed project, beyond collisions that may result due to unsafe drivers or collisions that could not be prevented by design of the circulation system.
The proposed project assumes the extension of Moody Street from Cerritos Avenue to Katella Avenue, as well as the extension of Vessels Circle from its current western terminus to intersect with the Moody Street extension, consistent with the Specific Plan. The Moody Street extension would S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T
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4.17 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.17 Transportation.docx (03/11/26) -22 traverse the Buildout Area, passing adjacent to Lots 3, 4, 5, 6, 7, 12, 13, and 14 in proposed 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 proposed VTTM 19247. The proposed project also includes, consistent with the Specific Plan, the widening of Lexington Drive within Lot B in proposed VTTM 19247. In addition, the proposed project would include seven access driveways, including one at Lexington Drive and two each at Cerritos Avenue, Moody Street, and Vessels Circle. 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.
Except as otherwise provided in the Specific Plan, all roadway improvements in and around the Buildout Area shall be designed and constructed in accordance with Chapter 25, Article 5, Public Improvements, of the CMC and applicable Public Works Design Standards, which establish minimum requirements for street widths, curb return radii, intersection design, and driveway access. Except as otherwise provided in the Specific Plan, driveway design and access control shall also comply with CMC Appendix I (Zoning), Chapter 3.14 – Off-Street Parking and Loading, which regulates driveway width, location, and spacing to prevent hazardous conflicts between vehicular and pedestrian movements (CMC § 3.14.050). In addition, except as otherwise provided in the Specific Plan, all final site and roadway improvement plans shall conform to the City’s Public Works Design Criteria Manual, which incorporates California Manual on Uniform Traffic Control Devices (CA MUTCD) standards for intersection control, sight distance, and geometric design.
All final improvement and site access plans shall be subject to review and approval by the City’s Public Works and Fire Departments prior to issuance of building permits. Compliance with these requirements and design standards would ensure that new roadway and driveway improvements avoid sharp curves, unsafe intersection geometry, and visual obstructions, thereby maintaining safe and efficient circulation within and adjacent to the Buildout Area.
For these reasons, the proposed project's impact related to a substantial increase in hazards due to a design feature or incompatible use would be less than significant.
Threshold 4.15.4: Would the project result in inadequate emergency access? Less Than Significant Impact. As previously discussed, all roadway improvements in and around the Buildout Area would be designed and constructed to satisfy all City requirements for street widths, corner radii, and intersection control, as well as incorporate design standards tailored specifically to site access requirements. The proposed project and internal circulation system would be designed, constructed, and maintained to provide adequate emergency access and evacuation to all future onsite structures.
During construction of future development facilitated by the proposed project, the construction contractor would be required to implement a TCP that complies with applicable engineering standards outlined in the CA MUTCD. The proposed seven access driveways, including one at Lexington Drive and two each at Cerritos Avenue, Moody Street, and Vessels Circle, would also act as fire access roads and would be designed to adequately accommodate fire apparatus and other
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Adherence to the emergency access measures required by the City would ensure impacts related to inadequate emergency access would be less than significant.
4.17.7 Level of Significance Prior to Mitigation
Implementation of the proposed project would result in potentially significant impacts related to transportation.
4.17.8 Regulatory Compliance Measures and Mitigation Measures
4.17.8.1 Regulatory Compliance Measures
No regulatory compliance measures are applicable to the proposed project pertaining to transportation.
4.17.8.2 Mitigation Measures
Future development facilitated under the proposed project would be required to implement the following Mitigation Measure.
Mitigation Measure TRA-1 Transportation Demand Management Strategies. The Development Agreement between the City of Cypress 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 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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4.17.8.3 Level of Significance after Mitigation
Even with implementation of Mitigation Measure TRA-1, the proposed project would result in a significant and unavoidable impact related to residential VMT. No other feasible mitigation measures have been identified to reduce these impacts to less than significant.
4.17.9 Cumulative Impacts
The purpose of this section is to evaluate any additional incremental impact that the proposed project is likely to cause over and above the combined impacts of recently approved and proposed projects in the City. The impact area used to assess potential cumulative transportation impacts is the City and immediately surrounding area because the proposed project would affect transportation facilities within the City as well as immediately adjacent areas. Please refer to Table 4.A: Summary of Related Projects and Figure 4.1: Related Projects, in Chapter 4.0, Existing Setting, for the descriptions and locations of these related projects.
Each development proposal received by the City is required to undergo individual environmental review pursuant to CEQA. Some of the related projects identified in Table 4.A have undergone environmental review pursuant to CEQA, which included an analysis of potential impacts related to transportation. According to the EIRs prepared for the Shea Properties Mixed Use Development Project (Related Project 1) and Melia Homes -Citrus Square Project (Related Project 2), transportation and VMT impacts would be less than significant and no mitigation was required. In addition, the EIR prepared for the Los Alamitos Medical Center Project (Related Project 7) determined that transportation and VMT impacts would be reduced to less than significant with implementation of mitigation. Further, the EIRs determined that cumulative impacts related to transportation and VMT would be less than significant. The environmental documents prepared for the Goodman Commerce Center Project (Related Project 3) determined that all transportation and VMT impacts would also be less than significant with implementation of mitigation that requires a truck signage and striping plan. The Sycamore Creek Charter School Project (Related Project 6) and 4562 Katella Avenue Project (Related Project 8) were determined to be exempt from CEQA review under Section 15332 of the State CEQA Guidelines (for infill development) and Notices of Exemption (NOEs) were prepared. In order for a project to be exempt under Section 15332 of the State CEQA Guidelines, the project must not result in significant traffic impacts. The LTP Modern Machine Project (Related Project 5) and 8561 Belmont Street Project (Related Project 4) would also be required to undergo environmental review pursuant to CEQA, which would include an analysis of potential impacts on transportation and the identification of any mitigation measures to reduce potential impacts, if necessary.
Future development associated with the related projects would be required to comply with existing regulations, including the CMC and General Plan policies that have been adopted to minimize impacts related to transportation and circulation, as well as any applicable Federal, State and regional regulations. The City would also implement the General Plan policies that require the City to annually update the Capital Improvement Program to reflect City and community priorities for physical projects related to transportation for all travel modes. The project, together with
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P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.17 Transportation.docx (03/11/26) 4.17-25 cumulative development, would not cause physical deterioration of roadway facilities, interfere with planned or existing transit services, or preclude the implementation of adopted bicycle and pedestrian facilities. The project therefore would not result in a cumulative conflict with circulation system plans or policies, and the impact related to circulation system consistency would be less than significant.
Cumulative land use development and transportation projects would generally promote accessibility for people walking to and through the Buildout Area by conforming to General Plan policies and the CMC, and by adhering to planning principles that emphasize providing convenient connections and safe routes for people walking, bicycling, driving, and taking transit. As with current practice, related projects would be designed and reviewed in accordance with the City’s Public Works Department requirements and the Department would provide oversight engineering review to ensure that the project is constructed according to City specifications. As a result, the related projects would not generate activities that would increase hazards due to a design feature or incompatible use. As discussed above, because the proposed project would also comply with requirements and design standards to ensure that new roadway and driveway improvements avoid sharp curves, unsafe intersection geometry, and visual obstructions, the proposed project’s impacts related to a substantial increase in hazards due to a design feature or incompatible use would be less than significant. For these reasons, the proposed project, in combination with cumulative projects, would have a less than significant cumulative impact with respect to design features or incompatible uses.
Future development as part of the City’s project approval process would also be required to comply with existing regulations, including General Plan policies and the CMC that have been prepared to minimize impacts related to emergency access.
The City would implement the General Plan programs that require the City’s continued coordination with the City’s Police Department and the OCFA to establish circulation standards, adopt an emergency response route map, and equip all new traffic signals with preemptive traffic signal devices for emergency services. Furthermore, the implementation of the zoning regulations contained in Article 3, Section 11, Property Development and Use Standards, of the CMC related to adequate site and building access would help to minimize traffic congestion that could impact emergency access. As discussed above, implementation of the proposed project would have a less than significant impact related to emergency access with adherence to existing regulations and City standards. For these reasons, the proposed project, in combination with cumulative projects, would have a less than significant cumulative impact with respect to emergency access.
Detailed VMT analysis was conducted for the proposed project, including for both existing plus project (2019) and cumulative plus project (2050) scenarios. The cumulative plus project (2050) scenario reflects 2050 conditions with the proposed project incorporated. As discussed above, even with implementation of Mitigation Measure TRA-1, which requires 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 OPR (now the LCI),
15 if a project individually has a significant VMT impact, 15 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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Based on the analysis above, implementation of the proposed project, in addition to other recently completed, planned, and reasonably foreseeable projects within the City, could result in cumulative transportation impacts. Therefore, the proposed project’s cumulative impact with respect to residential VMT would be considered significant and unavoidable, while the other cumulative transportation impacts associated with the proposed project would be less than significant. 16 This similar treatment of project and cumulative VMT impacts is also summarized in Figure 5 of the Transportation Implementation Manual for the County of Orange (page 21), updated September 2021.
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4.18 TRIBAL CULTURAL RESOURCES
This section provides a discussion of the existing tribal cultural resource environment and evaluates the potential impacts on tribal cultural resources from implementation of the Specific Plan 3.0 Buildout Project (proposed project). According to California Public Resources Code (PRC) Section 21080.3.1 and Chapter 532, Statutes 2014 (i.e., Assembly Bill [AB] 52), “tribal cultural resources” are defined as the following:
1. Sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California Native American tribe that are either: (A) included or determined to be eligible for inclusion in the California Register of Historical Resources; or (B) included in a local register of historical resources as defined in subdivision (k) of Section 5020.1.
2. A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Section 5024.1.
This section summarizes information obtained from AB 52 Native American consultation efforts completed in support of the proposed project. The record of these consultation efforts is contained in Appendix L.
4.18.1 Scoping Process
The City of Cypress (City) received six comment letters during the public review period of the Notice of Preparation (NOP). For copies of the NOP comment letters, refer to Appendix A of this Draft Environmental Impact Report (Draft EIR). One comment letter, from the Native American Heritage Commission (NAHC), included comments related to tribal cultural resources.
The comment letter from the NAHC outlines the City’s tribal consultation requirements under AB 52.
4.18.2 Methodology
4.18.2.1 Records Searches
In January 2020, a cultural resource record search was completed as part of the environmental review process for the proposed mixed-use Cypress City Center Project, located directly south of the Buildout Area. The record search was conducted at the South Central Coastal Information Center (SCCIC) of the California Historical Resources Information System (CHRIS) at California State University, Fullerton, and included a review of all prehistoric and historic archaeological sites within a 0.25-mile radius of the Cypress City Center Project. As such, the records search performed as part of the Cypress City Center Project included the Buildout Area, as well as a review of known cultural resource survey and excavation reports in the surrounding area. The California State Historic Resources Inventory (HRI), National Register of Historic Places (National Register), California Historical Landmarks (SHL), California Points of Historical Interest (SPHI), and various local historical registers were examined. No archaeological resources had been previously recorded within the 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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Cypress City Center Project was constructed between 2021 and 2025, and no tribal cultural resources were identified during grading or construction activities. Because the records search for the Cypress City Center Project included the Buildout Area, this record search can be reasonably applied to the proposed project’s Buildout Area. As a result of the conditions discussed above, a new cultural resource records search under the proposed project was determined to be unnecessary by the City.
4.18.2.2 Assembly Bill 52
AB 52 requires that Lead Agencies evaluate a project’s potential to impact “tribal cultural resources.” Such resources include sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California Native American tribe that are eligible for inclusion in the California Register of Historical Resources or included in a local register of historical resources (PRC Section 21074). AB 52 also gives Lead Agencies the discretion to determine, supported by substantial evidence, whether a resource falling outside the definition stated above nonetheless qualifies as a “tribal cultural resource.” Also, per AB 52, as Lead Agency, the City must consult California Native American tribes that are traditionally and culturally affiliated with the geographic area of the project site and have previously requested that the Lead Agency provide the tribe with notice of such projects (PRC Section 21080.3.1).
A request form describing the proposed project and map depicting the Buildout Area was sent to the NAHC in West Sacramento on August 28, 2024, requesting a search of the Sacred Lands File (SLF) and a list of tribes eligible to consult with the City, pursuant to Public Resources Code Section 21080.3.1. On September 5, 2024, the NAHC responded in a letter indicating that the search of the SLF was negative. The NAHC also provided a list of 20 tribal contacts associated with the following tribes:
• Cahuilla Band of Indians
• Gabrieleño Band of Mission Indians - Kizh Nation
• Gabrieleño/Tongva San Gabriel Band of Mission Indians • Gabrielino Tongva Indians of California Tribal Council • Gabrielino/Tongva Nation
• Juaneno Band of Mission Indians Acjachemen Nation – Belardes • Juaneno Band of Mission Indians Acjachemen Nation 84A • Pala Band of Mission Indians
• Santa Rosa Band of Cahuilla Indians
• Soboba Band of Luiseno Indians
The City sent notification letters to these tribes on May 6, 2025, notifying them of the proposed project and providing the opportunity to consult with the City for the proposed project. Additional information is provided below in Section 4.18.6, Project Impacts, below. 1 City of Cypress. 2020. Cypress City Center Project Draft Environmental Report, SCH #2019110458. Section
4.16-4. Website: https://files.ceqanet.opr.ca.gov/257330-3/attachment/pPtqudn4yD91UlsUP_CKNqJ72 MJ0kYlHFzJsGzBHYFnlgWkhiTD33EKMOE--4IQOdoGX3ne3ABNyI6Km0 (accessed December 2025).
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4.18.3 Existing Environmental Setting
The area that is now the City of Cypress was prehistorically occupied by several different Native American tribes with unique oral histories, societal structures, and ways of life. To date, no federally recognized tribes claim to have occupied the land that is now considered the City of Cypress.
4.18.3.1 City of Cypress Ethnohistory
According to the City’s General Plan,2the level of Gabrielino culture that was encountered by the Spanish in the 18th century was a continuation of a culture formation originating as far back as 1200 AD. Prior to Spanish colonization, the Gabrielino population was estimated at more than 5,000 people. Various Spanish explorers had been in the region earlier, but in 1769, the Spanish under Gaspar de Portola began their colonization of the region. The people were given the name “Gabrielino” by the Franciscan Priests for their association with the Mission San Gabriel Arcangel, which was constructed by 1771 in San Gabriel, approximately 20 miles northwest of the Buildout Area. As a result of their induction into the mission, the Gabrielino population was decimated through disease.
The majority of the information on Gabrielino culture has been obtained from the remains of their material culture; however, much of it was perishable and therefore not available for research purposes. What is known is that they had abundant marine resources, terrestrial animals, and a heavy reliance on acorns. They also engaged in trade networks that included the exchange of resources from the Channel Islands, the mainland, and inland to Arizona, with more than 89 percent of the Gabrielino's physical environment within the extremely rich Sonoran life zone.
4.18.3.2 Existing Buildout Area Conditions
As outlined in the Environmental Impact Report, Soils and Geology Issues, Proposed Mixed-Use Development, 4961 Katella Avenue and 5100 Cerritos Avenue, Cypress, California (Geotechnical Investigation),
3 the Buildout Area is underlain by 3–5 feet of fill material on top of native alluvial soils. Undisturbed native alluvial soils may contain previously unknown archaeological resources, including tribal cultural resources. There is no information regarding specific known tribal cultural resources in or around the Buildout Area, as determined by the record search performed for the Cypress City Center Project, which included the Buildout Area. Therefore, there are no known tribal cultural resources within the Buildout Area and no tribal cultural resources listed or eligible for listing in the California Register of Historical Resources (California Register) or in a local register existing within the Buildout Area.
4.18.4 Regulatory Setting
The following section describes the federal, State, regional, and local regulatory framework applicable to analyzing potential impacts related to tribal cultural resources from development of the proposed project.
2 City of Cypress. 2001. Cypress General Plan Conservation/Open Space/Recreation Element. September 10, 2001.
3 Geotechnologies, Inc. 2024. Environmental Impact Report, Soils and Geology Issues, Proposed Mixed-Use Development, 4961 Katella Avenue and 5100 Cerritos Avenue, Cypress, California. May 2. (Appendix F) 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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4.18.4.1 Federal Regulations
Archaeological Resources Protection Act. The Archaeological Resources Protection Act was enacted in 1979 with the purpose of securing the protection of archaeological resources and sites on public lands and Native American lands, and to foster increased cooperation and exchange of information between governmental authorities, the professional archaeological community, and private individuals.
Native American Graves Protection and Repatriation Act (NAGPRA). The NAGPRA was passed in 1990 with the purpose of outlining a process for museums and federal agencies to return certain Native American cultural items (e.g., human remains, funerary objects, sacred objects, or objects of cultural patrimony) to lineal descendants, and culturally affiliated Indian tribes. NAGPRA also establishes procedures for the inadvertent discovery or planned excavation of Native American cultural items on federal or tribal lands. While these provisions do not apply to discovery or excavations on private or State lands, the collection portions of NAGPRA may apply to cultural items if they are under the control of an institution that receives federal funding. NAGPRA also makes it a criminal offense to traffic in Native American human remains without right of possession or in cultural items obtained in violation of NAGPRA.
4.18.4.2 State Regulations
Native American Heritage Commission (NAHC). In 1976, the California State Government passed AB 4239, creating the NAHC. The NAHC is responsible for identifying and categorizing Native American cultural resources as well as preventing damage to designated sacred sites and associated artifacts and remains. Legislation passed in 1982 authorized the NAHC to identify a Most Likely Descendant (MLD) when Native American remains are found outside the boundaries of a designated cemetery.
An MLD has the authority to make recommendations in regard to the treatment and disposition of the discovered remains.
California Public Resources Code (PRC) Sections 5097.9–5097.991. California PRC Sections 5097.9– 5097.991 provide protection to Native American historical and cultural resources (including sanctified cemeteries, places of worship, religious sites, or sacred shrines) and sacred sites and gives the NAHC enforcement authority.
Specifically, PRC Section 5097.98 outlines procedures that must be followed in the event that human remains are discovered. The County Coroner shall make a determination within 2 working days from the time the person responsible for the excavation, or designee, notifies the County Coroner of the discovery or recognition of the human remains. If the County Coroner identifies the remains to be of Native American origin or has reason to believe that the remains are those of Native American origin, the County Coroner must contact the California NAHC within 24 hours. The NAHC representative will then alert a Native American MLD to conduct an inspection of the site and to determine the following course of treatment and action. Additionally, State CEQA Guidelines Section 15064.5 sets forth a procedure if human remains are found on land outside of federal jurisdiction.
Health and Safety Code Section 7050.5. Section 7050.5 of the California Health and Safety Code protects Native American burials, remains, and associated grave artifacts in the event they are discovered in any location other than a designated cemetery. The Health and Safety Code mandates
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Should remains be discovered, the County Coroner must determine that the remains are not subject to the provisions of Section 27491 of the Government Code or any other related provisions of law concerning investigation of the circumstances, manner, and cause of any death, and the recommendations concerning the treatment and disposition of the human remains have been made to the person responsible for the excavation, or designee, in the manner provided in PRC Section 5097.98.
Assembly Bill 52. AB 52 requires that a project with an effect that may cause a substantial adverse change in the significance of a tribal cultural resource, as defined, is a project that may have a significant effect on the environment. The bill requires a lead agency to begin consultation with each California Native American tribe that is traditionally and culturally affiliated with the geographic area of the proposed project, if the tribe requested to the lead agency, in writing, to be informed by the lead agency of proposed projects in that geographic area and the tribe requests consultation, prior to determining whether a Negative Declaration, Mitigated Negative Declaration, or Environmental Impact Report is required for a project. The bill specifies examples of mitigation measures that may be considered to avoid or minimize impacts on tribal cultural resources. The bill makes the above provisions applicable to projects that have a Notice of Preparation or a notice of Negative Declaration or Mitigated Negative Declaration filed on or after July 1, 2015. By requiring the lead agency to consider these effects relative to tribal cultural resources and to conduct consultation with California Native American tribes, this bill imposes a State-mandated local program.
Penal Code Section 622.5. Section 622.5 of the Penal Code makes it a misdemeanor to willfully damage, deface, or destroy any object of archaeological or historical interest or value and applies to any archaeological or historical object whether situated on private land or within any public park or place.
Penal Code Section 623. Section 623 of the Penal Code provides for the protection of natural and archaeological materials in caves, including: damaging or defacing natural cave formations (e.g., stalactites, stalagmites); disturbing or altering archaeological evidence of prior human occupation in a cave; removing or harming plant or animal life in a cave; removing any “material” from a cave, where “material” includes archaeological, paleontological, historical, biological items; and tampering with cave entrances (gates, locks, doors) without permission.
4.18.4.3 Regional Regulations
There are no regional regulations that are applicable to tribal cultural resources relevant to the proposed project.
4.18.4.4 Local Regulations
There are no local regulations that are applicable to tribal cultural resources relevant to the proposed project.
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4.18.5 Thresholds of Significance
The thresholds of significance for tribal cultural resources impacts used in this analysis are consistent with Appendix G of the State CEQA Guidelines. Based on these thresholds, implementation of the proposed project would have a significant adverse impact with respect to tribal cultural resources if it would:
Threshold 4.18.1: Cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
i. Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k); or
ii. A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1? In applying the criteria set forth in subdivision (c) of Public Resource Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.
4.18.6 Project Impacts
Threshold 4.18.1: Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
i. Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k); or
ii. A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1? In applying the criteria set forth in subdivision (c) of Public Resource Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe?
Less Than Significant with Mitigation Incorporated. The City consulted with tribal representatives traditionally or culturally affiliated with the Buildout Area pursuant to the requirements outlined in AB 52. On May 6, 2025, the City sent outreach letters to the tribal contacts provided by the NAHC and formally invited each representative to consult with the City on the proposed project. The
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• On May 7, 2025, the Pala Band of Mission Indians responded, stating that the proposed project is not located within the boundaries of the recognized Pala Indian Reservation. The Pala Band of Mission Indians also indicated that the proposed project is beyond the boundaries of the territory that the tribe considers its Traditional Use Area (TUA). Therefore, the Pala Band of Mission Indians declined AB 52 consultation and deferred to the wishes of tribes in closer proximity to the project area.
• On May 7, 2025, the Santa Rosa Band of Cahuilla Indians responded, stating that they defer any comments to the Soboba Band of Luiseno Indians.
• On May 22, 2025, the Gabrielino Tongva Indians of California Tribal Council responded, stating they have no comment on the proposed project.
• On May 8, 2025, the Gabrieleño Band of Mission Indians - Kizh Nation responded and requested consultation with the City regarding the proposed project. On May 27, 2025, the City provided suggested mitigation measures relating to the protection of tribal cultural resources to the Gabrieleño Band of Mission Indians - Kizh Nation, as detailed in Mitigation Measures TCR-1 through TCR-4. These measures include required tribal cultural resources training and ALERT sheet posting, on-site tribal monitoring during ground disturbance of native sediment, and provisions in the event that previously unknown tribal cultural resources (including human remains and funerary objects) are discovered during construction activities.
On July 14, 2025, the Gabrieleño Band of Mission Indians - Kizh Nation responded, requesting tribal monitors on-site during all phases of ground disturbance, including in areas classified as previously disturbed or containing fill materials. On August 4, 2025, the City responded, summarizing the previous cultural records searches performed that include the Buildout Area, which indicate that no cultural resources are present within the Buildout Area. The City also indicated that the SLF search was negative, and that the Geotechnical Investigation prepared for the proposed project confirms the Buildout Area is underlain by 3 to 5 feet of fill material, with native alluvial soils beneath. The City also indicated that the area surrounding the Buildout Area has undergone significant development since 2014, including Lexington Park, Ovation at Flora Park, Belmont, and Cypress City Center projects, totaling approximately 62 acres of ground disturbance. Several of these projects included monitoring by Gabrieleño Band of Mission Indians - Kizh Nation representatives, and none resulted in the discovery of cultural resources.
As such, the City maintained that on-site tribal monitoring during all phases of ground disturbance into native alluvial soils would be sufficient to address potential impacts on previously unknown tribal cultural resources. In September 2025, the City considered tribal consultation with the Gabrieleño Band of Mission Indians - Kizh Nation completed.
No information regarding specific known tribal cultural resources within the Buildout Area was provided by the Gabrieleño Band of Mission Indians - Kizh Nation. Therefore, no tribal cultural resources listed or eligible for listing in the California Register of Historical Resources (California 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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Although no cultural or tribal cultural resources have been identified within the Buildout Area, future construction facilitated by the proposed project would include ground- disturbing activities including grading and excavation. Ground disturbing activities within the Buildout Area could result in a potentially significant impact to tribal cultural resources if previously undiscovered tribal cultural resources are unearthed during ground-disturbing activity, including human remains of Native American origin. However, as discussed in Section 4.5, Cultural Resources, future development facilitated under the proposed project would be required to adhere to Regulatory Compliance Measures CUL-1 and CUL-2, which detail provisions in the event that previously unknown cultural resources, including human remains, are discovered during ground-disturbing construction activities, consistent with the California Code of Regulations (CCR) Section 15064.5(e) and State Health and Safety Code Section 7050.5. In addition, future development facilitated under the proposed project would also be required to implement Mitigation Measures TCR-1 through TCR-4.
Mitigation Measure TCR-1 Tribal Cultural Resources Training and ALERT Sheet Posting. 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.
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applicant/City shall retain a Native American Monitor from or approved by the Gabrieleño 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 grounddisturbing activities and phases that may involve ground-disturbing 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 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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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)(1) 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.
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 grounddisturbing activities and the NAHC subsequently identifies the Gabrieleño 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
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P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.18 Tribal Cultural Resources.docx (03/11/26) 4.18-11 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 15064.5(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 Gabrieleño 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.
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 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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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.
The mitigation measures include required tribal cultural resources training and ALERT sheet posting, on-site tribal monitoring during ground disturbance of native sediment, and provisions in the event that previously unknown tribal cultural resources (including human remains and funerary objects) are discovered during ground-disturbing construction activities. With implementation of Mitigation Measures TCR-1 through TCR-4, the potential impacts to known and unknown tribal cultural resources would be less than significant with mitigation incorporated.
4.18.7 Level of Significance Prior to Mitigation
Impacts on known or unknown tribal cultural resources with implementation of the proposed project would be potentially significant.
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4.18.8 Regulatory Compliance Measures and Mitigation Measures
4.18.8.1 Regulatory Compliance Measures
The following regulatory compliance measures are existing regulations that are applicable to the proposed project and are considered in the analysis of potential impacts related to tribal cultural resources. The City considers these requirements to be mandatory; therefore, they are not mitigation measures.
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
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(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 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 15064.5(e), State Health and Safety Code
Section 7050.5, and PRC Section 5097.98, as stated
above.
4.18.8.2 Mitigation Measures
Future development facilitated under the proposed project would be required to implement the following mitigation measures.
Mitigation Measure TCR-1 Tribal Cultural Resources Training and ALERT Sheet Posting. 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
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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 Gabrieleño 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 grounddisturbing activities and phases that may involve ground-disturbing activities in native (previously undisturbed) soil has occurred (i.e., 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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4.18 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.18 Tribal Cultural Resources.docx (03/11/26) -16 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)(1) 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.
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 within 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-
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P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.18 Tribal Cultural Resources.docx (03/11/26) 4.18-17 disturbing activities and the NAHC subsequently identifies the Gabrieleño 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 15064.5(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 Gabrieleño 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.
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4.18 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.18 Tribal Cultural Resources.docx (03/11/26) -18 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.
4.18.9 Level of Significance after Mitigation
Impacts to known and unknown tribal cultural resources would be less than significant with implementation of Mitigation Measures TCR-1 through TCR-4.
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4.18.10 Cumulative Impacts
Defined in Section 15130 of the State CEQA Guidelines, cumulative impacts are the incremental effects of an individual project when viewed in connection with the effects of past, current, and reasonably foreseeable projects in an area of interest. The cumulative impact area for tribal cultural resources is the South Orange County region, including the City of Cypress. As previously discussed, no tribal cultural resources are known to exist within the Buildout Area. As such, implementation of the proposed project would have no impact on known tribal cultural resources and would therefore not contribute to a significant cumulative impact on known tribal cultural resources.
Potential impacts of the proposed project to unknown tribal cultural resources, when combined with other past, current, and reasonably foreseeable projects in the city and on land traditionally used by culturally affiliated tribes, including the related projects identified in Table 4.A: Summary of Related Projects and Figure 4.1, in Chapter 4.0, Existing Setting, could contribute to a cumulatively significant impact due to the overall loss of tribal cultural resources in the region. However, each development proposal received by the City is required to undergo individual environmental review pursuant to CEQA, including AB 52 outreach. Furthermore, impacts of other projects on tribal cultural resources are generally site-specific because they result from ground-disturbing activities that would require a site-specific impact analysis to determine the nature and extent of the resources and identify appropriate mitigation measures that would reduce or avoid significant impacts.
Ground disturbance associated with future development facilitated by the proposed project could result in a potentially significant impact to tribal cultural resources if previously undiscovered tribal cultural resources are unearthed during ground-disturbing activity, including human remains of Native American origin. However, future development facilitated under the proposed project would be required to adhere to Regulatory Compliance Measures CUL-1 and CUL-2 and implement Mitigation Measures TCR-1 through TCR-4, which include required tribal cultural resources training and ALERT sheet posting, on-site tribal monitoring during ground disturbance of native sediment, and provisions in the event that previously unknown tribal cultural resources (including human remains and funerary objects) are discovered during ground-disturbing construction activities.
Adherence to and implementation of these measures would ensure less than significant impacts on tribal cultural resources.
Similar to the proposed project, ground disturbance associated with related projects could result in potentially significant impacts on previously unidentified archaeological sites and associated human remains that may be unearthed. However, when the City considers future development proposals, both within the Buildout Area and citywide, these proposals would undergo environmental review pursuant to CEQA and when necessary, mitigation measures would be adopted as appropriate. In most cases, this environmental review and compliance with project conditions of approval and relevant policies of the General Plan would ensure that significant impacts on tribal cultural resources would be avoided or otherwise mitigated to less than significant levels. Further, discretionary projects would be required to engage in tribal consultation in order to identify and mitigate site-specific impacts on tribal cultural resources.
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4.18 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.18 Tribal Cultural Resources.docx (03/11/26) -20 Some of the related projects identified in Table 4.A have undergone environmental review pursuant to CEQA, which included an analysis of potential impacts on tribal cultural resources. According to the EIRs prepared for the Shea Properties Mixed Use Development Project (Related Project 1), Melia Homes-Citrus Square Project (Related Project 2), and the Los Alamitos Medical Center Project (Related Project 7), impacts on tribal cultural resources with implementation of the projects would be less than significant with implementation of measures similar to Mitigation Measures TCR-1 through TCR-4. Further, the EIRs determined that cumulative impacts on tribal cultural resources would be less than significant. In addition, Goodman Commerce Center and the 5665 Plaza Drive Projects (Related Project 3) were analyzed in an Initial Study/Mitigated Negative Declaration in 2023 and an EIR in 2024, respectively, which determined that all impacts on tribal cultural resources would also be less than significant with implementation of measures similar to Mitigation Measures TCR-1 through TCR-4. The Sycamore Creek Charter School Project (Related Project 6) and 4562 Katella Avenue Project (Related Project 8) were determined to be exempt from CEQA review under Section 15332 of the State CEQA Guidelines (for infill development) and Notices of Exemption (NOEs) were prepared. In order for a project to be exempt under Section 15332 of the State CEQA Guidelines, the project must not result in significant impacts due to unusual circumstances, such as being located on a site sensitive for tribal cultural resources. As such, development of the related projects in combination with the proposed project would not result in significant impacts on tribal cultural resources. The LTP Modern Machine Project (Related Project 5) and 8561 Belmont Street Project (Related Project 4) would also be required to undergo environmental review pursuant to CEQA, which would include an analysis of potential impacts on tribal cultural resources, the identification of any mitigation measures to reduce potential impacts, if necessary, and tribal consultation.
In addition, in January 2020, a cultural resource record search was completed as part of the environmental review process for the proposed mixed-use Cypress City Center Project, located directly across Katella Avenue south of the Buildout Area. The record search was conducted at the South Central Coastal Information Center (SCCIC) of the California Historical Resources Information System (CHRIS) at California State University, Fullerton, and included a review of all prehistoric and historic archaeological sites within a 0.25-mile radius of the Cypress City Center Project, which includes the Buildout Area, as well as a review of known cultural resource survey and excavation reports in that area. The California State Historic Resources Inventory (HRI), National Register of Historic Places (National Register), California Historical Landmarks (SHL), California Points of Historical Interest (SPHI), and various local historical registers were examined. No tribal archaeological resources had been previously recorded within the Cypress City Center Project site, and none were discovered as a result of the record search. The Cypress City Center Project was constructed between 2021 and 2025, and no tribal cultural resources were identified during grading or construction activities.
Thus, there is no potential for the proposed project to contribute to a significant cumulative impact associated with the significance of a tribal cultural resource pursuant to California Code of Regulations (CCR) Section 15064.5. Collectively, recent past, approved, and probable future projects that may occur in the vicinity, including the proposed project, would not result in a cumulative increase in impacts on tribal cultural resources or human remains, because these resources would be avoided or otherwise removed, analyzed, and reported (i.e., by a qualified archaeologist). In
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Based on the information in this section (Section 4.18, Tribal Cultural Resources), and in Section 4.5 Cultural Resources, and for the reasons summarized above, the proposed project would not contribute to significant adverse cumulative impacts related to tribal cultural resources when considered together with other cumulative development. Therefore, the cumulative impact on tribal cultural resources would not be cumulatively considerable.
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4.19 UTILITIES AND SERVICE SYSTEMS
This section describes the utility providers within whose jurisdiction the Buildout Area is located and evaluates the potential impacts on utilities and service systems as a result of physical improvements that may be necessary to accommodate the Specific Plan 3.0 Buildout Project (proposed project).
This section is based on multiple data sources, including the Sewer Capacity Study for Specific Plan
3.0 Buildout Project (Sewer Capacity Study)1(Appendix M), the Water Supply Assessment, Specific Plan 3.0 Buildout Project, Cypress, California (WSA)2(Appendix N), the Master Plan of Drainage for Specific Plan 3.0 Buildout Project, 4961 Katella Avenue, Cypress, CA (Drainage Report)3 (Appendix H-1), the California Emissions Estimator Model (CalEEMod) outputs generated for the proposed project (Appendix B), and written correspondence and coordination with utility providers (Appendix O). This section addresses the following utilities and service systems. • Electricity—Southern California Edison (SCE)
• Natural Gas—Southern California Gas Company (SoCalGas) • Solid Waste—Valley Vista Services; Orange County Waste and Recycling (OCWR) • Wastewater—Orange County Sanitation District (OC San) • Potable Domestic Water—Golden State Water Company (GSWC) • Storm Drainage—Orange County Flood Control District (OCFCD) • Telecommunications – AT&T
4.19.1 Scoping Process
The City of Cypress (City) received four 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 utilities and service systems.
4.19.2 Methodology
This section evaluates impacts to utilities and service systems to the extent that project demand for potable water and wastewater, electricity, natural gas, telecommunications facilities, and landfill capacity would require new or expanded facilities to support the proposed project, the construction of which would result in an adverse physical impact to the environment. Information regarding utilities and service systems was obtained from a variety of sources, including technical studies (Appendices M, N, and H-1) prepared for the proposed project, agency websites, and adopted planning documents of the service and utility providers.
This analysis also includes CalEEMod outputs generated for the proposed project, which are included in Appendix B of this Draft EIR. The proposed project’s energy usage, including electricity 1 TAIT & Associates, Inc. 2025b. Sewer Capacity Study for Specific Plan 2.0 Buildout Project, 4961 Katella Avenue Cypress, CA 90720. September. (Appendix M)
2 Golden State Water Company (GSWC). 2025. Water Supply Assessment, Specific Plan 3.0 Buildout Project, Cypress, California. March. (Appendix N)
3 TAIT & Associates, Inc. 2025a. Master Plan of Drainage for Specific Plan 3.0 Buildout Project, 4961 Katella Avenue, Cypress, CA. September 16. (Appendix H-1)
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4.19 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.19 Utilities and Service Systems.docx (03/11/26) -2 and natural gas, as well as the proposed project’s anticipated water demand and estimates for wastewater and solid waste generation were calculated using CalEEMod version 2022.1. In addition, will serve letters were provided by SCE, SoCalGas, OC San, GSWC, and AT&T on June 19, 2025, June 30, 2025, July 3, 2024, August 15, 2023, and June 17, 2025 (Appendix O).
4.19.3 Existing Environmental Setting
4.19.3.1 Electricity
In 2023, California’s electricity was generated primarily by natural gas (36.6 percent), coal (1.8 percent), large hydroelectric (11.7 percent), nuclear (9.3 percent), and solar (17 percent). Total electric generation in California in 2023 was 281,140 gigawatt-hours (GWh).4 The Buildout Area is within the service territory of SCE, which provides services through a grid of transmission lines and related facilities. SCE provides electricity to more than 15 million people in a 50,000-square-mile area of Central, Coastal, and Southern California.5 According to the California Energy Commission (CEC), total electricity consumption in the SCE service area in 2023 was 77,409 GWh6and total electricity consumption in Orange County in 2023 was 18,853 GWh (6,846 GWh for the residential sector and 11,990 GWh for the non-residential sector).7
4.19.3.2 Natural Gas
Natural gas consumed in California is used for electricity generation (45 percent), residential uses (21 percent), industrial uses (25 percent), and commercial uses (9 percent). California continues to depend upon out-of-state imports for nearly 90 percent of its natural gas supply.8SoCalGas, the service provider for the City, serves approximately 21.1 million customers in a 24,000-square-mile service territory.9SoCalGas has four storage fields—Aliso Canyon, Honor Rancho, La Goleta, and Playa del Rey—and has a combined storage capacity of 74 billion cubic feet.10 4 California Energy Commission (CEC). 2024. 2023 Total System Electric Generation. Website: https://www. energy.ca.gov/data-reports/energy-almanac/california-electricity-data/2023-total-system-electricgeneration#:~:text=In%202023%2C%20total%20generation%20for,percent%20in%202022.%20California %27s%20wide (accessed May 23, 2025).
5 Southern California Edison (SCE). n.d. About Us. Website: https://www.sce.com/about-us/who-we-are (accessed May 23, 2025).
6 California Energy Commission (CEC). n.d.-b. Electricity Consumption by Entity. Website: http://www. ecdms.energy.ca.gov/elecbyutil.aspx (accessed November 11, 2025). 7 California Energy Commission (CEC). n.d.-a. Electricity Consumption by County. Website: http://www. ecdmsenergy.ca.gov/elecbycounty.aspx (accessed November 11, 2025). 8 California Energy Commission (CEC). n.d.-e. Supply and Demand of Natural Gas in California. Website:
https://www.energy.ca.gov/data-reports/energy-almanac/californias-natural-gas-market/supply-anddemand-natural-gas-california (accessed May 23, 2025). 9 Southern California Gas Company (SoCalGas). n.d. Company Profile: About SoCalGas. Website:
https://www.socalgas.com/about-us/company-profile (accessed May 23, 2025). 10 United States Energy Information Administration (EIA). 2019. Today in Energy. Website: https://www.eia. gov/todayinenergy/detail.php?id=36416 (accessed May 23, 2025).
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P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.19 Utilities and Service Systems.docx (03/11/26) 4.19-3 According to the CEC, total natural gas consumption in the SoCalGas service area in 2023 was 5,233 million therms11 and total natural gas consumption in Orange County in 2023 was 607.6 million therms (378.9 million therms for the residential sector and 228.7 million therms for the non-residential sector).12
4.19.3.3 Solid Waste
The City currently contracts with Valley Vista Services of Orange County, a private solid waste hauler, to collect and dispose of the solid waste/refuse generated in the City. Solid waste/refuse collected in the City by Valley Vista is transported to one of the Class III landfills operated and maintained by OCWR. Class III landfills only accept non-hazardous municipal solid waste for disposal; no hazardous or liquid waste is accepted. County residents are able to dispose of their household hazardous waste items at any of OCWR’s four household hazardous waste collection centers.
Currently, OCWR maintains and operates three Class III sanitary landfills, identified below in Table 4.19.A: Orange County Class III Landfills.
Table 4.19.A: Orange County Class III Landfills
Landfill Location Service
Frank R. Bowerman 11002 Bee Canyon Access Road
Irvine, CA 92602
Commercial dumping
No public dumping
Olinda Alpha 1942 North Valencia Avenue
Brea, CA 92823
Commercial dumping
Public dumping allowed
Prima Deshecha 32250 La Pata Avenue
San Juan Capistrano, CA 92675
Commercial dumping
Public dumping allowed
Source: Landfill Information (Orange County Waste and Recycling n.d.).
The Frank R. Bowerman Landfill is projected to serve residents and businesses until approximately 2053. The landfill is currently permitted by the California Department of Resources, Recycling, and Recovery (CalRecycle) to receive a maximum of 11,500 tons per day (tpd) of waste, with a currently annual average of 8,500 tpd.13 Therefore, the Frank R. Bowerman Landfill currently operates at approximately 73.0 percent of its daily capacity. As of 2023, the Frank R. Bowerman Landfill had an estimated remaining disposal capacity of 160,896,082 cubic yards.14 11 California Energy Commission (CEC). n.d.-d. Gas Consumption by Entity. Website: https://ecdms.energy. ca.gov/gasbyutil.aspx (accessed November 11, 2025).
12 California Energy Commission (CEC). n.d.-c. Gas Consumption by County. Website: http://www.ecdms. energy.ca.gov/gasbycounty.aspx (accessed November 11, 2025). 13 Orange County Waste & Recycling. n.d. Landfill Information. Website: http://www.oclandfills.com/landfill (accessed May 23, 2025).
14 California Department of Resources, Recycling, and Recovery (CalRecycle). n.d.-a. SWIS Facility Detail, Frank R. Bowerman Sanitary LF (30-AB-0360). Website: https://www2.calrecycle.ca.gov/SolidWaste/Site Activity/Details/2767?siteID=2103 (accessed May 23, 2025).
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4.19 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.19 Utilities and Service Systems.docx (03/11/26) -4 The Olinda Alpha Landfill is scheduled to close in approximately 2036, at which time it will be landscaped to become a County Regional Park.15 The Olinda Alpha Landfill is currently permitted by CalRecycle to receive a maximum of 8,000 tpd of waste, but currently receives an average of approximately 7,000 tpd.16 Therefore, the Olinda Alpha Landfill currently operates at approximately
87.5 percent of its daily capacity. As of October 2020, the Olinda Alpha Landfill had an estimated remaining disposal capacity of 17,500,000 cubic yards.17 The Prima Deshecha Landfill is projected to serve residents and business until approximately 2102 and features several environmental protection measures, including odor control systems, 5.7 acres of wetland, 175 acres of coastal sage scrub, and 11 acres of riparian mitigation.18 The landfill is currently permitted by CalRecycle to receive 4,000 tpd and as of 2023, had a remaining capacity of 128,800,000 cubic yards.19
4.19.3.4 Wastewater
The OC San is responsible for safely collecting, treating, and disposing of the wastewater in central and northwest Orange County, including in the City of Cypress. The OC San provides wastewater collection, treatment, and recycling for approximately 2.6 million people living within its 479 squaremile service area. 20 The OC San’s facilities include 396 miles of sewer pipes and 15 pump stations located throughout the county. The OC San treats approximately 188 million gallons of wastewater from residential, commercial, and industrial sources per day that is sent to two treatment plants:
Reclamation Plant No. 1, located at 10844 Ellis Avenue in Fountain Valley, and Treatment Plant No. 2, located at 22212 Brookhurst Street in Huntington Beach. 21 OC San is responsible for the provision of wastewater treatment facilities that serve the Buildout Area. Sewage from the City of Cypress is diverted to either Reclamation Plant No. 1 or Treatment Plant No. 2. Excess wastewater from any of six trunk sewers tributary to Reclamation Plant No. 1 is diverted to Treatment Plant No. 2 to not overload the capacity of Reclamation Plant No. 1 and to provide for maintenance or construction activities.22 Reclamation Plant No. 1 has a primary 15 Orange County Waste & Recycling. n.d. Landfill Information. Website: http://www.oclandfills.com/landfill (accessed May 23, 2025).
16 Ibid.
17 California Department of Resources Recycling and Recovery (CalRecycle). n.d.-b. SWIS Facility Detail, Olinda Alpha Landfill (30-AB-0035). Website: https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/ Details/2757?siteID=2093 (accessed May 23, 2025).
18 Orange County Waste & Recycling. n.d. Landfill Information. Website: http://www.oclandfills.com/landfill (accessed May 23, 2025).
19 California Department of Resources Recycling and Recovery (CalRecycle). n.d.-c. SWIS Facility Detail, Prima Deshecha Landfill (30-AB-0019). Website: https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/ /2750?siteID=2085 (accessed May 23, 2025).
20 Orange County Sanitation District (OC San). n.d.-a. About Us, General Information, Service Area. Website:
https://www.ocsan.gov/service-area/ (accessed May 23, 2025). 21 Orange County Sanitation District (OC San). 2020. Draft 2020 Program Environmental Impact Report for the 2017 Facilities Master Plan, SCH# 2019070998. September 2020. 22 Orange County Sanitation District (OC San). 2024a. 2023–2024 Annual Report Resource Protection Division Pretreatment Program. Website: https://stage.ocsan.gov/wp-content/uploads/2024/10/OC_San_ Pretreatment_Annual_Report_FY_2023_2024_Final.pdf (accessed June 3, 2025).
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P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.19 Utilities and Service Systems.docx (03/11/26) 4.19-5 treatment capacity of 208 million gallons per day (mgd), 23 and is running under capacity at
approximately 124 mgd.24 Treatment Plant No. 2 has a primary treatment capacity of 168 mgd25 and currently receives 68 mgd.26 Additionally, through its Capital Improvement Program, the OC San strives to continue maintaining its facilities at optimal levels by planning, designing, and preparing for future demand by developing Facilities and Biosolids Master Plans that address 20-year planning horizons.
In the vicinity of the Buildout Area, there are two main existing sewer lines, including (1) a 30-inch vitrified clay pipe (VCP) sewer trunk line owned and maintained by OC San that flows north to south along Lexington Drive to Katella Avenue, and (2) a VCP sewer main owned and maintained by the City that flows east to west along Katella Avenue increasing in diameter from 18-inches to 21-inches.
There is also an 8-inch reach that picks up flows from southeast of the Buildout Area. This line runs in a 15-foot easement to the City of Cypress from north of Vessels Circle south toward Winners Circle and then ties into the City’s 18-inch line. The existing 21-inch VCP City sewer main connects to the existing 30-inch VCP OC San sewer trunk line at an OC San manhole located at the Lexington Drive and Katella Avenue intersection. The existing 30-inch VCP OC San trunk line continues west along Katella Avenue in the City of Los Alamitos and turns south at Los Alamitos Boulevard. The trunk line increases in size as it goes south and then west to the OC San Westside Pump Station.
From the OC San Westside Pump Station, the trunk line eventually drains to OC San Treatment Plant No. 1 in Fountain Valley.
In addition, the existing private sewer line within the Buildout Area flows west towards Lexington Drive where it connects to the 30-inch VCP OC San sewer trunk line. It collects sewage flows from the main racetrack building, support buildings, and from the horse stables. Additionally, there are other existing sewer lines within the Buildout Area, which were not studied in the Sewer Capacity Study, but are tributary to the main sewer lines described above.
4.19.3.5 Potable Domestic Water Service
Domestic water service to the Buildout Area is provided by GSWC. The City is within the Los Alamitos West Orange Service Area. GSWC’s Los Alamitos West Orange Service Area includes Cypress, Los Alamitos, and Stanton; additionally, small portions of Buena Park, Garden Grove, La Palma, Seal Beach, and the unincorporated community of Rossmoor are included. There are approximately 30,100 customers within GSWC’s Los Alamitos West Orange Service Area.27 The Los Alamitos West Orange Service Area 2020 Urban Water Management Plan (UWMP) demonstrates that GSWC has adequate domestic water supply for future water demands in normal, single dry years, and five consecutive dry year conditions through 2045. The entire GSWC West 23 Orange County Sanitation District (OC San). 2024b. Adopted Budget Fiscal Years 2024-2025 and 2025- 2026. Website: https://ocsan.gov/financial-reporting/adopted-budget-fy-2024-25-and-2025-26/ (accessed June 3, 2025).
24 Ibid.
25 Ibid.
26 Ibid.
27 Golden State Water Company (GSWC). n.d. Los Alamitos West Orange County. Website: https://www. gswater.com/los-alamitos (accessed March 2026).
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4.19 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.19 Utilities and Service Systems.docx (03/11/26) -6 Orange system is considered potable and is supplied from two primary sources: local groundwater and imported water purchased from the Metropolitan Water District of Southern California (MWD) through Municipal Water District of Orange County (MWDOC). A small portion of water is also supplied by recycled water from the City of Cerritos and through a contract with the City of Seal Beach. GSWC owns and operates 14 active wells with a combined capacity of 11,850 gallons per minute, which pump local groundwater from the Coastal Plain of Orange County Groundwater Basin. The UWMP includes a water supply and demand assessment that demonstrates that adequate water supply, including both imported groundwater and groundwater from GSWC-owned wells, will be available to GSWC through 2045.
28 The projected water demands for customers served
by GSWC in the Los Alamitos West Orange Service Area is shown in Table 4.19.B: Projected Water Demands by Use Through 2045 (AFY).
Table 4.19.B: Projected Water Demands by Use Through 2045 (AFY) Category Water Demand
2025 2030 2035 2040 2045
Single Family 6,493 6,671 6,855 7,044 7,237
Multi Family 2,667 2,740 2,816 2,893 2,973
Commercial/Institutional 3,283 3,374 3,467 3,562 3,660
Industrial 59 61 62 64 66
Landscape 810 833 856 879 903
Water Loss 825 848 871 895 920
Total 14,137 14,527 14,926 15,337 15,759
Source: West Orange Service Area 2020 Urban Water Management Plan, Table 4-5: Projected Water Demands (GSWC, July 15, 2021).
AFY = acre-feet per year
GSWC = Golden State Water Company
The total water supply available to the GSWC Los Alamitos West Orange Service Area is shown in Table 4.19.C: Total Water Supplies Available to GSWC West Orange Through 2045 (AFY).
Table 4.19.C: Total Water Supplies Available to GSWC West Orange Through 2045 (AFY)
Water Supply 2025 2030 2035 2040 2045
Groundwater 19,800 20,210 20,630 21,062 21,505
MWD of Orange County 2,100 2,100 2,100 2,100 2,100
City of Seal Beach Contract 40 40 40 40 40
Recycled Water 250 250 250 250 250
Total 21,940 22,350 22,770 23,202 23,645
Source: West Orange Service Area 2020 Urban Water Management Plan, Chapter 3 – Water Supply (GSWC, July 15, 2021).
AFY = acre-feet per year
GSWC = Golden State Water Company
MWD = Metropolitan Water District
28 Golden State Water Company (GSWC). 2020. 2020 Urban Water Management Plan, West Orange.
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P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.19 Utilities and Service Systems.docx (03/11/26) 4.19-7 The GSWC Los Alamitos West Orange Service Area only accesses enough water to meet its need in any given year. Accordingly, although some of the supplies available to GSWC Los Alamitos West Orange Service Area are shared among three GSWC service areas, GSWC Los Alamitos West Orange Service Area would not acquire the additional supplies unless they are needed as part of GSWC’s regional water management among the three service areas. As such, the GSWC Los Alamitos West Orange Service Area would acquire the total projected supplies as shown in Table 4.19.C, above.
According to the WSA prepared for the proposed project, the historical water use at the Buildout Area over the past several years (for two meters providing service to the Los Alamitos Race Course (LARC) has averaged approximately 73 acre feet per year (afy).
4.19.3.6 Storm Drain
As discussed in Section 4.10, Hydrology and Water Quality, 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 Lexington Drive, and a small portion of the Buildout Area in the north drains north towards Cerritos Avenue. The Drainage Report (Appendix H-1) identifies six Drainage Areas (A through F) for the Buildout Area under existing conditions, as depicted in Figure 4.10-1 in Section 4.10. Ultimately, all existing stormwater from the Buildout Area discharges to the Los Alamitos Channel. The Los Alamitos Channel is an engineered channel that flows through the County-operated Rossmoor Detention Basin and discharges to the San Gabriel River. The San Gabriel River outlets to the Pacific Ocean at Seal Beach.
4.19.3.7 Telecommunications Facilities
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, DishTV, and DirectTV. These services are privately operated and offered to each location in the City for a fee defined by the provider.
4.19.4 Regulatory Setting
The following section describes the federal, State, regional, and local regulatory framework applicable to analyzing potential impacts related to utilities and service systems from development of the proposed project.
4.19.4.1 Federal Regulations
There are no federal policies or regulations applicable to the proposed project.
4.19.4.2 State Regulations
Water Supply Assessment. California Public Resources Code (PRC) Section 21151.9 requires that any proposed “project,” as defined in Section 10912 of the Water Code, prepare a Water Supply Assessment in compliance with Water Code Section 10910, et seq. Water Code Section 10910 et seq. outlines the necessary information and analysis that must be included in an EIR to ensure that a 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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4.19 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.19 Utilities and Service Systems.docx (03/11/26) -8 proposed land development has a sufficient water supply to meet existing and planned water demand over a 20-year horizon.
According to the Water Supply Assessment requirements, a “project” is defined as any of the following:
• A residential development of more than 500 dwelling units; • A shopping center or business establishment employing more than 1,000 persons or having more than 500,000 square feet (sf) of floor space;
• A commercial office building employing more than 1,000 persons or having more than 250,000 sf of floor space;
• A hotel or motel, or both, having more than 500 rooms; • An industrial, manufacturing, or processing plant, or industrial park planned to house more than 1,000 persons, occupying more than 40 acres of land, or having more than 650,000 sf of floor area;
• A mixed-use project that includes one or more of the projects specified above; and • A project that would demand an amount of water equivalent to, or greater than, the amount of water required by a 500-dwelling-unit project.
If a public water system has fewer than 5,000 service connections, a “project” means any proposed residential, business, commercial, hotel or motel, or industrial development that would account for an increase of 10 percent or more in the number of the public water system’s existing service connections, or a mixed-use project that would demand an amount of water equivalent to, or greater than, the amount of water required by residential development that would represent an increase of 10 percent or more in the number of the public water system’s existing service connections.
The proposed project includes the reasonably foreseeable buildout of the Cypress Town Center and Commons Specific Plan 3.0 (Specific Plan), which would include a maximum buildout of 1,791 dwelling units and 440,000 square feet of non-residential space. A Water Supply Assessment was prepared by Stetson Engineers, Inc. for the proposed project in March 2025 (Appendix N).
Additionally, all future development facilitated by the proposed project would be required to undergo project specific environmental review and prepare site-specific water supply assessments if applicable.
Assembly Bill 341. Assembly Bill (AB) 341 extends the waste diversion requirements established under the California Integrated Waste Management Act of 1989 to the year 2020. In 1989, the California Legislature adopted the California Integrated Waste Management Act of 1989, which is administered by CalRecycle (formerly known as the California Integrated Waste Management Board) and requires each city, county, and regional agency to develop a source reduction and recycling
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P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.19 Utilities and Service Systems.docx (03/11/26) 4.19-9 element of an integrated waste management plan. Each adopted source reduction and recycling element was required to demonstrate the diversion of 50 percent of all solid waste from landfill disposal or transformation by January 1, 2000. Annual progress reports were required to be filed with the State Legislature that included specified information regarding the act. AB 341 further establishes the policy goal of the State that not less than 75 percent of solid waste generated be source-reduced, recycled, or composted by the year 2020. AB 341 requires CalRecycle, by January 1, 2014, to provide a report to the Legislature that provides strategies to achieve that policy goal and also includes other specified information and recommendations in addition to the annual progress report.
Title 24, California Building Code. Energy consumption by new buildings in California is regulated by the Building Energy Efficiency Standards, embodied in Title 24 of the California Code of Regulations (CCR), known as the California Building Code (CBC). The CEC first adopted the Building Energy Efficiency Standards for Residential and Nonresidential Buildings in 1978 in response to a legislative mandate to reduce energy consumption in the State. The CBC is updated every 3 years. The 2022 Building Energy Efficiency Standards became effective on January 1, 2023. The efficiency standards apply to both new construction and rehabilitation of both residential and non-residential buildings, and regulate energy consumed for heating, cooling, ventilation, water heating, and lighting. The building efficiency standards are enforced through the local building permit process. Local government agencies may adopt and enforce energy standards for new buildings, provided these standards meet or exceed those provided in CCR Title 24.
4.19.4.3 Regional Regulations
Metropolitan Water District of Southern California 2020 Urban Water Management Plan.
Metropolitan Water District of Southern California’s (MWD) 2020 Urban Water Management Plan (UWMP) lists and describes the various uses, demand, supplies, target reductions, and compliance measures for 26 member agencies. These include 14 cities, 11 municipal water districts, and one county water authority serving approximately 5,200 square miles including portions of Los Angeles, Orange, Riverside, San Bernardino, San Diego, and Ventura Counties. The 2020 Regional UWMP found that under the current supply demands for a multiple-dry-year scenario (i.e., drought conditions), MWD would have sufficient supply to meet the projected growing demand for water from 2025 to 2045. MWD is currently working to develop programs to increase its water supply and create a large surplus during multiple-dry-year scenarios to ensure that water demands will still be addressed during emergency drought situations.
Municipal Water District of Orange County 2020 Urban Water Management Plan. The region served by the Municipal Water District of Orange County (MWDOC) is located in Orange County, California, and includes 28 cities (including the City of Cypress) and water districts, referred to as MWDOC member agencies. MWDOC’s 2020 UWMP documents information on all sources of water supplies for the region—imported water, groundwater, surface water, recycled water, and wastewater—as a summary of information for regional planning. The plan concludes that the MWDOC service area will have sufficient existing and planned supplies to meet full service demands under every water-year hydrologic scenario from 2020 through 2025. The plan also evaluates each source of water in the region. The resource mix for meeting total demand includes local groundwater, recycled water, surface water, and imported water from MWD. The plan documents 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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4.19.4.4 Local Regulations
Golden State Water Company 2020 Urban Water Management Plan (West Orange). GSWC published its 2020 UWMP for the GSWC Los Alamitos West Orange Service Area, which outlines how GSWC will provide customers with a reliable supply of drinking water for the next 30 years. The 2020 UWMP provides the California Department of Water Resources with information regarding present and future water resources and demands and provides an assessment of GSWC’s water resource needs. The 2020 UWMP utilizes factors that were evaluated in ensuring supply reliability in the MWDOC’s 2020 UWMP and the MWD’s 2020 UWMP.
The UWMP conducts a supply assessment to meet the projected growing demand in its Los Alamitos West Orange Service Area. The UWMP analyzes water supply during multiple-dry-year scenarios to ensure that water demands will still be addressed during emergency drought situations. The UWMP includes these multiple-dry-year scenarios in its analysis of future water demand.
Cypress Town Center and Commons Specific Plan 3.0. The Cypress Town Center and Commons Specific Plan 3.0 does not contain any provisions related to utilities and service systems.
City of Cypress Municipal Code. The Cypress Municipal Code includes the following requirements that would apply to the proposed project related to the provision of utilities:
• Section 12-31 (Required Diversion Rates) of the City’s Municipal Code requires that the applicant for a covered project shall divert, at a minimum, the percentage of construction and demolition debris as specified by the California Green Building Standards. • Section 5-1 (California Building Codes—Adopted) adopts the 2022 California Green Building Standards Code, 2022 Edition (Title 24). Generally, the intent of Title 24 is to provide efficiency standards for new construction and the rehabilitation of both residential and nonresidential buildings, including building energy consumption, water conservation, and operational efficiencies. Title 24 regulates building energy consumption for heating, cooling, ventilation, water heating, and lighting with regard to both electricity and natural gas, while also regulating water consumption through the installation of efficient plumbing fixtures.
4.19.5 Thresholds of Significance
The thresholds of significance for utilities and service system 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 utilities and service systems if it would:
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P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.19 Utilities and Service Systems.docx (03/11/26) 4.19-11 Threshold 4.19.1: Require or result in the relocation or construction of new or expanded water, wastewater treatment or stormwater drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects;
Threshold 4.19.2: Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years; Threshold 4.19.3: Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments; Threshold 4.19.4: Generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals; or
Threshold 4.19.5: Comply with federal, state, and local management and reduction statutes and regulations related to solid waste.
4.19.6 Project Impacts
Threshold 4.19.1: Would the project require or result in the relocation or construction of new or expanded water, wastewater treatment or stormwater drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects? Less Than Significant Impact. The Specific Plan 3.0 Buildout includes development of a maximum of 1,791 residential units and 440,000 square feet of non-residential development within the Buildout Area. Upon full buildout of the Buildout Area, approximately 5,516 residents would be added to the City’s population. In addition, the proposed project would support the City's efforts to meet regional housing needs outlined in the Housing Element and Regional Housing Needs Assessment (RHNA).
4.19.6.1 Water
Construction. During construction, short-term demand for water may occur during project demolition and grading activities, primarily for dust mitigation purposes. Water from the existing potable water lines in the vicinity of the Buildout Area would be used. Overall, short-term construction activities would require minimal water and are not expected to have any adverse impacts on the existing water system or available water supplies. Therefore, construction of the proposed project would not require the construction of new or expanded water conveyance facilities. In addition, as discussed in Section 4.17, Transportation, the proposed project would be required to prepare and implement a Transportation Construction Plan (TCP) during construction activities, which would ensure that if the installation of utility connections and improvements would require temporary road or lane closures, there would be no significant transportation impact during construction. Impacts would be less than significant, and no mitigation is required.
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4.19 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.19 Utilities and Service Systems.docx (03/11/26) -12 Operation. As previously discussed, water service for the proposed project would be provided by the GSWC. 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 during operation of the proposed project. Future development under the proposed project would connect to these existing water lines through new water lines constructed within the proposed Moody Street extension.
The GSWC Los Alamitos West Orange Service Area 2020 UWMP states that annual water use in its service area is expected to be 15,759 acre-feet by 2045. In addition, the 2020 UWMP states that total water supplies available for the service area in 2045 would be 23,645 acre-feet. According to the WSA (Appendix N) prepared for the proposed project, the historical water use at the Buildout Area over the past several years (for two meters providing service to the LARC) has averaged approximately 73 afy and future development facilitated by the proposed project would result in an additional approximately 620 afy of total water use. This accounts for approximately 3.8 percent of the estimated water demand and 2.6 percent of the total available water supplies in the service area for 2045. This represents a minimal increase in water demand within the GSWC Los Alamitos West Orange Service Area. In addition, according to the CalEEMod projections, future development facilitated by the proposed project would result in approximately 185,501,462 gallons per year (gpy) (570 afy) of total water use, including approximately 99,912,926 gpy (307 afy) of indoor water use and approximately 85,588,536 gpy (263 afy) of outdoor water use, which would account for approximately 3.6 percent of the estimated water demand and 2.4 percent of the total available water supplies in the service area for 2045. Further, the WSA prepared for the proposed project indicated that sufficient water supplies exist to meet the existing and future water demands within the GSWC Los Alamitos West Orange Service Area, including the proposed project.
Additionally, some of the 1,791 housing units that would be facilitated under the proposed project would replace existing urban uses that currently use water. Any future projects implemented in accordance with the proposed project would be required to adhere to applicable development regulations pertaining to water, as discussed in Section 4.19.4, Regulatory Setting, and provide required development impact fees. As a part of the development review process, all future projects would be required to demonstrate that existing public utilities would be sufficient to serve the future projects’ needs.
As the new water infrastructure improvements are proposed as part of the project, the environmental impacts associated with construction of the improvements have been discussed and analyzed throughout this Draft EIR. In addition, the GSWC has indicated in a will serve letter that existing water infrastructure in the surrounding area has the capacity to serve the proposed project and sufficient water supplies exist to serve the proposed project. Therefore, operation of the proposed project would not require or result in the relocation or construction of new or expanded water facilities or infrastructure, beyond those proposed as part of the project, the construction or relocation of which could cause significant environmental effects. Impacts would be less than significant, and no mitigation is required.
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4.19.6.2 Wastewater
Construction. No significant increase in wastewater flows is anticipated as a result of construction activities within the Buildout Area as sanitary services during construction would be provided by portable toilet facilities, which transport waste off-site for treatment and disposal. Therefore, construction of the proposed project would not require the construction of new or expanded wastewater conveyance facilities. In addition, as previously discussed, the proposed project would be required to prepare and implement a TCP during construction activities, which would ensure that if the installation of utility connections and improvements would require temporary road or lane closures, there would be no significant transportation impact during construction. Impacts would be less than significant, and no mitigation would be required.
Operation. Wastewater services for the proposed project would be provided by the City of Cypress and the OC San. The proposed project would include the installation of two new sewer connections to existing sewer main lines, including (1) a new 10-inch sewer lateral extending from Lot 2 and connecting to the existing 30-inch sewer trunk line owned and maintained by OC San within Lexington Drive (Sewer Connection A), and (2) a new 8-inch sewer main line that would run north to south along the proposed Moody Street extension (Sewer Connection B), collecting sewer lateral flows from the adjacent lots before connecting to the existing 18-inch VCP City sewer main at the intersection of Moody Street and Katella Avenue. This proposed sewer line would be an 8-inch line where it commences and would gradually increase in size to a 15-inch line at Sewer Connection B. In addition, as recommended by the Sewer Capacity Study, Lots 10 and 11 located on the north side of Vessels Circle would connect to the existing 8-inch City sewer line located southeast of Lot 11.
The Sewer Capacity Study analyzed the hydraulic pipe capacity for the proposed sewer lateral connecting on Lexington Drive, three different locations along the proposed Moody Street Extension sewer main, and for the proposed Vessels Circle Extension sewer lateral that would connect to Moody Street Extension. The results of this analysis demonstrate that the proposed sewer lines would have adequate capacity to serve the proposed project. In addition, the Sewer Capacity Study found that the existing 18-inch pipe at proposed Sewer Connection B and the existing 21-inch pipe at the existing connection to the 30-inch OC San sewer trunk line would be adequate to serve the proposed project and no replacement facilities with increased capacity would be necessary.
As indicated above, the OC San has a capacity to treat 188 million gallons of wastewater per day from residential, commercial, and industrial sources at two plants: Reclamation Plant No. 1 in Fountain Valley and Treatment Plant No. 2 in Huntington Beach. Reclamation Plant No. 1 has a primary treatment capacity of 208 mgd,29 and is running under capacity at approximately 120 mgd.30 Treatment Plant No. 2 has a primary treatment capacity of 168 mgd and currently receives 59 mgd.31 The future residential and non-residential development facilitated by the proposed project is anticipated to generate approximately 276 acre-feet of wastewater annually, or approximately 29 Orange County Sanitation District (OC San). 2019. Budget Update Fiscal Year 2019-2020. Website:
https://www.ocsd.com/Home/ShowDocument?id=28411 (accessed March 2026). 30 Ibid.
31 Orange County Sanitation District (OC San). n.d.-b. Facts and Key Statistics Webpage. Website:
https://www.ocsd.com/services/regional-sewer-service (accessed March 2026).
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4.19 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.19 Utilities and Service Systems.docx (03/11/26) -14 246,398 gallons of wastewater per day.32 This accounts for approximately 0.1 percent of OC San’s daily capacity, the current capacity of Reclamation Plant No. 1, and the current capacity of Reclamation Plant No. 2. In addition, as provided in the Sewer Capacity Study, OC San has provided a Will Serve letter stating that OC San facilities can accommodate the full development of the Buildout Area under the proposed project.
Additionally, some of the 1,791 housing units that would be facilitated under the proposed project would replace existing urban uses that currently generate wastewater and are assumed in OC San’s wastewater generation projections. Any future projects implemented in accordance with the proposed project would be required to adhere to the Specific Plan and comply with applicable development regulations pertaining to wastewater treatment. As a part of the development review process, all future projects would be required to demonstrate that existing public utilities would be sufficient to serve the future projects’ needs.
As the proposed new wastewater infrastructure improvements are proposed as part of the project, the environmental impacts associated with construction of the improvements have been discussed and analyzed throughout this Draft EIR. In addition, OC San has indicated in a will serve letter that existing wastewater infrastructure in the surrounding area has the capacity to serve the proposed project and sufficient capacity at Reclamation Plant No. 1 and No. 2 exists to serve the proposed project. Therefore, operation of the proposed project would not require the relocation or construction of new or expanded wastewater facilities or infrastructure, beyond those proposed as part of the project, the construction or relocation of which could cause significant environmental effects. Impacts would be less than significant, and no mitigation is required.
4.19.6.3 Stormwater/Drainage
Construction. Drainage patterns would be temporarily altered during grading and other construction activities. Specifically, the removal of vegetation can eliminate natural interception of stormwater runoff, resulting in increased flow rate, and grading activities can reshape the ground surface, which would direct stormwater runoff differently than existing conditions. As specified in Section 4.10, Hydrology and Water Quality, if construction of future development associated with the proposed project would disturb greater than 1 acre of soil, those projects would be subject to the requirements of the Construction General Permit, as specified in Regulatory Compliance Measure HYD-1. As required by the Construction General Permit, the Construction Contractor would be required to prepare a Storm Water Pollution Prevention Plan (SWPPP) and implement construction Best Management Practices (BMPs) detailed in the SWPPP during construction activities. The SWPPP would detail the BMPs to be implemented during construction. Construction BMPs would include, but not be limited to, Erosion Control and Sediment Control BMPs designed to minimize erosion and retain sediment on site, and Good Housekeeping BMPs to prevent spills, leaks, and discharge of construction debris and waste into receiving waters. If construction of future development associated with the proposed project would disturb less than 1 acre of soil and are not a part of a larger common plan, those projects would be required to comply with Section 4.106 of the 2022 California Green Building Standards Code (CALGreen Code), as specified in Regulatory 32 In the absence of an official wastewater generation rate, wastewater can be reasonably assumed to be 90 percent of the indoor water use (i.e., 307 afy).
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P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.19 Utilities and Service Systems.docx (03/11/26) 4.19-15 Compliance Measure HYD-1. Section 4.106 of the CALGreen Code requires implementation of BMPs to prevent flooding and erosion and to retain sediment on site. Compliance with the requirements of the Construction General Permit or Section 4.106 of the CALGreen Code, including incorporation of construction BMPs, would ensure that construction impacts related to waste discharge requirements, water quality standards, degradation of water quality, increased pollutant discharge, and alteration of receiving water quality would be less than significant.
In addition, any groundwater extracted during groundwater dewatering activities that is discharged to surface waters would be tested and treated (if necessary) to ensure that any discharges meet the water quality limits specified in the applicable National Pollutant Discharge Elimination System (NPDES) permit, as also specified in in Section 4.10 Hydrology and Water Quality, Regulatory Compliance Measure HYD-2. Regulatory Compliance Measures HYD-1 and HYD-2 are existing NPDES requirements with which the project is required to comply. These measures would prevent substantial additional sources of polluted runoff being discharged to the storm drain system through implementation of construction BMPs that target pollutants of concern in runoff from the Buildout Area as well as testing and treatment (if required) of groundwater prior to its discharge to surface waters.
With implementation of BMPs, construction of the proposed project would not result in a substantial increase in the rate or amount of surface runoff, flow, and volume that would exceed the capacity of the adjacent stormwater drainage systems. Therefore, construction of the proposed project would not require or result in the relocation or construction of new or expanded stormwater drainage facilities, the construction or relocation of which could cause significant environmental effects. In addition, the proposed project would be required to prepare and implement a TCP during construction activities, which would ensure that if the installation of utility connections and improvements would require temporary road or lane closures, there would be no significant transportation impact during construction. Impacts would be less than significant, and no mitigation is required.
Operation. The Drainage Report identifies six Drainage Areas (A through F) for the Buildout Area under existing conditions, as described in Section 4.10, Hydrology and Water Quality, and depicted in Figure 4.10-1 in Section 4.10. Under existing conditions, the southern portion of the Buildout Area drains south towards the Katella Avenue Storm Drain, the northwestern portion of the Buildout Area drains west towards Lexington Drive, and a small portion of the Buildout Area in the north drains north towards Cerritos Avenue. In addition, under existing conditions, stormwater runoff within Drainage Areas E and F discharge to the artificial lakes located within the race course.
Implementation of the proposed project would require modifications to the existing Drainage Areas and the Buildout Area and would include the installation of Storm Drain Lines A, B, and C, as discussed in more detail below. Stormwater would no longer be directed to the existing race track and golf course lakes, which would be removed as part of the proposed project. As such, the number of Drainage Areas would be reduced to three proposed outfalls or Drainage Areas (i.e., Drainage Areas A through C) for hydrology and drainage design, which would meet the City’s discharge requirement of 0.308 cubic feet per second per acre (cfs/acre).
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4.19 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.19 Utilities and Service Systems.docx (03/11/26) -16 There are also 18 proposed Drainage Management Areas (DMAs A1, A2, B, C, D1, D2, E1, E2, F, G1, G2, H1, H2, and S1 through S5) that correspond to the anticipated location of future water quality BMPs. The numbering convention of the Drainage Areas does not correspond exactly between the existing and proposed conditions. Table 4.19.D: Existing and Proposed Drainage Conditions below is provided for clarification and comparison purposes.
Table 4.19.D: Existing and Proposed Drainage Conditions Outfall Location Existing Drainage
Area
Proposed
Drainage Area
Katella Avenue Storm Drain A and B A
Winner’s Circle Storm Drain C -
Lexington Drive Storm Drain D B
Cerritos Avenue Storm Drain E C
Existing Race Track Ponds F -
Source: Master Plan of Drainage for Specific Plan 3.0 Buildout Project, 4961 Katella Avenue, Cypress, CA (TAIT & Associates, Inc., September 16, 2025) (Appendix H-1) The three proposed Drainage Areas are described below and depicted in Figure 4.10-2 in Section 4.10, Hydrology and Water Quality, and the 18 proposed DMAs are described further in Section 4.10 and depicted in Figure 4.10-3 in that section. • Drainage Area A consists of the east and southeast portions of the Buildout Area, southeast of Drainage Area C, and includes approximately 44.76 acres of land. Proposed development within Drainage Area A would include commercial, medium-density residential, and senior housing uses with residential densities of approximately 29.7 and 17.5 dwelling units per acre, respectively. Additionally, the proposed Moody Street Extension south of the proposed Vessels Circle Extension would drain towards Drainage Area A and be captured by proposed catch basins that would discharge to the Katella Avenue Storm Drain. Stormwater within Drainage Area A would generally flow from north to south. Surface flows in this area would be conveyed to new inlet locations which would route the runoff towards a proposed storm drain line in the proposed Moody Street and Vessels Circle extensions (Storm Drain Line A). Storm Drain Line A would begin in Vessels Circle as a 24-inch reinforced concrete pipe (RCP) and would flow east to west towards Moody Street. Along Moody Street, this line would increase in size to a 36-inch storm drain system that would connect to the existing 39-inch Katella Avenue Storm Drain. The Moody Street extension would also include the construction of catch basin inlets that would ensure no surface runoff from the proposed street would spill onto Katella Avenue as it would in the existing condition.
The proposed Drainage Area A consolidated the existing Drainage Area A and Drainage Area B.
In the proposed condition, peak runoff was determined to be less than the existing stormwater runoff, which is due to the implementation of proposed detention basins within the proposed Drainage Area A. Five proposed detention basins, Basins A1, A2, A3, A4, and A5, are proposed in Drainage Area A to reduce the peak runoff from the project site, utilizing the 0.308 cfs/acre maximum discharge rate as required by the City, before ultimately discharging into the Katella Avenue Storm Drain. As discussed, the peak runoff would be greatly reduced when compared to
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P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.19 Utilities and Service Systems.docx (03/11/26) 4.19-17 the existing condition, which would improve the downstream system hydraulic conditions.
Discharge to Katella Avenue would not exceed the existing condition discharge for the 10-, 25- and 100-year expected value storm event.
• Drainage Area B consists of the western portion of the Buildout Area, west of Drainage Area C, and includes approximately 36.78 acres of land. Proposed development within Drainage Area B would include single-family residential, medium-family residential, and senior housing uses.
Stormwater within Drainage Area B would generally flow from northeast to southwest. Surface flows in this area would be conveyed through a proposed storm drain line (Storm Drain Line B) to discharge into the existing 48-inch storm drain line that begins at Enterprise Drive and ultimately connects to the existing 48-inch Lexington Drive Storm Drain. Three detention basins, Basins, Basins B1, B2, and B3, are proposed in Drainage Area B to reduce the peak runoff from the project site, utilizing the 0.308 cfs/acre maximum discharge rate as required by the City. • Drainage Area C consists of the central portion of the Buildout Area, between Drainage Area A and Drainage Area B, and includes approximately 61.87 acres of land. Proposed development within Drainage Area C would include single-family residential and medium-family residential, with the remaining portion to be developed with park and recreational uses. Drainage Area C is divided by the proposed Moody Street extension, with stormwater runoff generated to the west of the street extension set to flow northeasterly and runoff produced to the east of the street extension to flow northwesterly. All surface runoff from Drainage Area C would be conveyed via a proposed storm drain line (Storm Drain Line C) to the proposed detention basin, Basin C in the park area. Depending on the final design considerations of the ultimate buildout condition, 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. The stormwater runoff collected in Basin C would be fully retained during the storm event until the flow in the Cerritos Avenue Storm Drain system has fully subsided. Then, the runoff volume stored in Basin C would be pumped out to the Cerritos Avenue Storm Drain at a rate specified by the maximum conveyance capacity of the line.
As discussed above, the proposed project would include on and off-site upgrades to stormwater infrastructure, including the installation of a proposed storm drain line in the proposed Moody Street and Vessels Circle extensions (Storm Drain Line A), a proposed storm drain line in Drainage Area B that connects to the existing 48-inch storm drain line that begins at Enterprise Drive and ultimately connects to the existing 48-inch Lexington Drive Storm Drain (Storm Drain Line B), and a proposed storm drain line that would convey stormwater runoff from Drainage Area A to the proposed Basin C in the park area (Storm Drain Line C).
Drainage Area A also includes DMA-S4 and DMA-8. DMA-S4 includes approximately 0.23 acre of the proposed Vessels Circle extension and is already developed with the Melia Homes, Belmont residential project. Within DMA-S4, the existing drainage pattern would be maintained, and runoff flows would be captured and treated via a proprietary flow-based biofiltration system and discharged to the proposed storm drain line in the proposed Vessels Circle extension (Storm Drain Line A) and ultimately the Walker Street Storm Drain.
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4.19 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.19 Utilities and Service Systems.docx (03/11/26) -18 Approximately 11.57 acres of Drainage Area A is comprised of a portion of the Grace Church property and a portion of the existing race track that will be transferred by LARC to Grace Church as part of the land swap (Lot 8, per separate agreement and as depicted in the Vesting Tentative Tract Map [VTTM]). DMA-8 includes approximately 4.18 acres of Lot 8 that would be owned by Grace Church as part of this land swap deal. This portion of the Grace Church property currently discharges to the eastern Race Course Pond pursuant to a Declaration of Drainage Easement recorded on November 12, 2010, as Instrument No. 2010 in the Official Records of Orange County, California. As permitted by this easement agreement, the redevelopment of the LARC property would require an alteration in the design of the Grace Church drainage system. To preserve the existing drainage pattern of the Grace Church property, a proposed surface-level detention basin would be graded in Lot 8 (Lot 8 Basin) that intercepts the flows of the existing double 24-inch RCP line from Grace Church. Stormwater runoff within DMA-8 would either be treated via a proprietary flow-based biofiltration system or the Lot 8 Basin, depending on the final site design. The construction of the Lot 8 Basin will be done concurrently with the redevelopment of any portion of Lot 7 that would eliminate the use of the eastern Race Course Pond. Discharge from the Lot 8 Basin would be pumped to Storm Drain Line A within Vessels Circle, at a controlled rate of 0.308 cfs/acre of its tributary area during the 100-year storm event. All improvements to Lot 8 related to the Grace Church drainage system would be completed by the project Applicant per the Drainage Easement.
Ultimately, all stormwater from the Buildout Area would discharge to the Los Alamitos Channel, similar to the existing conditions. The proposed on-site storm drain system would be adequately sized to accommodate stormwater runoff so that on-site flooding would not occur.
With implementation of the proposed storm drain systems and detention system, as specified in Regulatory Compliance Measure HYD-3, operation of the proposed project would not result in a substantial increase in the rate or amount of surface runoff, flow, and volume that would exceed the capacity of the adjacent stormwater drainage systems. As the proposed stormwater infrastructure improvements are proposed as part of the project, the environmental impacts associated with construction of the improvements have been discussed and analyzed throughout this Draft EIR. In addition, the proposed stormwater infrastructure would be appropriately sized in order to ensure that stormwater runoff from the Buildout Area would be adequately accommodated by the existing stormwater infrastructure in the area. Therefore, operation of the proposed project would not require or result in the relocation or construction of new or expanded stormwater drainage facilities, beyond those proposed as part of the project, the construction or relocation of which could cause significant environmental effects. Impacts would be less than significant, and no mitigation is required.
Additionally, all future projects implemented in accordance with the proposed project would be required to adhere to the Specific Plan, provide required development impact fees, and comply with applicable development regulations pertaining to stormwater drainage. As a part of the development review process, all future projects would be required to demonstrate that existing public utilities would be sufficient to serve the future projects’ needs. As such, the proposed project would not require the relocation or construction of new or expanded stormwater facilities or infrastructure and impacts would be less than significant. No mitigation is required.
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4.19.6.4 Electric Power
Construction. Short-term construction activities associated with demolition of on-site structures would be limited to providing power to the staging area and portable construction equipment and would not substantially increase demand for electricity. The heavy equipment used for demolition and or construction is primarily powered by diesel fuel. Temporary electric power would be provided via existing utility boxes and lines within the Buildout Area. Given the limited nature of potential demand for electricity during construction and the availability of existing power lines on the site, there would not be a need to construct new or alter existing electric transmission facilities.
In addition, the proposed project would be required to prepare and implement a TCP during construction activities, which would ensure that if the installation of utility connections and improvements would require temporary road or lane closures, there would be no significant transportation impact during construction. Impacts would be less than significant, and no mitigation is required.
Operation. The Buildout Area is within the service territory of SCE, which provides services through a grid of transmission lines and related facilities. As discussed previously, according to the CEC, total electricity consumption in the SCE service area in 2023 was 77,409 GWh33 and total electricity consumption in Orange County in 2023 was 18,853 GWh (6,846 GWh for the residential sector and 11,990 GWh for the non-residential sector).
34 Based on the CalEEMod results for the proposed
project, the estimated electricity demand associated with the operation of the proposed project is approximately 11,888,842 kilowatt-hours (kWh) per year. Therefore, operation of the future development facilitated by the proposed project would increase annual electricity consumption in the SEC service area and Orange County by approximately 0.01 and 0.06 percent, respectively.
Consequently, anticipated electricity consumption by the proposed project is negligible (less than
0.1 percent) compared to the total consumption of the SCE service area and Orange County.
Additionally, any future projects implemented in accordance with the proposed project would be required to adhere to the Specific Plan and comply with applicable development regulations pertaining to electric power. As a part of the development review process, all future projects would be required to demonstrate that existing public utilities would be sufficient to serve the future projects’ needs. In addition, SCE provided a will serve letter on June 19, 2025, indicating that they have the ability to serve the proposed project.
As such, the proposed project would not require the relocation or construction of new or expanded electrical facilities or infrastructure, and impacts would be less than significant. No mitigation is required.
33 California Energy Commission (CEC). n.d.-b. Electricity Consumption by Entity. Website: http://www. ecdms.energy.ca.gov/elecbyutil.aspx (accessed November 11, 2025). 34 California Energy Commission (CEC). n.d.-a. Electricity Consumption by County. Website: http://www. ecdms.energy.ca.gov/elecbycounty.aspx (accessed November 11, 2025).
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4.19.6.5 Natural Gas
Construction. Project construction would not result in demand for natural gas since construction activities/equipment would not require natural gas or connect existing adjacent natural gas facilities. Therefore, construction activities would not impact natural gas services and the proposed project would not require new or physically altered gas transmission facilities. In addition, the proposed project would be required to prepare and implement a TCP during construction activities, which would ensure that if the installation of utility connections and improvements would require temporary road or lane closures, there would be no significant transportation impact during construction. Impacts would be less than significant, and no mitigation is required.
Operation. As discussed above, natural gas would continue to be provided to the Buildout Area by SoCalGas. Future development under the proposed project would include connections to existing natural gas infrastructure in the surrounding area. SoCalGas, the service provider for the City, serves approximately 21.1 million customers in a 24,000-square-mile service territory.35 According to the CEC, total natural gas consumption in the SoCalGas service area in 2023 was 5,233 million therms 36 and total natural gas consumption in Orange County in 2023 was 607.6 million therms (378.9 million therms for the residential sector and 228.7 million therms for the non-residential sector).37 CalEEMod was used to calculate the approximate annual natural gas associated with future development under the proposed project. Based on the CalEEMod results for the proposed project, the estimated potential increase in natural gas demand in the Buildout Area is anticipated to be approximately 38,243,251 thousand British thermal units (kBTU) per year, or approximately 382,524 therms per year. Therefore, operation of the new residential development allowed under the proposed project would increase annual consumption in the SoCalGas service area and Orange County by approximately 0.008 and 0.07 percent, respectively. Consequently, the anticipated natural gas consumption by the proposed project would be negligible (less than 0.1 percent) compared to the total consumption of the SoCalGas service area and Orange County. The proposed project would not require the construction of any physical improvements related to the provision of natural gas service that would result in significant environmental impact.
Additionally, any future projects implemented in accordance with the proposed project would be required to adhere to the Specific Plan, provide required development impact fees, and comply with applicable development regulations pertaining to natural gas. As a part of the development review process, all future projects would be required to demonstrate that existing public utilities would be sufficient to serve the future projects’ needs. In addition, SoCalGas provided a will serve letter on June 30, 2025, indicating that they have the ability to serve the proposed project.
As such, the proposed project would not require the relocation or construction of new or expanded natural gas facilities or infrastructure, and impacts would be less than significant. No mitigation is required.
35 Southern California Gas Company (SoCalGas). n.d. Company Profile: About SoCalGas. Website:
https://www.socalgas.com/about-us/company-profile (accessed May 23, 2025). 36 California Energy Commission (CEC). n.d.-d. Gas Consumption by Entity. Website: https://ecdms.energy. ca.gov/gasbyutil.aspx (accessed November 11, 2025).
37 California Energy Commission (CEC). n.d.-c. Gas Consumption by County. Website: http://www.ecdms. energy.ca.gov/gasbycounty.aspx (accessed November 11, 2025).
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4.19.6.6 Telecommunication Facilities
Telephone, television, and internet services are offered by a variety of providers in the City. Any future development facilitated by the proposed project would be responsible for constructing adequate tele-communication facility extensions on their respective project sites. The construction and expansion of these facilities would occur on site during the site preparation and earthwork phase and are not expected to impact any telephone, cable, or internet services offsite that serve the surrounding areas. Additionally, telecommunication facilities are generally installed concurrently with utility expansions and impacts associated with the expansion of telecommunications facilities are already considered in the air quality, noise, and construction traffic analysis. In addition, as previously discussed, the proposed project would be required to prepare and implement a TCP during construction activities, which would ensure that if the installation of utility connections and improvements would require temporary road or lane closures, there would be no significant transportation impact during construction. Therefore, the project impacts associated with the relocation or construction of new or expanded telecommunication facilities and impacts would be less than significant. No mitigation is required.
Threshold 4.19.2: Would the project have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years?
Less Than Significant Impact. As discussed above, although the proposed project would not directly result in physical development, the proposed project could result in the development of up to 1,791 residential units and 440,000 square feet of non-residential development within the Buildout Area, which could add approximately 5,516 residents to the City’s population.38 According to the 2020 UWMP, GSWC’s available water supply would meet the future projected demand for normal year demands from 2025 through 2045. GSWC’s Los Alamitos West Orange Service Area has a diverse water supply portfolio that allows GSWC to conjunctively use surface and groundwater assets. Water supply reliability is a result of the projected reliability of MWDOC, a member agency of MWD, which expects to provide reliable imported water supplies, OCWD management of the Orange County Groundwater Basin to ensure reliability, and conservation derived supply. Groundwater imported water from MWDOC, and the small amount of recycled water delivered within the service area by the City of Cerritos and the City of Seal Beach are all resilient during dry conditions and GSWC Los Alamitos West Orange Service Area is therefore not faced with shortages during normal or dry years.
As discussed above and according to the WSA (Appendix N) prepared for the proposed project, the historical water use at the Buildout Area over the past several years (for two meters providing service to the LARC) has averaged approximately 73 afy, and future development facilitated by the proposed project would result in an additional approximately 620 afy of total water use. This accounts for approximately 3.8 percent of the estimated water demand and 2.6 percent of the total available water supplies in the service area for 2045. This represents a minimal increase in water demand within the GSWC Los Alamitos West Orange Service Area. In addition, according to the 38 1,791 households x 3.08 persons per household = 5,516 persons 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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4.19 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.19 Utilities and Service Systems.docx (03/11/26) -22 CalEEMod estimates, future development facilitated by the proposed project would result in approximately 185,501,462 gpy (570 afy) of total water use, including approximately 99,912,926 gpy (307 afy) of indoor water use and approximately 85,588,536 gpy (263 afy) of outdoor water use, which accounts for approximately 3.6 percent of the estimated water demand and 2.4 percent of the total available water supplies in the service area for 2045. Further, as discussed above, the WSA prepared for the proposed project indicated that sufficient water supplies exist to meet the existing and future water demands within the GSWC Los Alamitos West Orange Service Area, including the proposed project. Therefore, the proposed project would not result in insufficient water supplies during normal, dry, and multiple dry years, and adequate water supply would be available to accommodate the future development in the Buildout Area facilitated by the proposed project. The proposed project would increase demand for water supplies; however, the GSWC would have sufficient water supplies to serve the proposed project. Therefore, the proposed project would result in less than significant impacts related to water supplies. No mitigation is required.
Threshold 4.11.3: Would the project result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?
Less Than Significant Impact. As discussed above, sewage from the City is diverted to either Reclamation Plant No. 1 in Fountain Valley or Treatment Plant No. 2 in Huntington Beach.
Reclamation Plant No. 1 has a primary treatment capacity of 208 million gallons per day (mgd),39 and is running under capacity at approximately 120 mgd.40 Treatment Plant No. 2 has a primary treatment capacity of 16841 mgd and currently receives 59 mgd.42 Construction. During construction, wastewater would be generated by construction workers, and sanitary services would be provided by portable toilet facilities, which would transport waste off-site for treatment and disposal at either Reclamation Plant No. 1 in Fountain Valley or Treatment Plant No. 2 in Huntington Beach. As construction activities would be temporary, the wastewater treatment provider is anticipated to have adequate capacity to serve the projected wastewater demand in addition to the provider’s existing commitments. Impacts would be less than significant, and no mitigation is required.
Operation. As discussed above, the future residential and non-residential development facilitated by the proposed project is anticipated to generate approximately 276 acre-feet of wastewater annually, or approximately 246,398 gallons of wastewater per day.43 This accounts for 39 Orange County Sanitation District (OC San). 2019. Budget Update Fiscal Year 2019-2020. Website:
https://www.ocsan.gov/wp-content/uploads/2024/06/Adopted-Budget-Update-FY-2019.pdf (accessed May 23, 2025).
40 Ibid.
41 Ibid.
42 Orange County Sanitation District (OC San). n.d.-b. Facts and Key Statistics. Website: https://www. ocsd.com/services/regional-sewer-service (accessed May 23, 2025). 43 In the absence of an official wastewater generate rate, wastewater can be reasonably assumed to be 90 percent of the indoor water use.
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P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.19 Utilities and Service Systems.docx (03/11/26) 4.19-23 approximately 0.1 percent of OC San’s daily capacity, the current capacity of Reclamation Plant No. 1, and the current capacity of Reclamation Plant No. 2. In addition, as provided in the Sewer Capacity Study, OC San has provided a Will Serve letter stating that OC San facilities can accommodate the full development of the Buildout Area under the proposed project. Additionally, through its Capital Improvement Program, the OC San strives to continue maintaining its facilities at optimal levels by planning, designing, and preparing for future demand by developing Facilities and Biosolids Master Plans that address 20-year planning horizons.44 Through these long-range planning activities, the OC San would be able to accommodate the growth in demand for wastewater treatment generated by the proposed project and other projects in its service area. Therefore, the proposed project would not result in a significant contribution to demands on the treatment capacity of Reclamation Plant No. 1 or Treatment Plant No. 2. Additionally, fees required by the OC San would sufficiently offset potential impacts generated by the proposed project. Furthermore, some of the 1,791 housing units that would be facilitated under the proposed project would replace existing urban uses that currently generate wastewater.
Therefore, the proposed project would result in less than significant impacts related to the wastewater treatment capacity and no mitigation is required.
Threshold 4.11.4: Would the project generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?
Less Than Significant Impact. As previously discussed, the City currently contracts with Valley Vista Services of Orange County, a private solid waste hauler, to collect and dispose of the solid waste/refuse generated in the City. Solid waste/refuse collected in the City by Valley Vista is transported to one of the Class III landfills operated and maintained by OCWR. Class III landfills only accept non-hazardous municipal solid waste for disposal; no hazardous or liquid waste is accepted.
County residents are able to dispose of their household hazardous waste items at any of OCWR’s four household hazardous waste collection centers. Currently, OCWR maintains and operates three Class III sanitary landfills: Frank R. Bowerman Landfill, Prima Deshecha Landfill, and Olinda Alpha Landfill.
Construction. The demolition of the existing structures within the Buildout Area and the future construction of the proposed project would generate typical construction debris, including wood, paper, glass, metals, cardboard, and green wastes. Construction of the proposed project would be required to comply with the City’s Construction and Demolition Ordinance, as detailed in Regulatory Compliance Measure UTIL-1, which requires that the applicants for future development submit a Materials Questionnaire should the contractor haul away their own demolition waste. As stipulated by City Ordinance No. 1166 and the California Green Building Standards Code, the proposed project would be required to divert a minimum of 65 percent of construction and demolition debris in order to obtain building permits.45 Additionally, Valley Vista Services certifies 75 percent diversion for all 44 In the absence of an official wastewater generation rate, wastewater can be reasonably assumed to be 90 percent of the indoor water use.
45 City of Cypress. 2021. C&D Recycling Requirement. Website: C&D Recycling Requirement, City of Cypress (cypressca.org) (accessed June 3, 2025).
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4.19 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.19 Utilities and Service Systems.docx (03/11/26) -24 construction and demolition material, which would contribute to an increased waste diversion rate within the City.46 Therefore, adherence to Regulatory Compliance Measure UTIL-1, City Ordinance No. 1166, and the California Green Building Standards Code would ensure that construction impacts related to solid waste generation from any future projects developed in accordance with the proposed project would remain less than significant. No mitigation is required.
Operation. Solid waste from future development allowed under the proposed project would be required to comply with State and local solid waste reduction, diversion, and recycling policies and regulations. According to CalEEMod calculations, the future development facilitated by the proposed project would generate approximately 1,811 tons of solid waste per year. Currently, OCWR maintains and operates three Class III sanitary landfills including the Frank R. Bowerman Landfill, Olinda Alpha Landfill, and Prima Deshecha Landfill.
The Frank R. Bowerman Landfill is currently permitted by the California Department of Resources, Recycling, and Recovery (CalRecycle) to receive a maximum of 11,500 tons per day (tpd) of waste, with a current annual average of 8,500 tpd. The Olinda Alpha Landfill is currently permitted by CalRecycle to receive a maximum of 8,000 tpd of waste but currently receives an average of approximately 7,000 tpd. The Prima Deshecha Landfill is currently permitted by CalRecycle to receive 4,000 tpd. The additional solid waste generation of 1,811 tons of solid waste per year, or approximately 5 tpd, facilitated by the proposed project represents 0.04 percent, 0.06 percent, and
0.1 percent of the daily permitted tonnage of the Frank R. Bowerman Landfill, Olinda Alpha Landfill, and Prima Deshecha Landfill, respectively. Consequently, anticipated solid waste generation by the proposed project is negligible (substantially less than 0.1 percent) compared to the total amount of solid waste received by the three landfills. The proposed project would not require the construction of any physical improvements related to the provision of solid waste disposal that would result in significant environmental impacts and the OCWR solid waste disposal system would have adequate capacity to serve the proposed project. Furthermore, some of the future development that would be facilitated by the proposed project would replace existing urban uses, most of which currently generate solid waste.
Threshold 4.19.5: Would the project comply with federal, state, and local management and reduction statutes and regulations related to solid waste? Solid waste from future development facilitated by the proposed project would be required to comply with State and local solid waste reduction, diversion, and recycling policies and regulations.
According to CalEEMod calculations, the future development facilitated by the proposed project would generate approximately 1,811 tons of solid waste per year. As discussed above, the additional solid waste generated by the proposed project represents 0.04 percent, 0.06 percent, and
0.1 percent of the daily permitted tonnage of the Frank R. Bowerman Landfill, Olinda Alpha Landfill, and Prima Deshecha Landfill, respectively. Consequently, anticipated solid waste generation by the proposed project is negligible (substantially less than 0.1 percent) compared to the total amount of solid waste received by the three landfills. The proposed project would not require the construction of any physical improvements related to the provision of solid waste disposal that would result in 46 City of Cypress. 2021. C&D Recycling Requirement. Website: C&D Recycling Requirement, City of Cypress (cypressca.org) (accessed June 3, 2025).
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P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.19 Utilities and Service Systems.docx (03/11/26) 4.19-25 significant environmental impacts and the OCWR solid waste disposal system would have adequate capacity to serve the proposed project. Furthermore, some of the 1,791 housing units that would be facilitated under the proposed project would replace existing urban uses, most of which currently generate solid waste.
Construction and operation of the proposed project would comply with federal, State, and local statutes and regulations related to solid waste, including AB 1327 (wood waste disposal), Chapter 18 of the California Solid Waste Reuse and Recycling Access Act of 1991 (requires adequate, permanent space for recycling and solid waste collection at new developments), AB 939 (CalRecycle), AB 75 (solid waste diversion), AB 1826 (organic waste recycling), and SB 1383 (organic waste collection services).
Therefore, impacts related to solid waste generation from any future projects developed in accordance with the proposed project would be less than significant. No mitigation is required.
4.19.7 Level of Significance Prior to Mitigation
The proposed project would result in less than significant impacts related to utilities and service systems.
4.19.8 Regulatory Compliance Measures and Mitigation Measures
4.19.8.1 Regulatory Compliance Measures
The following regulatory compliance measures pertaining to utilities and service systems are applicable to the proposed project.
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.
4.19.8.2 Mitigation Measures
No mitigation measures are applicable to the proposed project.
4.19.9 Level of Significance after Mitigation
The proposed project would not result in any significant impacts to utilities or service systems. No mitigation is required.
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4.19.10 Cumulative Impacts
As defined in Section 15130 of the State CEQA Guidelines, cumulative impacts refer to 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 public services. The cumulative study area for utilities and service systems is the City of Cypress. The cumulative project list is provided in Table 4.A: Summary of Related Projects, and a map of the cumulative project locations is provided in Figure 4-1: Related Projects, in Chapter 4.0, Existing Setting, of this Draft EIR.
As discussed in Section 4.14, Population and Housing, the proposed project would accommodate up to 1,791 residential units within the Buildout Area, supporting the City's efforts to meet regional housing needs outlined in the Housing Element and RHNA. The RHNA process identified that the City is in need of 3,936 units, and the proposed project could, at a maximum, accommodate 1,791 of those units. Utilizing the average number of people per household as identified by the U.S. Census Bureau (3.08), the proposed project would include population growth by an additional 5,516 people.
Although the proposed project would facilitate the development of new housing in the City, the new housing would not induce substantial unplanned population growth, as the proposed project is designed to meet the City’s housing need allocation for the planning period between 2021 and 2029 of 3,936 units as determined by the Southern California Association of Governments (SCAG) RHNA.
As such, population growth generated by the proposed project in conjunction with related projects has already been accounted for in the City’s planning efforts. Because this population increase is consistent with the population growth for the City and region, increased utility demands associated with the residential component of the proposed project is also consistent with growth in the City and region.
Any future projects implemented in accordance with the proposed project would be required to adhere to the Specific Plan, provide applicable development impact fees, and comply with applicable development regulations pertaining to water, wastewater treatment, stormwater drainage, electric power, natural gas, or telecommunications facilities. Although the proposed project includes the construction of new utility infrastructure, including water, wastewater, stormwater drainage, electricity, and natural gas connections and improvements both on- and offsite (i.e., the Grace Church property), the environmental impacts associated with construction of these improvements have been discussed and analyzed throughout this Draft EIR. In addition, as discussed in Section 4.17, Transportation, the proposed project would be required to prepare and implement a TCP during construction activities, which would ensure that if the installation of utility connections and improvements would require temporary road or lane closures, there would be no significant transportation impact during construction.
Additionally, adequate water supply is available to accommodate the future development facilitated by the proposed project. Solid waste and wastewater generated by the new development facilitated by the proposed project could be accommodated with existing infrastructure and would not lead to a significant increase that would alter the capacity of the existing solid waste and wastewater infrastructure set in place. Any future projects would be required to comply with existing and future statutes and regulations, including waste diversion programs mandated by City, State, and federal law.
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P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.19 Utilities and Service Systems.docx (03/11/26) 4.19-27 In addition, some of the related projects identified in Table 4.A have undergone environmental review pursuant to CEQA, which included an analysis of potential impacts on utilities and service systems. According to the EIRs prepared for the Shea Properties Mixed Use Development Project (Related Project 1), Melia Homes-Citrus Square Project (Related Project 2), and the Los Alamitos Medical Center Project (Related Project 7), these projects including new on-site infrastructure and connections to existing infrastructure in the surrounding area and impacts on utilities and service systems would be less than significant with implementation of the projects. Further, the EIRs determined that cumulative impacts related to utilities and service systems would be less than significant. In addition, Goodman Commerce Center and the 5665 Plaza Drive Projects (Related Project 3) were analyzed in an Initial Study/Mitigated Negative Declaration (IS/MND) in 2023 and an EIR in 2024, respectively. The Goodman Commerce Center and the 5665 Plaza Drive Projects included the construction of new on-site water and wastewater lines which would connect to existing water lines and sewer mains within Plaza Drive and new connections to the existing electricity infrastructure, and the 2023 IS/MND and 2025 EIR determined that all impacts on utilities and service systems would be less than significant. In addition, the environmental documents for these projects required adherence to measures similar to Regulatory Compliance Measure UTIL-1.
While the construction of utility improvements associated with the proposed project and the related projects may be constructed currently, based on the distance between the Buildout Area and the related project sites, construction of the utility improvements and connections to existing infrastructure are not expected to result in cumulative environmental impacts.
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 site must be adequately served by all required utilities and public services. As such, development of the related projects in combination with the proposed project would not result in significant impacts on utilities and service systems. The LTP Modern Machine Project (Related Project 5) and 8561 Belmont Street Project (Related Project 4) would also be required to undergo environmental review pursuant to CEQA, which would include an analysis of potential impacts on utilities and service systems and the identification of any mitigation measures to reduce potential impacts, if necessary.
Implementation of the proposed project, in conjunction with reasonably foreseeable development in the surrounding area, may result in cumulative impacts to utility infrastructure and service capacity. However, developers of future development projects facilitated by the proposed project, as well any projects associated with the City’s buildout assumptions, would be required to analyze potential impacts to utilities systems, ensure that utility providers would have adequate capacity and supply to serve the projects as well as existing conditions, and would be required to comply with existing and future statutes and regulations, including waste diversion programs mandated by City, State, and federal law. Therefore, the impacts from the proposed project would not be considered cumulatively considerable.
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4.20 WILDFIRE
This section evaluates the potential for implementation of the Specific Plan 3.0 Buildout Project (proposed project) to result in wildfire-related impacts. This section also describes the existing setting within and near the Buildout Area and sets forth the relevant regulatory requirements that apply to the proposed project’s potential impacts on wildfire. This section incorporates data from the Safety Element of the Cypress General Plan,
1 the Orange County Local Hazard Mitigation Plan,
2 and a review of existing resources, technical data, and applicable laws, regulations, and guidelines.
4.20.1 Scoping Process
The City of Cypress (City) received six comment letters during the public review period of the Notice of Preparation (NOP). For copies of the NOP comment letters, refer to Appendix A of this Draft Environmental Impact Report (Draft EIR). No comment letters included comments related to wildfire.
4.20.2 Methodology
The potential wildfire-related impacts from project-related activities were evaluated qualitatively based on information provided in documents and maps obtained from the City’s General Plan, the Orange County Fire Authority’s (OCFA) Local Hazard Mitigation Plan, and the California Department of Forestry and Fire Protection (CAL FIRE).
4.20.3 Existing Environmental Setting
Fire environments are dynamic systems and include many types of environmental factors and site characteristics. Fires can occur in any environment where conditions are conducive to ignition and fire movement. Areas of naturally vegetated open space typically provide conditions that may be favorable to wildfire spread. The three major components of the fire environment are topography, climate, and vegetation (fuels). The state of each of these components and their interactions with each other determines the potential characteristics and behavior of a fire at any given moment.
A wildfire is a nonstructural fire that occurs in vegetative fuels. Wildfire generally does not include prescribed or controlled fires set by firefighters to manage fuel loads in fire-prone landscapes.
Wildfire ignition sources may include lightning, improperly managed campfires, cigarettes, arson, sparks from automobiles, lawnmowers, and maintenance equipment, and other sources. It is important to note that wildland fire may transition to urban fire if structures are receptive to ignition. Structure ignition depends on a variety of factors and can be prevented through a layered system of protective features including fire-resistive landscapes adjacent to structure(s), application of known ignition-resistive materials and methods, and suitable infrastructure for firefighting purposes. Understanding the existing wildland vegetation and urban fuel conditions on and adjacent to the site is necessary to understand the potential for fire within and around the Buildout Area. 1 City of Cypress. 2001. Cypress General Plan Safety Element. September. 2 County of Orange & Orange County Fire Authority. 2015. Local Hazard Mitigation Plan. Website:
https://www.smwd.com/DocumentCenter/View/2193/APPENDIX-H_OC-HMP-Final (accessed August 2025).
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4.20 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.20 Wildfire.docx (03/11/26) -2 CAL FIRE has classified lands within State Responsibility Areas (SRAs) into Fire Hazard Severity Zones (FHSZs). FHSZs include the following classifications: Moderate, High, and Very High. FHSZs have been developed using a model that assigns a hazard score based on the factors that influence fire likelihood and fire behavior including fire history, existing and potential fuel (natural vegetation), predicted flame length, blowing embers, terrain, and typical fire weather for the area. As part of this mapping system, lands where CAL FIRE is responsible for wildland fire protection are generally located in unincorporated areas and are classified as SRAs. Where local fire protection agencies (e.g., OCFA) are responsible for wildfire protection, the lands are classified as Local Responsibility Areas (LRAs). CAL FIRE currently identifies the Buildout Area as an LRA. 3 In addition, according to CAL FIRE, the Buildout Area is not in a Very High Fire Hazard Severity Zone (VHFHSZ). The nearest VHFHSZs are located approximately 6.8 miles northeast of the Buildout Area in the West Coyote Hills area of Fullerton (northern Orange County).
The following sections discuss the characteristics of the Buildout Area, as well as the site characteristics, local climate, and fire history within and immediately surrounding the site. The intent of evaluating conditions at this macro-scale is to provide a better understanding of the regional fire environment, which is not constrained by property boundary delineations.
4.20.3.1 Climate and Topography
The City is located on relatively flat terrain in northwestern Orange County with City elevations ranging from 20 to 75 feet above mean sea level. According to the Environmental Impact Report, Soils and Geology Issues, Proposed Mixed-Use Development, 4961 Katella Avenue and 5100 Cerritos Avenue, Cypress, California (Geotechnical Investigation) in Appendix F, prepared by Geotechnologies, Inc. in 2024,
4 the Buildout Area is relatively flat with no pronounced elevation changes.5
The City is situated within an area typified by a Mediterranean climate, which is characterized by mild winters and dry, warm summers with an average July maximum temperature of 79 degrees Fahrenheit and an average January maximum daily temperature of 64 degrees Fahrenheit. The record high and low temperatures have been 108 and 28 degrees Fahrenheit, respectively.6 Fires are most common during the summer and fall, before the rainy period, especially during dry Santa Ana wind events. The City and Buildout Area are subject to periodic high winds including Santa Ana winds. Although Santa Ana wind events can occur at any time of the year, they generally occur during the autumn months, although the last few years have resulted in spring and summer events as well. Santa Ana winds may gust up to 75 miles per hour (mph) or higher. This phenomenon 3 California Department of Forestry and Fire Protection (CAL FIRE). 2025a. Fire Hazard Severity Zones.
March 24. Website: https://osfm.fire.ca.gov/what-we-do/community-wildfire-preparedness-andmitigation/fire-hazard-severity-zones (accessed August 2025). 4 Geotechnologies, Inc. 2024. Environmental Impact Report, Soils and Geology Issues, Proposed Mixed-Use Development, 4961 Katella Avenue and 5100 Cerritos Avenue, Cypress, California. May 2. (Appendix F) 5 Ibid.
6 City of Cypress. 2001. Cypress General Plan. September. Website: https://www.cypressca.org/home/show publisheddocument/11369/638061699910600000 (February 6, 2025).
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P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.20 Wildfire.docx (03/11/26) 4.20-3 markedly increases the wildfire danger and intensity by drying out and preheating vegetation (fuel moisture of less than 5 percent for 1-hour fuels is possible) as well as accelerating oxygen supply, and thereby making possible the burning of fuels that otherwise might not burn under cooler, moister conditions.
4.20.3.2 Fuels Vegetation
The Buildout Area and surrounding areas are primarily developed and disturbed with some landscaped areas that support non-native/ornamental plant species.
4.20.3.3 Fire History
Fire history is an important component in analyzing wildfire susceptibility. Fire history data provide valuable information regarding fire spread, fire frequency, most vulnerable areas, and significant ignition sources, among others. In turn, this understanding of why fires occur in an area and how they typically spread can then be used for pre-planning and designing defensible communities.
Fire history within the Buildout Area and surrounding area was determined by referencing the Fire and Resources Assessment Program (FRAP) database. The FRAP summarizes fire perimeter data dating to the late 1800s; the FRAP maps used for this analysis focus on 1950–2023. These data provide a summary of recorded fires and can be used to show whether large fires have occurred in the Buildout Area, which is one indication of the likelihood of fires occurring at the Buildout Area in the future. These data suggest that the City has not experienced wildfires from 1970 to 2020.
Further, according to CAL FIRE, no wildfire incidents were recorded within the City between 2020 and 2025.7 Additionally, there have been no recorded fires that have burned onto any portion of the Buildout Area. As such, the FRAP map indicates that the Buildout Area is not within an area historically prone to wildland fires.
8 4.20.4 Regulatory Setting
Federal, State, and local regulations and programs related to wildfire that are applicable to the proposed project are described below.
4.20.4.1 Federal Regulations
National Fire Protection Association (NFPA) Code 1710. Code 1710 of the NFPA provides the minimum requirements for the organization and deployment of fire suppression operations, emergency medical operations, and special operations to the public by career fire departments.
National Incident Management System (NIMS). The NIMS provides a systematic, proactive approach to guide government agencies, nongovernmental organizations, and the private sector to work together to prevent, report, recover from, and mitigate the effects of fire incidents, regardless 7 California Department of Forestry and Fire Protection (CAL FIRE). 2025b. Incidents. Website: https://www. fire.ca.gov/incidents (accessed August 2025).
8 California Department of Forestry and Fire Protection (CAL FIRE). 2022. Fire and Resource Assessment Program. California Fire Perimeters 2022. Website: https://www.fire.ca.gov/what-we-do/fire-resourceassessment-program/fire-perimeters (accessed February 6, 2025).
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4.20 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.20 Wildfire.docx (03/11/26) -4 of cause, size, location, or complexity, to reduce the loss of life and property harm to the environment. The City participates in NIMS, which improves its ability to prepare for and respond to potential incidents and hazard scenarios.
4.20.4.2 State Regulations
CAL FIRE and Resources Assessment Program. CAL FIRE publishes maps that predict the threat of fire for each county within the State. LRAs, SRAs, and Federal Responsibility Areas (FRAs) are classified as either VHFHSZ or non-VHFHSZ based on factors including fuel availability, topography, fire history, and climate. The 2024 Strategic Fire Plan for California was generated by CAL FIRE to provide guidelines and objectives to account for associated fire impacts.
California Fire Code (CFC). The CFC includes regulations for emergency planning, fire service features, fire protection systems, hazardous materials, fire flow requirements, and fire hydrant locations, distribution, and spacing. Several fire safety requirements include installation of sprinklers in all high-rise buildings; the establishment of fire resistance standards for fire doors, building materials, and particular types of construction; and the clearance of debris and vegetation within a prescribed distance from occupied structures in wildlife hazard areas.
California Strategic Fire Plan. This statewide plan is a strategic document that guides fire policy for much of California. The plan is aimed at reducing wildfire risk through pre-fire mitigation efforts tailored to local areas through assessments of fuels, hazards, and risks.
California State Hazard Mitigation Plan (SHMP). The purpose of the SHMP is to significantly reduce deaths, injuries, and other losses attributed to natural and human-caused hazards in California. The SHMP provides guidance for hazard mitigation activities emphasizing partnerships among local, State, and federal agencies as well as the private sector.
California Government Code. California Government Code Section 51175 defines VHFHSZs and designates lands considered by the State to be a very high fire hazard. California Government Code Section 51189 directs the Office of the State Fire Marshal to create building standards for wildland fire resistance. The Government Code includes measures that increase the likelihood of a structure withstanding intrusion by fire (e.g., building design and construction requirements that use fireresistant building materials) and provides protection of structure projections (e.g., porches, decks, balconies, and eaves) and structure openings (e.g., attics, eave vents, and windows).
California Public Resources Code (PRC). The State’s Fire Safe Regulations are set forth in PRC Section 4290, which include the establishment of SRAs. PRC Section 4291 sets forth defensible space requirements, which are applicable to anyone that “… owns, leases, controls, operates, or maintains a building or structure in, upon, or adjoining a mountainous area, forest-covered lands, brush covered lands, grass-covered lands, or land that is covered with flammable material” (PRC §4291(a)).
Assembly Bill 337. Per Assembly Bill (AB) 337, local fire prevention authorities and CAL FIRE are required to identify VHFHSZs in LRAs. Standards related to brush clearance and the use of fireresistant materials in FHSZs are also established.
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P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.20 Wildfire.docx (03/11/26) 4.20-5 California Code of Regulations (CCR), Title 8 (Industrial Relations). In accordance with CCR Title 8 Sections 1270 and 6773 (Fire Prevention, and Fire Protection and Fire Equipment), the California Occupational Safety and Health Administration (Cal/OSHA) establishes fire suppression service standards. The standards range from fire hose size requirements to the design of emergency access roads.
California Code of Regulations, Title 14 (Natural Resources). Division 1.5 (Department of Forestry and Fire Protection), Title 14 of the CCR establishes a variety of wildfire preparedness, prevention, and response regulations.
California Code of Regulations, Title 19 (Public Safety). Title 19 of the CCR establishes a variety of emergency fire response, fire prevention, and construction and construction materials standards.
California Code of Regulations, Title 24 (California Building Standards Code). The CFC is set forth in Part 9 of the Building Standards Code. The CFC, which is pre-assembled with the International Fire Code (IFC) by the International Code Council (ICC), contains fire-safety building standards referenced in other parts of Title 24.
California Health and Safety Code Section 13000 et seq. and California Building Code (CBC). State fire regulations are set forth in §13000 et seq. of the California Health and Safety Code, which is divided into “Fires and Fire Protection” and “Buildings Used by the Public.” The regulations provide for the enforcement of the CBC and mandate the abatement of fire hazards. The California Health and Safety Code establishes broadly applicable regulations, such as standards for buildings and fire protection devices, in addition to regulations for specific land uses, such as childcare facilities and high-rise structures.
California Health and Safety Code Division 12.5 (Buildings Used by the Public). Division 12.5 establishes requirements for buildings used by the public, including essential services buildings, earthquake hazard mitigation technologies, school buildings, and post-secondary buildings.
California Residential Code Section R337. Section R337 establishes minimum standards for the protection of life and property by increasing the ability of a building located in any FHSZ within an SRA or any Wildland Urban Interface (WUI) Fire Area to resist the intrusion of flame or burning embers projected by a vegetation fire and contributes to a systematic reduction in conflagration losses. This section regulates materials and construction methods for exteriors susceptible to wildfire exposure.
California Building Code (CBC), Chapter 7A. Chapter 7A applies to building materials, systems, and/or assemblies used in the exterior design and construction of new buildings located within a WUI Fire Area. This section of the CBC establishes minimum standards for features such as fire retardant-treated wood and wood shingles, surface treatment protection, ignition-resistant construction, roof coverings and gutters, vents, exterior walls and coverings, exterior porch ceilings, underfloor protection, exterior windows, skylights, and doors, decking, and accessory structures.
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4.20 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.20 Wildfire.docx (03/11/26) -6 Executive Order N-04-19. On January 9, 2019, Governor Newsom announced Executive Order (EO) N-04-19, which requires State agencies to identify innovative and sustainable solutions to address the State’s wildfire crisis, such as upgraded fire detection technology.
Executive Order N-05-19. On January 9, 2019, Governor Newsom also announced EO N-05-19, which requires CAL FIRE and other State agencies to compile policy and regulatory recommendations concerning wildfire mitigation, emphasizing environmental sustainability and public health. EO N-05-19 requires the incorporation of socioeconomic analysis when conducting risk management of wildfires and mandates that agencies identify geographic areas with populations that are more vulnerable to the impacts of wildfires.
Executive Order N-18-25. In February 2025, Governor Newsom issued EO N-18-25, which is intended to strengthen wildfire resilience in urban and suburban areas by enhancing "Zone 0" defensible space and improving hazard mapping and preparedness systems. EO N-18-25 also initiated the development of a comprehensive, statewide wildfire resilience framework through an interagency, stakeholder-led process. Specifically, EO N-18-25 directs the State Board of Forestry and Fire Protection, in consultation with the State Fire Marshal, to finalize formal regulations establishing an ember-resistant zone within 5 feet of structures and instructs the Office of the State Fire Marshal to release updated FHSZ maps for areas within an LRA, which was completed in early 2025.
4.20.4.3 Regional Regulations
OCFA Fire Master Plans for Commercial & Residential Development, Guideline B-09. Guideline B-09 of the 2023 Fire Master Plans for Commercial & Residential Development establishes general guidelines pertaining to the installation and maintenance of fire department access roadways, access walkways to and around buildings, and hydrant quantity and placement as required by the 2022 CFC and CBC, and as amended by local ordinance. The proper installation and maintenance of fire access roadways, the proper siting of hydrants, adequate water supply, and proper access to structures are essential in enabling effective emergency response and firefighting operations.
County of Orange and OCFA Local Hazard Mitigation Plan (2021). This plan identifies risks and vulnerabilities, establishes hazard mitigation strategies, describes emergency organization, task assignments, and general procedures, and provides for coordination of response in the event of an emergency. This plan does not identify specific emergency response or evacuation routes.
4.20.4.4 Local Regulations
City of Cypress Municipal Code. Building and construction in the City are subject to the regulations of the City of Cypress Municipal Code. California Code of Regulations (CCR), Title 24, Part 2, the California Building Code (CBC) (2022), provides minimum standards for building design in the State.
Local codes are permitted to be more restrictive than Title 24, but not less restrictive. The procedures and limitations for the design of structures are based on site characteristics, occupancy type, configuration, structural system height, and fire hazard severity. New buildings located in any FHSZ, or any WUI Fire Area designated by the enforcing agency constructed after the application date, and additions to and remodel of buildings constructed before 2012 located in areas currently designated as such, are required to comply with the provisions of this chapter. The provisions also
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P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.20 Wildfire.docx (03/11/26) 4.20-7 apply to additions, remodels, and accessory structures located within 100 feet of a fuel modification zone, vegetation management area, or similar area containing hazardous combustible vegetation, regardless of whether the property is currently located in a designated FHSZ or WUI Fire Area, when materials and/or construction methods for exterior wildfire exposure were previously required at the property by the Building or Fire Code Official. In addition, the proposed project would adhere to the regulatory standards described in the City's Building Code, which adopt the CBC with amendments and modifications.
City of Cypress General Plan Safety Element. The Safety Element of the Cypress General Plan identifies the following goals, policies, and actions related to wildfire and fire protection services:
Goal SAF-5 Fire Protection: Protect life and property in Cypress from urban fires. Maintain the Orange County Fire Authority’s high level of service to community businesses and residents.
Policy SAF-5.2: Evaluate the effects of new development on the Orange County Fire Authority’s response time. Ensure through the development review process that new development will not result in reduced emergency service levels.
Policy SAF-5.6: Provide adequate fire equipment access to structures within the community.
Policy SAF-5.7: Maintain an ongoing fire inspection program to reduce fire hazards associated with older buildings, critical facilities, public assembly facilities, and industrial and commercial buildings.
Policy SAF-5.8: Promote the utilization of fire-safe building materials and enforce the City's fire sprinkler ordinance.
Cypress Town Center and Commons Specific Plan 3.0. The Cypress Town Center and Commons Specific Plan 3.0 does not include goals or policies related to wildfire and fire protection services.
4.20.5 Thresholds of Significance
The thresholds of significance for wildfire impacts used in this analysis are consistent with Appendix G of the State CEQA Guidelines. Based on these thresholds, implementation of the proposed project would have a significant impact with respect to wildfires if it were located in or near state responsibility areas or lands classified as a very high fire hazard severity zone and would:
Threshold 4.20.1: Substantially impair an adopted emergency response plan or emergency evacuation plan;
Threshold 4.20.2: Due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire;
Threshold 4.20.3: Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that 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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4.20 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.20 Wildfire.docx (03/11/26) -8 may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment; or
Threshold 4.20.4: Expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes.
4.20.6 Project Impacts
Potential impacts of the proposed project related to wildfire are discussed below pursuant to the thresholds established in Section 4.20.5, above. The thresholds of significance in Appendix G of the State CEQA Guidelines focus on wildfire impacts from projects located in or near SRAs or lands classified as VHFHSZs. According to the CAL FIRE VHFHSZ Maps for the Orange County region, the entire City is designated as a non-VHFHSZ, and the City does not include an SRA. The nearest VHFHSZ to the Buildout Area is approximately 6.8 miles northeast in Coyote Hills on the western side of Fullerton. The nearest SRA is in Puente Hills, approximately 12 miles northeast of the Buildout Area. As such, the proposed project is not located in or near any SRAs or lands classified as VHFHSZs. Therefore, there would be no impact related to wildfires from implementation of the proposed project. The following analysis is for informational purposes only regarding the additional topics raised in the four specific thresholds of significance in Appendix G of the State CEQA Guidelines.
Threshold 4.20.1: If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project substantially impair an adopted emergency response plan or emergency evacuation plan?
No Impact. According to the CAL FIRE Very High Fire Hazard Severity Zone, VHFHSZ Maps for the Orange County region, the entire City is designated as a non-VHFHSZ, and the City does not include an SRA. The nearest VHFHSZ to the Buildout Area is approximately 6.8 miles northeast in Coyote Hills on the western side of Fullerton. The nearest SRA is in Puente Hills, approximately 12 miles northeast of the Buildout Area. As such, the proposed project would not be a project located in or near an SRA or VHFHSZ and substantially impair an adopted emergency response plan or emergency evacuation plan. Accordingly, the proposed project would have no impacts related to this threshold.
Regardless, the following analysis is provided for informational purposes.
The City’s emergency evacuation routes are shown on Exhibit SAF-5 in the Safety Element of the City’s General Plan. All emergency evacuation activities are coordinated by the City’s Police Chief. In the unlikely event of a large-scale emergency evacuation, the Police Chief would issue evacuation orders based on information gathered from emergency experts. Evacuation operations would be conducted by law enforcement agencies, highway/road/street departments, and public and private transportation providers.9The Buildout Area is bounded by Katella Avenue to the south and located 9 City of Cypress. 2001. Cypress General Plan Environmental Impact Report. Geology and Seismic Hazards,
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P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.20 Wildfire.docx (03/11/26) 4.20-9 near Valley View Street to the east, both of which are identified as emergency evacuation routes by the City.10
Construction. The proposed project does not include any emergency facilities, nor would it serve as an emergency evacuation route. The proposed project assumes the extension of Moody Street from Cerritos Avenue to Katella Avenue, as well as the extension of Vessels Circle from its current western terminus to intersect with the Moody Street extension, consistent with the Specific Plan. The proposed project also includes, consistent with the Specific Plan, the widening of Lexington Drive within Lot B in Vesting Tentative Tract Map (VTTM) 19247. The proposed project would also include connections to existing utility infrastructure in the surrounding area, which would occur within public roadways. Construction of these roadway and utility improvements may require road closures or detours in the immediate vicinity of the Buildout Area. However, during future construction activities the contractor would be required to implement a construction worksite traffic control plan that complies with applicable engineering standards outlined in the California Manual of Uniform Traffic Control Devices,
11 ensuring that construction activities, which may temporarily restrict vehicular traffic, would be required to implement adequate and appropriate measures to facilitate the passage of persons and vehicles through/around any required road closures. Overall, all large construction vehicles entering and exiting the site would be guided by the use of personnel using signs and flags to direct traffic. Therefore, construction activities would not impact vehicle flow.
Because the proposed project would not include the construction of any emergency facilities, the Buildout Area does not serve as an emergency evacuation route, and construction activities would not impact the use of roadways near the Buildout Area, the proposed project would not physically impair or interfere with emergency response or evacuation in the project vicinity. Therefore, construction of the proposed project would have a less than significant impact associated with the substantial impairment of an adopted emergency response plan or emergency evacuation plan, and no mitigation is required.
Operation. The Buildout Area is not within the vicinity of a VHFHSZ or an SRA, as defined by CAL FIRE. The development scenario evaluated in this Draft EIR includes the maximum potential buildout of 1,791 residential units and 440,000 square feet of non-residential uses within the Buildout Area, as allowed under the existing Specific Plan.
The proposed project includes the completion of several key roadways within the Buildout Area, including the extension of Moody Street from Cerritos Avenue to Katella Avenue and an extension of Vessels Circle. Emergency access to and from the Buildout Area would be provided via these streets as well as other streets surrounding the Buildout Area, including Enterprise Way, Cerritos Avenue, Katella Avenue, and Lexington Drive. Additionally, all proposed structures and internal circulation paths within the Buildout Area would be developed in accordance with the City and OCFA 10 City of Cypress. 2001. Cypress General Plan Safety Element. Emergency Evacuation Routes Map (Exhibit SAF-5), October 2, 2001.
11 California Department of Transportation (Caltrans). 2014. California Manual of Uniform Traffic Control Devices, Federal Highway Administration’s MUTCD 2009 Edition, including Revision 1, 2, & 3 as amended for use in California, 14th Editions, Revision 9.
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4.20 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.20 Wildfire.docx (03/11/26) -10 emergency access standards. The proposed project would also be required to comply with all applicable codes and ordinances for emergency vehicle access, which would ensure that emergency vehicles have adequate access to, from, and within the Buildout Area.
The proposed project does not include any modifications to Katella Avenue or Valley View Street and would not introduce any new driveways or other vehicular access points to either street.
Because the Buildout Area is not located in a VHFHSZ or in or near an SRA, does not serve as an emergency evacuation route, and would not impair the evacuation of surrounding areas in the event of an emergency, operation of the proposed project would have a less than significant impact associated with impairment of an adopted emergency response plan or emergency evacuation plan, and no mitigation is required.
Threshold 4.20.2: If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project, due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?
No Impact. As stated previously, the Buildout Area is not located in a VHFHSZ or in an SRA. The nearest VHFHSZ is 6.8 miles northeast of the Buildout Area. The Buildout Area is located in a developed portion of the City. As such, since the proposed project is not located in or near an SRA or VHFHSZ, it would not exacerbate wildfire risks due to slope, prevailing winds, and other factors, and thereby would not expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire. Accordingly, the proposed project would have no impacts related to this threshold. Regardless, the following analysis is provided for informational purposes.
Topography influences the movement of air, thereby directing a fire course. For example, if the percentage of uphill slope doubles, the rate of spread in a wildland fire will likely double. 12 Wind
events magnify the risks of wildfire and have the potential to expose inhabitants of the City to elevated pollutant concentrations.
The development scenario evaluated in this Draft EIR assumes the existing land uses within the Buildout Area would be replaced with new development allowed under the Specific Plan. Neither the Buildout Area nor the immediate project vicinity is prone to wildfires. The Buildout Area is relatively flat with no steep slopes, and there are no significant slopes within the vicinity of the Buildout Area.
13 Therefore, there is an extremely low likelihood that wildfires would spread to the Buildout Area.
12 County of Orange & Orange County Fire Authority. 2015. Local Hazard Mitigation Plan. Website:
https://www.smwd.com/DocumentCenter/View/2193/APPENDIX-H_OC-HMP-Final (accessed February 6, 2025).
13 Geotechnologies, Inc. 2024. Environmental Impact Report, Soils and Geology Issues. Proposed Mixed-Use Development. 4961 Katella Avenue and 5100 Cerritos Avenue, Cypress, California. May. (Appendix F)
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P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.20 Wildfire.docx (03/11/26) 4.20-11 Future development within the Buildout Area would also adhere to applicable building and fire codes, which would further reduce the risk of wildfire. As the Buildout Area is not located within the vicinity of a VHFHSZ or in an SRA, the uncontrolled spread of wildfire in the vicinity of the Buildout Area is unlikely due to existing development, and impacts from downwind pollutant concentrations from a wildfire to occupants as a result of the proposed project would be negligible. Therefore, due to slope, prevailing winds, location, and other factors, the proposed project would not exacerbate wildfire risks. Impacts would be less than significant, and no mitigation is required.
Threshold 4.20.3: If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment?
No Impact. As described above, the Buildout Area is not located in a VHFHSZ or in an SRA. As such, the proposed project would not exacerbate fire risk through the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities), which may result in temporary or ongoing impacts to the environment. Accordingly, the proposed project would have no impacts related to this threshold. Regardless, the following analysis is provided for informational purposes.
In the absence of any significant potential for on-site or adjacent wildfire hazards, future development within the Buildout Area would not need to incorporate fire protection infrastructure (such as roads, fuel breaks, emergency water sources, power lines, or other non-existing utilities) that may themselves exacerbate fire risk.
The proposed project includes the construction of roads, water resources, power lines, and other utilities. The proposed project would include the extension of Moody Street from Cerritos Avenue to Katella Avenue, and the extension of Vessels Circle from its current western terminus to intersect with the Moody Street extension, consistent with the Specific Plan. 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 would also include various utility and infrastructure improvements identified in the Specific Plan and described in Chapter 3.0, Project Description. These improvements include the installation of new sewer connections and the installation of an additional drainage outfall.
Specifically, wastewater improvements for the proposed project would include the installation of a new 8-inch line on Lot 2, which would connect to the existing 30-inch sewer trunk line owned and maintained by the Orange County Sanitation District (OC San) within Lexington Drive, a new 8-inch sewer line that would gradually increase to 15 inches 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, and an additional sewer connection that would connect to the existing 18-inch and 21-inch sewer main lines owned and maintained by the City in Katella Avenue. In addition to these improvements, it is also anticipated that the existing 18-inch and 21-inch sewer main lines within Katella Avenue would need to be upsized to a 24-inch main line.
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4.20 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.20 Wildfire.docx (03/11/26) -12 Additionally, in order to accommodate the existing drainage patterns of the Buildout Area, the proposed project would include an additional outfall that would be installed at the existing Vessels Circle storm drain, and the installation of a tributary line to the Walker Street storm drain. Electricity would be provided by existing utility lines, and no natural gas would be utilized.
Although the proposed project would include extensions of Moody Street and Vessels Circle, as described in the Specific Plan, the proposed project would not include any changes to public or private roadways that would exacerbate fire risk or that would result in impacts to the environment.
Utilities, including water facilities, sewer facilities, storm drain lines, and power lines would be modified and/or extended throughout the Buildout Area; however, these improvements would be underground and would not exacerbate fire risk. All utility lines, pipes, utility junction boxes, and transformers would be located underground. The design and implementation of utility improvements would be reviewed and approved by the City’s Public Works Department to ensure that it would be sized to accommodate future development allowed under the approved Specific Plan and comply with all applicable fire codes, design standards, and regulations.
Because the installation of all project-related utility improvements would be implemented in an urbanized setting in accordance with the current California Building Code, California Fire Code, and applicable local ordinances, impacts related to the installation or maintenance of infrastructure that may exacerbate fire risk or result in temporary or ongoing impacts to the environment would be less than significant, and no mitigation is required.
Threshold 4.20.4: If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes? No Impact. As described above, the Buildout Area is not located in a VHFHSZ or in an SRA. As such, the proposed project would not expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes. Accordingly, the proposed project would have no impacts related to this threshold.
Regardless, the following analysis is provided for informational purposes.
Landslides. Landslides, including mudflows, debris flows, and soil slips, occur as soil moves downslope under the influence of gravity. Landslides are frequently triggered by intense rainfall or seismic shaking but can also occur as a result of erosion and downslope runoff caused by rain following a fire. According to the Geotechnical Investigation completed for the proposed project, 14 the probability of seismically induced landslides occurring on the Buildout Area is considered to be negligible due to the level topography observed across and adjacent to the Buildout Area.
Additionally, the Buildout Area does not lie within a designated Landslide Hazard Zone. Further, as stated previously, the Buildout Area is not located in a VHFHSZ, or in or near an SRA. In the extremely unlikely event that a wildfire should spread to the Buildout Area, it would not expose any on-site slopes to erosion and potential failure because the Buildout Area does not contain any steep 14 Geotechnologies, Inc. 2024. Environmental Impact Report, Soils and Geology Issues Proposed Mixed-Use Development 4961 Katella Avenue and 5100 Cerritos Avenue, Cypress, California. May. (Appendix F)
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P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\4.20 Wildfire.docx (03/11/26) 4.20-13 slopes that are prone to landslides. The proposed project would not expose people or structures to significant risks, including downslope landslides, as a result of runoff, post-fire slope instability, or drainage changes. There would be no impact to project occupants or nearby residents or workers related to post-wildfire landslide risks, and no mitigation is required.
Flooding. According to the Federal Emergency Management Agency (FEMA) Federal Insurance Rate Map (FIRM) No. 06059C0116J (December 3, 2009), the Buildout Area is located within Zone X, which comprises areas of 0.2 percent annual chance flood (500-year flood). This means that there is a very low likelihood of flooding within the Buildout Area.
15 According to the City’s General Plan Safety
Element,
16 the Buildout Area is located within the inundation zone of the Prado Dam and the Carbon Canyon Dam. There are no large open bodies of water in the vicinity of the Buildout Area, and the project is therefore not located within an inundation zone of a seiche. The Buildout Area is located approximately 6 miles northeast of the Pacific Ocean and is not located within the tsunami inundation zone. The levee inundation zone of Coyote Creek/Carbon Creek is located to the west of the Buildout Area; however, the Buildout Area is not located within this inundation area.17 Therefore, downslope or downstream flooding as a result of runoff, post-fire slope instability, or drainage changes would not expose people or structures to significant risks. Impacts to people or structures related to post-wildfire flooding risks would be less than significant, and no mitigation is required.
4.20.7 Level of Significance Prior to Mitigation
The proposed project would result in no impacts related to wildfire.
4.20.8 Regulatory Compliance Measures and Mitigation Measures No regulatory compliance measures are applicable to the proposed project relating to wildfire, and no mitigation measures are required.
4.20.9 Level of Significance after Mitigation
The proposed project would result in no impacts related to wildfire.
4.20.10 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 wildfire. The cumulative study area for wildfire is the City of Cypress as described in Chapter 4.0, Existing Setting. The cumulative project 15 Federal Emergency Management Agency (FEMA). 2009. FEMA's National Flood Hazard Layer (NFHL) Viewer. December. Website: https://hazards-fema.maps.arcgis.com/apps/webappviewer/index.html?id= 8b0adb51996444d4879338b5529aa9cd (accessed February 6, 2025). 16 City of Cypress. 2001. Cypress General Plan Safety Element, Exhibit SAF-2 “Dam Inundation Areas”.
September 10.
17 California Department of Water Resources (DWR). 2025. Flood Risk Map Web Viewer. Website:
https://gis.lfpz.water.ca.gov/lfpz/ (accessed February 6, 2025).
S P E C I F I C PL A N 3 . 0 B U I L D O U T P R O J E C T
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As detailed in this section, the proposed project would result in less than significant impacts related to wildfire. As stated previously, the Buildout Area is not located in a VHFHSZ or in an SRA. The nearest VHFHSZ is 6.8 miles northeast of the Buildout Area. The Buildout Area is located in a developed portion of the City.
Additionally, all discretionary private development and public works projects within the cumulative study area would be required to comply with CEQA. In this way, potential impacts related to wildfire would be evaluated and mitigated by each individual project. Some of the related projects identified in Table 4.A have undergone environmental review pursuant to CEQA, which included an analysis of potential impacts relating to wildfire. The EIRs prepared for the Shea Properties Mixed Use Development Project (Related Project 1), Melia Homes -Citrus Square Project (Related Project 2), and the Los Alamitos Medical Center Project (Related Project 7) concluded that no impacts relating to wildfire would occur with implementation of the projects. Further, the EIRs determined that cumulative impacts related to wildfire would be less than significant. In addition, Goodman Commerce Center Project (Related Project 3) was analyzed in an Initial Study/Mitigated Negative Declaration (IS/MND), which also determined that no impacts relating to wildfire 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 Exemptions (NOEs) were prepared. In order for a project to be exempt under Section 15332 of the State CEQA Guidelines, the project must not result in any significant effects due to unusual circumstances, which includes being located within a fire hazard zone. As such, development of the related projects in combination with the proposed project would not result in significant impacts relating to wildfire. The LTP Modern Machine Project (Related Project 5) and 8561 Belmont Street Project (Related Project 4) would also be required to undergo environmental review pursuant to CEQA, which would include an analysis of potential impacts relating to wildfire and the identification of any mitigation measures to reduce potential impacts, if necessary.
Additionally, all discretionary private development and public works projects within the cumulative study area would be required to adhere to City, County, State, and federal regulations designed to reduce and/or avoid impacts related to wildfire including flooding hazards and landslides after a wildfire event. Since all projects within the cumulative study area would be required to implement appropriate mitigation measures and adhere to applicable regulations, implementation of the proposed project, when evaluated in combination with the development of projects listed in Table 4.A, would not contribute to a cumulatively considerable impact related to wildfire.
Therefore, there would be no cumulatively significant impact related to wildfire, and no mitigation is required.
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5.0 ALTERNATIVES
5.1 INTRODUCTION
The State CEQA Guidelines require that an Environmental Impact Report (EIR) include a discussion of reasonable project alternatives that would “feasibly attain most of the basic objectives of the project, but would avoid or substantially lessen any significant impacts of the project, and evaluate the comparative merits of the alternatives” (State CEQA Guidelines, Section 15126.6). This chapter identifies potential alternatives to the Specific Plan 3.0 Buildout Project (proposed project), evaluates the potential impacts of each alternative, and compares the potential impacts of each alternative against the proposed project’s impacts, as required by CEQA.
Section 15126.6 of the State CEQA Guidelines sets forth the intent and requirements for the alternatives analysis in an EIR, including the following provisions:
• The discussion of alternatives shall focus on alternatives to the project or its location that are capable of avoiding or substantially lessening any significant effects of the project, even if these alternatives would impede to some degree the attainment of the project objectives or would be more costly (15126.6[b]).The range of potential alternatives to the proposed project shall include those that could feasibly accomplish most of the basic objectives of the project and could avoid or substantially lessen one or more of the significant effects. The EIR should briefly describe the rationale for selecting the alternatives to be discussed. The EIR should also identify any alternatives that were considered by the lead agency but were rejected as infeasible during the scoping process and briefly explain the reasons underlying the lead agency’s determination.
Among the factors that may be used to eliminate alternatives from detailed consideration in an EIR are: (1) failure to meet most of the basic project objectives, (2) infeasibility, or (3) inability to avoid significant environmental impacts (15126.6[c]).
• The EIR shall include sufficient information about each alternative to allow meaningful evaluation, analysis, and comparison with the proposed project (15126.6[d]). • The specific alternative of ‘no project’ shall also be evaluated along with its impact (15126.6[e][1]). The ‘no project’ analysis shall discuss the existing conditions at the time the Notice of Preparation is published, and at the time the environmental analysis is commenced, as well as what would reasonably be expected to occur in the foreseeable future if the project were not approved, based on current plans and consistent with available infrastructure and community services. If the environmentally superior alternative is the ‘no project’ alternative, the EIR shall also identify an environmentally superior alternative among the other alternatives (15126.6[e][2]).
• The range of alternatives required in an EIR is governed by the ‘rule of reason’ that requires the EIR to set forth only those alternatives necessary to permit a reasoned choice. The alternatives shall be limited to ones that would avoid or substantially lessen any of the significant effects of the project. Of those alternatives, the EIR need examine in detail only the ones that the lead agency determines could feasibly attain most of the basic objectives of the project. The range of S PECIFIC PLAN 3.0 B UILDOUT P ROJECT
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feasible alternatives shall be selected and discussed in a manner to foster meaningful public participation and informed decision-making. Among the factors that may be taken into account when addressing the feasibility of alternatives are site suitability, economic viability, availability of infrastructure, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries, and whether the proponent can reasonably acquire, control or otherwise have access to the alternative site (or the site is already owned by the proponent) (15126.6[f]). • For alternative locations, only locations that would avoid or substantially lessen any of the significant effects of the project need be considered for inclusion in the EIR (15126.6[f][2][A]). If the lead agency concludes that no feasible alternative locations exist, it must disclose the reasons for this conclusion, and should include the reasons in the EIR. For example, in some cases there may be no feasible alternative locations for a geothermal plant or mining project which must be in close proximity to natural resources at a given location (15126.6[f][2][B]). • An EIR need not consider an alternative whose effect cannot be reasonably ascertained and whose implementation is remote and speculative (15126.6[f][3]).
Pursuant to the guidelines stated above, a range of alternatives to the proposed project is considered and evaluated in this Draft EIR. These alternatives were developed in the course of project planning and environmental review. The discussion in this section provides:
1. A description and analysis of impacts for each of the alternatives considered;
2. Comparative analysis of each alternative that focuses on the potentially significant unavoidable environmental impacts of the proposed project (the purpose of this analysis is to determine whether alternatives are capable of eliminating or reducing the significant environmental impacts of the project to a less than significant level); and
3. Conclusions regarding the alternative’s: (1) ability to avoid or substantially lessen the significant unavoidable impacts of the project; (2) ability to attain the project objectives (as stated below); and (3) merits compared to the merits of the proposed project.
5.2 PROPOSED PROJECT
The project analyzed in this Draft EIR is the reasonably foreseeable buildout of the Cypress Town Center and Commons Specific Plan 3.0 (Specific Plan), which City of Cypress voters approved on November 5, 2024, pursuant to "Measure S" as part of the Housing Element Implementation Project.
5.2.1 Project Characteristics
The proposed project consists of the reasonably foreseeable buildout of a portion of the area governed by Specific Plan that includes approximately 134 acres of land (Buildout Area) in the City of Cypress (City). The proposed project includes consideration of Vesting Tentative Tract Map No. 19247 (VTTM 19274). 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 part of the existing Grace Church property, which is located outside
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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.
The proposed project also does not include two other areas subject to the Specific Plan, which include (1) the seven acres of land (Melia Property) that Melia Homes previously developed as the Belmont residential project (SCH No. 2020099025), and (2) the nine acres of land the City developed as Lexington Park.
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, as described below.
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 already-constructed units at the Melia Property. Melia Homes previously developed the Belmont residential project with 135 units on the Melia Property. Therefore, an additional 1,791 residential units (1,926 - 135 = 1,791) may be developed within the Buildout Area.
Non-Residential Development: As shown in Table 3.A, the Specific Plan permits a 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 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. If buildout exceeds 440,000 square feet of non-residential development, each future applicant for a project that would cause the overall non-residential floor area within the Buildout Area to exceed, or further exceed, 440,000 square feet, will be required to prepare and submit additional environmental review in accordance with the provisions of CEQA and the State CEQA Guidelines may be required if such non-residential development requires any discretionary action by the City.
Street Extension: The proposed project also includes the extension of Moody Street from Cerritos Avenue to Katella Avenue, as well as the extension of Vessels Circle from its current western terminus to intersect with the Moody Street extension, consistent with Figure 2-1 of the Specific Plan. The Moody Street extension would traverse vertically through the Buildout Area, adjacent to Lots 4, 3, 13, and 14 in VTTM 19247, and create a new 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.
Open Space and Landscaping: The proposed project also includes 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 S PECIFIC PLAN 3.0 B UILDOUT P ROJECT
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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. The Buildout Area would also include landscaped areas as required by the Specific Plan and the City of Cypress Municipal Code (Municipal 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.
5.2.2 Project Purpose and Objectives
Each project alternative is analyzed to determine whether it achieves the objectives of the proposed project. The underlying purpose of the proposed project is to redevelop the Buildout Area in accordance with the voter-approved Specific Plan. As stated in Section 3.0, Project Description, the following project objectives have been established for the proposed project.
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 generate new sources of revenue for the City through increased property values and retail sales.
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.
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5.2.3 Significant Adverse Unavoidable Impacts of the Proposed Project
5.2.3.1 Air Quality
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.
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.
In addition, proposed project emissions of ozone precursors (VOC) can contribute to regional exceedances of air quality standards and that such exceedances are associated with increased respiratory and cardiovascular symptoms in sensitive populations. Accordingly, this impact would also be significant and unavoidable, even with implementation of all feasible mitigation measures to minimize emissions during operation.
5.2.3.2 Cultural Resources
Historical Resources. Proposed project implementation would include the demolition of characterdefining 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.
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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 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 builtenvironment historic resources as defined in State CEQA Guidelines Section 15064.5 would remain significant and unavoidable.
5.2.3.3 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.
5.3 ALTERNATIVES INITIALLY CONSIDERED BUT REJECTED FROM FURTHER
CONSIDERATION
Section 15126.6(c) of the State CEQA Guidelines suggests that EIRs identify any alternatives that were considered by the Lead Agency but were rejected during the scoping process and briefly explain the reasons underlying the Lead Agency’s determination. In evaluating an appropriate range of alternatives to the proposed project, a Residential-Only Development Alternative was considered and rejected by the City.
The following is a discussion of alternatives considered during the environmental review process and the reasons they were not selected for detailed analysis in this Draft EIR.
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5.3.1 Residential-Only Development Alternative
The Residential-Only Development Alternative would eliminate the commercial and/or communityserving components of the proposed project and retain only the residential component. Similar to the proposed project, the Residential-Only Development Alternative would result in the future development of 1,791 residential units within the Buildout Area, consistent with the Specific Plan.
However, implementation of this alternative would not meet the underlying purpose of the proposed project to redevelop the Buildout Area in accordance with the voter-approved Specific Plan. Specifically, implementation of the Residential-Only Development Alternative would not 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; 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 provide an enhanced consumer and employee base for the new commercial uses; invigorate the local economy by providing new employment and business opportunities; or provide commercial/retail improvements that generate new sources of revenue for the City through increased property values and retail sales. Therefore, the Residential-Only Development Alternative was not forwarded for further analysis.
5.3.2 Off-Site Alternative
An off-site alternative was considered but rejected because the Buildout Area is a unique, contiguous property comprising approximately 134 acres with existing infrastructure, longestablished access, and a site context that is not readily replicable elsewhere within the City or surrounding area. The applicant already owns the vast majority of the Buildout Area and it is particularly suitable for the proposed project because Cypress voters have approved a Specific Plan that applies to the land within the Buildout Area allow for a comprehensive, master-planned redevelopment that can accommodate a coordinated mix of uses, internal circulation, open space, and infrastructure improvements in a manner that smaller or fragmented off-site parcels could not reasonably achieve.
In addition, development on an alternative off-site location would not meet the underlying purpose of the proposed project to redevelop the Buildout Area in accordance with the voter-approved Specific Plan. Moreover, an off-site alternative would not meet the core purpose of the proposed project, which is to redevelop the Buildout Area in accordance with the voter-approved Specific Plan. Identifying and assembling a comparable off-site property of similar scale and characteristics would be speculative, could introduce additional environmental impacts, and would not reduce impacts relative to the proposed project. Therefore, the off-site alternative was determined to be infeasible and was not carried forward for further analysis.
5.4 ALTERNATIVES UNDER CONSIDERATION
Section 21100 of the Public Resources Code (PRC) and Section 15126 of the State CEQA Guidelines 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. Based on the S PECIFIC PLAN 3.0 B UILDOUT P ROJECT
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criteria listed above, the following three alternatives have been determined to represent a reasonable range of alternatives that could 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 LARC 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 non-residential development.
The existing LARC character-defining features that would be retained include the original pre1970 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.
5.5 ALTERNATIVES ANALYSIS
5.5.1 No Project Alternative
5.5.1.1 Description
As previously described, 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
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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 barns; and parking structures. In addition, the roadway improvements and extensions envisioned under the proposed project would not occur.
Under the No Project Alternative, it is assumed the Los Alamitos Race Course would continue to operate under its existing conditions and entitlements. No new development, redevelopment, or expansion would occur beyond what is currently allowed, and ongoing activities at the site— including horse racing events, simulcast operations, associated parking, lighting, and supporting facilities—would remain generally consistent with present-day operations. As a result, there would be no change to existing land use patterns, intensity of use, or operational characteristics at LARC, and environmental conditions would remain substantially similar to baseline conditions, aside from normal fluctuations associated with routine operations and maintenance.
5.5.1.2 Comparison of Environmental Impacts
Aesthetics. Under the No Project Alternative, the existing visual character and quality of the Buildout Area and its surroundings would not be altered and would remain as it is in its existing condition. As such, implementation of the No Project Alternative would not result in any change in the aesthetic character of the Buildout Area and would not result in any new sources of light or glare. Therefore, compared to the less than significant impacts of the proposed project, the No Project Alternative would have no impact related to aesthetics.
Agriculture and Forestry Resources. The No Project Alternative would not result in the development of the Buildout Area with new residential or non-residential uses and the Buildout Area would remain as it is in its existing condition. Therefore, implementation of the No Project Alternative would have no impact related to agriculture and forestry resources, similar to the proposed project.
Air Quality. The No Project Alternative would not result in the development of the Buildout Area with new residential or non-residential uses and no demolition or construction activity would occur within the Buildout Area. Existing operational conditions, including vehicle trips, would remain the same. As such, implementation of the No Project Alternative would not result in any constructionrelated increase in pollutant concentrations and dust, exhaust, and organic emissions. Similarly, this alternative would not result in new exposure of residents to substantial pollutant concentrations, including toxic air contaminants (TACs). Implementation of the No Project Alternative would also not result in an increase in operational vehicle trips in the City, and, because the No Project Alternative would not facilitate any development within the Buildout Area, no other emissions (such as those leading to odor) would be generated. Because the No Project Alternative would not facilitate any development within the Buildout Area, Regulatory Compliance Measures AIR-1 through AIR-4, Mitigation Measure AIR-1, Mitigation Measure AIR-2, and Mitigation Measure TRA-1 would not be applicable. Therefore, compared to the significant and unavoidable air quality impacts associated with the proposed project, the No Project Alternative would have no impact on air quality.
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is in its existing condition. No demolition or construction activity would occur within the Buildout Area. As such, implementation of the No Project Alternative would not result in any impacts on biological resources, including special status species, riparian habitat or other sensitive natural communities, or wetlands. In addition, implementation of the No Project Alternative would not interfere with the movement of any wildlife species, impede the use of wildlife nursery sites, conflict with any local policies or ordinances protecting biological resources, or conflict with an adopted Habitat Conservation Plan (HCP). Because the No Project Alternative would not facilitate any development within the Buildout Area, Regulatory Compliance Measures BIO-1 and BIO-2 and Mitigation Measure BIO-1 would not be applicable. Therefore, compared to the less than significant impacts with the incorporation of mitigation associated with the proposed project, the No Project Alternative would have no impact on biological resources.
Cultural Resources. The No Project Alternative would not result in the development of the Buildout Area with new residential or non-residential uses and the Buildout Area would remain as it is in its existing condition. No demolition or construction activity would occur within the Buildout Area.
Therefore, the existing character-defining features of the LARC Property, including the grandstand, 1954 quarter-mile chute, and the pre-1970 track, which are considered historic resources as defined in State CEQA Guidelines Section 15064.5, would not be demolished and Mitigation Measures CUL-1 through CUL-3 would not be required. Therefore, compared to the significant and unavoidable impacts of the proposed project, the No Project Alternative would have no impact on builtenvironment historic resources as defined in State CEQA Guidelines Section 15064.5.
In addition, implementation of the No Project Alternative would not include construction or other ground disturbance activities that could result in the accidental discovery of archeological and/or cultural resources, including human remains. As such, Regulatory Compliance Measures CUL-1 and CUL-2 would not be applicable or required. Therefore, compared to the less than significant impacts of the proposed project, the No Project Alternative would have no impact on archaeological resources, including human remains.
Overall, implementation of the No Project Alternative would avoid the significant and unavoidable impacts of the proposed project associated with cultural resources.
Energy. The No Project Alternative would not result in the development of the Buildout Area with new residential or non-residential uses and no demolition or construction activity would occur within the Buildout Area as the Buildout Area would remain the same as it is under existing conditions. As such, implementation of the No Project Alternative would not result in constructionrelated energy demand. Similarly, the No Project Alternative would not result in an increase in VMT, daily vehicle trips, or utility use (i.e., electricity and natural gas) within the Buildout Area compared to existing conditions. Therefore, the No Project Alternative would not result in impacts related to operational-period energy usage. Accordingly, compared to the less than significant energy impacts associated with the proposed project, the No Project Alternative would have no impact related to energy.
Geology and Soils. The No Project Alternative would not result in the development of the Buildout Area with new residential or non-residential uses and the Buildout Area would remain as it is in its existing condition. No demolition, grading, or construction activity would occur within the Buildout
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Area. As such, implementation of the No Project Alternative would not cause potential substantial adverse effects, including the risk of loss, injury, or death involving the rupture of a known earthquake fault, strong seismic ground shaking, seismic-related ground failure (including liquefaction), and landslides. In addition, as no development would occur, implementation of the No Project Alternative would not result in substantial soil erosion or the loss of topsoil, be located on an unstable geologic unit or expansive/unstable soil, or result in any impacts related to alternative wastewater disposal systems. As such, Regulatory Compliance Measure GEO-1 and Mitigation Measure GEO-1 would not be applicable or required for the No Project Alternative.
In addition, implementation of the No Project Alternative would not include construction or other ground disturbance activities that could result in the accidental discovery of paleontology resources.
Therefore, implementation of the No Project Alternative would not destroy a unique paleontological resource or site, either directly or indirectly and Mitigation Measures GEO-2 and GEO-3 would not be applicable or required for the No Project Alternative.
Therefore, compared to the less than significant impacts of the proposed project with the incorporation of mitigation, the No Project Alternative would have no impact related to geology and soils.Greenhouse Gas Emissions. The No Project Alternative would not result in the development of the Buildout Area with new residential or non-residential uses and no demolition or construction activity would occur within the Buildout Area as the Buildout Area would remain the same as it is under existing conditions. As such, implementation of the No Project Alternative would not result in the generation of construction-period GHG emissions. Similarly, the No Project Alternative would not result in an increase in VMT, daily vehicle trips, or utility use (i.e., electricity, natural gas, water, and wastewater) within the Buildout Area compared to existing conditions. Therefore, the No Project Alternative would not result in any GHG impacts related to project operations. Because the No Project Alternative would not facilitate any development within the Buildout Area, Mitigation Measure AIR-1, Mitigation Measure GHG-1, and Mitigation Measure TRA-1 would not be applicable. Therefore, compared to the less than significant GHG impacts with the incorporation of mitigation associated with the proposed project, the No Project Alternative would have no impact related to GHG.
Hazards and Hazardous Materials.The No Project Alternative would not result in the development of the Buildout Area with new residential or non-residential uses and the Buildout Area would remain as it is in its existing condition. No demolition, grading, or construction activity would occur within the Buildout Area. As such, implementation of the No Project Alternative would not involve the routine transport, use, or disposal of hazardous materials; emit or handle hazardous materials within 0.25-mile of a school; or create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment. In addition, as no development would occur, implementation of the No Project Alternative would not create a significant hazard to the public or the environment due to it being on a hazardous materials site identified pursuant to Government Code Section 65962.5; result in a safety hazard or excessive noise for people residing or working in the project area; impaired implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan; or expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires. As such, Regulatory Compliance Measure HAZ-1 and S PECIFIC PLAN 3.0 B UILDOUT P ROJECT
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Mitigation Measure HAZ-1 would not be applicable or required for the No Project Alternative.
Therefore, compared to the less than significant impacts of the proposed project with the incorporation of mitigation, the No Project Alternative would have no impact related to hazards and hazardous materials.Hydrology and Water Quality.The No Project Alternative would not result in the development of the Buildout Area with new residential or non-residential uses and the Buildout Area would remain as it is in its existing condition. No demolition, grading, or construction activity would occur within the Buildout Area. As no construction activities would occur and the Buildout Area would remain the same as existing conditions, implementation of the No Project Alternative would not increase the potential for pollutants of concern from construction activities and vehicle traffic (e.g., fuels and lubricants, tire wear particulates, brake dust, and fallout from exhaust emissions) to be generated within the Buildout Area and conveyed in runoff during storm events when compared to existing conditions. Therefore, the No Project Alternative would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality and Regulatory Compliance Measures HYD-1 and HYD-2, would not be required. In addition, because the No Project Alternative would not result in the development of the Buildout Area, require additional water supply, or result in increased impervious surface area within the Buildout Area, implementation of the No Project Alternative would not substantially decrease groundwater supplies, interfere substantially with groundwater recharge, or substantially alter the existing drainage pattern of the site, and Regulatory Compliance Measure HYD-3 would not be required. Implementation of the No Project Alternative would also not increase the risk of release of pollutants due to inundation beyond existing conditions and would also not conflict with applicable water quality control or sustainable groundwater management plans. Therefore, compared to the less than significant impacts of the proposed project, the No Project Alternative would have no impact on hydrology and water quality.
Land Use and Planning. The No Project Alternative would not result in the development of the Buildout Area with new residential or non-residential uses and the Buildout Area would remain as it is in its existing condition, despite the fact that the previously approved Specific Plan would still apply to the land within the Buildout Area. The Buildout Area would continue to be developed with its existing uses and structures, 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 barns; and parking structures. Therefore, compared to the less than significant impacts of the proposed project, the No Project Alternative would have no impact related to land use and planning. However, it should be noted that implementation of the No Project Alternative, because it does not include the construction of any residential units, would not provide any housing to meet the significant unmet housing demand in the City, which is in conflict with the stated goals of the Specific Plan.
Mineral Resources. The No Project Alternative would not result in the development of the Buildout Area with new residential or non-residential uses and the Buildout Area would remain as it is in its existing condition. Therefore, implementation of the No Project Alternative would have no impact related to mineral resources, similar to the proposed project.
Noise. The No Project Alternative would not result in the development of the Buildout Area with new residential or non-residential uses and the Buildout Area would remain as it is in its existing
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condition. No demolition, grading, or construction activity would occur within the Buildout Area. As no construction activities would occur, implementation of the No Project Alternative would not expose surrounding land uses to short-term construction-related noise or vibration. Noise at the Buildout Area would not increase above that already occurring on the site and no increase in traffic noise would occur. Because the No Project Alternative would not facilitate any development within the Buildout Area, Regulatory Compliance Measures NOI-1 and NOI-2 would not be applicable.
Therefore, compared to the less than significant noise impacts associated with the proposed project, the No Project Alternative would have no impact related to noise.
Population and Housing. The No Project Alternative would not result in the development of the Buildout Area with new residential or non-residential uses and the Buildout Area would remain as it is in its existing condition. As no new residential or non-residential uses would be constructed at the Buildout Area, implementation of the No Project Alternative would not result in any population increase in the city. Therefore, compared to the less than significant impacts of the proposed project, the No Project Alternative would have no impact related to population and housing.
However, it should be noted that implementation of the No Project Alternative, because it does not include the construction of any residential units, would not provide any housing to meet the significant unmet housing demand in the City, which is in conflict with the stated goals of the Specific Plan.
Public Services. The No Project Alternative would not result in the development of the Buildout Area with new residential or non-residential uses and the Buildout Area would remain as it is in its existing condition. As no new residential or non-residential uses would be constructed within the Buildout Area, implementation of the No Project Alternative would not result in any population increase in the city or increase in demand for public services, including on fire and police protection services, schools, parks, and other public services, as compared to existing conditions. In addition, Regulatory Compliance Measures PS-1, PS-2, and PS-3, and the payment of applicable development impact fees would not be applicable or required with implementation of the No Project Alternative.
Therefore, compared to the less than significant impacts of the proposed project, the No Project Alternative would have no impact on public services.
Recreation. The No Project Alternative would not result in the development of the Buildout Area with new residential, non-residential uses, or parks and the Buildout Area would remain as it is in its existing condition. As no new residential or non-residential uses would be constructed within the Buildout Area, implementation of the No Project Alternative would not result in any population increase in the city or increase in demand on parks and recreation facilities, as compared to existing conditions. In addition, as discussed above, Regulatory Compliance Measure PS-3 would not be applicable or required with implementation of the No Project Alternative. Therefore, compared to the less than significant impacts of the proposed project, the No Project Alternative would have no impact on parks and recreation.
Transportation. The No Project Alternative would not result in the development of the Buildout Area with new residential or non-residential uses and the Buildout Area would remain as it is in its existing condition. No construction activity would occur within the Buildout Area. As no construction activities or development would occur, implementation of the No Project Alternative would not result in any increases in automobile, transit, bicycle, or pedestrian travel to or from the Buildout S PECIFIC PLAN 3.0 B UILDOUT P ROJECT
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Area. As such, a Transportation Construction Plan (TCP), which includes measures for traffic coordination during construction to lower impacts to roadway systems, would not be applicable or required. In addition, because no development would occur, implementation of the No Project Alternative would not increase hazards due to a geometric design feature or incompatible uses or result in inadequate emergency access.
Implementation of the No Project Alternative would also not result in any increase related to VMT as no increase in daily trips to and from the Buildout Area would occur. As such, Mitigation Measure TRA-1 would not be applicable or required with implementation of the No Project Alternative.
Therefore, compared to the significant and unavoidable impacts of the proposed project, the No Project Alternative would have no impact related to VMT.
Tribal Cultural Resources. The No Project Alternative would not result in the development of the Buildout Area with new residential or non-residential uses and the Buildout Area would remain as it is in its existing condition. No demolition or ground-disturbing activities from construction would occur within the Buildout Area. As such, implementation of the No Project Alternative would not result in the accidental discovery of tribal cultural resources and Regulatory Compliance Measures CUL-1 and CUL-2 and Mitigation Measures TCR-1 through TCR-4 would not be applicable or required. Therefore, compared to the less than significant impacts of the proposed project with the incorporation of mitigation, the No Project Alternative would have no impact related to tribal cultural resources.
Utilities and Service Systems. The No Project Alternative would not result in the development of the Buildout Area with new residential or non-residential uses and the Buildout Area would remain as it is in its existing condition. As no new residential or non-residential uses would be constructed within the Buildout Area, implementation of the No Project Alternative would not result in any population increase in the city or increase in demand on utilities, including water, wastewater, stormwater drainage, electric power, natural gas, and telecommunications, as compared to existing conditions.
In addition, Regulatory Compliance Measure UTIL-1 would not be applicable or required with implementation of the No Project Alternative. Therefore, compared to the less than significant impacts of the proposed project, the No Project Alternative would have no impact on utilities and service systems.
Wildfire.The No Project Alternative would not result in the development of the Buildout Area with new residential or non-residential uses and the Buildout Area would remain as it is in its existing condition. As such, implementation of the No Project Alternative would not impair an adopted emergency response plan or emergency evacuation plan; exacerbate wildfire risks; require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk; or expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes. Therefore, implementation of the No Project Alternative would have no impact related to wildfire, similar to the proposed project.
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5.5.1.3 Attainment of Project Objectives
The No Project Alternative would not meet the underlying purpose of the proposed project or any of the project objectives. The attainment of project objectives is discussed further below.
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.
The No Project Alternative would not result in any new residential uses within the Buildout Area.
Therefore, implementation of the No Project Alternative would not help meet the significant unmet demand for housing in the City and the project vicinity. As such, the No Project Alternative would not meet this project objective.
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.
The No Project Alternative would not result in any new residential or non-residential uses within the Buildout Area. Therefore, implementation of the No Project Alternative would not establish a mixed-use town center or gathering place for the community as no mix of entertainment, retail, restaurant, commercial and residential uses would be developed. As such, the No Project Alternative would not meet this project objective.
3. Revitalize a large urban area in the City that is currently significantly underutilized.
The No Project Alternative would not result in any new residential or non-residential uses within the Buildout Area. Therefore, implementation of the No Project Alternative would not revitalize the Buildout Area, which is currently significantly underutilized. As such, the No Project Alternative would not meet this project objective.
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.
As discussed above, the No Project Alternative would not result in any new residential uses within the Buildout Area. Therefore, implementation of the No Project Alternative would not 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. As such, the No Project Alternative would not meet this project objective.
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.
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As discussed above, the No Project Alternative would not result in any new residential or nonresidential uses within the Buildout Area. Therefore, implementation of the No Project Alternative would not 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. As such, the No Project Alternative would not meet this project objective.
6. Develop a project that will invigorate the local economy by providing new employment and business opportunities.
As discussed above, the No Project Alternative would not result in any new non-residential uses within the Buildout Area. Therefore, implementation of the No Project Alternative would not invigorate the local economy by providing new employment and business opportunities. As such, the No Project Alternative would not meet this project objective.
7. Provide residential and commercial/retail improvement that generate new sources of revenue for the City through increased property values and retail sales.
As discussed above, the No Project Alternative would not result in any new residential or nonresidential uses within the Buildout Area. Therefore, implementation of the No Project Alternative would not provide residential and commercial/retail improvements that generate new sources of revenue for the City through increased property values and retail sales. As such, the No Project Alternative would not meet this project objective.
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.
The No Project Alternative would not include the extension of Moody Street from Cerritos Avenue to Katella Avenue and the extension of Vessels Circle from its current western terminus to intersect with the Moody Street extension as no development within the Buildout Area would occur. Therefore, the Not Project Alternative would not improve overall traffic circulation in the vicinity of the Buildout Area. As such, the No Project Alternative would not meet this project objective.
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.
As discussed above, the No Project Alternative would not result in any new residential or nonresidential uses within the Buildout Area. As such, the No Project Alternative would not meet this project objective.
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5.5.2 Historic Preservation Alternative
5.5.2.1 Description
The Historic Preservation Alternative would develop new residential and non-residential uses within the Buildout Area and would retain the existing character-defining features at LARC that contribute to the LARC’s eligibility for listing in the National Register and California Register, as shown in Figure 5-1. The character-defining features, including the original pre-1970 track, the 1954 quartermile chute, the infield and ponds, and a portion of the grandstand, would be converted into a performance venue for future concerts, plays, and other entertainment performances. When not being used as a performance venue, Lots 5 through 8 and portions of Lots 3 and 4 would be open to the public as a park or recreational use. All non-historic features of the race course, including the race-track extensions, barns, temporary buildings, clubhouse building, and annex would be demolished. Existing restaurants, food service, and the three existing lakes within the original race track would be retained. The Historic Preservation Alternative also includes a six-level above-ground parking structure with 1,600 parking spaces (1 space for every 3 seats) to accommodate the performance venue and account for the loss of parking at the race course, as shown in Figure 5-1.
Implementation of the Historic Preservation Alternative would require a Specific Plan amendment, which would have to be voter approved, to allow the performance venue use within the MediumDensity Residential District and Single-Family Attached Subdistrict. In addition, the Historic Preservation Alternative would require approval of a VTTM, similar to the proposed project. The proposed lots in the VTTM would be different than the proposed project and would include a lot for the race course improvements being retained and to accommodate the event venue use and related modifications of other lots.
Residential and Commercial Development. Under the Historic Preservation Alternative, development on Lots 2, 10, 11, 12, and 14 would be the same as the proposed project. In addition, similar to the proposed project, Lots 5 and 6 would be limited to parks and recreational uses.
Table 5.A: Comparison of Project Buildout for the Proposed Project and Historic Preservation Alternative provides a comparison of the development proposed on each lot for the proposed project and the Historic Preservation Alternative.
As part of the Historic Preservation Alternative, Lot 7 would be limited to parks and recreational uses, as opposed to the residential uses proposed under the project. In addition, portions of Lots 3 and 4 would also include parks and recreational uses and the development area within Lot 13 would be reduced as compared to the proposed project.
Further, the Historic Preservation Alternative would only transfer ownership of an approximately 1- acre portion of Lot 8 to Grace Church and would develop the remaining 3-acres of Lot 8 with parks and recreational uses, similar to Lots 5, 6, 7, and portions of Lots 3 and 4. Similar to the proposed project, no development is proposed on Lot 9 and the ownership of Lot 5 would be transferred from Grace Church to LARC.
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SOURCE: Forma - Aug 2025
FEET
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FIGURE 5-1
Historic Preservation Alternative
Los Alamitos Race Course Development Project
CYPRESS TOWN CENTER AND COMMONS Historic Preservation Alternative 0 75 150 August 2025
Grandstand to Remain
• Event Seating (3,694 seats)
• Restaurant and Food Services - 2nd and 3rd Floors
• Equipment Storage, Dressing Rooms, Offices and
Rehearsal Space - 1st Floor
Permanent
Clamshell Stage
Access to
Parking Structure
,
Katella Avenue
Access from
Katella Ave.
Infield and Ponds
Original Oval Track to Remain
to Remain
Existing Chute
to Remain
,
Infield Seating - 500
New Parking Structure
• 6 Levels
• Approx. 1,600 Spaces
(1 space for every 3 seats)
Temporary Track
,
Seating - 500
Landscaping to Remain
tr
:j
I ~
· l
JfF ' -
I II
; &
LSA
$
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Table 5.A: Comparison of Project Buildout for the Proposed Project and Historic Preservation Alternative
Lot No.
Proposed Project Historic Preservation Alternative
Land Use
Number of Dwelling
Units / NonResidential Floor AreaLand Use
Number of Dwelling
Units / NonResidential Floor Area
1 Parks and Recreation - Parks and Recreation -
2 Residential (Senior
Housing) 404 du Residential (Senior Housing) 404 du
3 Residential 269 du Residential and Parks
and Recreation 210 du
4 Residential 141 du Residential and Parks
and Recreation 134 du
5 Parks and Recreation - Parks and Recreation -
6 Parks and Recreation - Parks and Recreation -
7 Residential 309 du Parks and Recreation1 -
8 No Development - Parks and Recreation2 -
9 No Development - No Development -
10 Mixed-Use 29 du Mixed-Use 29 du
11 Mixed-Use 51 du Mixed-Use 51 du
12 Mixed-Use 265 du Mixed-Use 265 du
13 Mixed-Use 195 du Mixed-Use 179 du
14 Mixed-Use 128 du Mixed- Mixed-Use 128 du
10-14 Non-Residential 440,000 sq ft Non-Residential 440,000 sq ft Total
1,400 residential units
440,000 square feet of
non-residential floor
area
Source:
1. Includes the clamshell stage, permanent infield seating, and temporary infield seating.
2. Ownership of approximately 1-acre of Lot 8 would be transferred to Grace Church.
Overall, the Historic Preservation Alternative would result in development of 1,400 residential units and 440,000 square feet of non-residential development, in addition to the events venue. As such, implementation of the Historic Preservation Alternative would result in an approximately 22 percent reduction in residential units, or 391 fewer residential units, as compared to the proposed project and the same amount of non-residential floor area as the proposed project.
The Historic Preservation Alternative would also include the extension of Vessels Circle like the proposed project, and the extension of Siboney Street to connect to the intersection of the Vessels Circle extension. Under the Historic Preservation Alternative, Moody Street would not be extended to Katella Avenue to create a new north-south connection between Cerritos Avenue and Katella Avenue.
Event Space. A new approximately 3,500-square foot clamshell stage would be constructed within Lot 7, facing south towards the existing grandstands and away from Cerritos Avenue. In addition, permanent infield seating for approximately 500 guests and temporary seating on the track for approximately 500 guests would also be provided facing the stage. Including the 3,694 seats S PECIFIC PLAN 3.0 B UILDOUT P ROJECT
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associated with the existing grandstand, which would be retained, the Historic Preservation Alternative would result in a total of 4,694 seats for the performance venue. The oval track, chute, and infield would be utilized as a public park when the performance venue is not in use and the track and chute would be used for walking, cycling and running paths with the infield available for passive park activities, including picnic areas, playgrounds, and/or gardens. In addition, the two existing ponds would be retained and would contain paddle boats and/or canoes available for rent.
Food and beverage services, similar to existing facilities within the grandstand, would be available during performances and may also be available during non-performance hours for visitors to the public park amenities. The existing restaurant would be retained. The lower two floors of the grandstand would be utilized for equipment storage, offices, dressing rooms, and rehearsal space. In addition to the preserved LARC facilities, a 6-level parking structure containing approximately 1,600 parking spaces would be constructed west of the grandstand to provide parking for future events hosted at the performance venue, consistent with Section 2.06.050 of the City’s Municipal Code.
5.5.2.2 Comparison of Environmental Impacts
Aesthetics. The following provides a comparison of potential aesthetic impacts between the proposed project and the Historic Preservation Alternative.
Scenic Vistas and Scenic Resources. 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. Similar to the proposed project, given that no scenic vista is currently viewable from any public vantage point in proximity to the Buildout Area, the development of the Historic Preservation Alternative would not alter an existing scenic vista or block views of any scenic vistas. Therefore, the Historic Preservation Alternative would not have a substantial adverse effect on a scenic vista. In addition, 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 Pacific Coast Highway.
Therefore, the Historic Preservation Alternative would have no impact related to the substantial damage of scenic resources within a State Scenic Highway, similar to the proposed project.
Visual Character and Public Views. The aesthetic character of the Buildout Area would change with implementation of the Historic Preservation Alternative during both construction and operation.
Construction of the proposed project would introduce the use of machinery such as excavators and bulldozers, and the presence of the construction equipment, as well as the construction activities, would temporarily alter the visual character of the project site. In addition, the Historic Preservation Alternative would develop the Buildout Area with similar uses as the proposed project, including residential and non-residential uses; while retaining the existing LARC character-defining features that contribute to the LARC’s eligibility for listing in the National Register and California Register. The Historic Preservation Alternative would also result in an approximately 22 percent reduction in residential units, or 391 fewer residential units, as compared to the proposed project and the same amount of non-residential floor area as the proposed project. The character-defining features, including the original pre-1970 track, the 1954 quarter-mile chute, the infield and ponds, and a portion of the grandstand, would be converted into a performance venue for future concerts, plays, and other entertainment performances. The Historic Preservation Alternative also includes a sixlevel above-ground parking structure with 1,600 parking spaces to accommodate the performance
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venue and account for the loss of parking at the race course, which would introduce a new large structure at the Buildout Area that would alter the visual character of the Buildout Area.
However, construction would be temporary and, due to the phased nature of construction activities, would be staggered across the project site. Therefore, the visual character of the Buildout Area would not be significantly impacted during construction activities. In addition, although the Historic Preservation Alternative includes the construction of a six-level above-ground parking structure which would introduce a new large structure at the Buildout Area that would alter the visual character of the Buildout Area, because the Historic Preservation Alternative would retain the original pre-1970 track, the 1954 quarter-mile chute, the infield and ponds, and a portion of the grandstands, which are prominent aesthetic features of the Buildout Area, implementation of the Historic Preservation Alternative would alter the aesthetic character of the Buildout Area to a lesser degree when compared to the proposed project. All development pursuant to the Specific Plan would be required to consider and comply with, as applicable, relevant sustainable design guidelines stated or referenced in the Specific Plan. Similar to the proposed project, development would also be subject to applicable Zoning Ordinance design regulations related to scenic quality, including the objective design standards in Section 3.17.110 of the Zoning Ordinance for multi-family development. Therefore, the Historic Preservation Alternative would have a less than significant impact related to conflict with applicable zoning and other regulations governing scenic quality, similar to the proposed project.
Light and Glare. As the Buildout Area is in an urbanized area, 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. Similar to the proposed project, all development within the Buildout Area would be required to comply with all applicable requirements related to light and glare, including applicable regulations of the 2022 State Building Energy Efficiency Standards (Title 24), all applicable sustainable design strategies related to lighting in the Specific Plan, and all applicable development standards related to lighting in the Zoning Ordinance. Consistent with these requirements and similar to the proposed project, all lighting associated with the Historic Preservation Alternative would be shielded such that it would minimize light spillage onto adjacent properties. Similar to the proposed project, building exteriors of future development facilitated by the Historic Preservation Alternative would generally be covered by non-reflective materials, which would minimize glare, and glass windows would be incorporated into each building design in accordance with development standards established in the Specific Plan and the City’s Municipal Code.
The Historic Preservation Alternative would include a performance venue that would likely require stadium-style lighting during events. While the proposed project would include lighting typical of residential and commercial uses, the Historic Preservation Alternative would introduce additional lighting and would result in greater lighting impacts relative to the proposed project.
Similar to the proposed project, new lighting associated with the Historic Preservation Alternative would be required to meet all applicable lighting standards in the City’s Zoning Ordinance as outlined in the Section 4.1, Aesthetics, of this Draft EIR: Section 3.11.060.A (Exterior Features); Section 3.11.060.B (Intensity); Section 3.11.060.C (Security Lighting); Section 3.11.060.D (Shielding S PECIFIC PLAN 3.0 B UILDOUT P ROJECT
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of Light Source); Section 3.14.050.C.4 (Required Improvements for Off-Street Parking Areas); and Section 3.15.110 (Standards for Specific Types of Signs). Proposed lighting would also be required to comply with Section 4.6: Lighting, of the Specific Plan.
Overall, although the Historic Preservation Alternative would result in greater, more substantial sources of lighting than the proposed project, aesthetic impacts would remain less than significant with adherence to existing development standards established in the Specific Plan and the City’s Municipal Code.
Agriculture and Forestry Resources. The Historic Preservation Alternative would develop the same area of the city (i.e., Buildout Area) with similar uses as the proposed project, including residential and non-residential uses. As discussed in Section 4.2, Agriculture and Forestry Resources, the entire Buildout Area and surrounding area is designated as “Urban and Built-Up Land” by the California Department of Conservation’s California Important Farmland Finder. In addition, the Buildout Area is not used for agricultural or forestry production and is not protected by, or eligible for, a Williamson Act contract. Therefore, the Historic Preservation Alternative would have no impact related to agriculture and forestry resources, similar to the proposed project.
Air Quality. The following provides a comparison of potential air quality impacts between the proposed project and the Historic Preservation Alternative.
Construction. Although the Historic Preservation Alternative would include less demolition compared to the proposed project due to the retention of the LARC character-defining features, construction activities, such as site preparation, grading, construction of structures, and architectural coating of structures, would be similar to the proposed project and is anticipated to result in similar air quality emissions. As such, similar to the proposed project, construction emissions associated with full buildout of the Historic Preservation Alternative would not exceed the SCAQMD thresholds for VOCs, NOx, CO, SOX, PM2.5, or PM10 emissions. Therefore, with compliance with regulatory requirements (as specified in Regulatory Compliance Measures AIR-1 through AIR-4), construction impacts related to the cumulatively considerable net increase of any criteria pollutant for which the project region is in nonattainment under applicable federal or State ambient air quality standard would be less than significant, similar to the proposed project.
Operation. As discussed in Section 4.3, Air Quality, operation of the proposed project would result in VOC emissions that would exceed the SCAQMD’s significance criteria even with implementation of Mitigation Measure AIR-1 and Mitigation Measure TRA-1. As there are no additional feasible mitigation measures that would reduce project operational-source VOC emissions to a less-thansignificant 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.
The Historic Preservation Alternative would reduce operational emissions associated with the residential development due to the 22 percent reduction in residential units; however, due to the inclusion of the performance venue, which would result in an increase in vehicle trips to and from the project site as compared to the proposed project, and 6-story parking garage, implementation of the Historic Preservation Alternative may not reduce the overall emissions associated with operation of the alternative. In addition, the air quality emissions under the Historic Preservation
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Alternative have not been quantified. Accordingly, this Draft EIR includes a qualitative, comparative discussion of this alternative based on available information and professional judgement, and it is therefore assumed that implementation of the Historic Preservation Alternative would also result in 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, even with implementation of Mitigation Measure AIR-1 and Mitigation Measure TRA-1.
Health Risk Assessment. Construction of development envisioned under the Historic Preservation Alternative may expose nearby sensitive receptors to airborne particulates and pollutants from construction equipment (i.e., usually diesel-fueled vehicles and equipment). Therefore, Mitigation Measure AIR-2, which requires the use of U.S. EPA 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 or the preparation of project-specific construction HRA in certain circumstances, would be applicable to the Historic Preservation Alternative. Therefore, this impact would be less than significant with mitigation incorporated, similar to the proposed project. In addition, similar to the proposed project, the Historic Preservation Alternative would not include the development of any uses identified by CARB as being substantial source of TACs that would require specific siting distances based on CARB recommendations. In addition, the industrial uses near the Buildout Area on the western and eastern boundaries are further than 500 feet, so any new sensitive receptors, such as proposed residential uses, will be consistent with CARB’s siting recommendations. Therefore, impacts related to TACs would be less than significant, similar to the proposed project.
Conflict with Applicable Air Quality Plans. As discussed in Section 4.3, Air Quality, the proposed project would be consistent with Indicator 2 of the 2022 Air Quality Management Plan (AQMP) as the proposed project would not exceed the growth assumptions in Connect SoCal 2024 or the 2022 AQMP; however, 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. Overall, even with implementation of Mitigation Measure AIR-1 and Mitigation Measure TRA-1, the proposed project would result in a significant and unavoidable impact associated with conflict with applicable air quality management plans. Although the Historic Preservation Alternative would reduce operational emissions associated with the residential development due to a 22 percent reduction in residential units, with the inclusion of the performance venue and parking garage, and because the air quality emissions under the Historic Preservation Alternative have not been quantified, implementation of the Historic Preservation Alternative would also result in a significant and unavoidable impact associated with conflict with applicable air quality management plans.
Odors. Construction of the Historic Preservation Alternative would generate similar odors as construction of the proposed project. Similar to the proposed project, these odors would be S PECIFIC PLAN 3.0 B UILDOUT P ROJECT
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temporary and limited to the construction period. The Historic Preservation Alternative would also not include any activities or operations that would generate objectionable odors and once operational, development envisioned under the Historic Preservation Alternative would not be a source of odors. Therefore, the Historic Preservation Alternative would not result in other emissions (such as those leading to odors) affecting a substantial number of people, similar to the proposed project.
Overall, implementation of the Historic Preservation Alternative would have a significant and unavoidable air quality impact, even with implementation of Mitigation Measures AIR-1 and AIR-2, and Mitigation Measure TRA-1 and adherence to Regulatory Compliance Measures AIR-1 through AIR-4, similar to the proposed project.
Biological Resources. The Historic Preservation Alternative would develop the same area of the city (i.e., Buildout Area) with similar uses as the proposed project, including residential and nonresidential uses. The following provides a comparison of potential impacts to biological resources between the proposed project and the Historic Preservation Alternative.
Habitats and Vegetation Communities. As discussed in Section 4.4, Biological Resources, the Buildout Area primarily consists of developed land cover. The dominant vegetation within this vegetation community includes ornamental landscaping and ruderal grassland with patches of herbaceous invasive species. Other vegetation communities within the Buildout Area include ornamental landscaping and artificial ponds. In addition, no portion of the Buildout Area contains designated or proposed critical habitat for any federally listed plant or animal species. Further, there is a high level of existing disturbance within the Buildout Area, and native wildlife habitat is largely absent within the Buildout Area and in the vicinity. The development surrounding the Buildout Area and the lack of ground cover and suitable foraging habitat make the site undesirable for many native wildlife species. Therefore, implementation of the Historic Preservation Alternative would have no impact on any native habitats or vegetation communities, similar to the proposed project.
Special-Status Plant Species. As discussed in Section 4.4, Biological Resources, no special-status plants were observed within the Buildout Area during the reconnaissance survey; and none of the 30 special-status plant species from the records searches are expected to occur within the Buildout Area due to the lack of suitable habitat and/or conditions. Therefore, implementation of the Historic Preservation Alternative would have no impact on any special-status plant species, similar to the proposed project.
Special-Status Wildlife Species and Migratory/Nesting Birds. As discussed in Section 4.4, Biological Resources, no special-status wildlife species were observed during the field survey, and suitable habitat for such species is absent from the Buildout Area due to the high level of development. In addition, no nesting birds or their nests were observed at the time of the field survey. However, based on a review of resource databases, 6 special-status wildlife species have the potential to occur on or near the Buildout Area, including monarch butterfly (Danaus plexippus plexippus), Ferruginous hawk (Buteo regalis), Swainson’s hawk (Buteo swainsoni), western mastiff bat (Eumops perotis californicus), western yellow bat (Lasiurus xanthinus), and pocketed free-tailed bat (Nyctinomops femorosaccus). In addition, although no sign of roosting bats was observed during the September 2024 field survey, suitable day and night roosting habitat could be present at several of the building
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structures throughout the Buildout Area and within the ornamental palm trees located around the Buildout Area. Additionally, other ornamental tree species within the Buildout Area could provide habitat to native bats in the form of foliage, bark, or cavity roosts.
Implementation of the Historic Preservation Alternative would develop the Buildout Area with similar uses as the proposed project and anticipated construction activities, including site preparation and grading activities, would be similar. In addition, potential direct and/or indirect impacts (e.g., noise during construction) could potentially disrupt or otherwise adversely affect bird nesting activities in and/or adjacent to the Buildout Area if construction activities would occur within the nesting bird season (between February 1 and August 31). Because construction of the Historic Preservation Alternative would be similar as compared to the proposed project, impacts on special-status species, including bats, and nesting birds would be similar with implementation of the Historic Preservation Alternative as the proposed project. Therefore, the Historic Preservation Alternative would also be required to adhere to Regulatory Compliance Measure BIO-1, requiring pre-construction bay surveys, and Regulatory Compliance Measure BIO-2, requiring preconstruction nesting bird surveys and active nest avoidance buffers during construction, and impacts would be less than significant.
Riparian Habitat and Sensitive Natural Communities. As discussed in Section 4.4, Biological Resources, the Buildout Area currently contains one existing drainage feature, one existing detention basin, and three existing artificial ponds. All of these aquatic features were constructed in previously graded or developed areas and do not represent natural stream channels, wetlands, or riparian systems. Their primary functions are aesthetic or related to stormwater conveyance and retention. As such, no riparian habitat is present within the Buildout Area. Therefore, similar to the proposed project, no impacts to riparian habitat would result from implementation of the Historic Preservation Alternative.
Jurisdictional Waters. As previously discussed, there is one drainage feature, one detention basin, and three ponds within the Buildout Area. The three ponds and the detention basin are not expected to be regulated by USACE, RWQCB, or CDFW. In addition, implementation of the Historic Preservation Alternative would not include the removal of the three ponds. However, the single drainage feature located on Lot 3 contains ruderal vegetation and may connect to Coyote Creek, which is tributary to the San Gabriel River and ultimately flows into the Pacific Ocean. Therefore, the removal of this drainage may be subject to regulation by the RWQCB and CDFW. Therefore, similar to the proposed project, the Historic Preservation Alternative would be required to implement Mitigation Measure BIO-1, which requires a jurisdictional delineation be conducted prior to construction. In addition, similar to the proposed project, the Historic Preservation Alternative would be required to adhere to Regulatory Compliance Measures HYD-1 through HYD-3 during construction and operation to address erosion-related impacts through implementation of construction site BMPs and operational-period biotreatment BMPs to avoid erosion and sedimentation impacts to downstream aquatic areas and water quality. With implementation of Mitigation Measure BIO-1 and adherence to Regulatory Compliance Measures HYD-1 through HYD-3, implementation of the Historic Preservation Alternative would result in less than significant impacts on jurisdictional waters, similar to the proposed project.
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Wildlife Movement and Nursery Sites. As discussed in Section 4.4, Biological Resources, the Buildout Area does not function as a wildlife movement corridor. In addition, as discussed above, the Historic Preservation Alternative would comply with Regulatory Compliance Measure BIO-1, requiring pre-construction bay surveys, and Regulatory Compliance Measure BIO-2, requiring preconstruction nesting bird surveys and active nest avoidance buffers during construction. Therefore, similar to the proposed project, implementation of the Historic Preservation Alternative would have a less than significant impact related to wildlife movement and nursey sites.
Local Policies and Ordinances. Similar to the proposed project, construction of Historic Preservation Alternative would involve tree removal activities. As required by Article 3, Performance and Development Standards, Section 13 (3.13.070(c)), of the Municipal Code, existing trees would be preserved when feasible. In addition, all tree removal activities would be consistent with Section 3.9 of the Specific Plan, which supersedes the City’s Landmark Tree Ordinance, as codified in Sections 17-17 through 17-27 of the City Municipal Code, and details the tree replacement development standards for development within the Buildout Area. Consistent with Specific Plan requirements, all tree removal required for future development would be described during site plan review and all removed trees would be replaced with an equivalent number of specimen trees. With adherence to the tree replacement development standards detailed in the Specific Plan, the Historic Preservation Alternative would not conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance, similar to the proposed project, and impacts would be less than significant.
Overall, implementation of the Historic Preservation Alternative would have a less than significant impact related to biological resources with adherence to Regulatory Compliance Measures BIO-1 and BIO-2 and implementation of Mitigation Measure BIO-1, similar to the proposed project.
Cultural Resources. The following provides a comparison of potential impacts to cultural resources between the proposed project and the Historic Preservation Alternative.
Historical Resources. The Historic Preservation Alternative would develop the same area of the city (i.e., Buildout Area) with similar uses as the proposed project, including residential and nonresidential uses; however, the existing character-defining features at LARC that contribute to LARC’s eligibility for listing in the National Register and California Register would be retained for use as a performance venue for future concerts, plays, and other entertainment performances. The existing LARC character-defining features 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.
All improvements to the existing LARC character-defining features under the Historic Preservation Alternative, would be completed in compliance with the Secretary of the Interior's Standards for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating, Restoring, and Reconstructing Historic Buildings or the Secretary of the Interior's Standards for Rehabilitation and
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Guidelines for Rehabilitating Historic Buildings1 (Secretary’s Standards). The Secretary’s Standards provide guidance for working with historic properties (and historical resources under CEQA) and are used by federal agencies and local governments to evaluate proposed rehabilitation, restoration, preservation, and reconstruction work on historical resources; they are applied to a wide variety of resource types, including buildings, sites, structures, objects, and districts.
The Secretary’s Standards comprise four sets of standards to guide the treatment of historic properties and historical resources: Preservation, Rehabilitation, Restoration, and Reconstruction.
Typically, one set of standards is chosen for a project based on the project scope. These four distinct treatments are defined as follows:
• Preservation: The Standards for Preservation “... require retention of the greatest amount of historic fabric, along with the building’s historic form, features, and detailing as they have evolved over time.”
• Rehabilitation: The Standards for Rehabilitation “... acknowledge the need to alter or add to a historic building to meet continuing new uses while retaining the building’s historic character.” • Restoration: The Standards for Restoration “... allow for the depiction of a building at a particular time in its history by preserving materials from the period of significance and removing materials from other periods.”
• Reconstruction: The Standards for Reconstruction “... establish a limited framework for recreating a vanished or non-surviving building with new materials, primarily for interpretive purposes.” 2
Typically, one set of standards is chosen for a project based on the project scope. In terms of the Secretary’s Standards, only one treatment standard, Rehabilitation, addresses potential impacts to the setting by new construction. Therefore, the Historic Preservation Alternative would be required conforms to the Secretary’s Standards for Rehabilitation. Of the 10 Standards for Rehabilitation issued, only two, Standards 9 and 10, most directly address new construction and would be applicable to the Historic Preservation Alternative. Rehabilitation Standards 9 and 10 are quoted below.
• Standard 9: New additions, exterior alterations, or related new construction shall not destroy historic materials that characterize the property. The new work shall be differentiated from the old and shall be compatible with the massing, size, scale, and architectural features to protect the historic integrity of the property and its environment. 1 Weeks, Kay D., and Anne Grimmer. 2017. The Secretary of the Interior’s Standards for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating, Restoring & Reconstructing Historic Buildings. U.S. Department of the Interior, National Park Service, Technical Preservation Services, Washington, D.C. 2 Ibid. Pages 2-3.
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• Standard 10: New additions and adjacent or related new construction shall be undertaken in such a manner that if removed in the future, the essential form and integrity of the historic property and its environment would be unimpaired.
Because it would retain the existing character-defining features, including the pre-1970 track, the 1954 quarter-mile chute, the infield and ponds, and a portion of the grandstand, implementation of the Historic Preservation Alternative would not result in a material impairment of the LARC as a historical resource and Mitigation Measures CUL-1 through CUL-3, which requires documentation of the historic resource in accordance with the Historic American Building Survey (HABS) standards, would not be applicable or required and implementation of the Historic Preservation Alternative would avoid the significant and unavoidable impact to built-environment historic resources as defined in State CEQA Guidelines Section 15064.5 associated with the proposed project. Other noncharacter defining features of LARC would be demolished under the Historic Preservation Alternative; however, because these structures do not contribute to the LARC’s eligibility for listing in the National Register and California Register, demolition of these structures would not result in a significant impact related to built historical resources.
Archaeological Resources. In addition, construction of the Historic Preservation Alternative has the potential to significantly impact unidentified archaeological resources during ground-disturbing activities. Therefore, similar to the proposed project, the Historic Preservation Alternative would be required to adhere to Regulatory Compliance Measure CUL-1, which detail provisions in the event that previously unknown cultural resources, including human remains, are discovered during ground-disturbing construction activities, consistent with the California Code of Regulations (CCR) Section 15064.5(e) and State Health and Safety Code Section 7050.5. Further, similar to the proposed project, the Historic Preservation Alternative would also be required to adhere to Regulatory Compliance Measure CUL-2 for the treatment of human remains in order to ensure that descendant communities have significant input in the treatment and final disposition of human remains, if encountered at the project site during future development activities. With adherence to Regulatory Compliance Measures CUL-1 and CUL-2, implementation of the Historic Preservation Alternative would result in less than significant impacts related to archaeological resources and human remains.
Overall, implementation of the Historic Preservation Alternative would have a less than significant impact related to cultural resources with adherence to Regulatory Compliance Measures CUL-1 and CUL-2 and would avoid the significant and unavoidable impact to built-environment historic resources as defined in State CEQA Guidelines Section 15064.5 associated with the proposed project.
Energy. Implementation of the Historic Preservation Alternative would result in 391 fewer residential units as compared to the proposed project and the same amount of commercial uses as the proposed project. This would result in a corresponding reduction in energy use associated with the residential development during construction and operation, as compared to the proposed project. However, construction and operation of the performance venue, which would host future concerts, plays, and other entertainment performances, and construction and operation of the 6- story parking garage and 500-seat clamshell would result in new energy use and demand.
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Construction. Although the Historic Preservation Alternative would include less demolition compared to the proposed project due to the retention of the LARC character-defining features, construction activities, such as site preparation, grading, construction of structures, and architectural coating of structures, would be similar to the proposed project and are anticipated to result in similar energy use. As such, similar to the proposed project, construction energy use would not cause or result in the need for additional energy facilities or an additional or expanded delivery system and fuel consumption during construction would not be more inefficient, wasteful, or unnecessary than other similar development projects of this nature, and impacts would be less than significant, similar to the proposed project.
Electricity and Natural Gas. Based on the total electricity and natural gas demand in Orange County, operational activities associated with buildout of the Historic Preservation Alternative would increase the annual electricity consumption in Orange County by a negligible percent.
Future development envisioned under the Historic Preservation Alternative would be constructed to meet sustainability in accordance with: Appliance Efficiency Regulations (Title 20, CCR Sections 1601 through 1608), the CALGreen Code, Title 24 energy efficiency requirements, and AB 1881 water efficient landscape requirements.
Similar to the proposed project, the expected energy consumption during construction and operation associated with future buildout envisioned under the Historic Preservation Alternative would be consistent with typical usage rates for residential and commercial uses; however, energy consumption is largely a function of personal choice and the physical structure and layout of buildings. As such, electrical and natural gas demand associated with operation of the Historic Preservation Alternative would not be considered inefficient, wasteful, or unnecessary in comparison to other similar developments in the region. Therefore, impacts would be less than significant, similar to the proposed project.
Fuel Usage. Operation of the Historic Preservation Alternative would also result in energy usage associated with gasoline and diesel fuel consumed by vehicle trips. While vehicle trips would be similar for commercial uses and lower for residential uses, due to the reduction in units, new trips would be generated associated with future concerts, plays, and other entertainment performances hosted at the proposed performance venue. Even though the Historic Preservation Alternative would result in more vehicle trips than the proposed project, based on fuel consumption from vehicle trips in Orange County, the increase in vehicle trips associated with buildout of the Historic Preservation Alternative is expected to increase annual fuel consumption in Orange County by a negligible percent, similar to the proposed project.
Lastly, implementation of the Historic Preservation Alternative would not conflict with or obstruct compliance with State or local plans for renewable energy or energy efficiency, similar to the proposed project as energy impacts of the Historic Preservation Alternative at the regional level would be negligible. Because California’s energy conservation planning actions are conducted at a regional level, and because the Historic Preservation Alternative’s total impact on regional energy supplies would be minor, buildout of the Historic Preservation Alternative would not conflict with or obstruct California’s energy conservation plans as described in the CEC’s Integrated Energy Policy Report.
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Therefore, the Historic Preservation Alternative would have a less than significant impact related to energy, similar to the proposed project.
Geology and Soils. As discussed in Section 4.7, Geology and Soils, although the Buildout Area is subject to strong ground motion resulting from earthquakes on nearby faults, there are no known faults crossing the Buildout Area. In addition, landslides have not been recorded within the City boundaries and are not anticipated based on the lack of any significant topographic features.
However, the entire city, including the Buildout Area, is designated as a liquefaction zone. Similar to the proposed project, new development within the Buildout Area facilitated by the Historic Preservation Alternative would be subject to the seismic design criteria of the 2022 California Building Standards Code requirements that aim to prevent building collapse and reduce the impacts of seismic ground shaking, as specified in Regulatory Compliance Measure GEO-1. In addition, future construction contractors would be required to comply with the recommendations in the Geotechnical Investigation, as detailed in Mitigation Measure GEO-1, to ensure liquefaction impacts are reduced to a less than significant level. Mitigation Measure GEO-1 would require that the upper soils of the Buildout Area be stabilized with ground improvement techniques beneath any structure intended for human occupancy. The ground improvements may consist of Rammed Aggregate Piers, Vibrated Aggregate Piers, or similar techniques, and would be required to be designed by a qualified ground improvement contractor in an interactive process with the geotechnical engineer and structural engineer.
Construction of the Historic Preservation Alternative would be required to comply with existing NPDES permit requirements, including the Construction General Permit, and Section 4.106 of the CALGreen Code to ensure impacts related to erosion during construction would be less than significant (Regulatory Compliance Measure HYD-1). Further, the Historic Preservation Alternative would also be required to implement stormwater management and treatment BMPs, such as detention basins and/or proprietary flow-based biofiltration systems, to address erosion impacts during operation (Regulatory Compliance Measure HYD-3).
Similar to the proposed project, construction of the Historic Preservation Alternative has the potential to disturb native alluvium at a depth that could have an impact on paleontological resources. Therefore, the Historic Preservation Alternative would also have to implement Mitigation Measures GEO-2 and GEO-3, which include provisions for unknown paleontological resources discovery stop work procedures and worker training procedures, similar to the proposed project, in order to reduce potential impacts to less than significant.
Lastly, future development within the Buildout Area under the Historic Preservation Alternative would be served by the City of Cypress and the Orange County Sanitation District and would not include the development of or use of any septic tanks or alternative wastewater disposal systems.
Therefore, the Historic Preservation Alternative would have a less than significant impact related to geology and soils with adherence to Regulatory Compliance Measure GEO-1 and implementation of Mitigation Measure GEO-1 through GEO-3, similar to the proposed project.
Greenhouse Gas Emissions. As implementation of the Historic Preservation Alternative would result in 391 fewer residential units as compared to the proposed project and the same amount of
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commercial uses as the proposed project, a corresponding reduction in GHG emissions during construction and operation compared to the proposed project would result. However, construction and operation of the performance venue, which would host future concerts, plays, and other entertainment performances, and the 6-story parking garage would result in new GHG emissions.
Similar to the proposed project, because the Historic Preservation Alternative would implement Mitigation Measure AIR-1, the Historic Preservation Alternative would be consistent with the 2022 Scoping Plan key project attribute related to EV charging requirements. However, future development under the Historic Preservation Alternative could be all-electric or could use natural gas. Therefore, Mitigation Measure GHG-1, which requires that future development either be allelectric or incorporate additional emission reduction measures if all-electric development is not feasible, would be applicable to the Historic Preservation Alternative. In addition, the Historic Preservation Alternative would also be required to implement Mitigation Measure TRA-1, which requires the implementation of TDM strategies, similar to the proposed project. Therefore, the Historic Preservation Alternative would be consistent with the identified measures and goals from Connect SoCal 2024 and, similar to the proposed project, the Historic Preservation Alternative would result in less than significant impacts related to GHG emissions based on consistency with the 2022 Scoping Plan, as described above.
In addition, as the Historic Preservation Alternative would result in less than significant impacts related to GHG emissions based on consistency with the 2022 Scoping Plan, as described above, the Historic Preservation Alternative would not conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs and impacts would be less than significant with implementation of Mitigation Measure GHG-1, Mitigation Measure AIR-1, and Mitigation Measure TRA-1, similar to the proposed project.
Overall, implementation of the Historic Preservation Alternative would have less than significant GHG impacts with implementation of Mitigation Measure GHG-1, Mitigation Measure AIR-1, and Mitigation Measure TRA-1, similar to the proposed project.
Hazards and Hazardous Materials. Similar to the proposed project, the Historic Preservation Alternative would be required to comply with existing regulations pertaining to the transport and use of hazardous materials during construction and operation, including those listed in Section 4.9, Hazards and Hazardous Materials. In addition, long-term operations activities typical uses envisioned under the Historic Preservation Alternative would be typical of residential and commercial uses. These types of activities do not involve the use of a large or substantial amount of hazardous materials. Further, such materials would be contained, stored, and used in accordance with manufacturers’ instructions and handled in compliance with applicable federal, State, and local regulations. In addition, operation of future residential and non-residential development associated with the Historic Preservation Alternative would not store, transport, generate, or dispose of large quantities of hazardous substances, similar to the proposed project. Therefore, implementation of the Historic Preservation Alternative would not create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials or emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school.
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As discussed in Section 4.9, Hazards and Hazardous Materials, a controlled recognized environmental conditional (CREC), historic recognized environmental conditional (HREC), and business environmental risk (BER) were identified within the Buildout Area. As such, the Phase I ESA recommended preparation and implementation of an Operations and Maintenance (O&M) Plan to safely manage the suspect ACMs and LBP associated with the existing buildings within the Buildout Area and the notification of the OCHCA as required in the case closure summary from 1996 for the CREC. No additional subsurface investigations were recommended. Because implementation of the Historic Preservation Alternative would occur within the same area as the proposed project and would be subject to the same hazardous conditions present within the Buildout Area, future development facilitated by the Historic Preservation Alternative would be required to implement these recommendations, similar to the proposed project and as detailed in Mitigation Measure HAZ-1. In addition, a comprehensive asbestos survey would be required prior to demolition of the non-historic structures under the Historic Preservation Alternative, consistent with SCAQMD Rule 1403 and similar to the proposed project. Therefore, impacts associated with the release of hazardous materials into the environment through reasonably foreseeable upset and accident conditions would be less than significant with adherence to existing regulatory requirements, including SCAQMD Rule 1403, and implementation of Mitigation Measure HAZ-1, requiring implementation of the recommendations provided in the Phase I ESA, similar to the proposed project.
In addition, as discussed in Section 4.9, database searches of the Buildout Area, including a GeoTracker search and a search of Superfund sites, determined that the Buildout Area is not included on a list of hazardous materials sites that could create a significant hazard to the public or the environment, is not included on the Cortese List compiled pursuant to Government Code Section 65962.5, and is not a recorded Superfund site.
Similar to the proposed project, implementation of the Historic Preservation Alternative would also not result in a safety hazard or excessive noise for people residing or working in the Buildout Area because any future development within the Buildout Area would be required to comply with all appropriate FAA standards and requirements, including Regulatory Compliance Measure HAZ-1, which requires that the FAA be notified of any proposed structure(s) that would penetrate the 100 to 1 imaginary surface that surrounds the runway at JFTB Los Alamitos.
Future development projects within the Buildout Area under the Historic Preservation Alternative would be required to conform with the adopted emergency response or evacuation plan established by the City and would be required to conform with applicable City standards and criteria that specify general fire safety provisions consistent with the California Fire Code, such as automatic, on-site fire protection systems, such as sprinklers in multi-occupancy buildings; and maintenance of certain vegetation that pose a fire hazard risk. Therefore, implementation of the Historic Preservation Alternative would not impair implementation of or physically interfere with the adopted emergency response plan or emergency evacuation plan or result in impacts related to the exposure of people or structures to a significant risk of loss, injury or death involving wildland fires.
Therefore, the Historic Preservation Alternative would have a less than significant impact related to hazards and hazardous materials with adherence to Regulatory Compliance Measure HAZ-1 and implementation of Mitigation Measure HAZ-1, similar to the proposed project.
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Hydrology and Water Quality. As the Historic Preservation Alternative would be located at the same location as the proposed project, the Historic Preservation Alternative would be subject to the same hydrologic conditions as the proposed project.
Construction. Similar to the proposed project, future development under the Historic Preservation Alternative would be required to comply with applicable construction permits and regulations associated with water quality. Specifically, if construction of future development associated with the Historic Preservation Alternative would disturb more than one acre of soil, those projects would be subject to the requirements of the General Permit for Stormwater Discharges Associated with Construction and Land Disturbance Activities, Order WQ 2022-0057-DWQ, NPDES No. CAS000002 (Construction General Permit)3
, as specified in Regulatory Compliance Measure HYD-1. As required by the Construction General Permit, the Construction Contractor would be required to prepare a SWPPP and implement construction BMPs detailed in the SWPPP during construction activities. The SWPPP would detail the BMPs to be implemented during construction. Construction BMPs would include, but not be limited to, Erosion Control and Sediment Control BMPs designed to minimize erosion and retain sediment on site, and Good Housekeeping BMPs to prevent spills, leaks, and discharge of construction debris and waste into receiving waters. If construction of future development associated with the Historic Preservation Alternative would disturb less than one acre of soil and are not a part of a larger common plan, those projects would be required to comply with Section 4.106 of the 2022 California Green Building Standards Code (CALGreen Code), as specified in Regulatory Compliance Measure HYD-1. Section 4.106 of the CALGreen Code requires implementation of BMPs to prevent flooding and erosion and to retain sediment on site.
Compliance with the requirements of the Construction General Permit or Section 4.106 of the CALGreen Code, including incorporation of construction BMPs, would ensure that construction impacts related to waste discharge requirements, water quality standards, degradation of water quality, increased pollutant discharge, and alteration of receiving water quality would be less than significant, similar to the proposed project.
In addition, similar to the proposed project, it is likely that groundwater dewatering would be required during excavation activities associated with buildout of the Historic Preservation Alternative. Groundwater dewatering activities during excavation would be conducted in accordance with 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 (Groundwater Dewatering Permit)4
, as specified in Regulatory Compliance Measure
HYD-2. This permit requires testing and treatment (as necessary) of groundwater encountered during groundwater dewatering prior to release to the storm drain system. As a result, groundwater dewatering would not introduce pollutants to receiving waters at levels that would violate water quality standards or waste discharge requirements, degrade water quality, increase pollutant discharge, or alter the quality of the receiving water. With implementation of Regulatory 3 SWRCB. 2022. National Pollutant Discharge Elimination System (NPDES) General Permit for Storm Water Discharges Associated with Construction and Land Disturbance Activities (General Permit), Order WQ 2022-0057-DWQ, NPDES No. CAS000002. Adopted September 8. 4 Santa Ana RWQCB. 2020. 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. June 19.
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Compliance Measures HYD-1 and HYD-2, impacts associated with the violation of water quality standards or waste discharge requirements during construction of the Historic Preservation Alternative would be less than significant, similar to the proposed project. Implementation of Regulatory Compliance Measures HYD-1 and HYD-2 would also ensure that construction impacts related to on-site, off-site, or downstream erosion or siltation; exceeding the capacity of the adjacent stormwater drainage systems; providing substantial additional sources of polluted runoff; resulting in an increase in any pollutant for which the receiving water body is already impaired; and causing or contributing to an exceeded applicable surface or groundwater receiving water quality objectives or degradation of beneficial uses would be less than significant, similar to the proposed project.
Operation. Implementation of the Historic Preservation Alternative would increase the amount of impervious surface area within the Buildout Area due to the development of the residential and non-residential uses, performance venue, and parking garage. However, because implementation of the Historic Preservation Alternative would retain the existing infield and ponds within the race course and would result in 391 fewer residential units as compared to the proposed project, implementation of the Historic Preservation Alternative is expected to result in less impervious surface area within the Buildout Area. During operation, the Historic Preservation Alternative would be required to comply with the requirements of 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), 5 similar to the proposed project. Compliance with the Orange County MS4 Permit is achieved through adherence to Chapter 13-23 of the Cypress Municipal Code. As required by Chapter 13-23 of the Cypress Municipal Code, and specified in Regulatory Compliance Measure HYD-3, the Historic Preservation Alternative would be required to prepare a project-specific WQMP to specify BMPs that would be implemented to capture, treat, and reduce pollutants of concern in stormwater runoff. With implementation of Regulatory Compliance Measure HYD-3, impacts associated with the violation of water quality standards or waste discharge requirements; providing substantial additional sources of polluted runoff; and resulting in an increase in any pollutant for which the receiving water body is already impaired during operation of the Historic Preservation Alternative would be less than significant, similar to the proposed project.
All stormwater from the Buildout Area under the Historic Preservation Alternative would also discharge to the Cerritos Avenue Storm Drain, Katella Avenue Storm Drain, Lexington Drive Storm Drain, and Walker Street Storm Drain and ultimately the Los Alamitos Channel, similar to the existing conditions and the proposed project. Because implementation of the Historic Preservation Alternative would result in less impervious surface area within the Buildout Area, implementation of the Historic Preservation Alternative would result in less stormwater runoff into the surrounding storm drain infrastructure as compared to the proposed project. In addition, the Historic Preservation Alternative would also be required to implement similar storm drain infrastructure 5 Santa Ana RWQCB. 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.
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improvements as the proposed project, including upsizing the existing 18-inch storm drain line in Vessels Circle to a 30-inch line to provide sufficient capacity for the 25-year high confidence storm event flowrate. Therefore, because the Drainage Report prepared for the proposed project concluded that implementation of the proposed project would not adversely affect the downstream receiving drainage facilities and the Historic Preservation Alternative would implement similar improvements to the storm drain infrastructure, implementation of the Historic Preservation Alternative would not exceed the capacity of the adjacent stormwater drainage systems, similar to the proposed project.
Similar to the proposed project, implementation of the Historic Preservation Alternative would not substantially change infiltration within the Buildout Area because the Buildout Area has low infiltration potential. In addition, even though GSWC West Orange’s water supply sources include groundwater pumped from the Orange County Groundwater Basin, increased water use during operation of the Historic Preservation Alternative would not substantially affect groundwater supplies, because the groundwater basin has been sustainably managed by OCWD over the last 10 years and is expected to continue to be sustainably managed. In addition, OCWD and GSWC West Orange coordinate in order to ensure that groundwater extracted for municipal water supplies would not substantially deplete groundwater supplies. Therefore, operational impacts related to a decrease in groundwater supplies or interference with groundwater recharge with implementation of the Historic Preservation Alternative would be less than significant, similar to the proposed project.
Because the Historic Preservation Alternative is located at the same location as the proposed project, it would be subject to the same conditions related to flooding, dam failure, seiche, tsunami, and mudflow. As discussed in Section 4.10, Hydrology and Water Quality, the Buildout Area is not located within a 100-year floodplain, an inundation zone of a levee, or an area mapped by the California Emergency Management Agency as being potentially inundated by a tsunami. In addition, the Buildout Area is relatively flat and not at risk of mudflow and, due to the distance from the nearest enclosed body of water to the Buildout Area, the Buildout Area is not in a seiche hazard zone. Therefore, no impact related to these hydrologic hazards would occur with implementation of the Historic Preservation Alternative, similar to the proposed project. However, the Buildout Area is located within the inundation zone of Prado Dam and the Carbon Canyon Dam. Although the Historic Preservation Alternative would facilitate the construction of new structures in a dam inundation zone, similar to the proposed project, the Historic Preservation Alternative would not increase the chance of inundation from failure of Carbon Canyon Dam or Prado Dam. Further, the potential for dam failure is remote and the City’s emergency evacuation plans would be implemented if these dams were susceptible to rupture during heavy rains or other events.
Therefore, impacts related to the exposure of people and structures to significant risk associated with flooding as a result of dam failure with implementation of the Historic Preservation Alternative would be less than significant, similar to the proposed project.
No riparian habitat currently exists within the Buildout Area. However, four potential jurisdictional water resources currently exist within the Buildout Area, including three artificial ponds located within the LARC racetrack area, one drainage feature, and one detention basin. The three artificial ponds are located within the interior of the track and would be retained under the Historic S PECIFIC PLAN 3.0 B UILDOUT P ROJECT
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Preservation Alternative. The existing detention basin is located along the southern Buildout Area boundary, at the northwest corner of the existing residential development located south of the Buildout Area, and the existing drainage feature extends east from this detention basin. The drainage feature and the detention basin are expected to be regulated by the Santa Ana RWQCB and CDFW. Similar to the proposed project, if the Historic Preservation Alternative would impact the drainage feature or the detention basin, regulatory permits may be required, including those under Section 404 of the CWA as administered by the USACE, the Water Quality Certification under Section 401 of the CWA or Waste Discharge Requirements under the Porter-Cologne Water Quality Control Act as administered by the Santa Ana RWQCB, or the Streambed Alteration Agreement under Section 1602 of the California Fish and Game code as administered by CDFW, as detailed in Mitigation Measure BIO-3. Therefore, with implementation of Mitigation Measure BIO-3, potential impacts on aquatic, wetland, or riparian habitat with implementation of the Historic Preservation Alternative would be less than significant, similar to the proposed project.
Therefore, the Historic Preservation Alternative would have a less than significant impact related to hydrology and water quality, similar to the proposed project.
Land Use and Planning. Similar to the proposed project, given the nature of the uses envisioned under the Historic Preservation Alternative, the future buildout of the Buildout Area would improve existing connectivity in the area with the extension of Vessels Circle and would not divide or separate any existing land uses or neighborhoods. The neighboring residential communities would not be separated by the proposed road extensions or proposed buildout of the Historic Preservation Alternative. Implementation of the Historic Preservation Alternative, if approved by voters, would carry out the vision of the Specific Plan and would remain consistent with surrounding uses. In addition, the Historic Preservation Alternative would be consistent with all General Plan and zoning designations. Therefore, the Historic Preservation Alternative would not result in the physical division of an established community, similar to the proposed project.
In addition, as the Historic Preservation Alternative would develop the Buildout Area with similar uses as the proposed project, the Historic Preservation Alternative would not be inconsistent with Connect SoCal, the City’s General Plan, or City’s Zoning Ordinance. However, in contrast to the proposed project, the Historic Preservation Alternative, as proposed, would be inconsistent with the existing uses permitted in the Specific Plan and would require amendments to the adopted Specific Plan to allow for the performance venue. These amendments require voter approval, so the likelihood of the amendments being approved by voters is not known. If the amendments to the Specific Plan were adopted, the Historic Preservation Alternative would not conflict with the Specific Plan. As such, the Historic Preservation Alternative would potentially introduce inconsistencies in the applicable City land use and planning policies. In addition, because implementation of the Historic Preservation Alternative would include 1,400 residential units (391 fewer residential units within the Buildout Area compared to the proposed project), the Historic Preservation Alternative would not be consistent with the amount of housing identified in the Specific Plan and the City’s Housing Element for the Buildout Area. Further, future development applications contemplated within the Buildout Area would also be required to comply with all applicable regulations and standards related to land use and planning. Any future development or redevelopment projects requiring discretionary actions would also be subject to environmental review, in accordance with
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the provisions of CEQA and the State CEQA Guidelines. Therefore, the Historic Preservation Alternative would have a less than significant impact related to land use and planning, similar to the proposed project.
Mineral Resources. As discussed in Section 4.12, Mineral Resources, there are no known mineral resources in or in the vicinity of the Buildout Area, and there are no other known mineral deposits or resources within the City that are of significant value to the region or the State. In addition, the Buildout Area does not contain a locally important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan. Therefore, the Historic Preservation Alternative would have no impact related to mineral resources, similar to the proposed project.
Noise. The Historic Preservation Alternative would develop the same area of the city (i.e., Buildout Area) with similar uses as the proposed project, including residential and non-residential uses; however, the existing LARC character-defining features that contribute to the LARC’s eligibility for listing in the National Register and California Register would be retained for use as a performance venue for future concerts, plays, and other entertainment performances. Overall, the Historic Preservation Alternative would result in development of 1,400 residential units and 440,000 square feet of non-residential development. As such, implementation of the Historic Preservation Alternative would result in 391 fewer residential units as compared to the proposed project and the same amount of non-residential uses as the proposed project. This would result in a corresponding reduction in operation noise associated with the residential development during operation, as compared to the proposed project. However, construction and operation of the performance venue and the 6-story parking garage would include new stationary noise sources associated with future concerts, plays, and other entertainment performances at the Buildout Area. In addition, because operation of the performance venue would increase the number of vehicle trips to and from the Buildout Area during a performance event, operation of the performance venue would also generate additional transportation noise.
Construction. Development under the Historic Preservation Alternative would generate noise and vibration associated with construction activities on a similar scale to the proposed project. Similar to the proposed project, compliance with the allowed construction hours in the City’s Noise Ordinance would ensure that construction noise does not disturb residents during typical sleeping hours or during hours when ambient noise levels are likely to be lower (i.e., at night). Therefore, and the Historic Preservation Alternative’s construction noise impacts would be less than significant, similar to the proposed project.
As discussed in Section 4.13, Noise, the nearest existing residential building at the edge of Lot 13 and south of Lot 3 would experience vibration levels below the FTA threshold for building damage.
As the Historic Preservation Alternative would also include construction activities within Lot 13, it would result in a similar less than significant impact related to vibration damage..
In addition, construction-generated ground-borne vibration associated with the Historic Preservation Alternative would not exceed FTA thresholds related to human annoyance at nearby sensitive receptors, similar to the proposed project. Therefore, similar to the proposed project, the Historic Preservation Alternative would result in less than significant impacts related to potential vibration-related human annoyance.
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Operation. As the Historic Preservation Alternative would generate more vehicle trips to and from the Buildout Area when compared to the proposed project due to the addition of the performance venue, traffic noise impacts could be greater than the proposed project. However, the level of transportation noise increase is still expected to be less than 3 dBA and would not be perceptible to the human ear in an outdoor environment. Therefore, off-site traffic noise impacts would be less than significant, similar to the proposed project.
Similar to the proposed project, development under the Historic Preservation Alternative would generate various on-site stationary noise sources, including heating, ventilation, and air conditioning (HVAC) and commercial uses activities such as loading and unloading and parking lot activities. In addition, concerts, plays, and other entertainment performances at the performance venue would generate a substantial amount of noise. The Cypress Municipal Code limits non-construction noise experienced at surrounding noise-sensitive uses to 55 dBA or less per the hourly daytime noise level standards for Noise Zone 1 and 60 dBA or less for Noise Zone 2. Similar to the proposed project, preparation of a specific acoustical analysis would be required to confirm compliance with the City’s exterior and interior noise standards related to land use compatibility, as established in City of Cypress Municipal Code Chapter 8 (Noise), Sections 8-1-4 and 8-1-5, which set forth allowable noise limits by noise zone and authorize the City to require noise measurements or acoustical studies to verify compliance with applicable standards prior to or following project occupancy. In addition, City of Cypress Municipal Code Chapter 9 details provisions for live entertainment permits that are relevant for businesses or venues hosting performances, including requiring a plan for control of noise affecting nearby premises, specifically to prevent nuisance noise to nearby residents/businesses. Chapter 9 also states that noise from live entertainment must not exceed the City’s noise standards detailed in the City of Cypress Municipal Code, meaning operators hosting concerts or performances must comply with standard noise limits and include mitigation strategies in their permit applications. Therefore, the Historic Preservation Alternative would be anticipated to meet the City’s noise standards and impacts would be less than significant, similar to the proposed project.
In addition, as the Historic Preservation Alternative would be located in the same area as the proposed project, the Historic Preservation Alternative would also be located within the 60 dBA CNEL noise contour, but outside of the 65 dBA CNEL noise contour for JFTB Los Alamitos. The Buildout Area is also located within Noise Impact Zone 2 (moderate noise impact) and is outside of Noise Impact Zone 1 (high noise impact) defined by the Airport Environs Land Use Plan. However, similar to the proposed project, given that the Historic Preservation Alternative does not contain outdoor sensitive receptors and the City defined levels between 60 and 65 dBA CNEL as conditionally acceptable with the incorporation of an HVAC system allowing a windows- closed condition and standard building construction, impacts related to exposing people residing or working in the area to excessive noise levels due to airport operations would be less than significant, similar to the proposed project.
Overall, under the Historic Preservation Alternative, operational noise impacts would be greater than the proposed project due to the development of the performance venue. Nevertheless, implementation of the Historic Preservation Alternative would have a less than significant noise impact with implementation of Mitigation Measure NOI-1, similar to the proposed project.
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Population and Housing. The Historic Preservation Alternative would result in development of 1,400 residential uses and 440,000 square feet of non-residential development. This represents 391 fewer residential units as compared to the proposed project and the same amount of non-residential uses as the proposed project.
Due to the reduction of 391 residential units in comparison to the proposed project, implementation of the Historic Preservation Alternative would result in fewer future residents within the Buildout Area when compared to the proposed project. Assuming a ratio of 3.08 people per household, the Historic Preservation Alternative would result in a net increase of approximately 4,312 persons at full buildout.
6 This represents a reduction of 1,204 new residents within the Buildout Area with full buildout of the alternative compared to the proposed project.
Similar to the proposed project, the Specific Plan allows for the construction of the residential uses facilitated by the Historic Preservation Alternative and the reduced population increase associated with the Historic Preservation Alternative is within the planned growth for the region. As such, the Historic Preservation Alternative would not result in unplanned growth as the City has already planned for the reasonably foreseeable development of housing within the Buildout Area as a way of meeting the City’s RHNA obligations. However, because implementation of the Historic Preservation Alternative would include 1,400 residential units (391 fewer residential units within the Buildout Area compared to the proposed project), the Historic Preservation Alternative would not be consistent with the amount of housing identified in the Specific Plan and City’s Housing Element for the Buildout Area. In addition, as the Buildout Area does not contain any habitable or occupied structures, implementation of this alternative would not require the demolition of existing housing and would not displace an existing population residing within the Buildout Area.
Therefore, the Historic Preservation Alternative would have a less than significant impact related to population and housing, similar to the proposed project.
Public Services. The Historic Preservation Alternative would result in 391 fewer residential units as compared to the proposed project; the Historic Preservation Alternative would result in 1,204 fewer new residents at the project site that would be added to the City’s population. This would result in a corresponding reduction in demand for public services, including on fire and police protection services, schools, parks, and other public services, as compared to the proposed project. However, the performance venue, which would host future concerts, plays, and other entertainment performances, would increase demand on fire and police protection services during those events compared to the proposed project.
As discussed in Section 4.15, Public Servies, implementation of the proposed project would not result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for fire and police protection services, schools, or parks with adherence to Regulatory Compliance Measures PS-1, PS-2, and PS-3, and the payment of applicable development impact fees.. The Historic Preservation 6 1,253 households x 3.08 persons per household = 3,860 persons S PECIFIC PLAN 3.0 B UILDOUT P ROJECT
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Alternative would also be required to adhere to Regulatory Compliance Measures PS-1, PS-2, and PS-3, and the payment of applicable development impact fees. Therefore, although implementation of the Historic Preservation Alternative would result in an increased demand on these services as compared to the proposed project due to the performance venue, implementation of the Historic Preservation Alternative is also expected result in less than significant impacts on these services due to the payment of fees and coordination with the OCFA required by Regulatory Compliance Measures PS-1, PS-2, and PS-3.
In addition, implementation of the Historic Preservation Alternative would generate additional funding for the City and County through additional property tax revenue, similar to the proposed project. These funds could be used for the development of new or expanded library facilities or new library equipment if required. Therefore, implementation of the Historic Preservation Alternative would also result in less than significant impacts on other public services, including the Orange County Public Library (OCPL) system.
Therefore, the Historic Preservation Alternative would have a less than significant impact related to public services with adherence to Regulatory Compliance Measures PS-1, PS-2, and PS-3, and the payment of applicable development impact fees, similar to the proposed project.
Recreation. The Historic Preservation Alternative would result in 391 fewer residential units as compared to the proposed project; the Historic Preservation Alternative would result in 1,204 fewer new residents at the project site that would be added to the City’s population. This would result in a corresponding reduction in demand on parks and recreation facilities.
As discussed in Section 4.16, Recreation, the City currently has 93.9 acres of parkland available for its 48,782 residents, and it currently provides approximately 1.92 acres of parkland per 1,000 residents, which does not meet the City’s parkland objective of 4.5 acres per 1,000 residents. The additional residents with implementation of the Historic Preservation Alternative would change this ratio. Implementation of the Historic Preservation Alternative would include more land on which park and recreational uses would be developed when compared to the proposed project. The existing Lexington Park, which is approximately nine acres and has already been developed adjacent to Lots 1 and 2 of VTTM 19247, is counted as part of the existing parkland acreage in the City. The specific amenities and improvements that would be developed in the public park space would be determined in connection with future development projects that are proposed within the Buildout Area. The Historic Preservation Alternative would also include additional open space areas as an amenity for future residents.
As specified in Article VI of the City’s Municipal Code, the City requires land to be dedicated as parks for subdivisions that include new residential construction that qualify as dwelling units as defined by section 6.31.020(D) of the City’s Zoning Ordinance and section 205(D) of the 2001 California Building Code as they currently exist. The Municipal Code also allows payment of park fees or a credit for private open space in lieu of the land dedication. Similar to the proposed project, the Historic Preservation Alternative would be required to adhere to Regulatory Compliance Measure PS-3, which requires compliance with Article VI of the City’s Municipal Code. Therefore, the Historic Preservation Alternative would have a less than significant impact on parks and recreation, similar to the proposed project.
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Transportation. The Historic Preservation Alternative would result in 391 fewer residential units as compared to the proposed project and the same amount of non-residential uses as the proposed project. The Historic Preservation Alternative would also include the extension of Vessels Circle, similar to the proposed project, and the extension of Siboney Street to connect to the intersection of the Vessels Circle extension. However, under the Historic Preservation Alternative, Moody Street would not be extended. The extensions would be constructed consistent with City standards and regulations.
As the Historic Preservation Alternative would include the same amount of non-residential uses as the proposed project, the non-residential uses under the Historic Preservation Alternative would generate the same number of vehicle trips to and from the Buildout Area during operation.
However, due to the reduction in residential units under the Historic Preservation Alternative compared to the proposed project, the residential uses under the Historic Preservation Alternative would generate fewer vehicle trips to and from the Buildout Area. In addition, based on the total number of seats associated with the performance venue (i.e., 4,694 seats), the performance venue would generate a substantial number of vehicle trips during future concerts, plays, and other entertainment performances hosted at the Buildout Area.
Similar to the proposed project, the Historic Preservation Alternative would not conflict with any of the goals and policies contained in the City’s General Plan related to the circulation system. In addition, the Historic Preservation Alternative would be consistent with, and reinforce, applicable Connect SoCal 2024 goals, including Connect SoCal 2024’s goals to develop, connect and sustain communities that are livable and thriving and to create a healthy region for the people of today and tomorrow, by providing additional housing opportunities within locations near amenities and already used by the public for commercial, recreational, and/or professional uses. In addition, the proposed project would support the development, connection, and sustainability of communities that are livable and thriving by providing necessary housing for all income levels in a bustling economic corridor. In addition, the Historic Preservation Alternative would not conflict with any adopted transit system plans, guidelines, policies, or standards as implementation would not interfere with implementation of applicable transit planning documents, including the specific actions to address the growing need for expanded transit service contained in the City’s General Plan Circulation Element, 2024 Orange County Transit Vision Master Plan,7 and the County’s Directions 2050 plan,8 which would update OCTA’s Long-Range Transportation Plan (LRTP). Further, implementation of the Historic Preservation Alternative would provide sidewalks along the frontages and pedestrian sidewalks and pathways would be provided throughout the Buildout Area and provide connections to existing pedestrian and bicycle facilities in the surrounding area, similar to the proposed project. Additionally, as discussed further below and detailed in Mitigation Measure TRA-1, the Historic Preservation Alternative would be required to implement feasible Transportation Demand Management (TDM) strategies to mitigate the alternative’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 7 Orange County Transportation Authority (OCTA). 2025. 2024 Orange County Transit Vision Master Plan.
May. 8 OCTA. 2025. OCTA Seeks Public Input to Help Shape Orange County’s Transportation Future. October 3.
Website: https://www.octa.net/news/news-releases/octa-seeks-public-input (accessed October 2025).
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construction of off-site sidewalks to improve sidewalk coverage and pedestrian access to the surrounding area. Therefore, the Historic Preservation Alternative would not conflict with any adopted bicycle or pedestrian system plans, guidelines, policies, or standards, similar to the proposed project.
Similar to the proposed project, the Historic Preservation Alternative would also be required to prepare and implement a Transportation Construction Plan (TCP) during construction activities, as detailed in the development agreement, that would be submitted to the City of Cypress Public Works Department for review and approval, in order to reduce impacts to roadway systems during construction. In addition, similar to the proposed project, although the Historic Preservation Alternative would also result in a significant and unavoidable VMT impact, the VMT impact does not, by itself, indicate inconsistency with circulation system policies or a failure to accommodate multimodal transportation. Therefore, based on the above analysis, and because the Historic Preservation Alternative would be required to adhere to the Specific Plan and the General Plan, similar to the proposed project, the Historic Preservation Alternative would generally be consistent with all programs, plans, ordinances, and policies addressing the circulation system, including those regulating transit, roadway, bicycle, and pedestrian facilities. Impacts would be less than significant, similar to the proposed project.
Because the Historic Preservation Alternative would include the same amount and type of new nonresidential uses as the proposed project, the non-residential uses under the Historic Preservation Alternative would result in a less than significant VMT impact, similar to the proposed project. While the Historic Preservation Alternative would result in fewer residential units as compared to the proposed project and the VMT impacts are expected to be reduced, without quantification of the VMT associated with the residential uses under the Historic Preservation Alternative or alternativespecific VMT analysis, it cannot be determined if the reduction in residential development would result in VMT impacts below applicable levels of significance (i.e., 13.21 VMT per capita, 15 percent below the existing regional average). In addition, the performance venue proposed under the Historic Preservation Alternative is expected to generate a significant amount of VMT as the performance venue would be a regional-serving use and attract visitors from outside the County during performance and events. As such, the Historic Preservation Alternative would also be required to implement the VMT reduction measures detailed in Mitigation Measure TRA-1.
Implementation of Mitigation Measure TRA-1 would require the Historic Preservation Alternative to reduce overall VMT; however, even with implementation of Mitigation Measure TRA-1, the VMT rates under the Historic Preservation Alternative are expected to remain above the established thresholds and impacts would be significant and unavoidable, similar to the proposed project.
Lastly, the Historic Preservation Alternative would not substantially increase hazards due to a geometric design feature or result in inadequate emergency access as all roadway improvements in and around the Buildout Area would be designed and constructed in accordance with Chapter 25, Article 5, Public Improvements, of the City’s Municipal Code and applicable Public Works Design Standards, similar to the proposed project. In addition, except as otherwise provided in the Specific Plan, all final site and roadway improvement plans shall conform to the City’s Public Works Design Criteria Manual, which incorporates California Manual on Uniform Traffic Control Devices (CA MUTCD) standards for intersection control, sight distance, and geometric design, and all final
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improvement and site access plans shall be subject to review and approval by the City’s Public Works Department and the Orange County Fire Authority prior to issuance of building permits.
Overall, implementation of the Historic Preservation Alternative would have a significant and unavoidable transportation impact related to VMT, even with implementation of Mitigation Measure TRA-1, similar to the proposed project.
Tribal Cultural Resources. The Historic Preservation Alternative would develop the same area of the city (i.e., Buildout Area) with similar uses as the proposed project, including residential and nonresidential uses; however, the existing LARC character-defining features that contribute to the LARC’s eligibility for listing in the National Register and California Register would be retained for use as a performance venue for future concerts, plays, and other entertainment performances.
Although the Historic Preservation Alternative would include less demolition compared to the proposed project due to the retention of the LARC character-defining features, ground-disturbing construction activities associated with implementation of this alternative, such as site preparation and grading activities has the potential to significantly impact unidentified tribal cultural resources during ground-disturbing activities, similar to the proposed project. Therefore, consistent with the proposed project, the Historic Preservation Alternative would be required to adhere to Regulatory Compliance Measures CUL-1 and CUL-2, which detail provisions in the event that previously unknown cultural resources, including human remains, are discovered during ground-disturbing construction activities, consistent with the California Code of Regulations (CCR) Section 15064.5(e) and State Health and Safety Code Section 7050.5. In addition, because the Historic Preservation Alternative would be located at the same location as the proposed project, the alternative would also be required to implement Mitigation Measures TCR-1 through TCR-4, which include required tribal cultural resources training and ALERT sheet posting, on-site tribal monitoring during ground disturbance of native sediment, and provisions in the event that previously unknown tribal cultural resources (including human remains and funerary objects) are discovered during ground-disturbing construction activities.
With adherence to Regulatory Compliance Measures CUL-1 and CUL-2 and implementation of Mitigation Measures TCR-1 through TCR-4, the potential impacts to known and unknown tribal cultural resources would be less than significant with mitigation incorporated, similar to the proposed project.
Utilities and Service Systems. The Historic Preservation Alternative would result in 391 fewer residential units as compared to the proposed project; the Historic Preservation Alternative would result in 1,204 fewer new residents at the project site that would be added to the City’s population.
This would result in a corresponding reduction in demand on utilities, including water, wastewater, stormwater, electricity, natural gas, and telecommunications, as compared to the proposed project.
However, the performance venue, which would host future concerts, plays, and other entertainment performances, would increase demand on utilities during those events. Similar to the proposed project, the Historic Preservation Alternative would connect to existing utility infrastructure in the vicinity of the Buildout Area and would be required to install the required infrastructure and utility improvements to achieve these connections.
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Similar to the proposed project, implementation of the Historic Preservation Alternative would not require the relocation or construction of new or expanded water, wastewater treatment or stormwater drainage, electric power, natural gas, or telecommunications facilities or infrastructure, beyond those required for the proposed project. In addition, based on the water supply and demand estimates in the GSWC Los Alamitos West Orange Service Area 2020 Urban Water Management Plan (UWMP) and the remaining wastewater treatment capacity for OC San’s Reclamation Plant No. 1 in Fountain Valley and Treatment Plant No. 2, the water and wastewater service provides could adequately accommodate the development under the Historic Preservation Alternative. Further, the stormwater drainage system under Historic Preservation Alternative, as required by Regulatory Compliance Measure HYD-3, would be designed to ensure that operation of the Historic Preservation Alternative would not result in a substantial increase in the rate or amount of surface runoff, flow, and volume that would exceed the capacity of the adjacent stormwater drainage systems, and no new additional infrastructure would be required. Lastly, SCE and SoCalGas are anticipated to be able to adequately serve the Historic Preservation Alternative because the Historic Preservation Alternative would result in reduced demand for electricity and natural gas in comparison to the proposed project.
Additionally, similar to the proposed project, all future projects implemented in accordance with the Historic Preservation Alternative would be required to adhere to the Specific Plan, provide required development impact fees, and comply with applicable development regulations pertaining to utility improvements and connections. As a part of the development review process, all future projects would be required to demonstrate that existing public utilities would be sufficient to serve the future projects’ needs, through the issuance of a will serve letter. As such, the Historic Preservation Alternative would not require the relocation or construction of new or expanded utilities and impacts would be less than significant.
In addition, similar to the proposed project, impacts related to solid waste with implementation of the Historic Preservation Alternative would be less than significant with adherence to Regulatory Compliance Measure UTIL-1 requiring compliance with the City’s Construction and Demolition Ordinance. Further, solid waste from future development facilitated by the Historic Preservation Alternative would be required to comply with State and local solid waste reduction, diversion, and recycling policies and regulations, including AB 1327 (wood waste disposal), Chapter 18 of the California Solid Waste Reuse and Recycling Access Act of 1991 (requires adequate, permanent space for recycling and solid waste collection at new developments), AB 939 (California Department of Resources Recycling and Recovery [CalRecycle]), AB 75 (solid waste diversion), AB 1826 (organic waste recycling), and SB 1383 (organic waste collection services). With adherence to these existing regulatory requirements and based on the remaining capacity of the Frank R. Bowerman Landfill, Olinda Alpha Landfill, and Prima Deshecha Landfill, the Historic Preservation Alternative would result in less than significant impacts related to solid waste.
Therefore, the Historic Preservation Alternative would have a less than significant impact related to utilities and service systems with adherence to Regulatory Compliance Measure UTIL-1, similar to the proposed project.
Wildfire. As discussed in Section 4.20, Wildfire, according to the California Department of Forestry and Fire Protection (CAL FIRE) Very High Fire Hazard Severity Zones (VHFHSZ) for the Orange County
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region, the entire city is designated as a non-VHFHSZ,9 and the city does not include a State Responsibility Area (SRA). The nearest VHFHSZ to the Buildout Area is approximately 6.8 miles northeast in Coyote Hills on the western side of Fullerton.10 The nearest SRA is in Puente Hills, approximately 12 miles northeast of the Buildout Area. As such, the Buildout Area is not located in or near any SRAs or lands classified as VHFHSZs. Therefore, the Historic Preservation Alternative would have no impact related to wildfire, similar to the proposed project.
5.5.2.3 Attainment of Project Objectives
The Historic Preservation Alternative would not meet the project objectives to the same extent as the proposed project, as discussed further below.
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.
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 to the Specific Plan to allow for the performance venue. As such, the Historic Preservation Alternative would be inconsistent with the Specific Plan as approved by the voters.
Therefore, the Historic Preservation Alternative would not satisfy this objective to the same extent as the proposed project.
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.
The Historic Preservation Alternative would facilitate development of new residential and nonresidential uses, including a mix of entertainment, retail, restaurant, and commercial uses, within the Buildout Area, which would establish the Buildout Area as a mixed-use town center.
Although implementation of the Historic Preservation Alternative would result in the same amount of non-residential uses as the proposed project, the Historic Preservation Alternative would result in 391 fewer residential units as compared to the proposed project. Nevertheless, the Historic Preservation Alternative would be similar to the proposed project in meeting this project objective. However, the Historic Preservation Alternative would not meet the residential component of this objective to the same extent as the proposed project.
3. Revitalize a large urban area in the City that is currently significantly underutilized. 9 California Department of Forestry and Fire Protection (CAL FIRE). 2011. Very High Fire Hazard Severity Zones in LRA. Website: https://osfm.fire.ca.gov/media/6739/fhszl_map30.pdf (accessed February 6, 2025). 10 Ibid.
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Similar to the proposed project, the Historic Preservation Alternative would facilitate the development of the Buildout Area with new residential and non-residential uses. Therefore, the Historic Preservation Alternative would revitalize a large urban area in the City that is currently significantly underutilized and the Historic Preservation Alternative would be similar to the proposed project in meeting this project objective.
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.
As discussed above, while the Historic Preservation Alternative would facilitate development of 1,400 residential units within the Buildout Area, which would include a variety of housing product types and densities to meet a range of housing needs of Cypress and area residents, the Historic Preservation Alternative would result in 391 fewer residential units than the proposed project. Although the Historic Preservation Alternative would develop fewer residential units within the Buildout Area, the housing product types are expected to be similar to those under the proposed project. As such, the Historic Preservation Alternative would be similar to the proposed project in meeting this project objective.
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.
As discussed above and similar to the proposed project, the Historic Preservation Alternative would facilitate the development of the Buildout Area with new residential, non-residential, and park uses, consistent with the Specific Plan. Therefore, like the proposed project, the Historic Preservation Alternative would 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. However, the Historic Preservation Alternative would not meet the residential component of this objective to the same extent as the proposed project.
6. Develop a project that will invigorate the local economy by providing new employment and business opportunities.
The Historic Preservation Alternative would facilitate development of approximately 440,000 square feet of non-residential (commercial) uses within the Buildout Area, the same as the proposed project, which would invigorate the local economy by providing new employment and business opportunities. Moreover, the Historic Preservation Alternative would provide a performance venue that would attract visitors from throughout the region to the City, which would create increased opportunities for patronage at local businesses, particularly those specializing in retail and hospitality. Therefore, the Historic Preservation Alternative would meet this objective to a greater extent than the proposed project.
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7. Provide residential and commercial/retail improvement that generate new sources of revenue for the City through increased property values and retail sales.
As discussed above, while the Historic Preservation Alternative would facilitate development of new residential and non-residential uses, which would provide residential and commercial/retail improvements that generate new sources of revenue for the City through increased property values and retail sales, the Historic Preservation Alternative would result in 391 fewer residential units as compared to the proposed project. Although the reduced number of new residents created by the Historic Preservation Alternative would likely be partially offset by the increased opportunities for patronage at local retail outlets generated by the additional regional performance venue included in this alternative, the Historic Preservation Alternative is not likely to result in the same net increase in property values and retail sales as the proposed project. As such, the Historic Preservation Alternative would not meet this objective to the same extent as the proposed project.
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.
The Historic Preservation Alternative would include the extension of Vessels Circle, similar to the proposed project, and the extension of Siboney Street to connect to the intersection of the Vessels Circle extension. The proposed street extensions would provide some vehicular and pedestrian access for project residents, tenants, visitors and patrons. However, under the Historic Preservation Alternative, Moody Street would not be extended, which would likely result in increased vehicle traffic on other arterial streets surrounding the Buildout Area to access the area, which may not improve overall traffic circulation in the project vicinity to the same degree as the proposed project. Nevertheless, the proposed street extensions would provide necessary vehicular and pedestrian access for project residents, tenants, visitors and patrons. Therefore, the Historic Preservation Alternative would be inferior to the proposed project in meeting this project objective.
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.
The Historic Preservation Alternative would facilitate the development of 1,400 residential units within the Buildout Area and, similar to the proposed project and consistent with the Specific Plan, would include senior housing communities. However, the Historic Preservation Alternative would result in 391 fewer residential units compared to the proposed project. Therefore, the Historic Preservation Alternative would be inferior in developing residential uses with sufficient housing units to support the size, scale and operation of planned public parks and other amenities and common areas included within the Buildout Area. As such, the Historic Preservation Alternative would not meet this objective to the same extent as the proposed project.
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Overall, the Historic Preservation Alternative would not satisfy, or fully satisfy, a number of the key project objectives related to the number of residential units provided and build out of the alreadyapproved Specific Plan. Therefore, this alternative would not satisfy the project objectives to the same extent as the proposed project. In addition, the Historic Preservation Alternative would not meet the underlying purpose of the proposed project to redevelop the Buildout Area in accordance with the voted-approved Specific Plan, as the Historic Preservation Alternative would require amendments to the Specific Plan that must be voted on and adopted by voters.
5.5.3 Reduced Development Alternative (30% Reduction)
5.5.3.1 Description
As previously described, 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. This represents a decrease of 538 residential units and approximately 132,000 square feet of nonresidential uses as compared to the proposed project. Under this alternative, the demolition and removal of all or a substantial portion of the existing improvements associated with the LARC property, including the race track and infield area, grandstand, buildings, barns and structures and three artificial lakes, would still occur, similar to the proposed project. In addition, the extension of Moody Street from Cerritos Avenue to Katella Avenue and the extension of Vessels Circle from its current western terminus to intersect with the Moody Street extension would still occur, consistent with the Specific Plan. In addition, the 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 associated with the proposed project would be included in the Reduced Development Alternative
5.5.3.2 Comparison of Environmental Impacts
Aesthetics. The follow provides a comparison of potential aesthetic impacts between the proposed project and the Reduced Development Alternative.
Scenic Vistas and Scenic Resources. 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. Similar to the proposed project, given that no scenic vista is currently viewable from any public vantage point in proximity to the Buildout Area, the development of the Reduced Development Alternative would not alter an existing scenic vista or block views of any scenic vistas.
Therefore, the Reduced Development Alternative would not have a substantial adverse effect on a scenic vista. In addition, 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 Pacific Coast Highway. Therefore, the Reduced Development Alternative would have no impact related to the substantial damage of scenic resources within a State Scenic Highway, similar to the proposed project.
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Visual Character and Public Views. The proposed project would include higher density development within the Buildout Area than currently exists, though at a lower density than the proposed project.
Similar to the proposed project, the aesthetic character of the Buildout Area would change with implementation of the Reduced Development Alternative during both construction and operation.
Construction of the proposed project would introduce the use of machinery such as excavators and bulldozers, and the presence of the construction equipment, as well as the construction activities, would temporarily alter the visual character of the project site. However, construction would be temporary and, due to the phased nature of construction activities, would be staggered across the project site. Therefore, the visual character of the Buildout Area would not be significantly impacted during construction activities.
All development pursuant to the Specific Plan would be required to consider and comply with, as applicable, 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.
The development would also be consistent with the mass and scale of existing development near the Buildout Area, which are primarily commercial and residential uses. Therefore, the Reduced Development Alternative would have a less than significant impact related to conflict with applicable zoning and other regulations governing scenic quality, similar to the proposed project.
Light and Glare. As the Buildout Area is in an urbanized area, 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. Similar to the proposed project, all new housing or non-residential development within the Buildout Area would be required to comply with all applicable requirements related to light and glare, including applicable regulations of the 2022 State Building Energy Efficiency Standards (Title 24), all applicable sustainable design strategies related to lighting in the Specific Plan, and all applicable development standards related to lighting in the Zoning Ordinance.
Consistent with these requirements and similar to the proposed project, all lighting associated with the Reduced Development Alternative would be shielded such that it would minimize light spillage onto adjacent properties. In addition, building exteriors of future development facilitated by the Reduced Development Alternative would generally be covered by non-reflective materials, which would minimize glare, and glass windows would be incorporated into each building design in accordance with development standards established in the Specific Plan and the City’s Municipal Code.
As such, even though the Reduced Development Alternative would develop the Buildout Area at a reduced scale, the development facilitated by the Reduced Development Alternative would be similar in nature to the development facilitated by the proposed project. Therefore, the Reduced Development Alternative would have a less than significant impact related to aesthetics, similar to the proposed project.
Agriculture and Forestry Resources. The Reduced Development Alternative would develop the same area of the city (i.e., Buildout Area) with similar uses as the proposed project, including S PECIFIC PLAN 3.0 B UILDOUT P ROJECT
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residential and non-residential uses. As discussed in Section 4.2, Agriculture and Forestry Resources, the entire Buildout Area and surrounding area is designated as “Urban and Built-Up Land” by the California Department of Conservation’s California Important Farmland Finder. In addition, the Buildout Area is not used for agricultural or forestry production and is not protected by, or eligible for, a Williamson Act contract. Therefore, the Reduced Development Alternative would have no impact related to agriculture and forestry resources, similar to the proposed project.
Air Quality. The following provides a comparison of potential air quality impacts between the proposed project and the Reduced Development Alternative. The Reduced Development Alternative would result in 538 fewer residential units and a reduction of approximately 132,000 square feet of non-residential uses as compared to the proposed project. This would result in a corresponding reduction in air quality emissions during construction and operation, as compared to the proposed project.
Construction. Due to the reduction in development, which would reduce construction timelines, construction of the Reduced Development Alternative would result in fewer air quality emissions as compared to the proposed project. As such, similar to the proposed project, construction emissions associated with full buildout of the Reduced Development Alternative would not exceed the SCAQMD thresholds for VOCs, NOx, CO, SOX, PM2.5, or PM10 emissions. Therefore, with compliance with regulatory requirements (as specified in Regulatory Compliance Measures AIR-1 through AIR4), construction impacts related to the cumulatively considerable net increase of any criteria pollutant for which the project region is in nonattainment under applicable federal or State ambient air quality standard would be less than significant, similar to the proposed project.
Operation. As discussed in Section 4.3, Air Quality, operation of the proposed project would result in VOC emissions that would exceed the SCAQMD’s significance criteria even with implementation of Mitigation Measure AIR-1 and Mitigation Measure TRA-1. As there are no additional feasible mitigation measures that would reduce project operational-source VOC emissions to a less-thansignificant 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.
The Reduced Development Alternative would reduce operational emissions due to the reduction in residential units and non-residential uses. However, because the air quality emissions under the Reduced Development Alternative have not been quantified, it is unknown if implementation of the Reduced Development Alternative would result in VOC emissions below SCAQMD’s significance criteria. Accordingly, this Draft EIR includes a qualitative, comparative discussion of this alternative based on available information and professional judgement, and it is therefore assumed that implementation of the Reduced Development Alternative would also result in 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, albeit less than the proposed project.
Health Risk Assessment. Construction of development envisioned under the Reduced Development Alternative may expose these nearby sensitive receptors to airborne particulates and pollutants from construction equipment (i.e., usually diesel-fueled vehicles and equipment). Therefore, Mitigation Measure AIR-2, which requires the use of U.S. EPA Tier 4 Final or cleaner construction
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equipment if and to the extent commercially available, or the cleanest available technology that is commercially available and feasible or the preparation of project-specific construction HRA in certain circumstances, would also apply to the Reduced Development Alternative. Therefore, this impact would be less than significant with mitigation incorporated, similar to the proposed project.
In addition, similar to the proposed project, the Reduced Development Alternative would not include the development of any uses identified by CARB as being substantial source of TACs that would require specific siting distances based on CARB recommendations. In addition, the industrial uses near the Buildout Area on the western and eastern boundaries are further than 500 feet, so any new sensitive receptors, such as proposed residential uses, will be consistent with CARB’s siting recommendations. Therefore, impacts related to TACs would be less than significant, similar to the proposed project.
Conflict with Applicable Air Quality Plans. As discussed in Section 4.3, Air Quality, the proposed project would be consistent with Indicator 2 of the 2022 AQMP as the proposed project would not exceed the growth assumptions in Connect SoCal 2024 or the 2022 AQMP; however, 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. Overall, even with implementation of Mitigation Measure AIR-1 and Mitigation Measure TRA-1, the proposed project would result in a significant and unavoidable impact associated with conflict with applicable air quality management plans. Although the Reduced Development Alternative would reduce operational emissions due to the 30 percent reduction in residential units and non-residential uses, because the air quality emissions under the Reduced Development Alternative have not been quantified, it is unknown if implementation of the Reduced Development Alternative would result in long-term operational pollutant emissions that would be below applicable thresholds. Therefore, implementation of the Reduced Development Alternative would also result in significant and unavoidable impact associated with conflict with applicable air quality management plans.
Odors. Construction of the Reduced Development Alternative would generate similar odors as construction of the proposed project. Similar to the proposed project, these odors would be temporary and limited to the construction period. The Reduced Development Alternative would also not include any activities or operations that would generate objectionable odors and once operational, development envisioned under the Reduced Development Alternative would not be a source of odors. Therefore, the Reduced Development Alternative would not result in other emissions (such as those leading to odors) affecting a substantial number of people, similar to the proposed project.
Overall, although the Reduced Development Alternative would generate less air quality emissions when compared to the proposed project, because the air quality emissions under the Reduced Development Alternative have not been quantified, it is unknown if implementation of the Reduced Development Alternative would reduce the proposed project’s air quality impacts to less than S PECIFIC PLAN 3.0 B UILDOUT P ROJECT
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significant levels. Therefore, implementation of the Reduced Development Alternative would have a significant and unavoidable air quality impact, even with implementation of Mitigation Measure AIR-1, Mitigation Measure AIR-2, and Mitigation Measure TRA-1 and adherence to Regulatory Compliance Measures AIR-1 through AIR-4, similar to the proposed project.
Biological Resources. The Reduced Development Alternative would develop the same area of the city (i.e., Buildout Area) with similar uses as the proposed project, including residential and nonresidential uses, but at a reduced scale. The following provides a comparison of potential impacts to biological resources between the proposed project and the Reduced Development Alternative.
Habitats and Vegetation Communities. As discussed in Section 4.4, Biological Resources, the Buildout Area primarily consists of developed land cover. The dominant vegetation within this vegetation community includes ornamental landscaping and ruderal grassland with patches of herbaceous invasive species. Other vegetation communities within the Buildout Area include ornamental landscaping and artificial ponds. In addition, no portion of the Buildout Area contains designated or proposed critical habitat for any federally listed plant or animal species. Further, there is a high level of existing disturbance within the Buildout Area, and native wildlife habitat is largely absent within the Buildout Area and in the vicinity. The development surrounding the Buildout Area and the lack of ground cover and suitable foraging habitat make the site undesirable for many native wildlife species. Therefore, implementation of the Reduced Development Alternative would have no impact on any native habitats or vegetation communities, similar to the proposed project.
Special-Status Plant Species. As discussed in Section 4.4, Biological Resources, no special-status plants were observed within the Buildout Area during the reconnaissance survey; and none of the 30 special-status plant species from the records searches are expected to occur within the Buildout Area due to the lack of suitable habitat and/or conditions. Therefore, implementation of the Reduced Development Alternative would have no impact on any special-status plant species, similar to the proposed project.
Special-Status Wildlife Species and Migratory/Nesting Birds. As discussed in Section 4.4, Biological Resources, no special-status wildlife species were observed during the field survey, and suitable habitat for such species is absent from the Buildout Area due to the high level of development. In addition, no nesting birds or their nests were observed at the time of the field survey. However, based on a review of resource databases, 6 special-status wildlife species have the potential to occur on or near the Buildout Area, including monarch butterfly (Danaus plexippus plexippus), Ferruginous hawk (Buteo regalis), Swainson’s hawk (Buteo swainsoni), western mastiff bat (Eumops perotis californicus), western yellow bat (Lasiurus xanthinus), and pocketed free-tailed bat (Nyctinomops femorosaccus). In addition, although no sign of roosting bats was observed during the September 2024 field survey, suitable day and night roosting habitat could be present at several of the building structures throughout the Buildout Area and within the ornamental palm trees located around the Buildout Area. Additionally, other ornamental tree species within the Buildout Area could provide habitat to native bats in the form of foliage, bark, or cavity roosts.
Implementation of the Reduced Development Alternative would develop the Buildout Area with similar uses as the proposed project, but at a reduced scale. As such, anticipated construction activities, including site preparation and grading activities, would be similar, although reduced. In
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addition, potential direct and/or indirect impacts (e.g., noise during construction) could potentially disrupt or otherwise adversely affect bird nesting activities in and/or adjacent to the Buildout Area if construction activities would occur within the nesting bird season (between February 1 and August 31). Because construction of the Reduced Development Alternative would be similar, or slightly reduced, as compared to the proposed project, impacts on special-status species, including bats, and nesting birds would be similar with implementation of the Reduced Development Alternative as the proposed project. Therefore, the Reduced Development Alternative would also be required to adhere to Regulatory Compliance Measure BIO-1, requiring pre-construction bay surveys, and Regulatory Compliance Measure BIO-2, requiring pre-construction nesting bird surveys and active nest avoidance buffers during construction, and impacts would be less than significant.
Riparian Habitat and Sensitive Natural Communities. As discussed in Section 4.4, Biological Resources, the Buildout Area currently contains one existing drainage feature, one existing detention basin, and three existing artificial ponds. All of these aquatic features were constructed in previously graded or developed areas and do not represent natural stream channels, wetlands, or riparian systems. Their primary functions are aesthetic or related to stormwater conveyance and retention. As such, no riparian habitat is present within the Buildout Area. Therefore, similar to the proposed project, no impacts to riparian habitat would result from implementation of the Reduced Development Alternative.
Jurisdictional Waters. As previously discussed, there is one drainage feature, one detention basin, and three ponds within the Buildout Area. The three ponds and the detention basin are not expected to be regulated by USACE, RWQCB, or CDFW. However, the single drainage feature located on Lot 3 contains ruderal vegetation and may connect to Coyote Creek, which is tributary to the San Gabriel River and ultimately flows into the Pacific Ocean. Therefore, the removal of this drainage may be subject to regulation by the RWQCB and CDFW. Therefore, similar to the proposed project, the Reduced Development Alternative would be required to implement Mitigation Measure BIO-1, which requires a jurisdictional delineation be conducted prior to construction. In addition, similar to the proposed project, the Reduced Development Alternative would be required to adhere to Regulatory Compliance Measures HYD-1 through HYD-3 during construction and operation to address erosion-related impacts through implementation of construction site BMPs and operationalperiod biotreatment BMPs to avoid erosion and sedimentation impacts to downstream aquatic areas and water quality. With implementation of Mitigation Measure BIO-1 and adherence to Regulatory Compliance Measures HYD-1 through HYD-3, implementation of the Reduced Development Alternative would result in less than significant impacts on jurisdictional waters, similar to the proposed project.
Wildlife Movement and Nursery Sites. As discussed in Section 4.4, Biological Resources, the Buildout Area does not function as a wildlife movement corridor. In addition, as discussed above, the Reduced Development Alternative would comply with Regulatory Compliance Measure BIO-1, requiring pre-construction bay surveys, and Regulatory Compliance Measure BIO-2, requiring preconstruction nesting bird surveys and active nest avoidance buffers during construction. Therefore, similar to the proposed project, implementation of the Reduced Development Alternative would have a less than significant impact related to wildlife movement and nursey sites.
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Local Policies and Ordinances. Similar to the proposed project, construction of Reduced Development Alternative would involve tree removal activities. As required by Article 3, Performance and Development Standards, Section 13 (3.13.070(c)), of the Municipal Code, existing trees would be preserved when feasible. In addition, all tree removal activities would be consistent with Section 3.9 of the Specific Plan, which supersedes the City’s Landmark Tree Ordinance, as codified in Sections 17-17 through 17-27 of the City Municipal Code, and details the tree replacement development standards for development within the Buildout Area. Consistent with Specific Plan requirements, all tree removal required for future development would be described during site plan review and all removed trees would be replaced with an equivalent number of specimen trees. With adherence to the tree replacement development standards detailed in the Specific Plan, the Reduced Development Alternative would not conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance, similar to the proposed project, and impacts would be less than significant.
Overall, implementation of the Reduced Development Alternative would have a less than significant impact related to biological resources with adherence to Regulatory Compliance Measures BIO-1 and BIO-2 and implementation of Mitigation Measure BIO-1, similar to the proposed project.
Cultural Resources. The following provides a comparison of potential impacts to cultural resources between the proposed project and the Reduced Development Alternative.
Historical Resources. Implementation of the Reduced Development Alternative would include the demolition and removal of all or a substantial portion of the existing improvements associated with the LARC property, including the race track and infield area, grandstand, buildings, barns and structures and three artificial lakes, similar to the proposed project. As the pre-1970 track, the 1954 quarter-mile chute, and the grandstand are character-defining features that contribute to the LARC’s eligibility for listing in the National Register and California Register, the demolition of the grandstand, chute, and track would be a potentially significant impact.
Demolition of a historic resource is considered a material impairment of the historical resource, and other than avoiding demolition, no feasible mitigation measures are available to fully mitigate the demolition of the historical resource to a less-than-significant level. However, similar to the proposed project, implementation of mitigation measures could reduce significant adverse impacts to some degree. If the historical significance of the character-defining features are thoroughly documented, well photographed, and publicly available, the demolition of the character-defining features would have a reduced impact on the historical significance of the character-defining features. As such, the Reduced Development Alternative would be required to implement Mitigation Measures CUL-1 through CUL-3, similar to the proposed project, which requires documentation of the historic resource in accordance with the Historic American Building Survey (HABS) standards. Implementation of Mitigation Measures CUL-1 through CUL-3 would reduce, but not avoid, adverse impacts to the historical resource.
Because implementation of the Reduced Development Alternative would demolish the characterdefining features of LARC Property, implementation of the Reduced Development Alternative would result in a substantial adverse change to a historic architectural resource under CEQA and impacts to
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built-environment historic resources as defined in State CEQA Guidelines Section 15064.5 would be significant and unavoidable, similar to the proposed project.
Archaeological Resources. In addition, consistent with the proposed project, construction of the Reduced Development Alternative has the potential to significantly impact unidentified archaeological resources during ground-disturbing activities. Therefore, similar to the proposed project, the Reduced Development Alternative would be required to adhere to Regulatory Compliance Measure CUL-1, which detail provisions in the event that previously unknown cultural resources, including human remains, are discovered during ground-disturbing construction activities, consistent with the California Code of Regulations (CCR) Section 15064.5(e) and State Health and Safety Code Section 7050.5. Further, similar to the proposed project, the Reduced Development Alternative would also be required to adhere to Regulatory Compliance Measure CUL-2 for the treatment of human remains in order to ensure that descendant communities have significant input in the treatment and final disposition of human remains, if encountered at the project site during future development activities. With adherence to Regulatory Compliance Measures CUL-1 and CUL-2, implementation of the Reduced Development Alternative would result in less than significant impacts related to archaeological resources and human remains.
Overall, implementation of the Reduced Development Alternative would continue to result in a significant and unavoidable impact related to cultural (historical) resources, even with implementation of Mitigation Measures CUL-1 through CUL-3, similar to the proposed project.
Energy. The Reduced Development Alternative would result in 538 fewer residential units and a reduction of approximately 132,000 square feet of non-residential uses as compared to the proposed project. This would result in a corresponding reduction in energy use associated with the residential development during construction and operation, as compared to the proposed project.
Construction. Due to the reduction in development, the length of construction is estimated to be shorter than the proposed project and would result in less energy use as compared to the proposed project. As such, similar to the proposed project, construction energy use would not cause or result in the need for additional energy facilities or an additional or expanded delivery system and fuel consumption during construction would not be any more inefficient, wasteful, or unnecessary than other similar development projects of this nature, and impacts would be less than significant, similar to the proposed project.
Electricity and Natural Gas. As discussed in Section 4.6, Energy, operational activities associated with buildout of the proposed project would increase the annual electricity consumption in Orange County by a negligible percent. Due to the reduction in development, operational activities associated with buildout of the Reduced Development Alternative would also increase the annual electricity consumption in Orange County by a negligible percent. Furthermore, similar to the proposed project, future development envisioned under the Reduced Development Alternative would be constructed using energy efficient modern building materials and construction practices, and would use new modern appliances and equipment, in accordance with the Appliance Efficiency Regulations (Title 20, CCR Sections 1601 through 1608). Future development would also be designed to meet sustainability goals, including the CALGreen Code, Title 24 energy efficiency requirements, and AB 1881 water efficient landscape requirements. CALGreen Code and Title 24 building energy S PECIFIC PLAN 3.0 B UILDOUT P ROJECT
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efficiency standards establish minimum efficiency standards related to various building features, including appliances, water and space heating and cooling equipment, building insulation and roofing, and lighting, which would reduce energy usage. Similar to the proposed project, the expected energy consumption during construction and operation associated with future buildout envisioned under the Reduced Development Alternative would be consistent with typical usage rates for residential and commercial uses; however, energy consumption is largely a function of personal choice and the physical structure and layout of buildings. As such, electrical and natural gas demand associated with operation of the Reduced Development Alternative would not be considered inefficient, wasteful, or unnecessary in comparison to other similar developments in the region. Therefore, impacts would be less than significant, similar to the proposed project.
Fuel Usage. Similar to the proposed project, operation of the Reduced Development Alternative would also result in energy usage associated with gasoline and diesel fuel consumed by vehicle trips.
As the Reduced Development Alternative would result in a 30 percent decrease in residential units and non-residential floor area, the Reduced Development Alternative would generate fewer vehicle trips to and from the Buildout Area. As discussed in Section 4.6, Energy, vehicle trips associated with buildout of the proposed project is expected to increase annual fuel consumption in Orange County by a negligible percent. As such, the Reduced Development Alternative would also increase annual fuel consumption in Orange County by a negligible percent. In addition, vehicles associated with trips to and from the Buildout Area would be subject to fuel economy and efficiency standards, which are applicable throughout the State. As such, the fuel efficiency of vehicles associated with future operation of the Reduced Development Alternative would increase throughout the life of the project, similar to the proposed project.
Lastly, similar to the proposed project, implementation of the Reduced Development Alternative would not conflict with or obstruct compliance with a State or local plan for renewable energy or energy efficiency, as energy impacts of the Reduced Development Alternative at the regional level would be negligible. Because California’s energy conservation planning actions are conducted at a regional level, and because the Reduced Development Alternative’s total impact on regional energy supplies would be minor, buildout of the Reduced Development Alternative would not conflict with or obstruct California’s energy conservation plans as described in the CEC’s Integrated Energy Policy Report.
Therefore, the Reduced Development Alternative would have a less than significant impact related to energy, similar to the proposed project.
Geology and Soils. As discussed in Section 4,7, Geology and Soils, although the Buildout Area is subject to strong ground motion resulting from earthquakes on nearby faults, no known faults cross the Buildout Area. In addition, landslides have not been recorded within the City boundaries and are not anticipated based on the lack of any significant topographic features. However, the entire city, including the Buildout Area, is designated as a liquefaction zone. Similar to the proposed project, new development within the Buildout Area facilitated by the Reduced Development Alternative would be subject to the seismic design criteria of the 2022 California Building Standards Code requirements that aim to prevent building collapse and reduce the impacts of seismic ground shaking, as specified in Regulatory Compliance Measure GEO-1. In addition, future construction contractors would be required to comply with the recommendations in the Geotechnical
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Investigation, as detailed in Mitigation Measure GEO-1, to ensure liquefaction impacts are reduced to a less than significant level. Mitigation Measure GEO-1 would require that the upper soils of the Buildout Area be stabilized with ground improvement techniques beneath any structure intended for human occupancy. The ground improvements may consist of Rammed Aggregate Piers, Vibrated Aggregate Piers, or similar techniques, and would be required to be designed by a qualified ground improvement contractor in an interactive process with the geotechnical engineer and structural engineer.
The Reduced Development Alternative would be required to comply with existing NPDES permit requirements, including the Construction General Permit, and Section 4.106 of the CALGreen Code during construction in order to ensure impacts related to erosion during construction would be less than significant (Regulatory Compliance Measure HYD-1). Further, the Reduced Development Alternative would also be required to implement stormwater management and treatment BMPS, such as detention basins and/or proprietary flow-based biofiltration systems, to address erosion impacts during operation (Regulatory Compliance Measure HYD-3).
Similar to the proposed project, construction of the Reduced Development Alternative has the potential to disturb native alluvium at a depth that could have an impact on paleontological resources. Therefore, the Reduced Development Alternative would also have to implement Mitigation Measures GEO-2 and GEO-3, which make provisions for unknown paleontological resources discovery stop work procedures and worker training procedures, similar to the proposed project, in order to reduce potential impacts to less than significant.
Lastly, future development within the Buildout Area under the Reduced Development Alternative would be served by the City of Cypress and the Orange County Sanitation District and would not include the development of or use of any septic tanks or alternative wastewater disposal systems.
Therefore, the Reduced Development Alternative would have a less than significant impact related to geology and soils with adherence to Regulatory Compliance Measure GEO-1 and implementation of Mitigation Measure GEO-1 through GEO-3, similar to the proposed project.
Greenhouse Gas Emissions. The Reduced Development Alternative would result in 538 fewer residential units and a reduction of approximately 132,000 square feet of non-residential uses as compared to the proposed project. This would result in a corresponding reduction in GHG emissions during construction and operation compared to the proposed project due to the reduction in development and subsequent reduction in energy demand and trip generation.
Similar to the proposed project, because the Reduced Development Alternative would implement Mitigation Measure AIR-1, the Reduced Development Alternative would be consistent with the 2022 Scoping Plan key project attribute related to EV charging requirements. However, future development under the Reduced Development Alternative could be all-electric or could use natural gas. Therefore, Mitigation Measure GHG-1, which requires that future development either be allelectric or incorporate additional emission reduction measures if all-electric development is not feasible, would be applicable to the Reduced Development Alternative. In addition, the Reduced Development Alternative would also be required to implement Mitigation Measure TRA-1, which requires the implementation of TDM strategies, similar to the proposed project. Therefore, the S PECIFIC PLAN 3.0 B UILDOUT P ROJECT
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Reduced Development Alternative would be consistent with the identified measures and goals from Connect SoCal 2024 and, similar to the proposed project, the Reduced Development Alternative would result in less than significant impacts related to GHG emissions based on consistency with the 2022 Scoping Plan, as described above.
In addition, as the Reduced Development Alternative would result in less than significant impacts related to GHG emissions based on consistency with the 2022 Scoping Plan, as described above, the Reduced Development Alternative would not conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs and impacts would be less than significant with implementation of Mitigation Measure GHG-1, Mitigation Measure AIR-1, and Mitigation Measure TRA-1, similar to the proposed project.
Overall, under the Reduced Development Alternative, construction and operational GHG emissions would be less than the proposed project due to the reduction in development and vehicle trips to and from the Buildout Area. However, implementation of the Reduced Development Alternative would still result in less than significant impacts with incorporation of Mitigation Measure GHG-1, Mitigation Measure AIR-1, and Mitigation Measure TRA-1, similar to the proposed project.
Hazards and Hazardous Materials. Similar to the proposed project, the Reduced Development Alternative would be required to comply with existing regulations pertaining to the transport and use of hazardous materials during construction and operation, including those listed in Section 4.9, Hazards and Hazardous Materials. In addition, long-term operations activities typical of residential and the non-residential uses envisioned under the Reduced Development Alternative involve the use and storage of small quantities of potentially hazardous materials in the form of cleaning solvents, fertilizers, and pesticides. For example, maintenance activities related to landscaping include the use of fertilizers and light equipment (e.g., lawn mowers and edgers) that may require fuel. These types of activities do not involve the use of a large or substantial amount of hazardous materials. Further, such materials would be contained, stored, and used in accordance with manufacturers’ instructions and handled in compliance with applicable federal, State, and local regulations. In addition, operation of future residential and non-residential development associated with the Reduced Development Alternative would not store, transport, generate, or dispose of large quantities of hazardous substances, similar to the proposed project. Therefore, implementation of the Reduced Development Alternative would not create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials or emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school.
As discussed in Section 4.9, Hazards and Hazardous Materials, a CREC, HREC, and BER were identified within the Buildout Area. As such, the Phase I ESA recommended preparation and implementation of an Operations and Maintenance (O&M) Plan to safely manage the suspect ACMs and LBP associated with the existing buildings within the Buildout Area and the notification of the OCHCA as required in the case closure summary from 1996 for the CREC. No additional subsurface investigations were recommended. Because implementation of the Reduced Development Alternative would occur within the same area as the proposed project and would be subject to the same hazardous conditions present within the Buildout Area, future development facilitated by the Reduced Development Alternative would be required to implement these recommendations, similar
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to the proposed project and as detailed in Mitigation Measure HAZ-1. In addition, a comprehensive asbestos survey would be required prior to demolition under the Reduced Development Alternative, consistent with SCAQMD Rule 1403 and similar to the proposed project. Therefore, impacts associated with the release of hazardous materials into the environment through reasonably foreseeable upset and accident conditions would be less than significant with adherence to existing regulatory requirements, including SCAQMD Rule 1403, and implementation of Mitigation Measure HAZ-1, requiring implementation of the recommendations provided in the Phase I ESA, similar to the proposed project.
In addition, as discussed in Section 4.9, database searches of the Buildout Area, including a GeoTracker search and a search of Superfund sites, determined that the Buildout Area is not included on a list of hazardous materials sites that could create a significant hazard to the public or the environment, is not included on the Cortese List compiled pursuant to Government Code Section 65962.5, and is not a recorded Superfund site.
Similar to the proposed project, implementation of the Reduced Development Alternative would also not result in a safety hazard or excessive noise for people residing or working in the Buildout Area because any future development within the Buildout Area would be required to comply with all appropriate FAA standards and requirements, including Regulatory Compliance Measure HAZ-1, which requires that the FAA be notified of any proposed structure(s) that would penetrate the 100 to 1 imaginary surface that surrounds the runway at JFTB Los Alamitos.
Future development projects within the Buildout Area under the Reduced Development Alternative would be required to conform with the adopted emergency response or evacuation plan established by the City and would be required to conform with applicable City standards and criteria that specify general fire safety provisions consistent with the California Fire Code, such as automatic, on-site fire protection systems, such as sprinklers in multi-occupancy buildings; and maintenance of certain vegetation that pose a fire hazard risk. Therefore, implementation of the Reduced Development Alternative would not impair implementation of or physically interfere with the adopted emergency response plan or emergency evacuation plan or result in impacts related to the exposure of people or structures to a significant risk of loss, injury or death involving wildland fires.
Therefore, the Reduced Development Alternative would have a less than significant impact related to hazards and hazardous materials with adherence to Regulatory Compliance Measure HAZ-1 and implementation of Mitigation Measure HAZ-1, similar to the proposed project.
Hydrology and Water Quality.. As the Reduced Development Alternative would be located at the same location as the proposed project, the Reduced Development Alternative would be subject to the same hydrologic conditions as the proposed project.
Construction. Similar to the proposed project, future development under the Reduced Development Alternative would be required to comply with applicable construction permits and regulations associated with water quality. Specifically, construction of future development associated with the Reduced Development Alternative would disturb more than one acre of soil, those projects would S PECIFIC PLAN 3.0 B UILDOUT P ROJECT
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be subject to the requirements of the Construction General Permit11, as specified in Regulatory Compliance Measure HYD-1. As required by the Construction General Permit, the Construction Contractor would be required to prepare a SWPPP and implement construction BMPs detailed in the SWPPP during construction activities. The SWPPP would detail the BMPs to be implemented during construction. Construction BMPs would include, but not be limited to, Erosion Control and Sediment Control BMPs designed to minimize erosion and retain sediment on site, and Good Housekeeping BMPs to prevent spills, leaks, and discharge of construction debris and waste into receiving waters.
If construction of future development associated with the Reduced Development Alternative would disturb less than one acre of soil and are not a part of a larger common plan, those projects would be required to comply with Section 4.106 of the 2022 California Green Building Standards Code (CALGreen Code), as specified in Regulatory Compliance Measure HYD-1. Section 4.106 of the CALGreen Code requires implementation of BMPs to prevent flooding and erosion and to retain sediment on site. Compliance with the requirements of the Construction General Permit or Section
4.106 of the CALGreen Code, including incorporation of construction BMPs, would ensure that construction impacts related to waste discharge requirements, water quality standards, degradation of water quality, increased pollutant discharge, and alteration of receiving water quality would be less than significant, similar to the proposed project.
Similar to the proposed project, it is likely that groundwater dewatering would be required during excavation activities associated with buildout of the Reduced Development Alternative.
Groundwater dewatering activities during excavation would be conducted in accordance with the Groundwater Dewatering Permit12, as specified in Regulatory Compliance Measure HYD-2. This permit requires testing and treatment (as necessary) of groundwater encountered during groundwater dewatering prior to release to the storm drain system. As a result, groundwater dewatering would not introduce pollutants to receiving waters at levels that would violate water quality standards or waste discharge requirements, degrade water quality, increase pollutant discharge, or alter the quality of the receiving water. With implementation of Regulatory Compliance Measures HYD-1 and HYD-2, impacts associated with the violation of water quality standards or waste discharge requirements during construction of the Reduced Development Alternative would be less than significant, similar to the proposed project. Implementation of Regulatory Compliance Measures HYD-1 and HYD-2 would also ensure that construction impacts related to on-site, off-site, or downstream erosion or siltation; exceeding the capacity of the adjacent stormwater drainage systems; providing substantial additional sources of polluted runoff; resulting in an increase in any pollutant for which the receiving water body is already impaired; and causing or contributing to an exceeded applicable surface or groundwater receiving water quality objectives or degradation of beneficial uses would be less than significant, similar to the proposed project.
11 SWRCB. 2022. National Pollutant Discharge Elimination System (NPDES) General Permit for Storm Water Discharges Associated with Construction and Land Disturbance Activities (General Permit), Order WQ 2022-0057-DWQ, NPDES No. CAS000002. Adopted September 8. 12 Santa Ana RWQCB. 2020. 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. June 19.
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Operation. Implementation of the Reduced Development Alternative would increase the amount of impervious surface area within the Buildout Area due to the development of the residential and non-residential uses within the Buildout Area. However, because implementation of the Reduced Development Alternative would result in 538 fewer residential units and a reduction of approximately 132,000 square feet of non-residential uses as compared to the proposed project, it is assumed that implementation of the Reduced Development Alternative would result in less impervious surface area than the proposed project. During operation, the Reduced Development Alternative would be required to comply with the requirements of the Orange County MS4 Permit, 13 similar to the proposed project. Compliance with the Orange County MS4 Permit is achieved through adherence to Chapter 13-23 of the Cypress Municipal Code. As required by Chapter 13-23 of the Cypress Municipal Code, and specified in Regulatory Compliance Measure HYD-3, the Reduced Development Alternative would be required to prepare of a project-specific WQMP to specify BMPs that would be implemented to capture, treat, and reduce pollutants of concern in stormwater runoff. With implementation of Regulatory Compliance Measure HYD-3, impacts associated with the violation of water quality standards or waste discharge requirements; providing substantial additional sources of polluted runoff; and resulting in an increase in any pollutant for which the receiving water body is already impaired during operation of the Reduced Development Alternative would be less than significant, similar to the proposed project.
All stormwater from the Buildout Area under the Reduced Development Alternative would also discharge to the Cerritos Avenue Storm Drain, Katella Avenue Storm Drain, Lexington Drive Storm Drain, and Walker Street Storm Drain and ultimately the Los Alamitos Channel, similar to the existing conditions and the proposed project. Because implementation of the Reduced Development Alternative would result in less overall development than the proposed project, it is assumed that the Reduced Development Alternative would have less impervious surface area within the Buildout Area and would result in less stormwater runoff into the surrounding storm drain infrastructure as compared to the proposed project. In addition, the Reduced Development Alternative would also be required to implement similar storm drain infrastructure improvements as the proposed project, including upsizing the existing 18-inch storm drain line in Vessels Circle to a 30-inch to provide sufficient capacity for the 25-year high confidence storm event flowrate. Therefore, because the Drainage Report prepared for the proposed project concluded that implementation of the proposed project would not adversely affect the downstream receiving drainage facilities and the Reduced Development Alternative would implement similar improvements to the storm drain infrastructure, implementation of the Reduced Development Alternative would not exceed the capacity of the adjacent stormwater drainage systems, similar to the proposed project.
Similar to the proposed project, implementation of the Reduced Development Alternative would not substantially change infiltration within the Buildout Area because the Buildout Area has low infiltration potential. In addition, even though GSWC West Orange’s water supply sources include groundwater pumped from the Orange County Groundwater Basin, increased water use during operation of the Reduced Development Alternative would not substantially affect groundwater 13 Santa Ana RWQCB. 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.
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supplies, because the groundwater basin has been sustainably managed by OCWD over the last 10 years and will continue to be sustainably managed. In addition, OCWD and GSWC West Orange coordinate in order to ensure that groundwater extracted for municipal water supplies would not substantially deplete groundwater supplies. Therefore, operational impacts related to a decrease in groundwater supplies or interference with groundwater recharge with implementation of the Reduced Development Alternative would be less than significant, similar to the proposed project.
Because the Reduced Development Alternative would be located at the same location as the proposed project, it would be subject to the same conditions related to flooding, dam failure, seiche, tsunami, and mudflow. As discussed in Section 4.10, Hydrology and Water Quality, the Buildout Area is not located within a 100-year floodplain, an inundation zone of a levee, or an area mapped by the California Emergency Management Agency as being potentially inundated by a tsunami. In addition, the Buildout Area is relatively flat and not at risk of mudflow and, due to the distance from the nearest enclosed body of water to the Buildout Area, the Buildout Area is not in a seiche hazard zone. Therefore, no impact related to these hydrologic hazards would occur with implementation of the Reduced Development Alternative, similar to the proposed project. However, the Buildout Area is located within the inundation zone of Prado Dam and the Carbon Canyon Dam.
Although the Reduced Development Alternative would facilitate the construction of new structures in a dam inundation zone, similar to the proposed project, the Reduced Development Alternative would not increase the chance of inundation from failure of Carbon Canyon Dam or Prado Dam.
Further, the potential for dam failure is remote and the City’s emergency evacuation plans would be implemented if these dams were susceptible to rupture during heavy rains or other events.
Therefore, impacts related to the exposure of people and structures to significant risk associated with flooding as a result of dam failure with implementation of the Reduced Development Alternative would be less than significant, similar to the proposed project.
No riparian habitat currently exists within the Buildout Area. However, four potential jurisdictional water resources currently exist within the Buildout Area, including three artificial ponds located within the LARC racetrack area, one drainage feature, and one detention basin. Similar to the proposed project, if the Reduced Development Alternative would impact these existing features feature or the detention basin, regulatory permits may be required, including those under Section 404 of the CWA as administered by the USACE, the Water Quality Certification under Section 401 of the CWA or Waste Discharge Requirements under the Porter-Cologne Water Quality Control Act as administered by the Santa Ana RWQCB, or the Streambed Alteration Agreement under Section 1602 of the California Fish and Game code as administered by CDFW, as detailed in Mitigation Measure BIO-3. Therefore, with implementation of Mitigation Measure BIO-3, potential impacts on aquatic, wetland, or riparian habitat with implementation of the Reduced Development Alternative would be less than significant, similar to the proposed project.
Therefore, the Reduced Development Alternative would have a less than significant impact related to hydrology and water quality, similar to the proposed project.
Land Use and Planning. Given the nature of the uses envisioned under the Reduced Development Alternative, the future buildout of the Buildout Area would improve existing connectivity in the area with the extension of Moody Street and Vessels Circle and would not divide or separate any existing land uses or neighborhoods. The neighboring residential communities would not be separated by
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the proposed road extensions or proposed buildout of the Reduced Development Alternative.
Implementation of the Reduced Development Alternative would implement the vision of the Specific Plan and would not introduce an inconsistency with the existing uses in the surrounding area and would be consistent with all General Plan and zoning designations. Therefore, the Reduced Development Alternative would not result in the physical division of an established community, similar to the proposed project. Like the proposed project, the Reduced Development Alternative would create more opportunities for connection due to the Moody Street and Vessels Circle extensions that create new north-south and east-west connections in the Buildout Area.
In addition, as the Reduced Development Alternative would develop the Buildout Area with similar uses as the proposed project, the Reduced Development Alternative would not be inconsistent with Connect SoCal, the City’s General Plan, City’s Zoning Ordinance, or the Specific Plan. Similar to the proposed project, the Reduced Development Alternative does not include any proposed amendments or modifications to the adopted Specific Plan. However, the Reduced Development Alternative would not result in as many residential units as contemplated in the Specific Plan and would further reduce the square footage of the town center area. As such, the Reduced Development Alternative would not introduce inconsistencies in the applicable City land use and planning policies.
Further, future development applications contemplated within the Buildout Area would also be required to comply with all applicable regulations and standards related to land use and planning.
Any future development or redevelopment projects requiring discretionary actions would also be subject to environmental review, in accordance with the provisions of CEQA and the State CEQA Guidelines. Therefore, the Reduced Development Alternative would have a less than significant impact related to land use and planning, similar to the proposed project.
Mineral Resources. The Reduced Development Alternative would develop the same area of the city (i.e., Buildout Area) with similar uses as the proposed project and would be subject to the same conditions related to mineral resources as the proposed project. As discussed in Section 4.12, Mineral Resources, there are no known mineral resources in or in the vicinity of the Buildout Area, and there are no other known mineral deposits or resources within the City that are of significant value to the region or the State. In addition, the Buildout Area does not contain a locally important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan. Therefore, the Reduced Development Alternative would have no impact related to mineral resources, similar to the proposed project.
Noise. The Reduced Development Alternative would develop the same area of the city (i.e., Buildout Area) with similar uses as the proposed project; however, 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. This represents a decrease of 538 residential units and approximately 132,000 square feet of non-residential uses as compared to the proposed project and would result in a corresponding reduction in operation noise associated with the residential development during operation, as compared to the proposed project.
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Construction. Although the development under the Reduced Development Alternative would be less intense than the proposed project, noise- and vibration-generating construction activities for both projects would be similar because construction would require the same types of construction activities and equipment. Similar to the proposed project, compliance with the allowed construction hours in the City’s Noise Ordinance would ensure that construction noise does not disturb residents during typical sleeping hours or during hours when ambient noise levels are likely to be lower (i.e., at night). Therefore, the Reduced Development Alternative’s construction noise impacts would be less than significant, similar to the proposed project.
As discussed in Section 4.13, Noise, the nearest existing residential building at the edge of Lot 13 and south of Lot 3 would experience vibration levels below the FTA threshold for building damage.
As the Reduced Development Alternative would also include construction activities in this area, it would result in a similar less than significant impact related to vibration damage.
In addition, construction-generated ground-borne vibration associated with the Reduced Development Alternative would not exceed FTA thresholds related to human annoyance at nearby sensitive receptors, similar to the proposed project. Therefore, similar to the proposed project, the Reduced Development Alternative would result in less than significant impacts related to potential vibration-related human annoyance.
Operation. As the Reduced Development Alternative would result in fewer vehicle trips to and from the Buildout Area due to the reduced development. As such, traffic noise impacts would be less than the proposed project (i.e., less than 0.9 dBA along the analyzed road segments). A noise level increase of less than 3 dBA would not be perceptible to the human ear in an outdoor environment.
Therefore, off-site traffic noise impacts would be less than significant, similar to the proposed project.
Similar to the proposed project, development under the Reduced Development Alternative would generate various on-site stationary noise sources, including heating, ventilation, and air conditioning (HVAC) and commercial uses activities such as loading and unloading and parking lot activities, but at a reduced scale. The Cypress Municipal Code limits non-construction noise experienced at surrounding noise-sensitive uses to 55 dBA or less per the hourly daytime noise level standards for Noise Zone 1 and 60 dBA or less for Noise Zone 2. Similar to the proposed project, preparation of a specific acoustical analysis would be required to confirm compliance with the City’s exterior and interior noise standards related to land use compatibility, as established in City of Cypress Municipal Code Chapter 8 (Noise), Sections 8-1-4 and 8-1-5, which set forth allowable noise limits by noise zone and authorize the City to require noise measurements or acoustical studies to verify compliance with applicable standards prior to or following project occupancy. Therefore, as the Reduced Development Alternative would meet the City’s noise standards, impacts would be less than significant, similar to the proposed project.
In addition, as the Reduced Development Alternative would be located in the same area as the proposed project, the Reduced Development Alternative would also be located within the 60 dBA CNEL noise contour, but outside of the 65 dBA CNEL noise contour for JFTB Los Alamitos. The Buildout Area is also located within Noise Impact Zone 2 (moderate noise impact) and is outside of Noise Impact Zone 1 (high noise impact) defined by the Airport Environs Land Use Plan. However,
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similar to the proposed project, given that the Reduced Development Alternative does not contain outdoor sensitive receptors and the City defined levels between 60 and 65 dBA CNEL as conditionally acceptable with the incorporation of an HVAC system allowing a windows- closed condition and standard building construction, impacts related to exposing people residing or working in the area to excessive noise levels due to airport operations would be less than significant, similar to the proposed project.
Overall, under the Reduced Development Alternative, operational noise impacts would be less than the proposed project due to the reduction in the number of vehicle trips to and from the Buildout Area and implementation of the Reduced Development Alternative would have a less than significant noise impact with implementation of Mitigation Measure NOI-1, similar to the proposed project.
Population and Housing. Because of the reduced scale, implementation of the Reduced Development Alternative would result in fewer future residents and less long-term employment opportunities within the Buildout Area compared to the proposed project. Assuming a ratio of 3.08 people per household, the Reduced Development Alternative would result in a net increase of approximately 3,860 persons at full buildout, which was assumed to take place over 12 years, for an average of 322 people per year.
14 This represents a reduction of 1,656 residents at the Buildout Area with full buildout of the alternative compared to the proposed project.
Similar to the proposed project, the Specific Plan allows for the construction of the residential uses facilitated by the Reduced Development Alternative and the Reduced Development Alternative population increase is within the planned growth for the region. As such, the Reduced Development Alternative would not result in unplanned growth as the City has already planned for the reasonably foreseeable development of housing within the Buildout Area as a way of meeting the City’s RHNA obligations. However, because implementation of the Reduced Development Alternative would include 1,253 residential units (538 fewer residential units within the Buildout Area compared to the proposed project), the Reduced Development Alternative would not be consistent with the amount of housing identified in the Specific Plan and City’s Housing Element for the Buildout Area. In addition, as the Buildout Area does not contain any habitable or occupied structures, implementation of this alternative would not require the demolition of existing housing and would not displace an existing population residing within the Buildout Area.
Therefore, the Reduced Development Alternative would have a less than significant impact related to population and housing, similar to the proposed project.
Public Services.The Reduced Development Alternative would result in 1,656 fewer residents in the Buildout Area that would be added to the City’s population. This would result in a corresponding reduction in demand for public services, including on fire and police protection services, schools, parks, and other public services, as compared to the proposed project.
As discussed in Section 4.15, Public Servies, implementation of the proposed project would not result in substantial adverse physical impacts associated with the provision of new or physically 14 1,253 households x 3.08 persons per household = 3,860 persons S PECIFIC PLAN 3.0 B UILDOUT P ROJECT
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altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for fire and police protection services, schools, or parks with adherence to Regulatory Compliance Measure PS-1, Regulatory Compliance Measure PS-2, Regulatory Compliance Measure PS-3, and the payment of applicable development impact fees. As implementation of the Reduced Development Alternative would result in a decreased demand on these services as compared to the proposed project, implementation of the Reduced Development Alternative would also result in less than significant impacts on these services. The Reduced Development Alternative would also be required to adhere to Regulatory Compliance Measure PS-1, Regulatory Compliance Measure PS-2, Regulatory Compliance Measure PS-3, and the payment of applicable development impact fees.
In addition, implementation of the Reduced Development Alternative would generate additional funding for the City and County through the additional property tax revenue, similar to the proposed project. These funds could be used for the development of new or expanded library facilities or new library equipment if required. Therefore, implementation of the Reduced Development Alternative would also result in less than significant impacts on other public services, including the Orange County Public Library (OCPL) system.
Therefore, the Reduced Development Alternative would have a less than significant impact related to public services with adherence to Regulatory Compliance Measure PS-1, Regulatory Compliance Measure PS-2, Regulatory Compliance Measure PS-3, and the payment of applicable development impact fees, similar to the proposed project.
Recreation. The Reduced Development Alternative would result in a corresponding reduction in demand on parks and recreation facilities due to fewer residential units and less nonresidential development, compared to the proposed project.
As discussed in Section 4.16, Recreation, the City currently has 93.9 acres of parkland available for its 48,782 residents, and it currently provides approximately 1.92 acres of parkland per 1,000 residents, which does not meet the City’s parkland objective of 4.5 acres per 1,000 residents. The additional residents with implementation of the Reduced Development Alternative would change this ratio. Similar to the proposed project, implementation of the Reduced Development Alternative would include approximately 11 acres of land on which park and recreational uses would be developed. The existing Lexington Park, which is approximately nine acres and has already been developed adjacent to Lots 1 and 2 of VTTM 19247, is counted as part of the existing parkland acreage in the City. The specific amenities and improvements that would be developed in the additional two acres of public park space would be determined in connection with future development projects that are proposed within the Buildout Area. The Reduced Development Alternative would also include additional open space areas as an amenity for future residents.
In addition, as specified in Article VI of the City’s Municipal Code, the City requires land to be dedicated as parks for subdivisions that include new residential construction that qualify as dwelling units as defined by Section 6.31.020(D) of the City’s Zoning Ordinance and Section 205(D) of the 2001 California Building Code as they currently exist. The Municipal Code also allows payment of park fees or a credit for private open space in lieu of the land dedication. Similar to the proposed
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project, the Reduced Development Alternative would be required to adhere to Regulatory Compliance Measure PS-3, which requires compliance with Article VI of the City’s Municipal Code.
Therefore, the Reduced Development Alternative would have a less than significant impact on parks and recreation, similar to the proposed project.
Transportation. Under this alternative, the extension of Moody Street from Cerritos Avenue to Katella Avenue and the extension of Vessels Circle from its current western terminus to intersect with the Moody Street extension would still occur, consistent with the Specific Plan and proposed project, and would be constructed consistent with City standards and regulations.
Similar to the proposed project, the Reduced Development Alternative would not conflict with any of the goals and policies contained in the City’s General Plan related to the circulation system. The Reduced Development Alternative would also be consistent with, and reinforce, applicable Connect SoCal 2024 goals, including Connect SoCal 2024’s goals to develop, connect and sustain communities that are livable and thriving and to create a healthy region for the people of today and tomorrow, by providing additional housing opportunities within locations near amenities and already used by the public for commercial, recreational, and/or professional uses. In addition, the proposed project would support the development, connection, and sustainability of communities that are livable and thriving by providing necessary housing for all income levels in a bustling economic corridor.
In addition, the Reduced Development Alternative would not conflict with any adopted transit system plans, guidelines, policies, or standards as implementation would not interfere with implementation of applicable transit planning documents, including the specific actions to address the growing need for expanded transit service contained in the City’s General Plan Circulation Element, 2024 Orange County Transit Vision Master Plan,15 and the County’s Directions 2050 plan,16 which would update OCTA’s Long-Range Transportation Plan (LRTP). Further, implementation of the Reduced Development Alternative would provide sidewalks along the frontages and pedestrian sidewalks and pathways would be provided throughout the Buildout Area and provide connections to existing pedestrian and bicycle facilities in the surrounding area, similar to the proposed project.
Additionally, as discussed further below and detailed in Mitigation Measure TRA-1, the Reduced Development Alternative would be required to implement feasible TDM strategies to mitigate the alternative’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 Reduced Development Alternative would not conflict with any adopted bicycle or pedestrian system plans, guidelines, policies, or standards.
Similar to the proposed project, the Reduced Development Alternative would also be required to prepare and implement a TCP during construction activities, as detailed in development agreement for the proposed project, that would be submitted to the City of Cypress Public Works Department for review and approval, in order to reduce impacts to roadway systems during construction. In 15 Orange County Transportation Authority (OCTA). 2025. 2024 Orange County Transit Vision Master Plan.
May. 16 OCTA. 2025. OCTA Seeks Public Input to Help Shape Orange County’s Transportation Future. October 3.
Website: https://www.octa.net/news/news-releases/octa-seeks-public-input (accessed October 2025).
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addition, similar to the proposed project, although the Reduced Development Alternative would also result in a significant and unavoidable VMT impact, the VMT impact does not, by itself, indicate inconsistency with circulation system policies or a failure to accommodate multimodal transportation. Therefore, based on the above analysis, and because the Reduced Development Alternative would be required to adhere to the Specific Plan and the General Plan, similar to the proposed project, the Reduced Development Alternative would generally be consistent with all programs, plans, ordinances, and policies addressing the circulation system, including those regulating transit, roadway, bicycle, and pedestrian facilities. Impacts would be less than significant, similar to the proposed project.
As the Reduced Development Alternative would result in fewer residential units and a reduction in non-residential uses as compared to the proposed project, the Reduced Development Alternative would generate fewer vehicle trips to and from the Buildout Area and a reduction in VMT during operation. However, without quantification of VMT or alternative-specific VMT analysis, it cannot be determined if the reduction in proposed development and vehicle trips to and from the project site would reduce VMT impacts to below applicable significance thresholds. As such, the Reduced Development Alternative would also be required to implement the VMT reduction measures detailed in Mitigation Measure TRA-1. Implementation of Mitigation Measure TRA-1 would require the Reduced Development Alternative to reduce overall VMT; however, even with implementation of Mitigation Measure TRA-1, without quantification of VMT or alternative-specific VMT analysis, VMT impacts under the Reduced Development Alternative would be significant and unavoidable, similar to the proposed project.
Lastly, the Reduced Development Alternative would not substantially increase hazards due to a geometric design feature or result in inadequate emergency access as all roadway improvements in and around the Buildout Area shall be designed and constructed in accordance with Chapter 25, Article 5, Public Improvements, of the City’s Municipal Code and applicable Public Works Design Standards, similar to the proposed project. In addition, except as otherwise provided in the Specific Plan, all final site and roadway improvement plans shall conform to the City’s Public Works Design Criteria Manual, which incorporates California Manual on Uniform Traffic Control Devices (CA MUTCD) standards for intersection control, sight distance, and geometric design, and all final improvement and site access plans shall be subject to review and approval by the City’s Public Works Department and the Orange County Fire Authority prior to issuance of building permits.
Overall, implementation of the Reduced Development Alternative would have a significant and unavoidable transportation impact related to VMT, even with implementation of Mitigation Measure TRA-1, similar to the proposed project.
Tribal Cultural Resources. The Reduced Development Alternative would develop the same area of the city (i.e., Buildout Area) with similar uses as the proposed project, including residential and nonresidential uses, at a reduced scale. Similar to the proposed project, construction of this alternative has the potential to significantly impact unidentified tribal cultural resources during grounddisturbing activities, similar to the proposed project. Therefore, consistent with the proposed project, the Reduced Development Alternative would be required to adhere to Regulatory Compliance Measures CUL-1 and CUL-2, which detail provisions in the event that previously unknown cultural resources, including human remains, are discovered during ground-disturbing
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construction activities, consistent with the California Code of Regulations (CCR) Section 15064.5(e) and State Health and Safety Code Section 7050.5. In addition, because the Reduced Development Alternative would be located at the same location as the proposed project, the alternative would also be required to implement Mitigation Measures TCR-1 through TCR-4, which require tribal cultural resources training and ALERT sheet posting, on-site tribal monitoring during ground disturbance of native sediment, and provisions in the event that previously unknown tribal cultural resources (including human remains and funerary objects) are discovered during ground-disturbing construction activities.
With adherence to Regulatory Compliance Measures CUL-1 and CUL-2 and implementation of Mitigation Measures TCR-1 through TCR-4, the potential impacts to known and unknown tribal cultural resources would be less than significant with mitigation incorporated, similar to the proposed project.
Utilities and Service Systems. The Reduced Development Alternative would result in a reduction in demand on utilities, including water, wastewater, stormwater, electricity, natural gas, and telecommunications, as compared to the proposed project. Similar to the proposed project, the Reduced Development Alternative would connect to existing utility infrastructure in the vicinity of the Buildout Area and would include the installation of the same or similar utility improvements as the proposed project.
Similar to the proposed project, implementation of the Reduced Development Alternative would not require the relocation or construction of new or expanded water, wastewater treatment or stormwater drainage, electric power, natural gas, or telecommunications facilities or infrastructure, beyond those associated with the alternative detailed above. Because the Reduced Development Alternative would result in less demand on utilities and Section 4.19, Utilities and Service Systems determined that GSWC and OC San could adequately serve the development under the proposed project, these water and wastewater service provides could adequately accommodate the development under the Reduced Development Alternative. Further, the stormwater drainage system under Reduced Development Alternative, as required by Regulatory Compliance Measure HYD-3, would be designed to ensure that operation of the Reduced Development Alternative would not result in a substantial increase in the rate or amount of surface runoff, flow, and volume that would exceed the capacity of the adjacent stormwater drainage systems, and no new additional infrastructure would be required. Lastly, SCE and SoCalGas would be able to adequately serve the Reduced Development Alternative, similar to the proposed project.
Additionally, similar to the proposed project, all future projects implemented in accordance with the proposed project would be required to adhere to the Specific Plan, provide required development impact fees, and comply with applicable development regulations pertaining to utility improvements and connections. As a part of the development review process, all future projects would be required to demonstrate that existing public utilities would be sufficient to serve the future projects’ needs, through the issuance of a will serve letter. As such, the Reduced Development Alternative would not require the relocation or construction of new or expanded utilities and impacts would be less than significant.
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In addition, similar to the proposed project, impacts related to solid waste with implementation of the Reduced Development Alternative would be less than significant with adherence to Regulatory Compliance Measure UTIL-1 requiring compliance with the City’s Construction and Demolition Ordinance. Further, solid waste from future development facilitated by the Reduced Development Alternative would be required to comply with State and local solid waste reduction, diversion, and recycling policies and regulations, including AB 1327 (wood waste disposal), Chapter 18 of the California Solid Waste Reuse and Recycling Access Act of 1991 (requires adequate, permanent space for recycling and solid waste collection at new developments), AB 939 (California Department of Resources Recycling and Recovery [CalRecycle]), AB 75 (solid waste diversion), AB 1826 (organic waste recycling), and SB 1383 (organic waste collection services). With adherence to these existing regulatory requirements and because the Reduced Development Alternative would generate less solid waste as compared to the proposed project, the Historic Preservation Alternative would also result in less than significant impacts related to solid waste.
Therefore, the Reduced Development Alternative would have a less than significant impact related to utilities and service systems with adherence to Regulatory Compliance Measure UTIL-1, similar to the proposed project.
Wildfire. As discussed in Section 4.20, Wildfire, according to the CAL FIRE VHFHSZ for the Orange County region, the entire city is designated as a non-VHFHSZ,17 and the city does not include a SRA.
The nearest VHFHSZ to the Buildout Area is approximately 6.8 miles northeast in Coyote Hills on the western side of Fullerton.18 The nearest SRA is in Puente Hills, approximately 12 miles northeast of the Buildout Area. As such, the Buildout Area is not located in or near any SRAs or lands classified as VHFHSZs. Therefore, the Reduced Development Alternative would have no impact related to wildfire, similar to the proposed project.
5.5.3.3 Attainment of Project Objectives
The Reduced Development Alternative would not meet the project objectives to the same extent as the proposed project, as discussed further below.
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.
While the Reduced Development Alternative would facilitate development of 1,253 residential units within the Buildout Area, which would help meet the significant unmet demand for housing in the City and the project vicinity, the Reduced Development Alternative would result in 538 fewer residential units than the proposed project. As such, the Reduced Development Alternative would no satisfy this objective to the same extent as the proposed project. 17 California Department of Forestry and Fire Protection (CAL FIRE). 2011. Very High Fire Hazard Severity Zones in LRA. Website: https://osfm.fire.ca.gov/media/6739/fhszl_map30.pdf (accessed February 6, 2025). 18 Ibid.
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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.
While the Reduced Development Alternative would facilitate development of new residential and non-residential uses, including a mix of entertainment, retail, restaurant, and commercial uses, within the Buildout Area, which would establish the Buildout Area as a mixed-use town center, the Reduced Development Alternative would result in 538 fewer residential units and a reduction of approximately 132,000 square feet of non-residential uses as compared to the proposed project. As such, the Reduced Development Alternative would not meet this objective to the same extent as the proposed project.
3. Revitalize a large urban area in the City that is currently significantly underutilized.
Similar to the proposed project, the Reduced Development Alternative would facilitate the development of the Buildout Area with new residential and non-residential uses, consistent with the Specific Plan. Therefore, the Reduced Development Alternative would revitalize a large urban area in the City that is currently significantly underutilized. However, the Reduced Development Alternative does not include the same residential or nonresidential density as the proposed project, as permitted in the Specific Plan. As such, the Reduced Development Alternative would not meet this objective to the same extent as the proposed project.
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.
As discussed above, while the Reduced Development Alternative would facilitate development of 1,253 residential units within the Buildout Area, which would include a variety of housing product types and densities to meet a range of housing needs of Cypress and area residents, the Reduced Development Alternative would result in 538 fewer residential units than the proposed project. As such, the Reduced Development Alternative would not meet this objective to the same extent as the proposed project.
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.
As discussed above and similar to the proposed project, the Reduced Development Alternative would facilitate the development of the Buildout Area with new residential, non-residential, and park uses, consistent with the Specific Plan. Therefore, like the proposed project, the Reduced Development Alternative would 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. The Reduced Development Alternative would be similar to the proposed project in meeting this project objective. However, the Reduced Development Alternative does not include the same residential or nonresidential density as the S PECIFIC PLAN 3.0 B UILDOUT P ROJECT
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proposed project, as permitted in the Specific Plan. As such, the Reduced Development Alternative would not meet this objective to the same extent as the proposed project.
6. Develop a project that will invigorate the local economy by providing new employment and business opportunities.
As discussed above, while the Reduced Development Alternative would facilitate development of approximately 308,000 square feet of non-residential (commercial) uses within the Buildout Area, which would invigorate the local economy by providing new employment and business opportunities, the Reduced Development Alternative would result in a reduction of approximately 132,000 square feet of non-residential uses as compared to the proposed project. As such, the Reduced Development Alternative would not meet this objective to the same extent as the proposed project.
7. Provide residential and commercial/retail improvements that generate new sources of revenue for the City through increased property values and retail sales.
As discussed above, while the Reduced Development Alternative would facilitate development of new residential and non-residential uses, which would provide residential and commercial/retail improvements that generate new sources of revenue for the City through increased property values and retail sales, the Reduced Development Alternative would result in 538 fewer residential units and a reduction of approximately 132,000 square feet of nonresidential uses as compared to the proposed project. As such, the Reduced Development Alternative would not meet this objective to the same extent as the proposed project.
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.
Similar to the proposed project, the Reduced Development Alternative would include the extension of Moody Street from Cerritos Avenue to Katella Avenue and the extension of Vessels Circle from its current western terminus to intersect with the Moody Street extension would still occur, consistent with the Specific Plan. However, the Reduced Development Alternative’s decreased vehicle traffic would mean that these new street connections may effectively improve overall traffic circulation in the project vicinity in comparison to the proposed project.
Therefore, the Reduced Development Alternative would be superior to the proposed project in meeting this project objective.
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.
The Reduced Development Alternative would facilitate the development of 1,253 residential units within the Buildout Area and, similar to the proposed project and consistent with the Specific Plan, would include senior housing communities. However, the Reduced Development Alternative would result in 538 fewer residential units compared to the proposed project.
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Therefore, the Reduced Development Alternative would be inferior in developing residential uses with sufficient housing units to support the size, scale and operation of planned public parks and other amenities and common areas included within the Buildout Area. As such, the Reduced Development Alternative would not meet this objective to the same extent as the proposed project.
Overall, the Reduced Development Alternative would not fully satisfy a number of the key project objectives relating to the already-approved Specific Plan and number of residential units. Therefore, this alternative would not satisfy the project objectives to the same extent as the proposed project.
5.6 COMPARISON OF ALTERNATIVES AND IDENTIFICATION OF ENVIRONMENTALLY
SUPERIOR ALTERNATIVE
5.6.1 Alternatives Summary Comparison of Impacts and Ability to Meet Project Objectives Table 5.B: Proposed Project and Project Alternatives Impact Comparison below, identifies the level of impact for the proposed project and each alternative (e.g., no impact, less than significant impact, less than significant impact with mitigation, significant and unavoidable impact, or significant and unavoidable impact with mitigation) and whether the impact of the alternative would be the same as, less than, or greater than the proposed project impacts. In some cases, the proposed project and alternative would result in the same significance determination, but the degree of that impact with the alternative might be less than or greater than the proposed project.
Table 5.B: Proposed Project and Project Alternatives Impact Comparison Environmental Impacts Proposed
Project
No Project
Alternative
Historic
Preservation
Alternative
Reduced
Development
Alternative
4.1: Aesthetics
Threshold 4.1.1: Would the project have a substantial adverse effect on a scenic vista? NI NI
=
NI
=
NI
=
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?
NI NI
=
NI
=
NI
=
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?
LTS NI
<
LTS
<
LTS
=
Threshold 4.1.4: Would the project create a new source of substantial light or glare that would adversely affect daytime or nighttime views in the area?
LTS NI
<
LTS
>
LTS
<
4.2: Agriculture and Forestry Resources
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?
NI NI
=
NI
=
NI
=
Threshold 4.2.2: Would the project conflict with existing zoning for agricultural use or a Williamson Act contract? NI NI =
NI
=
NI
=
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Table 5.B: Proposed Project and Project Alternatives Impact Comparison Environmental Impacts Proposed
Project
No Project
Alternative
Historic
Preservation
Alternative
Reduced
Development
Alternative
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))?
NI NI
=
NI
=
NI
=
Threshold 4.2.4: Would the project result in the loss of forest land or conversion of forest land to non-forest use? NI NI =
NI
=
NI
=
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 non-agricultural use or conversion of forest land to non-forest use?
NI NI
=
NI
=
NI
=
4.3: Air Quality
Threshold 4.3.1: Would the proposed project conflict with or obstruct implementation of the applicable air quality plan? SU NI <
SU
=
SU
=
Threshold 4.3.2: Would the proposed project result in a cumulatively considerable net increase of any criteria pollutant for which the project region is in non-attainment under an applicable federal or State ambient air quality standard? SU NI
<
SU
=
SU
<
Threshold 4.3.3: Would the proposed project expose sensitive receptors to substantial pollutant concentrations? SU NI <
SU
=
SU
<
Threshold 4.3.4: Would the proposed project create
objectionable odors affecting a substantial number of people? LTS NI <
LTS
=
LTS
=
4.4: Biological Resources
Threshold 4.4.1: Would the project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or the U.S. Fish and Wildlife Service?
LTS NI
<
LTS
=
LTS
=
Threshold 4.4.2: Would the project have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, and regulations or by the California Department of Fish and Wildlife or the U.S. Fish and Wildlife Service?
NI NI
=
NI
=
NI
=
Threshold 4.4.3: Would the project have a substantial adverse effect on federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
LTSM NI
<
LTSM
=
LTSM
=
Threshold 4.4.4: Would the project interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites? LTS NI
<
LTS
=
LTS
=
Threshold 4.4.5: Would the project conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
LTS NI
<
LTS
=
LTS
=
Threshold 4.4.6: Would the project conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan?
NI NI
=
NI
=
NI
=
4.5: Cultural Resources
Threshold 4.5.1: Would the project cause a substantial adverse change in the significance of a historical resource pursuant to §15064.5?
SU NI
<
LTSM
<
SU
=
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Table 5.B: Proposed Project and Project Alternatives Impact Comparison Environmental Impacts Proposed
Project
No Project
Alternative
Historic
Preservation
Alternative
Reduced
Development
Alternative
Threshold 4.5.2: Would the project cause a substantial adverse change in the significance of an archaeological resource pursuant to §15064.5?
LTS NI
<
LTS
=
LTS
=
Threshold 4.5.3: Would the project disturb any human remains, including those interred outside of dedicated cemeteries? LTS NI <
LTS
=
LTS
=
4.6: Energy
Threshold 4.6.1: Would the project result in a potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation?
LTS NI
<
LTS
=
LTS
<
Threshold 4.6.2: Would the project conflict with or obstruct a state or local plan for renewable energy or energy efficiency? LTS NI <
LTS
=
LTS
<
4.7: Geology and Soils
Threshold 4.7.1: Would the project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving: (i) Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of known fault? (Refer to Division of Mines and Geology Special Publication 42) (ii) Strong seismic ground shaking? (iii) Seismic-related ground failure, including liquefaction? (iv) Landslides?
LTSM NI
<
LTSM
=
LTSM
=
Threshold 4.7.2: Would the project result in substantial soil erosion or the loss of topsoil? LTS NI
<
LTS
=
LTS
=
Threshold 4.7.3: Would the project be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on-site or off-site landslides, lateral spreading, subsidence, liquefaction, or collapse?
LTSM NI
<
LTSM
=
LTSM
=
Threshold 4.7.4: Would the project be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating direct or indirect substantial risks to life or property? NI NI
<
NI
=
NI
=
Threshold 4.7.5: Would the project have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater?
NI NI
<
NI
=
NI
=
Threshold 4.7.6: Would the project directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
LTSM NI
<
LTSM
=
LTSM
=
4.8: Greenhouse Gas Emissions
Threshold 4.8.1: Would the project generate GHG emissions either directly or indirectly that may have a significant impact on the environment?
SU NI
<
SU
=
SU
<
Threshold 4.8.2: Would the project conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of GHGs?
SU NI
<
SU
=
SU
=
4.9: Hazards and Hazardous Materials
Threshold 4.9.1: Would the project create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials?
LTS NI
<
LTS
=
LTS
=
Threshold 4.9.2: Would the project create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?
LTSM NI
<
LTSM
=
LTSM
=
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Table 5.B: Proposed Project and Project Alternatives Impact Comparison Environmental Impacts Proposed
Project
No Project
Alternative
Historic
Preservation
Alternative
Reduced
Development
Alternative
Threshold 4.9.3: Would the project emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? LTS NI
<
LTS
=
LTS
=
Threshold 4.9.4: Would the project be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment?
LTSM NI
<
LTSM
=
LTSM
=
Threshold 4.9.5: Would the project for a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard for people residing or working in the project area?
LTS NI
<
LTS
=
LTS
=
Threshold 4.9.6: Would the project impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
NI NI
<
NI
=
NI
=
Threshold 4.9.7: Would the project expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires?
NI NI
<
NI
=
NI
=
4.10: Hydrology and Water Quality
Threshold 4.10.1: Would the project violate any water quality standards or waste discharge requirements? LTS NI
<
LTS
=
LTS
=
Threshold 4.10.2: Would the project substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level (e.g., the production rate of pre-existing nearby wells would drop to a level which would not support existing land uses or planned uses for which permits have been granted)?
LTS NI
<
LTS
=
LTS
=
Threshold 4.10.3: Would the project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of stream or river, in a manner which would result in substantial erosion or siltation on- or off-site? LTS NI
<
LTS
=
LTS
=
Threshold 4.10.4: Would the project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, or substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site?
LTS NI
<
LTS
=
LTS
=
Threshold 4.10.5: Would the project create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff?
LTS NI
<
LTS
=
LTS
=
Threshold 4.10.6: Would the project otherwise substantially degrade water quality? LTS NI
<
LTS
=
LTS
=
Threshold 4.10.7: Would the project place housing within a 100-year flood hazard area as mapped on a federal Flood Hazard Boundary or Flood Insurance Rate Map or other flood hazard delineation map?
NI NI
<
NI
=
NI
=
Threshold 4.10.8: Would the project place within a 100-year flood hazard area structures which would impede or redirect flood flows?
NI NI
<
NI
=
NI
=
Threshold 4.11.9: Would the project expose people or
structures to a significant risk of loss, injury or death involving flooding, including flooding as a result of the failure of a levee or dam?
LTS NI
<
LTS
=
LTS
=
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Table 5.B: Proposed Project and Project Alternatives Impact Comparison Environmental Impacts Proposed
Project
No Project
Alternative
Historic
Preservation
Alternative
Reduced
Development
Alternative
Threshold 4.10.10: Would the project be subject to inundation by seiche, tsunami, or mudflow? NI
NI
<
NI
=
NI
=
Threshold 4.10.11: Would the project result in an increase in pollutant discharges to receiving waters? Consider water quality parameters such as temperature, dissolved oxygen, turbidity and other typical stormwater pollutants (e.g., heavy metals, pathogens, petroleum derivatives, synthetic organics, sediment, nutrients, oxygen-demanding substances, and trash)
LTS NI
<
LTS
=
LTS
=
Threshold 4.10.12: Would the project result in significant alteration of receiving water quality during or following construction?
LTS NI
<
LTS
=
LTS
=
Threshold 4.10.13: Would the proposed project result in increased erosion downstream? LTS NI
<
LTS
=
LTS
=
Threshold 4.10.14: Would the project result in increased impervious surfaces and associated increased runoff? LTS NI <
LTS
=
LTS
=
Threshold 4.10.15: Would the project create a significant adverse environmental impact to drainage patterns due to changes in runoff flow rates or volumes?
LTS NI
<
LTS
=
LTS
=
Threshold 4.10.16: Would the project be tributary to an already impaired water body, as listed on the Clean Water Act Section 303(d) list? If so, can it result in an increase in any pollutant for which the water body is already impaired? LTS NI
<
LTS
=
LTS
=
Threshold 4.10.17: Would the project be tributary to other environmentally sensitive areas? If so, can it exacerbate already existing sensitive conditions?
LTS NI
<
LTS
=
LTS
=
Threshold 4.10.18: Would the project have a potentially significant environmental impact on surface water quality to either marine, fresh, or wetland waters?
LTS NI
<
LTS
=
LTS
=
Threshold 4.10.19: Would the project have a potentially significant adverse impact on groundwater quality? LTS NI <
LTS
=
LTS
=
Threshold 4.10.20: Would the project cause or contribute to an exceeded applicable surface or groundwater receiving water quality objectives or degradation of beneficial uses?
LTS NI
<
LTS
=
LTS
=
Threshold 4.11.21: Would the project impact aquatic, wetland, or riparian habitat? LTSM NI
<
LTSM
<
LTSM
=
4.11: Land Use and Planning
Threshold 4.11.1: Would the project physically divide an established community? LTS NI
<
LTS
=
LTS
=
Threshold 4.11.2: Would the project cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect?
LTS NI
<
LTS
=
LTS
=
4.12: Mineral Resources
Threshold 4.12.1: Would the project result in the loss of availability of a known mineral resource that would be a value to the region and the residents of the State?
NI NI
<
NI
=
NI
=
Threshold 4.12.2: Would the project result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan?
NI NI
<
NI
=
NI
=
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Table 5.B: Proposed Project and Project Alternatives Impact Comparison Environmental Impacts Proposed
Project
No Project
Alternative
Historic
Preservation
Alternative
Reduced
Development
Alternative
4.13: Noise and Vibration
Threshold 4.13.1: Would the project result in the generation of a substantial temporary or permanent increase (defined as an increase of 3 dBA or more) in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies?
LTS NI
<
LTS
=
LTS
<
Threshold 4.13.2: Would the project result in the generation of excessive groundborne vibration or groundborne noise levels? LTSM NI <
LTSM
=
LTSM
=
Threshold 4.13.3: For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within 2 miles of a public airport or public use airport, would the project result in the exposure of people residing or working in the project area to excessive noise levels? LTS NI
<
LTS
=
LTS
=
4.14: Population and Housing
Threshold 4.14.1: Would the project induce substantial
unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)? LTS NI
<
LTS
<
LTS
<
Threshold 4.14.2: Would the project displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?
NI NI NI
=
NI
=
4.15: Public Services
Threshold 4.15.1: Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for fire protection?
LTS NI
<
LTS
>
LTS
<
Threshold 4.15.2: Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for police protection?
LTS NI
<
LTS
>
LTS
<
Threshold 4.15.3: Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for schools?
LTS NI
<
LTS
<
LTS
<
Threshold 4.15.4: Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for parks?
LTS NI
<
LTS
<
LTS
<
Threshold 4.15.5: Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to LTS NI
<
LTS
<
LTS
<
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Table 5.B: Proposed Project and Project Alternatives Impact Comparison Environmental Impacts Proposed
Project
No Project
Alternative
Historic
Preservation
Alternative
Reduced
Development
Alternative
maintain acceptable service ratios, response times or other performance objectives for other public facilities?
4.16: Recreation
Threshold 4.16.1: Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated?
LTS NI
<
LTS
<
LTS
<
Threshold 4.16.2: Would the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment? LTS NI
<
LTS
<
LTS
<
4.17: Transportation
Threshold 4.17.1: Would the project conflict with a program, plan, ordinance or policy addressing the circulation system including transit, roadway, bicycle and pedestrian facilities? SU NI
<
SU
<
SU
<
Threshold 4.17.2: Would the project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)? SU NI <
SU
<
SU
<
Threshold 4.17.3: Would the project substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)?
LTS NI
<
LTS
=
LTS
=
Threshold 4.17.4: Would the project result in inadequate emergency access? LTSM NI
<
LTSM
=
LTSM
=
4.18: Tribal Cultural Resources
Threshold 4.18.1: Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
(1) Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k); or (2) A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1? In applying the criteria set forth in subdivision (c) of Public Resource Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe?
LTSM NI
<
LTSM
=
LTSM
=
4.19: Utilities and Service Systems
Threshold 4.19.1: Would the project require or result in the relocation or construction of new or expanded water, wastewater treatment or stormwater drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?
LTS NI
<
LTS
=
LTS
<
Threshold 4.19.2: Would the project have insufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years? LTS NI
<
LTS
=
LTS
<
Threshold 4.19.3: Would the project result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?
LTS NI
<
LTS
=
LTS
<
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Table 5.B: Proposed Project and Project Alternatives Impact Comparison Environmental Impacts Proposed
Project
No Project
Alternative
Historic
Preservation
Alternative
Reduced
Development
Alternative
Threshold 4.19.4: Would the project generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?
LTS NI
<
LTS
=
LTS
<
Threshold 4.19.5: Would the project conflict with federal, state, and local management and reduction statutes and regulations related to solid waste?
LTS NI
<
LTS
=
LTS
<
4.20: Wildfire
Threshold 4.20.1: Would the project substantially impair an adopted emergency response plan or emergency evacuation plan?
NI NI
=
NI
=
NI
=
Threshold 4.20.2: Due to slope, prevailing winds, and other factors, would the project exacerbate wildfire risks, and thereby expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?
NI NI
=
NI
=
NI
=
Threshold 4.20.3: Would the project require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment?
NI NI
=
NI
=
NI
=
Threshold 4.20.4: Would the project expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes?
NI NI
=
NI
=
NI
=
LTS = Less than Significant
NI = No Impact
SU = Significant and Unavoidable
LTSM = Less Than Significant with Mitigation
< (less than proposed project)
> (greater than proposed project)
= (equal to proposed project)
A comparison of each alternative and its ability to meet the project objectives compared to the proposed project is summarized below in Table 5.C: Summary of Ability of the Proposed Project and Alternatives to Address Project Objectives and evaluated in more detail in the subsequent discussion.
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Table 5.C: Summary of Ability of the Proposed Project and Alternatives to Address Project Objectives
Project Objective Proposed
Project
No Project
Alternative
Historic
Preservation
Alternative
Reduced
Development
Alternative
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.
Yes No Yes
<
Yes
<
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.
Yes No Yes
<
Yes
<
3. Revitalize a large urban area in the City that is currently significantly underutilized. Yes No Yes= Yes
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.
Yes No Yes
=
Yes
<
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.
Yes No Yes
< Yes
6. Develop a project that will invigorate the local economy by providing new employment and business
opportunities.
Yes No Yes
>
Yes
<
7. Provide residential and commercial/retail improvement that will generate new sources of revenue for the City
through increased property values and retail sales.
Yes No Yes
<
Yes
<
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.
Yes No Yes Yes
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.
Yes No Yes
<
Yes
<
< (less than)
> (greater than)
5.6.1.1 No Project Alternative
Based on the above analysis, 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 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 the underlying purpose of the project and would not meet any of the project’s objectives.
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5.6.1.2 Historic Preservation Alternative
Because the alternative would retain the existing character-defining features, including the pre-1970 track, the 1954 quarter-mile chute, the infield and ponds, and a portion of the grandstand, implementation of the Historic Preservation Alternative would avoid the significant and unavoidable impact to built-environment historic resources as defined in State CEQA Guidelines Section 15064.5 associated with the proposed project.
Because development within the Buildout Area under the Historic Preservation Alternative would occur on a project-by-project basis and the specific design and sequence of those projects cannot be determined at this time, it is not yet known if future development projects would result in construction-related health risks that would be below the SCAQMD’s significance thresholds.
Therefore, the Historic Preservation Alternative would not avoid the proposed project’s significant and unavoidable related to conflict with the applicable air quality plan. In addition, although the Historic Preservation Alternative would reduce operational emissions associated with the residential development due to the 22 percent reduction in residential units, due to the inclusion of the performance venue, which would result in an increase in vehicle trips to and from the project site as compared to the proposed project, and 6-story parking garage, and because the air quality emissions under the Historic Preservation Alternative have not been quantified, the Historic Preservation Alternative would also not avoid the proposed project 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.
In addition, while the Historic Preservation Alternative would result in fewer residential units as compared to the proposed project and the VMT impacts are expected to be reduced, without quantification of the VMT associated with the residential uses under the Historic Preservation Alternative or alternative-specific VMT analysis, it cannot be determined if the reduction in residential development would result in VMT impacts below applicable levels of significance (i.e.,
13.21 VMT per capita, 15 percent below the existing regional average). In addition, the performance venue proposed under the Historic Preservation Alternative is expected to generate a significant amount of VMT as the performance venue and would attract visitors from outside the county during performance and events. Therefore, the Historic Preservation Alternative would not avoid the proposed project’s significant and unavoidable VMT impact.
As indicated in Table 5.C, above, the Historic Preservation Alternative would meet the objectives of the project to a lesser extent than the proposed project due to the reduced number of residential units. In addition, the Historic Preservation Alternative would not meet the underlying purpose of the proposed project to redevelop the Buildout Area in accordance with the voted-approved Specific Plan, as the Historic Preservation Alternative requires amendments to the Specific Plan that must be voted on and adopted by voters.
5.6.1.3 Reduced Development Alternative
The Reduced Development Alternative would not avoid the significant and unavoidable impact to historical resources as defined in State CEQA Guidelines Section 15064.5 as implementation of the alternative would include the demolition and removal of all or a substantial portion of the existing
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improvements associated with the LARC property, including the race track and infield area, grandstand, buildings, barns and structures and three artificial lakes, similar to the proposed project.
Further, because development within the Buildout Area under the Reduced Development Alternative would occur on a project-by-project basis and the specific design and sequence of those projects cannot be determined at this time, it is not yet known if future development projects would result in construction-related health risks that would be below the SCAQMD’s significance thresholds. Therefore, the Reduced Development Alternative would not avoid the proposed project’s significant and unavoidable related to conflict with the applicable air quality plan. In addition, although the Reduced Development Alternative would reduce operational emissions associated with the residential development due to the reduction in residential units, because the air quality emissions under the Reduced Development Alternative have not been quantified, the Reduced Development Alternative would also not avoid the proposed project 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.
In addition, while the Reduced Development Alternative would generate fewer vehicle trips to and from the project site and result in a reduction in VMT, without quantification of VMT or alternativespecific VMT analysis, it cannot be determined if the reduction in proposed development and vehicle trips to and from the project site would reduce VMT impacts to below applicable significance thresholds. Therefore, implementation of the Reduced Development Alternative would continue to result in significant and unavoidable impacts related to VMT.
As indicated in Table 5.C, above, the Reduced Development Alternative would generally meet the objectives of the project to a lesser extent than the proposed project due to the reduced number of residential units and non-residential space compared to the proposed project.
5.6.2 Environmentally Superior Alternative
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’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 or air quality.
Accordingly, the Historic Preservation Alternative is considered the Environmentally Superior Alternative.
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6.0 OTHER CEQA CONSIDERATIONS
Section 15126.2(c) of the State CEQA Guidelines requires that an Environmental Impact Report (EIR) describe any significant impacts that cannot be avoided in all phases of a project, including:
planning, acquisition, development, and operation. This chapter discusses these CEQA considerations associated with the implementation of the proposed Specific Plan 3.0 Buildout Project (proposed project). Specifically, Section 15126.2(c) states that an EIR shall:
“Describe any significant impacts, including those which can be mitigated but not reduced to a level of insignificance. Where there are impacts that cannot be alleviated without imposing an alternative design, their implications and the reasons why the project is being proposed, notwithstanding their effect, should be described.”
According to Section 15126 of the State CEQA Guidelines, an EIR must include the following as part of its analysis, as addressed in this chapter:
1. Significant short- and long-term environmental effects associated with project implementation (Section 6.1, Short-and Long-Term Implications);
2. Significant environmental effects due to wasteful, inefficient, or unnecessary consumption use of energy, or wasteful use of energy resources (Section 6.2, Energy Impacts);
3. Significant environmental effects that cannot be avoided if the proposed project is implemented (Section 6.3, Summary of Significant Unavoidable Impacts);
4. Significant irreversible environmental changes that would result from implementation of the proposed project (Section 6.4, Significant Irreversible Environmental Changes); and
5. Growth-inducing impacts resulting from implementation of the proposed project (Section 6.5, Growth-Inducing Impacts).
6.1 SHORT-AND LONG-TERM IMPLICATIONS
Section 15126.2(a) of the State CEQA Guidelines requires that an EIR identify and focus on the significant effects of the proposed project on the environment. Specifically, Section 15126.2(a) states:
“Direct and indirect significant effects of the project on the environment shall be clearly identified and described, giving due consideration to both the short-term and long-term effects. The discussion should include relevant specifics of the area, the resources involved, physical changes, alterations to ecological systems, and changes induced in population distribution, population concentration, the human use of the land (including commercial and residential development), health and safety problems caused by the physical changes, and other aspects of the resource base such as water, historical resources, scenic quality, and public services. The EIR shall S PECIFIC PLAN 3.0 B UILDOUT P ROJECT
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6 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\6.0 Other CEQA Considerations.docx (03/12/26) -2 also analyze any significant environmental effects the project might cause or risk exacerbating by bringing development and people into the area affected.” The proposed project involves the reasonably foreseeable buildout allowed under the Cypress Town Center and Commons Specific Plan 3.0 (Specific Plan), which City of Cypress voters approved as part of the Housing Element Implementation project. The reasonably foreseeable buildout under the Specific Plan includes an additional 1,791 residential units and 440,000 square feet of nonresidential development.
The proposed project includes the requested approval of VTTM 19274, which includes approximately 151.6 acres split into 14 lots, of which approximately 134 acres are located within the Buildout Area. In accordance with the approved Specific Plan, the proposed project includes residential development in the Buildout Area on Lots 2 through 4 and 7, residential and nonresidential development on Lots 10 through 14, and the development of park and recreational improvements on Lots 1, 5 and 6.
As discussed in Section 4.4, Biological Resources, the Buildout Area is located within an urban, builtout area in Cypress and is currently disturbed and developed with existing uses. Existing vegetation communities and land covers within the Buildout Area consist mostly of ornamental and ruderal grassland, and no habitat for Special-Status Natural Communities exists in the Buildout Area. While 73 species-status plant and animal species are known to occur within the project site vicinity, no special-status species were observed within the Buildout Area during the reconnaissance survey. In addition, compliance with Regulatory Compliance Measures BIO-1 and BIO-2 and implementation of Mitigation Measure BIO-1 would ensure that any potential impacts to special-status species, communities, or jurisdictional waters would be less than significant. Therefore, future development associated with the proposed project would not alter existing ecological systems in the Buildout Area.
Future construction facilitated by the proposed project would not result in health and safety issues, as all future development within the Buildout Area requiring discretionary actions would be required to adhere to all applicable health and safety regulations, as specified in Section 4.9, Hazards and Hazardous Materials, during construction and operation. In addition, demolition activities associated with the proposed project would not commence without a demolition permit and compliance with Mitigation Measure HAZ-1. Mitigation Measure HAZ-1 requires an asbestos survey be completed prior to demolition, ensuring no impacts to health and safety would occur during future demolition. Therefore, the future development facilitated by the proposed project would not cause any health and safety issues.
As discussed in Section 4.10, Hydrology and Water Quality, the proposed project would be required to include construction and operational Best Management Practices (BMPs) to reduce impacts to water quality and hydrology in compliance with local ordinances and plans adopted to comply with requirements of the various applicable NPDES permits. Specifically, if construction of a future development project associated with the proposed project would disturb greater than one acre of
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If construction of a future development project associated with the proposed project would disturb less than one acre of soil and are not a part of a larger common plan, that project would be required to comply with Section 4.106 of the 2022 California Green Building Standards Code (CALGreen Code), as specified in Regulatory Compliance Measure HYD-1. Section 4.106 of the CALGreen Code requires implementation of BMPs to prevent flooding and erosion and to retain sediment onsite. In addition, groundwater dewatering activities during excavation would be conducted in accordance with the Groundwater Dewatering Permit2
, as specified in Regulatory Compliance Measure HYD-2,
which requires testing and treatment (as necessary) of groundwater encountered during groundwater dewatering prior to release to the storm drain system. As a result, groundwater dewatering would not introduce pollutants to receiving waters at levels that would violate water quality standards or waste discharge requirements, degrade water quality, increase pollutant discharge, or alter the quality of the receiving waters.
The proposed project would be required to comply with the requirements of the Orange County MS4 Permit3
, as required by Chapter 13-23 of the Cypress Municipal Code and specified in Regulatory Compliance Measure HYD-3. Consistent with the Orange County MS4 Permit, the proposed project would implement Source Control and LID BMPs, including biotreatment BMPs (either detention basins and/or proprietary flow-based biofiltration systems, depending on the design considerations of the final buildout condition), to capture and treat stormwater runoff before discharging stormwater to the surrounding storm drain system. The proposed BMPs would target and reduce pollutants of concern from runoff from the Buildout Area in compliance with the Orange County MS4 Permit requirements, Orange County DAMP, and City of Cypress LIP. Overall, compliance with the above requirements, including incorporation of construction and operational BMPs to target pollutants of concern, would ensure that water quality impacts, degradation of water quality, increased pollutant discharge, and alteration of receiving water quality during project construction and operation would be less than significant. 1 SWRCB. 2022. National Pollutant Discharge Elimination System (NPDES) General Permit for Storm Water Discharges Associated with Construction and Land Disturbance Activities (General Permit), Order WQ 2022-0057-DWQ, NPDES No. CAS000002. Adopted September 8. 2 Santa Ana RWQCB. 2020. 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. June 19. 3 Santa Ana RWQCB. 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.
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6 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\6.0 Other CEQA Considerations.docx (03/12/26) -4 As described in Section 4.1, Aesthetics, development facilitated by the proposed project would be consistent with the approved Specific Plan and would not result in any impacts to aesthetic resources. In addition, the Buildout Area is in an urban area with surrounding and existing development. Therefore, the proposed project would not result in any impacts related to scenic quality.
Public services providers within the jurisdiction of the Buildout Area include the Orange County Fire Authority (OCFA), the Cypress Police Department (CPD), the City of Cypress Recreation and Community Services Department, the Orange County Public Library (OCPL), the Cypress School District (CSD), the Los Alamitos Unified School District (LAUSD), and the Anaheim Union High School District (AUHSD). As discussed in Section 4.15, Public Services, future development facilitated by the proposed project would not result in any substantial adverse physical impacts associated with the provision of public services. All indirect and direct population, housing, and employment growth associated with the proposed project would be consistent with SCAG growth projections for the City and region. In addition, future development facilitated by the proposed project would be required to pay fire, school, and park development fees to ensure adequate provision of public services under buildout conditions. Therefore, the proposed project would not result in any adverse impacts related to the provision of public services.
As discussed in Section 4.5, Cultural Resources, the grandstand, 1954 quarter-mile chute, and pre1970 track are considered character-defining features of the LARC Property and collectively constitute a “historic resource” for the purposes of CEQA. Implementation of the proposed project and development of the land uses allowed by the Specific Plan within the Buildout Area would require the demolition and removal of all or a substantial portion of the existing improvements associated with the LARC Property, including the historic elements described above, as well as the post-1970 extension of the race track non-historic buildings, barns and structures and three artificial lakes. Based on State CEQA Guidelines Section 15064.5(b), the proposed project would have a significant impact on historical resources if it would cause a substantial adverse change in the significance of a historical resource. Demolition is considered a material impairment of the historical resource and, other than avoiding demolition, no feasible mitigation measures are available to fully mitigate the demolition of the historical resource to a less than significant level. Implementation of Mitigation Measures CUL-1 through CUL-3, which requires documentation of the historic resource in accordance with the Historic American Building Survey (HABS) standards, would reduce the impacts on the historical resource but would not reduce it to a level of insignificance. Because implementation of the proposed project would demolish the identified historical resource, implementation of the proposed project would result in a substantial adverse change to a historic resource under CEQA. Therefore, the impact on built-environment historic resources as defined in State CEQA Guidelines Section 15064.5 would be significant and unavoidable.
Implementation of the proposed project would result in less than significant impacts related to biological resources, population and housing, hazards and hazardous materials (including health and safety impacts), water quality, aesthetics, and public services with adherence to applicable regulatory requirements and implementation of identified mitigation measures.
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6.2 ENERGY IMPACTS
According to Section 15126.2(b) of the State CEQA Guidelines, “[i]f analysis of the project’s energy use reveals that the project may result in significant environmental effects due to wasteful, inefficient, or unnecessary consumption use of energy, or wasteful use of energy resources, the EIR shall mitigate that energy use.”
As described in Section 4.3, Energy, the proposed project would result in less than significant impacts related to energy use.
Construction associated with the Buildout Area pursuant to the Specific Plan is estimated to consume approximately 5,892,834.6 gallons of gasoline and approximately 2,352,156.6 gallons of diesel fuel. When averaged over the 12-year construction schedule, the proposed project is estimated to consume approximately 491,069.5 gallons of gasoline per year and 196,013.0 gallons of diesel fuel per year during construction. When compared to gasoline and diesel consumption in Orange County, construction associated with buildout of the proposed project is estimated to increase the annual fuel consumption from vehicle trips in Orange County by approximately 0.6 percent for gasoline fuel usage and approximately 1.4 percent for diesel fuel usage. Due to the minimal increase in annual fuel consumption in Orange County, project construction activities would have a negligible effect on local and regional energy supplies.
Furthermore, no unusual project characteristics would necessitate the use of construction equipment that would be less energy efficient than at comparable construction sites in the region or the State. In addition, construction activities are not anticipated to result in inefficient use of energy as gasoline and diesel fuel would be supplied by construction contractors who would conserve the use of their supplies to minimize their costs on the project. The proposed project would also utilize construction equipment that meets Tier 2 emissions standards or higher, which would ensure fuel efficiency. For these reasons, the proposed project would not cause wasteful, inefficient, or unnecessary consumption of energy resources during construction, and impacts would be less than significant.
Operational activities associated with the buildout of the proposed project would result in energy demand associated with natural gas use, electricity consumption, and fuel used for vehicle trips.
Operation of the proposed project is estimated to negligibly increase the annual natural gas consumption in Orange County by approximately 0.03 percent. Further, operation of the proposed project is estimated to negligibly increase the annual electricity consumption in Orange County by
0.06 percent. Electrical and natural gas demand associated with project operations would not be considered inefficient, wasteful, or unnecessary. Furthermore, the proposed project would be constructed using energy-efficient modern building materials and construction practices, and would use new modern appliances and equipment, in accordance with the Appliance Efficiency Regulations (Title 20, CCR Sections 1601 through 1608). Future development would also be designed to meet sustainability goals, including the CALGreen Code and Title 24 energy efficiency requirements.
CALGreen Code and Title 24 building energy efficiency standards establish minimum efficiency standards related to various building features, including appliances, water and space heating and cooling equipment, building insulation and roofing, and lighting, which would reduce energy usage.
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6 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\6.0 Other CEQA Considerations.docx (03/12/26) -6 As described in Section 4.6, Greenhouse Gas Emissions, Mitigation Measure GHG-1 requires that individual development projects in the Buildout Area either be all-electric or incorporate additional emission reduction measures if all-electric development is not feasible, which would further reduce energy usage. Although energy consumption is largely a function of personal choice and the physical structure and layout of buildings, the expected energy consumption during operation of the proposed project would be consistent with typical usage rates for residential and nonresidential uses. As such, electrical and natural gas demand associated with project operations would not be considered inefficient, wasteful, or unnecessary in comparison to other similar developments in the region.
Vehicle trips associated with the proposed project are estimated to increase the annual fuel use in Orange County by approximately 0.03 percent for gasoline fuel usage and approximately 0.02 percent for diesel fuel usage. In addition, as discussed further in Section 4.17, Transportation, future development under the proposed project would be required to implement Mitigation Measure TRA-1, which requires the implementation of feasible TDM strategies to mitigate the proposed project’s VMT impact. The TDM strategies include constructing or improving bicycle facilities that would connect the proposed project to the existing regional bicycle network and improving the pedestrian network, including the construction of off-site sidewalks to improve sidewalk coverage and pedestrian access to the surrounding area. As such, implementation of Mitigation Measure TRA-1 would help to reduce project-generated vehicle trips and VMT and encourage travel by other modes. Therefore, fuel consumption associated with vehicle trips generated by project operations would not be considered inefficient, wasteful, or unnecessary in comparison to other similar developments in the region.
As demonstrated above, because the proposed project would not result in the wasteful, inefficient, or unnecessary consumption of energy, potential impacts related to conflict with or obstruction of a State or local plan for renewable energy or energy efficiency would also be less than significant.
Therefore, impacts to energy would be less than significant, and no mitigation is required.
6.3 SUMMARY OF SIGNIFICANT UNAVOIDABLE IMPACTS
The Executive Summary of this document (Chapter 1.0) contains a detailed summary that identifies the proposed project’s environmental impacts as compared to existing conditions, recommended feasible mitigation measures, and the level of significance of impacts after mitigation. The following is a summary of impacts considered significant, adverse, and unavoidable with all feasible mitigation. These impacts are also described in detail in Chapter 4.0, Existing Environmental Setting, Environmental Analysis, Impacts, and Mitigation Measures.
6.3.1 Air Quality
6.3.1.1 Operational Air Quality Emissions
As discussed in Section 4.3, Air Quality, operation of the proposed project would result in VOC emissions that would exceed the SCAQMD’s significance criteria even with implementation of Mitigation Measure AIR-1 and Mitigation Measure TRA-1. 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
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6.3.1.2 Conflict with Applicable Air Quality Plans
As discussed in Section 4.3, Air Quality, the proposed project would not exceed the growth assumptions in the SCAG’s 2024–2050 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) (Connect SoCal 2024) or the 2022 AQMP; however, the proposed project would have the potential to conflict or obstruct implementation of applicable air quality plans as the 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. Overall, even with implementation of Mitigation Measure AIR-1 and Mitigation Measure TRA-1, the proposed project would result in a significant and unavoidable impact associated with conflict with applicable air quality management plans.
6.3.2 Cultural Resources
6.3.2.1 Historical Resources
As discussed in Section 4.5, Cultural Resources, the grandstand, 1954 quarter-mile chute, and pre1970 track are considered character-defining features of the LARC Property and collectively constitute a “historical resource” for the purposes of CEQA. Implementation of the proposed project and development of the land uses allowed by the Specific Plan within the Buildout Area would require the demolition and removal of all or a substantial portion of the existing improvements associated with the LARC Property, including the historic elements described above, as well as the post-1970 extension of the race track, non-historic buildings, barns and structures and two artificial lakes. Based on State CEQA Guidelines Section 15064.5(b), the proposed project would have a significant impact on historical resources if it would cause a substantial adverse change in the significance of a historical resource. Demolition is considered a material impairment of the historical resource and no feasible mitigation measures are available to mitigate the demolition of the historical resource to a less than significant level. Implementation of Mitigation Measures CUL-1 through CUL-3, which require documentation of the historic resource in accordance with the Historic American Building Survey (HABS) standards, would reduce the impact on the historical resource, but would not reduce it to a less than significant level.
Because implementation of the proposed project would result in the demolition of the identified historic resource, implementation of the proposed project would result in a substantial adverse change to a historic architectural resource under CEQA. Therefore, the impacts on the historic resource (as defined in State CEQA Guidelines Section 15064.5) would be significant and unavoidable..
S PECIFIC PLAN 3.0 B UILDOUT P ROJECT
CYPRESS , C ALIFORNIA
DRAFT ENVIRONMENTAL I MPACT REPORT
MARCH 2026
6 P:\A-E\CCP2201.05 LARC EIR\PRODUCTS\3_Public Draft EIR 2\6.0 Other CEQA Considerations.docx (03/12/26) -8
6.3.3 Transportation
6.3.3.1 Vehicle Miles Traveled (VMT)
As discussed in Section 4.17, Transportation, the Home-Based VMT per Capita for the proposed project would be higher than the County's residential VMT significance thresholds under both existing and cumulative plus project conditions, resulting in a Home-Based VMT per Capita that would exceed the significance threshold by 11.6 percent. Implementation of Mitigation Measure TRA-1 would require the proposed project to implement TDM measures to reduce overall VMT in order to contribute to achieving the overall VMT reduction target of 11.6 percent. However, even with implementation of Mitigation Measure TRA-1, the proposed project's residential VMT impact would remain above the established thresholds and the impact would be significant and unavoidable.
6.4 SIGNIFICANT IRREVERSIBLE ENVIRONMENTAL CHANGES
Section 15126.2 (d) of the State CEQA Guidelines requires that an EIR consider and discuss significant irreversible changes that would be caused by implementation of the proposed project.
Specifically, Section 15126.2 (d) states:
“Uses of nonrenewable resources during the initial and continued phases of the project may be irreversible since a large commitment of such resources makes removal or nonuse thereafter unlikely. Primary impacts and, particularly, secondary impacts (such as highway improvement which provides access to a previously inaccessible area) generally commit future generations to similar uses. Also irreversible damage can result from environmental accidents associated with the project. Irretrievable commitments of resources should be evaluated to assure that such current consumption is justified.”
Generally, a project would result in significant irreversible environmental changes if the proposed consumption of resources is not justified, if the project would involve a large commitment of nonrenewable resources, or if the project would involve uses in which irreversible damage could result from any potential environmental accidents associated with the project.